Office Procedures ManualStephen Oldham Solicitors

1. Introduction1.1 IntroductionStephen Oldham Solicitors is a sole practitioner solicitors firm. Stephen Oldham is the only person involved in the firm and performs all roles.The firm conducts criminal litigation for its own clients and as agent for other firms.

1.2 StructureStephen Oldham is the only person involved in the business.Stephen Oldham will perform all of the following roles:

■ Sole principal■ Compliance Office for Legal Practice - COLP■ Compliance Officer for Finance and Administration - COFA■ Money Laundering Reporting Officer - MLRO■ Complaints manager

1.3 Business PlanThe business plan is in a separate document. There will be a formal review of the business plan every 12 months and an informal review every 6 months.

1.4 Business Continuity Plan1.4.1 Special ExecutorStephen Oldham will appoint a special executor to deal with his estate generally. There will be a clause in Stephen’s will appointing a Special Executor to deal with the firm. A specialist solicitor will be used to draft the will.The Special Executor will be a solicitor and a substitute will be nominated in the will to ensure better continuity.There will be a charging clause.These provisions will be enacted prior to the establishment of the firm.

1.4.2 Lasting Power of AttorneyStephen will execute a Lasting Power of Attorney for Property and Affairs appointing a practising solicitor as attorney specifically to deal with the firm.The attorney will be given general authority only in relation to the firm Stephen Oldham Solicitors.The Lasting Power of Attorney will be executed prior to the establishment of the firm.

1.4.3 Fire, theft and floodThe firm will operate from Stephen Oldham’s home. Should fire or flood strike there is a risk that files and records will be damaged.This policy ensures the following:

■ There is an easily accessible electronic copy of all possible documentation■ There is a minimum amount of material that it at risk of loss if fire, theft or flood occurs■ If one location suffers a disaster then there is an alternative set of records elsewhere

All of the following will be stored in 3 locations:■ Client files■ Letters■ Emails■ Court documents■ Statements■ Archived files■ Account records■ Office records■ Office manual■ Electronic diary

The 3 locations are:■ Stephen’s laptop computer which will be password protected to ensure that it cannot be

accessed if it is stolen■ An automatic backup of the laptop to a password protected external hard drive stored in

the office and linked via a computer network■ An encrypted cloud based backup of the hard drive located in the UK

Every effort will be made not to hold original un-replaceable documents such as driving licences at all.All valuables belonging to the firm or to clients documents including the firm’s cheque books will be kept in a locked safety box.All confidential videos and recordings will be kept in a locked safety box.All original documents will be returned to clients when the case is concluded.Content of paper files will be kept to a minimum. Electronic documents are available for most elements in criminal litigation.

1.5 Orderly Wind-Down Plan1.5.1 Stage 1 – planningIdentify reasons for closureIdentify closure dateIdentifying a successor practice if possibleIf possible a successor practice will be identified.If there is no alternative or if clients have not identified another firm files will be transferred to the identified successor practice.Notifying the SRA of financial or professional difficultiesThe SRA will be informed if there are serious financial difficulties including bankruptcy, insolvency, IVA/PVA, striking off or suspension.

1.5.2 Stage 2 – informing othersInforming clients

All clients for whom the firm is currently acting will be informed. They will be given as much notice as possible to enable them to instruct another firm. Clients will be given the opportunity to choose who they will instruct and their files will be transferred to their new firm.An non-current clients who will be affected will also be informed (i.e. if we are holding documents or there is any potential for their requiring access to archived records.)Informing the SRAAs soon as the decision to close the practice is made the SRA will be informed via operations@sra.org.uk, or via the SRA supervisor if applicable. The notification will include:

The date on which the firm will cease to practice The reason for closing (e.g. retirement, financial difficulties etc.); and A request to revoke your firm's authorisation or your recognition as a sole practitioner

from the date of closure.The SRA will also be informed:

If the date of the intended closure changes; and When all regulatry matters have been dealt with and the firm is fully closed.

