TupperS Law

Anti-bribery and Corruption Policy

This policy applies to all directors, employees, consultants and other people or bodies associated with TupperS Law .

It is the policy of the firm to conduct all business in an honest and ethical manner. The firm has a zero-tolerance approach to bribery and corruption and will take all possible measures to ensure that every aspect of our business and associated relationships is undertaken and conducted professionally, and with integrity. 


The Bribery Act 2020 creates three main offences:

  1. Bribing a person to induce or reward them to perform a relevant function
  2. Improperly requesting, accepting or receiving a bribe as a reward for performing a relevant legal function; and
  3. Improperly using a bribe to influence a foreign official to gain a business advantage.

Bribery does not always involve the payment o cash from one party to another. Gifts, hospitality and entertainment can be bribes if they are intended to influence a decision.

Offences relating to bribery and corruption carry substantial terms of imprisonment for individuals and unlimited fines for firms. In addition, firms that are convicted of such offences could be excluded from tendering for public contracts and face damage to their reputations. 

Preventative procedures

Contracts with agents and other providers of services, and all individuals and organisations with whom the firm has a business relationship, should be considered in light of this policy and its procedures. If appropriate, consideration must be given to whether such individuals or organisations have anti-bribery and corruption policies and whether they should be made aware of the existence of our policy. 

Where anyone is unsure of the appropriate course of action, they must confer with Stephen Tupper, the Managing Director.

Gifts and hospitality 

The provision of gifts and hospitality that are reasonable and proportionate, with regard to the relationship the firm has with an individual or organisation to whom this is offered, is not prohibited by the Bribery Act 2010. 

The firm will provide such gifts and hospitality as Stephen Tupper considered appropriate, but not in circumstances where this might influence, or reasonably be perceived to influence, the improper performance of a relevant function. 

A non-exhaustive list of the types of gifts and entertainment which the firm will provide includes: 

  • seasonal gifts as a reflection of good relationships
  • promotional items bearing the firm’s name
  • lunches
  • tickets to events 

The firm’s policy is that all offers to provide gifts or hospitality must be authorised by Stephen Tupper prior to them being made to a third party. All gifts shall be given openly, not secretly. 

On some occasions, offers of gifts and hospitality are received. The firm’s policy is that such offers should not be accepted without the approval of Stephen Tupper. In deciding whether to give such approval, he will consider the firm’s relationship with the individual or organisation making the offer, and he will remain mindful of the firm’s duty to act in the best interests of its clients at all times. If there is any doubt or concern about the propriety of receiving any gifts and/or hospitality, then Stephen Tupper’s decision is final.

To assist in monitoring compliance with, and reviewing the effectiveness of, this policy, a record of all gifts and hospitality provided to and from the firm, and of those offered to, and accepted by, the firm, is kept by Stephen Tupper, and everyone should ensure that he is advised of all offers and acceptances accordingly. 

Enforcement and breach

Any breach of the policy is a risk to the firm and is, accordingly, likely to be regarded as a serious disciplinary offence. When, at any time, a breach of the policy has been identified, an investigation will be undertaken by Stephen Tupper in order to ascertain the full facts and circumstances of the breach.

Everyone is under a duty to immediately report an actual, suspected or attempted breach of the policy caused by a third party to Stephen Tupper.

TupperS Law Limited
12 February 2024