I call this meeting to order. Good morning, everyone.
Welcome to meeting No. 59 of the House of Commons Standing Committee on Access to Information, Privacy and Ethics.
Today’s meeting is taking place in a hybrid format, pursuant to the House Order of June 23, 2022, and therefore, members can attend in person in the room and remotely using the Zoom application.
Should any technical challenges arise, please advise me. Please note that we may have to suspend for a few minutes, as we need to ensure that all members are able to participate fully.
Pursuant to Standing Order 108(3)(h) and the motion adopted by the committee on Wednesday, November 30, 2022, the committee is resuming its study of the third edition of the Lobbyists' Code of Conduct.
In accordance with the committee's routine motion concerning connection tests for witnesses, I am informing the committee that all witnesses appearing virtually have completed the required connection test in advance of this meeting.
I would now like to welcome our witnesses today. From the Government Relations Institute of Canada, we have Megan Buttle, who is the president. Welcome, Ms. Buttle.
From Lobbyisme Québec, we have Jean-François Routhier, Commissioner of Lobbying.
From the National Aboriginal Capital Corporations Association, we have Shannin Metatawabin, chief executive officer. From the Public Affairs Association of Canada, we have Mr. Kyle Larkin, who is the treasurer. He is attending in person.
We're going to start with our opening comments.
Ms. Buttle, you have up to five minutes for your opening statement to the committee. Please go ahead.
That's great. Thank you, Mr. Chair.
Good morning, Mr. Chair and members of the committee.
Thank you for inviting the Government Relations Institute of Canada, or GRIC, to discuss the draft third edition of the Lobbyists' Code of Conduct.
Let me begin by introducing GRIC and our mandate. GRIC is a national not-for-profit organization that represents both in-house and consultant professionals from across the country. Our members advocate on behalf of charities, non-profits, national and provincial member-based associations, unions and the industry writ large.
We are, of course, acutely interested in the draft third edition of the Lobbyists' Code of Conduct.
GRIC has been an active and constructive stakeholder in the multi-stage consultation initiated by the Commissioner of Lobbying on her proposed changes to the code. Although we acknowledge that there have been several improvements from previous drafts, there remain two areas of critical concern for our members.
The first relates to rule 4 and the suggested updates under “hospitality”. The proposed annual limit of $80 poses a significant challenge for our members, particularly with regard to the logistical and administrative challenges involved in tracking the combined value of hospitality to a specific individual over the course of a calendar year.
While we appreciate the commissioner's testimony, wherein it was suggested that doing so involved simply dividing the total budget by the number of those expected to attend a particular event, in our view that's an oversimplification of what has been proposed.
To meet the proposed annual hospitality limit of $80 per official by tracking MPs, senators and other public office holders who have previously attended receptions and received hospitality would be nearly impossible and would impose an undue burden on some members.
As all of you know, receptions or meetings and briefings are, for many, based well outside of Ottawa. They provide a chance to meet with several decision-makers at once rather than hosting individual one-on-one meetings. Presently, the code functions well under the requirement that lobbyists should be limited to providing reasonable hospitality.
As this committee is already aware, public office holders are already subject to the Conflict of Interest Act, which requires them to disclose gifts totalling more than $200 in value over a 12-month period. In addition, both the Lobbying Act and the Conflict of Interest Act prohibit gifts of any value that could reasonably be seen to have been offered to influence the public office holder or to create a sense of obligation.
The second concern for our members, and one that the committee has already heard a great deal about, relates to rule 9 and the limits on political activities, which our members see as a direct violation of section 2 and section 3 of the Charter of Rights and Freedoms.
GRIC believes that if limitations must be imposed, doing so should be done through thorough debate in Parliament, not through a non-statutory instrument such as the Lobbyists' Code of Conduct. Our members strongly oppose this section and believe it's a dramatic overreach.
More practically, while we accept that a cooling-off period may be necessary for those within senior, high-profile and strategic roles, unpaid volunteers who support campaigns in lower and less prominent roles should not be subject to cooling-off periods that would potentially impact their livelihood.
By their very nature, lobbyists or those who may be lobbyists in the future are engaged in the political process and often want to take part in the election of their representatives. All of you rely on volunteers to help you during your campaigns, campaigns that neither you nor the volunteers know whether or not you will win, let alone whether you will be elected to government, become a parliamentary secretary or have the honour of being named to cabinet.
Our fear is that this measure will severely limit volunteer engagement and create an additional regulation in an area where no identified systemic problem or issue has been presented to date.