Other bodies to notifyThe following will be informed if applicable:

Accountants Bank Counsel's chambers Court offices Crown Prosecution Service Information Commissioner (data protection) HMRC

1.5.3 Stage 3 – practicalitiesClient accountThere is no client account. If the firm opens a client account this plan will be modified.Indemnity insuranceThe firm’s insurers will be informed of the planned closure.If there is a successor practice, then run-off cover may be provided through the mechanism of the successor practice's insurance.If there is no successor practice run-off indemnity cover for 6 years will be purchased through the firm’s insurers.UndertakingsThere will be a review of undertakings still in force. Release will be sought from undertakings where possible. Appropriate arrangements will be made in respect of other undertakings,Undertakings in criminal litigation are relatively rare.Retention of records and filesArrangements will be put in place for the retention of all records. The SRA will be informed of the location of all records. Most, if not all, of the records will be held electronically. Files will be predominantly electronic but there may be significant numbers of paper files.

Records will include: Business records for 6 years; Accounts records for 6 years;

VAT records (if applicable) for 6 years; Money Laundering Records for 6 years; and Client/matter files for 6 years.

1.6 Type of Work to be ConductedThe firm will only conduct criminal litigation and advocacy either for its own clients or as agent for other firms.

1.7 Office ManualThis office manual is kept in electronic format.All changes to the manual are to be recorded in Appendix 3 - Change Log.

2. Policies and Standards2.1 ObjectivesTo provide a high quality service to individual clients.To provide a high quality service to business clients through agency services.To maintain the highest standards of compliance to the SRA, and other relevant statutory regulators.

2.2 Equality and DiversityThe firm has no current plans to engage any employees.The firm recognises the need to respect equality and diversity with respect to suppliers and will not discriminate in the choice of suppliers.The firm recognises the need to respect equality and diversity with respect to client groups and will not discriminate in the clients from whom it accepts instructions.The firm will subscribe to the Law Society Diversity Charter on start up.

2.3 Conflict of InterestsThe firm will not act when there is a conflict of interests between clients; personal conflicts of interests or professional conflicts of interests.File management procedures will ensure conflict checking takes place when a file is opened.

2.4 Risk Management2.4.1 AccountantThe accountant will have access to some of the firm’s records. There is a risk attached to this access being granted. This risk is mitigated by the professional standing and qualifications of the accountant.

2.4.2 DebtsNo work will be undertaken for clients unless they have paid in advance. That payment will have one of three formats:

Payment on account of the firm’s fees Payment of a fixed fee

Payment on account for an expert’s feeAgency work for other solicitors will be billed after the work is done. The risk of bad debts is mitigated by the fact that all of these bodies are regulated by the SRA. If any one firm proves to be a bad payer a review will take place as to whether to continue to work for them.The firm does not expect to have significant start up costs or overheads and is unlikely to establish any serious debt. If the firm does not make money then the risk is that Stephen Oldham will not have sufficient funds to live on. The business plan addresses this eventuality.

2.4.3 Case ManagementFile opening procedures will ensure that a risk assessment is undertaken at the outset of every case and at the end of every case.Whilst there is no specific procedure the firm will be mindful of case and client based risks at all times when dealing with client matters.

2.5 Money Laundering and Terrorist Financing2.5.1 Money Laundering Reporting OfficerStephen Oldham is the MLRO. Should there be any concerns of money laundering or terrorist financing the MLRO will report the matter to the National Crime Agency.

2.5.2 Criminal LitigationThe firm only conducts criminal litigation. The firm does not authorise itself to do any other type of work. This enables the firm to avoid many of the money laundering legislation.

2.5.3 Customer Due DiligenceCDD is not necessary.

2.5.4 Client Account DetailsThe details of our client account will not be disclosed to anyone other than: banks or other financial institutions; other solicitors or professionals acting for third parties in transactions for which we have full instructions; clients but only if strictly necessary for the legitimate deposit of funds by telegraphic transfer.

2.5.5 Cash PaymentsCash payments are not encouraged. Cash payments of more than £1,000.00 will not be accepted unless there is an adequate explanation of why funds cannot be deposited in the bank.

