The Royal Parks’ second annual report as a charity says nothing about Holocaust Memorial and Learning Centre

  1. The government continues to support construction of the controversial Holocaust Memorial and Learning Centre (HMLC) in Victoria Tower Gardens, next to parliament in Westminster. In February 2019, charity The Royal Parks (TRP), which looks after Victoria Tower Gardens and other open spaces in London, publicly opposed the latest planning application to the local council, saying the small park wouldn’t be an appropriate location for the proposed structure (see 17 June 2019 post). Despite its key intervention, the charity’s second annual report, made up to 31 March 2019, fails to refer to its public opposition to the project. What’s more, the second annual report says nothing about HMLC at all even after I pointed out the omission in its first annual report (see 17 June 2019 post).
  2. The 17 June 2019 post quotes David McLaren, chief of staff at TRP, who responded to requests for comment last year. Mr McLaren again commented this time.
  3. I initially requested comment on the following three issues about the second annual report. First, why does it fail to refer to TRP’s public opposition to the latest planning application for HMLC? Second, why does the latest annual report again omit to mention the project at all? Third, is TRP really an independent charity?
  4. In his first response, Mr McLaren didn’t address the first issue. While on the second, he referred me to his explanation last year for the omission in the first annual report (see 17 June 2019 post), adding: “Since the facility has not received approval from planners and construction work has not started it was not mentioned in the report.” On the third issue, TRP’s independence, Mr McLaren wrote: “…The Royal Parks is an independent charity and must act within the parameters of its articles of association”.
  5. By reply, I pointed out his failure to address the first issue.
  6. I then said his response to the second issue is laughable, I’m afraid. “TRP can’t just pretend the Holocaust Memorial and Learning Centre isn’t relevant to the charity, until and if it actually goes ahead in Victoria Tower Gardens.” I went on: “It would surely be appropriate to mention the project in the Managing risk section, where TRP lists the risks it faces. As you know, there’s a significant probability it will be built.” My final point on the second issue was: “By deliberately omitting the Holocaust Memorial and Learning Centre in their annual report, the trustees fail the reader and could reasonably be perceived as unaccountable, particularly as this is the second year in a row.”
  7. On Mr McLaren‘s response to the third issue, I wrote: “All companies, charitable or not, must act according to their articles of association. That’s a given. The same applies for all charities in relation to their governing document, of course.” I continued: “I‘m concerned TRP isn’t adequately protecting its independence. I refer to the Charity Commission’s guidance for charities with a connection to a non-charity: https://www.gov.uk/guidance/guidance-for-charities-with-a-connection-to-a-non-charity. Please see section three, Operate independently. There the commission says: A charity must be independent of any connected non-charities it works or operates with. It stipulates a charity must be governed by its trustees acting only in the interests of the charity.” I finished: “TRP demonstrated its independence when the charity publicly opposed the latest planning application for the Holocaust Memorial and Learning Centre. Nevertheless the trustees have capitulated to the government (DCMS) [Department for Digital, Culture, Media and Sport] on the matter, thereby undermining TRP’s independence and credibility.”
  8. I invited Mr McLaren to comment. He replied: “… You of course are free to question the editorial decisions of our annual report but [sic] is wholly inaccurate to suggest that this organisation has failed to act within its charitable objects.”
  9. By reply, I said in an email: “I didn’t envisage sending another message, but I must request clarification of the following statement: … but [sic] is wholly inaccurate to suggest that this organisation has failed to act within its charitable objects. Where did I say or suggest that?”
  10. Mr McLaren responded: “I apologise if I have misinterpreted your email but you made several references to the charity’s responsibilities implying that it is failing to live up [sic] these by, you allege, not acting independently. Thank you for clarifying that you are not accusing the charity of failing to uphold its charitable objects.”
  11. Companies House records show the secretary of state for DCMS is sole “person with significant control” of TRP (see 17 June 2019 post). Back then I concluded: “Does meddling by DCMS explain the absence in the annual report? Or were Mr Grossman [Loyd Grossman, chair of TRP] 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.” The second annual report repeats the omission – even after the charity publicly opposed the latest planning application for HMLC.
  12. In November 2019, the government “called in” the planning application for determination at the national level “because of the project’s significant effects beyond the immediate locality”. Meanwhile, in February 2020, Westminster city council rejected the planning application. In response, the government announced a public inquiry, chaired by a planning inspector, into the proposal. The planning inquiry was due to start this month, but has been postponed until October because of coronavirus. The government has reaffirmed its commitment HMLC be built in Victoria Tower Gardens.
  13. TRP is responsible for Victoria Tower Gardens. Yet anyone reading its two annual reports would have no idea of HMLC, let alone the charity’s public opposition to the project. What’s more, TRP failed to provide a satisfactory explanation for the repeated omissions. What really is going on at the “independent” charity?

