Implied. But because of the general application loophole where you can be involved in a matter as long as it's a matter of general application and never be in a conflict—again, you could be the finance minister, own a million dollars' worth of shares in a bank, and still be making changes to the Bank Act—then the appearance of apparent conflict of interest standard does not apply. That would be an appearance of a conflict of interest, right? Most people would say if the finance minister owns a million dollars' worth of shares in a bank and is changing the Bank Act, that appears to them to be a conflict of interest, but because of the general application loophole, that standard is not enforced.
That's the most important loophole to remove. If you're in the appearance of a conflict of interest, whether it's a specific matter you're dealing with or a general matter, you have to recuse yourself.