2.6 Bribery and Gifts from ClientsThe firm will not accept any bribes or gifts from clients.

2.7 ComplaintsInformation about complaints will be provided to clients in the opening client care letter/email. The standard working is in Appendix D.If a client makes a complaint the firm will send them a letter acknowledging receipt of their complaint within three days of receiving it, enclosing a copy of the complaints handling procedure.

Stephen Oldham will then investigate the complaint.Stephen Oldham will then invite you to a meeting (in person or by telephone) to discuss and hopefully resolve your complaint. He will do this within 14 days of sending you the acknowledgement letter. Within three days of the meeting, Stephen will write to the client to confirm what took place and any solutions agreed. If the client does not want a meeting or it is not possible, Stephen Oldham will send a detailed written reply to the complaint, including my suggestions for resolving the matter, within 21 days of the acknowledgement letter. If the client is still not satisfied and requests a review Stephen Oldham will review the decision.Stephen Oldham will write to the client within 14 days of receiving the request for a review, confirming the final position and explaining my reasons. The client will be informed of the services of the Legal Ombudsman.

2.8 Client FeedbackAll clients will be asked to provide feedback via an online form at the end of their case.An annual review of all client feedback will be performed. Changes to the firms policies may be made following the review.

2.9 ConfidentialityAll client matters will be kept confidential. No confidential material will be released to a third party except where required by the regulator, by law or by an order of the court.Client files will be kept secure when not in use.Data security is dealt with in the section of this manual dealing with IT.

2.10 TrainingStephen Oldham will comply with the CPD requirements of the SRA by completing 16 hours of CPD per year.

2.11 Professional StandardsThe firm will adhere to the highest professional standards. Compliance is the day to day responsibility of every person involved. The COLP and the COFA will be responsible for the day to day maintenance of the highest standards as well as the reporting of breaches.

2.12 COLP and COFA Reporting of BreachesAll material breaches will be reported to the SRA immediately.All non-material breaches will be reported to the SRA in an annual report.The COLP and COFA will report all breaches of the rules contained in the SRA Handbook including the SRA Code of Conduct and the Solicitors Accounts Rules to the SRA as follows:

2.12.1 Step 1When an incident takes place that is capable of being a breach I will report it to myself as COLP or COFA by completing a Breach Report and an entry in the Breach Register Form. A copy of the form is in the Office Procedures Manual.

2.12.2 Step 2I will assess the incident and perform a triage. Incidents will be classed as:

a. Not a breachb. A non-material breachc. A material breach

2.12.3 Step 3a. If the incident is not a breach no action is to be taken.b. If the incident is a non-material breach it will be recorded in the non-material breach

register which will be sent to the SRA annually.c. If the incident is a material breach the breach report will be sent to the SRA immediately.

Reports are made by email to reports@sra.org.uk In deciding whether a breach is material I will apply the following criteria. (If necessary I will contact the SRA Advice helpline):

the detriment, or risk of detriment, to clients  the extent of any risk of loss of confidence in the practice or in the provision of legal

services  the scale of the issue  the overall impact on the practice, its clients and third parties.

2.12.4 Annual Report and ReviewI will complete an annual COLP and COFA report to the SRA.I will conduct an annual review of reports of material and non-maerial breaches. I will consider changing the firms practices and procedures if there is a concerning number of breaches or a pattern of repeat breaches.If there are more than 5 non-material breaches or 2 material breaches in a 12 month period I will complete additional training and review the firm’s procedures.

2.13 Whistle BlowingThere will not be a whistle blowing policy due to the fact that the firm only has one member. Should the firm expand then a whistle blowing policy will be formulated.

