Boxer Amir Khan’s charity failed to follow good practice on independent examiner

1. The latest (2017) accounts for charity The Amir Khan Foundation (AKF) show the trustees failed to follow Charity Commission good practice when selecting an independent examiner, the external person who scrutinises a charity’s accounts. Rather than a fully qualified member of one of the accountancy bodies listed by the commission, AKF instead chose someone who, I discovered, is merely a student registered with one of the authorised organisations. Further, what appears to be the independent examiner’s personal Facebook page shows him as a “partner” at a firm with the same name as the Bolton accountancy business in whose name he carried out the independent examination, Adam & Co. However, clicking the Adam & Co link there doesn’t produce a page for the accountancy firm. Rather, it produces a page for an alleged London restaurant also called Adam & Co. The information on that page also invites suspicion.
2. On 13 November 2018, I exclusively revealed several problems with the then two sets of accounts for AKF, for 2015 and 2016, publicly available at the Charity Commission. At that date the 2017 accounts were 13 days overdue; the charity previously filed late on both occasions. On 7 December 2018, The Times newspaper reported my investigation (see 7 December 2018 post).
3. AKF finally submitted its 2017 accounts on 17 December 2018 – 47 days late. The latest accounts show the name and company affiliation of the external person who carried out the independent examination of the accounts. It was “Aziz Hajee (CIMA)” of “Adam & Co Accountants Limited”. Adam & Co is in Bolton, where trustee and eponymous founder Amir Khan, the professional boxer, lives. This is the firm’s website: www.adamandco.com (screen shot in Figure 1). (The address on the website is the same as that in the charity accounts.)
   

   Figure 1. Adam & Co Accountants Limited website at 28 December 2018

4. As you can see, Mr Hajee used the letters “CIMA” after his name in the document. CIMA is the Chartered Institute of Management Accountants. However, searching CIMA’s database with his surname in the UK produces no results. Similarly, searching with the company name in the UK doesn’t return any results, either. (I used the “Find a CIMA Accountant” page on the CIMA website.)
5. In December 2018, I twice emailed Mr Hajee at Adam & Co asking whether he‘s a CIMA accountant or not. I didn’t receive a response.
6. So I contacted CIMA, who informed me Mr Hajee isn’t a certified practising CIMA member. Rather, he’s a CIMA registered student.
7. That Mr Hajee isn’t a CIMA accountant is a concern because Charity Commission good practice requires a fully qualified accountant to carry out an independent examination of so-called accruals accounts (these are accruals accounts). The commission guidance, “Independent examination of charity accounts: Directions and guidance for examiners (CC32)”, is clear on this point: “Trustees who have had the charity’s accounts prepared on an accruals [sic] should select a person who is a member of one of the accountancy bodies listed in the 2011 Act as amended by the 2015 Order.” (Appendix 5: Relevant experience/knowledge and professional qualification requirements). The commission explains what it means by “should” at the front of its document: “‘should’ means guidance that is good practice which the commission expects the independent examiner to follow when carrying out their examination.”
8. Meanwhile, if a charity’s gross income exceeds £250k, charity law requires the independent examiner to be a fully qualified accountant. AKF income was £213k in 2017.
9. Then there‘s what appears to be Mr Hajee‘s personal Facebook page (screen shot in Figure 2). There Mr Hajee, if indeed it’s him, identifies himself as a “partner” at Adam & Co – but it isn’t the Bolton accountancy firm. His page links to an alleged London restaurant also called Adam & Co (screen shot in Figure 3). Yet the alleged restaurant bears both the London phone number and website address of private bank Adam & Company! Adam & Company is a brand of The Royal Bank of Scotland PLC (RBS). Until September 2017, the London office of Adam & Company was at 22 King Street; London SW1Y 6QY. And that’s the address shown for the alleged Adam & Co restaurant on the Facebook page, except there the postcode is “SW1Y6” (sic) (Figure 3).
   