To close, as the Commissioner of Lobbying herself stated, Canada has one of the world's strongest set of lobbying rules. They are balanced, reasonable and transparent. However, we are concerned that the overly prescriptive nature that the commissioner is proposing in certain areas may add complexity and confusion and may limit the ability of ethical and professional lobbyists to engage and inform elected officials on important public policy issues.
We urge the committee to consider our feedback, and we ask that the commissioner consider revising these two sections of her recommendations to continue forward.
I'd be pleased to answer any questions as they relate to our concerns with, and positions on, these proposed lobbying changes.
Members of the committee, thank you for inviting me to share the views of Lobbyisme Québec on the oversight of lobbying activities, and more specifically on the ethical rules that apply to the practice of lobbying. I humbly hope that by sharing our expertise and our research into lobbying best practices I will be able to contribute to your study.
In Quebec, the Lobbying Transparency and Ethics Act was enacted by the National Assembly in 2002. It applies to lobbying of parliamentary, government and municipal public office holders; this makes it a unique scheme with the broadest scope in Canada. The first commissioner then adopted the Code of Conduct for Lobbyists, in 2004. The code derives from the civil law and provides the general rules of ethics and conduct with which lobbyists must comply in their practice.
My presentation today is part of the well established culture of collaboration among Canadian officials responsible for regulating lobbying. That is also the spirit in which Lobbyisme Québec participated in the consultation conducted by the federal commissioner concerning the code of conduct she is proposing.
Lobbyisme Québec is very active, and has been very active in recent years, in researching and implementing best practices in lobbying oversight. In 2019, Lobbyisme Québec tabled a report in the National Assembly that proposed a reform of the Quebec legislation based on principles inspired by national and international best practices. In fact, the report attracted interest from the Organization for Economic Cooperation and Development, which in turn published a complete study of the Quebec lobbying oversight scheme in March 2022 and made recommendations for incorporating international best practices into that scheme.
On the subject of the rules of ethics and conduct in Canada and Quebec and elsewhere in the world, the legislation that provides for oversight of lobbying generally recognizes the legitimacy of lobbying when it is conducted transparently and in a sound and ethical manner. Those schemes are sometimes supplemented by ethics and conduct guidelines, as is the case in Quebec and in the federal government.
In our view, transparency and ethics are responsibilities that are shared between the persons who perform or benefit from lobbying activities and public institutions or office holders. It is therefore important to strike the right balance in apportioning those responsibilities. From that perspective, the laws and codes that govern lobbying should not, in our opinion, be used to make up for flaws in other transparency, ethics or integrity schemes, including those that apply to public office holders.
In addition, we believe that the laws that govern lobbying activities have for too long focused on the individuals who perform those activities rather than on the companies, consulting firms or clients by or for whom those activities are performed. We think that the apportionment of responsibilities is still incomplete.
Even though the federal and Quebec schemes are intended to ensure transparency in a large proportion of influence communications and have a number of factors in common, they unfortunately also share flaws that limit the scope of that transparency. The most notable example is the concept of "significant part", by virtue of which a firm's lobbying activities need not be disclosed until the point when the time spent on the conduct of those activities makes up a significant part of the job or function of the individual who performs them.
The federal and Quebec schemes also differ on certain points, in particular as regards the two cases reported by the federal commissioner and raised by her when she appeared before the committee: political participation and hospitality. The treatment of those matters differs significantly between our two jurisdictions.
However, we understand very well the federal commissioner's concerns, in that, absent a statutory revision, and considering her own situation, she chose to propose amendments to her code of conduct. The purpose of those amendments is to enable her to clarify the objectives of transparency and ethics enshrined in her act and put those objectives into practice better.
Thank you for your attention and I am entirely at your disposal to answer your questions to the best of my abilities.
Good morning, everybody.
[Witness spoke in Cree]
My name is Shannin Metatawabin. I am the CEO for the National Aboriginal Capital Corporations Association, or NACCA, and I am a member of the Peetabeck First Nation of the Mushkegowuk tribal territory.
Thank you for the invitation to testify as part of your committee's study on the third edition of the Lobbyists' Code of Conduct.
Before I begin, I would like to acknowledge that this meeting is hosted on the unceded territory of the Algonquin people.
NACCA represents a national network of 58 indigenous-led lending institutions. Our members make business loans to first nations, Métis and Inuit entrepreneurs. We advocate for our member institutions and on behalf of indigenous business development in general.