2.14 Claims Against the FirmAll claims will be referred to the PII insurer immediately.

2.15 PII InsuranceThe firm will have a PII insurance policy in line with the requirements of the SRA.

2.16 Communicating with the SRAThe firm will comply with the SRA.The following will be reported to the SRA:

2.16.1 As a solicitor■ within 7 days if we have

■ been committed to prison in civil or criminal proceedings;■ been charged with or convicted of an indictable offence;■ made the subject of bankruptcy proceedings;

■ made a proposal for an individual voluntary arrangement or are the manager of a firm which made a proposal for insolvency

■ been admitted as a member of a legal profession of a jurisdiction other than England and Wales or a lawyer of England and Wales other than a solicitor

■ been made subject to disciplinary proceedings as a member of a legal profession of a jurisdiction other than England and Wales or a lawyer of England and Wales other than a solicitor

■ become a manager of, or acquire any interest in, a firm which is a non-ABS, or become a manager or owner of a firm which is regulated by another approved regulator

■ set up a sole practice as a member of a legal profession of a jurisdiction other than England and Wales or as a lawyer of England and Wales other than a solicitor

■ changed their name as shown on the Roll■ ceased to practice (Practising Regulations, 14)

■ within 14 days, of any change in place or places of business, if they have, or have applied for, a practising certificate (s84, Solicitors Act 1974)

2.16.2 As a firm■ promptly, any material changes to relevant information about you including:

■ serious financial difficulty,■ action taken against you by another regulator and■ serious failure to comply with the handbook (Chapter 10, outcome 3)

■ serious misconduct by any person or firm authorised by the SRA, or any employee, manager or owner of any such firm (Chapter 10, outcome 4)

■ comply with the SRA’s requests for other information (Chapter 10 Outcome 6 -11)■ inform the SRA when you become aware that your firm will cease to practice (Chapter

10, outcome 13)

2.16.3 As a compliance officer■ any material failures to comply to the SRA, as soon as reasonably practicable.

2.17 Communicating with the Legal OmbudsmanThe firm will release all materials correctly required by the Legal Ombudsman and will comply with investigations by the Legal Ombudsman.The firm will inform all clients about the Legal Ombudsman in client care letters and in Complaints Handling documentation.

2.18 Community Access to JusticeThe firm will promote access to justice in the following ways:

■ Signposting enquiries who wish to engage a solicitor under the Legal Aid Scheme to an appropriate local provider

■ Taking on one client per month on a reduced fee scheme at Legal Aid rates or lower (the qualifying criteria will be either receipt of passport benefits, receipt of the minimum wage or an equivalent income)

■ Providing services to Legal Aid clients by acting as agent for other firms with a Legal Aid contract

3. Case Management3.1 Introduction3.2 Client EnquiriesAll client enquiries whether by email or telephone will be dealt with by Stephen Oldham.Matters that we cannot deal with will be signposted to an appropriate alternative supplier where the firm is aware of one.The firm aims to deal with all enquiries within one working day.

3.3 Accepting Instructions3.3.1 Individual ClientsInstructions will be accepted by email, telephone, post or in person.Instructions will only be accepted in areas of law which the firm conducts.The file opening form must be completed before instructions are formally accepted.An entry in the case log will be made when the file is opened.A client care email will be sent to clients immediately on acceptance of instructions.

3.3.2 Other FirmsInstructions to act for other firms as agent will be accepted by email, telephone, post or in person.The usual practice is to confirm terms by email. If this is not practicable it is acceptable to agree a fee and basic terms verbally.A file opening form will be completed.An entry in the case log will be made.

3.4 Conflicts of InterestsThe file opening form has mandatory sections for the checking of conflicts of interests in the following areas:

■ Other clients■ Witnesses■ Personal■ Professional■ Other

The firm will not act if there is a conflict of interests.

3.5 Outset of the MatterAt the outset of the matter the following steps will be taken:

■ Complete file information form■ Obtain client information and details■ Open a paper file if necessary

■ Allocate a file reference number and open an electronic record of the case■ Open an accounts record■ Obtain payment on account or payment of a fixed fee■ Send client a client care email/letter■ Take client’s full instructions and a proof of evidence if it is likely that there will be a

guilty plea (in most cases instructions can be taken over the telephone)■ Advise client verbally and confirm that advice in writing■ Record all key dates■ Make arrangements to attend court/police station attendance

3.6 Referrals from OthersThe firm will accept referrals from others.The firm will not make any payments or offer any other inducements for referrals.The firm will be mindful of conflicts of interests when accepting referrals.

