Information & Ethics committee  There were three recent cases I actually referred to the RCMP. After opening an investigation, I determined that I had reasonable grounds on which to say there was an offence under the act, so I referred it to the Royal Canadian Mounted Police. Something I should point out is that once I refer something to the Royal Canadian Mounted Police, I must suspend further looking at that until it is dealt with by that body.

Information & Ethics committee  There is a protocol. If I have reason to believe that an investigation is necessary to ensure compliance with the act or the code, for example, because the activities that have occurred, that have been brought to my attention, are sufficient. But if during that investigation I actually determine that there are reasonable grounds, then I will refer it to the peace officer right away and I must stop.

Information & Ethics committee  With the act coming up for review, I've been looking at it. I recently issued the guidance on rule 8. I think for this year it's more looking at the actual existing code and seeing whether we should be providing guidance on some of the other rules. With the act coming up for review, that could be one of the things that actually gets touched during the review.

Information & Ethics committee  I must admit that was before my time, but if you're interested, I can get back to the committee on that one. Do you know?

Information & Ethics committee  Well, the guidance was looking at conflict of interest in terms of placing a public office holder in a conflict of interest. Rule 8 hasn't changed. The guidance is just that, it's guidance, and it's consistent with what the court instructed I must look at, in terms of it no longer being simply a “real” conflict of interest, but actually a reasonable apprehension of it.

Information & Ethics committee  I don't....

Information & Ethics committee  It would probably make things easier in some respects. In terms of the different legislation, when I look at the office of Mary Dawson, the Conflict of Interest and Ethics Commissioner, there is some overlap between our two definitions, but our acts are targeted at sort of different individuals, in terms of communicating.

Information & Ethics committee  The first thing I would do is to decide whether to open what we call the administrative review, which is a fact-finding exercise to gather information. It conducts searches of publicly available sources and does interviews. I am then presented with a comprehensive report that allows me to make decisions, such as whether I have reasonable grounds on which to believe that a breach of the act has occurred and to refer the matter to a peace officer, to the Royal Canadian Mounted Police, or whether I have enough information to determine that an investigation is necessary to ensure compliance with either the act or the code.

Information & Ethics committee  Generally speaking, I do not have an example of a case where a lobbyist arranged a meeting with someone, but the act is clear: it is incumbent upon the lobbyist to comply with the act. If you know of any examples, please tell me, because I take allegations....

Information & Ethics committee  That's (c).

Information & Ethics committee  It's (a), (b), and (c).

Information & Ethics committee  The act itself provides for a number of exemptions in terms of any oral or written submissions made to the committee, or the Senate--so appearances such as this--and any oral--

Information & Ethics committee  It's any oral or written communication made by an individual or person or organization with respect to the enforcement or interpretation of the act. So, for example, someone who's even calling my office to get clarifications on the Lobbying Act or some of its interpretations is communicating with a public office holder, but they're doing so with something that's actually existing.

Information & Ethics committee  The onus is on the lobbyists to ensure they comply with both the Lobbying Act and the lobbyists' code of conduct. The only requirement for designated public office holders is that if I were to request that they verify a communication entry then they must respond to me.

Information & Ethics committee  Not under the Lobbying Act.