The fundraiser, the comedian and the ex-cabinet minister: The tale of a military charity

  1. This is an investigation into the activities of military charity Afghan Heroes and their official professional fundraiser, Prize Promotions Limited, in different parts of Greater Manchester. The charity, which has a topical and popular cause with emotive appeal, involves both a comedian and an ex-cabinet minister. In 2012, it spent less than 3 per cent of its £548 440 income on “charitable activities”; and more than 91 per cent on “income generation and governance”. On 17 December 2013, the Charity Commission announced that it has opened a “statutory inquiry” into Afghan Heroes. Here I expose two schemes the professional fundraiser is using to raise funds from the public illegally: one in shopping centres, the other on the street.
  2. Before February 2013, I’d never heard of Afghan Heroes (registered charity number: 1132340). But I was then familiar with Help for Heroes (registered charity number: 1120920), the well-known and much bigger military charity launched 1 October 2007. “Support for our Wounded” is the Help for Heroes slogan. Help for Heroes predates Afghan Heroes: the latter began 15 September 2009. Clearly, the two military charities have similar names.
  3. I first became aware of Afghan Heroes 20 February 2013, when that evening I happened to visit the Merseyway shopping centre in Stockport, Greater Manchester. There in the covered section I saw a temporary stand with the charity’s name and branding, then unattended. That night online I found the Afghan Heroes website, http://www.afghanheroes.org.uk. Next in the centre 22 February evening: again no one was at the promotion. I returned the following morning, a Saturday, but this time two men were at the stand. There were orange collection tubs on the associated table, enabling the public to make cash donations apparently to Afghan Heroes.
  4. As I walked past, one of them asked: “Do you want to buy a raffle ticket to help injured soldiers?” I stopped and asked for further information about the “raffle” and the exact role of the two men. He referred me to the Afghan Heroes website. The man then told me that they worked for Prize Promotions Limited, the official professional fundraiser for the charity. Familiar with the charity’s website, I knew it didn’t at that time provide any detail about the promotion other than it was a “raffle” and an organisation called Prize Promotions were responsible for it. The Afghan Heroes website didn’t have a link to a website for Prize Promotions, for example. Here is the “Prize Promotions Raffle Draw” page from the charity website at 25 February 2013, announcing the winners of the “raffle” for “December 5th”: http://sdrv.ms/1gZ7KwH. Further, here is a Facebook page from Afghan Heroes dated 28 September 2012 announcing the Prize Promotions “raffle” winners: http://sdrv.ms/19k5bAp.
  5. I therefore asked the man who addressed me if there was any information about the promotion and his company I could take away. Somewhat flustered, he handed me a “raffle” ticket.
    Figure 1. Afghan Heroes “raffle” ticket: front