Staff costs omission in Rio Ferdinand Foundation accounts

  1. The 2015 accounts for charity Rio Ferdinand Foundation (RFF) fully and correctly disclose staff costs at the “staff costs” note in the notes to the financial statements. By contrast, for each of the years 2016-2019, the “staff costs” note fails to report the staff costs. When asked for comment on the omission in the more recent sets of accounts, RFF provided an explanation that failed to withstand scrutiny.
  2. Former England footballer Rio Ferdinand set up his charity in 2012 and registered it at the Charity Commission on 7 March 2013. Mr Ferdinand remains a trustee. RFF provides services for disadvantaged young people In London and Manchester. The charity website says: “Recognising that sports, media and the creative arts are great motivating factors for young people, the Foundation utilises those mediums and Rio’s connections within those industries, to provide a pathway for youth development.”

    Figure 1. Rio Ferdinand Foundation: 2015 accounts

  3. The 2015 accounts fully and correctly disclose staff costs at the “staff costs” note in the notes to the financial statements. There both “wages and salaries” and “social security costs” are reported (screen shot in Figure 1).

    Figure 2. Rio Ferdinand Foundation: 2016 accounts

  4. By contrast, the accounts for each of the other four years all FAIL to fully and correctly disclose staff costs at the “staff costs” note. In each year, there both “wages and salaries” and “social security costs” are NOT reported (screen shots in Figures 2-5).

    Figure 3. Rio Ferdinand Foundation: 2017 accounts

    Figure 4. Rio Ferdinand Foundation: 2018 accounts

    Figure 5. Rio Ferdinand Foundation: 2019 accounts

  5. When asked for comment on the omission in the accounts, 2016-2019, RFF provided a written statement from “our accountants” (it didn’t name them).
  6. They said: “Reporting of charity finances is governed by Charities SORP (FRS 102) – Accounting and Reporting by Charities: Statement of Recommended Practice applicable to charities preparing their accounts in accordance with the Financial Reporting Standard applicable in the UK and Republic of Ireland (FRS 102) (effective 1 January 2015)”.
  7. Here’s that document, Charities SORP (FRS 102) (effective 1 January 2015): frs102_complete.
  8. They referred to module 9 – Disclosure of trustee and staff remuneration, related party and other transactions – in particular, para 9.26 (screen shot in Figure 6).

    Figure 6. Charities SORP (FRS 102) (effective 1 January 2015): para 9.26

  9. Quoting all of para 9.26, the accountants emphasised the words “activity basis”.
  10. They then quoted para 4.6 of the same SORP: “This SORP requires expenditure to be reported on an activity basis to show how the charity has used its resources to further its charitable aims for the public benefit. HOWEVER, CHARITIES BELOW THE CHARITY AUDIT THRESHOLD MAY OPT TO REPORT THEIR CHARITY’S EXPENDITURE IN A DIFFERENT WAY, FOR EXAMPLE BY THE NATURE OF EXPENDITURE RATHER THAN ON AN ACTIVITY BASIS [their emphasis].”
  11. The accountants concluded: “As the Rio Ferdinand Foundation is below the charity audit threshold the charity accounts are not prepared on an activity basis.”
  12. RFF’s explanation fails to withstand scrutiny, as I showed in my emailed response.
  13. I, too, refer to Charities SORP (FRS 102) (effective 1 January 2015).
  14. Para 4.14 states: “All charities must disclose the nature and amount of any material item(s) of income or expenditure when this information is relevant to an understanding of the charity’s financial performance.” Therefore, RFF must disclose staff costs.
  15. Paras 4.22-4.26, which constitute section “Structure of the SoFA – smaller charities below the charity audit threshold”. (“SoFA” is an abbreviation for “statement of financial activities”.) Para 4.25 stipulates: “If a material component of income or expenditure is not presented on the face of the SoFA, the nature and amount of the item must be disclosed in the notes to the accounts.” Therefore, staff costs must be disclosed in the notes to the financial statements.
  16. At the end of my response, I again requested comment. Nothing was received.

