Thank you for your question.
As you no doubt saw when reading our brief, we didn't comment specifically on part 1 of the bill.
Generally speaking, though, when it comes to these types of penalties and fines, especially an administrative monetary penalty regime, a whole process goes into determining the amounts of the fines, whether they apply to individuals or businesses. In many cases, it's a percentage of the business's revenues. A lot of factors are taken into account.
I won't comment on whether the approach is consistent or appropriate, but I will say that a lot of work has to go into establishing an administrative monetary penalty regime.
I encourage you to compare this regime with others that have already been adopted to see whether there are any similarities. You can also look to the teachings of the Supreme Court in decisions relating to the validity of such regimes.