3.7 File MaintenanceThe firm will keep paper files. Those files will not be a comprehensive record of the case. They must be read in conjunction with the electronic file.All files will have:A file progress sheet with key datesA list of original documentation and their locationA reference to the location of the electronic file (a file path and file reference)

3.8 Dealing with DocumentsWe will try to avoid holding original documents.Valuable documents such as driving licences will be kept in a secure box in the office.The location of valuable documents will be recorded on the file progress sheet.

3.9 Key DatesKey dates are as follows:

■ Police station dates■ Court dates■ Dates for compliance with directions■ Appointment (client or others)■ Reminders about other key dates (e.g. 1 week warning for a compliance with a direction)■ Inactivity check dates■ File destruction date■ Other important dates

Key dates are recorded in 3 locations:■ On the paper file progress sheet■ In a central paper diary■ In a central electronic diary which is backed up in a separate location

3.10 Progressing MattersClients will be informed in writing about the progress of their case.

Files will be monitored for inactivity. No file will be left for more than 3 months without an activity check being made.

3.11 Costs UpdatesClient will be informed of likely costs at the outset of their case.We aim to offer fixed fees for the majority of our work.Client will be informed in writing of the following changes in case costs immediately when they occur:

■ Costs for experts■ Costs of counsel if they are not included in a fixed fee■ Additional or increased costs from us■ Changes in charging rates■ Additional fixed fees that need to be paid■ Fees for experts to attend court■ Liability if experts’ fees are not met by the court■ Amount of costs recovery■ Any other factors that increase (or decrease) the cost of the case

3.12 Continuing Risk ManagementThe file opening form has a mandatory risk assessment for every new case.Risk to the client and risk to the firm should be borne in mind every time an action takes place on a file. A full risk assessment is not necessary.If client’s instructions change or if the nature of the case changes significantly then a new full risk assessment may be necessary. It should be recorded on a fresh file opening form.

3.13 Inactivity ChecksFiles that have not had any action in 3 months will have a mandatory file review.This will be monitored in the following way:

■ The next key date for a file is recorded on the file and in the diary■ If that key date is in the next 3 months then no action is required as work will be done on

the file within the 3 month period■ If the key date is more than 3 months away then a file review key date will be put in the

diary

3.14 File ReviewsFiles will be reviewed on an ongoing basis. All files will be reviewed every 3 months in line with the inactivity procedure outlined.A brief review of all files will take place once a month.

3.15 UndertakingsOnly Stephen Oldham is authorised to give undertakings.All undertakings are recorded on the file progress sheet.A central electronic log of undertakings will be kept.Files cannot be closed until the undertaking has been discharged or has expired.

3.16 Consumer Contracts and Distance SellingAll contracts will be completed on the firm’s premises.Clients who sign up over the telephone or via email will be told that they have a 7 day cooling off period during which they may cancel their instructions.Any unused funds will be refunded should the client cancel.

3.17 Instructing Counsel and ExpertsAll instructions to counsel and experts will be made in writing. They will be recorded on the client’s file.Fees will be agreed before instructions are provided.A register of counsel and experts will record the following:

■ Name■ Contact details■ Expertise■ Date of first instructions■ Status

■ A - First instruction/probationary period■ B - Qualified approval with details of qualifying criteria■ C - Full approval■ X - Blacklisted do not use

■ Complaints■ Comments

3.18 End of the CaseAt the end of a case the following steps will be taken.

■ Final letter sent to client■ Client feedback requested■ Original documents returned to client■ Accounts review■ File closing form and risk assessment■ Paper files into storage■ Location of stored paper file recorded in a central register (if possible the paper file

should be scanned and shredded - this can only be done if there are no original documents and no items such as photographs or DVDs)

■ Electronic file archived■ Diary entry made for six years time to destroy the file

3.19 Notice of Right to CancelClients who sign up over the telephone or via email will be told that they have a 7 day cooling off period during which they may cancel their instructions.