As far as I know, I'm the sole indigenous representative invited to speak on the revised code of conduct. This is unsurprising, in a way. Though a number are growing, only a handful of indigenous organizations can be found on the registry of lobbyists. Indeed, indigenous advocacy is in some ways unique, following from the special relationships our people have with the Crown. Paragraph 4(d) of the Lobbying Act exempts members of first nation band councils or self-governing indigenous governments. Many national and regional indigenous organizations might argue that they too are exempt.
For our part, NACCA made the decision to join the registry in 2018 at the urging of our government relations consultant, Isabel Metcalfe. Our registration ensured that the advocacy work would be transparent and guided by the same standards that apply to all organizations.
I will save my few comments on the revised code for the end, using most of my time to explain why we embraced the lobbyist registry and to highlight some of the benefits it has brought to NACCA.
First, we are not rights holders and an entity exempted from the act. Rather, we are a national indigenous organization that operates in a competitive business environment. Ensuring we have a clear record of interactions with public office holders is simply good business practice. The principles set out in the code—ones like integrity, honesty, openness and professionalism—are also front and centre of our own organizational values.
Second, NACCA is, without question, an advocacy organization. We do manage programs. Our indigenous women's entrepreneurship program, for example, offers microloans and business training to indigenous women. However, at our founding in 1997—we just celebrated 25 years—advocacy was our original reason for being, and it remains our focus now. Our cause is the full participation of indigenous people in Canada's economy, and it still cries out for public attention.
Due to barriers not of their own making, aspiring indigenous business owners still lack capital and support to participate in the Canadian economy. We have every reason to remind federal office holders of this. We take pride in the registry's list of meetings, which provides a record of our effort to do so.
Now I'll speak to some of the benefits we have realized since 2018.
The first is that the record itself is freely available to our members, other business organizations and public office holders. Second, our upholding of the code of conduct has helped increase faith in us as a credible, trustworthy organization. Our presence on the registry sends a clear signal. We belong to a growing, new generation of indigenous business leaders who are confident to play by the same rules as other business organizations.
Finally, and most importantly, being a registered organization has opened doors for NACCA at the highest levels. We are a known quantity and have gained access to dialogue and decision-making tables that we could not have dreamed of before.
Your committee invited me here to comment on the proposed draft code of conduct for lobbyists. On this, I would make only three points.
First, the new code puts forward what appears to be reasonable and well-grounded amendments.
Second, some have questioned the hospitality limits as too strict. For our part, we appreciate clear, modest spending limits. They help level the playing field for organizations like ours, which do not have deep pockets.
I would like to compare it to the treaty-making process. My treaty was assigned four-dollar treaty payments that have remained in place for more than a hundred years. It's not reasonable to assume that the value of money maintains the same level of spending. Doing this in legislation is probably a bad idea.
My third and final suggestion would be to canvass the views of other registered indigenous organizations. Our own perspective is shaped by our work as a national advocate for indigenous business development. Other indigenous organizations could well have a different take, and are coming on board in increasing numbers.
To close, I thank you for the invitation to attend this meeting. I welcome any questions you may have.
Good morning, everyone. Thanks for braving the snow this morning to be here in person.
My name is Kyle Larkin.
Thank you, Chair, and thank you to the members of the committee for inviting us to testify today.
I'm the treasurer of the Public Affairs Association of Canada, also known as PAAC. As you may know, PAAC is a national not-for-profit organization that represents hundreds of public affairs professionals across the country. Our members come from both the private and the public sectors, in areas such as industrial and financial companies, Crown corporations, consulting firms, small businesses, ministries and municipalities, PR organizations, trade associations, educational institutions, and law and accounting firms.
I'm pleased to be here today with my colleague Megan, from the Government Relations Institute of Canada, whom we have worked closely with in engaging on this consultation for the renewed Lobbyists' Code of Conduct.
I would like to begin my remarks today by stating that while some of the changes to the Lobbyists' Code of Conduct are welcome, others are truly a solution in search of a problem.
As you've already heard from other witnesses, the commissioner has proposed an annual limit of $80 for hospitality, which includes parliamentary receptions.
As you know, receptions in Ottawa and events across Canada are a unique opportunity for elected officials to meet with Canadians who are working in a variety of different industries. Lobbyists have the pleasure of working with these individuals on a regular basis. Craig from Barrie, Sue from Hamilton and Christina from Vancouver have all attended parliamentary receptions hosted by associations over the past year. None of them or the thousands of other business leaders who visit Parliament annually are registered lobbyists.
