The problem with the article cited as the source is that it's unclear as to how many are former public servants or serving ones. Of course, Peers hold their seat in the Lords by virtue of appointment and title, and unless they quit, the implication is that at least some of these are basically side gigs and hence, not a revolving door (that would be how regulatory capture happens in the US and the mere fact that one can straight up a member of the Upper House, however broadly powerless it nowadays, is frankly, asking for the appearance of impropriety). Also 18 people still work there and the PR firm might have screwed up by making a statement that needlessly bring up the question of whether those who no longer work for companies and the veterans mentioned overlap in part or whole. The list of names don't add up to to 30, but 26.
But it'd be really helpful if this obvious moral hazard is explicitly enumerated in the law somehow. Look, the Commons runs the country, and the PM can't violate the constitution (not that there is one and I don't think it's a coincidence that countries have tended to write theirs down, apologies of Bagehot). Why does the Lords still exist when they are basically a rump branch anyway? If the lower house can simply legislate every aspect of it, it's a liability and not that great of a look from afar, whether some sort of influence peddling actually occurred or not. In the US the standard is appearance of impropriety in addition to actual bias and conflict of interest (as in, more than appearance) because this kind of relationship erodes public trust. At some point, it can't be worth the potential PR problem to keep around a rump branch of the government. There's almost 1000 years worth of sunk cost so gotta know when to let go. Are the OBEs and CBEs and all that honours list stuff not good enough? I'm with David Bowie on this one.