Can you link this code of conduct? This is all I could find, http://www.biota.com.au/?page=1021030&subpage=1021177 and it does not support your assertions.
I note the share price was lower for almost two weeks after he bought. I feel confident if SP remained lower I would have read a miso post stating how James Fox conned people into buying via his pathetically small buy of 110,000 shares.