RE: 4. Proper interpretation and enforcement of the Lobbyists’ Code of Conduct;

These codes complement one another and together contribute to public confidence in the integrity of government decision making.” The Introduction to the Lobbyists’ Code also states: “Lobbyists, when engaging in lobbying activities, shall meet the standards set out in the principles and rules of the Code.” The “Integrity” Principle of the Lobbyists’ Code states “Integrity and Honesty: Lobbyists sho. [...] 32 that all that is required for an apparent conflict of interest to exist is that the reasonable observer perceive the conflict based on the “surrounding circumstances” and that “although appearance of conflict requires that the perception be fair-minded and reasonably well informed, it does not require that the perception be based on a complete understanding of all the facts, including the publi. [...] The intent of the Lobbyists’ Code, and purpose and provisions of the Code’s rules, are to enhance and maintain the public’s confidence in the integrity of government by preventing lobbyists from placing public office holders in even an apparent conflict of interest. [...] Protecting these appearances is more than a trivial concern.” As a result, the legally correct interpretation and enforcement approach that the Commissioner of Lobbying must take concerning the Lobbying Act and Lobbyists’ Code is that when there is even an appearance of lack of integrity in the actions of a lobbyist or someone directly connected to a lobbying organization or in the relationship be. [...] Given the broad objective of disclosure of lobbying activities set out in the Preamble of the Act, and based on the high compliance requirement set out in the Professionalism principle in the old Lobbyists’ Code, and the Objectives and Expectations sections of the new Code, the Commissioner should never excuse lobbyists who lobby without registering when they are required to register.