Abbey King Khawaja vanishes from Imperial Corporate Capital PLC website

1. What news of Abbey King Khawaja and Imperial Corporate Capital PLC (ICC)?
2. I first wrote about the property developer and investor ICC on 21 March 2019, giving six reasons investors should avoid the firm. On 4 April 2019, I published its belated response to one of the concerns raised in the first post.
3. On 24 May 2019, I received an email from Mr Khawaja, with the subject line in capitals: “FAKE NEWS BY DR ALEX MAY”. There he said: “Your recent fake and inaccurate blogs have resulted in damage to our business. I have lost my employment due to your fake news. You leave me with no option but to seek legal advice from reputable media lawyers to commence proceedings and claim substantial damages against you, word press [sic] and google [sic].”
4. I then checked the ICC website: sure enough, Mr Khawaja had vanished, his photo and biography nowhere to be found.
5. Meanwhile, at the same time I discovered Mr Khawaja had recently established the blog Abbey King Khawaja Esq at abbeykingkhawajaesq.blogspot.com. The post of 27 May 2019 states: “Abbey is presently a Senior [sic] advisor and Government Relations Officer with ICC PLC, a progressive property development company…” (screen shot in Figure 1).
   

   Figure 1. Abbey King Khawaja Esq blog: Mr Khawaja is working for ICC, says 27 May 2019 post

6. That blog post claims Mr Khawaja is working for ICC. It was published after his email. So I asked by reply on 28 May 2019: “Which is correct, your email or yesterday’s blog post?”
7. Mr Khawaja responded the same day: “I have been given notice by ICC PLC due to your negative and inaccurate blogs. Serious damage to my business reputation. You are responsible for this decision by ICC PLC.”
8. I, too, went back the same day, beginning by noting his reference to my “inaccurate blogs”. I continued: “If there are any inaccuracies, I am and always have been happy to publish corrections and clarifications (see 6 August 2014 post, for example).” I requested Mr Khawaja report any alleged inaccuracies.
9. In a concluding paragraph, I wrote: “Further, I am and always have been happy to publish a formal response from you, or anyone else for that matter (see 8 December 2015 post, for example). Alternatively or in addition, you can post a comment(s): the blog has always been open for comments.”
10. At date of publication I haven’t received a response from Mr Khawaja to my last email. He hasn’t posted a comment(s), either.
11. Besides the involvement of Mr Khawaja, another concern about ICC was the information on the firm website about Bobby Singh, “vice-chairman and founder” (see para 7 in 21 March 2019 post). Before my first post, Mr Singh boasted of having “held CEO positions for successful property companies such as Harwood Group”. As I wrote back then, Mr Singh is owner and sole director of Harwood Group Limited, which was incorporated on 26 June 2015. Its last publicly available accounts, for 2017, reveal the average number of employees during the year – er, one, as it was in 2016! I also reported both sets of accounts to date were submitted late, after Companies House began compulsory strike-off. Not a good sign. At date of publication the 2018 accounts are overdue: these were due by 31 March 2019. And, again, Companies House has initiated compulsory strike-off. Mr Singh now omits to mention Harwood Group on the ICC website (screen shot in Figure 2).
    

    Figure 2. Bobby Singh profile: ICC website at 2 July 2019

12. Talking of late accounts, ICC itself was late filing its last accounts, for 2018. Also due by 31 March 2019, these were submitted on 11 June 2019. The independent auditor’s report includes a separate section entitled “Material Uncertainty Related to Going Concern”. Here the auditor concludes a “material uncertainty” exists that “may cast significant doubt” over ICC’s “ability to continue as a going concern”. The presence of this section indicates the auditor considers management have included adequate disclosures relating to the material uncertainty.
13. I don’t know whether Mr Khawaja is involved with ICC any longer or not. Yes, at date of publication he remains absent from the firm website. But as my first post shows, ICC has made false and exaggerated claims. If Mr Khawaja no longer has a role there, why did he have one in the first place?

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Lord Polak now shown as a trustee of The Holocaust Memorial Charitable Trust

1. Today (27 June 2019) records for charity The Holocaust Memorial Charitable Trust have been updated at both the Charity Commission and Companies House. Previously Lord Polak wasn’t shown as a trustee or director respectively (see previous post). He now is.

