Information & Ethics committee  For the two types of in-house lobbyists, the idea was that they were employees of the corporation. We have a situation that could be considered as similar for outside directors of associations or companies like this, because sometimes they're only compensated by their travel or meal costs.

Information & Ethics committee  It is extremely hard to prove. This is a very difficult area to get into, and it's difficult to get to the intention of people or what might happen in the future.

Information & Ethics committee  Well, with respect, it's Parliament that decided this, and it is a feature of many legislative regimes. The way I would look at it, the argument that you're making seems to make more sense for the in-house lobbyist, because when they do the renewal they do a six-month prospectus to say that for the next six months here are the lobbying assignments.

Information & Ethics committee  From time to time we have a tremendous number of renewals come in. That's one possibility. I'm not sure whether it's a month--

Information & Ethics committee  There does have to be payment, but payment doesn't have to be money. If they were convincing the person to volunteer in the expectation of maybe getting a job with the corporation....

Information & Ethics committee  --but let me speak to your question. Last year, with the amendments that came in under the act, there was a new requirement that everyone had to re-register every six months. The first time that happened, which was around December or January, the flood that came in and the questions from people who were re-registering did cause us to get behind in that first six-month period.

Information & Ethics committee  Pierre, do you want to speak to that?

Information & Ethics committee  The lobbyists code of conduct speaks to a potential situation. That's why they have a registrar who looks into the facts of each individual situation. Under the lobbyists code of conduct, which Karen will talk about in a few minutes, one part says that you're not supposed to exercise improper influence.

Information & Ethics committee  So the employer.

Information & Ethics committee  The act is silent on that matter. The act talks about the registration of a lobbyist, not about the lobbyist's previous career. When they stop being a lobbyist, there is nothing to stop them from carrying on a different type of career. There are other conflict of interest codes that the Ethics Commissioner looks after that may talk about some circumstances, but the Lobbyists Registration Act, which is my area of responsibility, doesn't speak to the point that you just raised.

Information & Ethics committee  I'm sorry, the firm...?

Information & Ethics committee  Sure. If they're hiring that person to talk on their behalf to a public office holder about any of these subjects--changing legislation, changing a policy--and they're paying that person, then that person needs to register as a consultant lobbyist. When we go on to the next section--and I'll turn to Pierre to explain--we'll see that there are different types of lobbyists.

Information & Ethics committee  Absolutely. There are three different types. I am going to ask Pierre to explain the types of lobbyists and the registry.

Information & Ethics committee  I will continue, but that's an important thing to clarify. Thank you for that question. The office can't operate unless you've got that independence. Page 7 in the deck concerns the registrar of lobbyists. This is what the registrar does. Essentially, we run a registry. When we get interviewed by the press sometimes, the questions are all about how many investigations and what kind of enforcement we're doing.

Information & Ethics committee  Absolutely.