The current rules already disallow lobbying at receptions. Receptions are instead a unique opportunity for an association, charity or industry to raise its awareness among parliamentarians. There are tens of thousands of associations, charities and companies in Canada, and for some, the only way to connect with elected officials is through a reception or event. These events also allow parliamentarians to meet Canadians from across the country who are on the ground and building businesses, creating economic development and supporting their own communities.
To ensure that these important democratic functions are able to continue, we are proposing that the term “reasonable” continue to be applied to receptions, as is the case in the current code of conduct.
The second area that PAAC finds issue with in the proposed Lobbyists' Code of Conduct relates to the new section on political work.
As you have also heard from other witnesses, the new cooling-off period limitations pose challenges for the democratic participation that is allowed for all Canadians, no matter their profession. PAAC does believe that a cooling-off period should continue to apply to those who hold senior roles on campaigns, as this could potentially create a sense of obligation for public office holders. However, to hold this same standard for door knocking, canvassing, distributing campaign literature and other minor campaign activities infringes on Canadians' ability to participate in our democracy.
Furthermore, there are no examples of non-compliance as it relates to political activities that we know about. Lobbyists, many of whom have worked on Parliament Hill, are naturally passionate about Canadian politics. Many have also been involved in campaigns one way or another since a young age and continue to participate due to their belief in specific candidates or a passion for a certain political party. In no way are lobbyists participating in elections to create favour, and if they did create a sense of obligation, they would already be precluded from lobbying that individual.
Last, as you all know, volunteers are the backbone of local political campaigns. As lobbyists are naturally risk-averse and have a strong history of complying with the act and the code of conduct, many would cease to involve themselves during elections. While this might not have a tremendous impact on campaigns, it does create a system that excludes certain professionals from participating in our democracy.
Finally, I would like to thank all of you for taking the time to study the renewed Lobbyists' Code of Conduct. It's important that we get this right in order to ensure that transparency and accountability among lobbyists continues, while also mitigating unintended consequences on important democratic functions.
Thank you again. I'd be happy to take any questions you may have.
Thank you very much, Mr. Chair, and thank you to all of our witnesses for joining in the conversation here today.
Just to start, off the top, I think everyone around this table agrees on the need for a robust regime to ensure that there's accountability, so that ultimately Canadians can trust the system, both in lobbying and the way that lobbying happens as well as in federal decision-making.
I have just a few questions for some of the witnesses. I hope to get through to everybody. If not, maybe I'll have a round later in our meeting.
Ms. Buttle from the Government Relations Institute of Canada, you mentioned that there were some things that were improved in the updated code. Would you mind referencing a few of the improvements?
We've heard a fair amount about the challenges related to hospitality and the cooling-off period. I'm just wondering if you could highlight some of the things that you see as improvements.
Sure. Thank you. That was a good point.
There were many things that we saw improved. One that the membership really appreciated was the update to the preamble. There was an acknowledgement of transparent ethical lobbying and that it is a legitimate part of the public policy process to help inform federal public officials. We found that this part was really critical to involve and update.
We also found that the move from the four-year threshold within the political work to the cooling-off period of two years for senior and highly and strategically valued participants and volunteers in campaigns makes a lot more sense, particularly given the minority government situation.
Originally the four-year threshold was tied to fixed election dates. In today's situation, we all know that a fixed election date is often not the cycle we're operating in. We thought that reducing the cooling-off period to two years was more attuned to the actual situation with elections and what that rule was supposed to address.
However, we still have concerns around political work generally being added in through a non-statutory instrument like this.
Thank you to all the witnesses today. I know you're coming here very much with the desire to ensure that we have a transparent and good code, so I appreciate that.
My first question is for Mr. Metatawabin. I had a campaign volunteer who is indigenous. She's the daughter of a sixties scoop member, so she didn't have a lot of opportunity growing up to learn her culture.
She volunteered on my campaign and brought a lot of wisdom to the campaign. We had a blanket ceremony. Not just me, but other members of my team learned tremendously from her. Then, after the election, she had always wanted to return to her tribe where she had never lived, actually, and one of the only ways to do that was through being a government relations person. There was one spot. Somebody had had it for 25 years. It comes open very rarely. She was offered that and she did take that position so that she could learn her roots.
Under the way that this new code is proposed, would she have had to turn down that lifetime opportunity?
This is for Mr. Metatawabin.
I think that's exactly it.
I would also say that current lobbyists, or those looking to get into the lobbying sector, are naturally risk-averse and certainly wouldn't want to get into any situation in which they would be breaking the law or breaking the code of conduct. I totally agree with you that it would prevent most, if not all, from getting involved in the political process through canvassing, door knocking, dropping off literature or even in senior roles.
