Polly Miles

Polly Miles

Solicitor & Senior Manager, Regulatory & Commercial Disputes, PwC United Kingdom

Polly prides herself on providing her clients with sound, forward-thinking and tailored advice in relation to their financial crime compliance, governance and due diligence frameworks. Her work particularly focuses on modern slavery, anti-money laundering, anti-bribery and corruption controls and fraud prevention.

Every client has their own unique regulatory and legal risk profile. With the increasing regulation, particularly in the realm of ESG and non-financial reporting, the need to ensure a robust, tailored and comprehensive compliance framework for all businesses is greater than ever.

"Polly is equipped with the knowledge and skillset to advise clients on how to enhance their compliance framework in written form and in their implementation through the education of key stakeholders and suitable capabilities and resource."

Polly advises clients across all sectors on their compliance with the UK’s Modern Slavery Act, Criminal Finances Act, Money Laundering Regulations and Bribery Act. The projects she has led on typically focus on compliance reviews, impact and risk assessment workshops, creation of e-learn technology training, benchmarking exercises to identify market norm and industry best practice, advising on the implementation of proportionate policies and procedures and building transparency and ethical supply chain relations, both upstream and downstream.

"Polly is the UK’s lead legal advisor for corporate compliance with the UK’s Modern Slavery Act and supply chain transparency and management."

Throughout her career to date she has worked on several investigations and regulatory matters representing clients on a number of multi-jurisdictional investigations involving UK and international regulators such as HM Treasury, HMRC, the Financial Ombudsman Service and the Financial Conduct Authority. These investigations have included those initiated by suspicions of or allegations of mis-selling, fraud, bribery and tax evasion. During these investigations Polly has assisted clients in the design, implementation and monitoring of enhanced internal compliance systems.

Specialism

  • Modern Slavery corporate compliance, Anti-modern laundering, Anti-bribery and corruption Controls, Corporate Criminal Offences for the facilitation of tax evasion, Regulatory Compliance, Whistleblowing, ESG Compliance, Ethical business

Recent work

  • Advised numerous clients in the financial services, pharmaceutical and construction industries on their corporate compliance obligations under the UK’s Modern Slavery Act.
  • Project managed a multi-disciplinary team advising a UK Premier League football club on how to create and implement a prioritisation plan for identifying and remediating supply chain due diligence issues.
  • Led an international investigation on behalf of a UK plc into malpractice and potential criminal activity by an ex employee.
  • Advised a number of retail clients on multi-phased anti-money laundering compliance programs following investigations by HMRC.
  • Led several vendor due diligence projects, advising clients in the technology and agriculture industries on any potential target risks such as sanctions concerns, bribery and corruption risk profile and potential or existing litigation that could impact the target’s worth.
  • Advised a global engineering consultancy firm on their obligations under the EU Whistleblowing Directive and its impact on their global operations and grievance frameworks.

Area of focus

  • Modern Slavery corporate compliance
  • Anti-modern laundering
  • Anti-bribery and corruption Controls
  • Corporate Criminal Offences for the facilitation of tax evasion
  • Regulatory Compliance
  • Whistleblowing
  • ESG Compliance
  • Ethical business

Credentials

  • Polly was recently invited to present the the Consumer Goods Forum 2022 in Dublin on the topic of modern slavery red flags in the context of Deals.
  • Lead legal advisor for corporate compliance with the UK’s Modern Slavery Act.
  • Her work on financial crime compliance is paired with her ability to assess the operational effectiveness of legal policies, procedures and mitigation controls.
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