We operate a strict Anti-Bribery and Anti-Corruption Policy as described under the greek laws and the England, Wale’s and Northern Ireland Solicitors’ Regulation Authority (S.R.A.) Code of Professional Conduct and the guidelines of the New York Bar Association. Thus we implement the U.K. Bribery Act 2010 as well as the U.S. Foreign Corrupt Practices Act 1977 (FCPA), as amended. We also frequently update our policy based on the Green and Red Card Warnings as issued by the S.R.A.
This being the reason, the guidelines of our policy can be summarized as follows:
- We apply a zero-tolerance policy and we closely monitor the prospective clients, we may work with.
- We set up escrow accounts on behalf of our clients, if and only if we can trace the money to be held on them.
- We apply the “Chinese wall” doctrine, according to which certain internal regulations have to be adopted when we work with two or more clients competing for the same interests, assets etc. This means that we physically separate the Attorneys engaged in the cases and have them signed Non Disclose Agreements (N.D.A.) in order to ensure that no information will reach the other side. If this is not possible under the circumstances, we inform each client individually and ask for their consent in order to continue handling their cases.
- We do not accept bribes. More specifically, we will not in any case whatsoever ask or accept from any, directly or indirectly involved in the case, party benefits of any nature for ourselves of for any third party acting on our behalf. Furthermore, we will not act as third parties to any bribery attempt of public servants within or outside the greek jurisdiction. Nevertheless, due to the fact that many
- All of our Associates have been successfully passed the screening process we apply before working with them. If you have any suspicion about bribery or attempt of bribery, please do feel free to contact the Designated Anti-Bribery Officer.
- We work closely with the Authorities when requested by Law. Having in mind the Attorney-Client privilege, our main concern is to protect and promote our clients’ best interests. However, if any summons or subpoenas will be served to any of our associates, it is highly probable that we will have to comply with the requested actions, unless we can provide a non-rebuttable presumption of great reasons not to do so.
- We do not act on behalf of clients wishing to obtain our legal inputs/advices in order to overcome certain legal barriers being there for specific reasons. That means that we are not in any case working with clients for whom we know or reasonably suspect that they conduct / may be involved in illegal activities.
- We ask details to fulfill a KYC (Know Your Client) form from all of our clients (either companies or individuals). This may insist in asking for copies of their Identity Cards, Passports, Utility Bills, Articles of Association, details of their Legal Representatives and anything else appropriate under the circumstances.
- We follow an extensive bookkeeping process under the tax-protocols in force at the time being. That means that we usually deny payments in cash. The preferred method is via money-transfer through designated bank accounts or by debit or credit card.
Besides the above, we are well aware that in many occasions gift giving is a personal way to express gratitude for the services provided. However, according to our Anti-Bribary and Anti-Corruption Policy we pay significant attention to giving and receiving gifts. Although customary gifts (e.g. desserts, bottles of wine, dinner invitations) are most of the times more than welcome, we avoid receiving gifts which would be considered extravagant or otherwise inappropriate.