Proposed Holocaust Memorial and Learning Centre hires TWO lobbying firms

1. Here I reveal the serious, if opaque, lobbying effort for the proposed Holocaust Memorial and Learning Centre in Victoria Tower Gardens, next to parliament in Westminster (see previous post). A second lobbying firm has just been hired, according to the latest public affairs register, 1 March 2019-31 May 2019, at the Public Relations and Communications Association (PRCA) website. Meanwhile, the government’s project secretariat disclosed unacceptably confused and incomplete information about the exact activities of the first lobbying firm.
2. The UK Holocaust Memorial Foundation (UKHMF), “an advisory board” to the Ministry of Housing, Communities and Local Government, is overseeing delivery of the proposed development. Former cabinet ministers Sir Eric Pickles and Ed Balls are co-chairs of UKHMF. The board includes, among others, Gerald Ronson, Lord Feldman of Elstree and Peter Freeman (screen shot in Figure 1). Why I’ve highlighted these five individuals will become clear in a moment.
   

   Figure 1. UK Holocaust Memorial Foundation members: foundation website at 20 June 2019

3. UKHMF is a client of political lobbyist Four Communications, the latest PRCA public affairs register shows. I asked UKHMF in an email to tell me, for transparency, both whom UKHMF is lobbying via Four Communications and for what purpose. In my first email I didn’t refer to the latest PRCA public affairs register: I simply said it’s a matter of public record that UKHMF is a client of the political lobbyist.
4. In its first response, UKHMF said Four Communications had been appointed to “consult local stakeholders about the proposals”. It added: “This includes engaging with local residents and businesses, amenity groups and councillors.” Thus UKHMF said nothing about lobbying.
5. When I went back for clarification, UKHMF wrote in another email: “Four do not do any lobbying on our behalf”.
6. I then pointed to the fact Four Communications discloses UKHMF as a political lobbying client, on the latest PRCA public affairs register. Thus I requested further clarification. I didn’t receive a response.
7. UKHMF is a long-term client of Four Communications. The current form of the PRCA public affairs register dates back to last summer (1 June 2018-31 August 2018). The archived register for that period shows the political lobbyist working for UKHMF.
8. As I say, a second lobbying firm has just been hired. While UKHMF continues with Four Communications, new charity The Holocaust Memorial Charitable Trust (HMCT) has appointed Newgate Communications.
9. Registered as a charity on 30 January 2019, HMCT has five founding trustees: Gerald Ronson, Lord Feldman, Peter Freeman, Sir Eric Pickles and Ed Balls. Yes, all five are members of UKHMF.
10. On 7 May 2019, prime minister Theresa May announced a further £25m for the new Holocaust Memorial and Learning Centre – in addition to the £50m the government has already committed. The £25m is to be matched by £25m raised by HMCT. Total project costs will be around £100m, predicts UKHMF.
11. At date of publication there’s very little on the public record about HMCT. For a start, it doesn’t have a website. A solicitor at law firm Withers, Neasa Coen, is shown as public contact on the Charity Commission public register of charities (screen shot in Figure 2). Ms Coen told me in an email she’s unpaid as public contact. When asked why HMCT appointed an external solicitor, rather than an internal person, Ms Coen said in another email: “I provided legal advice on the establishment and registration of the charity. My details were inserted as charity contact as the charity does not have its own offices and is in the early stages of operation.” However, I didn’t receive a response after asking her two more questions, both reasonable. First, who or what entity sought your legal advice on the establishment and registration of the charity? Second, were you paid for providing the legal advice?
    

    Figure 2. Contact details for charity The Holocaust Memorial Charitable Trust: Charity Commission website at 7 May 2019

12. One thing is clear: HMCT has five founding trustees, according to records at both the Charity Commission and Companies House. Or does it? Lord Polak states he’s a trustee as well, on the register of lords’ interests (screen shot in Figure 3).
    

