Understand Your Rights. Solve Your Legal Problems
The case was filed in the federal court on Wednesday by Katta O’Donnell, a fifth-year law student at La Trobe University in Melbourne, who owns Australian government bonds.
The suit argues that Australia’s economy will be severely impacted by its government’s response to climate change, and that it has failed to disclose these risks to investors. The court filing claims that, as a promoter of its bonds, the Australian government “owes a duty of utmost candour and honesty” to its investors regarding the material risks posed by climate change.
“The Commonwealth breached its duty as a promoter by ... failing to disclose any information about Australia’s climate change risks,” the filing continues.
The action seeks a declaration from the government that it breached its duty of disclosure and an injunction to prevent the further promotion of the government’s bonds until it complies with this duty.
David Barnden of Equity Generation Lawyers, who is backing O’Donnell’s case, said that he believed it to be the first to deal with climate change as a material risk to the global sovereign bond market.
“Australia is on the frontline of sovereign climate risk,” he said. “We confront the harrowing physical impacts of drought and bushfires and we also face the financial risks of an economy over-exposed to fossil fuels being left behind as the world shifts to clean energy.”
The Australian government is aware of the legal challenge.
“Legal representatives are considering the matter. As it concerns current court proceedings the government will not make any comment,” a spokesperson for the Australian government told Reuters.
More than most qualifications, a law degree will open doors to a wide range of sectors that may not be directly connected to your subject of study. A strong critical acumen, well-developed communication skills and a wealth of technical knowledge are all a necessary part of gaining a degree in law, and will stand you in good stead no matter what field you choose to enter once you graduate.
If you are currently studying law or thinking of studying it, it’s worth taking a look at some of the other career paths that your degree will let you access.
Legal counsel is sought after in every branch of government. US students will want to explore the options available to them at the local, state and federal levels and find the roles that appeal to them. One valuable source in the Washington, DC area is Opportunities in Public Affairs, which lists jobs on Capitol Hill in think tanks, non-profits and government institutions. Vacancies range across numerous fields, including government affairs, policy, legislation, PR, communications, fundraising, research, writing and journalism. Many of these jobs are entry-level or internships ideal for recent graduates.
Those in the UK may want to look into the Government Legal Service and its trainee scheme, for which the application deadline is 28 July. Also of note is the Civil Service Fast Stream, which offers around 700 graduate-level positions each year in a variety of government roles. Each of the Fast Stream’s tracks involves a series of intensive job placements that will leave participants equipped for a senior managerial role in the civil service, and most of them are open to law grads.
Outside of government and typical law firms or corporate placements, graduates with law degrees can often find employment in the financial sector. Law grads make attractive candidates for positions related to taxation, whether in chartered accountancy firms or dedicated tax consultant firms. Investment banks want legal professionals for research and regulatory roles; insurance companies need legal guidance on underwriting, claims and pensions. Knowledge of law is an attractive quality across the financial sector, and there is no shortage of jobs for the qualified.
For law graduates seeking jobs related to the above examples, it will be beneficial to have taken modules or classes in accounting, tax law or an adjacent subject. An undergraduate major in one of these areas would be especially beneficial for American students.
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Combining a “traditional” career as a barrister with one in a charitable foundation, non-profit legal aid societies can offer fulfilling work in representing the interests of the economically disadvantaged, similar to the pro bono work occasionally undertaken by for-profit firms. For US students, public interest opportunities can often be found on PSJD. In the UK, legal aid has been placed under greater restrictions in recent years, but remains a worthwhile field in which to specialise, and legal aid roles are often advertised by the Legal Aid Practitioners Group among other bodies.
If you have already begun a law degree, you have likely tapped into a range of online and print resources written by qualified lawyers. Westlaw, Infolaw, LexisNexis, Lawbore and other knowledge bases rely on staff-produced content, as do legal news sites like Jurist, Law.com, Legal Cheek, the Law Society Gazette and countless others, to say nothing of the many respected print and electronic journals that cater to legal professionals. All of these publications employ writers and researchers with backgrounds in law. For grads with an interest in journalism or publishing, any one of these outlets could provide a way into a creatively fulfilling career.
