BuzzFeed re-examines Give Us Time after my investigation

  1. On 29 April 2017, James Ball at BuzzFeed re-examined Give Us Time, a military charity founded in 2012 by Dr Liam Fox MP. This was after my recent investigation (see 20 April 2017 post).
  2. Special Correspondent Ball named and credited me. His report: https://www.buzzfeed.com/jamesball/liam-foxs-military-charity-has-still-helped-just-a-fraction.
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Give Us Time: accounts hide provision of flights for founder Dr Liam Fox MP’s staff

  1. The most recent accounts for Give Us Time, a military charity founded in 2012 by Dr Liam Fox MP, hide in two ways its provision of flights for Dr Fox’s staff. First, the two staff members are included within the charity’s beneficiaries, but there’s no indication in the accounts that Give Us Time considers them as such – or why. Second, the flights represent an undisclosed related party transaction between the charity and Dr Fox, the international trade secretary. Yet there were no related party transactions, according to the accounts.
  2. On 21 March 2016, Brexiteer Dr Fox declared on the register of MPs’ financial interests a visit at the end of the previous month to the Balkan Jewel Resort in Bulgaria as part of a group holiday for military families organised by Give Us Time (registered charity number: 1152978). The cabinet minister was accompanied by two staff members, whose return flights to Bulgaria were paid for by the charity, his declaration shows. The accommodation for all three, meanwhile, was donated by the Balkan Jewel Resort.
  3. The charity has recently returned from another group holiday at the Balkan Jewel Resort (screen shot in Figure 1). Give Us Time “takes holidays donated by owners of holiday groups, hotels, holiday homes and timeshares, and matches them with military families in need of rest, rehabilitation and reconnection after tours of duty,” the “About Us” page on the charity website says.

    Figure 1. Give Us Time tweets about recent group holiday at the Balkan Jewel Resort in Bulgaria at 13 April 2017

  4. Something not on the website: Give Us Time began as a collaboration between Dr Fox and Afghan Heroes (registered charity number: 1132340), the notorious failed military charity (see para 32 in my 6 January 2014 post). Dr Fox was a patron of Afghan Heroes, quitting when regulator the Charity Commission announced in December 2013 that it’d opened a statutory inquiry into the charity. That inquiry continues.
  5. Dr Fox’s staff were with him on last year’s group holiday in Bulgaria as “representatives” of Give Us Time, according to his declaration on the register of MPs’ financial interests.
  6. A few weeks ago, Give Us Time published its latest trustees’ annual report (TAR) and accounts, made up to 30 September 2016. Thus both cover the year Dr Fox and two staff members went on the charity’s Bulgaria group trip. Nevertheless neither record the fact that Give Us Time had paid for flights for Dr Fox’s staff.
  7. When I queried the omission, Rupert Forrest, public contact for Give Us Time, said in an email: “I do not believe it is necessary to break out the two flights in the annual accounts.” In response, I asked him to tell me where exactly the value of the two flights is reported in the itemised breakdown of the costs of charitable activities, in note 7, “Activities undertaken directly,” on p.9 of the latest TAR and accounts (screen shot in Figure 2). That is, under which item?

    Figure 2. Note 7, “Activities undertaken directly,” Give Us Time accounts made up to 30 September 2016

  8. The flights, he replied, were part of a group booking, which in turn is included within “Travel and accommodation expenses for beneficiaries.” Thus Dr Fox’s two staff members are classified as beneficiaries, but there’s no indication in the accounts that Give Us Time considers them as such – or why.
  9. The other way in which the charity’s provision of flights for Dr Fox’s staff is hidden is via an undisclosed related party transaction. Yet there were no related party transactions, according to the accounts: see note 12, “Related party transactions,” p.10 of the latest TAR and accounts (screen shot in Figure 3).

    Figure 3. Note 12, “Related party transactions,” Give Us Time accounts made up to 30 September 2016

