Cover-up undermines credibility of GambleAware

  1. Here I describe a cover-up by GambleAware, the leading gambling charity, that undermines its credibility.
  2. GambleAware, formerly called the Responsible Gambling Trust (registered charity number: 1093910), is a national charity “committed to minimising gambling-related harm.” It does this by funding research, education and treatment services. Funded itself by donations from the gambling industry, the self-styled independent charity works closely with the industry – too closely for critics. I first wrote about GambleAware on 27 February 2017, identifying four main problems with the charity. Here’s another: it recently instituted a cover-up.
  3. On 28 March 2017, GambleAware published a news item on its website, entitled “Evaluation of MOSES” (screen shot in Figure 1). MOSES is the Multi Operator Self Exclusion Scheme for betting shops, a national scheme run by Multi Operator Self Exclusion Scheme Ltd (registered company number: 10269436). The company in turn is a wholly-owned but self-styled stand-alone subsidiary of the Senet Group (registered company number: 09310491).

    Figure 1. GambleAware news page at 30 March 2017

  4. Anyone wanting to control his or her high-street gambling can, with a single phone call to MOSES, register an initial wish to self-exclude from a self-selected group of betting shops, regardless of operator (self-exclusion.co.uk). A photo is required, which is shared with the relevant operators “to help staff recognise someone who has self-excluded and intervene if he or she breaches that undertaking.”
  5. The Senet Group is “an independent body set up to promote responsible gambling standards and ensure that the marketing of gambling is socially responsible,” says its website. Membership is open to “any gambling operator, and any associated organisation.” On 28 March 2017, the Senet Group, too, announced the MOSES evaluation on its website (screen shot in Figure 2). Its news item linked to the press release on the GambleAware website.

    Figure 2. Senet Group news page at 30 March 2017

  6. The GambleAware press release states that the charity had commissioned the evaluation of MOSES. The evaluation was carried out by company Chrysalis Research UK Limited (registered company number: 07375791). I didn’t understand why the original version of the Chrysalis Research report the charity published didn’t refer to GambleAware at all, astonishingly.
  7. On 29 March 2017, I therefore emailed the report’s author, Louise Duffy, seeking an explanation for the omission of GambleAware in her report. She’s a director of the research company. Having heard nothing, I sent a reminder a week later. This time Ms Duffy replied, on 6 April 2017, saying only: “Apologies for the delay. The published report does now have the acknowledgement in it and is attached here for your information.”
  8. The next day I pointed out in an email that she hadn’t explained, though, why the original version of the report didn’t refer to GambleAware at all. On 10 April 2017, Ms Duffy wrote: “It was an oversight on our part and we should have included that it was commissioned by GambleAware, hence the amendment made.”
  9. I wanted to be clear: did GambleAware really commission the evaluation, as stated in the accompanying press release? A related question is: what exactly is the relationship between the charity and the Senet Group anyway? I shall explain why the relationship is so important in a later post.
  10. The original version of the report was dated 23 March 2017 on the front cover. The file creation date in the file metadata as well is 23 March 2017 (screen shot in Figure 3). Here’s the original version, downloaded from the GambleAware website on 29 March 2017: jn175-moses-evaluation-final-report-230317.

    Figure 3. Original version of report: PDF document properties

  11. The revised version, though, remains dated 23 March 2017 on the front cover, which is misleading and dishonest, or could be perceived as such. The file creation date in the file metadata, meanwhile, is now later – 30 March 2017 (screen shot in Figure 4). Here’s the revised version, downloaded from the GambleAware website on 7 April 2017: jn175-moses-evaluation-report-final-report-230317.

    Figure 4. Revised version of report: PDF document properties

  12. At date of publication the report linked to on the charity website is the revised version I downloaded on 7 April 2017.
  13. There’s no record in the revised version that it’s actually been revised, which again is misleading and dishonest, or could be perceived as such. Similarly, it’s misleading and dishonest, or could be perceived as such, that the revised version fails to explain the reason for the changes.
  14. What’s worse, GambleAware simply swapped the files in the news item dated 28 March 2017 – again misleading and dishonest, or could be perceived as such. Thus the charity hid the change of files (screen shot in Figure 5).