The indebted adviser: Metro Bank’s three loans to adviser Rohan Silva’s Second Home

  1. Ex-government adviser Rohan Silva is co-founder of Second Home Limited, a swish workspace company incorporated in the UK on 18 October 2013. It has sites in London, Lisbon and Los Angeles.
  2. Mr Silva enjoys a high media profile, including writing a column for London’s Evening Standard newspaper. By happy chance, the Standard is edited by former chancellor George Osborne, whom Mr Silva worked for as an adviser. The entrepreneur also used to work for prime minister David Cameron.
  3. Metro Bank PLC told me Mr Silva served as an adviser to the high-street challenger bank from 20 April 2016 until 2019, when its advisory board was disbanded.
  4. The “advisory board allows Metro Bank’s executive team unprecedented access to, and advice from, a group of visionary thinkers, industry experts and market disruptors, who are all leaders in their respective fields,” says a press release dated 27 February 2017 on the bank website (screen shot in Figure 1).

    Figure 1. Metro Bank press release dated 27 February 2017: “New appointment to Metro Bank advisory board”

  5. Second Home’s latest accounts, made up to 31 December 2018, were filed several months late at Companies House. Not a good sign. These show the firm has three loans from Metro Bank, one of which it breached covenants for at year-end. “The breach was subsequently waived and the covenants reset post year-end,” reports the workspace company.
  6. Meanwhile, Metro Bank has three corresponding charges against Second Home assets as security for its loans, which are all outstanding, according to Companies House records.
  7. Two of the charges were created on 30 June 2016, with the third on 22 June 2018.
  8. In other words, while Mr Silva was an adviser, Metro Bank lent money to his start-up. Here the Second Home co-founder was clearly conflicted as an adviser. Yet the leading challenger bank was evidently happy with the arrangement.
  9. Metro Bank didn’t pay Mr Silva for his advisory role, according to its spokesperson. Paid or not, the arrangement is problematic because the loans undermine his independence.
  10. When asked for comment on Mr Silva’s alleged conflict of interest as an adviser, the Metro Bank spokesperson said in an email: “The advisory board had no influence in the running of the business, and no influence in any lending decisions.”
  11. The bank’s response begs an obvious question. If it “had no influence in the running of the business”, what was the point of the advisory board? “The advisory board gave Metro Bank access to wider industry expertise and insight,” replied the spokesperson.
  12. Incorporated on 6 November 2007, Metro Bank’s share price stood above £40 two years ago. It’s now languishing around 70p following a series of crises, including an accounting error. Chief executive Craig Donaldson stepped down at the end of last year – two months after the early departure of controversial chair and founder Vernon Hill. In February 2020, the bank reported a huge pre-tax loss of £131m for 2019, in contrast to a profit of £41m the year before.
  13. In 2012, Mr Hill published a management book, “Fans! Not Customers: How to Create Growth Companies in a No Growth World”. The second edition, published in 2016, bears a testimonial from fan AND customer Mr Silva: “I had the opportunity to sit down with Vernon Hill and pick his brains on starting a business. He gave me a copy of his book, ‘Fans! Not Customers’. ‘Read this book,’ he said, and I did. A whole bunch of things we do at Second Home, my company, are taken straight from the book.”
  14. The love runs both ways. Mr Hill raves about Mr Silva and Second Home in the book. The Metro Bank founder uses the workspace company as a case study of what he says is a start-up successfully applying his ideas and philosophy.
  15. A filing on 7 May 2020 by Second Home at Companies House reveals Sam Aldenton, the other co-founder, resigned as a director on 9 March 2020. Sky News reported at the end of 2019 that Mr Aldenton would step down after costs seriously overran at the start-up’s first US site in Los Angeles. The stateside costs overrun forced Second Home in December 2019 to seek new funding from existing shareholders. It raised £9.5m: the fundraising is disclosed under note 26, “subsequent event”, in the notes to the financial statements in the latest (2018) accounts.
  16. Providing loans to adviser Mr Silva’s Second Home raises questions about the governance of Metro Bank. Further, it’s reasonable to call into question the decision-making process the lender followed. Then there’s the public, mutual admiration between Mr Hill and Mr Silva – another reason to look more closely at the loans.
  17. Mr Silva didn’t respond to requests for comment.
  18. There’s no suggestion that anyone has done anything illegal.