As mentioned at the beginning of this guide, legal qualifications open doors. The simple fact that you earned a law degree means that you are able to work diligently and apply a keen eye for detail to your job, and prospective employers will take note of this. Entry-level jobs in media, marketing, PR, human resources, teaching, advertising and accountancy are generally open to anyone who holds an undergraduate degree, and a background in law is a perfectly valid entry point in many cases.
If any of these areas appeal to you, it is highly recommended that you gain as much relevant experience as possible, ideally through internships or summer placements over the course of your degree. Be sure to tap into whatever career resources your college offers; they will likely be helpful in landing a placement, whether or not you have already graduated.
The Court of Justice of the European Union (CJEU) struck down a major EU-US data flows agreement called Privacy Shield due to the inadequacy of its protection for EU citizens’ privacy, according to a press release issued by the Court on Thursday.
The CJEU found that, under the terms of the EU-US Data Protection Shield “the requirements of US national security, public interest and law enforcement have primacy, thus condoning interference with the fundamental rights of persons whose data are transferred to that third country”, and that the measures it established to mitigate interference of this kind (such as the creation of an ombudsman role to handle the complaints of EU citizens) did not meet the required legal standard of “essential equivalence” with EU law.
Austrian privacy activist and lawyer Max Schrems, who brought the case, hailed the decision as a victory for privacy rights.
“It is clear that the US will have to seriously change their surveillance laws, if US companies want to continue to play a role in the EU market,” Schrems said in a statement.
Though the agreement was invalidated, the CJEU upheld the validity of another data transfer mechanism called “standard contract clauses” (SCCs), which are used by more than 5,000 US companies (including Facebook, Twitter and Google) to transfer European data.
Wilbur Ross, the US Secretary of Commerce, said that his department was “deeply disappointed” by the decision, and hoped to “limit the negative consequences” to transatlantic trade.
The decision was unexpected for some. Bridget Treacy, data privacy partner at Hunton Andrews Kurth LLP, mentioned that for businesses that transfer personal data from the EU to the US, this represents the worst of all possible outcomes. "SCCs, commonly utilised for transfers around the globe, will be subject to much closer scrutiny by data exporters and by EU regulators. Transfers of personal data from the EU to the US will require particular care given comments made by the Court about US surveillance. But all personal data transfers from the EU, whether to the US or elsewhere (including the UK after 1 January 2021) will now require much closer scrutiny. "
This ruling will mainly impact EU-US transfers. Businesses that relied upon the Privacy Shield will need to assess whether they can utilize SCCs as an alternative data transfer mechanism, but with more proactive scrutiny of the data transfers than previously. Explaining this further, Briget tells us, "EU regulators will need to adopt a pragmatic approach to enforcement, allowing businesses a period of grace in which to implement alternative arrangements to the Shield in order to continue to lawfully transfer personal data from the EU to the US. Businesses will expect urgent guidance from regulators on transition arrangements.
“The ruling on the Privacy Shield is likely to have implications for the UK’s hopes for a post-Brexit data protection adequacy ruling from the European Commission. The UK can expect its surveillance laws to be subject to similar scrutiny to those of the US, to assess whether they respect the privacy rights of EU citizens.”
It is fortunate, says Matthew Getz, Partner at Boies Schiller Flexner, that the use of standard contractual clauses has been validated. But the decision gives the green light to national and regional data protection authorities to ban transfers on the basis of those clauses to countries with lower levels of protection.
"And of course, the United States will be the first recipient country the authorities will be thinking about. We may end up with a patchwork of different decisions whereby a multinational company can send data to the US from Holland but not Belgium, for example. Such divergence may not be in the spirit of the GDPR – but could be in the letter", explains Matthew.
He advises that all companies transferring personal data to the US and anywhere else around the world need to act quickly. "If they had contingency plans, they should implement them; if they did not, they should immediately work out what other bases they have to transfer data, and whether they have to suspend some transfers. This could require rapid re-engineering of systems and structures."
The million pound question is what does this mean for the UK? "We are due sometime this summer to get the European Commission’s view as to whether our level of protection of personal data is adequate", Matthew expands, "Now more than ever, we should pray for a good decision, because transfers to any country without an adequacy decision have become harder. On top of COVID-19 and other Brexit effects, the economy-dragging effect of restrictions on data transfers to this country would not be a welcome development in 2021.”
The order pertained to two separate Irish tax rulings that reduced the tax burden of Apple’s two Irish subsidiaries – Apple Sales International and Apple Operations Europe – over the course of two decades, reaching as low as 0.005% in 2014, which the European Commission found to constitute illegal state aid.
