Submission on the Draft Voluntary Code of Conduct for lobbyists

April 8, 2024

Introduction

The New Zealand Council for Civil Liberties (‘the Council’) is a voluntary, not-for-profit, organisation which advocates to promote human rights and maintain civil liberties.

We are responding to this consultation for three reasons.

First, people’s rights and liberties are more likely to be protected when there is high integrity and more open and participatory public policy making by government. Unregulated lobbying will ensure the present – and longstanding – undermining of the integrity of policy making continues, so it is in the public interest to ensure robust mechanisms are in place to protect this integrity. A voluntary code will not do this, but the consultation provides an opportunity for us to reiterate this to the government.

Second, the draft voluntary Code of Conduct (‘the Code’) states in the paragraph 5 definition of ‘Lobbyist’ that this is ‘Any person or organisation that aims to influence government policy, process or law’.¹ The Council is clearly caught by this definition, so the Code cannot be said to be restricted to third party lobbyists as was the then Prime Minister’s intention when he commissioned this work in April 2023. The Council has an interest in how the Code could affect its work to advocate for human rights and civil liberties.

Third, measures to protect the integrity of public policy making by regulating lobbying are clearly connected to freedom of expression (section 14 of the New Zealand Bill of Rights Act 1990) and to freedom of association (section 17 of the Act). These rights are key to the civil liberties of all people living in Aotearoa New Zealand.

In this submission we deal first with the way the Ministry has undertaken the task assigned to it by the then Prime Minister, the claims made in the preamble to the Code, the definition of a ‘Lobbyist’, and finally the need for the Ministry to establish a meaningful and public monitoring regime to avoid future claims of a lack of evidence.

Ministry has both failed and gone beyond its brief

In producing the draft Code, the Ministry of Justice has both gone beyond what it was asked to do by the former Prime Minister in April 2023, and failed to do the tasks it should have been undertaking.

The Ministry has gone beyond what it was asked to do by drafting the voluntary code for third party lobbyists itself.

The Prime Minister’s press release of 3 April 2023 states, “I am calling on third-party lobbyists to develop a voluntary code of conduct”. He continued, “The Government will offer assistance from the Ministry of Justice to help draft the code and to provide research on overseas practises and guidance.”²

Although the Ministry restates the Prime Minister’s call to third-party lobbyists, there is no evidence that they have drafted a code of conduct. Instead, the Ministry – which regularly cites lack of policy capacity to undertake the review of the Official Information Act – has gone beyond what it was asked to do, by not just assisting third party lobbyists to create a voluntary code of conduct, but by doing the job for them. We are unclear why the Ministry has relieved the industry of this burden. If the industry had failed to produce such a code, this would have been evidence that more substantive government work was needed. It was not the Ministry’s task to help the industry out beyond what the Prime Minister had instructed them to do.

However, the Ministry has also failed to do what it was asked, in two key ways. First, its assistance to the lobbying industry was meant to be in relation to a voluntary code that applied only to third party lobbyists. But it has not done this; it has drafted a code which specifies in paragraph 5 that a ‘lobbyist’ is not just someone paid to carry out lobbying for third parties, but is ‘Any person or organisation that aims to influence government policy, process or law’.

Just because the professional lobbyists it spoke to wanted immediately to deflect attention away from themselves by saying “a lobbying code should apply to anyone influencing government decisions” did not mean this is what the Ministry should do.³ The Ministry’s decision to adopt this all-encompassing definition not only means the Ministry has failed the first of the tasks assigned to them by the Prime Minister, but has also opened itself to a much bigger issue. While the definition of ‘lobbyist’ was limited to third party lobbyists, it had a limited task in relation to assessment of the freedom of expression and association issues. But when it adopted a definition of ‘lobbyist’ that applies to everyone, the Ministry should have realised that this meant the work needed to be accorded a much higher public profile and greater investment in analysis and public engagement (beyond mere consultation). The freedom of expression and association issues now apply to the whole of the public, but the Ministry has failed to expand its engagement work on this issue. If it has conducted an analysis of the Bill of Rights Act issues, it has failed to publish it alongside the draft Code to assist readers and submitters.