    Figure 1. Afghan Heroes “raffle” ticket: front

    Figure 2. Afghan Heroes “raffle” ticket: back

    Figure 2. Afghan Heroes “raffle” ticket: back

  6. Figure 1 shows the front of the ticket; Figure 2 the back. While here is an independent photo of the front of another of these tickets – for a “draw” on 5 December 2012: http://thoughtsofoscar.blogspot.co.uk/2012/11/misleading.html. The first thing I noticed about these tickets was that they say on the front “skill prize competition” – not raffle. In fact, the word “raffle” doesn’t actually appear anywhere on the tickets. At the time, this was confusing for three reasons. First, the explicit solicitation in the shopping centre to buy a raffle ticket. Second, the contemporaneous “Prize Promotions Raffle Draw” page from the charity website. Third, in their then most recent accounts on the Charity Commission website, for financial year ending (FYE) 31 December 2011, Afghan Heroes state that Prize Promotions operate “raffles” in shopping centres on their behalf (p. 21).
  7. The contemporaneous “Prize Promotions Raffle Draw” page from the charity website failed to provide the Terms and Conditions for the “raffle”. Although the ticket didn’t specify a website address for Prize Promotions either, it did give an email address through which they “would welcome any feedback to improve our customer service” (Figure 2). On 25 February 2013, I emailed asking for the raffle Terms and Conditions, explaining that I had a ticket for the 5 June 2013 “draw”. Not having received a reply a week later (4 March), I sent another request. Again, this was ignored. On 12 March, I therefore emailed the charity with the same request. Founder and trustee Denise Harris replied 14 March: she would ask Prize Promotions to provide the raffle Terms and Conditions.
  8. On 15 March, director of Prize Promotions Tony Chadwick emailed: “Please can you provide a contact telephone number so we can call you and find out your exact requirements?” I replied 19 March (copied to the charity) that my request was clear and reasonable, adding that as the promoter, it was his responsibility to make available the Terms and Conditions for his promotion. On 22 March, Mr Chadwick responded that he “would like to discuss your exact reasons for your request.” Again, he asked for a contact number he could call. I replied the same day (copied to the charity) that there is nothing to discuss on the phone. I yet again repeated my request for the Terms and Conditions. I continued: “Afghan Heroes used Rogavi for its 2011 fundraising campaign, Afghan Heroes Golf (rogavi.com/powered-by-rogavi). Rogavi makes available to everyone the details of the promotions it organises on behalf of charities (rogavi.com/how-it-works). It is open and transparent.” Then I concluded: “Similarly, the Terms and Conditions for your promotion should be accessible to all. Because you do not make them available thus, I am suspicious. And given you are unwilling to provide the Terms and Conditions on request, I am even more suspicious.” There was no reply.
  9. On 15 April, I emailed Mr Chadwick (copied to the charity) when as well as requesting yet again the Terms and Conditions, I asked either of them to answer a question. Explaining that the ticket I had for the 5 June 2013 “draw” says on the front “skill prize competition” (Figure 1), is it a prize competition or a raffle? He replied the next day – but again only to ask for my contact phone number. My response the same day (copied to the charity) repeated my 15 April 2013 question: is your promotion a prize competition or a raffle? Again, neither Prize Promotions nor Afghan Heroes answered the question.
  10. Not only did the ticket not specify a website address for Prize Promotions. It seemed (seems) there isn’t one: searching online for a company website for the public was (is) unsuccessful. This made me suspicious. But Prize Promotions did (does) have a website to recruit “sales promotion staff” to sell “skill prize draw tickets in shopping centres across the UK” on behalf of Afghan Heroes: http://www.blackpoolsalesjobs.co.uk/prizepromotions.php.  Note here the jobs are not to sell raffle tickets – but something they call “skill prize draw” tickets.
