Candidates' due diligence: Sussex Police and Crime Commissioner
Jamie Bennett (Lib Dem), Jonathan Christopher Kent (Green), Paul Adrian Richards (Labour and Co-op).
Due Diligence Summary
For those seeking a concise overview of the findings of this due diligence investigation into the candidates for the Sussex Police and Crime Commissioner election, a summary report is available available at https://alisonwright.substack.com/p/due-diligence-sussex-police-and-crime.
This summary provides a high-level overview of key observations and concerns identified during the analysis. However, for those interested in a more comprehensive examination, detailing specific anomalies and areas of scrutiny, the full report is provided below.
Candidates' due diligence: Sussex Police and Crime Commissioner
As part of the upcoming election for the position of Police and Crime Commissioner for Sussex, due diligence assessments have been conducted for the following candidates: Jamie Bennett (Lib Dem), Jonathan Christopher Kent (Green), Paul Adrian Richards (Labour and Co-op), and Katy Bourne (Conservative).
To provide voters with comprehensive insights into each candidate's background and potential compliance with legal and regulatory requirements, information has been gathered from various sources. The Choose My Police and Crime Commissioner website (choosemypcc.org.uk) serves as a primary resource for candidate profiles and election-related information, serving as the initial reference point for the analysis.
Subsequently, detailed scrutiny has been applied to each candidate's declarations and interests, with a focus on compliance with relevant legislation such as the Companies Act 2006, as well as considerations related to anti-money laundering and counter-terrorism financing laws. Companies House records have been consulted to ascertain any business affiliations or directorships held by the candidates, which are then assessed for adherence to legal requirements and ethical standards.
The Electoral Commission emphasises the importance of candidates confirming their eligibility and avoiding making false statements on their nomination papers (Disqualifications | Electoral Commission). Candidates are required to sign a declaration confirming their qualification for election, and any inaccuracies can result in criminal charges. As such, candidates are advised to seek legal advice if unsure about their eligibility.
The Electoral Statement forms a crucial part of the candidate's public information, providing an opportunity to disclose relevant background information and objectives. Failure to disclose employment and interests, which are required by law to be declared in proposed transactions, constitutes a breach of the Companies Act 2006. This omission undermines the validity of their candidacy and raises questions about transparency and accountability.
The following sections present the methodology employed in conducting the due diligence assessments, outlining the steps taken to collect, analyse, and synthesise the relevant information. By providing voters with transparent and objective evaluations of the candidates, this report aims to facilitate informed decision-making in the upcoming election for the Sussex Police and Crime Commissioner position.
Methodology
The due diligence report presented herein was compiled through a multi-step process involving data collection, analysis, and synthesis. The methodology can be summarised as follows:
Data Collection: The primary data sources utilised in this report include publicly available information from official websites, electoral documents, Companies House filings, and other relevant sources. Specific details on each candidate's background, declarations, and business interests were gathered from these sources.
Data Analysis: The collected data were systematically reviewed and analysed to identify any discrepancies, omissions, or potential breaches of electoral regulations and legal requirements. This involved cross-referencing information provided by the candidates with official records and conducting additional research where necessary.
Summaries and Conclusions: The findings from the data analysis were synthesised to produce individual summaries for each candidate, highlighting key points related to their candidacy, declarations, and compliance with relevant laws and regulations. Conclusions were drawn based on the synthesised information, outlining any concerns or recommendations arising from the analysis.
Quality Assurance: The report underwent a process of review and verification to ensure the accuracy and reliability of the information presented. This included fact-checking, peer review, and validation of findings against established criteria and standards.
Acknowledgment of Limitations: It is important to note that while extensive efforts were made to gather accurate and comprehensive data, limitations exist in the availability and reliability of certain information. Additionally, the analysis presented here is based on the information accessible at the time of writing and may be subject to change or revision.
Collaborative Approach: The report was developed collaboratively, with input from Alison Wright and analysis assistance from ChatGPT. While ChatGPT facilitated data analysis and summarisation, it is acknowledged that errors or omissions may occur, which were addressed through iterative revisions to ensure the accuracy and integrity of the final report.
Jamie Bennett, Liberal Democrat candidate
Jamie Bennett declares that he is a Councillor and that his agent is C Gibson, both at 100 Seaside Road, Eastbourne, East Sussex, BN21 3PF. He provides references to the South East Lib Dems website and his Facebook page (https://www.southeastlibdems.org.uk/pcc-elections-2024/jamie-bennett-for-sussex and https://www.facebook.com/profile.php?id=61557278283593).
