Alliance for Responsible Citizenship Limited Compliance Assessment Part A: Sir Paul Marshall

Draft for public consultation and feedback

Paul Marshall, Alan McCormick, Lord Hill and Oliver Plunkett of Alliance for Responsible Citizenship Limited (ARC): Compliance Assessment.

Draft for public consultation. Individuals are identified who are have breached sections of the Companies Act 2006, breaches that expose the public to the risk of money laundering, terrorism financing and people trafficking as they confound due diligence software. This method of fraud represents a high risk to the public’s best interests. Police investigation of my findings is required to include discovery of all financial transactions of the companies and individuals who are involved with identity and financial breaches.

As with all my reports there is more information that needs to be included. This has some incomplete sections; evidence yet to be included and conclusions to be drawn.

1. Introduction and Purpose

This Compliance Assessment evaluates the directors of Alliance for Responsible Citizenship Limited, specifically; Sir Paul Marshall and Alan McCormick, and former directors Oliver Plunkett and Lord Hill of Oareford.

Table of contents.

1. Introduction and Purpose

2. Company Overview: Alliance for Responsible Citizenship Limited

3. Trading Disclosures Compliance Assessment of ARC Conference Invitation

4. Director Profiles including:

• Identification of interests

• Accounts Compliance Assessment

• Unique Identifier Compliance Assessment

• Openness and Transparency Assessment.

A. Sir Paul Marshall

B. Alan McCormick

C. Lord Hill of Oareford

D. Oliver Plunkett

Conclusion and Overall Compliance Assessment.

Context:

On 5th August 2024 I received a general email invitation from Jordan B. Peterson to the Alliance for Responsible Citizenship (ARC) conference, scheduled for 17-19 February 2025, in London. A copy of the invitation is provided in the image below, image 1: Invitation to the Alliance for Responsible Citizenship (ARC) Conference 2025.

Image 1: Invitation to the Alliance for Responsible Citizenship (ARC) Conference 2025, received 5/8/2023.

Upon reviewing the invitation I identified subtle breaches of Trading Disclosure legislation. The relevant guidance is outlined on Gov.uk under “Running a limited company: your responsibilities: Signs, stationery and promotional material.” This guidance is derived from the Trading Disclosures legislation and regulations, specifically Part 5 Chapter 6 Sections 82 to 85 of the Companies Act 2006 and PART 6 Regulations 20 to 29 of the Trading Disclosures of The Company, Limited Liability Partnership and Business Regulations 2015 (CTDR 2015). Non-compliance with these regulations can result in civil and criminal penalties for company directors.

The guidance, Running a limited company: your responsibilities: Signs, stationery and promotional material states:

“Running a limited company: your responsibilities -

Signs

You must display a sign showing your company name at your registered company address and wherever your business operates. If you’re running your business from home, you do not need to display a sign there. (…)

Stationery and promotional material

You must include your company’s name on all company documents, publicity and letters.

On business letters, order forms and websites, you must show:

• the company’s registered number

• its registered office address

• where the company is registered (England and Wales, Scotland or Northern Ireland)

• the fact that it’s a limited company (usually by spelling out the company’s full name including ‘Limited’ or ‘Ltd’)

If you want to include directors’ names, you must list all of them.

If you want to show your company’s share capital (how much the shares were worth when you issued them), you must say how much is ‘paid up’ (owned by shareholders).”

To assess whether a company is compliant with Company Trading Disclosures requirements (CTDR 2015), the company records in Companies House are located and compared with the information provided in the letter or website under review. In this way breaches, where they exist, can be identified.

Other compliance assessments.

Since 2022, I have been preparing compliance assessments focussing on compliance with the Companies Act 2006, specifically relating to: Integrity of annual accounts, compliance of individuals to holding one unique identifier in Companies House, and transparency of disclosures of interests.

Accounts Compliance:

Assessing whether, at a minimum, the annual accounts are “up to date” and that final accounts are up to date and have been delivered for dissolved companies as required by section 441 of the Companies Act 2006, duty to file accounts and reports with the registrar (s441:CA2006). This can be determined from the overview information provided by Companies House, in which overdue accounts are typically flagged with a warning sign.

