Law on transparency, the fight against corruption and the modernization of economic life

So just reflecting on that, I think we've spent a lot of time talking about the points of contact between the EU directive on combating corruption and the UK Bribery Act from 2010, and that's understandable.

But there is also another key comparator here to help us establish a direction of travel, and that's the French Lois-Sapin-Deux from 2017.

Whereas the UK Bribery Act established this concept of adequate procedures as a defence for those organisations accused of failing to prevent bribery, and it issued high-level guidance on what an adequate procedures compliance program might look like, the SAP and DOE went a step further.

Rather than simply setting out guidance, it legally required all InScope companies to implement an anti-bribery encryption compliance program with eight mandatory pillars.