    Figure 5. GambleAware news page at 7 April 2017

  15. I asked Iain Corby at GambleAware in an email why the charity had failed to document on its website the fact that it’d swapped the files – and when. Also, the reason for doing so. Accuracy and transparency, I added, are essential for public trust and confidence in GambleAware and its work. Mr Corby, now deputy chief exec, simply said in his response: the “researcher corrected a minor error.” He said nothing about the charity hiding the change of files. Mr Corby also told me he wasn’t prepared to answer any further queries from me. (I’d explicitly acknowledged him in my 27 February 2017 post for being responsive and willing to engage in discussion. I also phoned then to thank him verbally.)
  16. ADDENDUM: On the subject of self-exclusion, a GambleAware trustee has seemingly failed to declare a relevant interest on the online trustee register of interests. I refer to Clive Hawkswood (screen shot in Figure 6), who is sole director of company The National Online Self Exclusion Scheme Limited (NOSES; registered company number: 10504973), too, according to Companies House records. The company is creating and will operate NOSES, an equivalent self-exclusion scheme for online gambling.

    Figure 6. Trustee Clive Hawkswood’s declared interests at 30 March 2017

  17. On this point Mr Corby said in his email: “Clive Hawkswood’s interest with the RGA [Remote Gambling Association], which is developing NOSES, is already registered.” True, but Mr Hawkswood is sole director of The National Online Self Exclusion Scheme Limited: his role at the company should surely be declared for full disclosure.
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Company donation to Mark Spencer MP requires explanation

  1. On 13 April 2017, Mark Spencer, Conservative MP for Sherwood and an Assistant Government Whip, declared a cash donation of £2.15k on the register of MPs’ financial interests. It came from SJ Ankh Ltd, a local company; but the registered company number that Mr Spencer stated fails to match that on the Companies House register. The mismatch between company name and number requires explanation. Further, while £2.15k may not be a huge amount, here I show that Mr Spencer’s declaration on the register means we’re talking telephone numbers.
  2. Farmer Mr Spencer, who was first elected MP for Sherwood in May 2010, listed 9654867 as company number. Yet the registered company number of SJ Ankh Ltd is 10525122, according to Companies House records. While 9654867 is the company number of Bedfordshire Land Promotions Ltd.
  3. There’s something else about number 9654867, though. It’s the phone number for Sherwood Conservative Association (without prefix 0115, area code for Nottingham).
  4. Samuel (“Sam”) Ancliff is sole director of SJ Ankh Ltd, which is a new company. He’s “deputy chairman (membership)” of Ashfield and Mansfield Conservatives, too, says his Twitter biography (screen shot in Figure 1). On 4 May 2017, Mr Ancliff stood unsuccessfully in the local elections, as Conservative candidate for county councillor in Kirkby North, Nottinghamshire County Council. He came second, behind Labour’s John Knight.

    Figure 1. Sam Ancliff on Twitter at 9 May 2017

  5. Mr Spencer, who is Conservative candidate for Sherwood in the current general election, didn’t respond to requests for comment (emails). Neither did Sherwood Conservatives. Where’s the “strong and stable leadership”?
  6. Mr Ancliff, however, said in an email: “Besides that it is a [sic] clearly a simple admin error on someone’s part, I have nothing further to contribute to your blog.” Well, if so, who exactly made “a simple admin error,” and where?

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.

Why won’t Tim Farron explain the donation he declared from a dormant company just prior to dissolution without filing overdue accounts?

  1. On 4 April 2016, Lib Dem leader Tim Farron MP declared a cash donation of £2k on the register of MPs’ financial interests. It came from BTP Advisers International Ltd (registered company number: 08522892). The Lib Dems in his constituency, Westmorland and Lonsdale, accepted the donation from the company on 31 March 2016, according to the Electoral Commission online database.
  2. BTP Advisers International Ltd was dissolved on 19 July 2016, after filing one set of accounts only – for a dormant company – made up to 31 May 2014, Companies House records show. It was incorporated on 9 May 2013 by its two directors, Sandra Lawman and Mark Pursey.
  3. Both have been politically active with the Lib Dems, and for a long time. On 6 March 2017, Mr Pursey said in an email that he was a party member, and had been “for the last 27 years.” He added: “I have no involvement in the party today beyond being a member and supporter. However, in the past, I have served as a local Lib Dem councillor, worked for the party, and volunteered to help on many of its campaigns.” Meanwhile, Ms Lawman’s profile on the website of Dudley Miles Company Services Limited (registered company number: 03208062), a company where she’s now a director, lists various roles as a Lib Dem activist (screen shot in Figure 1).

