Complaints, Concerns and Removal Procedure

Version 1.0 · Effective from Monday 31 August 2026

Version. 1.0

Effective from. Monday 31 August 2026

Review. Annually, or sooner on incident.

Published at. bonsai.law/circle/concerns

1. Two kinds of matter, one process

Matters raised about a member fall into two broad kinds:

Concerns - safeguarding, behaviour, breaches of the Confidentiality Regime, breaches of the Code of Conduct.
Complaints - dissatisfaction with a Circle service (a meeting, a decision, the forum).

We handle both through this procedure. Concerns take priority.

Matters about referral quality alone (a member didn't reply to a referral, a member's service didn't meet your expectations) are not a Circle disciplinary matter. Raise those direct with the member.

2. Who can raise a matter

Anyone. Member, applicant, refused applicant, guest, or any other third party.

Anonymous matters are taken seriously; our ability to investigate will be constrained.

3. How to raise a matter

Web form at bonsai.law/circle/concerns, or email bonsai.circle@bonsai.law with subject line "Concern" or "Complaint".

Give us:

what happened, in your own words;
when and where, as best you recall;
who was involved;
what you would like us to do, if anything.

Attach documents if you have them.

3A. Flagging a message

Every forum post and every direct message on the Circle carries a flag button. Flagging a message is the fastest way to raise a matter about content - faster than the concerns form for content that is already on the platform.

A flag goes straight to the founders' moderation queue. You can flag:

a message you sent that you now regret;
a message you received that should not remain on the platform;
a forum post from any board that breaches these terms or the Confidentiality Regime;
content that raises a safeguarding concern.

When you flag, you can add a one-line note. You do not have to.

What the founders do with a flag.

Read the message and any linked context.
Decide whether to leave the message as-is, redact it, remove it, or escalate the matter into the full concerns process at section 4.
Redaction is a permanent decision. The visible message is replaced with a short note ("Redacted by moderator, [date]"). The underlying record is retained on the moderation audit log for the full retention period. The reason for redaction is logged. Neither party is told the specific reason unless the founders consider it necessary.

Timing.

Flags are triaged within 24 working hours. Where the flag identifies a safeguarding concern, we act immediately.

Flagging your own message is not an admission of anything.

You may flag a message you sent because you regret it, because you consider on reflection it should not remain on the platform, or because the recipient has told you they did not want it. Flagging is a mature action, not an admission of a rule breach.

4. What happens next

4.1 Acknowledgement

We acknowledge within one working day.

4.2 Triage

A founder reads the matter and decides:

(a) whether an interim suspension of the member is necessary pending investigation;
(b) whether the matter should be referred to the police, a regulator, or another authority immediately;
(c) whether it is a concern, a complaint, or both;
(d) which founder will handle it (a founder who is conflicted or is the subject of the matter does not handle it, whether at investigation, decision or appeal stage).

Before any decision is taken under 4.4, both founders sign a written declaration that neither has a material personal or commercial conflict beyond their role as founder. The declaration is filed with the case papers.

Interim suspension is a protective step and is not itself a finding.

4.3 Investigation

Proportionate to the matter. May include:

taking a written account from the person who raised the matter;
putting the substance of the matter to the member concerned, in writing;
taking further accounts from anyone else present;
reviewing forum content or moderation records;
reviewing direct-message threads and attendance records where relevant;
taking advice.

We aim to complete investigation within 20 working days of acknowledgement. Where that is not possible we keep both parties informed of progress.

4.4 Decision

Removal-for-cause decisions are made jointly by the founders. Every other decision is made by the deciding founder alone. Where a founder is conflicted or is the subject of the matter, the other founder decides alone at every stage.

A breach of the Confidentiality Regime carries a strong presumption of removal. The presumption is applied on the findings, having heard the member's response, and with the ordinary right of appeal.

The founder or founders writing up the findings decide one of:

no case to answer;
a private note filed, no further action;
formal warning under the Code of Conduct;
suspension continuing for a defined period, with conditions;
removal for cause under clause 10 of the Terms of Membership;
referral to a regulator or the police (if not already done).

Decisions are recorded in writing with reasons. The record is retained under the Data Retention Schedule and disclosable to the member on request in respect of their own case.

4.5 Communication of the decision

Both parties get:

the decision;
a short summary of the findings that led to it;
the appeal route.

