CQS (CPMS) Anti-Bribery Policy
The recent update to the CQS Core Practice Management Standards (CPMS) requires CQS firms to have a policy in place in relation to Anti-Bribery (s5.14).
Policy documents can be time-consuming and difficult to prepare without a Policy Template as a starting point.
Lexsure’s COMPLETIONmonitor team have drafted a set of policy templates designed to make it simpler for conveyancing firms to meet their compliance obligations .
The Anti-Bribery Policy Template includes reference to:
- Gifts and Hospitality
- Responsibilities (including record keeping)
- Kickbacks
- Non-compliance implications
...as well as other formalities and general obligations as required under 5.14 of the CPMS.
CONTENTS Document Properties Change Control Associated Policies Contents 1. Introduction 2. Policy 3. Gifts and hospitality 4. Responsibilities 5. Non-compliance 6. Recognising environments for heightened risk
Exclusions to note
Sample template bundles do not include a template to show the structure of the residential conveyancing department at a firm. The data protection policy template covers the requirements of CQS, however it is the responsibility of the firm to ensure it is compliant with the requirements of the General Data Protection Regulation.
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