Rubicon Strategy

Rubicon Strategy is a lobbying firm with offices in Ottawa and Toronto, Ontario.¹⁾ The company was co-founded by Kory Teneycke and Mike Coates, and represents a number of companies and organizations with interest in the COVID-19 crisis.

Teneycke served as Campaign Manager for Doug Ford’s successful campaign for Premier of Ontario in 2018.²⁾ He incorporated Rubicon Strategy on June 27, 2018, corporate filings show, just 20 days after the election.³⁾

While Teneycke is prevented by law from representing clients to the government he helped elect, he can legally profit through the junior colleagues he employs at Rubicon.⁴⁾

On March 17, 2020, a state of emergency was declared by Premier Doug Ford using the Emergency Management and Civil Protection Act, following the World Health Organization’s declaration of a pandemic six days prior.^{5) 6) 7)}

Rubicon's main webpage advertises that they “have elected Premiers in Ontario and Alberta” by “shaping public opinion,” and other online strategies. Simultaneously, the company describes itself as “trusted advisors to companies and associations in health care, gaming, cannabis, government procurement, entertainment, environment, energy, natural resources, and more.” Rubicon also boasts itself as “a premier aerospace and defence group comprised of battle-hardened experts in the areas of Canadian federal procurement with a focus on policies, practices, politics, procedures and the detailed requirements of complex military acquisitions.”

Teneycke is the co-founder and CEO of Rubicon Strategy. He has a long resume in Canadian politics and business. He served as Director of Communications to Prime Minister Stephen Harper from July 7, 2008 until shortly after July 28, 2009.^{8) 9)} He has weaved through various media roles including consulting and executive roles at SUN TV, and as a “pundit” on CTV News and CBC (where he still writes opinion pieces).^{10) 11)}

He returned to politics in 2015 to act as Chief Spokesman for the Conservative Party in advance of that year’s federal election.¹²⁾

He is currently on leave from Rubicon to act as the campaign manager for the Ontario Progressive Conservative Party in the 2022 election cycle.¹³⁾ Despite this declaration, Teneycke and his corporate partners still profit from his team’s lobbying on behalf of several companies promoting COVID-19 related policies.¹⁴⁾ This clear conflict of interest has been pointed out before, including by Democracy Watch who revealed that Teneycke had been “let off” by the Integrity Commissioner after violating Ontario’s lobbying laws.¹⁵⁾ His response to the accusations of wrongdoing by Canada Christian College President Charles McVety was to call him a “conspiracy theorist” and state that McVety “is to Canadian politics what Alex Jones is to U.S. politics.”

This seems to be a go-to defense for Teneycke. While actively working with the Ford government, he criticized MPP Rick Nicholls for declining a COVID-19 injection and called him a “kooky conspiracy theorist”.¹⁶⁾ Nicholls announced he would not abide by the Progressive Conservative Party’s “mandatory vaccination” policy, which was swiftly followed by his public dismissal by Premier Doug Ford.¹⁷⁾

His confrontational attitude predates COVID-19. During a February 2020 Convention for the Ontario PC Party, he remarked that Ford’s critics are protesting in the streets not because of cuts to education or attacks on workers’ rights, but because they have “gotten fat off the largesse of past regimes.”¹⁸⁾

Teneycke incorrectly stated that “pharmaceutical companies are not lobbying for vaccine passports anywhere in the world, to his knowledge, citing the ‘near infinite’ demand for their Covid shots.” Today, this is misleading at best, given that several countries have explicitly asked the companies in question to stop sending doses due to oversupply and lack of demand.^{19) 20)} At worst, he is knowingly lying given that Rubicon represents Providence Therapeutics who are themselves making a COVID-19 mRNA vaccine product, and who specifically mention influence over “vaccine passports” in the lobbying registration.

Coates is the co-founder and Executive Chairman of Rubicon Strategy. He has been a contributor to the Huffington Post, and CEO of Hill+Knowlton Strategies (which is associated with the business community of the World Economic Forum).^{21) 22)}

He lobbied for Providence Therapeutics - a company developing “personalized mRNA-based vaccines against cancers” - from June 16, 2020 until July 16, 2021, with the goal of “asking for funding so that they can increase their capacity to produce a vaccine for COVID-19”.^{23) 24) 25)}

To accomplish this, Coates communicated with the Offices of the Ministers of Colleges and Universities, Economic Development Job Creation and Trade, and Health, as well as the Premier and Cabinet offices and Members of Provincial Parliament (MPPs).

