Foran Glennon (UK) LLP is a limited liability partnership registered in England and Wales, with registered number OC396971. The LLP is authorised and regulated by the Solicitors Regulation Authority SRA Number 619964. A list of members of is available for inspection at the LLP’s registered address at 3rd Floor, 11 Leadenhall Street, London EC3V 1LP. The word “partner” denotes an LLP member, or a consultant or employee with equivalent standing and qualifications.“Foran Glennon” is the trading name of an international affiliation of legal practices consisting of FG(UK)LLP and Foran Glennon Palandech Ponzi & Rudloff PC (“FGPPR PC”) which has offices across the United States. “Foran Glennon” does not provide legal services and all legal services are provided to clients by FG(UK) LLP and/or FGPPR PC, each of which is a separate and distinct legal entity. Our clients’ contractual retainers will be with FG(UK) LLP and/or FGPPR PC as the terms of the engagement with the respective entity will expressly so specify. The use of the term “partner” should not be construed as meaning that any form of general partnership exists between FG(UK) LLP and/or FGPPR PC.
LEGAL AND REGULATORY INFORMATION
FG(UK) LLP (or “we”, “us”, “our”) have set out below some additional information which we are obliged to provide to clients (as provided for in our standard Terms of Business). If you are a client and would like to receive the current Terms of Business and/or any other information in hard copy, please contact your Client Relationship Partner. [FG(UK) LLP is authorised and regulated by the Solicitors Regulation Authority (“SRA”). The SRA Handbook 2011 sets out our professional and ethical rules and obligations (including the SRA Code of Conduct and SRA Accounts Rules), and can be viewed at www.sra.org.uk]. FG(UK) LLP is registered for Value Added Tax purposes with VAT number: 209 9228 91.
FINANCIAL SERVICE AND MARKETS ACT 2000
Some investment-related activities (including insurance mediation activities) of FG(UK) LLP are regulated under the Financial Services and Markets Act 2000 of the United Kingdom (“FSMA”). Like most law firms, we are not authorised by the Financial Conduct Authority (the “FCA”) under FSMA. Instead, we are authorised and regulated by the SRA. The Law Society is a designated professional body for the purposes of FSMA, but responsibility for regulation and complaints handling has been separated from the Law Society’s representative functions. The SRA is the independent regulatory body of the Law Society and the Legal Ombudsman deals with complaints about lawyers registered in England and Wales. In the light of this, we can provide investment-related services (including insurance mediation activities) if they are an incidental part of the professional services we have been engaged to provide, if they can reasonably be regarded as a necessary part of our professional services or if we are otherwise permitted to provide them under FSMA. For the purpose of insurance mediation activities (broadly, advising on, selling and the administration of insurance contracts), we are included on a register maintained by the FCA and are permitted by the FCA to carry on insurance mediation activities. This register can be accessed via the FCA website at www.fca.org.uk/register.
FG(UK) LLP may require clients to provide documents and information concerning the contracting client entity and related persons, entities or affiliates as set out, in order to comply with relevant anti-money laundering laws and regulations. We may be prevented from carrying out your instructions if we are unable to meet our requirements, which often include verifying the identities of your ultimate beneficial owners. We may be required by law or regulation to report to a governmental or regulatory authority our knowledge and/or suspicion that certain criminal offences have been committed, regardless of whether such an offence has been committed by a client of ours or by a third party. We may not be able to discuss such reports with you because of restrictions imposed by those laws and regulations, and we may have to cease acting for you in those circumstances. You agree that FG(UK) LLP are not responsible for any adverse consequences you may suffer as a result of our compliance with such laws and regulations, whether caused by our inactivity or otherwise.
ANTI-BRIBERY AND CORRUPTION
FG(UK) LLP’s policy is to act at all times in accordance with the highest professional, ethical and business standards, and we expect the same from our clients and their related persons, entities or affiliates. We have a zero tolerance approach to bribery or corruption and you agree not to expect or request any conduct from us that might bring our name into disrepute or compromise our integrity and independence and that you or your related persons, entities or affiliates will refrain from any practices involving bribery or any other corrupt activities.
CLIENT AUDIT REQUESTS
If FG(UK) LLP are required by any governmental or regulatory body, or by your auditing accountants or any other service provider appointed by you, to produce documents or provide information on any engagement, we shall be entitled to bill you for the work involved (and any disbursements or expenses incurred) at the rates agreed for the relevant matter. In response to any request to provide information to your auditors, our policy is to comply with the laws and regulations applicable to us and in particular with the guidance from the Law Society of England & Wales and with the American Bar Association Statement of Policy Regarding Lawyers’ Responses to Auditors’ Requests for Information.
We want to give you the best possible service. However, if at any point you become unhappy or concerned about the service we provided then you should inform us immediately, so that we can do our best to resolve the problem. In the first instance it may be helpful to contact the person who is working on your case to discuss your concerns and we will do our best to resolve any issues at this stage. If you would like to make a formal complaint, then you can read our full complaints procedure here. Making a complaint will not affect how we handle your case. The Solicitors Regulation Authority can help you if you are concerned about our behaviour. This could be for things like dishonesty, taking or losing your money or treating you unfairly because of your age, a disability or other characteristic. You can raise your concerns with the Solicitors Regulation Authority.
WHAT TO DO IF WE CANNOT RESOLVE YOUR COMPLAINT
The Legal Ombudsman can help you if we are unable to resolve your complaint ourselves. They will look at your complaint independently and it will not affect how we handle your case. Before accepting a complaint for investigation, the Legal Ombudsman will check that you have tried to resolve your complaint with us first. If you have, then you must take your complaint to the Legal Ombudsman:
- Within six months of receiving a final response to your complaint
- No more than six years from the date of act/omission; or
- No more than three years from when you should reasonably have known there was cause for complaint.
If you would like more information about the Legal Ombudsman, please contact them.
CLIENT ACCOUNT AND INTEREST
Pursuant to the SRA Accounts Rules, FG(UK) LLP’s policy is to account to our clients for a sum in lieu of interest on a fair and reasonable basis. If the total amount of interest calculated over the course of a matter is less than £20 no payment in lieu of interest will be paid. Client monies will be deposited in a general client account (an instant access account in which amounts for different clients are pooled) unless we are instructed to create a separate designated account. In any event, it is unlikely that a client will receive as much interest as might have been obtained had the funds been invested by the client itself.