The commissioner is an administrative tribunal. She's a quasi-judicial office already. She is judging. She is enforcing the law. She is finding people in violation.
If you have an apparent conflict of interest standard, you must either have a regulation that says what it means, or she has to issue an interpretation bulletin, or no one should go forward. It wouldn't be fair to have an appearance standard or a potential conflict of interest standard without defining what it means, because so many situations are there.
Right now you can't challenge the Ethics Commissioner in court on any of her rulings, even if she makes an error of fact or of law; no one is allowed to challenge her. That has to be eliminated. Everyone should be able to appeal to the courts on her rulings, especially if you were to bring in more rules, such as an apparent standard. If you were to bring in penalties, you need all those protections of due process that Mr. Calkins was talking about, so that you could appeal her rulings in court if you disagreed with them.