1. Policy Statement
Spouse Visa Lawyers is professionally run and managed by Gulbenkian Andonian Solicitors
We are 100% dedicated to operating the business in a transparent, virtuous, and legal manner. We embrace a zero-tolerance attitude against bribery and corruption in any capacity and are committed to performing our work professionally, fairly, and with complete integrity.
We promise to maintain all laws applicable to restrain bribery and corruption across all jurisdictions where we operate, with a particular emphasis on the UK’s 2010 Bribery Act.
Violating anti-bribery or corruption laws could lead to risk of prosecution, which includes up to 10 years of imprisonment for individuals and potentially unlimited penalties. Therefore, we take the legal obligations with utmost seriousness.
This Policy is intended to convey to third parties our stance on bribery and corruption. Our staff members should refer to our internal policy for further details.
For the purpose of this policy, third parties indicate any individual or entity interacting with us, such as existing and prospective clients, vendors, business contacts, regulators, and governmental bodies, among others.
2. Who does the policy cover?
This policy applies to:
1. All individuals affiliated with us at every level, including partners, senior managers, directors, employees, contractors, trainees, temporary staff, volunteers, and agents.
2. Third parties engaged by us will also be expected to abide by the defined principles in this policy, following appropriate due diligence.
3. What are bribery and corruption?
Corruption is the abuse of power or status for individual gain. Bribery is the act of offering, promising, or providing any advantage with the intent to influence the decision-making or behaviour of another party inappropriately.
4. SRA’s Position on Bribery
Gulbenkian Andonian Solicitors is authorised by the SRA Code of Conduct which establishes the criteria and responsibilities that the Firm should uphold for the welfare of our clients and in the public interest.
Besides adhering to the Bribery Act 2010, we must comply with regulatory guidelines outlined in the SRA Code of Conduct.
5. Our Standards
We strictly prohibit anyone associated with us from:
- Offering, promising, or giving any advantage, whether it is a payment, gift, or hospitality, with the anticipation or implication that a business favour will be presented in return.
- Providing any inducements to government officials to expedite or “facilitate” routine processes.
- Accepting any form of advantage from a third party if there is a basis to suspect that such an offer indicates an expectation of reciprocal business favour.
- Accepting presents or hospitality from a third party under circumstances where it is believed that an advantage from the firm will be expected in return.
- Retaliating against any staff member who refuses to engage in bribery or who reports a possible breach of this policy.
- Engaging in any exercise that may lead to an infringement of this policy.
6. Facilitation Payments and Kickbacks
Facilitation payments are generally insignificant and undocumented made to fast-track governmental actions, while kickbacks are usually payments made to secure a business advantage. Both are strictly prohibited.
Gulbenkian Andonian Solicitors neither pays nor takes any facilitation payments or kickbacks of any manner.
We do not make political contributions. Charitable donations are only made when legal and ethical under local laws.
8. How to Raise a Concern
We encourage third parties to report any malpractice or suspicions at the earliest opportunity. Concerns should be directed to Armen Andonian and emailed to email@example.com
9. Monitoring and Assessment
We will consistently monitor and inspect the effectiveness of this policy, and we will make periodic assessments of its suitability, adequacy, and efficacy.