We couldn't point to one model jurisdiction. I think there are a few where there are good features we could learn from and adapt to the Canadian context.
The U.K., specifically England and Wales, is the first jurisdiction to have adopted a guidance for its prosecutors. It has been helpful. It has not been a full solution to the problem, which is a lesson we should learn from Canada, if we needed more evidence from beyond our own borders about how directives are insufficient in themselves, important though they may be.
We can also look to jurisdictions like California, for example, that has a fairly narrowly crafted offence in its law about when criminal charges may apply. I don't suggest every feature of the California legislation should necessarily be replicated here. I think there's room for improvement. It is an example of a jurisdiction where they have taken a much narrower approach to when the criminal law might be applied. We could look to a few of them in coming up with something that fits in our legal context here.