Identity Compliance

Directors are required to maintain a single “unique identifier” in Companies House. Multiple unique identifiers for an individual obscures interests and compromises audits and Know Your Customer (KYC) checks. The presence of multiple “unique identifiers” represents a breach of Section 1082 of the Companies Act 2006, “Allocation of unique identifiers,” (S1082:CA2006). A search in Companies House on the name of the individual will typically return additional identities registered with the same name, a visual search can locate those with the same date of birth, if there are any.

Multiple identities cause “false non-match errors” in computer software, occurring during identity checks in “zero-trust”, cybersecure, systems. Therefore, the UK Government National Cyber Security Centre’s “Zero trust architecture design principles” also require people to be “uniquely identifiable” (Zero trust architecture design principles (ncsc.gov.uk)).

Transparency Compliance

Compliance is assessed by establishing whether all interests are disclosed in the Register of Interests, when available, or in biographies on associated company websites, using the principles derived from the House of Lords’ Code of Conduct (HLCC2023).

Principles for Disclosure of Directorship:

Complete Disclosure: Ensure all directorships are fully disclosed, without omissions, to provide a comprehensive view of business interests.

Consistency: Verify that information in the Register of Interests or biographies matches records in Companies House to avoid discrepancies.

Transparency: Clearly identify directorships, including company name, role, and, appointment/resignation dates for stakeholder understanding.

Accuracy: Maintain up-to-date and accurate details reflecting any changes in directorships promptly.

These principles can be tested by comparing the Register of Interests or biographies with appointments listed in Companies House.

This report will provide:

1. Trading Disclosure Compliance Assessments of the Alliance for Responsible Citizenship’s invitation and website, and related companies’ websites. Breaches are highlighted as “Non-compliant (CTDR 2015)”.

2. Unique Identity Compliance Assessments: Directors will be screened for multiple identities registered in Companies House. Breaches are highlighted as “Non-compliant (s1082:CA2006)”.

3. Accounts Compliance Assessments: Attention will be drawn to companies that have dissolved with accounts overdue, the risk being that unmonitored transactions may occur. Overdue accounts represents a breach of Section 441 of the Companies Act 2006. Breaches are highlighted as “Non-compliant (s441:CA2006)”.

4. Transparency and Openness Assessments: Interests disclosed in the Register of Interests, if available, and on biographies will be compared with interests registered in Companies House. Omissions are highlighted as “Non-compliant (HLCC2023)”.

This report aims to provide a comprehensive executive overview of compliance, related to trading disclosures, identity management, accounts, and transparency and openness, of the directors of Alliance for Responsible Citizenship Limited, based on the records viewed.

2. Alliance for Responsible Citizenship Limited

A search in Companies House for “Alliance for Responsible Citizenship” returns the company record (Alliance for Responsible Citizenship - Find https://find-and-update.company-information.service.gov.uk/search?q=Alliance+for+Responsible+Citizenship). The screenshot, below, shows the first two results only, see image 2: Search results for Alliance for Responsible Citizenship on 30/9/2024.

Image 2: Search results for Alliance for Responsible Citizenship on 30/9/2024.

The search record is reproduced below:

“ALLIANCE FOR RESPONSIBLE CITIZENSHIP LIMITED

10519995 - Incorporated on 12 December 2016

78 Pall Mall, London, England, SW1Y 5ES”

Note that the address on the invitation “78 Pall Mall, London, SW1Y 5ES”, omits “England” and refers to the same location as provided by Companies House as the registered address “78 Pall Mall, London, England, SW1Y 5ES”. This anomaly will be revisited Trading Disclosures compliance assessment, after considering the Companies House records in more detail.

Alliance for Responsible Citizenship Overview:

The records for this company are reached by clicking on the underlined name in Companies House (and herein). See image 3: Alliance for Responsible Citizenship Limited’s company overview record on 30/9/2024.

