Compliance & Penalties
Investigations
The Integrity Commissioner, as Ontario’s Lobbyist Registrar, has the power to investigate potential non-compliance with the Lobbyists Registration Act, 1998. Individuals who have information about potential non-compliance with the Act can complete the form below.
The Act prohibits the Commissioner from releasing any information about ongoing investigations. Statistics and information about concluded investigations can be found in the Office's annual reports.
Penalties
If the Commissioner reaches a finding of non-compliance with the Act, the Commissioner may impose a penalty by making public the name of the lobbyist, a description of the non-compliance and any other information that the Commissioner considers necessary.
The Commissioner may also prohibit a person found to be in non-compliance from lobbying for up to two years.
Prohibition
John Mutton, Consultant Lobbyist
Prohibition period: April 17, 2025 to April 17, 2027
In late 2016 and early 2017, Mr. Mutton failed to comply with the Lobbyists Registration Act, 1998 by failing to file a registration after lobbying three different public office holders, on three different occasions, on behalf of a client with respect to the client’s goal of amending government policy and the making of legislation.
In late 2021 and early 2022, Mr. Mutton did not comply with the Act by failing to file a registration after he lobbied two public office holders with respect to a client’s request for a Minister’s Zoning Order (“MZO”). In the course of his work for this same client, Mr. Mutton also contravened the Act by undertaking to lobby when payment was contingent upon success. He was paid a $300,000 contingency fee for this work.
In 2022, Mr. Mutton did not comply with the Act by failing to file a registration after he lobbied two public office holders with respect to requesting that a client’s lands be removed from the Greenbelt Area, then established by Ontario Regulation 59/05 and government policy. In the course of his work for this same client, Mr. Mutton also contravened the Act by knowingly placing these public office holders in a position of real or potential conflict of interest by offering them gifts of a round of golf at a private golf course and tickets to a Toronto Raptors basketball game. Also in the course of his work for this client, Mr. Mutton contravened the Act by undertaking to lobby when payment was contingent upon success. He was paid a $225,000 contingency fee for this work.
In 2022, Mr. Mutton did not comply with the Act by failing to file a registration after he lobbied two public office holders with respect to a client’s request for an MZO. In the course of his work for this same client, Mr. Mutton also contravened the Act by undertaking to lobby when payment was contingent upon success. He was paid a $100,000 contingency fee for this work. In 2023, Mr. Mutton lobbied a third public office holder about amending a government policy or legislation with respect to this same client’s desire to service this property, when he had never filed a registration.
In 2023, Mr. Mutton did not comply with the Act by failing to file a registration after lobbying a public office holder with respect to a client’s request for an MZO. In the course of his work for this same client, Mr. Mutton also contravened the Act by undertaking to lobby when payment was contingent upon success. The contingency fee of $250,000 also included payment for additional work and was not yet payable at the time the investigation was completed.
In the course of lobbying for two of the clients listed above, Mr. Mutton also contravened the Act by knowingly placing two public office holders that he lobbied in a position of potential conflict of interest. For one of these public office holders, Mr. Mutton organized a political fundraiser raising more than $25,000 for the public office holder’s riding association approximately two months prior to the beginning of the 2022 provincial election. In a lobbying communication to the second public office holder, Mr. Mutton noted he was responsible for bringing $5,000 to a particular political fundraiser and suggested some of these funds might benefit this public office holder, who was participating in that event.
Mr. Mutton’s several failures to register, use of contingency fees, and disregard of the conflict of interest prohibition undermine the Act’s purpose of transparency and public confidence in the independence of public sector decision making. Given the significant number of serious contraventions going back several years, the Registrar decided to prohibit Mr. Mutton from lobbying Ontario public office holders, as defined in the Act, for a period of two years, in addition to publishing his name and a summary of his non-compliance.
Published Non-compliance
2024-2025
Amin Massoudi, Consultant Lobbyist
In 2023, Amin Massoudi failed to comply with the Lobbyists Registration Act, 1998 by failing to file a registration after lobbying a public office holder about his client’s request during a telephone call, and by knowingly placing that person in a position of potential conflict of interest during that communication, because Mr. Massoudi had offered that same public office holder a ticket to a Toronto Raptors basketball game the previous day.
Mr. Massoudi’s failure to register and offer of a gift undermines the Act’s purpose of transparency and public confidence in the independence of public sector decision making. The Lobbyist Registrar directed that his name be published with a brief description of the non-compliance.
Michael Foderick, Consultant Lobbyist
In 2023, Mr. Foderick failed to comply with the Lobbyists Registration Act, 1998 by failing to file three registrations with respect to undertakings on behalf of three different clients.