The South East Liberal Democrat website provides the following biographic information:
Jamie Bennett was born in Brighton, grew up in East Sussex but now serves his local community as a Councillor in the Rustington area of Arun in West Sussex.
He lives with his wife Jo and their son Elliott and daughter Sophie in Littlehampton. Jamie has 14 years of experience on Rustington Parish Council, during which time he has served as Chairman and Vice Chairman of the Council. Jamie also served on Arun District Council between 2019-2023.
Visiting Arun District Council’s website, since Jamie Bennett is no longer a Councillor, so his register of Interests is unavailable there (Arun District Council).
Rustington Parish Council provided a register of interests to Arun District Council on 26 April 2021, republished in August 2023 (Rustington Parish Council - Register of Interests - August 2023 (arun.gov.uk)). This discloses:
Bennett, JF Self - Hotel Manager, Travelodge Brighton, 165-167 Preston Road, Brighton BN1 6AW
Spouse/Partner - Maternity Care Assistant, University Hospital NHS Foundation Trust, Worthing Hospital
Self - Arun Liberal Democrats
Self - Governor, Georgian Gardens Community Primary School, Rustington
Self - Liberal Democrats
Sensitive Interests as agreed by the Monitoring Office
His biography states that Jamie was first elected to the Council at the age of 20 years old in 2009 and has lived in Rustington since 2007. A search was made in Companies House using the search term “Jamie Bennett” as an officer, with year of birth 1989 (Jamie Bennett - Find and update company information - GOV.UK (company-information.service.gov.uk)).
There are no appointments in Companies House for Jamie Bennett with year of birth 1989.
A concern relates to the detail of his disclosure “Sensitive Interests as agreed by the Monitoring Office”. Given the significance of the role of Police and Crime Commissioner, he has a duty to disclose his “sensitive interests” to the public.
Potential breach of separation of powers
A recent BBC article sheds light on issues concerning the safety and welfare of unaccompanied asylum-seeking children housed in hotels. A breach of separation of powers could occur if Travelodge, the hotel where Mr. Bennett is employed, was or is associated with the Home Office and the contracts related to housing asylum seekers or other vulnerable individuals. As a candidate for the Police and Crime Commissioner position, Mr. Bennett's potential conflict of interest in such a scenario raises concerns about the integrity of the electoral process and the impartiality required for the role. It is essential to ensure that candidates for public office maintain independence from government bodies to uphold the principles of democracy and accountability.
Conclusion
In summary, Jamie Bennett, the Liberal Democrat candidate for Sussex Police and Crime Commissioner, presents a detailed background highlighting his experience as a local councillor in Rustington. However, he fails to disclose his association with Travelodge Brighton in his election address, despite declaring it in his register of interests with Rustington Parish Council. This omission, along with the ambiguity surrounding his "Sensitive Interests," raises concerns about transparency and openness with the electorate, particularly in the context of potential implications regarding missing unaccompanied children from hotels since 2021, with Travelodge potentially being one of the hotels involved. Additionally, the potential breach of separation of powers if Travelodge is associated with the Home Office in contracts related to housing asylum seekers or other vulnerable individuals raises further questions about Mr. Bennett's suitability for the role. It is essential to ensure that candidates for public office maintain independence from government bodies to uphold the principles of democracy and accountability.
Jonathan Christopher Kent, Green Party candidate
His biography states:
I grew up and live in Ticehurst. I went to local state schools and read philosophy and theology at Oxford. As a journalist and former foreign correspondent I campaigned on issues including human rights, miscarriages of justice, the treatment of migrant workers and sex trafficking.
This statement has been prepared by Jonathan’s election agent; Keith Obbard, of The Green Party Office, 39-41 Surrey Street, Brighton, Sussex, BN1 3PB
Contact Details Jonathan.Kent@Rother.Greenparty.org.uk
A search in Companies House locates one identity with the name Jonathan Christopher Kent (Jonathan Christopher KENT - Find and update company information - GOV.UK (company-information.service.gov.uk)).
