S Knowlson & Another

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

SRA applied for Section 43 Orders against two non-solicitor 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 their culpability: the First Respondent had done so over a longer period and accepted it was part of the team ethos to gain financially, while the Second Respondent had been trained to do so, had raised the issue with her supervisor, and had not been 'bonus hunting'. No express finding of dishonesty was made. A Section 43 Order was made against the First Respondent only; the application against the Second Respondent was dismissed as disproportionate. The First Respondent was ordered to pay £1,000 costs; no costs against the Second Respondent.

Duties found breached:

• No unlawful discrimination or harassment
• Handle inadvertently received material

Aggravating factors:

• First Respondent was the senior in the team and accepted she knew she may receive a higher bonus by entering incorrect data
• Conduct continued over approximately one year

Mitigating factors:

• Early admissions of the underlying facts
• First Respondent stated incorrect data entry was widespread among other employees/teams and that the supervisor was aware but did nothing
• Bonus scheme was set up in a way that could be exploited absent proper supervision
• No evidence that either Respondent was actually overpaid; case put only on 'potential' to receive bonus
• Second Respondent had been trained to log dates that way, raised the issue with her supervisor, attended the Tribunal, and had not been 'bonus hunting'