  10. How did Give Us Time engage in an undisclosed related party transaction? Founder Dr Fox is a related party because he “has significant influence over the reporting entity” (see International Accounting Standard 24 Related Party Disclosures (IAS 24): http://www.iasplus.com/en-gb/standards/ias/ias24). Thus Dr Fox’s receipt, in his name, from Give us Time of return flights to Bulgaria for two staff members is a related party transaction – an undisclosed related party transaction.
  11. When I requested a comment on the undisclosed related party transaction, Mr Forrest said in a one-sentence email: “Give Us Time’s accounts have been prepared in accordance with the Charities SORP.” (The Charity Commission and the Office of the Scottish Charity Regulator issue the Statement of Recommended Practice (SORP) for charities, guidance on their financial accounting and reporting: http://www.charitysorp.org.)
  12. Give Us Time’s response on the undisclosed related party transaction is clearly inadequate because it fails to explain the charity’s statement in the accounts that there were no related party transactions.
  13. The trustees are collectively responsible for Give Us Time’s actions, including its financial reporting. Founder Dr Fox isn’t a trustee, and so can’t be held directly accountable for the unacceptable lack of disclosure in the latest accounts related to his involvement with the charity.
  14. What’s worse, before preparing the most recent accounts, Give Us Time knew that there had been legitimate media interest in the return flights to Bulgaria for Dr Fox’s staff following his declaration: see the BuzzFeed News investigation into the charity, published on 31 July 2016: https://www.buzzfeed.com/jamesball/liam-fox-faces-questions-over-charity-he-set-up-to-help-mili.
  15. Give Us Time’s intended beneficiaries are “military families in need.” The actual beneficiaries, however, include Dr Fox’s two staff members – something hidden in the accounts.

The Forgotten Heroes: charity with Ed Miliband and other MPs as patrons spends none of income on charitable activities twice – and only a tiny proportion once

  1. A military charity with Ed Miliband and other MPs as patrons has to date spent only a tiny proportion of its income on charitable activities. Astonishingly, nothing was spent on charitable activities for two years – financial years ending 30 April 2012 and 30 April 2014. While the intervening year wasn’t much better: just 3.1% of the £31 957 income, £1000, went on charitable activities. What’s more, the most recent annual accounts, for financial year ending 30 April 2014, were “qualified” – and for a worrying reason. The chairman, also public contact, has at date of publication failed to provide a satisfactory explanation for the shameful record of spending – or not spending – on charitable activities. The fourth annual accounts are at date of publication overdue at the Charity Commission, itself a sign of a badly-run charity. In fact, The Forgotten Heroes failed to file its accounts on time twice in the previous three years. Two of three MP patrons replied to my enquiries – but neither was willing to account for the consistent underspending on charitable activities. Patron Ed Miliband MP, former Labour leader, didn’t reply to my emails. Nor did patrons The Proclaimers, the Scottish band.
  2. Leeds-based charity The Forgotten Heroes (registered charity number: 1140819) was set up in 2011 by Adam Douglas, an injured Iraq War veteran. Its mission is “to provide the very best support and advice to the carers and families of wounded servicemen and women”, says the website: www.theforgottenheroes.org.uk. The charity isn’t a member of the official umbrella organisation for military charities, the Confederation of Service Charities (Cobseo).
  3. The Forgotten Heroes has impressive and serious patrons, including several MPs from different parties; and, somewhat incongruously, The Proclaimers, the Scottish band.
  4. Yet the charity has to date spent only a tiny proportion of its income on charitable activities. Astonishingly, nothing was spent on charitable activities for two years – financial years ending 30 April 2012 and 30 April 2014. While the intervening year wasn’t much better: just 3.1% of the £31 957 income, £1000, went on charitable activities.
  5. What’s more, the most recent annual accounts, for financial year ending 30 April 2014, were “qualified” – and for a worrying reason. Qualified accounts are accounts questioned by an independent assessor. Here the independent examiner’s qualified statement is serious: “The trustees have prepared accounts which report income of £26 665 and expenditure of £21 900. However, limited records are available to support the transactions within the charity’s bank account upon which these accounts are based. The absence of accounting records follows a change in the composition of the board of trustees with the new board unable to locate the records maintained by the previous treasurer.” Clearly, the reason for the qualification raises serious questions about the charity and its management, financial and otherwise.
  6. The chairman, also public contact, has at date of publication failed to provide a satisfactory explanation for the shameful record of spending – or not spending – on charitable activities. On 9 March 2016, David Sessions told me in an evasive email: “I can confirm that since I have taken over as chairman of the charity we have given away money to beneficiaries.” Well, yes, but the amount spent on charitable activities is pitiful, according to the three years of accounts filed at the Charity Commission. And Mr Sessions hasn’t just become chairman either. While the first year’s accounts show Mr Douglas as chairman, those for the second and third years list Mr Sessions in the role.
  7. In the same email, Mr Sessions added that the charity was “moving offices at the moment”, but hed send “a factual and considered response… as soon as possible.At date of publication I’ve received nothing.
  8. Perhaps the charitable spending will improve in the fourth annual accounts. These are at date of publication overdue at the Charity Commission, itself a sign of a badly-run charity. In fact, The Forgotten Heroes failed to file its accounts on time twice in the previous three years.
  9. Two of three MP patrons replied to my enquiries – but neither was willing to account for the consistent underspending on charitable activities. Both directed me to the trustees. The two are local MPs Greg Mulholland (Liberal Democrats) and Stuart Andrew (Conservatives). The latter is billed as “Stuart Andrews” [sic] on the charity website (screen shot in Figure 1). If they can’t get the name right…
    Figure 1. Patron “Stuart Andrews” [sic] MP at 29 March 2016