    Figure 3. Lord Polak: register of lords’ interests at 19 June 2019

13. Lord Polak didn’t respond to emailed requests for comment.
14. Who he? Stuart Polak relinquished his 25-year role as head of Conservative Friends of Israel (CFI) when joining the Lords in October 2015. The Tory peer remains honorary president. CFI, which lobbies on behalf of the Israeli state, regularly organises trips there for Conservative parliamentarians and candidates. Lord Polak was at the centre of the scandal back in 2017 involving then UK international development secretary Priti Patel that led to her resignation from the cabinet in November that year. Ms Patel had unauthorised meetings with Israeli politicians and organisations earlier in 2017 while on holiday there. Lord Polak organised all 12 meetings, and was present at all but one.
15. UKHMF member and HMCT trustee Mr Ronson is also chair of eponymous charity The Gerald and Gail Ronson Family Foundation, whose trustees include solicitor Ian Rosenblatt. It’s a small world: Mr Rosenblatt is married to Emma Kane, chief executive of Newgate Communications.
16. In fact, it’s even smaller than that. In January 2000, Mr Rosenblatt and Ms Kane founded Redleaf Communications, which was rebranded as Newgate Communications in 2018. Further, Ms Kane has long provided PR services for Mr Ronson and his companies, including Ronson Capital Partners (screen shot in Figure 4) and property company Heron International.
    

    Figure 4. Ronson Capital Partners website: Emma Kane of Redleaf is PR contact at 21 June 2019

17. Ms Kane is also chair of arts and culture charity The Barbican Centre Trust Limited, which is based at The Barbican Centre, “a world-class arts and learning centre” in central London. It was in that capacity she wrote an article in The Jewish Chronicle newspaper on 27 November 2014, entitled “To compete, the arts need to collaborate” (screen shot in Figure 5). There the chair of the Barbican Centre Trust effused at length about The Heron, Heron International’s then new apartment tower next to The Barbican Centre. Yet Ms Kane failed to disclose a relevant financial interest: Redleaf Communications then acted for Heron International and The Heron (screen shot in Figure 6).
    

    Figure 5. Emma Kane, chair of charity the Barbican Centre Trust, writes article in The Jewish Chronicle newspaper on 27 November 2014 (“To compete, the arts need to collaborate”)

    

    Figure 6. The Heron development website: Redleaf is PR contact at 21 June 2019

18. When asked for comment, Ms Kane said in a one-sentence email: “This is to confirm that I have received your email and have forwarded it to the Jewish Chronicle as publisher of the article.”
19. Let’s hope Newgate Communications is more honest and transparent when working for HMCT, whomever the new charity is actually lobbying and for what purpose.
20. Recently, critics have questioned why the government hired PR firm Big Ideas to help “public engagement” over the plans. They fear the government is attempting to rig the planning consultation organised by Westminster city council (see previous post). There’s credible evidence for this, as The Jewish Chronicle, The Architects’ Journal, Private Eye magazine and The Times newspaper have separately reported.
21. Meanwhile, hitherto the lobbying effort for the proposed Holocaust Memorial and Learning Centre has remained hidden. Here I show not just one lobbying firm is involved, but two. Such serious lobbying risks the perception that the government is determined to do whatever it takes to pressure Westminster city council into approving the proposed development. Do opponents of the scheme stand a chance?
22. There’s no suggestion that anyone has done anything illegal.

The fatal omission in The Royal Parks’ first annual report as a charity

1. Registered as a charity on 15 March 2017, The Royal Parks (TRP) manages 5k acres of parks across London, including the world-famous Hyde Park in the city centre. The new charity’s latest trustees’ annual report (TAR), its first, is made up to 31 March 2018. The document contains a fatal omission: it says nothing about the new Holocaust Memorial and Learning Centre.
2. On 27 January 2016, then prime minister David Cameron announced that a new national memorial to the Holocaust would be built in Victoria Tower Gardens, next to parliament in Westminster. TRP looks after Victoria Tower Gardens. The official press release said: “The memorial will be developed with guidance from Westminster Council [sic], the Royal Parks and the Department for Culture, Media and Sport.” (screen shot in Figure 1). Yet the charity’s first TAR doesn’t mention the new national memorial.
   

   Figure 1. “PM: Holocaust memorial will stand beside Parliament as permanent statement of our British values”: government press release on 27 January 2016

3. On 18 November 2016, the government announced the 10 “world-class” teams that had been selected from almost 100 entries to create designs for the new Holocaust Memorial. It also said an independent jury would select the winner. Loyd Grossman, chair of TRP, was a jury member (screen shot in Figure 2). (Charitable company TRP was incorporated as a limited company – limited by guarantee, not shares – on 19 February 2016. Mr Grossman was appointed as a director on 10 October 2016.)
   

