ANTI-BRIBERY AND CORRUPTION (ABC) ENFORCED PRACTICE: LD CONSULTORES (VENEZUELA)
Company: LD Consultores C.A.
Jurisdiction: Bolivarian Republic of Venezuela
Effective Date: January 2026 (Revised)
1. Zero-Tolerance Mandate
LD Consultores operates under a strict zero-tolerance policy regarding bribery, kickbacks, and facilitation payments. In a jurisdiction with high administrative complexity, our firm maintains a “Compliance First” approach. We strictly prohibit the offering, promising, or giving of anything of value to a public official or private counterparty to influence an outcome or secure a business advantage.
2. Public Official Interaction Protocol
Given our role in Employment of Record (EOR) and statutory compliance, our staff frequently interacts with Venezuelan labour and tax authorities (IVSS, INCES, BANAVIH, SENIAT).
- Transparency: All payments to government bodies must be made via traceable bank transfers and supported by an official, serialised government receipt.
- Facilitation Payments: We categorically prohibit “expediting” or “grease” payments to expedite the movement of files through the bureaucracy. Our continuity is based on technical legal expertise, not illicit influence.
3. Third-Party and Sub-Contractor Oversight
Any third party (e.g., local logistics or physical security providers) acting on behalf of LD Consultores must sign a “Compliance Affirmation.” We hold our partners to the same ethical standards as our internal staff, conducting periodic audits of their billing to ensure no “hidden” costs are used for improper purposes.
ANTI-BRIBERY AND CORRUPTION (ABC) ENFORCED PRACTICE: L&A ATTORNEYS AT LAW (UK)
Company: León & Associated Attorneys at Law Ltd.
Jurisdiction: United Kingdom / International Advisory
Compliance Standard: UK Bribery Act 2010
1. Regulatory Alignment
As a UK-incorporated legal consultancy, L&A Attorneys at Law operates in full compliance with the UK Bribery Act 2010. We recognise our responsibility to prevent bribery not only within our direct operations but also by “associated persons” acting on our behalf globally.
2. High-Risk Jurisdiction Controls
When advising on matters involving high-risk jurisdictions, L&A implements enhanced due diligence. We ensure that all legal strategies provided to clients are strictly within the letter of the law. We do not engage in, nor do we tolerate, any conduct that could be construed as “Failing to Prevent Bribery” under Section 7 of the Act.
3. Gifts, Hospitality, and Expenses
The firm maintains a formal “Gifts and Hospitality Register.” Any business courtesy extended to or received from a client or third party must be:
- Proportionate and reasonable.
- Professionally justified.
- Approved by the Managing Partner if exceeding the firm’s set de minimis threshold.