Anti-Bribery, Anti-Money Laundering & Zero Referral Fee Policy
Effective from: 02.11.2018
Approved by: Robin, Founder, Arthaat Legal
1. Our Commitment
Arthaat Legal earns every engagement on the merit and quality of its work. We do not offer, pay, request or accept bribes, kickbacks, commissions or improper advantages of any kind, whether to or from public officials or private individuals.
As a compliance audit practice, our clients rely on our independence. This Charter sets out the standards we hold ourselves to, so that clients, their compliance teams and their auditors can engage us with confidence.
2. Applicable Laws
This Charter is designed to support compliance with the Prevention of Corruption Act, 1988 (as amended in 2018) and the Prevention of Money Laundering Act, 2002. It is also informed by international anti-bribery standards relevant to our multinational clients, including the UK Bribery Act, 2010 and the US Foreign Corrupt Practices Act, 1977.
3. Scope
This Charter applies to the founder, all employees, associates, interns and consultants of Arthaat Legal, and to any third party engaged to work on our behalf.
4. Zero Tolerance for Bribery
We do not:
offer, promise, give, request or accept any bribe, directly or through any other person;
make facilitation or “speed” payments to any government official to expedite routine actions, registrations, approvals or inspections;
offer anything of value to influence a decision of a client employee, auditor, official or any other person.
This applies to dealings with public servants and private persons alike.
5. Zero Referral Fee Policy
Arthaat Legal neither pays nor receives referral fees, commissions, finder’s fees or any share of fees for introducing or obtaining work.
We pay third parties only for genuine services actually rendered, at fair market value, under written terms.
No person is paid for procuring an engagement or introducing a client.
Where we collaborate with other professional firms, each firm defines its own scope and bills the client directly and transparently.
This preserves the independence of our audit findings and means our fees reflect only the work we deliver.
6. Gifts, Hospitality and Entertainment
We do not give or accept cash or cash equivalents (gift cards, vouchers, securities) in any circumstances.
Gifts or hospitality of nominal value given or received in the ordinary course of business must be modest, infrequent, transparent and never connected to a pending decision, engagement or audit outcome.
We do not offer gifts or hospitality to government officials.
7. Fee and Payment Integrity
Every engagement is governed by a written engagement letter that sets out the scope and fees.
All fees are invoiced through proper tax invoices.
We do not accept fees in cash. All payments are received only through banking channels.
We accept payment only from the client’s own account. We do not accept payments from unrelated third parties on behalf of a client.
Refunds, if any, are made only to the account from which payment was received.
8. Anti-Money Laundering and Client Due Diligence
Before accepting an engagement, we:
verify the identity of the client and, for entities, take reasonable steps to understand their ownership and authorised signatories;
assess whether the engagement is consistent with the client’s known business;
decline any engagement, or withdraw from it, where we have reasonable grounds to suspect that funds are derived from unlawful activity or that our services are being sought to facilitate a crime.
We cooperate with lawful requests from competent authorities in accordance with applicable law.
9. Engaging Third Parties
Any associate, subcontractor or service provider engaged by us must:
be selected on the basis of competence and fair pricing;
be engaged through written terms that require compliance with this Charter;
be paid only against documented work actually performed.
10. Conflicts of Interest
We identify and disclose any actual or potential conflict of interest before accepting an engagement. Where a conflict would compromise the independence of our work, we decline the engagement.
11. Political and Charitable Contributions
We make no political contributions on behalf of the firm. No charitable contribution or sponsorship is made to obtain or retain business or to influence any decision.
12. Records
We maintain accurate books, records, engagement letters and invoices that fairly reflect every transaction. No off-the-books payments or accounts are permitted.
13. Raising Concerns
Anyone who suspects a breach of this Charter, whether a client, employee, collaborator or member of the public, may write to us in confidence using contact us option given in this website. Concerns raised in good faith will be examined promptly, and no person raising a concern in good faith will face retaliation.
14. Consequences of Breach
Any breach of this Charter by a member of the firm will lead to disciplinary action, which may include termination. Any breach by a third party will lead to termination of the relationship. Matters will be reported to authorities where required by law.
15. Review
This Charter is reviewed at least once a year and updated to reflect changes in law and practice. All members of the firm acknowledge it in writing when they join and annually after that.