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Section II: Analysis of Program Activities by Strategic Outcome

Analysis by Program Activity

Strategic Outcome

Transparency and accountability in the lobbying of public office holders contribute to confidence in the integrity of government decision-making.

Program Activity Name

Registration of Lobbyists


Financial Resources (in $000)
Planned Spending Authorities Actual Spending
1 519 1 487 1 460


Human Resources
Planned Actual Difference
7 7 0

Priority #1: Update the Registry and enhance its transparency.

Lobbying the federal government is a legitimate activity but it must be done transparently. The Lobbyists Registration Act (Act) requires that individuals who are paid to lobby public office holders must disclose certain details of their lobbying activities. The Registrar approves lobbyists' registrations and makes them available for searching in an electronic registry that is publicly available on the Internet through the Lobbyists Registration System (LRS). As part of its 2006-2007 Report on Plans and Priorities, the Office of the Registrar of Lobbyists (ORL) identified that its priority, with regard to the "Registration of Lobbyists" activity, was to "Update the Registry and enhance its transparency."

During fiscal year 2006-2007, the ORL completed a series of changes to the LRS. In particular, improvements were brought to the system's administrative interface with a view to enabling staff from the ORL's Registration Unit to handle the 38% increase in registrations that took place in 2006-2007. Changes were also made to the public interface of the LRS in order to help registrants to manage their registrations more efficiently. Finally, the ORL continued to implement ways to increase the transparency of the Registry by making improvements to some of the system's tools for the preparation of reports, including its search feature. As a result, users of the system can search and explore the Registry more easily. For instance, it is now possible to make more refined searches of all active and inactive registrations contained in the Registry by performing additional searches within a first set of search results. As well, search results are now presented in a more transparent manner, with key information on each registration shown in a summary box.

To further improve the registration approval process, the ORL completed a review of its business processes, with the objective of making better use of the LRS's capabilities to process electronic transactions. New procedures were implemented to allow for a broader use of electronic correspondence to issue renewal and termination notices. Electronic correspondence has also become the most widely used means of communication with registrants.

Registration results for 2006-2007 are presented in the table below. Results for 2005-2006 are included for purposes of comparison.


  2006-2007 2005-2006
Individual Lobbyists - active as of March 31, 2007
Consultant lobbyists 860 732
In-house lobbyists (corporations) 1 882 1 809
In-house lobbyists (organizations) 2 539 2 306
Total registered individual lobbyists, all categories 5 281 4 847
Registration - active as of March 31, 2007
Consultant lobbyists (one registration per client) 2 975 2 726
Corporations 313 276
Organizations 457 364
Total active registrations, all categories 3 745 3 366

Analysis by Program Activity

Strategic Outcome

Transparency and accountability in the lobbying of public office holders contribute to confidence in the integrity of government decision-making.

Program Activity Name

Education and Research


Financial Resources (in $000)
Planned Spending Authorities Actual Spending
930 899 744


Human Resources
Planned Actual Difference
5 5 0

Priority #2: Increase awareness of Lobbyists Registration Act (Act) and Lobbyists' Code of Conduct (Code) requirements.

The Office of the Registrar of Lobbyists (ORL) used a variety of means to promote and foster awareness of the requirements of the Act and the Code.

Direct Communications

The ORL responded to inquiries from lobbyists, the media, and the public on a daily basis. In addition, it provided updates about the Registry to registered lobbyists via e-mail and through notices to registrants on the ORL's website. It organized outreach and information sessions with lobbying firms to improve the overall quality and reliability of disclosures filed in the Registry of Lobbyists.

The ORL's website was updated in 2006-2007 making it a more useful information and communications tool, which was easier to navigate and included sections covering reports, presentations, interpretation bulletins and advisory opinions, all of which are updated or added on a regular basis.

ORL's newest education and enforcement initiative was the issuance of advisory letters to lobbyists who were alleged to have conducted unregistered lobbying activities. These letters are designed to enhance the knowledge of organizations and corporations regarding the Act and to encourage them to visit the ORL's website or contact it directly for additional information pertaining to registration requirements. A total of 24 such letters were sent, resulting in eight respondents replying that they were not required to register and four who registered shortly after receipt of the advisory letter.

Information Sessions

The ORL presented information sessions to interested groups and organizations outside the federal government. For example, the Registrar made a presentation at an information session on a proposed lobbyists registry for the City of Toronto. ORL staff provided a briefing session to the Korean Independent Commission Against Corruption. Other information sessions were provided to registered lobbyists as well as to organizations that expressed interest in becoming registered under the Act.

Media Relations

In August 2006, the ORL organized a half-day consultation session with members of the media to obtain their views on using the online Registry and how it might be made more easily accessible and helpful as a research tool.

