An Ottawa-based watchdog group believes that two opposition MPs didn't raise all possible violations of the ethics rules in their request for a conflict-of-interest investigation of Prime Minister Justin Trudeau.

So Democracy Watch has written to ethics commissioner Mario Dion requesting a second probe that will examine if anyone acting on Trudeau's behalf participated in or attempted to influence a public servant's decision regarding a sole-source $19.5-million contract to WE Charity.

In its letter to Dion, Democracy Watch has requested that he recuse himself from conducting the inquiry "because you were appointed by the Trudeau Cabinet, and also because of your statements showing bias against effective enforcement".

"Your communications state that you are not going to investigate one of the most important allegations raised by this situation, namely: Did the Prime Minister and/or anyone acting on his behalf in the Office of the Prime Minister or the Office of the Privy Council, and/or a deputy minister, associate deputy minister, deputy head or associate deputy head in the Government of Canada acting on his behalf, participate in the decision or attempt to influence anyone’s decision to recommend a solesource contract be given to WE Charity?" wrote board member Duff Conacher on behalf of Democracy Watch.

The 14-page letter was released after the Globe and Mail published an article noting that the prime minister's chief of staff, Katie Telford, did not recuse herself from discussions around the contract to WE Charity to administer the $900-million Canada Student Service Grant program.

"Democracy Watch’s position is that there is reason to believe that there was an attempt by the Prime Minister or someone acting on his behalf participate in the decision or to influence the recommendation to give WE Charity a sole-source contract and that, therefore, this part of the situation needs to be investigated," Conacher wrote.

Democracy Watch has also asked for an ethics probe into Finance Minister Bill Morneau, who did not recuse himself from cabinet discussions about the contract to WE Charity even though it employs his daughter.

Over the years, Me to WE, a private company owned by WE Charity founders Craig and Marc Kielburger, has paid Trudeau's mother $312,000 (minus a 20 percent commission to her agency) and brother $40,000 (minus a 20 percent agency commission) to speak at events, according to Canadaland.

Money flows back and forth between Me to WE and WE Charity, according to Charity Intelligence, which monitors registered charities.

Trudeau's wife does a free podcast for the charity and has had travel expenses reimbursed when she's spoken at the charity's events. Conacher's letter cites WE Charity's description of her as "more than an ambassador of WE Well-being, she is its mentor, booster and champion".

Conacher's letter pointed out that section 7 "would be violated whether the Prime Minister's spouse or Marc Kielburger or Craig Kielburger are determined to be the representatives of WE Charity, given the Prime Minister has a long-term relationship with all of them".

In response to requests for an investigation by Conservative MP Michael Barrett and NDP MP Charlie Angus, Dion's office cited possible contraventions of sections 6(1), 7, and 21 of the Conflict of Interest Act.

Section 6(1) of the act states: "No public office holder shall make a decision or participate in making a decision related to the exercise of an official power, duty or function if the public office holder knows or reasonably should know that, in the making of the decision, he or she would be in a conflict of interest."

Section 7 states: "No public office holder shall, in the exercise of an official 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 21 requires public office holders to recuse themselves from any discussion, debate, or vote on matters in which they would be in a conflict of interest.

Conacher, however, also wants an investigation into whether Trudeau violated section 9 of the act.

It states: "No public office holder shall use his or her position as a public office holder to seek to influence a decision of another person so as to further the public office holder’s private interests or those of the public office holder’s relatives or friends or to improperly further another person’s private interests."

"To be complete, the inquiry must examine all communications concerning the WE Charity contract (letters, faxes, emails, texts, pins, phone calls, virtual calls (Zoom, FaceTime, Skype etc.)) between and amongst everyone involved: public servants, Cabinet ministers, ministerial staff or Cabinet appointees (including deputy ministers, associate deputy ministers, deputy heads and associate deputy heads), and representatives of WE charity," Conacher wrote.

In addition, Democracy Watch released a 10-page letter that it mailed to the RCMP on Friday (July 10) seeking an investigation into whether there was a violation of the Criminal Code section dealing with breach of trust.

"Under the Supreme Court of Canada’s ruling in R. v. Boulanger (para. 58), there is a five-part test for breach of trust," Democracy Watch stated. "The WE Charity contract situation involves evidence for all five parts, as the Prime Minister 1. is a public official; 2. who took part in an official decision; 3. That violates the ethics standards for his office; 4. and violates those rules in a significant way, and; 5. the Prime Minister made dishonest statements to excuse his participation in the decision, all to unethically further the financial interests of one of his wife’s favourite charities."

None of these allegations have been proven in court.

Update

In his morning briefing today, Justin Trudeau apologized for not stepping aside from cabinet discussions that led grant the sole-source contract going to WE Charity to administer the Canada Student Service Grant program.

“I made a mistake in not recusing myself immediately from the discussions given our family’s history," Trudeau told reporters. "I’m sincerely sorry about not having done that.

"I got into politics to help people shape their country for the better. I’ve been youth critic and youth minister for our government. Every step of the way, I’ve tried to create opportunities for young people to serve."