Another group Coates formerly lobbied for is Medical Pharmacies Group Ltd., from February 26, 2020 to June 23, 2021.²⁶⁾ Despite his working on the Ford campaign transition team in 2018, he does not report as such on this particular registration. The goal for this effort was “to get the government to re-examine its policy on capitation funding model for pharmacies servicing long term care homes.”

Of particular interest is Coate’s work on behalf of the Ontario Medical Association from July 16, 2019 until March 23, 2021, during the entirety of the first year of the COVID-19 crisis.²⁷⁾ The stated goal of his lobbying for the OMA was to advocate “for more funding in mental health, addictions and housing supports, reducing hospital wait times, ending hallway medicine and building 15,000 long-term care beds in five years”.

According to the filing, Ontario Medical Association “represents the political, clinical and economic interests of the province's medical profession.” The organization receives significant funding through the Ontario Medical Foundation from the following pharmaceutical companies:²⁸⁾

• AstraZeneca Canada Inc.
• Amgen Canada Inc.
• Bayer Inc.
• GlaxoSmithKline Inc.
• Merck Frosst
• Pfizer Canada Inc.
• Pharmacia Canada (Now a Pfizer company. Former parent company of Monsanto.)²⁹⁾

Coates also previously consulted and lobbied for Loblaw Companies Ltd, Gowlings WLG, Cassels Brock & Blackwell LLP, TMX Group and Bruce Power Inc. He is currently registered as actively lobbying for KWG Resources Inc, Teranet, Cubic Transportation Systems Canada Ltd, and Behaviour Interactive Inc.

Letersky worked on the Progressive Conservative Party’s campaign in 2018 with Teneycke, then worked as Director of Communications for the Minister of Economic Development, Job Creation and Trade from June 2018 to June 2019. She then served as Chief of Staff in Premier Doug Ford’s government from June 2019 until August 2020. She was hired as Vice President at Rubicon Strategy the following month in September 2020.³⁰⁾

She is a registered lobbyist for a long list of companies with direct interest in profitable COVID-19 policies. One such company is Amazon, who is engaging the Ford government on “COVID-19 health and safety” and “participating in government policy discussions about COVID-19 vaccine rollout”, among others.³¹⁾

Alongside her colleague Mike Coates, Letersky is also lobbying for Providence Therapeutics. Rather than funding, however, her focus is ensuring that “individuals participating in COVID-19 vaccine clinical trials, as approved by Health Canada, are eligible to enter and work in places where proof of vaccination is required.”³²⁾ This almost certainly refers to Providence’s own mRNA COVID-19 vaccine product in development.

Further, Letersky represents Innovative Medicines Canada, an association of pharmaceutical companies that includes COVID-19 vaccine developers AstraZeneca, Janssen/Johnson & Johnson, and Pfizer, as well as AbbVie, Amgen, Bayer, Bristol-Myers Squibb, Eli Lilly, Emergent Biosolutions, Gilead, GlaxoSmithKline, Roche, Medicago, Merck, Novartis, Sanofi and roughly a dozen others.³³⁾ Their lobbying seeks to “collaborate with government to ensure ‘Transfer of Value’ Regulations avoid unintended consequences and support a sustainable, balanced and credible approach” surrounding the “Health Sector Payment Transparency ACT”.³⁴⁾

Doubling down on Janssen Inc, she is actively lobbying for the company to “engage in discussions with MPPs and staff about current and emerging policies impacting the evaluation, marketing, sale or use of pharmaceutical products in Ontario.” In particular, the registration references the “pan-Canadian Pharmaceutical Alliance, National Pharmacare, Changes to the Patented Medicines Product Review Board, The use of real-world evidence in the evaluation of pharmaceutical products.” Finally, Letersky is engaging MPPs and staff directly “that have questions about the Johnson and Johnson COVID-19 vaccine.”³⁵⁾

She has also previously lobbied for AstraZeneca from January 2021 until June 2021, advocating for their interests in “the evaluation, marketing, sale or use of pharmaceutical products in Ontario”; “the status and distribution of vaccines related to COVID-19, working with the Ministry to develop a policy for personalized medicine, policies related to biologics/biosimilars and therapeutic area forced switches for patients, outcomes/values based agreements and rare disease drugs.”³⁶⁾

The registrations specifically lists the following concerning Lobbying Targets:

• Office of the Minister of Health
• Office of the Premier and Cabinet Office
• Office of the Attorney General of Ontario
• Ministry of Health

Letersky is also currently lobbying on behalf of Sheridan College, Sienna Senior Living, Manulife, Ontario Hospital Association (more detail in the “Patrick Harris” section), Ontario Association of Radiologists, Cadillac Fairview, Canadian Niagara Hotels Inc, Behaviour Interactive Inc, PMML Corp, Sonderbloom and CareRx.