    Figure 1. Sandra Lawman profile on Dudley Miles Company Services Limited website at 27 April 2017

  4. Mr Pursey campaigned as a Lib Dem for the UK to leave the EU – he was a member of the Liberal Leave team, as its homepage at 20 June 2016 shows: https://web-beta.archive.org/web/20160620223359/liberalleave.org.
  5. Political donations above £2k must be disclosed by a company in the directors’ report within the annual report. This donation, of course, falls just under. Yet dormant BTP Advisers International Ltd didn’t even file its overdue second accounts, made up to 31 May 2015. It was then dissolved, of course, on 19 July 2016. How could a dormant company donate £2k to the Lib Dem leader?
  6. So I asked Ms Lawman and Mr Pursey in an email three questions about their company and the donation. On 6 March 2017, Mr Pursey told me in an email that the donation didn’t come from BTP Advisers International Ltd. Rather, it came from BTP Advisers Limited (registered company number: 07455523). That, he told me, “is an active company, and always has been.” Mr Pursey also asked where the donation was shown as from BTP Advisers International Ltd, despite the fact I’d explicitly referred to the register of MPs’ financial interests. I pointed again to Mr Farron’s entry there, providing the link; whereupon he replied in an email the same day: “Well then that’s wrong. I am [sic] no idea why that is what is down. I’ll ask them to change it.”
  7. Ms Lawman at Dudley Miles Company Services Limited didn’t respond to the original email.
  8. What does BTP Advisers Limited do? It’s a “multi-award winning communications agency working across international media relations, crisis management, political campaigns and legal disputes,” says the Twitter biography (@btpadvisers). Mr Pursey is founder and managing partner.
  9. Not everyone is a fan, however. In December 2011, for example, the Bureau of Investigative Journalism revealed that Mr Pursey had boasted to an undercover reporter of BTP Advisers Limited’s PR work for the Rwandan government, including its creation of an internet “attack site” to counter accusations that the government had been involved in genocide: https://www.thebureauinvestigates.com/stories/2011-12-06/pr-firm-attacked-critics-of-rwandan-government. There the Bureau also reported his claim the company was working for the controversial government of Azerbaijan.
  10. In March 2013, meanwhile, The Sunday Times newspaper exposed BTP Advisers Limited’s role in the Kenyan presidential election, in particular orchestrating an alleged “dirty tricks” campaign against British diplomats, on behalf of eventual winner Uhuru Kenyatta: https://www.thetimes.co.uk/article/lib-dem-defeats-our-man-in-kenya-830n0rs5vj5.
  11. On 21 April 2016, the Guido Fawkes website criticised Mr Farron for accepting the £2k donation from what it identifies as BTP Advisers because of the company’s PR work for “some of the most authoritarian regimes in the world”: https://order-order.com/2016/04/21/farron-bankrolled-by-disgraced-rwanda-spinners/. Guido Fawkes said nothing, though, about the actual company on the official record for the donation, BTP Advisers International Ltd.
  12. There’s no suggestion that anyone has done anything illegal.
  13. On 7 March 2017, I emailed Mr Farron at parliament seeking an explanation for the discrepancy between his declaration on the register of MPs’ financial interests and what Mr Pursey had told me in emails the day before. Having heard nothing, I sent a reminder a week later. This time his office (no name disclosed) acknowledged receipt, on 17 March 2017, adding: “We are making enquiries and will come back to you in due course.” Again, nothing. So I sent a third email on 19 April 2017. At date of publication I haven’t had a response.
  14. Mr Farron’s declaration is unchanged on the latest register of MPs’ financial interests (that is, at 10 April 2017). Similarly, at date of publication BTP Advisers International Ltd remains as donor on the Electoral Commission online database.

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.

GambleAware: The problems with the charity for problem gambling that undermine its independence and credibility

