Overall I agree with the draft Code Standard. My comments only apply to the commentary under the standard. I agree in general with the “Where practicable, avoid conflicts of interest” but suggest that this should not preclude delivery of a service provided on the basis that commission shall be taken. I note MBIE's recent comments on the role of commission as a form of remuneration, and the International Association of Insurance Supervisors view on the matter too. Perhaps every adviser should offer a fee-only alternative. I discussed that with my compliance adviser, and we could end up with something of a pantomime of not-really-an-option-fee-offers. The commentary should support the decision of our legislators to allow commission, but to require the conflict to be managed. So I think it important to allow that a service can be provided on a commission basis despite the conflict, if the product or service would not otherwise be available to the client, or would require the client to incur additional inconvenience and cost to obtain the same product or service elsewhere, and the client still wishes to proceed.