As I said before and as you know, lobbyists and public affairs professionals are some of the most passionate in politics. They've been involved in politics since a young age. They might have worked on Parliament Hill or in provincial legislatures. This would have a major impact on some of those most passionate volunteers that we see across Canada.
There is no definition in the Lobbying Transparency and Ethics Act. The Quebec act defines a lobbying activity as a communication by an individual on behalf of their enterprise, their organization, or a client, with the intention of influencing a decision by a public office holder.
Definitions may vary from case to case and law to law. They may talk about contracts or about influencing legislation, regulations, permits or grants. As I said initially, lobbying schemes that I would characterize as "modern" also provide rules of ethics and conduct that mean that lobbyists—the people who perform lobbying activities—must adhere to certain fundamental ethical principles.
I don't know whether you have looked at Quebec's Code of Conduct for Lobbyists, but some of the rules in that code are very similar to the rules in the federal Lobbyists' Code of Conduct. It talks about generally applicable rules of ethics, such as the prohibition against giving false or fraudulent information, the obligation to say who their real client is, or the fact that they must not try to unduly influence a public office holder.
In the case of Quebec, the most important rule in respect of ethics and integrity is not to try to persuade a public office holder to violate the rules of conduct applicable to that person themself.
For my questions, I'll begin with Mr. Metatawabin.
First of all, thank you for being here, sir. Your introductory remarks spoke to the integrity of your organization, and they are well represented with you here today.
I did have some questions because I want to make sure that we have the cultural competencies within these particular amendments that may best serve your communities, your nations.
I'm wondering if you've given contemplation to whether the rules regarding gifts or hospitalities place any inequitable limitations on your organizations, such as in offering a gift to an elder, a knowledge keeper or a community member, or providing food that is specific to a particular indigenous first nation, Métis or Inuit community that may surpass the low-value threshold during a meeting, event or reception?
Thank you for that question.
I kind of compare this to the treaty-making process more than 100 years ago. They designated $4 in that treaty. That was supposed to cover a big bag of flour, a big bag of sugar and other things that people needed on the lands. If you compare that to what it's valued at today, it would be an amount that would cover all those staples.
I appreciate Mr. Green's question, because you never know what the activity is going to be or what part of the country it's going to be in. Look at the cost of food. If you're having an event in northern Ontario or even in Nunavut, the cost of food is approaching $20 for milk. How is that going to fit into your standard for the value of a meal for having an event?
I think that it's more reasonable to say that there's a value of a meal and this is approximately what it is. It says “reasonable” right now, and that makes a lot of sense, and everybody can be left to justify that the meal covers the value of that event.
I would much prefer to be able to offer a gift of moccasins or something to a dignitary who's coming to our area, and the value of those have gone up exponentially because they are hard to come by.
I think we need to maintain some sort of reasonableness and common sense when we're thinking about this. Indigenous people don't generally put their names in the lobbyist registry, but there are going to be more like me who will be lobbying because it's essentially a funnel. More are trying to fit into a smaller area and get those meetings with certain individuals.
I just want to make sure that it's covered off in the study in a very specific way, because you've brought up some very important points around the history of rights holders and what the appreciated value would be in those agreements in terms of treaties.
Would it be reasonable then, sir, to conclude that when offering a gift to an elder, a knowledge keeper or a rights holder, it may be reasonable, or in fact legal, to consider those folks, as rights holders, to be outside of the framework of this particular legislation?
Would you seek to have some sort of exemption for those particular cultural exchanges, which are nation-to-nation and outside of a lobbyist-type scenario? Would that be helpful, sir?
For clarity, sir, because my time is ticking away, you're the representative of those organizations. Let's say, for instance, that you host an event that includes government officials. Your member organizations and dignitaries are from rights-holding nations. It's that grey area where you're not there representing a nation per se, but you're facilitating the event.
It doesn't have to be on the spot now, but for the benefit of this, I'm just wondering if you could provide any scenarios you might encounter in the course of your work. In many ways—if you look at the Two Row Wampum in the Haudenosaunee territories where I'm from, having gone to bread and cheese events there—you're travelling through two worlds in your work.
I just want to make sure that you have the opportunity to see that reflected, as a representative of your organization. Perhaps maybe in further contemplation and in written submission you can provide clarity to this committee around that, if you deem it important. I do think precision is important.
