According to a report filed with the federal lobbying commissioner by Barrick Gold Corp. on Aug. 27, Nigel Wright, the prime minister's chief of staff, was lobbied by the company a third time on May 29.
Barrick lobbied Wright for the first time on May 14 and a second time on May 25. Those two conversations were reported on July 30.
Under lobbying rules, the report on all three meetings should have been submitted to the federal lobbying commissioner by June 15.
On Tuesday, Foreign Affairs Minister John Baird told CBC News that Wright was not in a conflict of interest and did not use his position to further the financial interests of his friends.
Baird said Wright "has no personal or financial interest in Barrick Gold Corp." and that while a number of people were on the call with Barrick, Baird said "it was a one-way call where they called and raised an issue, and it was dealt with by someone else in the office."
The minister said Wright "didn't take part in any decisions on this issue."
However, Baird did not explain why Wright was on a second call with Barrick, nor did he mention that Wright was involved in a third call.
Wright has known Barrick founder and board chairman Peter Munk for years and is particularly close to his son, Anthony, who sits on Barrick's board of directors.
Ethics watchdog following-up with Wright
A spokesperson for Mary Dawson, the federal ethics commissioner, told CBC News on Tuesday that she is following up with Wright after the disclosure that he was lobbied twice by Barrick.
While Dawson can initiate an investigation, her office confirmed that no official complaint had been filed to date for her to do so.
The first report filed by Barrick does not identify who contacted Wright on May 14 to discuss international relations and international trade.
The second report indicates that Barrick talked to Wright again on the same subject matter — this time along with Harper's foreign policy adviser, Andrea van Vugt, and his principal secretary, Ray Novak, who is Harper's point man on government-to-government relations.
Barrick's contact with Wright came shortly after Harper blocked a resolution on Argentina's claim to the Falkland Islands during the Summit of the Americas in Colombia in mid-April.
Barrick operates a mine in Argentina and is developing another controversial open pit gold and silver mine that straddles the border between Chile and Argentina.
Conflict of Interest Act
A person doesn't necessarily need to be involved in actual decision-making to wind up in a conflict of interest.
Under the Conflict of Interest Act, a public office holder is supposed to recuse himself or herself from "any discussion, decision, debate or vote on any matter" which could result in a conflict.
The act describes conflict of interest as the exercise of "an official power, duty or function that provides (the public office holder) an opportunity to further his or her private interests or those of his or her relatives or friends or to improperly further another person's private interests."
On the advice of the federal ethics watchdog, Wright set up a "conflict of interest screen" when he joined the Prime Minister's Office.
The screen is meant to ensure that Wright abstains from any participation in matters relating to private equity investment firm Onex, its subsidiaries and affiliates or even involving general policy matters, such as tax treatment of the private equity industry, that could affect Onex.