Total number of appointments 1
Date of birth June 1966
BLACK COFFEE COMMUNICATIONS LTD (13395386)
Company status Active
Correspondence address Old Farmhouse, Beaumans, Wadhurst, Sussex, United Kingdom, TN5 6HL
Role ACTIVE Director Appointed on 13 May 2021
Nationality British Country of residence United Kingdom
Occupation Communications Consultant
BLACK COFFEE COMMUNICATIONS LTD Overview
Private limited Company Incorporated on 13 May 2021
Accounts overdue
Next accounts made up to 31 May 2023 due by 29 February 2024
Last accounts made up to 31 May 2022
Confirmation statement
Next statement date 12 May 2024
due by 26 May 2024Last statement dated 12 May 2023
Nature of business (SIC)
70210 - Public relations and communications activities
The accounts for Black Coffee Communications Ltd are 42 days overdue, since 29 February 2024. This is a breach of the Companies Act 2006.
Black Coffee has a website About – Black Coffee PR which provides the following information:
Whilst Black Coffee PR’s website does not carry statutory information about this company, we can conclude with certainty that this company is the same company as Black Coffee Communications Limited, since Jonathan Kent’s biography refers to him being a journalist and former foreign correspondent, which is the same occupations as described in Jonathan Christopher Kent’s Green election address.
Black Coffee Communications Limited’s Statement of Incorporation states that this company was established by an agent (BLACK COFFEE COMMUNICATIONS LTD filing history company-information.service.gov.uk):
COMPANIES MADE SIMPLE A DIVISION OF MADE SIMPLE GROUP LTD Agent's Address: 20-22 WENLOCK ROAD LONDON ENGLAND N1 7GU
This address is associated to 32,000 active companies (Search results - Find and update company information - GOV.UK (company-information.service.gov.uk)) which is a red flag for suspicious activity with high risk of being involved with money laundering.
Jonathan Christopher Kent fails to be transparent about his directorship of Black Coffee Productions Limited, which trades as Black Coffee PR. The accounts for this company are overdue. The company was established by an agent with an unusual potential span of control registered at 20-22 Wenlock Road, London.
Black Coffee Communications Limited present “Filleted accounts” for the year ending 31 May 2022. With tangible assets of £1, 675 and shareholder funds of £712, the figures presented are not in keeping with the profile of the clients it purports to supply on the Black Coffee PR website. It is proposed, on balance of probabilities, that the units have been filleted from these accounts, and that this company is laundering money, the omitted units could be thousands, millions or billions.
I will refer Mr Kent to the police for electoral misconduct, since he misrepresents his interests, his company statement is unrealistic and his company is in breach of the Companies Act 2006, by being overdue with submitting the most recent accounts.
Conclusion
In conclusion, the due diligence process on Jonathan Christopher Kent, the Green Party candidate for Sussex Police and Crime Commissioner, reveals significant discrepancies and concerns regarding his directorship of Black Coffee Communications Ltd. Kent's failure to maintain transparency about the company's operations, coupled with overdue accounts and questionable financial presentation, warrants further investigation and potential legal action. These findings underscore the importance of thorough scrutiny in assessing candidates' suitability for public office and upholding integrity in electoral processes.
Paul Adrian Richards, Labour and Co-operative Party candidate
His election address provides no details about his background (Paul Adrian Richards - Choose My Police and Crime Commissioner (choosemypcc.org.uk)_.
PAUL RICHARDS, your Labour & Co-operative candidate.
Statement prepared by J. Warmington (Agent) ,119 Lyndhurst
Road, Worthing BN11 2DEContact Details 01273 806773
https://labourinsussex.org.uk
paul@labourinsussex.org.uk
http://www.facebook.com/PaulRichardsSussexPCC
The Labour in Sussex website provides scant information on his background and experience. He is a member of the “East Sussex Co-op Party”. (Paul Richards for Sussex PCC - Labour Candidate for Police and Crime Commissioner (labourinsussex.org.uk)).
