These elements are incorporated in a five-step framework, which can be summarised as follows:

(a) Step 1: the removal of any economic benefit derived from a contravention;
(b) Step 2: the determination of a figure which reflects the seriousness of the contravention;
(c) Step 3: an adjustment made to the step 2 figure to take account of any aggravating and mitigating circumstances;
(d) Step 4: an adjustment made to the step 3 figure, where appropriate, to ensure that the penalty has an appropriate deterrent effect; and
(e) Step 5: if applicable, an adjustment for cooperation/early settlement may be made.