  1. Here I show that GambleAware, the leading gambling charity, isn’t nearly transparent enough – despite being one of the most transparent charities. The fat-cat pay of the new chair – her salary is nearly 70 per cent higher than the figure in last year’s job ad – and her failure to disclose in full personal interests, too, risk damaging the charity’s reputation. The role of Atlas Communications Partners Ltd (trading name: Atlas Partners) is a serious concern. The firm handles media enquiries for GambleAware. Yet the charity also uses Atlas Partners as a political lobbyist, the latest statutory Register of Consultant Lobbyists reveals. The charity website fails to disclose the firm’s function as political lobbyist. Given how close GambleAware is to the gambling industry, there’s an urgent need for the charity to prove that it isn’t actually lobbying for the industry. Finally, the composition of the board contravenes GambleAware’s stated policy on the proportion of trustees from the gambling industry.
  2. GambleAware, formerly called the Responsible Gambling Trust (registered charity number: 1093910), is a national charity “committed to minimising gambling-related harm.” It does this by funding research, education and treatment services. Funded itself by donations from the gambling industry, the self-styled independent charity works closely with the industry – too closely for critics. In a move to bolster independence and credibility, GambleAware appointed an independent chair, Kate Lampard, in June 2016. Unlike predecessor Neil Goulden, Ms Lampard has no known links with the gambling industry. Last November the charity published its new five-year strategy, which aims, among other things, to treble the number of people treated each year who suffer from gambling-related harm.
  3. There’s a glaring omission in the new strategy: the fundraising chapter, 6, fails to mention donation of services. It covers donation of money only. We know, though, that GambleAware receives donated services, according to the latest accounts, for financial year ending 31 March 2016 (and in previous years). More about the inadequate financial reporting of the donated services in a moment. But first I must explain why the omission in the new strategy is such a concern.
  4. Donation of services is fundamentally different from donation of money, conceptually and operationally. For any charity, both have their own advantages and disadvantages. GambleAware openly and readily acknowledges that it needs to counter the perception that it’s too close to the gambling industry. But a company donating services is necessarily nearer to the charity than a simple money donor, which is more removed. Clearly, GambleAware needs to be particularly careful about what companies it accepts donated services from and how, if it’s to uphold its independence and credibility.
  5. So what companies did the charity receive donated services from, according to the latest accounts? Unfortunately, the reader isn’t told; but there’s an itemised breakdown of the three gifts in kind: boardroom hire £11 000; exhibition space £5 000; and software £558. To its credit, GambleAware promptly identifed the three companies on request. Law firm Gordon Dadds LLP made its boardroom available for the regular meetings of the board of trustees, while events company Clarion Events Ltd gave the charity a free stand at the ICE exhibition, an event for the gambling industry. But working with both organisations in this way raises serious questions about the charity’s independence and credibility.
  6. Betting and gaming is a speciality of Gordon Dadds, as its website makes clear. There it trumpets its “involvement in the ongoing modernisation of the UK’s gambling laws,” which “means we have unrivalled knowledge of the latest developments…” (http://www.gordondadds.com/service/gaming-betting/) By accepting the gift in kind from lawyers for the gambling industry, GambleAware risks undermining its independence and credibility.
  7. It’s a shame, too, that the latest accounts don’t disclose Gordon Dadds as source. The lack of transparency invites suspicion: is the charity trying to hide the role of the law firm?
  8. On gaming, Clarion Events isn’t only responsible for the ICE Totally Gaming event, as its website makes clear. There it proclaims: “Clarion Events occupies a unique position in the [gaming] sector, providing the full range of services to the entire spectrum of the global industry including exhibitions, conferences, technical training, research and digital information.” (http://clarionevents.com/sectors/gaming/) So again, by accepting the gift in kind from an events company so involved with the gaming industry, GambleAware risks undermining its independence and credibility.
  9. And again, the failure in the latest accounts to disclose Clarion Events as source is disappointing.
  10. In another revealing omission, the list of supporters on the charity website shows donors of money only: neither Gordon Dadds nor Clarion Events appear in the 2015-16 list (Figures 1-2). Iain Corby, Director of Operations and Development at GambleAware, agreed in an email that donors of services, too, should appear in the list. He added: “I will raise this with our fundraising director as a suggestion.”
    Figure 1. GambleAware 2015-16 supporters: no Gordon Dadds LLP at 27 January 2017

    Figure 1. GambleAware 2015-16 supporters: no Gordon Dadds LLP at 27 January 2017

    Figure 2. GambleAware 2015-16 supporters: no Clarion Events Ltd at 27 January 2017

    Figure 2. GambleAware 2015-16 supporters: no Clarion Events Ltd at 27 January 2017

