S Knowlson & Another

Findings — machine-extracted (anthropic-batch:claude-opus-4-8); verify against the decision

The SRA applied for Section 43 Orders against two unadmitted employees of TLT LLP who entered incorrect EPC receipt dates into the firm's computer system, potentially inflating bonuses under the firm's Lender Sales Bonus Scheme. The Tribunal found both had knowingly entered incorrect data, but distinguished culpability: the First Respondent (Knowlson) had done so for about a year, was senior, and admitted awareness of the bonus benefit, while the Second Respondent had been trained to log dates that way, acted for a shorter period, did not seek a bonus, and had prompted the investigation. No express finding of dishonesty was made. The Tribunal made a Section 43 Order against the First Respondent and ordered her to pay £1,000 costs, but made no order of any kind against the Second Respondent, finding it disproportionate.

Duties found breached:

• Handle inadvertently received material
• Honour professional undertakings

Aggravating factors:

• First Respondent knew that by entering incorrect data she may receive a bonus she would not otherwise receive
• Conduct continued over about a year for the First Respondent
• First Respondent was senior in the team and part of team ethos to use incorrect dates to qualify for bonus

Mitigating factors:

• Second Respondent did not act to obtain a bonus and was trained to log dates this way by more experienced colleagues
• Second Respondent raised the issue with her supervisor, prompting the firm's investigation
• Supervisor allegedly aware of the incorrect logging; bonus system open to exploitation without proper supervision
• Both Respondents admitted the underlying facts early
• No evidence that either Respondent was in fact overpaid; £400 already deducted from final salaries
• Second Respondent attended the Tribunal and accepted her behaviour was wrong