On this, I have some sympathy for her because she's struggling with the fact that the rules themselves were not brilliantly drafted. They do create situations where two parts of the rules can be seen to some degree as one being more permissive than the other. This is true with gifts. As long as that's the case, she appears to be adopting the view that she will take the more restrictive of the interpretations, which I suppose I'd probably do if I were her too.
Having said that, it seems to me that the best way of resolving it is ultimately to change the rules to remove those restrictions. My own recommendation would be that we chat with each other—and we can do it offline if we're worried it will take up too much committee time—and see if there's a developing consensus. It would be to see if we can find a way of adjusting the wording of that part of the ethics code so there is greater precision.
I think that's the only solution.