The difference between the code and the act is that, once a member of Parliament leaves their parliamentary functions, they are no longer subject to the code in any way.
You didn't refer to the member in question by name, but it was Mr. Baylis. As a former member of Parliament, he is no longer subject to the Conflict of Interest Code for Members of the House of Commons and was not subject to it when the contract was being discussed or awarded. Nevertheless, the contract was not concluded with him.
As far as the code is concerned, it simply does not apply to Mr. Baylis. We also looked at the public office holders who were involved in awarding the contract and we decided that, at this point, there are no reasonable grounds to believe that the act may have been breached.