4. Accounts4.1 Responsibility for Financial ManagementStephen Oldham has overall responsibility for financial management.Stephen Oldham is responsible for all accounts.The firm’s accountant is Jeremy Bostock of Thomson Wright Chartered Accountants.The firm’s client and office bank accounts are with Santander Bank, Newcastle-under-Lyme Branch.Stephen Oldham is trained by Jeremy Bostock to set up and administer accounting systems.Stephen Oldham is the only authorised signatory for office account cheques and payments.Stephen Oldham is the only authorised signatory for client account cheques and payments.Stephen Oldham with the assistance of the accountant is responsible for compilation of the following:

■ Annual Budget■ Annual Balance Sheet■ Quarterly monitoring■ Profit and loss account■ Variance Analysis■ Work in progress■ Average cost of case

4.2 Client AccountThe firm will not operate a client account.Disbursements will be dealt with in one of 3 ways:As part of the quoted fixed fee (counsel’s fees, travel expenses and some experts fees).

■ Experts fees will be invoiced in advance to the client when the expert is instructed. The experts fees will then become a liability of the firm.

■ Experts will invoice clients directly when they are prepared to.■ Wasted costs and defence costs order payments will be claimed in the client’s name and

they will be paid directly.

4.3 Receipts into Office AccountReceipts will be recorded and banked on the day that they are received.

4.4 Payments OutPayments out can only be authorised by Stephen Oldham.

4.5 Cash ReceiptsReceipts will be banked the same day. The firm does not encourage cash payments.

4.6 Petty CashStephen Oldham will make cash payments from personal funds and claim money back directly from the firm.

4.7 Time RecordingAttendance notes on files will record time spent. Those records will be used for the preparation of a bill using hourly rates.

4.8 BillingThe majority of bills to clients will be fixed fees paid and invoiced in advance. The firm does not intend to bill clients on an hourly rate except in unusual circumstances.Any other client bills will be submitted within 28 days of the conclusion of the case.Clients may be presented with interim bills during the progress of the case.Bills for agency work will be sent out within 28 days.

4.9 Debit/Credit Card PaymentsPayments will be received into office account and will be processed in accordance with the bank’s conditions and regulations.

4.10 Protecting Client AssetsThe firm will not operate a client account and will not hold client assets.

5. Office5.1 LocationThe firm will operate from Stephen Oldham’s home.

5.2 TelephonesAll calls will be diverted to Stephen’s mobile telephone. Voicemail is active when the call cannot be taken.

5.3 Library and Knowledge BaseLegal updates will be maintained by:

■ Crimeline■ Copy of Archbold■ Copy of Stones Justices Manual■ Internet sources

5.4 OutsourcingThe firm does not outsource work.Work conducted by agents, counsel or experts does not come under the rules on outsourcing.

5.5 Information Technology5.5.1 Mobile phonesAll mobile phones will be password protected.

5.5.2 ComputersAll computers will be passport protected.

5.6 Information Management PolicyThe firm will register with the Information Commissioner’s Office under the Data Protection Act.Electronic documents will only be stored in the office or on cloud servers with appropriate security credentials:

■ ISO 9001 (quality management) standard■ ISO 27001 : 2005 (security management) standard■ ISAE 3402 (assurance reporting) standard■ BS 27999 (business continuity management) standard■ TIA 942 standard (requirements for a Tier 3 data centre)

The Information Security Policy is in a separate document.

5.7 Website and emailThe firm will maintain a website and a blog.Website hosting will be provided by: wordpress.com.Email is hosted by privateemail.com.

5.8 Paper filesWherever possible all documentation is kept in electronic format.All papers will be scanned and stored on the client/mater electronic file. The original paper document will then be shredded and disposed of.Where original papers have to be kept they will be kept in the client/matter paper file. This applies to:

Any original papers bearing an original signature Signed statements Original documents such as driving licences Any other document where the original must be kept.

All paper files are kept in a locked filing cabinet.All original documents such as driving licences will be sent back to clients at the conclusion of their case. The firm will not store documents or other items for clients.All paper and electronic client/matter files will be destroyed after 6 years of the conclusion of the case.For the avoidance of doubt no papers relating to client/matter files will be left outside a locked cabinet unless they are being worked on.