  11. Let’s recap. In February 2013, Merseyway shopping centre in Stockport hosted in the covered section a promotion by Prize Promotions Limited for the charity Afghan Heroes. The booking was for one week: 18 – 24 February. There Prize Promotions, the official professional fundraiser for the charity, collected funds from the public in two ways. First, they collected cash donations in orange collection tubs on a table. Second, they sold what both the charity and Prize Promotions in person describe as raffle tickets. Here is a photo on Facebook of Prize Promotions raising funds for Afghan Heroes in another shopping centre in Greater Manchester, Stretford Mall in Stretford: http://sdrv.ms/JVAY18. The charity tweeted (@AfghanHeroesUK) a link to this image 2 July 2013. Note the orange collection tub on the table for cash donations and the Prize Promotions person (centre) holding the “raffle” tickets. Similarly, see this photo on Facebook of Prize Promotions: http://sdrv.ms/1g3Nt5U, which the charity linked to on Twitter 9 July 2013. Again, this shows the two ways that Prize Promotions collects funds from the public in shopping centres.
  12. According to the Licensing Team at Stockport Metropolitan Borough Council, to collect cash donations from the public in Merseyway, charities need permission from two sources: the management of the shopping centre and the council. Clearly, Merseyway management were happy for Prize Promotions on behalf of Afghan Heroes to rent promotion space. But a Freedom of Information (FOI) request to the council showed that it had granted no “street collection permits” for Merseyway in February 2013. In other words, this was an illegal cash collection.
  13. In Stretford Mall, meanwhile, a charity wishing to collect cash must obtain the permission only of the management of the shopping centre. Permission from Trafford Council, the relevant local authority, is not required (source: the Licensing Section at the council).
  14. Like the charity’s accounts for FYE 31 December 2011, those for FYE 31 December 2012 (p. 29) also state that Prize Promotions operate “raffles” in shopping centres on their behalf. Raffles are a type of lottery. A lottery is a kind of gambling that has three essential elements: you have to pay to participate; there is at least one prize; and those prizes are awarded by chance (http://www.gamblingcommission.gov.uk/PDF/Running%20a%20lottery%20-%20November%202009.pdf). In a raffle, “players buy a ticket with a number on it. The tickets are randomly drawn and those holding the same numbered ticket win a prize”. The Afghan Heroes accounts for FYE 31 December 2011 (p. 21) and FYE 31 December 2012 (p. 29 and p.32) both state that comedian Bobby Ball usually draws “the winning numbers” in the Prize Promotions “raffles”.
  15. If these were genuine raffles, the role of Prize Promotions would constitute that of an “external lottery manager” (ELM) (http://www.gamblingcommission.gov.uk/pdf/Promoting%20society%20and%20local%20authority%20lotteries%20-%20November%202009.pdf). ELMs must be licensed by the Gambling Commission. Prize Promotions does not hold a lottery manager’s operating licence issued by the Commission. By this criterion therefore these “raffles” are illegal lotteries.
  16. Even if Prize Promotions was an ELM licensed by the Gambling Commission, which it is not, it would still not be allowed to sell lottery tickets in a public street (http://www.gamblingcommission.gov.uk/pdf/Promoting%20society%20and%20local%20authority%20lotteries%20-%20November%202009.pdf). Here “street” includes “passages through enclosed premises such as shopping malls”.
  17. Although the word “raffle” doesn’t actually appear anywhere on the tickets, the word “draw” is prominent on the front (Figure 1). There the date of the “draw” is specified. On the back, Prize Promotions state that they “conduct the prize draw on their [Afghan Heroes] behalf” (Figure 2). There are two other ways in which the tickets resemble genuine lottery tickets. First, the statement “Tickets must not be sold to persons under 16 years of age” (Figure 2). Lottery tickets must not be sold to, or by, those under the age of 16 (http://www.gamblingcommission.gov.uk/pdf/Promoting%20society%20and%20local%20authority%20lotteries%20-%20November%202009.pdf). Second, the statement “Guaranteed minimum 20% + profit goes towards Afghan Heroes charity” (Figure 2). In a genuine charity lottery, the charity must apply “at least 20% of the gross proceeds” of the lottery directly to the purposes of the charity (http://www.gamblingcommission.gov.uk/pdf/Promoting%20society%20and%20local%20authority%20lotteries%20-%20November%202009.pdf).
