Steven Westwood
Non-lawyer manager
628986

Decision - Employee-related decision

Outcome: Control of non-qualified staff (Section 43 / Section 99 order)

Outcome date: 9 June 2025

Published date: 12 December 2025

Firm details

Firm or organisation at time of matters giving rise to outcome

Name: SSB Group Limited

Address(es): Navigation House, South Quay Drive, Sheffield, S2 5SU

Firm ID: 654321

Outcome details

This outcome was reached by SRA decision.

Decision details

Who does the decision relate to?

Steven Westwood, who is not a solicitor, was a Director and Senior Manager of SSB Group Ltd (in Administration), a licensed body, between 14 January 2019 and January 2024.

Summary of decision

A finding of dishonesty and acting without integrity was made against Mr Westwood along with multiple breaches of the Code of Conduct for Firms and he was made subject to a disqualification order under section 99 of the Legal Services Act 2007.

The SRA has disqualified Mr Westwood from holding any of the following roles in law firms regulated by the SRA:

• Head of Legal Practice
• Head of Finance and Administration
• A manager
• An employee

The facts of the case

Mr Westwood was a director and stakeholder of SSB and had joint responsibility for policy decisions taken by SSB, alongside the systematic failures of SSB.

Mr Westwood was an experienced director having been the joint owner of SSB's predecessor firm since May 2016.That firm focused on personal injury work which used the ‘no win no fee' model used by SSB. He therefore had and has significant experience in this work area.

There were multiple, serious failings over an extended period of time. These affected SSB's clients, the courts, the SRA and the reputation of the legal profession at large. In a number of cases, SSB acted for clients in supposed ‘no win no fee' matters, but failed to obtain any ATE cover on these cases. Additionally, SSB was not in a proper position to cover potential adverse costs in these cases in the event that the claim failed. These occurrences were not isolated incidents where SSB's systems failed or individuals made mistakes. Rather, these were deliberate policy choices by SSB and by extension, the directors, including Mr Westwood. Acting for clients without an appropriate ATE policy being in place represented recklessness on the part of SSB and the directors and led to a clear risk of loss and harm to the client.

SSB initially obtained ATE policies that largely fell short of being effective. Firstly, it was apparent that the value of the ATE policies obtained (largely at indemnity levels of £25,000) soon became insufficient, usually due to the risk of or actualised defendant's costs exceeding this sum. Without top-up cover, this would invalidate these policies negating any prospect of it being paid out upon the claim failing.

SSB's business model meant that adhering to these policies in such a way that would not invalidate them was highly problematic. Upon onboarding, clients were not properly informed about the limitations of these policies or that they could find themselves liable for the other side's costs if the claim failed and the ATE policy would not pay out. Both SSB and the directors were reckless by acting in this way and continuing to onboard clients on the same or similar ATE policy terms as those that were either at risk of failure or had failed to pay out upon the failure of claims. This was not in the clients' best interests and led to actual loss and harm to a number of clients who found themselves liable for defendant's costs.

The ATE policies that were obtained by SSB on behalf of clients contained a number of conditions around its conduct in proceeding with claims and what information needed to be provided to the insurer throughout the life of the claim. In a considerable number of claims, SSB failed to adhere to these requirements leading the insurers to refuse to pay out on these policies when claims failed. In a number of these cases, SSB's failures around the policies were the result of deliberate policy decisions by the directors to breach or ignore the terms of the policies.

This had the effect of leaving clients liable for the other side's costs without having recourse to the policy that they would have believed to have covered them in these circumstances. Both SSB and the directors were reckless by acting in this way as failing to adhere to the policies invalidated them which is a risk that could be foreseen. This was not in the clients' best interests and led to actual loss and harm to a number of clients who found themselves liable for defendant's costs.

In a number of cases, relevant clients were not informed by SSB of adverse costs orders made against them within the seven day period required by the Civil Procedure Rules, if at all. These issues appear to have occurred due to a deliberate policy decision on SSB's part to not disclose these issues to the client rather than being isolated system or caseworker errors.

In a number of cases SSB did not obtain client instruction around proceeding to take matters to appeal. In at least one case, SSB actively went against the direct wishes of the client and proceeded to appeal regardless of its instructions. This was a deliberate policy decision at director level which did not benefit the clients who were subsequently exposed to further adverse costs due to SSB's actions. Mr Westwood, along with the other directors, either directed, approved or acquiesced to this as a matter of policy.

In at least one case, SSB pressed ahead with an appeal case despite having no proper instruction from the client. The client stood to gain nothing from this appeal which, due to a secondary issue in his claim, would have had no real effect on its success even if he had won. The purpose of this, if successful, was to use a positive judgment to enable SSB to continue with claims on behalf of some of its other clients. The appeal failed and client suffered further adverse costs which he became liable for. Nothing in this action was for the client's benefit and was only for the benefit of SSB and its other clients. Mr Westwood, along with the other directors, should have recognised that this presented a serious conflict of interest, was to the detriment of the client and demonstrated recklessness.

A policy was implemented within SSB where some claims would intentionally be undervalued to below £10,000. This was in circumstances where, even if the precise value of the claim had not been established, the true value of the claim was almost certain to exceed £10,000. The motivation for this misconduct was to minimise the initial cost to SSB of issuing these claims with the court in order to relieve cash-flow issues that SSB was experiencing. This was a deliberate and considered act which demonstrates a lack of honesty and a willingness to mislead the court for the benefit of SSB. It is apparent that Mr Westwood, along with the other directors, knew claims would have had higher values and knew that claims were worth more than £10,000 but either failed to challenge the policy decision or failed to rectify the issue. Their inaction resulted in the court being purposely misled and court fees underpaid. Solicitors, directors and managers of law firms have a positive responsibility to inform the SRA of any indicators of serious financial difficulty relating to them. It is apparent from 12 July 2022 that SSB was struggling with elements of its finances and that the funding model was not appropriate to guarantee the immediate future and financial stability of SSB. Despite being aware of some or all of these issues, Mr Westwood did not make any approach or report to the SRA.

Had appropriate reports been made to the SRA in a timely manner, it is possible that the financial interests of clients and the reputation of the profession, could have been protected or at the least prevented from being made worse by the continued actions of SSB. In failing to report these issues, Mr Westwood along with his fellow directors, did not fulfil their regulatory obligations and acted recklessly.

The misconduct by SSB and the directors had a far-reaching impact on affected clients. A number of clients became liable for the other side's costs without these being fully covered by either SSB or an appropriate ATE insurance policy. This resulted in several clients having charging orders placed on their homes, in one case to the value of £74,500. This led to a number of clients suffering either the risk of or actual, financial hardship.

The misconduct also had a serious impact on the profession at large. The collapse of SSB and subsequent loss to clients has been widely reported on at national level and would have adversely affected public trust and confidence in the profession.

Findings and our decision on sanction

It was found that Mr Westwood was in breach of paragraphs 1.2,1.4, 3.5, 3.6, 4.1, 4.2, 4.4, 6.1 and 8.1 of the Code of Conduct for Firms.

Also, that he was in breach of Principles 4 and 6 of the SRA Code of Conduct 2011 and Principles 2, 4, 5 and 7 of the SRA Principles 2019.

It was found that it would be undesirable for Mr Westwood to act as a Head of Legal Practice, Head of Finance and Administration, a manager or an employee of a body licensed in accordance with section 99 of the Legal Services Act 2007.

Mr Westwood was disqualified from holding any of these roles.

He was also directed to pay costs of £14,224.