Its second failing is more substantial and worrying though. In the Prime Minister’s press release of 3 April 2023, he also stated that work would start on “long term work on policy options to regulate lobbying”. This was described in paragraph 39 of the Ministry’s briefing to its Minister on 1 August 2023 as “Leading a substantive review of the policy options for regulating lobbying activities, including a public consultation process.”⁴ In the same briefing, the Ministry said that it would report back “by 28 February 2024” on “policy options for addressing issues with lobbying activities in New Zealand and proposals for substantive public consultation.” However, the Ministry’s communications in relation to this “substantive review” have been vague and it now seems to be at risk of not proceeding at all under the new government.

In its 29 September 2023 Update, the Ministry wrote, “The next step is to prepare a draft issues paper that will draw together our background research and the issues raised at the meetings. This paper will help us develop future policy options.”⁵ No such draft issues paper has been published for public comment or improvement. Since the work on lobbying was not mentioned once in the Ministry’s Briefing for the Incoming Minister, it is reasonable to infer that this work does not have a high priority for the Ministry. In the notes of its 25 January 2024 meeting with third-party lobbyists, paragraph 15 describes this ‘exploration of broader regulatory options’ as ‘a secondary piece of work’.⁶

The Council is concerned that the more “substantive review” is also not a high priority for the current government, and together with the impact of the cuts in funding of the Ministry, the work is therefore at high risk of not proceeding. This would be unacceptable, and ensure that attacks on the integrity of public policy-making continue.

A Code of Conduct for Third Party Lobbyists

Ministry’s role

The Ministry has run a number of workshops for ‘government relations consultants’ who are the third party lobbyists targeted by the first of the Prime Minister’s commitments. The Council welcomes the discussions with different groups on the broader issues around lobbying, and integrity of public policy making. However, the Ministry seems to have used the lobbying industry’s desire to deflect the focus on their activities, and the wider group’s views that a more-encompassing regulatory regime is needed, as a reason to broaden the scope of the voluntary code out to everyone who seeks to influence government policy, process or law.

But despite broadening the definition to cover everyone exercising their rights to freedom of expression and association, it has nevertheless given primacy to the concerns of the professional third party lobbyists.

The professional lobbyists’ privileged position in the process has not only been abused to deflect the voluntary Code’s applicability solely to them, but also to significantly water down the draft code from that presented solely to the industry for consultation in December 2023.⁷ The version of the draft Code which is now being consulted on has been changed between late January and mid-March at the instigation of those who were the targets of the former Prime Minister’s commitment.⁸ This is exactly the self-interested lobbying that the Ministry should have been guarding against, not giving in to. When claims are made that there is no evidence of lobbying improperly changing government work, this is a prime example to contradict such claims. If the Ministry cannot recognise this, it has a definitional problem that means it needs to reflect deeply on claims that there is little or no evidence of a problem.

The Council’s view is that since the Ministry’s task was only to assist the industry, not do the job of producing a Code for them, the Ministry needs to reassert control over the process, and revert to the December 2023 draft of the Code. This would mean that the industry is free to develop its own voluntary Code, but that the public is able to compare what the industry develops with a clear statement of the government’s expected industry standards. It is not the job of Ministry officials, acting with integrity after analysing the policy options, to give in to the pressure from professional lobbyists to water down what is already a voluntary Code. If the Ministry wanted to demonstrate the vulnerability of our existing policy processes to pressure from professional lobbyists, the current draft being consulted upon could not have done a better job. We trust the Ministry will develop some self-respect and revert the draft Code to that issued in December 2023 – with two exceptions as we will set out below.

Claims made in the Preamble to the Code

Following industry pressure, the Ministry has inserted paragraph 2 into the Preamble of the draft Code.⁹ This reads:

New Zealand enjoys high levels of transparency and low levels of corruption in public life. This code outlines good practice expectations for lobbying and helps everyone who aims to influence government decisions to maintain public trust in the integrity of government. It is one of several tools that help build public trust. This code complements New Zealand’s comprehensive transparency laws and mechanisms, and other professional rules and codes of practice.

The reality, as experienced by the Council, is significantly different. There are four areas where problems with transparency are clearly evident.