5.9 Confidentiality – familyAdult family members living at the home/office will be required to sign a confidentiality agreement stating the following:

1. I will not open any post addressed to Stephen Oldham Solicitors.2. I will not read any documents that belong to Stephen Oldham Solicitors.3. I will not access any electronic devices or documents that are the property of Stephen

Oldham Solicitors.4. If I inadvertently come into contact with any document or information relating to Stephen

Oldham Solicitors I will inform Stephen Oldham immediately.

5. If I inadvertently come into contact with any document or information relating to Stephen Oldham Solicitors I will not reveal that information to any third party unless authorized to do so by a member of Stephen Oldham Solicitors or by operation of the law.

Children and visitors are expected to be supervised by those adults!

5.10 PostPost is all opened by Stephen Oldham. Other family members are covered 5.8 Confidentiality – Family above. Other persons may not open post addressed to the firm.

5.11 Monthly ReviewAt the end of every month the following reviews will take place:

Check all outstanding invoices Chase up all outstanding invoices that are more than 28 days overdue Draw out of pocket expenses Archive all case files that were concluded in the previous month (i.e. files concluded in

January to be archived at the end of February etc.)

Appendix A - Forms and PrecedentsThese forms are in separate Word/PDF Files

1. COLP Breach Report2. COLP Breach Report3. COFA Material Breach Report4. COFA Non-Material Report5. File Risk Assessment Form6. Engagement Letter and Terms of Business

Appendix C - Change Log9/11/2014 Added sections 5.8, 5.9 and 5.106/1/2015 Added section 1.5 Orderly Wind-Down Plan6/1/2015 Amended 2.12 COLP/COFA Reporting Procedure1/3/2015 Amended 3.5 to read file information form30/3/15 Add 5,11 Monthly review22/5/15 Add reference to external Information Security Policy at 5.6

Appendix D - Complaints procedureStandard wording for all client care lettersComplaints

Stephen Oldham Solicitors is committed to high quality legal advice and client care. If you are unhappy about any aspect of the service you have received or about the bill, please contact Stephen Oldham by telephone, email or by post to the office. A procedure is in place which details how we handle complaints which is available on request from the person dealing with your case or from the office.Stephen Oldham Solicitors has eight weeks to consider your complaint. If it has not been resolved within this time you may complain to the Legal Ombudsman.If you are not satisfied with the handling of your complaint you can ask the Legal Ombudsman at PO Box 6806, Wolverhampton WV1 9WJ to consider the complaint. Normally, you will need to bring a complaint to the Legal Ombudsman within six months of receiving a final written response from Stephen Oldham Solicitors about your complaint or within a year of the act or omission about which you are complaining occurring (or you becoming aware of it).

Complaints procedure noticeStephen Oldham SolicitorsComplaints Handling PolicyI am committed to providing a high-quality legal service to all our clients. When something goes wrong, you need you to tell me about it. This will help me to improve our standards.

If you have a complaint, please contact me with the details. I have eight weeks to consider your complaint. If I have not resolved it within this time you may complain to the Legal Ombudsman.

What will happen next?

I will send you a letter acknowledging receipt of your complaint within three days of receiving it, enclosing a copy of this procedure.

I will then investigate your complaint.

I will then invite you to a meeting to discuss and hopefully resolve your complaint. I will do this within 14 days of sending you the acknowledgement letter.

Within three days of the meeting, I will write to you to confirm what took place and any solutions I have agreed with you.

If you do not want a meeting or it is not possible, I will send you a detailed written reply to your complaint, including my suggestions for resolving the matter, within 21 days of sending you the acknowledgement letter.

At this stage, if you are still not satisfied, you should contact me again and I will review the decision.

I will write to you within 14 days of receiving your request for a review, confirming my final position on your complaint and explaining my reasons.

If you are still not satisfied, you can then contact the

Legal Ombudsman, PO Box 6806WolverhamptonWV1 9WJ

about your complaint. Normally, you will need to bring a complaint to the Legal Ombudsman www.legalombudsman.org.uk.) within six months of receiving a final written response from me about your complaint or within a year of the act or omission about which you are complaining occurring (or you becoming aware of it). For further information, you should contact the Legal Ombudsman on 0300 555 0333 or at enquiries@legalombudsman.org.uk.