Her expired/former registrations include Cubic Transportation Systems Canada Limited, Medical Pharmacies Group Limited, ShipperBee Inc, and Ontario Medical Association.

O’Driscoll is Senior Vice President at Rubicon Strategy. He formerly served as Chief of Staff for three Ford Cabinet ministers - Minister of Natural Resources and Forestry (July to November 2018), Minister of Transportation (November 2018 to June 2019), and Minister of Environment, Conservation and Parks (June 2019 to January 2020). He was hired at Rubicon the same month he left his prior position.³⁷⁾

He is registered as an active lobbyist for Amazon with lobbying goals related to “COVID-19 health and safety”, “COVID-19 testing and tracing efforts, COVID-19 vaccine rollout, economic recovery efforts”. Listed targets are Office of the Minister of Health, Office of the Premier and Cabinet Office, Office of the Solicitor General of Ontario, and the Ministry of Health.³⁸⁾

Like his colleague Mr. Coates, O’Driscoll lobbied for Providence Therapeutics from May 2020 until July 2021, seeking “funding to increase their capacity to produce a vaccine for COVID-19.³⁹⁾

Other prior clients include Keiwit Canada Group Inc, Greater Toronto Airports Authority, Corbett Land Strategies, Insurance Insight, Moves, Properly Operations Inc, Himelfarb Proszanski Barristers & Solicitors, and Loblaw Companies Limited.

His current registrations also include Joint Electrical Promotion Plan, Provincial Building and Construction Trades Council of Ontario, Canadian Niagara Hotels Inc, Teranet, Mott MacDonald, Cadillac Fairview, Pattern Energy, Direx Solutions Ltd, South Essex Fabricating Inc, The Ontario Pipe Trades Council (OPTC), KWG Resources Inc, and Cubic Transportation Systems Canada Limited.

Harris is Managing Partner at the Toronto office for Rubicon Strategy who “changes government policy”. This is literally true, as he is the 4th Vice President of the Progressive Conservative Party of Ontario.⁴⁰⁾

He has represented several pharmaceutical companies, and is currently lobbying on behalf of Janssen Inc. The listed goals are the same as described in Letersky’s registration (seeking input on drug regulation and advocating directly to government staff on behalf of the Johnson & Johnson COVID-19 vaccine product).⁴¹⁾

Also like Letersky, Harris currently lobbies for Innovative Medicines Canada (which represents Pfizer, Janssen, AstraZeneca and other COVID-related pharma companies like Merck and Gilead).⁴²⁾ Among other things, the group aims to provide “input on any new policy or program that may be related to pharmaceutical drug policy in Ontario and that may have an impact on Innovative Medicine Canada member companies and/or patient access to medications in Ontario”.

AstraZeneca was in Harris' portfolio from January 20, 2021 until July 21, 2021.⁴³⁾ In addition to interests already mentioned, the company used Harris to lobby to “participate in government discussions surrounding the development of a provincial life sciences strategy, educate the government on policies that will attract innovative medicine investment and manufacturing to Ontario.”

Once again, Amazon appears on the list of active Rubicon clients. Harris continues to lobby for the mega corporation’s seat at the table on decisions surrounding “COVID-19 health and safety” and “COVID-19 vaccine rollout”.⁴⁴⁾

Harris also joins his colleagues in formerly representing the Ontario Medical Association (funded by AstraZeneca, AMGEN, Bayer, GlaxoSmithKline, Merck, Pfizer and Pharmacia Canada) from March 22, 2021 and July 20, 2021.⁴⁵⁾