A search in Companies House on the name Paul Adrian Richards returns two identities with different dates of birth (Paul Adrian Richards - GOV.UK (company-information.service.gov.uk)). These are:
Total number of appointments 1 - Born October 1952
Sterling House, 27 Hatchlands Road, Redhill, Surrey, England, RH1 6RW
Matching appointment names:
Paul RICHARDSTotal number of appointments 5 - Born October 1967
45 Summerdown Road, Eastbourne, East Sussex, United Kingdom, BN20 8DR
The second identity listed here has a correspondence address in East Sussex and will be investigated further. The appointments held by Paul Adrian Richards, date of birth October 1967, are as follows:
Paul Adrian RICHARDS
Current appointments 1
Total number of appointments 5
Date of birth October 1967
PAUL RICHARDS COMMUNICATIONS LIMITED (04004307) Company status Active Correspondence address 45 Summerdown Road, Eastbourne, East Sussex, United Kingdom, BN20 8DR Role ACTIVE Director Appointed on 30 May 2000 Nationality British Country of residence England Occupation Public Relations Consultant
ONE WORLD ACTION (02822893) Company status Dissolved Correspondence address 112 Brookwood Road, London, SW18 5DB Role RESIGNED Director Appointed on 28 January 2002 Resigned on 25 July 2005 Nationality British Occupation Pr Consultant
NICARAGUA HEALTH FUND (01974486) Company status Dissolved Correspondence address 112 Brookwood Road, London, SW18 5DB Role RESIGNED Director Appointed on 28 January 2002 Resigned on 25 July 2005 Nationality British Occupation Pr Consultant
URBAN VISIONS LTD (03737233) Company status Dissolved Correspondence address 112 Brookwood Road, London, SW18 5DB Role RESIGNED Director Appointed on 1 June 2002 Resigned on 30 May 2003 Nationality British Occupation Public Relations Consultant
109 LIMITED (02663522) Company status Active Correspondence address 109 Hammersmith Bridge Road, London, W6 9DA Role RESIGNED Director Appointed on 12 November 1996 Resigned on 8 December 1999 Nationality British Occupation Journalist
Paul Adrian Richards, date of birth October 1967, describes his occupation as journalist and Public Relations Consultant, in Companies House. He has three resigned directorships to dissolved companies: One World Action, Nicaragua Health Fund, Urban Visions Ltd and a resigned appointment to 109 Limited, a company that is still active. He has one active directorship with Paul Richards Communications Limited.
During a professionally sceptical audit the directors of these interests would be checked for potential related party transactions or conflict or interest.
Looking first at Paul Richards Communications Limited.
The overview:
PAUL RICHARDS COMMUNICATIONS LIMITED overview
Private limited Company Incorporated on 30 May 2000
Accounts Next accounts made up to 31 July 2023 due by 30 April 2024 Last accounts made up to 31 July 2022
Confirmation statement Next statement date 30 May 2024 due by 13 June 2024 Last statement dated 30 May 2023
Nature of business (SIC) 70229 - Management consultancy activities other than financial management
The officers:
PAUL RICHARDS COMMUNICATIONS LIMITED people
Company number 04004307
Current officers: 2
Officers: 6 officers / 4 resignations
BKPS LIMITED Correspondence address Unit 3 74, High Street, Swadlincote, Derbyshire, England, DE11 8HS Role ACTIVE Secretary Appointed on 1 March 2014 UK Limited Company Registration number 07076686
RICHARDS, Paul Adrian Correspondence address 45 Summerdown Road, Eastbourne, East Sussex, United Kingdom, BN20 8DR Role ACTIVE Director Date of birth October 1967 Appointed on 30 May 2000 Nationality British Country of residence England Occupation Public Relations Consultant
NEIGHBOUR, James Correspondence address 3 Nelson Close, Wallingford, Oxon, OX10 0LG Role RESIGNED Secretary Appointed on 30 May 2000 Resigned on1 January 2009 Nationality British
MCCANN CHRISTENSEN CORPORATES SERVICES LTD Correspondence address 75 Cecil Avenue, Sale, Cheshire, United Kingdom, M33 5BG Role RESIGNED Secretary Appointed on 19 January 2009 Resigned on 11 December 2012 Registered in a European Economic Area Place registered CHESHIRE Registration number 05357459
MCCANN-CHRISTENSEN LIMITED Correspondence address 14a, Regent Road, Altrincham, Cheshire, England, WA14 1RP Role RESIGNED Secretary Appointed on 10 December 2012 Resigned on 1 March 2014 Registered in a European Economic Area Place registered WALES Registration number 03105433
SWIFT INCORPORATIONS LIMITED Correspondence address 26 Church Street, London, NW8 8EP Role RESIGNED Nominee Secretary Appointed on 30 May 2000 Resigned on 30 May 2000
Swift Incorporations Limited is a company and corporate identity that has been recurring during my due diligence assessments of politicians and regulators’ interests. There is a risk that this company has established a cartel of companies.
