Anti-bribery and corruption statement
This statement is made on behalf of Mills & Reeve LLP and its subsidiaries, Mills & Reeve Trust Corporation Limited, Mills & Reeve Services Limited and Mills & Reeve Secretarial Services Limited (together, “Mills & Reeve”). Our approach to preventing bribery, corruption and other forms of economic crime is governed by applicable UK laws and regulations, including the Bribery Act 2010. References to “we”, “us” and “our” are to Mills & Reeve as defined above.
Our commitment
Mills & Reeve is committed to conducting business professionally, fairly and with integrity, and to maintaining high professional and ethical standards. This commitment is underpinned by our core values. We take a zero-tolerance approach to bribery and corruption in all forms, whether directly or indirectly and wherever we operate. We do not offer, promise, give, request, agree to receive or accept bribes, facilitation payments, kickbacks or other improper advantages, whether directly or through a third party.
Governance
The Board has overall responsibility for ensuring that policies, controls and procedures in place remain effective and comply with our legal and ethical obligations. Day-to-day responsibility for implementing and maintaining our anti-bribery and corruption framework sits with the COLP, who is responsible for monitoring its use and effectiveness, and dealing with queries on its interpretation.
Framework
Our anti-bribery and corruption framework is supported by policies, procedures and risk-based controls designed to prevent, detect and respond to bribery and corruption risks across our business.
Our controls include:
Risk-based due diligence on employees, partners, clients, suppliers and other third parties, both at the outset of a relationship and on an ongoing basis where appropriate.
Contractual protections in our agreements with suppliers, contractors and other third parties to support compliance with applicable anti-bribery and anti-corruption requirements.
Protocols for the giving and receiving of gifts, corporate hospitality and charitable donations, together with an approval process.
Reporting and escalation procedures, including whistleblowing arrangements.
Ongoing monitoring and review of the effectiveness of our controls, including periodic risk assessments to identify and address emerging risks.
Training and awareness
We maintain policies and guidance to support compliance with our anti-bribery and corruption obligations, including our Anti-Bribery and Corruption Policy and Corporate Hospitality Policy. These policies are published on our Intranet which is accessible by all partners and employees. In addition to these policies, training on anti-bribery and corruption is mandatory for all partners and employees.
Reporting
We are committed to fostering a culture of openness in which concerns can be raised without fear of retaliation.
We encourage anyone who becomes aware of any actual, suspected or attempted bribery, corruption or other unethical conduct to speak with us at the earliest opportunity. Our people may raise concerns through established management channels, to the risk & compliance team, or in accordance with our Whistleblowing Policy.
We also encourage clients, suppliers and other third parties to contact us if they have concerns about bribery, corruption or unethical conduct involving Mills & Reeve. Concerns can be raised without providing a name, although sharing contact details may help us understand the concern fully and take appropriate action.
Get in touch
Send us your enquiry and we will get back to you as soon as possible.