Image 3: Alliance for Responsible Citizenship Limited, record in Companies House on 30/09/2024

ALLIANCE FOR RESPONSIBLE CITIZENSHIP LIMITED overview:

“ALLIANCE FOR RESPONSIBLE CITIZENSHIP LIMITED Company number 10519995 Registered office address 78 Pall Mall, London, England, SW1Y 5ES Company status Active Company type Private limited Company Incorporated on 12 December 2016 Accounts Up to date Next accounts made up to 31 December 2023 due by 30 September 2024 Last accounts made up to 31 December 2022 Confirmation statement Up to date Next statement date 19 May 2025 due by 2 June 2025 Last statement dated 19 May 2024 Nature of business (SIC) 85520 - Cultural education Previous company names PROSPERITY UK 2017 LIMITED 12 Dec 2016 - 20 Jan 2023”

Alliance for Responsible Citizenship Limited officers:

The Companies House record has a tab called “people” (as seen in the image above) which provides the details of the officers (directors and secretary, if any) appointed to the company.

The officer details are copied below (the weblinks, associated to underlined text, are embedded in the data copied from Companies House).

ALLIANCE FOR RESPONSIBLE CITIZENSHIP LIMITED people:

“ALLIANCE FOR RESPONSIBLE CITIZENSHIP LIMITED

5 officers / 3 resignations

MARSHALL, Paul Roderick Clucas Correspondence address 78 Pall Mall, London, England, SW1Y 5ES Role Active Director Date of birth August 1959 Appointed on 12 December 2016 Nationality British Country of residence England Occupation Investment Manager

MCCORMICK, Alan James Correspondence address Legatum Plaza, Level 2, Gate Precinct 6, Dubai International Finance Centre, PO BOX 506625, Dubai, United Arab Emirates Role Active Director Date of birth June 1974 Appointed on 9 February 2023 Nationality British Country of residence United Arab Emirates Occupation Managing Director

PLUNKETT, Oliver Correspondence address C/o Wpo Limited, First Floor, 6 Grosvenor Street, London, United Kingdom, W1K 4PZ Role Resigned Secretary Appointed on 15 January 2017 Resigned on 19 January 2017

HILL, Jonathan Hopkin, The Rt Hon. The Lord Correspondence address 11 Charles Street, London, England, W1J 5DW Role Resigned Director Date of birth July 1960 Appointed on 31 January 2018 Resigned on 10 February 2023 Nationality British Country of residence England Occupation Self-Employed

PLUNKETT, Oliver Correspondence address 20 Eastbourne Terrace, London, England, W2 6LG Role Resigned Director Date of birth April 1972 Appointed on 19 January 2017 Resigned on 19 January 2018 Nationality British Country of residence England Occupation Company Director”

Summary of Active Directors:

Paul Roderick Clucas Marshall, born August 1959, was appointed on 12 December 2016, with occupation as Investment Manager. He uses the company’s registered address for his correspondence, 78 Pall Mall, London, England, SW1Y 5ES.

Alan James McCormick, born June 1974, appointed on 9 February 2023, is the Managing Director. He is British and resident in the United Arab Emirates. He gives his correspondence address as Legatum Plaza, Level 2, Gate Precinct 6, Dubai International Finance Centre, PO BOX 506625, Dubai, United Arab Emirates Role.

Summary of Resigned Individuals

Oliver Plunkett was appointed as secretary on 15 January 2017 and resigned on 19 January 2017. His correspondence address is C/o Wpo Limited, First Floor, 6 Grosvenor Street, London, United Kingdom, W1K 4PZ. On the same day, Oliver Plunkett, born April 1972, was appointed as a director, 19 January 2017, and resigned on 19 January 2018. He gave his occupation as Company Director and used a different correspondence address, 20 Eastbourne Terrace, London, England, W2 6LG.

Unusual activity: Oliver Plunkett:

1. Rapid Changes in Roles: Oliver Plunkett's brief tenure as secretary (four days) followed by his immediate appointment and subsequent resignation as a director within a year suggests unusual activity.

2. Different Correspondence Addresses: The use of different correspondence addresses for his roles as secretary and director might indicate an attempt to separate these roles or could simply reflect administrative choices. Oliver Plunkett’s correspondence address The address used as a secretary “C/o Wpo Limited, First Floor, 6 Grosvenor Street, London, United Kingdom, W1K 4PZ”, associates the Alliance for Responsible Citizenship Limited with “WPO Limited” and the address “First Floor, 6 Grosvenor Street, London, United Kingdom, W1K 4PZ”. These associations require testing for potential related party transactions.

