Anti-Bribery Policy

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Solidum Solicitors values its reputation and is committed to maintaining the highest level of ethical standards in the conduct of its business affairs. The actions and conduct of the practice’s staff as well as others acting on the practice’s behalf are key to maintaining these standards.

Understanding and recognising bribery and corruption:

Acts of bribery or corruption are designed to influence an individual in the performance of their duty and incline them to act in a way that a reasonable person would consider to be dishonest in the circumstances. 

Bribery can be defined as offering, promising or giving a financial (or other) advantage to another person with the intention of inducing that person to act or to reward them for having acted in a way which a reasonable person would consider improper in the circumstances. 

Corruption is any form of abuse of entrusted power for private gain and may include, but is not limited to, bribery. Bribes are not always a matter of handing over cash. Gifts, hospitality and entertainment can be bribes if they are intended to influence a decision. 

Penalties:

The Bribery Act 2010 came into force on 1 July 2011. Under that Act, bribery by individuals is punishable by up to 10 years’ imprisonment and/or an unlimited fine. If the practice is found to have taken part in bribery or is found to lack adequate procedures to prevent bribery, it too could face an unlimited fine.  

A conviction for a bribery or corruption related offence would have severe reputational and/or financial consequences for the practice.  

Solidum Solicitors will not tolerate bribery or corruption in any form.  The practice prohibits the offering, giving, solicitation or acceptance of any bribe or corrupt inducement, whether in cash or in any other form: 

(a)    to or from any person or company wherever located, whether a public official or public 

        body, or a private person or company; 

(b)   by any individual employee, partner, agent, consultant, contractor or other person or body 

        acting on the practice’s behalf;

(c)    in order to gain any commercial, contractual or regulatory advantage for the practice in any 

        way which is unethical or to gain any personal advantage, pecuniary or otherwise, for the   

        individual or anyone connected with the individual.  

This policy is not intended to prohibit the following practices provided they are appropriate, proportionate and are properly recorded: 

• normal hospitality, provided that the prior authorisation of a senior management team 

        (SMT) member has been sought; 

• fast tracking a process which is available to all on the payment of a fee; and/or 

• providing resources to assist a person or body to make a decision more efficiently, provided 

        that it is for this purpose only. 

Key risk areas:

Bribery can be a risk in many areas of the practice. Below are the key areas you should be aware of in particular:  

• Excessive gifts, entertainment and hospitality can be used to exert improper influence on 

        decision makers. Gifts, entertainment and hospitality are acceptable provided they are 

        within reasonable limits and are authorised by an SMT member. Any gift or hospitality, 

        either given or received, of any value should be reported to the Anti-Bribery Compliance 

        Officer.  

• Facilitation payments are used by businesses or individuals to secure or expedite the 

        performance of a routine or necessary action to which the payer has an entitlement as of 

        right. The practice will not tolerate or excuse such payments being made.   

• Reciprocal agreements or any other form of ‘quid pro quo’ are never acceptable unless they 

        are legitimate business arrangements which are properly documented and approved by the 

        SMT. Improper payments to obtain new business, retain existing business or secure any 

        improper advantage should never be accepted or made. 

• Actions by third parties for which the practice may be held responsible can include actions 

        by a range of people, e.g. agents, contractors and consultants, acting on the practice’s 

        behalf. Appropriate due diligence should be undertaken before a third party is engaged. 

        Third parties should only be engaged where there is a clear business rationale for doing so, 

        with an appropriate contract. Any payments to third parties should be properly authorised 

        and recorded.  

• Record keeping can be exploited to conceal bribes or corrupt practices. We must ensure that 

        we have robust controls in place so that our records are accurate and transparent. The Anti-

        Bribery Compliance Officer is responsible for all record keeping.