1. Anti-bribery & Corruption

1.1. What are bribery and corruption?
Corruption is the misuse of office or power for private gain. Bribery is a form of corruption. It means:

• giving or receiving money, gifts, meals, entertainment or anything else of value
• as an inducement to a person to do something which is dishonest or illegal
• in the course of doing business

In other words, bribery is designed to make a person act wrongly to secure an advantage for the giver.
1.1.1. Our position on bribery
Our position is simple. We conduct our business to the highest legal and ethical standards. We will not be party to corruption or bribery in any form. Such acts damage our reputation and expose us, and our employees, to the risk of fines and imprisonment. We take a zero-tolerance approach to bribery and corruption by our people and our third party representatives.
1.1.2. Areas of specific risk
There are certain aspects of practice work that could contain a higher risk

• gifts and hospitality
• donations (charitable or others)
• Commissions & other financial benefits
• facilitation payments
• intermediaries

We have detailed some of these a little more below.

1.2. What we do if you think something is wrong?
1.2.1. Where there is a concern an internal Suspicious Activity Report SAR (ED1210 -SAR) will be completed, sent to Sharon McDermott (SM) and the concern entered on the register.
1.2.2. Where the matter is considered to be a material breach of compliance she will also inform the SRA and, if appropriate, other relevant authorities.

2. Gifts & Hospitality

2.1. Our policy
2.1.1. We will not seek or request any gift or hospitality in the course of our work or offer or receive from any person or organisation who has had, has or may have any influence over the firm:
• a personal or corporate gift to a value in excess of £250.00 or
• hospitality to a value in excess of £250.00
2.1.2. We will never offer or receive any gift or hospitality that is in breach of relevant law.
2.1.3. We will not directly or indirectly, make an offer of, or make a donation to any political, charitable or not-for-profit organisation in the course of your employment as a way to obtain an advantage for the firm
2.1.4. In certain cases SM as the Principal of the practice may exercise discretion to permit gifts or hospitality which exceeds the threshold limit above.

2.2. Gifts register
2.2.1. Where gifts or hospitality are received in excess of these thresholds SM must be advised and she will note it in the register.

3. Donations

3.1.1. Charitable or other donations relating to Trenches Limited will only be made by SM.
3.1.2. A record of the donation will be kept in the Gifts register.

4. Commissions & Financial Benefits

4.1.1. As a general principle and as per our business plan, we avoid working in situations that would involve us receiving or paying commission for work provided.
4.1.2. If in doubt, or in exceptional circumstances, consult with SM before accepting any such arrangements.
4.1.3. A record of the commission will be kept in the Gifts register.

5. Intermediaries

5.1.1. Intermediaries may be consultants, advisors, other lawyers, agents, suppliers, distributors or other third parties, who assist with our business.
5.1.2. We will only use those intermediaries that are approved by SM as the COLP.