During 2006-2007, ORL staff responded to media inquiries relating to reported allegations of non-compliance with the Act or the Code. A good deal of media attention was directed to allegations of breaches of the Act and related court proceedings. The ORL responded to inquiries from the media about the Registry, provided clarification about the registration process, investigations and administrative reviews to the extent permissible under the Act and under privacy provisions.

There was substantial media interest in the new Lobbying Act, resulting in many questions related to the differences between the Lobbyists Registration Act and the new Lobbying Act, most of which were referred to the Treasury Board Secretariat, which is the primary policy centre for the Federal Accountability Act.

Conferences and Learning Events

The Registrar and senior office staff of ORL took part in a number of conferences and panel discussions in Canada and the United States. These included the Access and Privacy Conference, hosted by the University of Alberta in Edmonton; the Annual University Government Relations Officers' Meeting in Winnipeg; the Public Affairs Association of Canada Conference in Toronto; the Canadian Council for Public-Private Partnerships National Conference in Toronto and the Council of Governmental Ethics Laws Conference in New Orleans.

Briefings for Federal Government Institutions

The ORL continued its outreach efforts within the federal government through briefings to management at a number of departments and other federal organizations. These sessions were aimed at familiarizing departments and organizations with the provisions of the Act and the Code and addressing issues faced by specific organizations regarding lobbying and interactions with lobbyists.

Dialogue with other jurisdictions

The ORL continued its practice of exchanging ideas and practices with counterparts from provincial and international jurisdictions - British Columbia, Québec, Newfoundland and Labrador, Nova Scotia, Ontario, the United States and the Organisation for Economic Co-operation and Development (OECD).

Analysis by Program Activity

Strategic Outcome

Transparency and accountability in the lobbying of public office holders contribute to confidence in the integrity of government decision-making.

Program Activity Name

Reviews and Investigations under the Lobbyists Registration Act and the Lobbyists' Code of Conduct


Financial Resources (in $000)
Planned Spending Authorities Actual Spending
1 065 1 021 899


Human Resources
Planned Actual Difference
8 8 0

Priority #3: Pursue enforcement of the Act and Code and communicate the results achieved.

The Office of the Registrar of Lobbyists (ORL) validates information provided by registered lobbyists to ensure accuracy. Allegations of non-registered activity or misconduct by lobbyists are reviewed and formal investigations are carried out when required.

The ORL developed a set of procedures during the reporting period to improve the conduct of administrative reviews and investigations of allegations of non-registered activity or misconduct by lobbyists. An administrative review typically involves reviewing all registration files in the custody of the ORL, available correspondence and other forms of communication between the ORL and the lobbyist; and confirming, through telephone or in-person interviews with public office holders, whether registrable activities have indeed taken place.

If a review indicates there are reasonable grounds to believe a breach of the Act has occurred, the Registrar of Lobbyists is informed of the conclusions and the matter is referred to the Royal Canadian Mounted Police. If the contravention occurred outside the Act's stipulated two-year limitation period for contraventions, the ORL may still initiate an investigation under the Code, which has no limitation period.

In the reporting period of 2006-2007, the ORL initiated 24 administrative reviews dealing with allegations of unregistered lobbying. Nine of the reviews were within the two-year limitation period and were processed as possible contraventions of the Act. Three of these reviews were closed in 2006-2007 and six remained ongoing.

The other 15 reviews, which were beyond the Act's limitation period, were dealt with as possible contraventions of the Code. Six of these matters related to cases ruled on by the former Ethics Counsellor. The Registrar agreed to re-examine them and they were assigned to investigators. Seven reviews involved allegations of improper lobbying activity by individuals who were seeking financial benefits from a special operating agency of the federal government. The remaining two involved registered lobbyists who were alleged to be providing advice and professional services to federal public office holders at the same time as they were registered to lobby the government. One of the files became an investigation initiated by the Registrar, the rest are ongoing.

Investigations Under the Code

The Registrar tabled four Code investigations in Parliament in 2006-2007. The reports involved lobbying activities of one lobbyist on behalf of four companies. In each of the four cases, the Registrar concluded that the lobbyist violated the Act by failing to register as a lobbyist. As well, in each of the cases, the Registrar found that the lobbyist had breached the Code's Principle of Professionalism, which requires that lobbyists observe the highest professionalism and ethical standards. In particular, lobbyists must conform fully not only to the letter but the spirit of the Code as well as relevant laws, including the Lobbyists Registration Act.

The Registrar also determined in each report that Rule 3 of the Code, Disclosure of Obligations under the heading of Transparency, had been breached. This Rule requires that lobbyists shall indicate to their clients, employer or organization their obligations to adhere to the Code. In one of the reports, the Registrar also concluded that Rule 2 of the Code, Accurate Information had been breached. This Rule requires that lobbyists shall not knowingly mislead anyone and shall use proper care to avoid doing so inadvertently.