Ref Sunak and Zahawi: a PM doesn't need an Ethics Adviser. An Ethics Adviser, unless a lawyer steeped in ethics or a senior civil servant with decades of constitutional expertise, has no particular expertise or qualifications that the PM himself or herself doesn't have, and certainly no more than the Parliamentary Commissioner for Standards.
Using the advice of an Ethics Adviser appointed by the one who decides on the issue, in the final instance, is not due process. Due process is a requirement that legal matters be resolved according to established rules and principles, and that individuals be treated fairly, not on the whim of the PM. Only a lawyer trained in ethics, or a senior Civil Servant, is qualified to pronounce judgement on such issues, not an ex banker, as the current Independent Adviser is.
The earliest published form of the Ministerial Code is a result of the QPM's release by the Major Government in 1992. Subsequent governments made various amendments, but the final arbiter was always the PM of the day.
The Adviser under Tony Blair was Comptroller and Auditor General Sir John Bourn. When Gordon Brown came into office in June 2007 he appointed Sir Philip Mawer, Parliamentary Commissioner for Standards, as the Independent Adviser on Ministers' Interests. Both of these individuals were senior Civil Servants with very responsible roles in Parliament and therefore well versed in government and parliamentary issues, having their work overseen by Parliamentary Committees of MPs.
Since 2020 (under a certain Boris Johnson), two Independent Ethics Advisers appointed by Johnson have resigned; one in protest over their advice not being heeded and the other for lies on the part of Johnson during an investigation. To lose one may be regarded as a misfortune; to lose two looks like carelessness.
Liz Truss didn't even think she needed an Independent Adviser.
Why can the Advisor not be the Parliamentary Commissioner for Standards?
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