The persons with significant control:
PAUL RICHARDS COMMUNICATIONS LIMITED persons with significant control
2 active persons with significant control / 0 active statements
Mrs Sarah Richards ACTIVE Correspondence address 45 Summerdown Road, Eastbourne, East Sussex, BN20 8DR Notified on 10 May 2020 Date of birth August 1967 Nationality British Country of residence England Nature of control Ownership of shares – More than 25% but not more than 50% Ownership of voting rights - More than 25% but not more than 50%
Mr Paul Adrian Richards ACTIVE Correspondence address 45 Summerdown Road, Eastbourne, East Sussex, BN20 8DR Notified on 30 May 2017 Date of birth October 1967 Nationality British Country of residence England Nature of control Ownership of shares – 75% or more Ownership of voting rights - 75% or more
The most recent accounts for Paul Richards Communications Limited, as at 31 July 2021, are unsigned and do not list the secretary, BKPS Limited. These are two breaches of the Companies Act 2006.
The active secretary of Paul Richards Communications Limited is BKPS Limited, a corporate entity which is not named within the unsigned 2021 accounts. The accounts up to 31 July 2022 are due in two weeks on 30 April 2024.
The record for BKPS was entered by clicking on the name, which returns a list of the appointments held by this corporate identity.
BKPS LIMITED
Current appointments 4
Total number of appointments 5
LABOURLIST LIMITED (06996133) Company status Active Correspondence address 74 High Street, Swadlincote, Derbyshire, DE11 8HS Role ACTIVE Secretary Appointed on 5 May 2017 UK Limited Company Registration number 07076686
FLIXTON OSTEOPATHIC CLINIC LIMITED (06581322) Company status Active Correspondence address 74 High Street, Swadlincote, Derbyshire, England, DE11 8HS Role ACTIVE Secretary Appointed on 30 April 2015 UK Limited Company Registration number 07076686
FINANCIAL SENSE LIMITED (06432985) Company status Active Correspondence address 74 High Street, Swadlincote, Derbyshire, England, DE11 8HS Role ACTIVE Secretary Appointed on 20 November 2014 UK Limited Company Registration number 07076686
PAUL RICHARDS COMMUNICATIONS LIMITED (04004307) Company status Active Correspondence address Unit 3 74, High Street, Swadlincote, Derbyshire, England, DE11 8HS Role ACTIVE Secretary Appointed on 1 March 2014 UK Limited Company Registration number 07076686
CLOUDLEFT MEDIA LTD (07652534) Company status Dissolved Correspondence address 74 High Street, Swadlincote, Derbyshire, England, DE11 8HS Role RESIGNED Secretary Appointed on 1 March 2014 Resigned on 7 May 2021 UK Limited Company Registration number 07076686
BKPS Limited is an active secretary of four companies; Labourlist Limited, Flixton Osteopathic Clinic Limited, Financial Sense Limited and Paul Richards Communications Limited. A professionally sceptical audit of Paul Adrian Richards would test these companies for related party transactions, since they are associated via BKPS Limited.
Clicking on Labourlist Limited, returns the overview of this company:
Registered office address 5 Eastern Avenue, Burton-On-Trent, England, DE13 0AT Company status Active Company type Private company limited by guarantee without share capital Incorporated on 20 August 2009
Accounts Next accounts made up to 31 August 2023 due by 31 May 2024 Last accounts made up to 31 August 2022
Confirmation statement Next statement date 20 August 2024 due by 3 September 2024 Last statement dated 20 August 2023
Nature of business (SIC) 58190 - Other publishing activities
A search using a search engine locates the website of this company (LabourList - The latest news and comment on policy, elections, polls and more on Keir Starmer's Labour Party.) The website provides the following overview:
LabourList is an independent platform providing authoritative, non-factional news, comment from across and beyond the party, and a must-read daily email summarising all things Labour. Strand Partners is an advisory firm in London providing policy, communications and research advice to businesses.
Further information is given in the “About us” page:
Through our website, social media and daily email, LabourList provides the leading dedicated forum for authoritative news, insightful analysis and robust debate about the Labour Party across the UK.
Our readers and contributors alike come from across the party and beyond the party, from MPs, advisers, councillors and members to experts, pollsters, historians and campaigners.
Launched in 2009, we are supportive of the Labour Party, but independent of it and see ourselves as a “critical friend”.
Our purpose is to provide fair, fast, reliable and well-informed news coverage of all things Labour by our in-house journalists, from what the day’s big news story means for Labour to the internal or local party news story other media have missed.
Our purpose is also to provide a non-factional platform for rigorous debate and reflective analysis on Labour’s direction, facilitating a wide range of views from within the party and outside it– together informing and shaping the party’s future.
