Polly is a Solicitor and Senior Manager in the Regulatory and Commercial Disputes Team. Polly is PwC UK’s lead legal advisor for corporate compliance with the UK’s Modern Slavery Act. She regularly advises clients in relation to the compliance and governance of their regulatory and legal risk profile. Her work on modern slavery compliance is paired with her ability to assess the operational effectiveness of legal policies also with regards to anti-bribery and corruption controls, fraud prevention, anti-money laundering and the corporate criminal offences of the facilitation of tax evasion. Polly is equipped with the knowledge and skillset to advise clients in enhancing their policies and procedures and synergising their functionality and controls.
Polly has worked on several investigations and regulatory matters and has assisted in the representation of clients on a number of multi-jurisdictional investigations involving UK and international regulators such as HM Treasury, HMRC, the Financial Ombudsman Service and the Financial Conduct Authority. These investigations have included those initiated by suspicions of or allegations of mis-selling, fraud, bribery and tax evasion. During these investigations Polly has assisted clients in the design, implementation and monitoring of enhanced internal compliance systems.
- Advised a range of clients in the Financial Services, IP&S and Retail sectors with compliance with the Criminal Finances Act, Money Laundering Regulations, UKBA, and the Modern Slavery Act. Projects have included compliance reviews, impact and risk assessment workshops and advising on the implementation of reasonable policies and procedures.
- Advised numerous clients in the energy, sports, leisure, financial services, pharmaceutical and construction industries on their corporate compliance obligations under the UK’s Modern Slavery Act. Conducted a review of clients’ existing relevant policies, procedures and controls to produce a gap analysis and risk assessment identifying their risk profile for both their business and supply chains.
- Provided on-site secondment support over five years for a UK commercial banking group in a remediation project responding to a Financial Conduct Authority (FCA) mis-selling review. Liaised with the FCA, Financial Ombudsman Service, the bank’s legal department and bank stakeholders while acting as the Project Lead and the consequential loss subject matter expert.
- Project managed a multi-disciplinary and multi-jurisdictional advisory team advising a UK Premier League football club how to improve their triage of manufacturing suppliers announced and unannounced audit. Created a prioritisation plan for remediation steps and implemented company wide supply chain due diligence procedures.
- Led an internal review of a financial services company’s legal team’s function effectiveness; carrying out the test steps necessary for identifying the team’s potential risk areas and the controls in place to mitigate these, thereby identifying the residual risks and providing key recommendations to eliminate or minimise these.
- Conducted a four phase anti-money laundering compliance program for a high end fashion house who had recently been investigated by HMRC and needed to follow the Regulator’s subsequent guidance in order to retain their registration as a High Value Dealer.
- Project managed a multi-disciplinary and multi-jurisdictional advisory team to a UK plc in an investigation of malpractice by an ex employee following allegations made by that individual. Legal and forensic investigations were conducted of IT and hard copy records to identify evidence supporting these allegations and calculating the underpaid customs duties in order to provide comprehensive self-reports in each relevant country.