Parker Russell Legal (“the Firm”) is committed to conducting its business with honesty, integrity, independence, and professionalism. The Firm adopts a zero-tolerance approach to bribery and corruption and is committed to maintaining effective systems and controls to prevent, detect, and respond to bribery and corrupt practices.
This Policy establishes the standards expected of all partners, directors, consultants, employees, trainees, and third parties acting on behalf of the Firm.
This Policy supports compliance with:
All personnel must comply with both the letter and spirit of these requirements.
The Firm prohibits:
No employee or representative may engage in any conduct intended to improperly influence a client, public official, court, tribunal, regulator, supplier, or other stakeholder.
The Managing Partner has overall responsibility for ensuring that the Firm maintains effective anti-bribery controls.
The Compliance Officer shall:
Every individual working for or representing the Firm must:
Examples of higher-risk situations include:
Enhanced due diligence may be required in these circumstances.
The Firm recognises that reasonable business hospitality may be appropriate in certain circumstances.
Any gift or hospitality must:
The following are prohibited:
All gifts and hospitality above the Firm’s approved threshold must be recorded in the Gifts and Hospitality Register.
Special caution must be exercised when dealing with:
No person may offer any payment, gift, hospitality, or advantage intended to influence an official act or decision.
Prior approval from the Compliance Officer must be obtained before offering gifts or hospitality to public officials.
The Firm shall undertake appropriate due diligence on clients and matters to identify bribery and corruption risks.
Due diligence may include:
The Firm reserves the right to decline instructions where bribery or corruption concerns cannot be satisfactorily mitigated.
The Firm may be exposed to bribery risks through:
Appropriate due diligence shall be conducted before engagement.
Contracts should include anti-bribery and compliance provisions where appropriate.
All financial transactions must be:
No false, misleading, or incomplete accounting records shall be created.
Client account transactions must comply with applicable regulatory requirements and internal controls.
Personnel must avoid situations where personal interests conflict with professional duties.
Any actual, potential, or perceived conflict must be disclosed immediately and managed in accordance with the Firm’s Conflict of Interest Policy.
Any person who becomes aware of suspected bribery or corruption must report it immediately to:
Reports may be made confidentially and will be investigated promptly and fairly.
The Firm will not tolerate retaliation against any individual who reports concerns in good faith.
Individuals raising concerns will be protected to the fullest extent permitted by law.
All personnel shall receive anti-bribery and corruption training:
Training records shall be maintained.
The Firm shall periodically assess the effectiveness of its anti-bribery framework through:
Findings shall be reported to senior management.
Breaches may result in:
The Firm may also report matters to law enforcement agencies where appropriate.
This Policy shall be reviewed annually by the Compliance Officer and approved by the Managing Partner.