3. Assumption of Identity: A human might assume that both roles were held by the same individual based on the name and company name aligning. However, if these two appointments are held in two separate “unique identifiers” computer software would identify these records as belonging to two different individuals. This will be explored further.

Jonathan Hopkin Hill, The Rt Hon. The Lord, born July 1960, was appointed as a director on 31 January 2018 and resigned on 10 February 2023. He gave his occupation as Self-Employed. He is British and resident in England. His correspondence address is 11 Charles Street, London, England, W1J 5DW.

Alliance for Responsible Citizenship Persons with significant control:

The Persons with significant control are accessible via the “People” tab, in the company record. This states:

ALLIANCE FOR RESPONSIBLE CITIZENSHIP LIMITED persons with significant control

“5 active persons with significant control / 0 active statements

Mr Alan James Mccormick Active Correspondence address Legatum Plaza, Level 2, Gate Precinct 6, PO BOX 506625, Dubai International Financial Centre, Dubai, United Arab Emirates Notified on 10 February 2023 Date of birth June 1974 Nationality British Country of residence United Arab Emirates Nature of control Has significant influence or control

Mr Christopher Lincoln Chandler Active Correspondence address Legatum Plaza, Level 2, Gate Precinct 6, PO BOX 506625, Dubai International Financial Centre, Dubai, United Arab Emirates Notified on 10 February 2023 Date of birth January 1960 Nationality New Zealander Country of residence United Arab Emirates Nature of control Has significant influence or control

Mr Richard Edward Douglas Active Correspondence address Legatum Plaza, Level 2, Gate Precinct 6, PO BOX 506625, Dubai International Financial Centre, Dubai, United Arab Emirates Notified on 10 February 2023 Date of birth May 1953 Nationality Cayman Islander Country of residence Cayman Islands Nature of control Has significant influence or control

Mr Mark Alan Stoleson Active Correspondence address Legatum Plaza, Level 2, Gate Precinct 6, PO BOX 506625, Dubai International Financial Centre, Dubai, United Arab Emirates Notified on 10 February 2023 Date of birth July 1970 Nationality Maltese Country of residence United Arab Emirates Nature of control Has significant influence or control

Mr Paul Roderick Clucas Marshall Active Correspondence address 78 Pall Mall, London, England, SW1Y 5ES Notified on 12 December 2016 Date of birth August 1959 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%”

There are five “persons with significant control” of Alliance for Responsible Citizenship Limited, including the two active directors, Mr Alan James Mccormick, and Mr Paul Roderick Clucas Marshall, and Mr Christopher Lincoln Chandler (date of birth January 1960), Mr Richard Edward Douglas (date of birth May 1953) and Mr Mark Alan Stoleson (date of birth July 1970. Alan McCormick’s correspondence address is “78 Pall Mall, London, England, SW1Y 5ES”, the four other persons with significant control have correspondence address “Legatum Plaza, Level 2, Gate Precinct 6, PO BOX 506625, Dubai International Financial Centre, Dubai, United Arab Emirates”.

The active persons with significant control of Alliance for Responsible Citizenship, Mr Chandler, Mr Douglas and Mr Stoleson will be considered towards the end of this report, which will be published in a several parts.

3. Trading Disclosures Compliance Assessment: ARC Conference invitation.

The information from Companies House, above, is sufficient to be able to apply the Trading Disclosures Compliance Assessment to the invitation I received from Jordan B. Peterson:

1. Company's Registered Name: “Alliance for Responsible Citizenship” omits “Limited” which is misleading as the name suggests it may be not for profit charity. Non-compliant (CTDR 2015).

2. Company Registration Number: No registration number provided. Non-compliant (CTDR 2015).

3. Place of Registration: Omitted. Non-compliant (CTDR 2015).

4. Registered Office Address: “78 Pall Mall, London, SW1Y 5ES” omits “England”, Non-compliant (CTDR 2015).

5. Directors' Names (all, if any): Since Jordan B. Peterson is not a director, no directors are named. Compliant (CTDR 2015).

6. Share Capital Information: (Shares worth and paid up, if either). Neither provided. Compliant (CTDR 2015).

Trading Disclosures Compliance Assessment: The invitation to the Alliance for Responsible Citizenship 2025 Conference (image 1) fails to meet four out of six Trading Disclosures requirements and is therefore four times non-compliant (CTDR 2015). These legal oversights are the responsibility of the two active directors, Paul Roderick Clucas Marshall, born August 1959 and Alan James McCormick, born June 1974. These are red flags for potential obfuscation.