  11. Though GambleAware defended its failure to consider donation of services in the new strategy: the “vast majority” of donations are of money, said Mr Corby, “donations in kind are not at all material at present so did not merit mention in our strategy.” Nevertheless covert, back-room arrangements don’t engender trust and confidence. The charity simply can’t afford to be perceived as being too close in any way to the gambling industry. GambleAware should therefore surely be open and transparent about BOTH fundraising routes.
  12. But it isn’t just the new strategy that’s deficient in this way. The donation form on the website is for donation of money only. And there isn’t a separate form for donation of services. Again, the charity’s reputation can only be enhanced by making the process to donate services clear and transparent. Hiding the process, whatever it actually is, only invites suspicion.
  13. The presentation of the donated money in the latest accounts, too, is inadequate. There isn’t an itemised breakdown this time: the reader is unable to see which company has given what. This inadequate disclosure is even worse in light of Ms Lampard’s recent interview in the FT newspaper, headline: Gambling companies ‘taking the mickey’, says charity chief”: https://www.ft.com/content/9f6440fe-9b93-11e6-8f9b-70e3cabccfae. (Published in the print edition: 29 October 2016.) There the new chair lambasted unidentified companies for failing to give as much as the charity believes they should. Well, we just have to take her word for it. Here the list of supporters on the website doesn’t help either, as donation size isn’t disclosed. I don’t understand why the donation form doesn’t ask for permission to publish donation size. The data should surely be public. Why is the charity acting against the public interest by failing to publish the donation sizes?
  14. In response, Mr Corby said in an email: “it would be exceptional for a charity to publish the amount of individual donations.” Yet GambleAware does already – for donated services, as money equivalents (see para 5). The charity’s case for more support from the gambling industry would be more convincing if the data were public: that way anyone could see the donation sizes for themselves. Also, this transparency would bolster the charity’s independence and credibility.
  15. Something else to notice in the FT report: there Jim Mullen, chief executive of bookmaker Ladbrokes, rejected claims that the fixed odds betting terminals in high street betting shops are dangerous or addictive. He was responding to concerns about the notorious machines raised in part by Ms Lampard in the interview. Since then Mr Mullen has become a trustee of GambleAware! His appointment to the board in January is only the latest manifestation of the close ties between the gambling industry and the charity.
  16. Then there’s the fact that Ms Lampard is paid in her role – a lot. Remember: most charity trustees are volunteers. She works six days a month as chair of trustees, Mr Corby told me in an email. In January 2016, the post was advertised in The Sunday Times newspaper with a salary of c. £30 000 pa for this number of days a month: http://appointments.thesundaytimes.co.uk/job/449842/chair/. Yet Ms Lampard receives nearly 70 per cent more – £50 000 pa. Her fat-cat salary is revealed in the minutes of the board of trustees’ meeting that took place on 5 May 2016. (GambleAware publishes board minutes on its website.) £50 000 pa for six days a month is equivalent to £183 333 pa full-time, if the average number of working days in a month is 22. The full-time figure is well above £150 000, then, the government threshold forhigh earners” in the public sector; the Cabinet Office names all such individuals.
  17. On Ms Lampard’s high pay, Mr Corby said in an email: “Trustees received advice that the likely market rate for the appropriate candidate would be in a range of £30 000 to £50 000 for up to six days a month. During the recruitment process, it became clear that it would be necessary to pay up to £50 000 to attract the skills, experience and public reputation required. The Charity Commission were asked for and gave its permission for the payment of a trustee to act as chair in full knowledge of the amount involved.” Still, Ms Lampard is paid proportionately more than the prime minister – and most charity trustees are unpaid.
  18. GambleAware commendably publishes a trustee register of interests on its website. In further good practice, the charity asks trustees to declare “their interests in general (not only those with a potential for a conflict of interest).” And each trustee must also declare the interests of “close relative/household members.” So it’s disappointing that Ms Lampard fails to disclose in full personal interests. She’s declared “none” for the interests of “close relative/household members” (Figure 3). According to Who’s Who 2017, the chair is married to Hon. John Leigh-Pemberton. He’s a vice president of national charity The Country Trust (registered charity number: 1122103) (Figure 4). His position there should surely be disclosed by Ms Lampard.
    Figure 3. Kate Lampard's declared interests at 31 January 2017

    Figure 3. Kate Lampard’s declared interests at 31 January 2017

    Figure 4. Hon. John Leigh-Pemberton: a vice president of national charity The Country Trust at 10 February 2017

    Figure 4. Hon. John Leigh-Pemberton: a vice president of national charity The Country Trust at 10 February 2017