  18. On the funds raised for the charity, the Afghan Heroes accounts for FYE 31 December 2012 (p.32) are inconsistent with the statement on the back of the tickets, “Guaranteed minimum 20% + profit goes towards Afghan Heroes charity.” The latest accounts say “20% of the ticket sales” for each “prize draw” go to the charity. As well as this discrepancy, the accounts describe Prize Promotions as “donating” this amount. This is strange: a member of the public buying a ticket is led to believe that it’s their money that goes to Afghan Heroes.
  19. We must now turn to the “skill prize competition” on the front of the tickets. Afghan Heroes does not use this expression on their website or in their accounts. They variously refer to the Prize Promotions “raffles”, “prize draws” or “skill prize draws”. Because both Prize Promotions and Afghan Heroes refuse to provide the Terms and Conditions for the promotions, we have no idea of the significance, if any, of “skill prize competition”. “Prize competition” is a legitimate competition design. No kind of licence from the Gambling Commission is required to run a prize competition (http://www.gamblingcommission.gov.uk/frequently_asked_questions_fa/competitions_and_prize_draws/can_i_run_a_prize_competition.aspx).
  20. What exactly is a prize competition? It’s a competition “where success depends to a substantial degree on the exercise of skill, knowledge, or judgment. Such competitions may involve answering questions, solving puzzles, tie-breakers and so on.” (http://www.gamblingcommission.gov.uk/frequently_asked_questions_fa/competitions_and_prize_draws/can_i_run_a_prize_competition.aspx) Now, both tickets we have seen – for the “draws” on 5 December 2012 (http://thoughtsofoscar.blogspot.co.uk/2012/11/misleading.html) and 5 June 2013 (Figure 1-2) – have a single question on the front. In both cases, it’s a multiple choice question with only three alternative answers. It is important to note that the official announcement of the winners of the 5 December 2012 “raffle draw” on the charity website (http://sdrv.ms/1gZ7KwH) didn’t report the answer to the question on the front of the related ticket. There is no mention of the question. Similarly, the official announcement of the winners of the 5 June 2013 “skill prize draw” on the charity website (http://sdrv.ms/1hze4Iu) didn’t include the answer to the question on the front of the related ticket either. Again, there is no mention of the question.
  21. We don’t know the exact role, if any, of the single questions on the tickets. Perhaps the competition is split into two stages, where at the first stage a participant must answer the question. A correct answer then might enter the participant into a draw where winners are selected randomly. But note: “skill” isn’t required to select the correct answer to the single multiple choice question. And although “knowledge” is needed to do so, the necessary level of knowledge is insufficient because “the answer can be found easily on the Internet” (http://www.gamblingcommission.gov.uk/PDF/Prize%20competitions%20and%20free%20draws%20-%20The%20requirements%20of%20the%20Gambling%20Act%202005%20-%20December%202009.pdf). Also, with only three alternative answers, there is a 33% probability of picking the correct answer by chance. In other words, it is too easy to obtain the correct answer by chance. Further, there is just one question. If there are two stages, the requisite level of “skill, knowledge, or judgment” is insufficient. That is, if there are two stages, these competitions are illegal lotteries.
  22. In Merseyway, even if this was a genuine prize competition, which it is not, Prize Promotions would still not be allowed to sell the tickets without a “street collection permit” from Stockport Metropolitan Borough Council (source: the Licensing Team at the council). We already know that the council granted no “street collection permits” for Merseyway in February 2013 (see para 12).
  23. Now we leave the shopping centres of Greater Manchester and move outside to one of the main shopping streets – Market Street in Manchester city centre. There in 2013 I encountered another Prize Promotions scheme to raise funds from the public illegally: organised teams of people in Afghan Heroes branded clothing selling the charity’s wristbands.
    Figure 3. Afghan Heroes wristband leaflet: front