   Figure 2. Aziz Hajee’s personal Facebook page at 5 January 2019

   

   Figure 3. Adam & Co “restaurant” Facebook page at 5 January 2019

10. Like its predecessors, the 2017 accounts omit to mention Penny Appeal (PA), a Muslim international humanitarian charity established in 2009 (see 13 November 2018 post). Yet the AKF website proclaims it works “in partnership” with PA. There‘s one improvement, though: the charity does now at least specify, if partly, where its expenditure on charitable activities has actually gone, identifying some countries where it says it operates. Yet again there’s no breakdown of spend by country and/or project. The £304.6k spent on charitable activities again simply went on “relief of suffering”. As I asked on 13 November 2018, why so vague?
11. The relationship between AKF and PA continues to be unacceptably opaque (see 13 November 2018 post). What’s new here is another obvious concern: the failure of the trustees to follow Charity Commission good practice when selecting an independent examiner. Worse, the Facebook page for alleged London restaurant Adam & Co, to which what appears to be “partner” Mr Hajee‘s personal page links, raises serious questions about his credibility, if indeed it’s him.
12. Rizwan Malik, AKF public contact, didn’t respond to emailed requests for comment. Nor did Mr Hajee at Adam & Co.

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IPGL accounts fail to disclose related-party transaction with Conservative Foundation

1. Michael Spencer, the City financier and former Tory party treasurer, is chair and a director of The Conservative Party Foundation Limited (registered company number: 05289086), an endowment fund set up in March 2009 to support the long-term finances of the political party. In the latest (2017) accounts, note 10, “related-party transactions”, in the notes to the financial statements, discloses the related-party transaction between The Conservative Party Foundation Limited and Mr Spencer’s firm IPGL Limited (registered company number: 02011009). IPGL made an in-kind donation of £7.12k.
2. Mr Spencer is chair and a director, as well as majority shareholder, of IPGL (Holdings) Limited (registered company number: 09064598), the entity that owns and controls IPGL Limited. Mr Spencer is also chair and a director of IPGL Limited.
3. The financial year-end for The Conservative Party Foundation Limited is 31 December, while that for IPGL is 31 March. Thus IPGL filed two sets of accounts – made up to 31 March 2017 and 31 March 2018 – that are contemporaneous with the 2017 accounts for The Conservative Party Foundation Limited.
4. Both the 2017 and 2018 accounts for IPGL report related-party transactions in the notes to the financial statements: note 22 (2017) and note 20 (2018).
5. However, neither note 22 (2017) nor note 20 (2018) shows IPGL‘s in-kind donation of £7.12k, or part thereof, to The Conservative Party Foundation Limited. Why?
6. Mr Spencer didn’t respond to emailed requests for comment. I wrote to him at The Conservative Party Foundation Limited, copying both messages to Ivana Zadro, named contact on the IPGL website “for all enquiries”.

Lord Dannatt is chair and director of firm whose “head office” is merely a virtual office

1. On 7 January 2019, I wrote to Lord Dannatt requesting comment on five issues relating to his involvement with Cadence Consultancy Ltd (registered company number: 09349330). The British Army’s former Chief of General Staff Army acknowledged receipt of my email, saying: “I am checking the facts with regard to Cadence.” Nevertheless I didn’t receive anything further, despite sending a reminder. Meanwhile, Lord Dannatt duly corrected an error on the register of lords’ interests and presumably arranged the changes to the firm’s website I describe below.
2. The error on the parliamentary register was the first issue. The peer had got the business name wrong, referring to Cadence “Consulting”, instead of Cadence Consultancy Ltd (screen shot in Figure 1). As I say, that mistake has now been rectified.
   

   Figure 1. Lord Dannatt: register of lords’ interests at 4 January 2019

3. Then there’s the fact that Cadence Consultancy’s latest accounts, made up to 31 December 2017, show two directors only, Chesney Clark and Howard Chaganis (screen shot in Figure 2). Yet Companies House records indicate Lord Dannatt and three others were appointed as directors on 1 October 2017. So why aren’t the four new directors listed in the latest accounts?
   

   Figure 2. Cadence Consultancy Ltd 2017 accounts: company information

4. The third issue concerns the “contact us” page of Cadence Consultancy’s website, which gives the address of “head office” (screen shot in Figure 3). It’s misleading to identify that address as head office. Cadence Consultancy doesn’t actually have any staff – let alone head office – at that location: it’s only a so-called virtual office! It’s laughable to label such as head office. Worse, it’s a common trick of scammers to represent a virtual office as a real office. So why is Cadence Consultancy risking the perception that it’s a scammer?
   

