Michelle Hallett
Employee
7016695

Decision - Agreement

Outcome: Regulatory settlement agreement

Outcome date: 13 November 2024

Published date: 19 December 2024

Firm details

Firm or organisation at time of matters giving rise to outcome

Name: Osborne Clarke LLP

Address(es): 1 London Wall, London, EC2Y 5EB

Firm ID: 619990

Outcome details

This outcome was reached by agreement.

Decision details

1. Agreed outcome

1.1 Ms Michelle Hallett (Ms Hallett), a former employee of Osborne Clarke 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 Ms Hallett that, from the date of this agreement:
   1. no solicitor shall employ or remunerate her in connection with their 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.

2. Summary of facts

2.1 Ms Hallett, a non-authorised person, was employed by the Firm between 13 May 2019 and 17 January 2023 as a Travel Manager. 2.2 On 9 September 2022 the Firm informed the SRA that it had been contacted by the British Transport Police (BTP) to advise that it was investigating a non-lawyer member of staff of the Firm for fraud by false representation.

2.3 The circumstances surrounding the investigation were that between 1 August 2019 and 30 April 2020 Ms Hallett had made 290 false claims for travel delay repayment.

2.4 On 5 January 2023 Ms Hallett was interviewed by the BTP and made a full admission to the offence. She resigned from the Firm.

2.5 On 7 February 2024 Ms Hallett attended Swindon Magistrates Court and pleaded guilty to the offence of fraud by false representation. She received a community order which included a rehabilitation activity requirement and an unpaid work requirement to be completed within 12 months. She was also ordered to pay compensation of £7,002, a surcharge of £90 and costs of £85.

3. Admissions

3.1 Ms Hallett makes the following admissions which the SRA accepts:

1. between 1 August 2019 and 30 April 2020, she made multiple false claims for travel delay repayment
2. that her conviction for fraud by false representation means that it is undesirable for her to be involved in a legal practice
3. 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 Hallett and the following mitigation which she has put forward:

1. she pleaded guilty and cooperated with the police investigation
2. she has admitted the facts of the allegation to the SRA and cooperated with its investigation
3. she has expressed insight and remorse into her offending.

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

1. Ms Hallett is not a solicitor
2. her employment or remuneration at the Firm means that she was involved in a legal practice
3. she has been convicted of an offence which makes it undesirable for her to be involved in a legal practice.

4.4 The offence makes it undesirable for Ms Hallett to be involved in a legal practice because she has been convicted of fraud by false representation.

The offence happened whilst she was involved in a legal practice working as a Travel Manager. The SRA Enforcement Strategy says that we consider an offence involving fraud to be at the most serious end of the spectrum. Ms Hallett has acted dishonestly and her conduct lacks integrity. She has demonstrated a concerning pattern of behaviour. This conduct was not isolated as she has made multiple fraudulent claims over a period of eight months for financial gain. The serious nature of her criminal conviction is likely to damage public confidence in the delivery of legal services if she worked in an SRA regulated firm without the SRA’s prior permission.

5. Publication

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

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

6.1 Ms Hallett 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 Hallett agrees to pay the costs of the SRA's investigation in the sum of £300. Such costs are due within 28 days of a statement of costs due being issued by the SRA.