By David Young-
Former Volkswagen Financial Services general counsel Jeremy Bouch has been fined by the Solicitors Regulation Authority following an investigation into conflicts.
Bouch resigned from Volkswagen in August 2019 after over three years at the company following an internal disciplinary investigation. He is now lead legal counsel at Barclays.
AD: Capeesh Restaurant
He was also ordered to pay the £600 costs of the investigation and publication of the agreement.
Bouch was tasked with resolving criminal summonses that had occurred while Volkswagen had engaged a third-party to complete work processing Notices of Intended Prosecution in respect of the company’s lease vehicles.
His decision to employ an external firm to resolve the matter was concluded to be unethical and problematic because of the involvement of his close relative who was a solicitor at the firm.
AD: Oysterian Sea Food Restaurant And Bar
According to the SRA records, the firm submitted two invoices which appeared “excessive” with no breakdown of the work undertaken, to a total of £95,150 excluding VAT. Bouch approved both payments without disclosing to Volkswagen that his close relative was working on the matter and their fees were included within the invoices.
Jeremy Bouch, formerly general counsel with Volkswagen Financial Services (UK) Limited, was fined for suggesting his close relative could provide services and approving payment of invoices which included their fees. The SRA said these fees ‘appeared excessive’ but they were paid by VFS without Bouch revealing his connection with the person in receipt of them.
Bouch, who was admitted as a solicitor in 1998, joined VFS in 2016 as head of legal compliance before his title was changed to general counsel.
His employer provided fleet vehicles which it leased to customers, and engaged a third-party company to process notices incurred for speeding offences and parking fines.
A third party was fined for prompting the company to task Bouch and instruct another firm to deal with the issue. One of the firm’s solicitors was a longstanding friend of Bouch’s, the SRA said.
That firm expressed doubts about being able to carry out the work, so Bouch suggested his relative, a solicitor, could assist. In 2019, two invoices coming to £95,150 were submitted by the firm, with no breakdown of who had done the work.
Bouch cancelled the arrangement with this firm in June 2019 and VFS began an investigation into his conduct and approval of invoices. In August 2019 he resigned from the company.
Bouch admitted causing or allowing an own-interest conflict by instructing a firm where his friend was a solicitor, then suggesting to that firm that his relative could work on its cases. Neither of these links were disclosed to his employer.
He claimed to have experienced significant health and personal issues at the time of misconduct and was focused at the time on resolving these cases as a priority which allowed his judgement to be impaired.
The SRA considered his conduct to have been premeditated with the potential to cause harm to VFS. The engagement of his relative was instigated by Bouch and his failure to inform his company persisted for longer than was reasonable.
AD: Heritage And Restaurant Lounge Bar