4. Director Profiles:

The appointments associated with each officer’s unique identifier or identity can be accessed by clicking on their name in Companies House. This information is typically reviewed by auditors, due diligence software, and individuals conducting Know Your Customer (KYC) checks to identify potential "related party transactions." Auditors are obligated to monitor these transactions to prevent and detect fraud.

The companies associated with each director are listed below. Overdue accounts are highlighted as non-compliant under Section 441 of the Companies Act 2006 (s441:CA2006).

Formatting Notes:

• To streamline information from Companies House and avoid duplication, records have been consolidated, with some details omitted

• Assume the accounts and confirmation statement are “up to date”, unless stated otherwise.

• Italics indicates comments, while bold highlights legal breaches.

A. Sir Paul Marshall

The unique identifier record for Sir Paul Marshall holds all the appointments held by this unique identity. The full records are reproduced after the summary.

Summary of Sir Paul Marshall’s appointments: active appointments, resigned from active companies, and dissolved companies

Active Appointments:

1. Alliance for Responsible Citizenship Limited Appointed on: 12 December 2016

2. ARK Academies Projects Limited Appointed on: 15 May 2007

3. Marshall Wace LLP Appointed on: 1 September 2003

4. Absolute Return for Kids (ARK) Appointed on: 13 November 2002

5. Pimpernel and Partners Limited Appointed before: 15 March 1992

Resigned Appointments in Active Companies:

1. ARK Schools, Appointed on: 9 September 2004, Resigned on: 12 April 2024

2. Education Policy Institute, Appointed on: 7 December 2010, Resigned on: 1 January 2024

3. Marshall Wace Asset Management Limited, Appointed on: 2 July 1997, Resigned on: 24 May 2022

4. St Paul's Theological Centre, Appointed on: 12 July 2007, Resigned on: 4 September 2017

5. Standards Board for Alternative Investments Limited, Appointed on: 1 February 2008, Resigned on: 30 October 2016

6. ARK UK Programmes, Appointed on: 19 September 2006, Resigned on: 1 September 2013

7. Liberal Democrat Business Forum Limited, Appointed on: 13 September 2000, Resigned on: 24 June 2009

8. Pragma Wealth Management Ltd., Appointed on: 14 June 2001, Resigned on: 21 October 2004

9. BlackRock Investment Management (UK) Limited, Appointed on: 30 May 1995, Resigned on: 8 August 1997

10. Marshall Wace Asset Management Limited, Appointed on: 2 July 1997, Resigned on: 16 July 1997

Dissolved Appointments, all with accounts overdue:

1. MW Eaglewood Management Limited, Appointed on: 22 October 2013, Non-compliant (s441 CA2006).

2. MWAM NA Ltd, Appointed on: 6 June 2011. Non-compliant (s441 CA2006).

3. MWAM UK Ltd, Appointed on: 6 June 2011. Non-compliant (s441 CA2006).

4. Every Child a Chance Trust, Appointed on: 22 November 2007. Non-compliant (s441 CA2006).

5. Freedom Music Limited, Appointed on: 22 February 2013 Non-compliant (s441 CA2006).

The records from Companies House are copied below, précised and with details added from: the company overview, charges and register information, if any, and the person with significant control. These records are reached by clicking on the underlined company name. Officer details are considered separately, so are not included here. Text in italics has been added by the author.

“MARSHALL, Paul Roderick Clucas

Current appointments 5

Total number of appointments 20”

“ALLIANCE FOR RESPONSIBLE CITIZENSHIP LIMITED (10519995) Active, Correspondence address: 78 Pall Mall, London, England, SW1Y 5ES, Role: Active Director, Appointed on: 12 December 2016, Occupation: Investment Manager Registered office address Company status Active Company type Private limited company Incorporated on 12 December 2016 Accounts (Up to date) Next accounts made up to 31 December 2024 due by 30 September 2025 Last accounts made up to 31 December 2023 Confirmation statement Next statement date 19 May 2025 due by 2 June 2025 Last statement dated 19 May 2024 Nature of business (SIC) 85520 - Cultural education Previous company names PROSPERITY UK 2017 LIMITED 12 Dec 2016 - 20 Jan 2023”

