Prior good character should not be diminished as a mitigating factor in sentencing for foreign bribery offences unless the offender's good character actually positioned them to commit the offence or involved exploitation of a position of trust. A significant distinction exists between good character based merely on absence of criminal history and good character evidenced by positive contributions to society and philanthropy — the latter is a significant mitigating factor. The utilitarian value of a guilty plea must be taken into account as a separate consideration from the offender's subjective intention to facilitate the administration of justice when sentencing for Commonwealth offences.
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