The General Court disagreed, however, stating that there was insufficient evidence to demonstrate that Apple’s subsidiaries had been granted a selective economic advantage under EU competition rules.
“The General Court annuls the contested decision because the Commission did not succeed in showing to the requisite legal standard that there was an advantage for the purposes of Article 107(1) TFEU1,” judges said on Wednesday.
“This case was not about how much tax we pay, but where we are required to pay it,” Apple said in a comment on the ruling. “We're proud to be the largest taxpayer in the world, as we know the important role tax payments play in society.”
The Irish government, which also appealed the 2016 order, insisted that Apple’s treatment was always “in line with normal Irish taxation rules.”
The decision is a loss for the European Commission, though the body has 14 days to appeal the ruling at the European Court of Justice.
In a ruling on Tuesday, a Munich court banned Tesla Germany from repeating “misleading statements” related to the capabilities of its autonomous driving technology and driver assistance systems.
Per the ruling, Tesla will no longer be able to include the phrases “full potential for autonomous driving” or “Autopilot inclusive” in its German advertising materials.
The case was brought by the Wettbewerbszentrale, a German industry-sponsored body that polices anticompetitive practices. The body argued that Tesla’s claims amounted to misleading business practices, and that the average viewer of its advertisements might be led to believe that Tesla’s vehicles are capable of fully autonomous driving and that such technology is considered road-legal in Germany.
Concerns regarding Tesla’s automated driving systems have been voiced elsewhere, with the US National Transport Safety Board asserting that it lacks safeguards.
These issues feed into wider anxiety that automated assistance systems designed to take over partial control from a human driver for extended periods of time may have a negative effect on car owners, tempting them into neglecting their obligation to remain in control of their vehicle at all times.
Tesla has maintained that it has informed its customers that its automated driver assistance systems do not amount to a completely autonomous driving system, and has already rebranded “Autopilot” to “Autodrive” in its German materials.
Dr Andreas Ottofülling, attorney for the Wettbewerbszentrale, hailed the decision as an initial victory.
“Since autopiloted and autonomous driving at level 5 is currently neither legally permissible nor technically possible for the vehicle in question, Tesla must also adhere to the rules of the game and must not make false advertising promises,” he said.
Tesla Germany can appeal the court’s decision.
International firm Dentons is shuttering two of its regional UK offices as part of a broader shift towards remote working arrangements and to reduce its real estate holdings.
Partners and employees based in the firm’s Aberdeen and Watford offices, who have already adopted remote working arrangements, will continue to operate from home. However, Dentons confirmed that these employees will also have the option to access its Edinburgh and Milton Keynes offices when required.
In its statement on the closures, the firm said that it does not plan to shutter any more of its UK offices, though it will review the situation in 2025 when the lease on its London office expires. The London office was reopened in mid-June at a reduced capacity, with no movement of employees between floors and a “track and trace” system established to monitor the health of staff.
The firm’s other offices will open in a similar manner over the coming weeks.
Lisa Sewell, Dentons’ managing director for the UK, Ireland and Middle East remarked on the success of the firm’s remote working measures so far. “We have seen far less use of paper, more self-service and confidence using new technology and no drop in productivity or service levels despite teams not being co-located 100% of the time,” she said.
“It's an exciting shift for us, our people and for how we will be able to serve our clients in different ways in the future”.
Aman Johal, Lawyer and Director of Your Lawyers, illuminates the scandal for Lawyer Monthly.
Car manufacturer Daimler (Mercedes) is alleged to have installed software to ‘cheat’ diesel engine emissions testing in a similar way to Volkswagen.
Daimler is accused of fitting affected vehicles with “defeat devices” which are illegal under EU law. Such devices may allow vehicles to pass emissions testing and secure road safety approval under EU emissions regulations by detecting when a vehicle is on a test cycle that results in emissions-reducing technology to engage. However, once on the road and outside of test conditions, these same vehicles could produce quantities of NOx emissions far above EU and US standards.
Although news of the legal action we are taking has only recently hit the headlines, this is not a new issue for Mercedes vehicles. In Germany, Mercedes’s parent company Daimler was fined £776 million after 774,000 vehicles allegedly fitted with "defeat devices" were recalled across the country throughout 2018. Now, in the UK, it’s estimated that half a million vehicles could contain “defeat devices”, and owners could be eligible to claim substantial damages in compensation.
