Information & Ethics committee  If you don't have full transparency, if you leave a loophole open, then it will be exploited by unethical lobbyists. So get the full transparency, close all the loopholes, and then the public will decide and be able to track whether unethical lobbying is happening.

Information & Ethics committee  I'll speak to that.

Information & Ethics committee  The problem with all the provinces that have implemented the law is that they followed the federal model—this has generally been done around the world—wherein the lobbyist is required to disclose lobbying. Then the problems have always been what the definitions are of lobbyist an

Information & Ethics committee  No, because you would still have the loophole open that if you're unpaid you can lobby in secret. That's very dangerous, because cabinet ministers leave, they have a healthy pension, or they get some other job, and then friends call them and they make calls for their friends, and

Information & Ethics committee  Yes.

Information & Ethics committee  I'll just say that if you lobby about the enforcement or administration of a law, regulation, or program, you also don't have to register, and the commissioner has not touched that with her recommendations. You do have to look—in terms of a cooling-off period and these rules—at t

Information & Ethics committee  It's a protest against the loopholes.

Information & Ethics committee  No, it's not. My standard is to require all lobbying to be disclosed by law. If you're not going to do that, then don't expect people to register, and don't expect me to register. I did it as a civil action protest against the loopholes in the law and the continuing ignorance of

Information & Ethics committee  Oh, very much so. But I would say that this rumour—that people are not becoming staff of ministers because of the five-year ban—is a rumour. There's never been a case that anyone has ever come forward and said he or she didn't join the government because of the rule. There's no

Information & Ethics committee  No, I actually de-registered it a decade ago, in protest—

Information & Ethics committee  —of the loopholes. I had been before committee three times. Three times the government had said it was not going to close these loopholes. I'm not required to register. I was the only staff person, I wasn't lobbying more than 20% of my time, and I said before a Senate committee a

Information & Ethics committee  —especially in the first two years as a minister, because of the conflict of interest rules, not the Lobby Act rules, and one year as a senior government official covered by the Conflict of Interest Act. For anybody else, again, you just have to join a corporation and lobby less

Information & Ethics committee  First of all, they're not real clear rules. There's no five-year ban. You can lobby the next day. You just have to be careful—

Information & Ethics committee  Yes, I was going to. Thank you. The penalty should also be there for violations of the code, not just of the act. To remind you again of another reason why these loopholes need to be closed and the enforcement strengthened, in another context about another law, Prime Minister H

Information & Ethics committee  Thank you very much to the committee for this opportunity to appear before you as the chairperson of the Government Ethics Coalition, which is made up of more than 30 citizens groups from across the country, from various sectors of society, with a total membership of three millio