ICAC said it was satisfied that Mr Kazal provided more than $11,000 for Mr Kelly's 2007 trip to the United Arab Emirates (UAE) and hinted about a job for him.
Mr Kazal did this with the intention to "influence Mr Kelly to exercise his official SHFA functions in a manner favourable to the Kazal business interests", it found.
But while the commission found Mr Kazal's conduct could constitute an offence, it also said there was not sufficient admissible evidence to prosecute him.
In a civil hearing before the NSW Supreme Court earlier this week, Mr Kazal's barrister Robert Sutherland, SC, said this created "tension", which invalidated the corrupt conduct finding as the two facts could not stand together.
Mr Kazal had called for a declaration that the commission's report was made "without jurisdiction or in excess of jurisdiction and was a nullity" and that the findings were "wrong in law".
"The effect of Mr Kazal's submission would appear to be that in proceeding to a finding of corrupt conduct ... the Commission was not entitled to rely upon evidence that would be inadmissible in a criminal trial.
"The authorities do not support that proposition," he said.
In a hearing earlier this week, ICAC's barrister, Todd Alexis, SC, said the commission was not bound by the rules or practice of evidence as material gathered during an inquiry - such as a confession - could not always be used in subsequent criminal proceedings.
Mr Kazal's summons was dismissed with costs.