A senior in-house solicitor who failed to disclose that he had arranged work for a close relative has been fined by the SRA.
Jeremy Bouch, formerly general counsel with Volkswagen Financial Services (UK) Limited, admitted suggesting his close relative could do the work and approving payment of invoices which included their fees. The SRA said these fees ‘appeared excessive’ but they were paid by VFS without Bouch revealing his connection with the person in receipt of them.
Bouch, who was admitted as a solicitor in 1998, joined VFS in 2016 as head of legal compliance before his title was changed to general counsel.
His employer provided fleet vehicles which it leased to customers, and engaged a third-party company to process notices incurred for speeding offences and parking fines.
When that third party failed to attend to this, it resulted in fines being imposed and enforced against VFS, prompting the company to task Bouch to instruct another firm to deal with the issue. One of the firm’s solicitors was a longstanding friend of Bouch’s, the SRA said.
That firm expressed doubts about being able to carry out the work, so Bouch suggested his relative, a solicitor, could assist. In 2019, two invoices coming to £95,150 were submitted by the firm, with no breakdown of who had done the work.
Bouch cancelled the arrangement with this firm in June 2019 and VFS started an investigation into his conduct and approval of invoices. In August 2019 he resigned from the company.
Bouch admitted causing or allowing an own-interest conflict by instructing a firm where his friend was a solicitor, then suggesting to that firm that his relative could work on its cases. Neither of these links were disclosed to his employer.
He put forward mitigation that he was experiencing significant health and personal issues at the time of misconduct and was focused at the time on resolving these cases as a priority which allowed his judgement to be impaired.
The SRA considered that his conduct was planned and had the potential to cause harm to VFS. The engagement of his relative was instigated by Bouch and his failure to inform his company persisted for longer than was reasonable.
With Bouch having no regulatory history, the SRA fined him £2,000 and ordered costs of £600.
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