As a public services law firm, we are acutely aware of the requirements of our clients that we have a robust and transparent policy on the giving and receiving of gifts and hospitality. For many of our clients, those requirements go beyond the Bribery Act's requirements and we will always work to the higher standard of our clients' requirements or the Act.
Bribery means giving or receiving a financial or other advantage to encourage or reward the improper performance of a function or activity which is expected to be performed in good faith, or impartially or by someone in a position of trust. The Act makes such behaviour a criminal offence and a person found guilty of the offences can receive up to 10 years imprisonment.
Bevan Brittan does not tolerate bribery by its people or of its people. We have policies and associated guidance as tools to identify what is appropriate behaviour and a mechanism for reporting value given and received above a certain de minimis level. The following is a summary of our policies for the convenience of our clients, suppliers and those with whom we do business.
All lawyers and any senior support staff who do direct business with suppliers must complete and pass our online training course. We are committed to ongoing training and support.
corporate hospitality policy
It is our policy to offer and receive hospitality which is appropriate to the circumstances and is proportionate, taking account of any specific issues such as an imminent tender or frequency of contact. Our contact's own ABC policy must be respected and the tougher standard, in the event of a conflict between policies, must prevail. Our procedures require our people to be transparent, take account of all surrounding circumstances and obtain appropriate internal sign off depending on the nature of the event and the surrounding circumstances.
charitable and political donations
All charitable donations from the firm are made through the auspices of the CSER committee. The firm does not make political donations.
facilitation payments policy
Facilitation payments are payments demanded by officials (or others) simply to secure or expedite the performance of their normal duties (for example, granting a licence, allowing goods to cross a border, and so on). Bevan Brittan will not make such payments and will report any request for such a payment to the appropriate authorities.
financial controls policy
Bevan Brittan aspires to be a well run business with appropriate checks and balances on all our activities. Authority to act or spend is set out in our Authorities Matrix approved by the Board.
HR policy (partners and staff)
Bevan Brittan is committed to ensuring that no member of staff or associated person becomes involved in activities amounting to bribery. This applies equally to our external dealings with clients, referrers, or any other party who undertakes work for us. The partners recognise that the decision to report a concern can be difficult and that there may be concerns over reprisal from those responsible for the malpractice. The partners will do all that they can to ensure that harassment or other victimisation does not occur and will do what they lawfully can to protect anyone who raises a concern in good faith in accordance with our internal whistleblowing policy.
Any enquiries or concerns should be directed to our Director of Risk.
Other important information