First, although it is now more than 40 years since the enactment of the Official Information Act successive governments have resisted modernising the law, despite two Law Commission reviews, published scholarship, and the Ministry’s own 2019 consultation on whether there should be a review. The difficulties and problems associated with the law’s administration still remain. Those include slow and incomplete responses, a reluctance to provide information and often excessive redactions. A key issue is the reluctance of departments and ministries to provide adequate staff resources to meet their legal obligations. Furthermore, the OIA is not as ‘comprehensive’ as the Ministry claims: outside of the OIA’s scope are the state-owned energy companies, the courts, the Office of the Clerk, the Parliamentary Service, the Parliamentary Counsel’s Office, the Auditor-General, the Ombudsman, the Attorney-General and Solicitor-General when acting in a law officer capacity, and evidence or submissions made to Royal Commissions or Commissions of Inquiry.

Improvements to the practice of proactively releasing information are welcome, but are entirely outside the scope of an unmodernised OIA, and therefore the Ombudsman’s complaint jurisdiction under that Act. As they are completely voluntary efforts, even those that have been somewhat codified in Cabinet Office Circulars – such as the release of Cabinet papers – are highly vulnerable to changes in ministerial preferences. Already under the present government, we have seen at least one minister cease the practice adopted under the last government of proactively publishing a list of briefings sent to them in the previous fortnight. Similarly, between July and November 2021, at the height of the government’s policy shift from Covid-19 Alert Levels to the ‘traffic light’ scheme, the government simply stopped publishing Cabinet papers. This was at a time when it was also developing policy on vaccine certificates and vaccine mandates – issues with significant civil liberties ramifications.

Second, the existence of numerous secrecy clauses in legislation which exclude the application of the Official Information Act from particular information or agencies undermines the claim. More than 30 were created between 2017 and 2023, and we estimate there are now more than 115 in force.¹⁰ Governments still enact further secrecy clauses on a regular basis. The Ministry’s own weak conduct in relation to this consists of watering down an Open Government Partnership commitment that civil society organisations sought and the Public Services minister favoured, for a review of the existing secrecy clauses to make recommendations for repeal or amendment. Instead, the Ministry conducted a secretive consultation of five organisations on how scrutiny of departments’ proposals for further secrecy clauses could be improved.

Third, the anaemic conduct of successive governments and many departments and ministries – including the Ministry of Justice – in relation to the country’s participation in the Open Government Partnership further demonstrates a disdain for that process and casts real doubt on the legitimacy of the claim in the Preamble. The fact that the government was unwilling to include the Ministry’s work on lobbying in its fourth National Action Plan as a member of the Partnership confirms this: it did not want the independent external scrutiny of its work on this issue that would accompany it being an Action Plan commitment.

Fourth, the complete failure to operationalise and monitor departmental chief executives’ performance of their duties under section 12 of the Public Service Act 2020 further undermines the claim in the Preamble. Section 12 imposes duties on chief executives, including ‘to foster a culture of open government’. But the Public Service Commission has been unable to provide any meaningful evidence of it either providing guidance to chief executives on how to fulfil this duty, nor how the performance of chief executives in discharging this duty is being or will be assessed in a manner that ensures the public can judge for themselves.¹¹

In summary, while it may be comforting to the Ministry and the professional lobbyists who pressed it to include these claims in the preamble, the Council is clear that they are lip service, because there is no real evidence of a commitment to work on monitoring, analysing, or improving open government or transparency. Including this claim in the Preamble invites scepticism at a time when governments say that public trust in government is of vital importance to them.

If the Ministry wants to retain a similar paragraph in the Preamble, we recommend it is reworded accordingly:

This code outlines good practice expectations for lobbying by professionals on behalf of third parties, in order to help the industry whose work aims to influence government decisions to maintain public trust in the integrity of government. It is one of several tools that help build public trust. This code complements New Zealand’s transparency laws and mechanisms, and other professional rules and codes of practice.

Definition of a ‘Lobbyist’

As noted above, the Prime Minister tasked the Ministry with the job of assisting the people and companies who work as lobbyists on behalf of third parties to develop their own voluntary code of conduct.

While the Council strongly supports the development of a comprehensive regulatory regime for lobbying that has a broad scope – including lobbying undertaken by civil society organisations, trade unions, and companies – we disagree fundamentally with the position now put forward in the draft voluntary code for professional third party lobbyists.

Paragraph 5 of the draft Code provides the following definition of a ‘Lobbyist’:

Lobbyist – Any person or organisation that aims to influence government policy, process or law.

