The regulatory agency also suggested that prosecution would have been disproportionate. The terms included a financial penalty of GBP£19.2 million, as well as paying the SFO's costs and continuing to cooperate with the SFO and other investigative agencies. Finally, Serco was ordered to make improvements to its ethics and compliance policies and procedures. The DPA outlined stringent conditions for Serco to have "an effective system of internal accounting controls and a rigorous compliance program" to enable the company to detect fraud and bribery. The judge, in granting judicial approval of the DPA, rejected the cynicism against corporate entities receiving DPAs rather than being prosecuted. In making the judgment, he stated that "approval will only be given where there is the clearest possible demonstration of integrity on the part of the company concerned once the criminal activity has become apparent.