Reporting generally

You must report anything out of the ordinary or substandard to the Director of Operations and Compliance or otherwise in accordance with our Speaking-Up Policy. This includes any breach and any allegation of any breach of the law, regulation, professional standards, your suitability to practise in your professional capacity, your duties at any previous firm, the Internal Documents and our Culture. This excludes professional negligence complaints, claims and circumstances, which are reportable to the General Counsel and are dealt with in accordance with 4.4.2. We have a professional obligation to look after our clients with the utmost care and the firm expects the highest standards of work and behaviour in all that we do in the firm's name.

You can also make reports about finance matters to the Compliance Officer for Finance and Administration or €˜COFA', who is the Finance Director.

In order to achieve compliance under the Code, Central Office exercises oversight of matters such as AML, claims, Engagement Letters, Invoices, undertakings and money movements, while it leaves the de minimis compliance matters to a system of self-reporting and compliance training.

Examples of the type of compliance issues that you should report include incidences of or allegations of:

• Conflicts of interests
• Breach of client confidentiality
• Breach of our internal policies and procedures
• Negligence, and potential claims, complaints and poor service
• Other threats against the firm to take legal action, make an adverse public statement or to make a report to regulators or law enforcement
• Failure to comply with the terms of an undertaking
• Acting dishonestly or without integrity
• Other breaches of the Code, relevant laws, regulations or practice standards
• Behaviour inconsistent with our culture, for example, bullying, sexual misconduct, discrimination or harassment
• Acceptance of commercial or financial risks you consider may be reckless
• Other matters inside and outside the firm so long as it might reasonably be said that they adversely and materially impact on our business as a highly-respected law firm or that person as a regulated individual
• Anything else that you consider reportable

Where a report has been made to us, we will carry out an initial assessment to determine what we believe we need to do next and in particular, whether we need to undertake or bring in someone to undertake an investigation.

• We will let you know what we decide is the best course of action. We will aim to keep you informed of the progress of the investigation and its likely time scale. However, sometimes the need for confidentiality may prevent us giving you specific details of the investigation or any action taken as a result. You should treat any information we give you about the investigation as confidential.