“MW EAGLEWOOD MANAGEMENT LIMITED (08743417) Dissolved, Correspondence address: 1020 Eskdale Road, Winnersh, Wokingham, RG41 5TS, Role: Director, Appointed on: 22 October 2013, Occupation: Chairman Registered office address 1020 Eskdale Road, Winnersh, Wokingham, RG41 5TS Company status Dissolved Dissolved on 15 December 2018 Company type Private limited Company Incorporated on 22 October 2013 Accounts Last accounts made up to 29 February 2016 Accounts Overdue 1 March 2016 to 15 December 2018 (1y 9m) Non-compliant (s441 CA2006) Nature of business (SIC) 64205 - Activities of financial services holding companies Previous company names P2P PRINCIPALS LIMITED 22 Oct 2013 - 02 May 2014 1

Insolvency case Case number 1 — Members voluntary liquidation Commencement of winding up 22 December 2016 Dissolved on 15 December 2018 Practitioner Sean Kenneth Croston Grant Thornton Uk Llp 1020 Eskdale Road, Winnersh, Wokingham, RG41 5TS Appointed on 22 December 2016

There are no persons with significant control or statements available for this company.”

“MWAM NA LTD (07659460) Dissolved, Correspondence address: 30 Finsbury Square, London, England, EC2A 1AG, Role: Director, Appointed on: 6 June 2011, Occupation: Director Registered office address 30 Finsbury Square, London, England, EC2A 1AG Company status Dissolved Dissolved on 7 April 2022 Last accounts made up to 28 February 2019 Accounts Overdue 1March 2019 - 7 April 2022 (3y 1m) Non-compliant (s441 CA2006) Nature of business (SIC) 66300 - Fund management activities

1 Insolvency case Case number 1 — Members voluntary liquidation Commencement of winding up 6 November 2020 Dissolved on 7 April 2022 Practitioner Sean Kenneth Croston 30 Finsbury Square, London, EC2A 1AG Appointed on 6 November 2020

1 person with significant control / 0 statements Mwam North America Llp Correspondence address George House, 131 Sloane Street, London, United Kingdom, SW1X 9AT Notified on 24 April 2020 Governing law England And Wales Legal form Limited Liability Partnership Place registered Registrar Of Companies For England And Wales Registration number Oc430937 Incorporated in United Kingdom Nature of control Ownership of shares – 75% or more Ownership of voting rights - 75% or more Right to appoint or remove directors”

“MWAM UK LTD (07659458) Dissolved, Correspondence address 1020 Eskdale Road, Winnersh, Wokingham, RG41 5TS, Role Director, Appointed on: 6 June 2011, Occupation Director Registered office address 1020 Eskdale Road, Winnersh, Wokingham, RG41 5TS Company status Dissolved Dissolved on 23 November 2018 Company type Private limited Company Incorporated on 6 June 2011 Last accounts made up to 28 February 2017 Accounts Overdue 1 March 2017 - 23 November 2018 (1y 7m) Non-compliant (s441 CA2006) Nature of business (SIC) 66300 - Fund management activities 1 Insolvency case Case number 1 — Members voluntary liquidation Commencement of winding up 15 November 2017 Dissolved on 23 November 2018 Practitioner Sean Kenneth Croston Grant Thornton Uk Llp 1020 Eskdale Road, Winnersh, Wokingham, RG41 5TS Appointed on 15 November 2017

0 persons with significant control / 1 statement Statement The company knows or has reasonable cause to believe that there is no registrable person or registrable relevant legal entity in relation to the company Notified on 6 June 2017”

“EVERY CHILD A CHANCE TRUST (06434237) Dissolved, Correspondence address: The Adelphi 13th, (sic) Floor, 1-11 John Adam Street, London, United Kingdom, WC2N 6HT, Role: Director, Appointed on: 22 November 2007, Occupation: Chairman/Founding Partner Registered office address Kpmg Foundation, 15 Canada Square, London, United Kingdom, E14 5GL Company status Dissolved Dissolved on 20 August 2013 Company type Private Limited Company by guarantee without share capital use of 'Limited' exemption Incorporated on 22 November 2007 Last accounts made up to 30 September 2011 Accounts Overdue 1 October 2011 - 20 August 2013 (1y 10m) Non-compliant (s441 CA2006) Nature of business (SIC) 85200 - Primary education

There are no persons with significant control or statements available for this company.”

