I completely agree with that. What the Conflict of Interest and Ethics Commissioner assessed is not what you assessed. You looked at two different things. He looked at compliance with a code, and he found that the acts were not in compliance with that code. That does not mean it was criminal. In your case, lack of compliance with the code does not guarantee the results of an RCMP investigation.
In the investigations the RCMP usually conducts, for example in a case of theft, do you talk to the suspect, or do you only collect the information you deem sufficient?