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Should Projects undertake regulated government relations activities?

If it furthers the Project's charitable purpose, then it is worth considering regulated activities such as PPDDA and lobbying. While these activities are regulated, they remain fully charitable and can be an important way to further the Project's work. 

Note: Surveys have shown that as high as 96% of Canadians believe that charities have an important role to play in the development of government policy and procedure.

What are examples of permitted PPDDA activities?

The following are examples of permitted public policy dialogue and development activity:

  • Buying a newspaper advertisement to pressure the government on a particular issue.
  • Organizing a march to Parliament Hill to put pressure on the government to change its policy on an issue.
  • Organizing a conference to support the charity’s position on an issue.
  • Conducting a media campaign with respect to an issue, e.g. explicit communication to the public that a law, policy, or decision at any level of the government of Canada or a foreign country should be retained, opposed or changed.
  • Conducting a mail campaign to urge readers to contact the government.
  • Using a media campaign to urge people to contact the government on an issue.

The following are examples of permitted charitable activities that have a political aspect but are likely not PPDDA:

  • Distributing the charity’s research to all election candidates in a particular election.
  • Presenting the charity’s research to a parliamentary committee.
  • Giving a radio or television interview about the charity’s research or presentation to a Parliamentary Committee.
  • Distributing the charity’s research to all members of parliament.
  • Participating in a policy development working group where public officials also participate.
  • Making a representation to an elected representative or public official where the issue is connected to the charity’s purpose.

Generally speaking, the distinction between a political activity and a charitable activity is that political activities include an explicit call to action.

Note: Any of the activities listed here may require the Project to register as an in-house lobbyist under the Lobbying Act. Regulations vary across jurisdictions or levels of government. Projects should consult with their Project Specialist if they are planning any of these activities.

What are examples prohibited PPDDA activities?

The following are examples of prohibited PPDDA activities:

  • All illegal acts
  • Civil disobedience
  • Partisan political activity

Civil disobedience is defined as non-compliance with any of the laws of Canada or a province, or non-compliance with any court order. An example would be defying a court order to disperse with respect to a blockade. Civil disobedience is considered an illegal act.

Partisan politics is defined as direct or indirect support of, or opposition to, any political party or candidate for public office. Projects are prohibited from connecting themselves, or any of their positions, to a specific political party or candidate, including:

  • Indicating support for a particular federal, provincial, or municipal election candidate or party on a website or other communication media.
  • Indicating that a specific Member of Parliament, Member of the Legislative Assembly, or municipal politician should not be supported for re-election because of the manner in which they voted on a particular issue.
  • Distributing leaflets, purchasing advertisements (including billboards), or creating, linking to, or publicizing a website which highlights the lack of federal, provincial, or municipal government support for a particular issue.
  • Holding or promoting an event for a candidate for public office.

As a Canadian registered charity, MakeWay and its Projects are absolutely prohibited from engaging in both illegal acts and partisan political activities.

When do Projects need to register employees as lobbyists?

In general, organizations only need to register employees as lobbyists if they will spend more than a specified number of hours lobbying within a specified time-frame. The threshold for registration as a lobbyist is different in each jurisdiction.

The number of hours spent lobbying is calculated across all Projects belonging to MakeWay. So, even if your Project has not yet reached the threshold for registration, the cumulative lobbying hours of all Projects across MakeWay could pass the threshold and therefore require registration.

How do Projects track and report lobbying activity?

To report any federal lobbying activities, complete the Monthly Lobbying Report when it is emailed to you at the end of each month.

Projects engaged in lobbying at the federal level should contact their Project Specialist to get a copy of the Lobbying Act as well as a copy of MakeWay's Federal Lobbying Guide, which contains many examples of what is and is not considered lobbying activity.

MakeWay Charitable Society is registered to lobby in BC. To report any lobbying activities in BC, complete the Monthly Lobbying Report, which is emailed to projects at the end of each month. For lobbying in any other jurisdiction, report lobbying activity to your Project Specialist.

Projects should submit the relevant form(s) to their Project Specialist before the 7th of each month.