Two undertakings involved resending submissions initially made through a public consultation process to a senior public office holder after the relevant public consultation periods had ended.
The third undertaking involved lobbying public office holders to request a Minister’s Zoning Order related to a matter of public health and safety.
Mr. Foderick served as legal counsel to each of these three clients and lobbied on their behalf.
Mr. Foderick’s failure to register undermines the Act’s purpose of transparency. The Lobbyist Registrar directed that his name be published with this brief description of the non-compliance.
Matthew Johnston, Consultant Lobbyist
Between 2022 and 2024, Mr. Johnston failed to comply with the Lobbyists Registration Act, 1998 by failing to file registrations with respect to undertakings on behalf of two different clients.
One undertaking involved Mr. Johnston attending a meeting with public office holders in July 2022 during which his client requested and made the case for the removal of the client’s property from Ontario’s Greenbelt Area. For the same client, Mr. Johnston wrote to a senior public office holder in January 2024, to request a meeting to discuss building housing on this site and again referencing removal of the property from the Greenbelt.
Both undertakings involved sending submissions through a public consultation process to a senior public office holder, and including in those submissions an additional request that properties be removed from the Greenbelt, which was not a subject about which the government had requested advice and comment.
Mr. Johnston’s failure to register undermines the Act’s purpose of transparency. The Lobbyist Registrar directed that his name be published with this brief description of the non-compliance.
Nico Fidani-Diker, Consultant Lobbyist
In 2022, Mr. Fidani-Diker failed to comply with the Lobbyists Registration Act, 1998, by failing to file a registration after lobbying a public office holder with respect to requesting that a client’s lands be removed from the Greenbelt Area, then established by Ontario Regulation 59/05 and government policy. In the course of his work for this same client, Mr. Fidani-Diker also contravened the Act by knowingly placing two public office holders in a position of real or potential conflict of interest by offering them a gift of tickets to a Toronto Maple Leafs hockey game.
In 2022, Mr. Fidani-Diker also contravened the Act by knowingly placing a public office holder in a position of real or potential conflict of interest in the course of lobbying him on behalf of another client. Mr. Fidani-Diker had a prior close working relationship, had recently engaged in significant political work with this public office holder, and had a friendship with this public office holder.
In 2022-2023, Mr. Fidani-Diker also contravened the Act by knowingly placing a public office holder in a position of real or potential conflict of interest in the course of lobbying him on behalf of another client. Mr. Fidani-Diker had a long history of a close relationship with this public office holder, including significant personal, work and political connections.
In 2022, Mr. Fidani-Diker, with respect to a registration he filed on behalf of another client, contravened the Act by failing to provide particulars to identify the regulation change he was seeking on behalf of another client. This client was also seeking the removal of their lands from Greenbelt Area, which at the time required amendment of Ontario Regulation 59/05.
In 2023, Mr. Fidani-Diker, with respect to a registration he filed on behalf of another client, contravened the Act by failing to provide particulars to identify the regulation change he was seeking on behalf of another client. This client was seeking a Minister’s Zoning Order, which is a regulation, to increase the permitted building height and density on its property.
Mr. Fidani-Diker’s failure to register, failure to provide particulars and contraventions of the conflict of interest prohibition undermines the Act’s purpose of transparency and public confidence in the independence of public sector decision making. The Lobbyist Registrar directed that his name be published with a brief description of the non-compliance.
Katarzyna Sliwa, Consultant Lobbyist
In 2022, Katarzyna Sliwa failed to comply with the Lobbyists Registration Act, 1998 by failing to file registrations after sending two letters to a public office holder. One letter requested the amendment of the regulation then establishing the Greenbelt Area boundaries on behalf of one client, and the other requested three specific amendments to a Government of Ontario policy, specifically the Greenbelt Plan, on behalf of two clients.
By the time the investigation started, she was 398 days late to register her lobbying activity for the first client and 377 days late to register her activity for the second client.
Ms. Sliwa’s failure to register undermines the Act’s purpose of transparency. The Lobbyist Registrar directed that her name be published with a brief description of the non-compliance.
2022-2023
Craig Hughson, Consultant Lobbyist
Craig Hughson, a consultant lobbyist, was found to have failed to file a registration after arranging a meeting for a client with a public office holder. Mr. Hughson's failure to register undermines the Lobbyist Registration Act’s goal of transparency. The Lobbyist Registrar directed that the consultant lobbyist’s name be published with a brief description of the non-compliance.