Daily Mail reports my exposé of Sam Quek’s gambling tweets – but without credit

  1. It’s gratifying to see the Daily Mail newspaper today (15 May 2020) reporting my exposé of Sam Quek’s gambling tweets (see 12 May 2020 post). Their headline: “BBC urged to sack hockey star Sam for gambling own goal”.
  2. Not so gratifying, though, is the Mail fails to credit me for the story. It doesn’t name The Times, either (see 14 May 2020 post).
  3. Mail business correspondent Tom Witherow wrote the article. Mr Witherow has done much excellent reporting on the excesses of the gambling industry as part of his paper’s admirable “stop the gambling predators” campaign. That’s why I emailed him with the story the day I published.
  4. It’s simply unacceptable not to credit me. Poor show, Daily Mail.
  5. I shall email Mr Witherow for comment, inviting him to post a response below.

The conflicted chair of Portman Group’s “independent” complaints panel

  1. Portman Group (PG) describes itself on its website as the “alcohol social responsibility body and regulator of alcohol marketing in the UK”. Its membership comprises big alcohol companies.
  2. On 6 September 2016, PG’s “independent” complaints panel (ICP) was set up as a separate, not-for-profit entity; full name: The Portman Group Code Of Practice – Independent Complaints Panel. ICP adjudicates on complaints about the marketing and sponsorship of alcoholic drinks in the UK. “The chair appoints the other panel members and panel members must not be employed by the Portman Group or any of its member companies,” says the website. All very sensible.
  3. ICP consists of nine people. Chair is Jenny Watson, a founding director.
  4. Yet Ms Watson’s biography on the ICP section of the PG website (screen shot in Figure 1) omits to reveal a relevant interest: she’s chair, too, of charity The House of St Barnabas (HOSB).

    Figure 1. Jenny Watson: Portman Group website at 3 May 2020

  5. HOSB supports homeless people into employment, by operating a private members’ club in Soho, central London. There the charity runs a structured training programme that leads to jobs in the hospitality industry. As well as its not-for-profit members’ club, HOSB partners with other hospitality employers, who provide work placements across London.
  6. Alcohol is central to HOSB – both its members’ club and training scheme for hospitality workers.
  7. The ICP chair has a conflict of interest, therefore. What’s more, the ICP section of the PG website fails to disclose Ms Watson’s post at HOSB, despite listing other roles.
  8. Ms Watson, a former chair of the Electoral Commission, hasn’t just become involved with HOSB. She became a trustee (director) on 13 March 2018, according to Companies House records.
  9. Established in 1989, PG has been bedevilled by conflicts of interest from the outset. Which is unsurprising: self-regulation is rarely, if ever, sufficient. As the adage says: “self-regulation is no regulation” (see 4 November 2019 post). So the principle of PG’s ICP is to be welcomed. Sadly, ICP is independent in name only.
  10. When asked for comment, a Portman Group spokesperson said in an email: “Jenny Watson CBE has been the Chair of the Independent Complaints Panel since 2014 and is in her final year of office. We have been incredibly fortunate to have a Chair with such a wealth of experience gained in numerous high profile roles including as Chair of the Equal Opportunities Commission and the Electoral Commission.”
  11. They continued: “She was appointed by the Chief Executive of The Portman Group through an open and transparent process consistent with the standards used in making public appointments in accordance with the Nolan principles. The Chair shall be independent of the drinks industry and must not be, or previously have been, directly employed by an alcoholic drinks producer. Any potential conflict of interest would be considered upon appointment. Any subsequent roles and appointments are considered as and when they arise.”
  12. On why Ms Watson’s biography on the PG website fails to disclose her post at HOSB, despite listing other roles: “…the biography on the website is not intended as a comprehensive register of activities. All Panel members, including Jenny as Chair, must declare any interest in a case before considering it and would recuse themselves from any discussion where they are unable to offer an impartial perspective.”

