Poppy Phipps
Employee
7247278

Decision - Agreement

Outcome: Regulatory settlement agreement

Outcome date: 25 February 2025

Published date: 28 February 2025

Firm details

No detail provided:

Outcome details

This outcome was reached by agreement.

Decision details

Regulatory Settlement Agreement

Reasons/basis

1. Agreed outcome

1.1 Poppy Phipps, a former employee of Coodes LLP (the Firm), agrees to the following outcome to the investigation of her conduct by the Solicitors Regulation Authority (SRA):

1. to the SRA making an order under section 43 of the Solicitors Act 1974 (a section 43 order) in relation to Poppy Phipps that, from the date of this agreement:
   1. no solicitor shall employ or remunerate her in connection with his practice as a solicitor
   2. no employee of a solicitor shall employ or remunerate her in connection with the solicitor's practice
   3. no recognised body shall employ or remunerate her
   4. no manager or employee of a recognised body shall employ or remunerate her in connection with the business of that body
   5. no recognised body or manager or employee of such a body shall permit her to be a manager of the body
   6. no recognised body or manager or employee of such body shall permit her to have an interest in the body except in accordance with the SRA's prior permission
2. to the publication of this agreement
3. she will pay the costs of the investigation of £300.00

2. Summary of facts

2.1 Poppy Phipps worked at the Firm between July 2019 and March 2024 as a Mental Health Executive. She became a member of the Law Society's Mental Health Accreditation Scheme on 1 April 2018. Her accreditation expired on 31 March 2021.

2.2 In response to the SRA investigation Ms Phipps has accepted she misled the Firm, that she still held the Law Society's Mental Health Accreditation Scheme membership after she knew this had expired. This was done by forwarding an email that she had altered. She also completed Legal Aid Agency (LAA) supervisor standard and declaration forms with inaccurate information in relation to her accreditation.

2.3 Ms Phipps resigned during the Firm's internal investigation in respect of this matter.

3. Admissions

3.1 Poppy Phipps makes the following admissions which the SRA accepts: 

1. her accreditation to the Law Society's Mental Health Accreditation scheme had expired on 31 March 2021 and had not been renewed.
2. that on 11 March 2024 she forwarded an email to another staff member, purportedly from the Law Society, which she had altered to present that her accreditation had been renewed by the Law Society, when this was not true.
3. that she completed forms, which she knew were required to present information to the LAA on behalf of the Firm, with misleading information in relation to her accreditation when she knew this information was not true.
4. that altering and forwarding an email to another and completing forms to present a position which she knew to be untrue involved conduct which means that it is undesirable for her to be involved in a legal practice
5. that her conduct set out above was dishonest.

4. Why a section 43 order is appropriate

4.1 The SRA's Enforcement Strategy and its guidance on how it regulates non-authorised persons, sets out its approach to using section 43 orders to control where a non-authorised person can work.

4.2 When considering whether a section 43 order is appropriate in this matter, the SRA has taken into account the admissions made by Ms Phipps and the following mitigation which she has put forward:

1. Ms Phipps has admitted the conduct.
2. Ms Phipps was on a period of absence from work between March and July 2021 when her accreditation expired on 31 March 2021.
3. She contacted the Law Society on 6 July 2021 regarding her accreditation and had been told it could be renewed upon her return to work.
4. She submitted an application for accreditation on 20 July 2021 but needed to provide additional information, which she says she sent but which the Law Society has no record of receiving.
5. She contacted the Law Society in December 2021 and August 2022 to request a copy of her accreditation certificate.

4.3 The SRA and Ms Phipps agree that a section 43 order is appropriate because:

1. Ms Phipps is not a solicitor
2. by undertaking work in the name of, or under the direction and supervision of a solicitor
3. by altering and forwarding an email to present a position which was not true and completing forms with information which was not true Poppy Phipps has occasioned or been party to an act or default in relation to a legal practice (given the nature of the information she was seeking to verify). Ms Phipps' conduct in relation to that act or default makes it undesirable for her to be involved in a legal practice.

4.4 Ms Phipps' conduct makes it undesirable for her to be involved in a legal practice because:

1. Her conduct was dishonest.
2. She was in a senior role and held a position of trust within the Firm which relied on her to act with honesty and integrity.
3. The false information she provided could have been presented by the Firm to the Legal Aid Agency who could also have been misled by her dishonest actions.
4. Her conduct demonstrated a serious lack of judgment given her senior role and level of responsibility.
5. There is a possibility that she may act in a similar manner in future, which could impact on clients, if she is involved in legal practice without the SRA's prior consent.

5. Publication

5.1 The SRA will publish this decision. This is a requirement of the Legal Services Board's rules. We must publish information on enforcement action or sanctions imposed against a licensed body or manager or employee of a licensed body. There is no discretion in the rules for us not to do this.

5.2 The SRA considers it appropriate that this agreement is published in the interests of transparency in the regulatory process. Ms Phipps agrees to the publication of this agreement.

6. Acting in a way which is inconsistent with this agreement

6.1 Ms Phipps agrees that she will not deny the admissions made in this agreement or act in any way which is inconsistent with it. 

7. Costs

7.1 Ms Phipps agrees to pay the costs of the SRA's investigation in the sum of £300.00. Such costs are due within 28 days of a statement of costs due being issued by the SRA.