   Figure 3. Cadence Consultancy Ltd website: “contact us” page at 4 January 2019

5. The fourth issue relates to two documents available at the foot of the website, the “website privacy notice” (screen shot in Figure 4) and “website terms of use” (screen shot in Figure 5). The bottom of each page in both bears Cadence Consultancy’s “registered address”, which is the address of the virtual office. It’s misleading to refer to that address as “registered address”, when Companies House shows a different registered office address.
   

   Figure 4. Cadence Consultancy Ltd website: “website privacy notice” at 4 January 2019

   

   Figure 5. Cadence Consultancy Ltd website: “website terms of use” at 4 January 2019

6. Finally, the website failed to show both registered company number and registered office address. It also omitted to disclose that Cadence Consultancy is a limited company (screen shot in Figure 6). Although some, but not all, of these company details are revealed in the two documents I refer to in para 5, they all must be clearly shown on the website. While the website now clearly states both registered company number and company type, the registered office address remains undisclosed (at date of publication).
   

   Figure 6. Cadence Consultancy Ltd website: homepage at 5 January 2019

7. It’s surprising chair and director Lord Dannatt failed to get the company name right on the register of lords’ interests. More surprising, though, is the firm’s false representation of a virtual office address as “head office”. For the avoidance of doubt, the problem isn’t use of a virtual office address. Rather, it’s the false claim the virtual office address is “head office”.

Political lobbyist for trade organisation that files dormant accounts has also lobbied within parliament for undisclosed causes

1. An individual working for an MP in parliament is the political lobbyist for a member-based trade organisation that has filed dormant accounts since incorporation on 4 October 2013. No one at the trade organisation, including the political lobbyist, has responded to emails asking why it continues to file dormant accounts. The trade body has paid members, according to its website. In the same emails I asked why its accounts don’t show the membership fees it receives. As well as acting for the opaque and unaccountable trade organisation, this person has at the same time lobbied within parliament for undisclosed causes. It’s unclear whether the MP is fully aware of all the organisations for which his staff member has and continues to lobby within parliament.
2. On 31 July 2018, The Sustainable Energy Association (SEA; registered company number: 08718110) filed its latest accounts, made up to 31 October 2017. And again this set of accounts, its fourth year, was for a dormant company. Yet the SEA website displays annual membership rates, which vary by organisation type and size.
3. What is SEA? The website says it’s “a member-based industry body offering innovative policy solutions that link up building-level technologies and the wider energy system to achieve a low carbon, secure energy future for the UK, benefits for UK consumers, and commercial growth for businesses working in the sector.”
4. Companies House records show two founding directors, who are also the “persons with significant control”: Dave Sowden and Ecuity Consulting LLP (registered company number: OC373224). Mr Sowden identifies himself on the SEA website as “strategic adviser”. He was the first person there I emailed – twice in August 2018. No response. Later that month, I twice emailed Sandra Morris, “team project co-ordinator”. Again, nothing. Ron Bailey was the third person to whom I wrote – twice in September 2018. Mr Bailey, “head of parliamentary affairs”, didn’t reply, either (screen shot in Figure 1). Finally, in December 2018, I twice emailed Tim Minett, who, as chief executive of CPL Industries Ltd (registered company number: 02993245), is a member of the executive committee of SEA (screen shot in Figure 2). Again, Mr Minett was unresponsive.
   

   Figure 1. Ron Bailey: “head of parliamentary affairs” at Sustainable Energy Association

   

   Figure 2. Tim Minett: member of executive committee of Sustainable Energy Association

5. The dormant accounts require explanation. So it’s disappointing no one at the trade organisation replied to emails about them.
6. Mr Bailey works in parliament for Dr David Drew, Labour MP for Stroud, the register of interests of MPs’ staff shows. Thus SEA’s “head of parliamentary affairs” has a parliamentary pass.
7. Mr Bailey made the same disclosure on the register both at 11 July 2018 and the next update, at 22 August 2018: “Head of parliamentary affairs, Sustainable Energy Association (member-based industry body). Employed by Ecuity Consultancy. Clients: Canetis Ltd.” (register at 11 july 2018) (register at 22 august 2018) Therefore, he didn’t reveal his contemporaneous lobbying activities within parliament for the United Kingdom Without Incineration Network (UKWIN), a national organisation campaigning against waste incineration in the UK.
8. On 17 July 2018, UKWIN launched its report, “Waste Incineration and Particulate Pollution: A Failure of Governance”, at the House of Lords (screen shot in Figure 3). The official invitation to MPs and peers for the launch event shows Mr Bailey as named contact, with his parliament email address (screen shot in Figure 4).
   

