Anti-Bribery Policy

Last Updated: 14/05/2025

1. What does this policy cover?

1.1 This anti-bribery policy exists to set out the responsibilities of Thurstan Hoskin Solicitors LLP and those who work for us in regards to observing and upholding our zero-tolerance position on bribery and corruption.

1.2 It also exists to act as a source of information and guidance for those working for Thurstan Hoskin Solicitors LLP. It helps them recognise and deal with bribery and corruption issues, as well as understand their responsibilities.

2. Policy statement

2.1 Thurstan Hoskin Solicitors LLP is committed to conducting business in an ethical and honest manner, and is committed to implementing and enforcing systems that ensure bribery is prevented. Thurstan Hoskin Solicitors LLP has zero-tolerance for bribery and corrupt activities. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships, wherever in the country we operate.

2.2 Thurstan Hoskin Solicitors LLP will constantly uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate. We are bound by the laws of the UK, including the Bribery Act 2010, in regard to our conduct both at home and abroad.

2.3 Thurstan Hoskin Solicitors LLP recognises that bribery and corruption are punishable by up to ten years of imprisonment and a fine. If our firm is discovered to have taken part in corrupt activities, we may be subjected to an unlimited fine, be excluded from tendering for public contracts, and face serious damage to our reputation. It is with this in mind that we commit to preventing bribery and corruption in our business, and take our legal responsibilities seriously.

3. Who is covered by the policy?

3.1 This anti-bribery policy applies to all employees (whether temporary, fixed-term, or permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us (including third parties), or any of our subsidiaries or their employees, no matter where they are located (within or outside of the UK). The policy also applies to Officers, Trustees, Board, and/or Committee members at any level.

3.2 In the context of this policy, third-party refers to any individual or organisation Thurstan Hoskin Solicitors LLP meets and works with. It refers to actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies – this includes their advisors, representatives and officials, politicians, and public parties.

3.3 Any arrangements Thurstan Hoskin Solicitors LLP makes with a third party are subject to clear contractual terms, including specific provisions that require the third party to comply with minimum standards and procedures relating to anti-bribery and corruption.

4. Definition of bribery

4.1 Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage so as to induce or influence an action or decision.

4.2 A bribe refers to any inducement, reward, or object/item of value offered to another individual in order to gain commercial, contractual, regulatory, or personal advantage.

4.3 Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and they accept it, they are also breaking the law.

4.4 Bribery is illegal. Employees must not engage in any form of bribery, whether it be directly, passively (as described above), or through a third party. They must not bribe a foreign public official anywhere in the world. They must not accept bribes in any degree and if they are uncertain about whether something is a bribe or a gift or act of hospitality, they must seek further advice from the firm’s Compliance Partner.

5. What is and what is NOT acceptable

5.1 This section of the policy refers to the following areas:

• Gifts and hospitality

• Facilitation payments

• Political contributions

• Charitable contributions

Gifts and Hospitality

5.2 Thurstan Hoskin Solicitors LLP accepts normal and appropriate gestures of hospitality and goodwill (whether given to or received from third parties) so long as:

• They are not made with the intention of influencing a decision or gaining a business advantage.

• They are not offered or accepted with an expectation of a return favour.

• They are given in accordance with local law.

• They are made in the firm’s name, not an individual’s name.

• They do not include cash or cash equivalents.

• They are appropriate for the occasion and timing.

• They are given and received openly.

• They are not excessive and typically valued under £100 unless approved.

• They are not offered to government officials or politicians without prior approval.

5.3 Where it is culturally inappropriate to decline a gift, it may be accepted if declared to the Compliance Partner for assessment.

Facilitation Payments and Kickbacks

5.4 Thurstan Hoskin Solicitors LLP does not accept or make any form of facilitation payments or kickbacks. These are considered bribery and are strictly prohibited.

5.5 In situations where a payment is demanded under threat to personal safety, the individual should comply but report the incident immediately to the Compliance Partner. Records should be kept of the payment.

Political Contributions

5.6 Thurstan Hoskin Solicitors LLP does not make donations to political parties or candidates.

Charitable Contributions

5.7 Thurstan Hoskin Solicitors LLP supports appropriate charitable giving and sponsorships. All donations must:

• Be legal and ethical

• Be properly documented

• Not be used as a form of bribery

• Be pre-approved by the Compliance Partner

6. Employee Responsibilities

6.1 Employees of Thurstan Hoskin Solicitors LLP must read, understand, and comply with this policy.

6.2 All employees are responsible for preventing, detecting, and reporting bribery. They must not engage in any activity that could be interpreted as breaching this policy.

6.3 Any suspected bribery must be reported to the Compliance Partner or a line manager immediately.

6.4 Breaches of this policy will be treated as gross misconduct and may lead to disciplinary action or dismissal. Contractual relationships may also be terminated.

7. Raising Concerns

7.1 Employees are encouraged to raise concerns early. If uncertain, they should contact the Compliance Partner or a senior manager.

7.2 Whistleblowing procedures are in place to allow staff to report in confidence.

7.3 If an employee is a victim of bribery or corruption, they must report it immediately.

7.4 Thurstan Hoskin Solicitors LLP will support anyone who raises concerns in good faith.

7.5 No employee will suffer detrimental treatment for refusing a bribe or reporting a concern.

8. Training and Communication

8.1 Training is provided at induction and refreshed regularly. Staff must confirm compliance annually.

8.2 Our anti-bribery policy and zero-tolerance stance will be communicated to third parties at the start of business relationships and as needed.

9. Record Keeping

9.1 Thurstan Hoskin Solicitors LLP will maintain accurate financial records and internal controls. All gifts and hospitality must be declared and are subject to managerial review.

10. Monitoring and Reviewing

10.1 The Compliance Partner is responsible for reviewing and monitoring this policy’s effectiveness.

10.2 Audits and internal control systems will be used to ensure compliance.

10.3 Improvements to the policy will be made promptly based on feedback or changes in risk.

10.4 This policy does not form part of an employment contract and may be amended at any time.