R. Michael Taper
DELIVERED BY REGISTERED MAIL
December 29, 2021
Commissioner of Lobbying
Office of the Commissioner of Lobbying in Canada
410 Laurier Avenue West, 8th Floor
Ottawa, ON K1R 1B7
Dear Ms. Belanger:
I am writing to request, pursuant to Section 10.4(1) of the Lobbying Act, that an investigation be opened into possible contraventions of Sections 5(1) and/or 7(1) of the Lobbying Act on the part of the organization “Canadians for Justice and Peace in the Middle East” (“CJPME”), its president Thomas Woodley, and its Vice-President Michael Bueckert.
Part I: Facts
CJPME is an organization whose address is: Canadians for Justice & Peace in the Middle East 580 Sainte-Croix Ave., Suite 060 Montreal, QC, H4L 3X5 Phone: 438-380-5410 Website: www.cjpme.org
CJPME describes itself as “a non-profit organization concerned with issues of justice, development and peace in the Middle East.”
There is no entry for CJPME or for its President, Thomas Woodley, or its Vice-President, Michael Bueckert, in the Registry of Lobbyists.
Notwithstanding Item 3 above, CJPME claims on its website that it engages in substantial lobbying of Members of Parliament. Specifically, (a) On its website https://www.cjpme.org/2021_four_critical_projects CJMPE states “Take Members of Parliament to Palestine: This was one of our objectives for 2021, but the pandemic and the federal election made it impossible. Nevertheless, we’re already in discussions with members of Parliament who are interested in going to Palestine, and we’d like to do everything we can make such a trip possible. We’d like to raise $25,000 to help enable a trip for approximately 20 MPs. The funds would be spent to help MPs pay travel expenses, to arrange services in Palestine, and to manage and coordinate the overall effort.” (b) CJPME has requested various Members of Parliament to sign the following pledge: “As a Member of Parliament, I understand that Canada has a responsibility to stand up for international law and human rights. For this reason, the Canadian government must show meaningful opposition to the annexation plans recently announced by Israeli leaders. I call on the Canadian government to consider all reasonable diplomatic and economic options to stop annexation and prompt Israeli compliance with international law.” This activity is documented by CJPME on its website at: pledge https://mppledge-cjpme.nationbuilder.com/. According to the CJPME website, 72 Members of Parliament have signed this pledge. https://mppledge-cjpme.nationbuilder.com/pledge_endorsements (c) In a message to its supporters on December 28, 2021, CJPME stated: “CJPME does the hard work of local mobilizing and high-intensity pressuring of members of Parliament – and because of this, does not qualify for charitable status and tax-deductible donations.” (d) CJPME published a flyer in December 2021 in which it described two of “the ten big hairy goals” for the organization for 2021, and its related accomplishment, as: “Influence politicians on Canada’s diplomatic failure to stand up for Palestinian human rights: Among other actions, CJPME meets regularly with MPs to oppose Canada’s knee-jerk diplomatic support for Israel, and we made a huge splash with our 2021 Elections Guide”. “Force vote in Canada’s parliament calling for Palestinian self-determination: No time for this in 2020, but CJPME will try again in Parliament’s next session. In the meantime, CJPME helped launch the international “Inter-Parliamentary Task Force to promote Palestinian Rights” group, which brought together Canadian, American, UK, Irish, and other European MPs to discuss the issue.” https://d3n8a8pro7vhmx.cloudfront.net/cjpme/mailings/2180/attachments/original/Newsletter_compressed_-_CJPME_-_EN_Flyer.pdf?1640640473 (e) In its year-end newsletter for 2019, CJPME stated that its activities included: “Dozens of face-to-face, one-on-one meetings with Members of Parliament, lobbying for things like increased Canadian funding for Palestinian refugees, condemnation of Israel’s territorial ambitions, reduced sales of arms to Israel and Middle East dictatorships, and greater action against Islamophobia in Canada.” https://www.cjpme.org/accomplishments_message
It is likely that CJPME has employed and paid staff to engage in these lobbying activities. In this same flyer, CJPME stated that in 2020, its operating expenses totaled $215,000.
In its 2019 year-end message, CJPME president Thomas Woodley stated that in that year, CJPME had 2.5 full-time equivalents of paid staff, and that for the year 2018 CJPME’s salary expenses were $145,000.
Part II: Law and Analysis
7. Section 5(1) of the Lobbying Act states that “An individual shall file with the Commissioner, in the prescribed form and manner, a return setting out the information referred to in subsection (2), if the individual, for payment, on behalf of any person or organization (in this section referred to as the “client”), undertakes to (a) communicate with a public office holder in respect of … (iv) the development or amendment of any policy or program of the Government of Canada, … or (b) arrange a meeting between a public office holder and any other person.” 8. Section 7(1) of the Lobbying Act states that: “The officer responsible for filing returns for a corporation or organization shall file with the Commissioner, in the prescribed form and manner, a return setting out the information referred to in subsection (3) if (a) the corporation or organization employs one or more individuals any part of whose duties is to communicate with public office holders on behalf of the employer or, if the employer is a corporation, on behalf of any subsidiary of the employer or any corporation of which the employer is a subsidiary, in respect of … (iv) the development or amendment of any policy or program of the Government of Canada, … and (b) those duties constitute a significant part of the duties of one employee or would constitute a significant part of the duties of one employee if they were performed by only one employee.” 9. The activities of CJPME and its officers, based on their descriptions in CJPME’s own published materials, appear to meet the criteria of lobbying as set out in the Act i.e., communication with designated public office holders (i.e., Members of Parliament) about the development of the foreign policy of the Government of Canada regarding conflicts in the Middle East. During the period from 2018 through 2021 and currently, CJPME appears to employ one or more individuals to carry out such activities on its behalf, and such activities appear, from their volume described in CJPME’s own materials, to constitute a significant part of the duties of such employees, or a significant part of the duties of only one employee if they were performed by only one employee. The fact that neither CJPME nor any of its principal officers appear in the Registry of Lobbyists strongly suggests that the returns required by the Lobbying Act were not filed. 10. None of the activities of CJPME appear to fall into the areas of non-applicability of the Lobbying Act as set out in Section 4 thereof.
Part III: Conclusion
11. Based on the facts and law recited above, I respectfully request that possible contraventions of the Lobbying Act by CJPME be investigated by your Office.
Yours very truly,