We are funded by donations from many of our readers, advertising, sponsorship, trade unions Unite the Union and the Fire Brigades Union and other donors.
The “Legal” page provides:
LabourList is published by LabourList Limited, registered in England and Wales, company number 06996133.
This is the same company number as is given in Companies House: LABOURLIST LIMITED (06996133).
The statutory information that should be present on the website of Labourlist Limited, including the directors and financial reports, are omitted from the website. This is a breach of transparency legislation.
Returning to Companies House filing records for Labourlist Limited, the most recent accounts were accessed. These were posted on 09 May 2023, labelled Micro company accounts made up to 31 August 2022 (LABOURLIST LIMITED filing history - Find and update company information - GOV.UK (company-information.service.gov.uk)).
These accounts fail to list the directors of the company and the accounts are not signed by a director. These are two breaches of the Companies Act 2006.
These accounts reflect those of a very small company with 3 employees and net assets and reserves of £48,396.
The Labourlist website said “We are funded by donations from many of our readers, advertising, sponsorship, trade unions Unite the Union and the Fire Brigades Union and other donors.” The accounts of the trade unions will be referenced to try to identify their donations., in order to test whether the figures presented in the accounts for Labourlist are realistic.
Following the link provided by Labourlist, to the Unite the Union website, the most recently reported Unite annual statement to members (unitetheunion.org) is for the period ended 31 December 2019. This provides:
Unite the Union STATEMENT TO MEMBERS ISSUED IN CONNECTION WITH THE UNION’S ANNUAL RETURN FOR PERIOD ENDED 31 DECEMBER 2019 AS REQUIRED BY SECTION 32A OF TRADE UNION AND LABOUR RELATIONS (CONSOLIDATION) ACT 1992
Income and Expenditure
The total income of the union for the period was £219,310,000. This amount included payments of £171,325,000 in respect of membership income of the union. The union’s total expenditure for the period was £177,239,000.
Political Fund
In respect of the union’s political fund, its total income was £7,200,000 and total expenditure was £9,474,000.
There is insufficient detail to determine a specific contribution to Labourlist Limited. More recent accounts were sought.
I checked the Mutuals Public Register, however Unite the Union is not registered there (Mutuals Public Register (fca.org.uk)).
A search in Companies House on “Unite the Union” locates three similarly named companies (Unite the union - Find - GOV.UK (company-information.service.gov.uk)). The records read:
Matching previous names:
UNITE THE UNION06160964 - Dissolved on 1 February 2011
Unit 6 Imperial Court, Laporte Way, Luton, Beds, United Kingdom, LU4 8FE
UNITE THE UNION SECOND TRUSTEE COMPANY LIMITED
Matching previous names:
UNITE THE UNION TRUSTEE COMPANY · UNION TRUSTEE COMPANY06477198 - Incorporated on 18 January 2008
10 Queen Street Place, London, EC4R 1BE
UNITE THE UNION TRUSTEE COMPANY LIMITED
00969191 - Incorporated on 29 December 1969
10 Queen Street Place, London, EC4R 1BE
Companies possessing similar names are a potential risk for clone company fraud. Unite the Union Trustee Company is the name of an active company and the previous name of another company now called Unite the Union Second Trustee Company. It is a breach of the Companies Act to duplicate the name of a company.
The person with significant control of both Unite the Union Trustee Company and Unite the Union Second Trustee Company is Sharon Graham (UNITE THE UNION TRUSTEE COMPANY LIMITED persons with significant control and UNITE THE UNION SECOND TRUSTEE COMPANY LIMITED persons with significant control.
Ms Sharon Graham ACTIVE
Correspondence address Unite House, 128 Theobald's Road, Holbon, London, United Kingdom, WC1X 8TN Notified on 27 September 2021 Date of birth December 1968
Unite the Union Trustee Company and Unite the Union Second Trustee Company are both dormant companies. Their accounts provide no information related to donations to Labourlist.
A request has been made through the Unite the Union website for the latest financial statements.
To be thorough I would check the other donor that Labourlist credits, Fire Brigades Union.
Above, I have just touched the surface of information to review relating to LabourList. To fully understand the linked directorate related LabourList Limited the interests of each of the directors requires examination.