Although news of the legal action we are taking has only recently hit the headlines, this is not a new issue for Mercedes vehicles.
For many, this story may feel like déjà vu. Back in 2015, over 1.2 million Volkswagen vehicles across England and Wales were under recall for defeat device technology. The High Court recently ruled that the technology used by Volkswagen is a type of defeat device, and tens of thousands of owners now await compensation. Your Lawyers spearheaded the initial legal effort to bring VW to justice with the first High Court action in January 2016, and was appointed with a seat on the Steering Committee by the High Court of Justice in 2018 having previously represented over 10,000 claimants. With an estimated average of £8,500 in compensation for each claimant, the action could total up to £10.2 billion nationwide as one of the largest group actions the UK has ever seen.
If the High Court rules in a similar way for the pending action against Daimler, owners taking part in what will become the latest ‘dieselgate’ litigation may also be due compensation. Revelations about the use of defeat devices has caused a great deal of understandable concern. In the US, it has been estimated that 59 premature deaths may have been caused by the excess pollution produced between 2008 and 2015 by vehicles equipped with a defeat device.
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Drivers who have owned or leased a Mercedes-Benz diesel car or van, first registered between 2009 and 2018, should look to claim compensation. Some owners could be eligible to claim under the Consumer Protection from Unfair Trading Regulations 2008 (CPUT) which can allow a claimant to receive up to 100% of the purchase price of their vehicle in cases where a vehicle manufacturer has engaged in ‘very serious’ prohibitive practices. This could fall to 75%, 50%, or 25% if the prohibitive practices are deemed to be less severe.
This means that Claimants eligible for a 100% CPUT claim could be entitled to receive between £23,775 and £96,220 in compensation depending on the model of their vehicle, according to ‘on the road’ price data from Mercedes in May 2020. Almost a third of Volkswagen Claimants are estimated to be eligible for a CPUT compensation claim and a similar proportion of Mercedes drivers are also expected to be eligible, if not more. We encourage Mercedes owners to come forward as soon as possible to claim compensation owed to them via Your Lawyers’ dedicated website: The Car Emissions Lawyers.
If Mercedes-Benz is found to have used “defeat devices” to cheat EU emissions regulations, they must be held to account for any irreversible human and environmental damage caused, and compensation should be issued to owners. Much like the Volkswagen case in 2015, we may be looking at another example of a big corporation putting profits before people, the environment, and public health.
Novartis International AG has reached settlements with the US Department of Justice (DOJ) and the US Securities and Exchange Commission (SEC) to resolve all currently active investigations into the allegedly improper conduct of its overseas subsidiaries.
In a statement, DOJ assistant attorney general Brian Benczkowski described the company as having “profited from bribes that induced medical professionals, hospitals, and clinics to prescribe Novartis-branded pharmaceuticals and use Alcon surgical products,” and concealing evidence of said bribery by falsifying records.
According to the agreement reached, Novartis Greece paid employees to provide “improper benefits” of its drug Lucentis to doctors between 2012 and 2015 to boost sales, and falsified records to conceal evidence of criminality.
A similar scheme was conducted by Alcon Pte Ltd, Novartis’s former subsidiary in Vietnam, where employees made corrupt payments through a third party to staff at state-run medical centres to boost sales of intraocular lenses. Again, records were falsified to record the issued bribes as consulting, marketing and human resource expenses.
With the settlement payments – which total $234 million to the DOJ and $113 million to the SEC – “all outstanding FCPA investigations into the company are now closed,” according to a statement issued by General counsel Shannon Thyme Klinger.
“Today’s settlements represent another milestone in our commitment to resolving legacy compliance issues and ensuring that Novartis truly lives its values.”
The Greek government has announced that it will be seeking compensation from Novartis for losses incurred by the state in connection with the bribery scandal.
While a new conciliation platform has been created before the Paris Commercial Court, in order to deal with the very high number of claims filed by businesses against each other on the ground of non-performance due to COVID-19, the British Cabinet Office published on 7 May 2020 a guidance in which it encourages "responsible and fair behaviour is strongly encouraged in relation to (…) making, and responding to, force majeure, frustration, change in law, relief event, delay event, compensation event and excusing cause claims". Sylvie Gallage-Alwis and Gaëtan de Robillard, respective Partner and Associate at Signature Litigation, explore the implications of this new guidance.
