I didn't get past the first sentence I'm afraid
"If any section of this policy is contrary to the code of practice then good reason has been given"
how nice - I wonder if they realise it is statutory guidance - they can't just pick and choose whether to have regard to it -
TROUBLE is they don't have to COMPLY with it, they have to have REGARD to it - so unless the wording says "must" - you are still stuffed if CoP says "should" or other wooliness
To prevent any further unpleasantness I'm not reading any further :)