    Figure 1. Patron “Stuart Andrews” [sic] MP at 29 March 2016

  10. Former Labour leader Ed Miliband MP, though, didn’t reply to my emails. The then party leader became a patron in November 2013, according to a report in the Yorkshire Evening Post newspaper. The Proclaimers, too, were unresponsive.
  11. The Forgotten Heroes confirms my earlier observation that an MP patron is no guarantee a charity spends a reasonable proportion of its income on charitable activities. My first experience was with failed military charity Afghan Heroes, whose patrons included former defence secretary Dr Liam Fox MP (see my 6 January 2014 post). I encountered it again with Our Local Heroes Foundation, another military charity with excessive fundraising costs. There Ben Wallace MP, ex-military himself, was a patron – until apparently last summer when I noticed he’d disappeared from the charity website, without explanation, whereupon he also became unresponsive (see my 17 December 2015 post).
  12. The public reasonably expect that patrons, MPs especially, have conducted due diligence on a charity they endorse and are involved with. Yet the consistent underspending on charitable activities calls into question the judgement of the patrons of The Forgotten Heroes. The ridiculously low level of charitable expenditure is indefensible. And here again we observe patrons of a charity avoiding accountability – that’s if they even reply to emails.

The disappearing Mr Wallace

  1. On 30 June 2015, I noticed that the military charity Our Local Heroes Foundation had again redesigned its website. There was an important omission, though: patron Ben Wallace MP had disappeared. I couldn’t see his name or photo on the section of the homepage then listing patrons. There were now two patrons. Yet Mr Wallace’s website (www.benwallacemp.com) had nothing to indicate a change in his relationship with the charity.
  2. As a patron, the MP for Wyre and Preston North has defended the charity and its fundraising activities with Prize Promotions Limited of Blackpool to both me and others, including BBC Radio 5 live (see para 11 in my 26 December 2014 post).
  3. As an MP, Mr Wallace lends credibility to Our Local Heroes Foundation. Further, he’s been a minister since May 2015 – Under Secretary of State for Northern Ireland. His endorsement is worth even more because he himself is ex-military. People will assume that the charity is credible as Mr Wallace will surely have done due diligence. But former Defence Secretary Dr Liam Fox MP was a patron of failed military charity Afghan Heroes (as was comedian Bobby Ball). Talking of Afghan Heroes, it too worked with the discredited professional fundraiser, Prize Promotions Limited.
  4. On 30 June 2015, I emailed Mr Wallace at parliament to ask whether his vanishing from the Our Local Heroes Foundation website meant he was no longer a patron. If so, as of when? No response.
  5. Two weeks later, I sent a reminder because he still wasn’t listed as a patron on the charity homepage at 14 July 2015. Again, no response.
  6. Nine weeks after my first message I emailed Mr Wallace a final time 1 September 2015 seeking a response to my 30 June 2015 message. Still nothing.
  7. The unresponsiveness of Mr Wallace is unacceptable, especially because he was responsive previously. Trustees of charities must be accountable; but so should patrons (see my 13 August 2015 post). I’ve discovered celebrity patrons unwilling to answer legitimate questions about involvement with a charity: trusted TV presenter Valerie Singleton, for example (see my 16 July 2014 post). Mr Wallace isn’t a celebrity. It is reasonable to expect an MP – let alone minister – to be accountable.

Our Local Heroes Foundation: Why are you a patron of a charity that works with Prize Promotions Limited?

