Conference calls are a grey area, I suppose. But unless the person who recorded the conversation was known to be "present" by the other participants, or was authorized to record it by someone who was known by the others to be "present", the recording sure looks like a violation of the criminal code to me. The code refers to the originator and the recipient, only two participants in the communication, but the intention seems clear: that the persons involved in the discussion may record it, and so may persons that they authorize to do so, but not others.