There are some interesting rules in the government document entitled Open and Accountable Government. It deals with the appearance of conflict of interest and the fact that you cannot peddle access to a minister.
You said that the document exists, but you have no authority over it and it does not fall under your responsibility. It’s actually a guide with empty promises. As far as you’re concerned, there are no legal consequences unless we include relevant and interesting rules that would be in the Conflict of Interest Act.
Should a serious government include those rules in the act? The government is very proud of those rules and uses them to defend itself, but it does not include them in the act. Basically, it is beyond the scope of your responsibilities.
Should the government include those rules in the act? In that way, you could at least address them.