The code is not a bill of attainder. Note that there are existing codes for other industries that operate along the same lines as the proposed code . e.g. The

The code is not a bill of attainder. Note that there are existing codes for other industries that operate along the same lines as the proposed code . e.g. The Telecom Industry Ombudsman operates via a code. The (non-government!) TIO has the government granted right to impose costs onto those companies that are deemed 'telecoms operators'.