Hyra v. Her Majesty the Queen et al, 2013 MBQB 83 says that a breach of professional conduct rules does not give rise to a cause of action. Presumably if a recognized tort – say negligence – was alleged a breach of professional rules might well be good evidence supporting such claim; however, standing alone, a breach is not a tort:
 With respect to the alleged cause of action of a violation of The Professional Code of Conduct, I am not aware of the existence of any such cause of action. While a breach of The Professional Code of Conduct may lead to discipline from the relevant Law Society, such breaches do not form a cause of action. Thus, there is no reasonable cause of action for violation of The Professional Code of Conduct.