Guidance to mitigate conflicts of interest resulting from political activities
Rule 9 – When a lobbyist undertakes political activities on behalf of a person which could reasonably be seen to create a sense of obligation, they may not lobby that person for a specified period if that person is or becomes a public office holder. If that person is an elected official, the lobbyist shall also not lobby staff in their Office(s).
Political activities and conflict of interest
If you undertake political activities on behalf of a person who is or becomes a public office holder, they can reasonably be perceived to be in a conflict of interest if you lobby them. A public office holder who benefits from political activities may have a sense of obligation towards those who undertook the activities. The risk of creating a sense of obligation increases with the frequency, quantity and strategic importance of the political activities, as well as with the degree of interaction with candidates.
Political activities with a higher risk of creating a sense of obligation
Political activities that are strategic in nature or involve significant interaction with candidates pose a higher risk of creating a sense of obligation on the part of a person benefiting from them who is or becomes a public office holder.
The sense of obligation towards you decreases over time. If you engage in higher-risk political activities then you should not lobby any public office holder who benefited from them, nor their staff, for a period equivalent to a full election cycle.
Examples of higher-risk political activities:
- Serving as a campaign chair or in another strategic role on a campaign team;
- Serving in a named position on behalf of a registered party as set out in the Canada Elections Act;
- Serving as an electoral district association officer within the meaning of the Canada Elections Act, such as chief executive officer, financial agent, appointed auditor, or any other officer;
- Organizing a political fundraising event;
- Gathering or soliciting donations that you then provide to a registered party or electoral district association;
- Working in a war room for a registered party in a strategic role;
- Preparing candidates for debates; or
- Acting as a designated spokesperson for a political candidate, campaign, registered party, electoral district association, or other organization.
Political activities less likely to create a sense of obligation
Political activities that are not strategic in nature and do not involve significant interaction with candidates pose a lower risk or no risk of creating a sense of obligation on the part of a person benefiting from them who is or becomes a public office holder.
Occasional involvement in the lower-risk political activities below does not restrict your lobbying of a public office holder who benefits from them. However, frequent involvement or involvement in multiple such activities increases the risk of creating a sense of obligation on the part of a public office holder who benefits from them. If so, you should exercise caution if you are considering lobbying that public office holder or their staff.
Examples of lower-risk political activities:
- Volunteering, canvassing, or scrutineering for a registered party or electoral riding association without significantly interacting with candidates;
- Attending fundraising events; or
- Expressing personal political views strictly in an individual capacity.
Examples of no-risk political activities:
- Displaying campaign signs or posters; or
- Making personal donations within the limits established in the Canada Elections Act.
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