The interests of BKPS Limited, their directors and directors’ other interests, including any held in multiple identities, and the accounts of all of these must be reviewed:
LABOURLIST LIMITED (06996133) Active Role ACTIVE Secretary Appointed on 5 May 2017 Company Registration number 07076686
FLIXTON OSTEOPATHIC CLINIC LIMITED (06581322) Active Role ACTIVE Secretary Appointed on 30 April 2015 Company Registration number 07076686
FINANCIAL SENSE LIMITED (06432985) Active Role ACTIVE Secretary Appointed on 20 November 2014 Company Registration number 07076686
CLOUDLEFT MEDIA LTD (07652534) Dissolved Role RESIGNED Secretary Appointed on 1 March 2014 Resigned on 7 May 2021 Company Registration number 07076686
Due diligence outstanding:
Election agent of Paul Adrian Richards:
J. Warmington, 119 Lyndhurst Road, Worthing BN11 2DE.
The resigned directors of Paul Richards Communications Limited:
NEIGHBOUR, James , 3 Nelson Close, Wallingford, Oxon, OX10 0LG Role RESIGNED Secretary Appointed on 30 May 2000 Resigned on1 January 2009
MCCANN CHRISTENSEN CORPORATES SERVICES LTD 75 Cecil Avenue, Sale, Cheshire, United Kingdom, M33 5BG Role RESIGNED Secretary Appointed on 19 January 2009 Resigned on 11 December 2012 Registration number 05357459
MCCANN-CHRISTENSEN LIMITED 14a, Regent Road, Altrincham, Cheshire, England, WA14 1RP Role RESIGNED Secretary Appointed on 10 December 2012 Resigned on 1 March 2014 Registration number 03105433
SWIFT INCORPORATIONS LIMITED 26 Church Street, London, NW8 8EP Role RESIGNED Nominee Secretary Appointed on 30 May 2000 Resigned on 30 May 2000
The person with significant control of Paul Richards Communications Limited:
Mrs Sarah Richards, date of birth August 1967.
The company that owns the corporate identity that is the active Secretary of Paul Richards Communications Limited, (which is omitted in the accounts, a breach of the Companies Act 2006) is:
BKPS LIMITED (07076686) 5 Eastgate Business Centre, Eastern Avenue, Burton-On-Trent, England, DE13 0AT Company status Active Company type Private limited Company Incorporated on 14 November 2009 Nature of business (SIC) 69201 - Accounting and auditing activities 69202 - Bookkeeping activities
Paul Adrian Richards past interests, these companies directors and their interests, including testing for multiple identities:
ONE WORLD ACTION (02822893) Company status Dissolved Correspondence address 112 Brookwood Road, London, SW18 5DB Role RESIGNED Director Appointed on 28 January 2002 Resigned on 25 July 2005 Nationality British Occupation Pr Consultant
NICARAGUA HEALTH FUND (01974486) Company status Dissolved Correspondence address 112 Brookwood Road, London, SW18 5DB Role RESIGNED Director Appointed on 28 January 2002 Resigned on 25 July 2005 Nationality British Occupation Pr Consultant
URBAN VISIONS LTD (03737233) Company status Dissolved Correspondence address 112 Brookwood Road, London, SW18 5DB Role RESIGNED Director Appointed on 1 June 2002 Resigned on 30 May 2003 Nationality British Occupation Public Relations Consultant
109 LIMITED (02663522) Company status Active Correspondence address 109 Hammersmith Bridge Road, London, W6 9DA Role RESIGNED Director Appointed on 12 November 1996 Resigned on 8 December 1999 Nationality British Occupation Journalist
Summary of companies and people that make up the immediate linked directorate of Paul Adrian Richards:
Paul Richards Communications Limited- Active Director
BKPS Limited - Active Secretary (Omitted in the accounts)
Labourlist Limited (06996133) - Active Role: Active Secretary
Flixton Osteopathic Clinic Limited (06581322) - Active Role: Active Secretary
Financial Sense Limited (06432985) - Active Role: Active Secretary
Cloudleft Media Ltd (07652534) - Dissolved Role: Resigned Secretary
Neighbour, James - Resigned Director
McCann Christensen Corporates Services Ltd - Resigned Secretary
McCann-Christensen Limited - Resigned Secretary
Swift Incorporations Limited - Resigned Nominee Secretary
BKPS Limited (07076686) - Company of Active Secretary (Omitted in the accounts)
One World Action (02822893) - Dissolved Role: Resigned Director
Nicaragua Health Fund (01974486) - Dissolved Role: Resigned Director
Urban Visions Ltd (03737233) - Dissolved Role: Resigned Director
109 Limited (02663522) - Active Role: Resigned Director
J. Warmington, election agent
Mrs. Sarah Richards, a person with significant control of Paul Richards Communications Limited.
