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CQS Anti-Bribery Policy: Considerations

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The Conveyancing Quality Scheme (CQS) is the recognised quality standard for SRA-regulated firms in residential conveyancing. It sets out the standards of competence, risk management, and client service levels expected of practices.

An essential element of the CQS Core Practice Management Standard is the anti-bribery policy. This policy must clearly articulate the firm’s dedication to combating bribery and corruption, customised to address the firm’s unique risk factors. When crafting a CQS Anti-Bribery Policy, you may wish to take into account the following considerations:

  1. Risk assessment: The anti-bribery policy should include a formal process for assessing the vulnerability of each of the firm’s business lines to bribery and corruption on an ongoing basis.
  2. Procedures: The policy should outline the procedures that the firm has in place to prevent bribery and corruption, including due diligence procedures for third-party relationships, gifts and hospitality, and facilitation payments².
  3. Training: You may want the policy to outline the training that the firm provides to its employees on anti-bribery and corruption measures.
  4. Monitoring and review: The policy should include a process for monitoring and reviewing the effectiveness of the firm’s anti-bribery and corruption measures.

An effective CQS anti-bribery policy plays an important role in mitigating the risk of claims and safeguarding the firm’s reputation. Furthermore, it serves as a testament to the firm’s dedication to ethical business practices and fosters trust with clients and industry stakeholders.

The Anti-Bribery Policy – A Key Document in the CQS Audit Process

Within a two-week timeframe from the notification date, CQS firms are required to supply a range of crucial policy documents. These may encompass Anti Money Laundering policies, an SDLT (Stamp Duty Land Tax) Policy, Dealing with Lenders Policy, Anti-bribery policy, and CQS Mortgage and Proprty Fraud prevention policies.

During the audit, the CQS assessor will carry out a comprehensive full-day review. This will encompass an opening meeting, a thorough examination of CQS policies and procedures (in accordance with the Core Practice Management Standard), review of central records, assessment of both open and closed files, as well as interviews with specific personnel.

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