It is a serious mistake on the part of the Ministry to have conflated the industry’s desire to deflect attention away from its conduct, and the desire of others outside the industry for comprehensive regulation The definition in the draft Code has turned what was meant to be a code for professional third party lobbyists into a document that now apparently applies to everyone who seeks ‘to influence government policy, process or law’. This means that it will now apply to individual members of the public who write to their MP or make a submission to a select committee. It will apply to church and community groups, to incorporated societies such as the Council, to charities, to trades unions, and to companies advocating on behalf only of themselves, not third parties.

The broadened definition also means that it now applies to iwi and other Māori, and their interactions with government. As the Ministry’s other work on this issue shows, it is acutely aware of the complexities in relation to Māori, and the need to distinguish between groups advocating on issues concerning the upholding of Te Tiriti o Waitangi, and lobbying on matters such as contracts and concessions.¹²

At the same time as the definition has been massively widened, the Ministry does not seem to have appreciated that such a change has major implications for the rights that people have under the New Zealand Bill of Rights Act, and the country’s compliance with its obligations under the International Covenant on Civil and Political Rights and other international human rights standards. If it had, the Ministry would surely have recognised that the publicity and communications effort around its work on the draft Code would need to be massively stepped up, not least to include holding workshops around the country with the public, civil society organisations and businesses.

The Council appreciates that for the wider lobbying regulatory system that is needed, the definition of who is a ‘lobbyist’ is an important and potentially difficult question which needs careful and open analysis that invites input from the public. But if the Ministry returns to the task given to it by the Prime Minister, it can draft a simpler definition that ensures the Code applies only to those the Prime Minister intended: professionals who lobby on behalf of third parties. They may be in dedicated ‘government relations’ companies, law firms, communications or public relations agencies, or in industry umbrella groups, but they are a definable group of people that are separate from those who lobby only on behalf of their own organisation or members, or the public at large.

The Council notes the definition in the Australian federal government’s Lobbying Code of Conduct is designed to apply to professional lobbyists working on behalf of third parties, and expresses the definition in the following way:¹³

A lobbyist means any person, company or organisation that conducts lobbying activities on behalf of a third party client or whose employees, contractors or persons otherwise engaged by the person, company or organisation conduct lobbying activities on behalf of a third party client.

Despite subsection (2), a lobbyist does not include any of the following:
charitable, religious and other organisations or funds that are endorsed as deductible gift recipients;
non profit associations or organisations constituted to represent the interests of their members that are not endorsed as deductible gift recipients;
persons making representations on behalf of relatives or friends about their personal affairs;
members of trade delegations visiting Australia;
persons who are registered under an Australian Government scheme regulating the activities of members of that profession, such as registered tax agents, customs brokers, company auditors and liquidators, provided that their dealings with Government representatives are part of the normal day to day work of people in that profession;

members of professions, such as doctors, lawyers or accountants, and other service providers, who make occasional representations to Government on behalf of others in a way that is incidental to the provision to them of their professional or other services.

To avoid doubt, if a significant or regular part of the services offered by a person employed or engaged by a firm of lawyers, doctors, accountants or other service providers involves lobbying activities on behalf of clients of that firm, the firm and the person offering those services must be included on the Register of Lobbyists.

The Council also notes that section 2 of the United Kingdom’s Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014 defines ‘consultant lobbying’ in a more complex manner, with reference to exceptions in from the definition in Schedule 1 of the Act:¹⁴

(1)     For the purposes of this Part, a person carries on the business of consultant lobbying if—

(a)     in the course of a business and in return for payment, the person makes communications within subsection (3) on behalf of another person or persons,

(b)     the person is registered under the Value Added Tax Act 1994, and

(c)     none of the exceptions in Part 1 of Schedule 1 applies.

(2)     Part 2 of that Schedule makes provision about the meaning, for the purposes of this Part of this Act, of terms used in subsection (1).

(3)     The communications within this subsection are oral or written communications made personally to a Minister of the Crown or permanent secretary relating to—

(a)     the development, adoption or modification of any proposal of the government to make or amend primary or subordinate legislation;

(b)     the development, adoption or modification of any other policy of the government;

(c)     the making, giving or issuing by the government of, or the taking of any other steps by the government in relation to,—

(i)      any contract or other agreement,

(ii)     any grant or other financial assistance, or

(iii)   any licence or other authorisation; or

(d)     the exercise of any other function of the government.

(4)     It does not matter whether the person to whom the communication is made, or the person making it, or both, are outside the United Kingdom when the communication is made.