   Figure 2. “10 world-class teams compete to design new National Holocaust Memorial”: government press release on 18 November 2016

4. Yet when the winning architects were unveiled on 24 October 2017, Mr Grossman had disappeared from the jury without explanation (screen shot in Figure 3). So what happened? It’s disappointing TRP didn’t see fit to document any of this in its first TAR.
   

   Figure 3. “Adjaye Associates and Ron Arad Architects win UK Holocaust Memorial International Design Competition”: government press release on 24 October 2017

5. The winning architects were: Adjaye Associates, Ron Arad Architects and Gustafson Porter + Bowman.
6. On 19 December 2018, a planning application for the new Holocaust Memorial and Learning Centre was submitted to Westminster city council. The designs were then revised and a new planning application duly made on 7 January 2019 (Westminster city council reference: 19/00114/FULL).
7. In a letter to the council dated 8 February 2019, TRP objected to the latest planning application, saying Victoria Tower Gardens wouldn’t be an appropriate location for the proposed structure. (19_00114_FULL-THE_ROYAL_PARKS-5827776)
8. TRP’s opposition was widely reported in the media. However, its letter contains a revealing sentence that escaped attention: “Ministers have made clear that there is no role for the charity [The Royal Parks] in the approval process.”
9. I asked TRP in an email: before its letter of 8 February 2019 to the council, was it a matter of public record that “Ministers have made clear that there is no role for the charity [The Royal Parks] in the approval process”? If so, when and where did Ministers publicly say this?
10. In response, David McLaren, chief of staff at TRP, said the government communicated its position to the charity in March 2018 – in a letter from the secretary of state for Digital, Culture, Media and Sport (DCMS) to Mr Grossman. Not an open letter, it isn’t on the public record.
11. The charity’s first TAR is made up to 31 March 2018, of course. So there TRP could have disclosed the constraints DCMS imposed on the charity in relation to the new Holocaust Memorial and Learning Centre. TRP opted to say nothing instead.
12. Companies House records show the secretary of state for DCMS is sole “person with significant control” of TRP. The culture secretary may appoint up to seven trustees, including the chair, while the Mayor of London may appoint up to six, according to the charity’s “articles of association”. There’s also an ex officio trustee, who represents the Royal Household. The maximum number of trustees is 14, therefore. Before becoming a charity, TRP was an executive agency of DCMS. There’s now a contract for the provision of services between TRP and DCMS.
13. TRP styles itself as an “independent” charity in its first TAR. True, it did demonstrate independence when it publicly objected to the latest designs for the development in Victoria Tower Gardens. Nevertheless the culture secretary alone controls TRP, while the charity depends on DCMS for funding. Further, TRP omits to mention two key issues in its first TAR. First, the new Holocaust Memorial and Learning Centre. Second, the charity’s dealings with DCMS around the development. A truly independent charity would and should document both.
14. When asked to comment on the omission, Mr McLaren said in an email: “The charity’s annual report covers some of the key activities that have taken place during the reporting year. If the learning centre and memorial receives planning permission (which was only submitted relatively recently) and is built, then I am sure this will feature in TRP’s annual report.”
15. Does meddling by DCMS explain the absence in the annual report? Or were Mr Grossman and fellow trustees simply too cowed by DCMS to tell the public about the charity’s activities in relation to the new Holocaust Memorial and Learning Centre? Regardless, the fatal omission undermines TRP’s independence and credibility.

Crispin Blunt MP to correct register of MPs’ financial interests after my investigation

1. On 3 June 2019, I revealed that the company former minister Crispin Blunt MP registered on the register of MPs’ financial interests as having paid him £20k back in March 2018 is actually dormant. How could a dormant company pay him thus?
2. Prior to publication, Mr Blunt didn’t respond to emailed requests for comment. I gave him a reasonable time.
3. On 11 June 2019, however, I received an email from the MP. There he acknowledged the company was in fact dormant; and pledged to correct the register of MPs’ financial interests accordingly.
4. Below follows Mr Blunt‘s email in full:

“Thank you for your email of 22 May 2019 and the chaser. Thank you for the notice of your blog and on preparing this reply I have noted your post of 3 June. I’m afraid I was away on leave and I have had to make inquiries of others to give you the fullest reply.