Force majeure and COVID-19 are indeed two concepts that have often been seen together these past weeks, businesses being stuck when it came to manufacturing, delivering or paying for instance. Yet case law was not there yet, and the only decisions in France where COVID-19 was recognised as being a force majeure event were rendered in very specific contexts, such as immigration proceedings. Up until now, businesses were therefore notifying force majeure and enforcing their force majeure clauses without any concrete decision handed down in a commercial scope in France.
The order handed down in summary proceedings by the Presiding Judge of the Paris Commercial Court on 20 May 2020 in a dispute between Total Direct Energie ("TDE") and Electricité de France ("EDF") alongside Réseau de Transport d'Electricité ("RTE"), in the presence of the French Independent Electricity and Gas Association ("AFIEG") has now changed this.
Up until now, businesses were therefore notifying force majeure and enforcing their force majeure clauses without any concrete decision handed down in a commercial scope in France.
While the order of 20 May 2020 is particularly interesting as it relates to the system consisting of the Regulated Access to Historic Nuclear Electricity, it provides an interesting example of the recognition of COVID-19 as a case of force majeure. It also illustrates the attention that the courts give to the wording of contractual force majeure clauses and the discussions that would have taken place had the ground of the action been hardship (imprévision), a concept which was introduced into French Law in 2016.
The dispute concerns the terms of Article 10 of the framework agreement binding EDF to TDE, according to which force majeure refers to "an extraneous, irresistible and unforeseeable event making it impossible to perform the parties' obligations in reasonable economic conditions".
There is somewhat of a similarity between the words "in reasonable economic conditions" and hardship, which is defined as a change in unforeseeable circumstances rendering "the performance of the agreement excessively costly for one of the parties".
Based on the definition of force majeure of Article 10, the Judge considered that "the spread of the virus is obviously extraneous to the parties, is irresistible and was unforeseeable, as proven by the sudden nature and extent of its appearance". This "obvious" nature was not being discussed, which explains the brevity of the reasoning compared to the case law relating to the H1N1, Dengue Fever and other epidemics, which have not been recognised as force majeure cases by French Courts.
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Here, it is the spread of the virus that is deemed a case of force majeure, not the governmental measures. This will probably trigger discussions in other cases, in particular when the question of knowing when the spread started and stopped.
TDE notably argued that the "governmental measures applied" would have triggered a "sudden decrease in consumption", creating a situation where it had to accept the delivery of ordered volumes of electricity and resell most of them at a loss due to the impossibility to store electricity.
As for EDF, it notably argued that the pandemic and the resulting decrease in energy consumption did not prevent TDE from performing its obligations regarding, in particular, the acceptance of the ordered volumes of electricity and the payment thereof.
Here, the Judge carried out a factual analysis to rule that "this results in [TDE] observing significant, immediate and permanent losses over a period of time beyond its control", further considering that the occurrence of a case of force majeure enables to "assume a disruption affecting prior economic conditions resulting in the occurrence of significant losses arising from the performance of the agreement".
Here, the Judge carried out a factual analysis to rule that "this results in [TDE] observing significant, immediate and permanent losses over a period of time beyond its control"
This reasoning can be interpreted as the implementation of a presumption according to which a case of force majeure necessarily leads to a more costly performance, the parties having to discuss the extent of the acceptable risk.
This case law shows that case-by-case analysis will be the norm when it comes to the interpretation of the contract. The review of the clauses is, therefore, a must do before relying on the now fashionable concept of force majeure. If no such clause is in the contract, businesses will have to refer to statutes and case law. This may change the whole outcome of the matter. Indeed, what if the EDF/TDE contract did not make any mention to the concept of "unreasonable economic circumstance"?
This decision also shows that there will be a case-by-case analysis when it comes to the impossibility to perform and on the economic impact of a performance, if the latter is possible. In this respect, interestingly, the parties have decided not to put forward the fact that their financial health was not endangered with the performance or non-performance of this contract. This encouraged the Judge to only focus on the contract itself and on its economic viability independently from any other consideration. One could question whether such approach is aligned with the guidance provided by both the French and British Governments which have asked businesses to act fairly, in a general way, and not just, contract per contract.
