I'm not a lawyer, but.......
My way of thinking is that your company manuals form part of the exposition. They explain how the company is going to comply with the law. In other words, to ignore them means you are now making up your own method of complying with the law as you go along. Therefore, your chance of now breaching the law is rather high. In any case, to my knowledge, the daylight restriction in Queenstown is the same for all operators as it is the only acceptable method of complying with the law. This may well change with RNP AR ops, but has not yet.