I entered into a contract with Wena Consult Ltd as declared in the register and received an initial payment of £20,000 as declared. Following your inquiry I have sought clarity on the actual source of the payment. Wena Consult Ltd is indeed a dormant company, 90% owned by UK citizen Nael El Farargy and 10% owned by Ihab Kamal, a Jordanian citizen who owns the Kamal Exchange Company. You will note from the register that I have worked with both Ihab Kamal and Nael Farargy before. I count both as friends as well as business partners and we share with an overriding interest in good UK-Arab relations.

The relationship began in 1997 when my then constituent Nael Farargy sought my help in his dispute over the expropriation of his Cairo hotel (now the Kempinski) by the Egyptian Government. This was eventually settled in 2002 (the Wena Hotel Case) under the UK-Egypt Investor Protection Treaty by the International Centre for the Settlement of Investor Disputes. Subsequently, Mr Farargy introduced me to Jordanian citizen Mr Kamal, with whom I worked, before becoming a minister in 2010. In that period I welcomed his significant support for the Council for Arab British Understanding of which he is now an Honorary Vice President.

Last year they sought my professional help again under the terms declared to the Registrar. Wena Consult Ltd was intended to be the corporate vehicle through which I assisted their joint interests, but so far no beneficial contracts from our work have been secured. Following your inquiry I have now established that the payment in March 2018 was made directly by the 90% owner of Wena Consult Ltd, Nael Farargy. This now needs to be made clear in the register and I am copying this to the registrar for that purpose and to invite her advice about how to make the correction. I still await the payment due in March 2019 and am in informal discussions with Mr Farargy and Mr Kamal to resolve matters. When I have, I will report the position to the Registrar who has already been notified of my non-payment, though I anticipate the contract will be honoured, and if Wena Consult Ltd remains dormant and a payment is made from another source of funds available to the owners the record will have to reflect this.

Thank you for bringing this to my attention.”

Unexplained inconsistency in reported donation to Pears Foundation by The William Pears Group of Companies Limited

1. The Pears family, who own and run a large number of property companies as The William Pears Group, are worth an estimated £3.3bn, which ranks them at number 45 on the latest (2019) Sunday Times rich list. On 4 March 1992, the London-based family registered a charity, The Pears Family Charitable Foundation (registered charity number: 1009195). Brothers Sir Trevor, Mark and David are the three trustees. Sir Trevor is executive chair, which is a full-time role, according to the charity website. Most of its income derives from donations made by related party The William Pears Group of Companies Limited (registered company number: 00556533). Here I reveal an unexplained inconsistency in a reported donation to the Pears Foundation in 2017 by the firm.
2. I refer to the latest accounts for The William Pears Group of Companies Limited, made up to 30 April 2018. Note 23 in the notes to the financial statements (“related-party transactions”) says: “During the year the company contributed £15 887 059 (2017 – £18 746 561) to The Pears Family Charitable Foundation…”
3. Meanwhile, see the latest accounts for William Pears Group Limited (registered company number: 08476364), also made up to 30 April 2018. Note 32 in the notes to the financial statements (“related-party transactions”) states: “During the year, a subsidiary contributed £15.9m (2017 – £18.4m) to The Pears Family Charitable Foundation…”
4. Thus in 2017 there’s an unexplained inconsistency in the reported donation by The William Pears Group of Companies Limited: £18 746 561 vs. £18.4m. The figures for 2018 are consistent, of course: £15 887 059 vs. £15.9m.
5. Further, the same unexplained inconsistency occurs in the 2017 accounts as well, again both with a year end of 30 April. Note 23 for The William Pears Group of Companies Limited says: “During the year the company contributed £18 746 561 (2016 – £13 166 764) to The Pears Family Charitable Foundation…” While note 32 for William Pears Group Limited states: “During the year, a subsidiary contributed £18.4m (2016 – £13.2m) to The Pears Family Charitable Foundation…” The figures for 2016 are consistent, of course: £13 166 764 vs. £13.2m.
6. For the avoidance of doubt, I can’t use the accounts of the Pears Foundation to help resolve the inconsistency: the charity has a year end of 31 March, not 30 April.
7. Sir Trevor didn’t respond to emailed requests for comment.

