And Simon, is this a wholly new development or are private sector organisations already abiding by similar legislation in Europe?

So I think the short answer is no, this is not a wholly new development.

Many private sector organisations operating in Europe already have anti-bribery and corruption programmes that have been shaped by legislation such as the UK Bribery Act, as well as, of course, national anti-corruption laws across EU member states.

So in that sense, the directive is building on foundations that many organisations have been putting in place for over a decade.

But I don't think businesses should dismiss this as simply more of the same.

There are a few areas where the directive goes further or at least takes a different approach.

And one example is corporate liability.

That could include, for example, areas of the organisation where bribery and corruption awareness or oversight is limited, with the potential to invoke fines linked to a lack of supervision or control if a bribe is paid.