Sam Quek plugs gambling firm on social media, without disclosure of interest – even after upheld complaint to ASA

  1. Olympic hockey gold medallist and BBC sport presenter Sam Quek writes a weekly column in the sports section of the Daily Mirror newspaper. The foot of her column proclaims she’s an “ambassador” for footie5, a weekly game promoted by gambling firm The Pools (The Football Pools Limited). That disclosure only started to appear after I pointed out Ms Quek fronts large ads for footie5 within the Mirror, as well as appear on the company website (see 7 September 2019 and 9 September 2019 posts)! Private Eye magazine reported my exposé (see 19 September 2019 post).
  2. On 23 December 2019, I complained to advertising regulator the Advertising Standards Authority (ASA) because Ms Quek was plugging footie5 on her personal Twitter account, without disclosure of interest.

    Figure 1. Sam Quek: Twitter biography at 23 December 2019

  3. Back then her Twitter biography omitted to reveal her commercial relationship with The Pools (screen shot in Figure 1). The “ambassador” was tweeting profusely about footie5 – but none of her tweets made clear they were ads (screen shot in Figure 2).

    Figure 2. Sam Quek: tweet about footie5 dated 22 December 2019

  4. On 28 January 2020, Duncan Hobbs of the ASA upheld my complaint in an email. There Mr Hobbs said the regulator had contacted both Ms Quek and the gambling company and “provided them with guidance on the rules relating to the disclosure of advertising and what we expect of brands and influencers on social media.”

    Figure 3. Sam Quek: tweet about footie5 dated 7 March 2020

  5. Nevertheless Ms Quek continued to use her personal Twitter account to plug footie5, without disclosure of interest, as her tweet about it on 7 March 2020 shows (screen shot in Figure 3). At the same time there was still nothing about The Pools in her Twitter biography (screen shot in Figure 4). On 9 March 2020, I complained again to the ASA, referring to my first complaint.

    Figure 4. Sam Quek: Twitter biography at 9 March 2020

  6. On 2 April 2020, Bianca Scarpati of the ASA upheld my second complaint in an email. There Ms Scarpati agreed the star’s tweet concerning footie5 dated 7 March 2020 was “misleading as the #ad label is not immediately obvious”. She went on: “We think you have a valid point and we will now instruct them to make changes to their advertising. We have asked them to ensure they change the ad [sic] make it immediately clear the post is marketing communications and to ensure all posts which are ads are clearly marked as an ad. We will get their assurance for these changes.”
  7. The Daily Mirror also publishes problematic ads for gambling companies – problematic because they’re merged with sports editorial and so not clearly distinguishable as ads (see 4 November 2019 post). The Gambling Commission, the gambling regulator, said it would act on the problems with gambling advertising that investigation uncovered. Meanwhile, on 11 March 2018, I examined why gambling advertising is a highly contentious issue (see, too, 21 July 2018 post).
  8. The gambling industry supposedly regulates itself on advertising. The trade body responsible, the Industry Group for Responsible Gambling (IGRG), has demonstrated it has no credibility when dealing with complaints about gambling advertising (see 4 November 2019 post). There’s no point in complaining to IGRG about Ms Quek’s activities with The Pools, therefore.
  9. As I say, Ms Quek works for the BBC, presenting on both TV and radio. As a BBC sport presenter, it’s bad enough she promotes a gambling firm. Worse, the star plugged it on social media, without disclosure of interest – even after my first upheld complaint to the ASA.
  10. Submission of my second upheld complaint coincided with suspension due to the Covid-19 crisis of both professional football and footie5 (the latter depends on football results). Ms Quek seems to have stopped tweeting about footie5 in the lull. When and if she resumes plugging it on the social media platform, let’s hope the star finally does so honestly and transparently. I don’t want to have to make a third complaint to the ASA.
  11. Ms Quek is a client of Activate Management Limited. Her Twitter biography directs enquiries to an email address there. I didn’t receive a response to emailed requests for comment.

DMGT company leader writes Mail On Sunday article, without disclosure of interest

  1. On 10 May 2020, Dr Robert Muir-Wood wrote a full-page article in the Mail On Sunday newspaper, “We’re fighting Covid the same way they fought the plague. But technology is the weapon that will beat it”.
  2. The Daily Mail and General Trust PLC (DMGT) owns the Mail On Sunday, among other papers.
  3. The newspaper says Dr Muir-Wood is chief research officer at Risk Management Solutions (RMS). The company name is printed prominently beneath the scientist’s name at the centre of the page, not at the foot of the article, where such information is usually disclosed more discreetly.
  4. Why was the firm name given such prominence? Perhaps it has something to do with RMS is a DMGT company – a fact both Dr Muir-Wood in his article and the Mail On Sunday omitted to reveal.

