Soldiering On Through Life Trust: charity or political lobbyist?

  1. This is an investigation into the activities of military charity Soldiering On Through Life Trust (SOTLT). The charity, which apparently has a topical and popular cause with emotive appeal, involves many celebrities and MPs, including the Prime Minister. Here I expose how on one day in November 2013, SOTLT raised funds from the public in central Manchester illegally, in two different ways. I also show that the charity gives the impression that it directly supports “heroes”, but in fact it doesn’t. Rather, SOTLT in turn donates funds to other military charities – very inefficiently. In 2012, it donated only 8.3% (i.e. £15 000) of its £180 564 income to military charities. So for whom exactly is SOTLT raising funds? It presents itself to business as a political lobbyist, offering “access” to “government” for cash. The Sunday Mirror newspaper is a corporate supporter, ensuring high public visibility. But anyone wishing to donate to military charities should do so directly, bypassing this expensive, unnecessary and opaque intermediary.
  2. Before November 2013, I’d never heard of SOTLT (registered charity number: 1144828; http://www.soldieringon.org). I first became aware of them 14 November 2013, when I encountered a marquee on their behalf in central Manchester. It was erected in the area of Piccadilly Gardens near the Queen Victoria statue. The public had free access to the marquee. Both under and outside the marquee, SOTLT representatives were soliciting money from the public.
  3. A Freedom of Information request to Manchester City Council showed that on 14 November 2013, the council had granted a “street collection permit” to SOTLT for the city centre. But SOTLT shouldn’t have been soliciting money from the public in that exact location (the area of Piccadilly Gardens near the Queen Victoria statue) even with a street collection permit. A street collection permit does not authorise collections of money in Piccadilly Gardens or any of the municipal parks in Manchester (source: the Licensing Unit at the council). The street collection section of the application form to hold a public charitable collection in Manchester (available on the council website) explicitly states that the council doesn’t allow charitable collections in Piccadilly Gardens.
  4. As well as collecting cash donations that day, SOTLT representatives were selling tickets for the SOTLT Grand Raffle 2013. At the time, no one could provide the raffle Terms and Conditions. The page on the SOTLT website for the raffle (http://www.soldieringon.org/grand-raffle.html) didn’t provide the Terms and Conditions either. The official leaflet about the Grand Raffle 2013 stated that trustee Colin Debenham was organiser. (On the day, laminated copies of the leaflet were available for inspection, but there were none to take away. When I challenged this, I was directed to the website. But the leaflet [PDF file] has now been removed from the raffle page there.)
  5. So on 15 November 2013, I emailed Mr Debenham to ask where I could access the raffle Terms and Conditions. In his 19 November 2013 reply, Mr Debenham attached the raffle Terms and Conditions, “which were submitted to the Gambling Commission for approval prior to the granting of our licence”. He also said that he would arrange for the Terms and Conditions to be put on the website (http://www.soldieringon.org/documents/GrandRaffle2013/TERMS%20AND%20CONDITIONS%20-%20Grand%20Raffle%202013.pdf).
  6. Although the raffle Terms and Conditions didn’t actually state that SOTLT has an active operating licence from the Gambling Commission, I could confirm this at the Gambling Commission website (reference: 35840). Further, the Terms and Conditions failed to say how much of the proceeds would go to the charity.
  7. On 21 November 2013, I therefore emailed Mr Debenham for the relevant proportion of proceeds, asking four other legitimate questions about the raffle. Mr Debenham replied the same day: “Perhaps it would be easier if we spoke to one another. Please forward your number and I shall ring you tomorrow.” I sent a message that day saying that I’d prefer to have the answers in writing (email), asking whether that was unreasonable. In his immediate response, Mr Debenham said: “Who are you? And why all these questions? Before I respond to your request, I would like to know who Soldiering On is dealing with. That is how we conduct our business.” He again stated that he’d prefer to talk on the phone, finishing: “We are, after all, merely running a raffle for those requiring our support.”
  8. On 25 November 2013, I disclosed my full name, adding that I was just a member of the public. I said that the five legitimate questions that I’d asked 21 November 2013 all related to the raffle. Nothing else. I didn’t hear anything more from Mr Debenham.
  9. 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”.
  10. The raffle Terms and Conditions that Mr Debenham sent didn’t actually specify type of lottery. This – type of lottery – was one of the five legitimate questions that I’d asked about the raffle. According to the Gambling Commission website, the SOTLT operating licence is for “society lotteries”.
  11. Society lotteries are “lotteries promoted for the benefit of a non-commercial society.” (http://www.gamblingcommission.gov.uk/pdf/Promoting%20society%20and%20local%20authority%20lotteries%20-%20November%202009.pdf)