Ditchley director has undisclosed other business interests that potentially overlap with the charity’s activities

1. An influential charity and its director won’t answer a simple question.
2. On 24 October 2018, James Arroyo, director of The Ditchley Foundation, spoke at an event on cyber security that took place at the London Stock Exchange Group (screen shot in Figure 1). (https://www.lseg.com/events/issuer-services-cyber-security-masterclass-24-october-2018) The meeting was sponsored by commercial companies. Mr Arroyo, as you can see, spoke in his capacity as Ditchley director. But was he paid to speak at the external event?
   

   Figure 1. Cyber security event at the London Stock Exchange Group on 24 October 2018 where James Arroyo spoke

3. Mr Arroyo didn’t respond to emails asking the question. Nor subsequently did Lord Hill of Oareford, chair of the charity. Their unresponsiveness is disappointing. The question is legitimate. Charities are rightly expected to be transparent and accountable.
4. Their lack of response contrasts with the willingness of Lord Evans of Weardale, another speaker that day, to answer the same question (and then others) via email (see 18 December 2018 post). Lord Evans is former director general of the Security Service, MI5.
5. Registered as a charity on 1 May 1962, Ditchley is “positioned at the crossroads of government, business and technology”, “connecting people and ideas”. The foundation brings “carefully selected groups of people together to discuss difficult issues, aiming to promote new thinking and to make new connections. We combine established leaders with emerging talent in a field and we connect people across fields of expertise.” Most of its events take place at the charity’s home, Ditchley Park, a historic house in the Oxfordshire countryside.
6. Ditchley is an establishment charity whose trustees comprise MPs, peers, business leaders, academics and journalists. As I say, Lord Hill, the UK’s former EU commissioner, is chair of the board of trustees, while Philip Stephens of the Financial Times newspaper is vice-chair.
7. Before being appointed director in 2016, Mr Arroyo was “director for data at the British Foreign and Commonwealth Office, charged with adapting the organisation to the digital age” (screen shot in Figure 2). However, his profile on the Ditchley website says nothing about his related other jobs.
   

   Figure 2. James Arroyo profile: Ditchley Foundation website at 1 May 2019

8. Mr Arroyo is also a partner at Wychwood Partners LLP, a firm that helps “companies and governments” build “capability and digital resilience” (screen shot in Figure 3). Mr Arroyo’s profile on the Wychwood Partners website leads with his role at Ditchley, but goes on to list several related other jobs (screen shot in Figure 4). The contrast to the non-disclosure on the Ditchley website is telling.
   

   Figure 3. Wychwood Partners LLP homepage at 1 May 2019

   

   Figure 4. James Arroyo profile: Wychwood Partners LLP website at 1 May 2019

9. Back to the simple question: was Mr Arroyo paid to speak at the external event on cyber security? He’s listed as speaking in his capacity as Ditchley director, of course. Thus if there was payment, who received it? The charity or another entity? Here the reputation of the charity is at stake. So it’s disappointing neither Mr Arroyo nor Lord Hill see fit to answer the question.
10. If there was no payment, there are still problems with Mr Arroyo’s appearance in Ditchley’s name at the event. This is because his other business interests potentially overlap with the charity’s activities. It was an event on cyber security, an expertise Mr Arroyo explicitly identifies in relation to his other jobs (Figure 4).
11. Last year, Ditchley’s highest-paid employee received £100k-£110k, according to the latest publicly available accounts, made up to 31 March 2018. As director, this was presumably Mr Arroyo.
12. All Ditchley’s events are invitation-only, which shows it likes to avoid scrutiny. Yet opacity and unresponsiveness from an organisation – let alone a charity – don’t inspire trust and confidence. Mr Arroyo’s biography on the charity website is clearly deficient. As a start, a public register of interests should be published there. The current absence of such an online register raises legitimate concerns about Ditchley’s handling of conflicts of interest, actual, potential, or perceived. The charity needs to do much more if it doesn’t want to be seen as a closed, cosy club where conflicts of interest are ignored.