  1. Ben Wallace, the MP for Wyre & Preston North (http://www.benwallacemp.com), is a patron of military charity Our Local Heroes Foundation. On 4 April 2014, I wrote to him (email) with my concerns about the charity due to its use of professional fundraiser Prize Promotions Limited. Having heard nothing, I sent a reminder three weeks later, 25 April 2014.
  2. On 20 May 2014, I received a reply from his office. Zoe Dommett, Senior Parliamentary Assistant and Office Manager, wrote: “I am writing on Ben Wallace’s behalf in response to your enquiry regarding his role as a Patron of Our Local Heroes Foundation. You should be aware that as a Patron, Mr Wallace is not involved in the day to day management of the charity. He has investigated the issues you raise about the charity’s decision to use a professional fundraising company. While, of course, we would all prefer to have dozens of fundraising volunteers, the use of a fundraising company is common practice amongst charities, large and small. The important thing is whether the charity itself is doing what it sets out to do. Mr Wallace will continue to monitor the performance of Our Local Heroes Foundation. However, to date the only issue you identify is that you are suspicious of the fundraising company, rather than the charity. Mr Wallace is a Patron of the latter, but has nothing to do with the former. Thank you for taking the time to contact Mr Wallace.”
  3. As an MP, Mr Wallace lends credibility to the charity. His endorsement is worth even more because he himself is ex-military. People will assume that Our Local Heroes Foundation is credible as Mr Wallace will surely have done due diligence. But former Defence Secretary Dr Liam Fox MP was a patron of Afghan Heroes (as was comedian Bobby Ball).
  4. On 17 December 2013, regulator the Charity Commission announced that it’d opened a “statutory inquiry” into Afghan Heroes. Statutory inquiries are the regulator’s most serious type of engagement with charities. On 5 February 2014, the Charity Commission stated publicly that it’d appointed an “interim manager” to Afghan Heroes.
  5. Contrary to Mr Wallace’s response, I don’t have concerns about use of a professional fundraiser per se: it’s the company that Our Local Heroes Foundation works with and how they work together. Prize Promotions Limited was the official professional fundraiser for Afghan Heroes.
  6. In January 2014, I exposed two schemes Prize Promotions Limited was using last year to raise funds for Afghan Heroes from the public illegally in Greater Manchester: one in shopping centres, the other on the street. (https://dralexmay.wordpress.com/2014/01/06/the-fundraiser-the-comedian-and-the-ex-cabinet-minister-the-tale-of-a-military-charity/)
  7. Prize Promotions Limited represents Our Local Heroes Foundation in public. In people’s eyes, the fundraising company’s staff are the charity’s staff. Indeed, the Prize Promotions Limited workers wear Our Local Heroes Foundation branded clothing. For any charity, the decision to work with a particular professional fundraiser is therefore an important one, as the Charity Commission says. (http://www.charitycommission.gov.uk/running-a-charity/fundraising/working-with-companies-and-professional-fundraisers/)
  8. But another reason why I am seriously concerned about the charity is how exactly it works with Prize Promotions Limited. (https://dralexmay.wordpress.com/2014/05/27/our-local-heroes-foundation-only-20-of-the-ticket-price-goes-to-the-charity-but-you-wouldnt-know-from-the-tickets-or-website/) Our Local Heroes Foundation permits unreasonable fundraising costs, with 80% retained by the professional fundraiser. Military charities have one of the most popular causes, so we would expect Our Local Heroes Foundation to raise funds much more efficiently. Both the high profile and size of Help for Heroes (registered charity number: 1120920) attest to the public’s sympathy for the plight of wounded soldiers. Indeed, Help for Heroes is so well-known and its cause so popular that most reported frauds relating to military charities derive from “charities” with names similar to Help for Heroes, says the police. (http://www.independent.co.uk/news/uk/crime/charity-fraudsters-use-help-for-heroes-popularityto-help-themselves-9242465.html) [This report appeared in the print Independent 7 April 2014 as “Charity fraudsters use Heroes’ popularity to help themselves”.]
  9. Not only does Our Local Heroes Foundation permit unreasonable fundraising costs. But also it allows inadequate disclosure of fundraising costs to both actual and potential donors. The £2.50 “prize draw” tickets sold in its name don’t say how much of the ticket price goes to the charity. It is wrong to conceal the fact that the proportion is just 20%. Further, the ticket sellers in the charity branded clothing are unable on request to provide printed information with the answer.
  10. Although ticket-holders are referred to http://www.ourlocalheroes.org.uk for “winners, donations and merchandise”, the Our Local Heroes Foundation website fails to disclose the proportion too. There the lack of disclosure persists, despite me bringing it to the charity’s attention in an email 14 May 2014.
  11. Our Local Heroes Foundation acts against the public interest by approving unreasonable fundraising costs of 80%, especially for such a popular cause. The charity also acts against the public interest by permitting Prize Promotions Limited to raise funds on its behalf without disclosure of fundraising costs. The £2.50 “prize draw” tickets sold in the name of Our Local Heroes Foundation are highly misleading. For these and other reasons, it is clear that the charity deserves scrutiny for its fundraising activities. I don’t understand why patron Mr Wallace disagrees.

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”.