   Figure 3. Launch of United Kingdom Without Incineration Network (UKWIN) report at House of Lords on 17 July 2018

   

   Figure 4. Invitation to launch of United Kingdom Without Incineration Network (UKWIN) report at House of Lords on 17 July 2018

9. UKWIN and SEA are independent of each other.
10. Shlomo Dowen is UKWIN national co-ordinator, according to its website. At the end of October 2018, I emailed him requesting confirmation Mr Bailey’s work for his organisation has nothing to do with his (Mr Bailey’s) role with SEA. Mr Dowen didn’t respond then, or to a reminder over two weeks later.
11. Another undisclosed cause for which Mr Bailey has and continues to lobby within parliament is Power for People Ltd (registered company number: 10892473), a new campaign organisation. Incorporated on 1 August 2017, Steve Shaw is owner and sole director. Mr Bailey appears on the organisation’s website as “director of parliamentary strategy” (screen shot in Figure 5). The political lobbyist has been involved with Power for People since inception: he was joint author with Mr Shaw of its September 2017 report, “Energy: The Age of Clean” (screen shot in Figure 6).
    

    Figure 5. Ron Bailey: “director of parliamentary strategy” at Power for People

    

    Figure 6. Acknowledgements: Power for People report, “Energy: The Age of Clean”, published September 2017

12. Mr Bailey doesn’t disclose his “director of parliamentary strategy” role at Power for People on the latest (at 27 December 2018) register, either. (register at 27 december 2018)
13. Holders of parliamentary passes as MPs’ staff are required to disclose only paid roles on the register. Nevertheless some report relevant unpaid ones as well, if erroneously (see 22 November 2017 post).
14. Perhaps, therefore, UKWIN didn’t pay Mr Bailey to lobby on its behalf. (The campaign organisation didn’t respond to emailed requests for comment, remember.) Yet his role at Power for People is, or at least has been, paid. For its “Energy: The Age of Clean” report, Mr Shaw and Mr Bailey acknowledge funding from charity Marmot Charitable Trust (registered charity number: 1106619) (Figure 6).
15. On 1 November 2018, the Public Relations and Communications Association (PRCA) and the Association of Professional Political Consultants (APPC) merged. Both were independent member-based bodies, each maintaining its own publicly accessible register of political lobbyists, where members were required to list relevant staff and all clients. There’s now one joint register, available at the PRCA website. The latest register, that from 1 September 2018 until 30 November 2018, comprises individual members as well as firms. Mr Bailey doesn’t appear on the register, so there we can’t find out on whose behalf he’s lobbying, either.
16. I recently emailed Dr Drew about Mr Bailey’s lobbying within parliament, asking two questions. First, does the MP actually pay Mr Bailey to work for him at parliament? If so, what’s his exact role? Second, is Dr Drew fully aware of all the organisations for which Mr Bailey has and continues to lobby within parliament?
17. The member for Stroud replied straightaway. Mr Bailey, he said, “works totally as a volunteer for me on my anti-incinerator campaign for which I give him one of my Westminster passes which he shares.” I then asked: did he mean UKWIN? UKWIN is “quite separate to us but clearly we have common objectives”, clarified Dr Drew in a second email. When I went on to point to Mr Bailey’s lobbying within parliament for UKWIN, the MP explained in a third message: “Ron Bailey lobbied on behalf of me for UKWIN.”
18. Note, though, that Dr Drew isn’t one of the three parliamentarians – two MPs and a peer – who invited colleagues to the UKWIN report launch event at the House of Lords on 17 July 2018 (Figure 4).
19. Meanwhile, the MP didn’t directly answer my second question. In his first email, he said: “I am well aware of the work he [Mr Bailey] undertakes given his brilliant reputation for environmental improvements in this country. I’m very lucky to be able to call upon his expertise and I’m pleased to say he’s made some major achievements already in the work that he volunteers for me.” When I pointed out his answer failed to directly address what I asked, Dr Drew didn’t comment.
20. On SEA, the MP said he’s worked with it “throughout my time in parliament”, adding: “I’ve found them to be the most transparent of organisations”. When I explained why I perceive the trade organisation to be opaque and unaccountable, Dr Drew only responded: “…the submission of accounts is a matter for them not for me.”
21. The lack of transparency and accountability around SEA’s money flows undermines public trust and confidence. Where exactly are the membership fees going and why? While its unresponsiveness only compounds the problems. A trade organisation should welcome public scrutiny. Then there’s its lobbying arrangements. SEA’s “head of parliamentary affairs”, who possesses a parliamentary pass as a member of an MP’s staff, has at the same time lobbied within parliament for hidden causes. SEA’s credibility is further damaged by such lobbying arrangements.

