Where multiple fraud offences arise from a single course of conduct with very substantial common elements, the totality principle requires careful attention to avoid double punishment, even where the total amount fraudulently obtained is substantial. A 20% discount for cooperation (past and future) is not manifestly inadequate where the assistance is limited to identifying a co-offender of the same offence, does not extend to other offences, and does not place the offender's welfare at risk, particularly where a separate 25% discount for guilty plea and separate recognition of remorse have already been applied.
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