On April 21, 2020, the DGCCRF (Directorate General for Competition, Consumer Affairs and Fraud Control), the French market surveillance authority, published the result of its investigation on digital platforms, and more specifically, their duty to inform. This investigation was conducted 2 years after the entry into force of new obligations in the European Union. Here are the lessons learnt after 73% of the controlled platforms were found non-compliant, analysed by Sylvie Gallage-Alwis and Lorène Massé, respective Partner and Paralegal at Signature Litigation.
Online selling, which is often referred to as electronic commerce or e-commerce, is the exchange of goods and services between two parties via electronic networks, in particular the internet. It is a specific type of selling that refers to all commercial transactions carried out from the website of a seller or through emails exchanged between potential co-contracting parties.
Whilst originally online selling referred to websites dedicated to creating business relations between professionals, in particular for calls for bids (B2B), its definition now extends to several other types of platforms, including those connecting professionals and consumers (B2C) and those connecting consumers, individuals and non-professionals, who want to sell their goods or services directly between themselves (C2C).
[Online selling] is a specific type of selling that refers to all commercial transactions carried out from the website of a seller or through emails exchanged between potential co-contracting parties.
The main European Regulation in the field of e-commerce and online platforms is Directive 2000/31/EC of the European Parliament and of the Council of June 8, 2000 on certain legal aspects of information society services, in particular electronic commerce, in the Internal Market, which created a regulatory framework for business transactions on the internet.
This Directive was strictly transposed in France in law no. 2004-575 of June 21, 2004 for Trust in the Digital Economy, which defines electronic commerce as "the economic activity whereby a person offers or provides at a distance and electronically services or goods".
On October 7, 2016, the French Digital Republic Law no. 2016-1321 was enacted, whereby its Article 49 created Article L. 111-7 of the French Consumer Code. This Article makes a distinction between two types of activities of operators of online platforms (search engines, marketplaces and collaborative platforms): (i) listing or classification and (ii) bringing different parties together for the conclusion of an agreement for the sale or exchange of goods, services or content.
Article L. 111-7 of the French Consumer Code lists the information to be provided by operators of online platforms to consumers in a "faithful, clear and transparent" way, including:
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Decree no. 2017-1434 of September 29, 2017, which came into force on January 1, 2018, specifies the conditions of the application of this Article, depend on the nature of the activity of operators of online platforms. It provides that they "must indicate in a special section the listing, delisting and classification conditions", this section must be "directly and easily accessible from all the pages of the website" and contain the following information:
The DGCCRF has conducted a survey targeting 44 online platforms to check their conformity to the above information obligations, concluding that there was a "high rate of non-conformities" with 32 out of the 44 companies failing to comply with the Decree.
According to the operators of online platforms, the Decree entered into force only recently (2018), hence not giving sufficient time to become compliant. There is also no information on the applicable regulations making it difficult for them to know what to do exactly.
The DGCCRF have argued that the new provisions containing the new obligations had been the subject of a very broad consultation and of an information letter issued by the DGCCRF reminding operators of the applicable obligations.
According to the operators of online platforms, the Decree entered into force only recently (2018), hence not giving sufficient time to become compliant.
Some of the concepts of the new obligations are also the source of interpretation difficulties.
For example, the section referred to in the Decree, which states that operators must include information on the listing, delisting and classification conditions, has led businesses to consider that their general terms and conditions could act as the "section" or that two different sections could exist. The DGCCRF answered that "the concept of section is defined as a specific section guaranteeing that the information is directly and easily accessible to the consumer".
Several operators are unwilling to precisely define this criterion as they consider that doing so would be tantamount to revealing one of their trade secrets. Indeed, the use of algorithms is a major aspect of the operation of online platforms.
The DGCCRF explains that for consumers to trust the digital economy, it is necessary to provide them with objective information, including regarding the definition of the classification criteria used and the indication of the main parameters applied, always in accordance with the principle of confidentiality of trade secrets.
All the above non-conformities have given rise to the application by the DGCCRF of 21 administrative police measures, 8 warnings and 4 reports of administrative fines. While most platforms quickly defined and implemented the appropriate corrective measures, many of them are still yet to take action. It will now be interesting to see whether the DGCCRF conducts another similar survey next year and whether the applied penalties will become stricter.
