Commissariat aux conflits d'inter?ts et a l'?thique Office of the Conflict of Interest and Ethics Commissioner 66, rue Slater Street 22? ?tage 22nd Floor OTTAWA, ONTARIO CANADA 0A6 CONFIDENTIAL December 13, 2016 The Honourable Rona Ambrose, P.C. Member of Parliament for Sturgeon River?Parkland The Valour Building, Suite 900 Ottawa, Ontario KIA 0A6 Subject: Concerns relating to fundraisers held in April, May and November 2016 Dear Ms. Ambrose: This is in response to your letter dated December 5, 2016 in which you request a full investigation into issues raised in relation to two fundraising events attended by the Right Honourable Justin Trudeau, P.C., M.P., the ?rst taking place on May 19, 2016 in Vancouver and the second on November 7, 2016 in Toronto, as well as one fundraising event attended by Mr. Bill Blair, M.P., Parliamentary Secretary to the Minister of Justice and Attorney General of Canada. In your letter, you set out concerns relating to possible contraventions of the Con?ict of InteresrAct (Act). You allege that individuals at the events had particular interests in relation to their dealings with the Government and that they received special access to Mr. Trudeau and Mr. Blair during the fundraisers. You raise one concern related to a fundraising event that took place on April 28, 2016 with respect to Mr. Blair. You allege that several people paid to attend the fundraiser in order to discuss topics related to marijuana legalization with Mr. Blair, including Ms. Abi Roach and Mr. Jon Liedtke, organizers of the Cannabis Friendly Business Association. You also raise three concerns related to the May 19, 2016 fundraising event attended by Mr. Trudeau. You allege that at the fundraiser, Mr. Trudeau had interactions with Mr. Thomas Liu, a Toronto businessman who has signi?cant ?nancial interests in canola exports to China, while there were ongoing negotiations with the government of China with regards to the nules surrounding canola exports. At the same fundraiser, you allege that Mr. Trudeau had interactions with Mr. Shengling Xian, founder of Wealth One Bank of Canada, and this bank received ?nal government approval as a Schedule I bank two months after Mr. Xian?s attendance at the fundraiser. Additionally, you allege that at the fundraiser on May 19, 2016, Mr. Trudeau solicited funds on behalf of the Pierre Elliott Trudeau Foundation. On June 2, 2016, a donation to the University of Montreal totalling $1 million by Mr. Zhang Bin and another person was announced. At that time, it was announced that the Trudeau Foundation would receive $200,000 of the donation. You also express concern regarding a fundraiser Mr. Trudeau attended on November 7, 2016 that was hosted by Mr. Miaofei Pan, who represents the Canadian Alliance of Chinese Associations. You write that Mr. Pan stated in an interview with the Globe and Mail that he attended the fundraiser to lobby Mr. Trudeau on a number of issues relating to investment by Anbang Insurance Group, the relaxation of immigration restrictions on Chinese investors and easing the ability of foreign real estate developers to invest in Canada. You allege that all these issues are apparently being considered by Cabinet or the Government of Canada. In your letter, you refer to sections 7 and 16 of the Act. Section 7 of the Act reads as follows: 7. No public o?ice holder shall, in the exercise of an o?icial power, duty or function, give preferential treatment to any person or organization based on the identity of the person or organization that represents the first?mentioned person or organization. Section 16 of the Act reads of follows: 16. No public o?ice holder shall personally solicit funds from any person or Organization if it would place the public office holder in a con?ict oftnter-est. Regarding section 7 of the Act, you refer to discussions with attendees at the events on a variety of topics that are currently being studied by Cabinet or the Government of Canada. In order to establish reasonable grounds that a contravention of section 7 may have occurred, 1 would need some information indicating that following the event, Mr. Trudeau or Mr. Blair, in the exercise of their of?cial powers or duties, gave preferential treatment to any of the attendees. Your letter does not include any information to support such an allegation. To establish reasonable grounds that Mr. Trudeau or Mr. Blair may have contravened section 16 of the Act, I would need some information indicating that they personally solicited funds and that this would have placed them in a conflict of interest. Your letter does not contain information indicating that Mr. Trudeau or Mr. Blair may have personally solicited funds with respect to the events. While the information provided in support of the allegations is not sufficient to cause me to initiate an examination under the Act at this time, your letter and media articles leave me with concerns in relation to Mr. Trudeau?s interactions with individuals involved with the canola export agreement, Wealth One Bank, and Anban Insurance Group. Consequently, I will follow up with Mr. Trudeau regarding his involvement with the fundraising events and with the three above-noted matters. I will inform you of the outcome in due course. I also have concerns in relation to Mr. Blair?s interactions with individuals involved with the Cannabis Friendly Business Association and will follow up regarding his involvement with the fundraising event held on April 28, 2016. I will also inform you of the outcome in due course. In relation to the donation to the Trudeau Foundation, at this time I have found no evidence that Mr. Bin has dealings with or is seeking funding from the Government of Canada or that Mr. Trudeau had any involvement in soliciting the funds from Mr. Bin. Information in the public domain indicates that the terms of the donation to the Trudeau Foundation were negotiated between September 2014 and spring 2016, after Mr. Trudeau?s involvement with the Foundation had ended. I will therefore not be looking into this matter any further at this time. Sincerely, if) Mary awson Conflict of Interest and Ethics Commissioner