The person who raised the matter is told the outcome. They are not told details of any disciplinary action beyond the fact and headline outcome, save where a court order or statutory requirement compels wider disclosure.

5. Suspension

Interim suspension may be imposed at any point from triage onwards.
It is protective, not punitive.
A suspended member is told in writing and given a short statement of reasons.
Suspension does not prevent the member responding, providing information, or being represented in the process.
Fees are not refunded during suspension. If the outcome is no case to answer, meeting fees paid but not used during the suspension are refunded.

6. Removal for cause

Removal for cause is a joint decision of the founders on any of the grounds in clause 10.4 of the Terms of Membership. Where one founder is conflicted or is the subject of the matter, the other founder decides alone. Removal takes effect on written notice.

On removal:

forum access is disabled immediately;
the removed member's name in forum posts and direct-message threads is updated to "Removed", or "Former member" where the departure follows a resignation rather than a founder decision; the content itself is retained on the schedule in the Retention Schedule;
the member is not entitled to attend further meetings;
a summary record of the removal is retained under the Data Retention Schedule to prevent re-admission;
fees are refunded only in the circumstances described in clause 10.6 of the Terms of Membership.

7. Appeals

7.1 Route

Within 14 days of the decision, the member may appeal in writing to bonsai.circle@bonsai.law with subject line "Appeal". The appeal is decided within 14 days of receipt.

7.2 Who decides an appeal

Appeals are decided internally by the founders. The Circle does not use an external appeals reviewer. Bonsai Law Ltd is a regulated firm; the Solicitors Regulation Authority and the Legal Ombudsman remain available to members as the external route in respect of Bonsai Law's conduct.

The appeal is heard as follows:

First-tier appeals. Where the original decision was taken by one founder alone (ordinary moderation, minor disciplinary, meeting decisions, or any matter where the other founder was recused), the appeal is heard by the founder who did not make the original decision.
Second-tier appeals. Where the original decision was a joint decision of both founders (which will be so in every removal for cause), the appeal is heard by both founders sitting jointly in an appeal capacity. The appeal is decided on the papers, with a written reasons letter issued within 14 days of receipt.
Appeals concerning the conduct of a founder. Where the appeal concerns the conduct of one founder, that founder recuses entirely and the other founder decides the appeal alone. Where the appeal concerns the conduct of both founders, that matter is outside the Circle's own appeal process; the member is directed to the Solicitors Regulation Authority and the Legal Ombudsman.

Both founders sign a written declaration of no material conflict before deciding any appeal. The declaration is filed with the case papers.

7.3 Grounds

An appeal may be brought on one or more of the following grounds:

the process was not followed;
the decision was outside the range of reasonable decisions available on the findings;
new material has come to light that was not, and could not reasonably have been, available at the time of the decision;
the sanction is disproportionate.

7.4 Outcome

The founder or founders deciding the appeal may:

uphold the decision;
substitute a lesser sanction;
overturn the decision;
direct that the matter be reconsidered on specified points.

The appeal decision is final so far as the Circle's own process is concerned. Nothing in this section affects the member's right to complain to the Solicitors Regulation Authority or the Legal Ombudsman about the conduct of Bonsai Law Ltd.

7.5 Transparency

Aggregate anonymised figures for appeals received, appeals overturned, appeals varied and appeals upheld are published each year in the transparency summary at bonsai.law/circle/transparency.

8. Records

The full file is retained for seven years from closure under the Data Retention Schedule.
Access is restricted to the founders and our professional advisers where relevant.
Aggregate, anonymised numbers are published in the annual transparency summary at bonsai.law/circle/transparency.

9. Referral to statutory authority

We refer to the police where we consider a criminal offence to have been committed and it is proportionate to do so, whether or not the person affected wishes to report themselves. We tell you before we do, save where doing so would compromise the investigation or increase risk.
We refer to a regulator where a regulatory obligation applies to us or the member concerned.
We comply with our own regulatory reporting obligations, including SRA obligations on Vanessa's part as a solicitor.

10. Conflicts of interest

A founder does not handle a matter of which they are the subject.
A founder does not handle a matter in which they have a material personal or commercial conflict.
Both founders sign a written declaration of no material conflict at the start of every matter and at the start of every appeal. The declaration is filed with the case papers.
Where both founders are conflicted, the matter is outside the Circle's own process. The member is directed to the Solicitors Regulation Authority and the Legal Ombudsman for any complaint about the conduct of Bonsai Law Ltd.