For example, this might include spending some of the company's funds to achieve long-term profits at the expense of short-term gains. The directors are also required to carry out their duties with due attention and diligence, as has been codified by the aforementioned legislation, in particular by art. 180, paragraph 1. They must not only consider current interests, but also those that may arise in the future. Despite the legislation, courts tend to be hesitant when it comes to corporate decisions made by directors. This was demonstrated in the case of Re Smith & Fawcett Ltd. Whether a director can demonstrate under section 180(2) that his powers were used for a proper purpose and that they reasonably believed that this was in the best interests of the company , this will be considered a defense. We will now see under section 181, they specifically ensure that directors "carry out their duties for" the best interests of the company