The main difference is that, at present, we do not have an equivalent legislation to your Conflict of Interest Act. We rely primarily, as I said, in the House of Commons, on a code of conduct, and in the House of Lords on their code of conduct. There is a ministerial code for ministers, which, again, is a quasi-legislative mechanism and not legislation.
The biggest difference between us at the moment is that you do more by legislation that we do by quasi-legislation.