  19. In response, Mr Corby said in an email: “Trustees are required to declare relevant potential conflicts of interests in line with Charity Commission guidance which is provided to them all upon appointment (https://www.gov.uk/government/publications/conflicts-of-interest-a-guide-for-charity-trustees-cc29/conflicts-of-interest-a-guide-for-charity-trustees). The Country Trust’s website states that The Country Trust help children to learn and experience food, farming and the countryside. I find it very hard to imagine a situation where GambleAware would in any way have dealing with this Trust.” Perhaps, but that’s not the point. GambleAware trustees should declare “their interests in general (not only those with a potential for a conflict of interest),” according to the online trustee register of interests.
  20. The role of Atlas Communications Partners Ltd (trading name: Atlas Partners) is a serious concern. The firm handles media enquiries for GambleAware (Figure 5). Yet the charity also uses Atlas Partners as a political lobbyist, the latest statutory Register of Consultant Lobbyists (October to December 2016) reveals. The charity website fails to disclose the firm’s function as political lobbyist. Although the published board minutes document last year’s appointment of Atlas Partners, they don’t explicitly refer to political lobbying, either. Given how close GambleAware is to the gambling industry, there’s an urgent need for the charity to prove that it isn’t actually lobbying for the industry.

    Figure 5. Atlas Partners: media contact for GambleAware at 6 February 2017

    Figure 5. Atlas Partners: media contact for GambleAware at 6 February 2017

  21. On the hidden lobbyist, Mr Corby said in an email: “I do take your point that, because we only list Atlas as a contact number for journalists, our website may not make it clear that Atlas have a wider brief than just media management, so I will add something to that effect.” He added: “GambleAware does not lobby on behalf of the gambling industry. Atlas Partners does not work for any gambling industry organisations, because these would be considered a conflict with their work for GambleAware.” So that’s alright then. Nevertheless Ladbrokes’ Mr Mullen isn’t alone on the board: half of the current trustees, five of the ten, hold senior positions in the domestic gambling industry! What’s more, the composition of the board contravenes GambleAware’s stated policy of “maintaining only a minority of trustees with any direct interest in the gambling industry” (trustees’ annual report with the latest accounts).
  22. ACKNOWLEDGEMENT: I’m grateful to Iain Corby, Director of Operations and Development at GambleAware, for being responsive and willing to engage in discussion.

Jake Berry MP’s avoidable conflict of interest

  1. Jake Berry MP’s second job as a paid consultant to a multinational law firm means that it’s unclear, at the very least, in what capacity he spoke at a recent real-estate event in Manchester sponsored by the same law firm. The MP, a self-proclaimed champion of transparency, hasn’t replied to requests for comment on what I consider to be his avoidable conflict of interest. Nor has the law firm.
  2. Mr Berry is Conservative MP for Rossendale and Darwen. He’s a solicitor, who, according to his personal website, “specialised in housing and development law” before entering parliament in 2010. On 10 November 2016, Mr Berry spoke at a real-estate event at the National Football Museum, Manchester. Here’s a newspaper preview: http://www.manchestereveningnews.co.uk/business/property/more-effort-needed-drive-provide-12156570.
  3. The breakfast meeting had two sponsors: law firm Squire Patton Boggs (UK) LLP and bank NatWest. The MP has a second job – as a paid consultant to, er, Squire Patton Boggs (UK) LLP. It’s been paying him £2 500 per month since September 2016, Mr Berry’s entry on the register of MPs’ financial interests shows.
  4. The newspaper preview fails to mention the MP’s second job. An unfortunate omission. I’ve asked Mr Berry in emails in what capacity he spoke at the event. Was he there as MP for Rossendale and Darwen – or as an employee of Squire Patton Boggs (UK) LLP?
  5. At date of publication I haven’t received a reply. Nor have I heard from Holly Carty, business development coordinator at Squire Patton Boggs (UK) LLP in Manchester. Ms Carty tweeted about the event on her official work account (@HACarty).
  6. Mr Berry’s failure to respond is particularly disappointing because he’s a self-proclaimed champion of transparency: www.jakeberry.org/transparency. “If you have any questions or would like any further details please do not hesitate to contact me,” he says on that page.
  7. It’s unclear which Mr Berry spoke at the real-estate event in Manchester last November. Yet he had an actual, potential, or perceived conflict of interest due to his second job. This conflict of interest risks undermining trust and confidence in the MP, as well as MPs generally. What’s worse, his is an avoidable conflict of interest.
  8. There’s no suggestion that Mr Berry has done anything illegal.