Given the integrity that you've provided in your introductory remarks, I wouldn't want to have amendments to this act that have a cultural gap in the treaty-to-treaty relationships that we have.
Thank you to all the witnesses for sharing their perspectives. It is appreciated.
I want to read into the record some comments that the outgoing ethics commissioner made in a bombshell of an interview. Then I'm going to ask the different witnesses for commentary on how, from their perspective, this impacts the code.
I'm just going to read some of these comments. This is from the interview with ethics commissioner Mario Dion. It says:
The government needs to take ethics “more seriously” and that repeated breaches by senior Liberals during his tenure have undermined public confidence in the government....
“The act has been there for 17 years for God's sake, so maybe the time has come to do something different so that we don't keep repeating the same errors.”...
“These are not new rules. You can't make these mistakes, you make everyone look bad, and you make public trust decline by making these mistakes”...
He said he had 140 presentations during his tenure, and thousands of attendees. He said, “that [this] did not prevent International Trade Minister Mary Ng”—who testified in this committee recently—“from telling a House committee”—that's us—“that it would be helpful if the commissioner's office offered 'additional' ethics training to political staff after no one in her office raised a flag when she [doled] out two [thousand dollars] to a...'close friend'.”
He says—and this isn't very complimentary:
“That's like if I drive in my car this afternoon and I drive through a red light and then [argue] with a (police) officer that it is too bad because I should have received training about red lights. It's a convenient excuse, in my view,” he said....
Quoting recent polls showing the public's confidence in politicians is “not going in the right direction,” Dion said in the interview that the ethics breaches by senior Liberals over his tenure were certainly a factor and that “something has to be done” [so that they] show that they “are taking this seriously.”
He says—and this applies also to the code:
“Public shaming is the foundation of the system.”...
The public is understandably frustrated at what appears to be a lack of accountability from law-breaking MPs.
“No one's resigning, no one's forced to resign and no one is [even] shuffled. And there's no appearance of even any sort of accountability, beyond having to stand in front of that question period and say a quick mea culpa, [my fault]”.
“It's really dissatisfying that these regimes work that way, and the solution has to lie with [a] culture of accountability within parliamentary democracies.”
I'm coming to the end of his comments
A voice: I hope so.
Mr. Marc Dalton: Well, I would understand why the member would hope so. Thank you, Liberal member.
I like to maintain a diverse lobbying effort. I like to update the government officials to make sure that they know what's going on in the indigenous community, in economic development in general and on the reconciliation front.
Right now, the government has a 5% procurement target. They had that 20 years ago, but it got nowhere because there were no consequences for a manager who didn't make a decision to choose an indigenous business as opposed to a business they knew, so no changes ever actually happened.
To Mr. Dalton's question, unless there are consequences and an impact on compensation and jail time...Singapore puts officials in jail if they undertake any breaches. We have to take it seriously when people think they can go above what the rules set. Impacting compensation, I think, would ensure that everybody doesn't breach.
Thank you to our witnesses for being here today.
Through you, Chair, I would like to begin by directing my questions to Mr. Metatawabin.
I have to tell you that I really appreciate that you took the time to participate here today. I found your intervention and your opening statement extremely interesting. It gave us more insight than I think we've heard from some other witnesses today.
I got from you that the lobbying code as it is in Canada actually levels the playing field among lobbyists, and that to change it in the way that has been proposed would not level the playing field. It would actually do the opposite, when, as I understood from the lobbying commissioner, the intent with these amendments was to level the playing field. What I got from you was that it would have the opposite effect.
Can you confirm and reflect on that for me?
I do believe it was fair. Three rounds of consultations in any manner is fair.
I would say that we have made strides in certain areas. The first proposed code of conduct that came in, in the first instance, proposed a $30 limit on hospitality. That also included tax, service fees, labour, the room charge, etc. It simply would have made receptions impossible. We've moved from that to $40, just for covering food and beverage. It's still a challenge. It still would make events nearly impossible, especially if you include any cultural elements, be it kosher food, indigenous food or halal food—no matter what it is. Also, food differences across Canada—a red pepper cost is different in Ottawa from what it is in Nunavut—are also not necessarily accounted for.
The consultation in general was well done. I would say that there is still more room to grow.
That concludes today's meeting.
I want to thank all of the witnesses on behalf of the committee and on behalf of Canadians for being here, and indigenous communities as well. I also want to thank our members, our clerk and our analysts.
We are going to be moving in camera to discuss the drafting instructions.
The public portion of this meeting is adjourned. Thank you.
[Proceedings continue in camera]