“ARK ACADEMIES PROJECTS LIMITED (04101629) Active, Correspondence address: The Yellow Building, 1 Nicholas Road, London, England, W11 4AN, Role: Active Director, Appointed on: 15 May 2007, Occupation: Fund Manager Registered office address 1 Edcity Edcity Walk, (sic) London, United Kingdom, W12 7TF Nature of business (SIC) 41100 - Development of building projects 81100 - Combined facilities support activities 85100 - Pre-primary education Previous company names ABSOLUTE RETURN FOR KIDS (ARK) TRADING LIMITED 30 Sep 2003 - 03 Jul 2007 TACT TRADING LIMITED 03 Nov 2000 - 30 Sep 2003

• Register of directors Information not on the public register since 16 December 2016

• Register of secretaries Information not on the public register since 16 December 2016

• Register of person(s) with significant control (PSCs) Information not on the public register since 16 December 2016

• Register of members Information not on the public register since 16 December 2016

Persons with significant control

Persons with significant control:1 active person with significant control / 0 active statements Ark Schools Active Correspondence address 1 Nicholas Road, London, England, W11 4AN Notified on 6 April 2016 Governing law The Laws Of England And Wales Legal form Private Company Limited By Guarantee Place registered England And Wales Companies Registry Registration number 05112090 Incorporated in England Nature of control Ownership of shares – 75% or more Ownership of voting rights - 75% or more”

“MARSHALL WACE LLP (OC302228) Active, Correspondence address: George House, 131 Sloane Street, London, England, SW1X 9AT, Role: Active LLP Member, Appointed on: 1 September 2003 Registered office address George House, 131 Sloane Street, London, England, SW1X 9AT Company status Active Company type Limited liability partnership Incorporated on 16 May 2002 Accounts (Up to date) Next accounts made up to 28 February 2024 due by 30 November 2024 Last accounts made up to 28 February 2023 Confirmation statement Next statement date 11 June 2025 due by 25 June 2025 Last statement dated 11 June 2024 1 charge registered 0 outstanding, 1 satisfied, 0 part satisfied Charge code OC30 2228 0001 Created 15 September 2015 Delivered 30 September 2015 Status Satisfied on 17 November 2021 Persons entitled Deutche (sic) Bank Ag Brief description Contains fixed charge…

24 active persons with significant control”

“ABSOLUTE RETURN FOR KIDS (ARK) (04589451) Active, Correspondence address: The Yellow Building, 1 Nicholas Road, London, England, W11 4AN, Role: Active Director, Appointed on: 13 November 2002, Occupation: Fund Manager Registered office address 1 Edcity Edcity (sic) Walk, London, United Kingdom, W12 7TF Company status Active Company type Private Limited Company by guarantee without share capital use of 'Limited' exemption Incorporated on 13 November 2002 Accounts (Up to date) Next accounts made up to 31 August 2024 due by 31 May 2025 Last accounts made up to 31 August 2023 Confirmation statement Next statement date 14 November 2024 due by 28 November 2024 Last statement dated 14 November 2023 Nature of business (SIC) 85600 - Educational support services 86900 - Other human health activities 1 charge registered 1 outstanding, 0 satisfied, 0 part satisfied Rent security deposit deed Created 5 January 2010 Delivered 9 January 2010 Status Outstanding Persons entitled A & a Kingsway Holdings Limited Short particulars The deposit account into which the initial deposit has been…

0 active persons with significant control / 1 active statement Statement Active The company knows or has reasonable cause to believe that there is no registrable person or registrable relevant legal entity in relation to the company Notified on 13 November 2016”

“PIMPERNEL AND PARTNERS LIMITED (02361343) Active, Correspondence address: 70 Upper Richmond Road, London, SW15 2RP, Role: Active Secretary, Appointed before: 15 March 1992 Registered office address 70 Upper Richmond Road, London, SW15 2RP Company status Active Company type Private limited Company Incorporated on 15 March 1989 Accounts (Up to date) Next accounts made up to 31 March 2024 due by 31 December 2024 Last accounts made up to 31 March 2023 Confirmation statement Next statement date 9 March 2025 due by 23 March 2025 Last statement dated 9 March 2024 Nature of business (SIC) 47791 - Retail sale of antiques including antique books in stores