Other active registrations include CareRx (to “help LTC homes deal with the ongoing COVID-19 pandemic and recovery efforts,” including “discussing a review of the government's policy on capitation and MedsCheck”);⁴⁶⁾ the Ontario Association of Radiologists (to discuss “the COVID 19 surgical backlog, investments in new technology or upgrades to existing technology, and the work of radiologists in the health care system”);⁴⁷⁾ Sienna Senior Living (to “discuss ways that Sienna Senior Living can assist with the ongoing COVID-19 recovery efforts and planned LTC sector transformation”);⁴⁸⁾ Arbor Memorial Inc. (to “discuss the impacts of COVID-19 on the funeral and cemetery industry”);⁴⁹⁾ the Ontario Hospital Association (to “discuss potential amendments to bill 218 that will enhance the legal protections such that they recognize the exceptional risks being borne by hospitals through the COVID-19 pandemic”);^{50) 51)} and the Council of Ontario Universities (to “work with the government to ensure that Universities are able to open safely in the wake of the COVID-19 pandemic”).⁵²⁾

Harris previously lobbied for Medical Pharmacy Group Ltd from October 6, 2020 until October 14, 2021 to “discuss ways that Medical Pharmacies can help Long-Term Care homes deal with the COVID-19 pandemic” including “discussing a re-examination of the government's policy on capitation and medscheck.”⁵³⁾

Even while working at Hill+Knowlton Strategies, Harris lobbied for Valeant Pharmaceuticals International Inc.⁵⁴⁾

According to her bio on Rubicon’s front page (where she is a Senior Consultant) Simundson worked in the “war room” for the PC Party’s 2018 election campaign that led to Ford’s election. She claims her guidance “elected 17 of the PC MPPs in Peel Region, Halton, Toronto and Northern Ontario.”

She is currently lobbying for Arbor Memorial Inc and Innovative Medicines Canada - the latter of which wants to “collaborate with Ontario to ensure timely review of medications”.^{55) 56)} Her other clients include the Council of Ontario Universities, South Essex Fabricating Inc, Direx Solutions Ltd, Mott MacDonald, Pattern Energy, Cubic Transportation Systems Canada Limited, Teranet, ProCom and Canadian Niagara Hotels Inc.

Former clients are Properly Operations Inc, Kiewit Canada Group Inc, Windstream Energy LLC, Toronto Wholesale Produce Association and Toronto Farmers Association, Greater Toronto Airport Authority, Cassels Brock & Blackwell LLP, Healthcare Insurance Reciprocal of Canada, Himelfarb Proszanski Barristers & Solicitors, Loblaw Companies Limited, MedMen Canada Inc, Grasshopper Solar Corporation, IBM Canada, Museum of Contemporary Art Toronto (MOCA), PearTree Financial Services Ltd, and Maple Leaf Foods Inc.

Delorme is Director of Operations at Rubicon. Prior to this, she worked alongside her Rubicon colleagues for the PC Party’s 2018 election campaign, the Manager, Caucus Tour for the House of Commons and the Conservative Research Bureau, and President of the Conservative Party Electoral District Association for Ottawa-Vanier.^{57) 58) 59) 60)}

She also worked at Sun Media as the Office Manager of their Parliamentary Bureau from 2011 until 2015.⁶¹⁾ Delorme’s former lobbying clients were KWG Resources Inc, IBM Canada and PearTree Financial Services Limited.⁶²⁾

Smithman is Vice President at Rubicon Strategy.

He formerly held positions in the Office of the Premier of Ontario as Special Assistant for Correspondence and Special Operations Assistant from 2003 until 2008, then became Senior Policy Advisor with the Government of Ontario from 2009 until 2012. From there, he took a job as Manager of Government and Public Relations at Samsung Renewable Energy, then in 2016 moved to Enbridge Gas Inc. where he was Manager of Government Affairs. He has held board positions for the Ontario Energy Association and the Empire Club.⁶³⁾

He is actively lobbying on behalf of the Ontario Association of Radiologists, to “engage in discussions with MPP's and staff about current and emerging policies impacting hospital procedures, technology, and the wider healthcare sector. This includes the COVID 19 surgical backlog, investments in new technology or upgrades to existing technology, and the work of radiologists in the health care system.”⁶⁴⁾

Like his colleague Patrick Harris, Smitheman is also working for Sienna Senior Living to “discuss ways that Sienna Senior Living can assist with the ongoing COVID-19 recovery efforts and planned LTC sector transformation.”⁶⁵⁾

Andrew Balfour is a Managing Partner for the Ottawa branch of Rubicon Strategy.

He lobbies the House of Commons of Canada on behalf of Innovative Medicines Canada.⁶⁶⁾