Yes, I know. But it says “shall submit any proposed rules for the administration”, and so on. It would imply “for approval”, but neither of these sections as drafted restricts the commissioner from doing it.
Further, if you go on to section 32, it indicates: “The Ethics Commissioner may undertake educational activities for Members and the general public regarding this Code and the role of the Ethics Commissioner.”
Earlier on in the code, you know there's the section that indicates that the commissioner can basically render generic or render non-personal any opinion for the benefit of members. Those also may be published. There are a lot of ways the commissioner has the power to issue interpretive guidelines, rules, or what have you. In my view, the way this is drafted for approval doesn't necessarily stop him from making it public. It depends on what the committee's role is in terms of guiding the commissioner.