Conclusion
Paul Adrian Richards, the Labour and Co-operative Party candidate for Sussex Police and Crime Commissioner, would benefit from providing more comprehensive information about his background and past business interests in his election address. As a public officer he has a duty to disclose his interests in full to the electorate to ensure transparency and assist voters in assessing his suitability for the role. Moreover, discrepancies such as the omission of BKPS Limited, the active secretary of his company, Paul Richards Communications Limited, in the company's accounts, raise concerns about compliance with the Companies Act 2006. This omission is particularly significant as BKPS Limited serves as an active secretary in three other active companies: Labourlist Limited, Flixton Osteopathic Clinic Limited, and Financial Sense Limited. Additionally, Mr. Richards' failure to disclose his involvement in four resigned directorships (One World Action, Nicaragua Health Fund, Urban Visions Ltd, and 109 Limited) in his election materials suggests a lack of transparency regarding his past professional affiliations. These discrepancies warrant further scrutiny to ensure accountability and transparency in Mr. Richards' candidacy.
Katy Bourne, Conservative Candidate
Katy Bourne is the subject of several due diligence reports and letters of serious complaint of allegations of criminal conduct, which are accessible through this website.
Conclusion
The failure of Katy Bourne to disclose sponsorship by the Conservative Party, the use of multiple identities in Companies House, and the delay in publishing audited accounts all undermine public trust and confidence in the governance of the Police and Crime Commission. These issues are particularly troubling given the upcoming elections, where Bourne seeks re-election for another term as Sussex Police and Crime Commissioner.
Transparency and accountability are paramount in ensuring the integrity of the electoral process and maintaining public confidence in democratic institutions. It is imperative that these allegations are investigated thoroughly and impartially to uphold the principles of fairness and justice.
I have urged the Investigations team and the Electoral Malpractice Office of Sussex Police to prioritise this matter and take appropriate action to address any potential misconduct or breaches of authority. The integrity of the electoral process and the public's trust in democratic institutions must be safeguarded at all costs.
Overall Summary
In summary, the due diligence conducted on the candidates for the upcoming Police and Crime Commissioner election in Sussex has revealed various concerns and discrepancies that warrant careful consideration by the residents of Sussex.
Firstly, Jamie Bennett, the Liberal Democrat candidate, has demonstrated a lack of transparency regarding his interests and affiliations, particularly in relation to sensitive interests not disclosed in his election materials.
Secondly, Jonathan Christopher Kent, representing the Green Party, has raised concerns about compliance with the Companies Act 2006, particularly regarding the overdue accounts of Black Coffee Communications Ltd and the potential implications for money laundering.
Thirdly, Paul Adrian Richards, the Labour and Co-operative Party candidate, has failed to provide comprehensive information about his background and past business interests in his election address, raising questions about transparency and compliance with the Companies Act 2006.
Lastly, Katy Bourne, the Conservative candidate, faces allegations of electoral malpractice, including failure to disclose sponsorship by the Conservative Party and the use of multiple identities in Companies House, raising significant doubts about transparency and integrity.
Given these findings, it is crucial for the residents of Sussex to carefully consider the candidates' suitability for the role of Police and Crime Commissioner. Transparency, accountability, and compliance with electoral regulations are essential qualities for candidates seeking to represent the interests of the community and uphold the principles of justice and fairness.
Ultimately, the residents of Sussex must exercise their democratic right to vote based on a thorough understanding of each candidate's background, qualifications, and commitment to transparency and integrity in public office. The integrity of the electoral process and the effective governance of the Police and Crime Commission depend on informed and conscientious decision-making by the electorate.
Sussex Police performance
Please visit my article covering the evidence relating to Sussex Police Performance:
Elections
I almost made the deadline to be nominated as a candidate for Sussex Police and Crime Commission. I have written about it in the following three articles:
Thanks for reading to the end. Please help with sharing this due diligence report to residents of Sussex, who will be selecting the next Sussex Police and Crime Commissioner in a vote on 2nd May 2024.
It takes several days to compile a report. Paid subscriptions are hugely appreciated. I presently support myself from a Personal Injury Trust which I received following a traumatic injury in 2008. I’ve applied for a job, as I have become productive again, since 2020, and the trust fund is low.