Client introductions and 'chain' introductions

Occasionally, the Acting Lawyer will find that a client whom they are advising but do not €˜own', introduces a new client ("Newly Introduced Client") directly to them.

When this happens, the Newly Introduced Client will be owned by the Acting Lawyer€˜s Pod and not by the entity (whether Central Office or a colleague's Pod) who owns the original client.

However, where the Newly Introduced Client is not distinct and independent from the original client or in some way is under the control of the original client, then this would not be fair. Accordingly, in such a case the Client Owner of the original client will own the Newly Introduced Client as well. This exception applies in any of the following circumstances:

• If the Newly Introduced Client and the original client are both people, and where the Newly Introduced Client and the original client are married, in a civil partnership or are close blood relatives or are employer and employee.
• If only one of the Newly Introduced Client and the original client is a person, and the other is the employer or otherwise if one is a controlling or majority shareholder of the other.
• If both the Newly Introduced Client and the original client are entities, and both are in the same group/under common control or one is (directly or indirectly) the controller and/or majority shareholder of the other.
• If both the Newly Introduced Client and the original client are entities, where the decision maker (often but not always the client contact) at the Newly Introduced Client and the original client are the same person.
• We use common sense when applying this policy. The principle is that there must be a close connection between the original client and the Newly Introduced Client such that we either know or reasonably believe that the original client will have had a hand in some way with the decision of the Newly Introduced Client to instruct the firm. The above examples show where that will be assumed. However, if it can be shown beyond doubt that the original client has no influence over the Newly Introduced Client and no involvement in their decision to instruct you, then this exception will not be applied. Where there is any doubt, the matter is referred to the Director of Operations and Compliance whose decision is final.