    Figure 3. Afghan Heroes wristband leaflet: front

    Figure 4. Afghan Heroes wristband leaflet: back

    Figure 4. Afghan Heroes wristband leaflet: back

  24. I first saw them 28 May 2013. When I asked a seller for more information, he handed me a leaflet. Figure 3 shows the front of the leaflet; Figure 4 the back. It fails to disclose how much of the purchase price, if any, goes to the charity. Next seeing them 4 June, I found out the price, £3, and asked how much of that goes to Afghan Heroes. “All of it”, he said. This was the first answer I received. But 200m away I got a second answer: “I don’t know; 20%, I think”, another seller said. He showed me the same leaflet, but wouldn’t let me keep it unless I bought a wristband. On 7 June, there was a third answer: “£2.50. Fifty pence is for expenses – we have to travel from Blackpool.” I was told something else 12 June: “All of it, except the cost of the wristband” (i.e. a fourth answer). I met them again 2 July, with their familiar solicitation: “Help our soldiers”. Again, the sellers were all wearing the black tops with “Helping British Forces” in orange on the back. The charity logo of a soldier in silhouette –  in black, orange and white – was on their left chest. Their right chest displayed the Prize Promotions logo. On 12 July, I was given a fifth answer: “I don’t know; £2, I think. Go and look on the Afghan Heroes website.” This information wasn’t available then on the charity website, and still isn’t. I happened to see them again 8 October.
  25. The Afghan Heroes accounts for FYE 31 December 2012 (p.32) also fail to disclose how much of the £3, if any, someone pays to a Prize Promotions seller for a wristband goes to the charity. It costs £1.99 to buy a wristband on the Afghan Heroes website.
  26. To conduct a collection of money or a sale of articles for the benefit of charitable or other purposes on a public street in Manchester, you are required to hold a “street collection permit” granted by Manchester City Council. The list of charities and societies with permits to perform charity collections within Manchester is publicly available on the council website. At 4 July 2013, Afghan Heroes was not on the register. That day I therefore emailed the charity to ask why without a permit the public should be confident in and trust this apparent fundraising activity in their name. Founder and trustee Denise Harris replied the next day: “…as far as I am aware they [Prize Promotions] do have a permit to do this…” She added that she’d forward my email to Prize Promotions and would “look into this” herself. I heard nothing from either.
  27. On 12 July 2013, I asked one of the Prize Promotions team in Market Street whether he was selling the wristbands with some kind of licence. He said he was operating with a “pedlar’s certificate”. Before this, I’d never heard of a pedlar’s certificate. The requirements for the certificate are not onerous: “Certificates are issued by the police in the area in which you have resided for the previous month. You must be above 17 years of age, a person of good character, and in good faith intend to trade as a pedlar.” (https://www.gov.uk/pedlars-certificate) There is a £12.25 charge, and a certificate remains in force for one year. Here is a November 2013 Prize Promotions job advert for “Charity Merchandise Street Seller”; it includes the requirement of a “pedlars [sic] licence” and says how to get one: http://sdrv.ms/1liliRa.
  28. In September 2013, a FOI request to Manchester City Council showed that for each of the six days to date in 2013 I happened to encounter the teams of sellers in Market Street (28 May; 4 June; 7 June; 12 June; 2 July; 12 July), the council had not granted a “street collection permit” there for the sale of the Afghan Heroes wristbands.
  29. According to the Afghan Heroes accounts for FYE 31 December 2012 (p.32), Prize Promotions raise funds for the charity in two ways: “skill prize draws” (”raffles” on p.29)  and selling the wristbands. Note: the accounts therefore don’t even say that in shopping centres the company collect cash donations for the charity from the public at the same time as selling the tickets.
  30. The “street collection permit” is important for public confidence and trust in charity fundraising. The permit shows the public that collectors are properly authorised, that money is collected in a secure way and the proceeds collected are properly accounted for. Both Stockport Metropolitan Borough Council and Manchester City Council stipulate submission of a statement of return completed by a qualified accountant, detailing the amount received and the expenses incurred – within a month of a collection.
  31. There is another reason for concern around fundraising. In 2012, Afghan Heroes spent less than 3 per cent of its £548 440 income on “charitable activities” (£15 153); and more than 91 per cent on “income generation and governance” (£501 135) (source: accounts for FYE 31 December 2012).
  32. Not only does comedian Bobby Ball usually draw “the winning numbers” for Prize Promotions. He is a patron of Afghan Heroes (p.29 of accounts for FYE 31 December 2012). Singer Tony Christie is another celebrity supporter: he released a single on behalf of the charity in October 2011 (http://www.telegraph.co.uk/culture/culturevideo/musicvideo/8831688/Tony-Christie-launches-Afghan-Heroes-charity-song.html), for example. Former Defence Secretary Dr Liam Fox MP is a patron too. In June 2012, he and Afghan Heroes launched “Give Us Time” (p.27 of accounts for FYE 31 December 2012), a scheme that “takes one-week holidays donated by owners of holiday homes and timeshares, and matches them with Afghanistan military personnel in need of rest, rehabilitation and reconnection with their families” (http://www.giveustime.org.uk). On 28 June 2013, Dr Fox officially opened the charity’s second post-services facility, “The Smuggled Retreat”, located in Somerset (http://www.liamfox.co.uk/events/afghan-heroes). The charity itself is also based in Somerset, as is their first “Retreat”. Dr Fox is MP for North Somerset.
  33. On charities and fundraising, the public is vulnerable to much worse than aggressive but legal “chuggers” and their exhortations to sign up to direct debit donations. Afghan Heroes is a military charity that has a topical and popular cause with emotive appeal. Its name is similar to Help for Heroes, the well-known and much bigger military charity. Public figures are involved: comedian Bobby Ball and ex-cabinet minister Dr Liam Fox MP. In 2012, it spent less than 3 per cent of its £548 440 income on “charitable activities”; and more than 91 per cent on “income generation and governance”. On 17 December 2013, the Charity Commission announced that it has opened a “statutory inquiry” into Afghan Heroes (http://www.charitycommission.gov.uk/news/armed-forces-charity-investigated-by-watchdog/). According to media reports, Dr Fox resigned as a patron 18 December 2013; but there is nothing about this on his website. I have tried many times to seek information from both Afghan Heroes and official professional fundraiser Prize Promotions, asking legitimate questions. They have either ignored me or not answered satisfactorily. Here I have exposed two schemes the professional fundraiser is using to raise funds from the public illegally: one in shopping centres, the other on the street.
  34. ADDENDUM: Cancer Recovery Foundation – UK (registered charity number: 1105703) says it works with Prize Promotions “holding draws and raffles across the UK. Stalls selling tickets and collecting donations for Cancer Recovery will be coming soon to a shopping centre near you.” (http://www.cancerrecovery.org.uk/prize-promotions) In 2012, the charity’s income was £3 143 099 (source: accounts for FYE 31 December 2012). On 8 June 2013, their “first prize draw through Prize Promotions” took place (http://cancerrecovery.org.uk/prizepromotionsdraw/june2013): comedian Bobby Ball selected the winners “at random”.