Hidden ads for Slimming World in the Daily Mirror

1. As I said in my previous post, the Daily Mirror regularly plugs Slimming World in editorial, without disclosure of interest. There’s a longstanding commercial relationship between the newspaper and the weight loss organisation.
2. I also mentioned the Mirror sometimes even slaps the Slimming World logo on such articles. Here’s an example from today’s (24 January 2019) paper: daily mirror 24 jan 2019.

Mirror chief sports writer promotes boozing and gambling

1. On 20 December 2018, Andy Dunn, chief sports writer at the Mirror, told readers how he intended spending Boxing Day, as his contribution to the newspaper’s “What Christmas means to me” series. (daily mirror 20 dec 2018) He’ll meet “the lads” for a “couple of pints”, he said, before betting on “the nags” at Kempton. Then they’ll watch Andy’s local football team, Crewe Alexandra. Finally, he’ll rush home “for a night in front of the telly with the family”. His last sentence was a warning, however: “Oh, and don’t forget, drink and gamble responsibly.” How sensible – but I can’t help wonder at the advisability of gambling under the influence of alcohol.
2. At the start of the new year, meanwhile, Andy was again promoting gambling, this time a specific company. On 5 January 2019, he shared his Footie5 FA Cup predictions. (daily mirror 5 jan 2019 p66) Footie5 is a new game from The Football Pools Limited, which trades as The Pools. Worse, his plugging of Footie5 was in editorial, not advertising. As you can see, there was no indication it was an ad or, sorry, “paid content”.
3. Like other newspapers, the Mirror’s sports pages are plastered with gambling ads. But the Mirror goes further: gambling firm William Hill notoriously sponsors football pundit Robbie Savage’s column on Saturday, for example. It’s a new low, though, when the chief sports writer plugs a gambling company in editorial.
4. Unfortunately, hidden advertising isn’t restricted to the paper’s sports pages. The Mirror has a longstanding commercial relationship with Slimming World, for instance, continuing to run promotions and giveaways for the weight loss organisation. At the same time it also regularly reports on individuals who’ve apparently shed weight on the programme, always explicitly identifying the firm. Such articles – with the obligatory “before” and “after” photos – sometimes even bear the Slimming World logo, but again aren’t labelled as ads.
5. Oh, and we mustn’t forget the Mirror’s high-profile columnists who plug firms, without disclosure of interest: Fiona Phillips (see 25 April 2018 post) and Heather Mills (see 16 November 2018 post). Ms Mills, in particular, can’t stop (see 13 December 2018 post). Indeed, she was yet again blatantly promoting her vegan food business, VBites, in her latest column on 10 January 2019. (daily mirror 10 jan 2019)

Lord Evans of Weardale exposé in The Sunday Times – and a job down

1. On 30 December 2018, Andrew Gilligan, senior correspondent, reported in The Sunday Times newspaper my Lord Evans of Weardale exposé (see 18 December 2018 post).
2. Mr Gilligan’s report (“Watchdog on conflicts of interest has six other jobs”), page 2 lead, is here: STS_20181230_null_null_01_2.
3. And following the story in this morning’s paper… In entirely unrelated news, Sky News later today revealed that Lord Evans, who is chair of the Committee on Standards in Public Life, is to give up one of his six other posts – as non-executive director of HSBC Holdings PLC: https://news.sky.com/story/former-mi5-chief-lord-evans-to-step-down-from-hsbc-board-11594861.