(5)     Regulations may amend subsection (3) so as to provide that communications made personally to a special adviser are within that subsection.

(6)     In this section—

“the government” means Her Majesty’s Government in the United Kingdom;

“Minister of the Crown” means the holder of an office in the government, and includes the Treasury;

“permanent secretary” means a person serving the government in—

(a)   the position of permanent secretary or second permanent secretary in the civil service of the State, or

(b)   a position listed in Part 3 of Schedule 1 (positions equivalent to those mentioned in paragraph (a));

“special adviser” means a person who serves the government in a position in the civil service of the State and whose appointment to that position meets the requirements applicable to that position set out in section 15(1) of the Constitutional Reform and Governance Act 2010.

Since the current piece of work by the Ministry is to assist with setting standards of conduct in a voluntary Code of Conduct, and not the drafting of legislation, the Council recommends changing the definition of ‘Lobbyist’ in the code to that used in the Australian Lobbying Code of Conduct. This would catch not only self-employed lobbyists, but also companies and, in paragraph 4 of the definition, lawyers.

Remainder of the draft Code

In all other respects, given that this should be a document that sets out government expectations for lobbying industry self-regulation, the Council recommends that the Ministry revert to the December 2023 draft of the Code.

If the lobbying industry in New Zealand does not want to live up to those standards then, at present, nothing compels them to. If the industry wants to produce a Code as weak as the second version the Ministry is currently consulting on, let it. The public will be able to judge how far the industry is falling short of the standards that the government expects of it, following public servants’ research and policy analysis, and a broader range of public input.

How will we know if the voluntary Code is working?

A key difference between the December 2023 draft of the Code and the current draft is that the section on Accountability has been eviscerated.

The December 2023 draft states:

Be accountable for actions

17.    Demonstrating how this code is being honoured and its provisions are being met will help build public trust in democratic process and lobbying activities.

17.1.   Monitor performance under the code and adjust behaviour if not meeting expectations as indicated in this code.

17.2.   Set up a process to monitor lobbying practices or behaviour that breach, dishonour, or do not align with this code, and ensure these are investigated and acted on.

However, the March 2024 draft is far weaker:

Be accountable for actions

17. Conducting business in a way that upholds the good practice expectations outlined in this code will help build public trust in democratic process and lobbying activities:

17.1. Establish a business culture that sets clear expectations about appropriate conduct and behaviour.

The earlier draft involved setting up a process to monitor lobbying practices or behaviour that breach the Code, and ensuring they are investigated and acted on. The current draft contains nothing of the sort, only wishy-washy words about ‘business culture’.

Aside from the fact that the December 2023 draft should be reinstated, even if that is done it cannot, as a voluntary Code, provide the government with meaningful data on how well it is operating. Without meaningful data on the operation and effects of the Code, the Ministry will be in the unenviable position in future of still claiming there is little evidence to help it with future policy development and consideration of whether to improve the regulatory approach.

The Council notes too that the professional lobbyists it consulted on the December 2023 draft have made contradictory statements about ‘evidence’ for problems with lobbying. In the Ministry’s 25 January 2024 summary of its meeting with the lobbyists, the Council notes that in paragraph 12 the lobbyists say ‘to their knowledge, there is no evidence of [bribery and corruption] happening in New Zealand’. In paragraph 13 the lobbyists say the Code is ‘seeking to address a problem that does not exist.’ But in paragraph 19, the Ministry’s notes say that the professional lobbyists told it that ‘In a small country, government relations consultants will have many personal relationships and they argued it is unrealistic to expect these will not be used for personal or commercial gain.’ Since the government relations consultants are in a position of power, thanks to their personal connections to ministers and senior officials, and a common definition of corruption is the abuse of a position of power for personal gain, what do these most ethical and upstanding lobbyists think this is, other than corruption? To us, it undermines their claims for a lack of evidence of corruption in New Zealand, and looks more like evidence that they themselves wouldn’t recognise corruption if they fell over it on Lambton Quay in broad daylight.

