Just culture, Natural Justice are conditional phrases which to the FOI on the front line mean little when placed in context against the needs of the performance review which will be judged on the outcomes of regulatory action, and this means negative action for industry as opposed to proactive action that might have better outcomes but is initially impossible to measure whereas a prosecution is immediately measurable.
Think , the outcomes are a
Tautology (rhetoric), using different words to say the same thing even if the repetition does not provide clarity. Tautology also means a series of self-reinforcing statements that cannot be disproved because the statements depend on the assumption that they are already correct.