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Compliance with Lobbying Laws and Regulations Policy

Area Responsible for Administration: Strategic Initiatives and Government Relations
Approval Authorities: Senior Executive Committee
Approval Date: None
Revision History: 2008
November 2017
Review Timeline: As legislation is updated

Purpose

To ensure compliance with all legislation, regulations and codes of conduct governing federal, provincial and municipal (where applicable) lobbying activities.

Scope

This policy applies to all Seneca employees who communicate with government officials regarding funding or policy discussions of relevance to Seneca or who administer projects and programs that receive government funding.

Key Definitions

Employees
Full-time, part-time and contract faculty, support staff and administrators of Seneca.
Communication (federal)
Any indirect or direct oral or written exchange of information with a public office holder, regardless of who initiates it. This includes phone calls, emails and casual meetings at social gatherings or events. This excludes requests for information or submissions and presentations made to Parliamentary committees.
Communication (provincial)

Any indirect or direct oral or written exchange of information with a public office holder, regardless of who initiates it, including grass roots campaigns. This includes phone calls, emails and casual meetings at social gatherings or events.

This excludes:

  • Submissions to legislative committees that are a matter of public record
  • Inquiries made with respect to the enforcement, interpretation, application, implementation or administration of any act, policy, program, directive or guideline
  • Responses to written requests for information, advice or comment from a public office holder
  • Routine constituency communications about matters of private interest.
Gift
A thing of value given willingly to someone without payment; a present.
Grass-roots campaigns
In accordance with the Lobbyists Registration Act, appeals to members of the public through the mass media or by direct communication that seek to persuade members of the public to communicate directly with a public office holder in an attempt to place pressure on the public office holder to endorse a particular opinion.
Lobbying (federal)

Communication with a federal public office holder if it is “in respect of” any of the five following types of government decisions:

  • The development of any legislative proposal by the federal government or by a Senator or Member of Parliament (MP)
  • The introduction of any Bill or resolution in either the Senate or the House of Commons, and the passage, defeat or amendment of any Bill or resolution that is before either the Senate or the House of Commons
  • The making or amendment of any federal government policy or program
  • The awarding of any grant, contribution or other financial benefit by or on behalf of the federal government.

Note: Communication does not need to be an attempt to influence, but can be “in regards to” a decision.

Lobbying (provincial)

Any communication made with a public office holder in an attempt to influence:

  • The development of any legislative proposal by the Government of Ontario or by a member of the Legislative Assembly
  • The introduction of any bill or resolution in the Legislative Assembly or the passage, defeat or amendment of any bill or resolution that is before the Legislative Assembly
  • The making or amendment of any regulation as defined in Part III (Regulations) of the Legislation Act
  • The development or amendment of any policy or program of the Government of Ontario or the termination of any program of the Government of Ontario
  • A decision by the Executive Council to transfer from the Crown for consideration all or part of, or any interest in or asset of, any business, enterprise or institution that provides goods or services to the Crown or to the public
  • A decision by the Executive Council, a committee of the Executive Council or a minister of the Crown to have the private sector instead of the Crown provide goods or services to the Crown
  • The awarding of any grant, contribution or other financial benefit by or on behalf of the Crown.
Public office holder (federal)

In accordance with the Lobbying Act:

  • A member of the Senate or the House of Commons and any person on the staff of such a member
  • A person who is appointed to any office or body by or with the approval of the Governor in Council or a minister of the Crown, other than a judge receiving a salary under the Judges Act or the lieutenant governor of a province
  • An officer, director or employee of any federal board, commission or other tribunal as defined in the Federal Courts Act
  • A member of the Canadian Armed Forces
  • A member of the Royal Canadian Mounted Police.
Public office holder (provincial)

In accordance with the Lobbyists Registration Act:

  • Any minister, officer or employee of the Crown
  • A member of the Legislative Assembly and any person on their staff
  • A person who is appointed to any office or body by or with the approval of the Lieutenant Governor in Council or a minister of the Crown, other than a judge or a justice of the peace or a person appointed by or with the approval of the Lieutenant Governor in Council on the address of the Legislative Assembly
  • An officer, director or employee of any agency, board or commission of the Crown
  • A member of the Ontario Provincial Police Force
  • An officer, director or employee of:
    • Ontario Power Generation Inc. and each of its subsidiaries
    • Independent Electricity System Operator.

Policy

1. Policy Statement

It is the policy of Seneca to ensure that employees comply with the legislation, regulations and codes of conduct governing lobbying and related activities at the federal and provincial levels. Lobbying at the federal level is governed by the Lobbying Act. Lobbying at the provincial level is governed by the Lobbyists Registration Act.

2. Roles and Responsibilities

2.1 It is the responsibility of the Government Relations office to ensure the accurate reporting of Seneca’s lobbying activities, including:

  • Maintaining and updating Seneca’s provincial lobby registrations and ensuring reporting is accurate
  • Assisting employees in complying with lobbying requirements
  • Tracking grants, contributions and other financial benefits received from all levels of government
  • Answering questions and queries from the Lobbyist Registrars’ offices
  • Seeking legal advice to ensure that Seneca is fully compliant with legislative and regulatory changes
  • Monitoring developments at all levels of government with respect to lobbying to ensure Seneca and its policies remain updated and compliance demonstrates accountability.

2.2 It is the responsibility of all employees to inform the Government Relations office upon beginning communication with federal and provincial public office holders.

3. Registering Lobbying Activities

3.1 In accordance with the Lobbying Act and Lobbyists Registration Act, Seneca is required to register its lobbying activities with the Federal Registry of Lobbyists and the Ontario Lobbyists Registry, respectively, if the cumulative amount of lobbying across the institution is equivalent to at least:

  • 20 per cent of an employee’s time during any month in the reporting period for the federal registry
  • 50 hours per year for the provincial registry.

3.2 In accordance with the Lobbyists Registration Act, Seneca must renew its registration in the Ontario Lobbyists Registry twice yearly

3.3 Seneca is exempt from the City of Toronto Lobbying By-law as a result of its status as a crown agency (Seneca was established under the authority of the Ontario Colleges of the Applied Arts and Technology Act).

4. Reporting Lobbying Activities

In accordance with the Lobbying Act and Lobbyists Registration Act, Seneca shall file federal and provincial annual updates that report any funding it received from government.

5. Gifts and Benefits

5.1 Seneca will comply with policies on gifts outlined in the Lobbyists Registration Act. In a situation where Seneca invites a public office holder to an event where tickets are purchased, Seneca will ask them to cover the cost of their ticket. Examples of gifts that may create a real or potential conflict of interest include:

  • Tickets to sporting, cultural or speaking events
  • Meals
  • Flowers
  • Gift baskets.

Supporting Documentation

  • None

Supporting Documentation

  • None

Supporting Documentation