Anti-Bribery & Corruption Policy

Introduction

Ai Law 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. The purpose of this document is to set out the practice’s policy in relation to bribery and corruption. The policy applies strictly to all employees, partners, agents, consultants, contractors and to any other people or bodies associated with Ai Law within all offices, areas and functions.

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.

Failure to prevent fraud

Since 1 September 2025 the Economic Crime and Corporate Transparency Act 2023 (section 199) has also made it an offence for a large organisation — one meeting two or more of: more than 250 employees, more than £36 million turnover and more than £18 million in total assets — to fail to prevent fraud by an employee, agent or other person performing services for it, where the fraud is intended to benefit the organisation or its clients, unless it had reasonable procedures in place to prevent it. Whatever its size, Ai Law will not tolerate fraud by anyone acting for it or on its behalf, and any concern about fraud should be raised with the Anti-Bribery Compliance Officer in the same way as a concern about bribery.

Policy

Ai Law 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:

● to or from any person or company wherever located, whether a public official or public body, or a private person or company;

● by any individual employee, partner, agent, consultant, contractor or other person or body acting on the practice’s behalf;

● 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.

It may not always be a simple matter to determine whether a possible course of action is appropriate. If you are in any doubt as to whether a possible act might be in breach of this policy or the law, the matter should be referred to the Anti-Bribery Compliance Officer, who is Tom Ellis.

The practice will investigate thoroughly any actual or suspected breach of this policy, or the spirit of this policy. Employees found to be in breach of this policy may be subject to disciplinary action which may ultimately result in their dismissal.

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.

● 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.

Employee responsibility and how to raise a concern

The prevention, detection and reporting of bribery or corruption are the responsibility of all partners and employees of the practice. If you become aware or suspect that an activity or conduct which is proposed or has taken place is a bribe or corrupt, then you have a duty to report this to the Anti-Bribery Compliance Officer without delay.

Further guidance

For further guidance see the Law Society’s guidance on the Bribery Act 2010, on its website at www.lawsociety.org.uk.

Version

This policy was last updated on 15 October 2026.