Couillard was not a registered lobbyist when she spoke with a high-ranking political aide on behalf of a Quebec company about a multimillion-dollar construction contract, says a newly released report by the lobbying commissioner.
"Ms. Couillard was paid to communicate with federal public office holders to obtain a contract," commissioner Karen Shepherd said Tuesday in a statement.
"This is a legitimate activity which requires registration. Ms. Couillard failed to submit information on her lobbying activities in the Registry of Lobbyists and, as such, I concluded she breached the Lobbyists' Code of Conduct."
Breaches of the code carry no fines or jail terms, but the commissioner is required to table a report to Parliament to present her findings and conclusions.
Couillard first caught the nation's eye when she arrived at a Rideau Hall swearing-in ceremony for her former beau, Maxime Bernier.
She became a household name in 2008 when, following her break-up with Bernier, her past ties with members of the Hells Angels were revealed.
Bernier resigned the Foreign Affairs post after admitting he left classified NATO documents at Couillard's Montreal-area home.
The lobbying commissioner launched a probe a short time later following reports Couillard tried to influence federal public office holders.
The commissioner's report says Couillard sought a contract for property developer Groupe Immobilier Kevlar Inc., for a 200,000-square foot development project in Quebec City.
At the time, she was a licensed real estate agent and ran a company called ITEK Global Solutions Inc.
The lobbying commissioner determined that Kevlar signed two agreements with Couillard and her company between March 2007 and June 2008. The first was contract to help Kevlar answer a request for proposals from Public Works. The second deal would pay Couillard a commission on the Quebec development project.
The investigation found Kevlar paid Couillard's company $51,277 for "consultancy fees for the RFP (request for proposals) file."
Couillard told the lobbying commissioner's investigators that she spoke mostly by telephone with Bernard Cote, a top adviser to former Public Works Minister Michael Fortier.
Cote resigned after it emerged that he briefly dated Couillard while she was lobbying his department on Kevlar's behalf.
The commissioner found no evidence Couillard lobbied Bernier or any other public office holder, besides Cote.
Couillard told the investigators she never meant to act as a lobbyist.
"According to Ms. Couillard, Mr. Cote did not have decision-making authority in relation to the contract. Ms. Couillard's perspective was that the contract could only be granted by the Treasury Board of Canada Secretariat," the report says.
"Ms. Couillard further stated that her communications were performed to obtain information regarding the conduct and progress of the request for proposals process by Public Works and Government Services Canada. In addition, Ms. Couillard indicated that she was inquiring whether it would be worthwhile for her client, Kevlar, to submit a proposal."
She argued her dealings with Cote were meant to ensure Kevlar had a complete and up-to-date proposal, the document says.
The commissioner disagreed.
"I have concluded that Ms. Couillard was paid to communicate with federal public office holders at PWGSC in respect of a request for proposals process by PWGSC for the construction and leasing of an office building in Quebec City, and that she failed to register her undertaking as required under the Lobbyists Registration Act."
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