  12. SOTLT shouldn’t have been selling the raffle tickets to the public in central Manchester that day. On sale of tickets, the Gambling Commission stipulates: “Tickets in society and local authority lotteries promoted under licence from the Commission must not be sold to anyone in a street.” (http://www.gamblingcommission.gov.uk/pdf/Promoting%20society%20and%20local%20authority%20lotteries%20-%20November%202009.pdf) Here “a street includes any bridge, road, lane, footway, subway, square, court, alley or passage (including passages through enclosed premises such as shopping malls) whether a thoroughfare or not.”
  13. But for whom exactly is SOTLT raising funds? “Supporting our Military Heroes throughout life” is their slogan. It repeatedly tweets (@soldieringontlt) this solicitation: “We shamelessly ask for donations!! Supporting our wounded military heroes Please RT, Thank you :)”, with a link to the homepage. SOTLT gives the impression that it directly supports “heroes”, but in fact it doesn’t. Rather, it in turn donates funds to other military charities (http://www.soldieringon.org/about-charities.html) – very inefficiently.
  14. SOTLT tells prospective corporate sponsors: “All monies raised [by SOTLT] go to people who are suffering from either physical disability due to injury and/or mental disabilities.” (http://www.purpletangerine.com/soldieringon/downloads/SoldieringOn.pdf) Yet that’s untrue. The corporate brochure, accessible from the sponsors page on the charity website (http://www.soldieringon.org/sponsors.html), also says that the auction at the 2012 SOTLT Awards Night raised “over £50 000”. But in their only accounts on the Charity Commission website, for financial year ending (FYE) 31 Jul 2012, SOTLT state that the auction raised £37 510.
  15. In 2012, SOTLT donated only 8.3% (i.e. £15 000) of its £180 564 income to military charities (“Grant to Charity” in the accounts). In other words, very little of the funds that SOTLT raises in the name of “our wounded military heroes” are actually used to help them. Even then less than £15 000 would have been spent on “charitable activities”: the recipient charities themselves have their own costs. Clearly, it is very inefficient for anyone to donate to military charities via SOTLT.
  16. But SOTLT isn’t just an expensive intermediary for donors to military charities. One of the reasons the charity gives companies for being involved is “access” to “government”: “meet the PM and other MPs”, says the corporate brochure. It shows a picture of the Prime Minister, smiling, with SOTLT trustee and chairman, Wing Commander Tal Lambert MBE. Here SOTLT presents itself to business as a political lobbyist, offering “access” for cash. Indeed, the draw for the Grand Raffle 2013 took place at the House of Commons on 28 November 2013. The host of the SOTLT reception there, an annual event, was the Parliamentary Under Secretary of State and Minister for Defence Personnel, Welfare and Veterans – Anna Soubry MP. SOTLT is at the heart of government.
  17. Cobseo, the Confederation of Service Charities (http://www.cobseo.org.uk), officially supports the 2014 SOTLT Awards Night (to be held on 5 April 2014); and encourages all military charities to participate (http://www.cobseo.org.uk/news/soldiering-on-through-life-trust-sotlt-awards-2014-saturday-5-april-2014). Here the endorsement from Cobseo enhances the influence of SOTLT as a political lobbyist.
  18. Cobseo also supports the SOTLT Grand Raffle 2013, according to the raffle Terms and Conditions. This alleged endorsement of the raffle encourages public confidence and trust in SOTLT and its activities.
  19. The Sunday Mirror is a corporate supporter of SOTLT, raising the public profile of the charity. 2014 is the second year that the newspaper has supported SOTLT by running the People’s Choice Award at the SOTLT Awards Night. On 23 February 2014, the paper announced the nominations for this year’s award (“Vote for your army hero”). Is the Sunday Mirror really serving its readers by associating itself with a charity that effectively charges the public a very large – and wholly avoidable – fee to donate to other military charities? It sounds to me like a case for Andrew Penman, the investigative journalist whose weekly column in the Daily Mirror “uncovers scams and exposes injustice”.
  20. On 24 February 2014, Wing Commander Lambert (email) confirmed two facts about the annual SOTLT Awards Night, the charity’s “flagship event”. First, military charities successfully nominating a winner of a SOTLT Award receive funds from SOTLT. Second, the actual winners themselves, the “heroes”, receive no funds from SOTLT.
  21. Anyone wishing to donate to military charities should do so directly, bypassing this expensive, unnecessary and opaque intermediary.
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4 thoughts on “Soldiering On Through Life Trust: charity or political lobbyist?

  1. Pingback: Soldiering On Through Life Trust: the “fab” new website that censors previously published information | Dr Alex May

  2. Pingback: Soldiering On Through Life Trust: “We would be delighted to hear from you and to answer your questions” | Dr Alex May

  3. Pingback: Why is Martin Lewis endorsing Soldiering On Through Life Trust? | Dr Alex May

  4. Pingback: Soldiering On Through Life Trust: a very inefficient military charity is now even more inefficient | Dr Alex May

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