The Council is therefore clear that following publication of the final Code, the Ministry must draw up a draft paper on how monitoring of the Code could take place, including what data will be gathered and how frequently. It should then consult the public, not just the third-party lobbyists covered by the Code, on this draft paper and publish the feedback and final monitoring arrangements. It should, in line with the Ministry’s claims about the country’s ‘high levels of transparency’, ensure that the monitoring data is regularly published on the Ministry’s website and published as open data. Connecting the lobbying data to contract award notices and beneficial ownership information as well as political party donations will be easier if the Ministry uses the NZ Business Number of each lobbyist as the key identifier against which data is collected. The Ministry – and Ministers – will, of course, have to commit to funding this work to collect and publish the data. A failure to do this will lead to people drawing the obvious conclusions about the government’s commitment to a high integrity public service and public policy-making, and its interest in maintaining public trust in government.

Conclusion

Without

reverting to the December 2023 draft of the Code;
narrowing the definition of who is a ‘lobbyist’ under this Code; and
designing and implementing a meaningful monitoring regime

this project is on course to suffer a similar failure as New Zealand’s membership of the Open Government Partnership. The current intention that this is to be a self-regulated voluntary code which does not require sign-up will make it easy for that failure to occur. It will not result in an outcome in which there is greater public confidence that the integrity of public policy making is being protected, and that third party lobbyists are not acting to undermine that integrity. The Code will become another instance of New Zealand’s performative rather than substantive approach to good governance, and will rightly be ridiculed by the serious actors in this space, such as the OECD.

1
Draft Voluntary Lobbying Code of Conduct, Ministry of Justice 15 March 2024. https://www.justice.govt.nz/justice-sector-policy/key-initiatives/political-lobbying/voluntary-code-of-conduct-for-political-lobbyists
2
New measures to increase lobbying transparency, Prime Minister Chris Hipkins, 3 April 2023. https://www.beehive.govt.nz/release/new-measures-increase-lobbying-transparency
3
Political Lobbying Project, sixth newsletter, Ministry of Justice, March 2024. https://www.justice.govt.nz/assets/Documents/Publications/Update-6-15-March-2024.pdf
4
Update on the Political Lobbying Project, Ministry of Justice briefing to the Minister of Justice and Prime Minister, ref: LOB-08-02. 1 August 2023. https://www.justice.govt.nz/assets/Documents/Publications/20230829-Political-Lobbying-Briefing.pdf
5
Political Lobbying Project, fourth newsletter, Ministry of Justice, 29 September 2023 https://www.justice.govt.nz/assets/Documents/Publications/MOJ0710_01-Political-Lobbying-Project-newsletter-A4_Sept-29-update-2023.pdf
6
Political Lobbying Project: Feedback meeting on voluntary lobbying code of conduct, Ministry of Justice, 25 January 2024. https://www.justice.govt.nz/assets/Documents/Publications/Feedback-meeting-with-government-relations-consultants-25-January-2024.pdf
7
Ibid, Appendix 2: Draft voluntary lobbying code of conduct.
8
Political Lobbying Project: Feedback Summary. Summary of written feedback from consultation on a voluntary code of conduct with government relations consultants, Ministry of Justice, 15 March 2024. https://www.justice.govt.nz/assets/Documents/Publications/Summary-of-written-feedback-Government-relations-consultants.pdf
9
Draft Code of Conduct: Good practice expectations for lobbyists. Discussion draft v2.0 (March 2024). Ministry of Justice, 15 March 2024. https://www.justice.govt.nz/assets/Documents/Publications/Lobbying-code-of-conduct-Discussion-draft-March-2024.pdf
10
Open Government – Briefing to Minister Hipkins, part one: Secrecy Clauses. NZCCL, 8 February 2022. https://nzccl.org.nz/open-government-briefing-to-minister-part-one-secrecy-clauses/
11
Information request regarding the principle in section 12 of the Public Service Act 2020. Public Service Commission, 1 September 2023. https://www.publicservice.govt.nz/assets/DirectoryFile/Information-request-regarding-the-principle-in-section-12-of-the-Public-Service-Act-2020.pdf
12
Political Lobbying Project: Wider Regulatory Issues Hui. Summary of Te Tāhū of te Ture Ministry of Justice facilitated engagement hui with Māori and Iwi on issues with political lobbying. 21 September 2023. https://www.justice.govt.nz/assets/Documents/Publications/Summary-Political-lobbying-issues-Hui-with-Maori-21-September-2023-Final.pdf
13
Lobbying Code of Conduct, Attorney-General’s Department, Government of Australia, 28 November 2019. https://www.ag.gov.au/integrity/publications/lobbying-code-conduct
14
Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014. Government of the United Kingdom https://www.legislation.gov.uk/ukpga/2014/4

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