Response from Edelman on its work for PCP Capital Partners

  1. On 23 April 2020, I revealed that PCP Capital Partners LLP is a client of political lobbyist Edelman. There I asked the question: is PCP Capital Partners using Edelman to lobby the government over the proposed Saudi-led Newcastle United takeover?
  2. Culture secretary Oliver Dowden recently said the government is unlikely to block the proposed takeover. So whether Amanda Staveley’s PCP Capital Partners has or is lobbying the government via Edelman on the matter is important.
  3. On 30 April 2020, Iain Dey of Edelman said in an email: “Edelman has not lobbied the UK government on behalf of a potential takeover of Newcastle United FC.”
  4. We just have to take his word for it. Nevertheless we do know his company is working for PCP Capital Partners. But doing what exactly?

Gambling Commission shares political lobbyist with law firms acting for gambling companies

  1. The Gambling Commission, the UK gambling regulator set up under the Gambling Act 2005, shares its political lobbyist with four law firms acting for gambling companies.
  2. The commission is a client of political lobbyist MHP Communications, according to the current PRCA Public Affairs Board lobbyist register, dated from 1 December 2019 until 29 February 2020.
  3. So, too, is law firm Knights.

    Figure 1. bet365 is a client of law firm Knights: Knights website at 27 April 2020

  4. Knights is listed on the London Stock Exchange, having joined the AIM market on 29 June 2018. Independent contemporaneous newspaper reports of the listing say gambling firm Paddy Power is a client. Meanwhile, online gambling company bet365 appears on the “A Selection of Our Clients” page of its website (screen shot in Figure 1). Further, Knights boasts a gambling licensing team, which “provides expert assistance… with all aspects of gambling licensing under the Gambling Act 2005” (screen shot in Figure 2).

    Figure 2. Knights gambling licensing team: Knights website at 27 April 2020

  5. Another relevant MHP Communications client is Harney Westwood & Riegels LLP, which trades as Harneys. A global offshore law firm, it advises on British Virgin Islands, Cayman Islands, Cyprus, Luxembourg, Bermuda and Anguilla law. These are all jurisdictions where gambling is important. Also, some of the licensed online gambling firms serving the UK are at least partly based offshore in low-tax jurisdictions. In addition, some UK gambling companies such as bet365 are multinationals. Indeed, Harneys states its Cyprus office recently advised bet365 “on its application for a Class B online betting licence in Cyprus” (screen shot in Figure 3).

    Figure 3. bet365 is a client of law firm Harneys: Harneys website at 27 April 2020

  6. Law firms Slaughter and May, and White & Case are both clients of MHP Communications. Both advise on gambling law in the UK, their websites show.
  7. Besides law firms linked to gambling, MHP Communications also acts for Qatar-based broadcaster beIN MEDIA GROUP, the largest overseas TV rights-holder for the Premier League. Gambling via advertising and sponsorship is key to the top tier of English football and broadcasting thereof to a global audience.
  8. Payment service provider PayPoint PLC is another relevant MHP Communications client. Among its services, PayPoint provides pre-payment cards, which can be used to fund online gambling. One problem with such pre-payment cards is they can facilitate money laundering via online gambling. Therefore, such cards and other payment methods relevant to gambling are within the ambit of the Gambling Commission. Payment service providers must ensure they don’t process transactions for unlicensed gambling operators, for example.
  9. To be an effective regulator, it’s necessary, but not sufficient, for the commission to distance itself from the gambling industry. True, MHP Communications’ clients don’t include gambling companies. Nevertheless they do include several law firms acting for such.
  10. What’s more, these law firms don’t merely have a financial interest in the gambling industry, though that would be bad enough. Their expertise relates to regulation of the sector.
  11. So regulator the Gambling Commission risks undermining its independence and credibility by sharing its political lobbyist this way.
  12. When asked for comment, a spokesperson for the Gambling Commission said in an email: “Following a competitive tender process we appointed MHP Communications in March 2019 to act as an advisor solely on media communications. As part of that process we ensured that there were no conflicts of interest within MHP’s client base or any of the work that they do. Any questions relating to the clients of MHP should be directed to them.”