1 active person with significant control / 0 active statements Mrs Sabina Marshall Active Correspondence address 70 Upper Richmond Road, London, England, SW15 2RP Notified on 6 April 2016 Date of birth December 1956 Nationality French Country of residence England Nature of control Ownership of shares – 75% or more”

“ARK SCHOOLS (05112090) Active, Correspondence address: George House 131, Sloane Street, London, SW1X 9AT, Role: Resigned Director, Registered office address 1 Edcity Edcity Walk, (sic) London, United Kingdom, W12 7TF Company status Active Company type Private Limited Company by guarantee without share capital use of 'Limited' exemption Incorporated on 26 April 2004 Accounts (Up to date) Next accounts made up to 31 August 2024 due by 31 May 2025 Last accounts made up to 31 August 2023 Confirmation statement Next statement date 18 April 2025 due by 2 May 2025 Last statement dated 18 April 2024Appointed on: 9 September 2004, Resigned on: 12 April 2024, Occupation: Fund Manager Nature of business (SIC) 85100 - Pre-primary education 85200 - Primary education 85310 - General secondary education Previous company names

• ARK ACADEMIES 10 Jul 2006 - 01 Sep 2010

• ABSOLUTE RETURN FOR KIDS (ARK) EDUCATION 12 May 2004 - 10 Jul 2006

• ABSOLUTE RETURN FOR KIDS (ARK) EDUCATION LIMITED 26 Apr 2004 - 12 May 2004

4 charges registered 4 outstanding, 0 satisfied, 0 part satisfied

• Charge code 0511 2090 0004 Created 25 October 2022 Delivered 7 November 2022 Status Outstanding Persons entitled The Secretary of State for Education of Sanctuary Buildings Brief description By way of legal mortgage the freehold property known as…

• Charge code 0511 2090 0003 Created 31 August 2018 Delivered 13 September 2018 Status Outstanding Persons entitled The Secretary of State for Education Brief description Freehold property at adair house 403 shooters hill london…

• Rent security deposit deed Created 27 August 2009 Delivered 5 September 2009 Status Outstanding Persons entitled Catchment Estates Limited Short particulars £5,966.06.

• Rent security deposit deed Created 27 August 2009 Delivered 5 September 2009 Status Outstanding Persons entitled Woodall Refrigeration Limited Short particulars £4,080.19.

1 active person with significant control / 0 active statements Absolute Return For Kids (Ark) Active Correspondence address 65 Kingsway, London, England, WC2B 6TD Notified on 1 September 2016 Governing law Charities Act 2011 Legal form Private Limited Company By Guarantee Without Share Capital Use Of 'Limited' Exemption Place registered Companies House Registration number 04589451 Incorporated in United Kingdom Nature of control Right to appoint or remove directors with control over the trustees of a trust”

“EDUCATION POLICY INSTITUTE (04579498) Active, Correspondence address: George House 131, Sloane Street, London, SW1X 9AT, Role: Resigned Director, Appointed on: 7 December 2010, Resigned on: 1 January 2024, Occupation: Asset Management Registered office address 150 Buckingham Palace Road, London, England, SW1W 9TR Company status Active Company type Private Limited Company by guarantee without share capital use of ‘Limited' exemption Incorporated on 1 November 2002 Accounts (Up to date) Nature of business (SIC)85590 - Other education not elsewhere classified Previous company names CENTRE FOR REFORM 01 Nov 2002 - 19 May 2016

0 active persons with significant control / 1 active statement

Statement Active The company knows or has reasonable cause to believe that there is no registrable person or registrable relevant legal entity in relation to the company Notified on 29 February 2024

Sir Paul Roderick Clucas Marshall Ceased Correspondence address Acacia House, 115 Mortlake High Street, London, United Kingdom, SW14 8HQ Notified on 1 November 2019 Ceased on 31 December 2023 Date of birth August 1959 Nationality British Country of residence England Nature of control Ownership of voting rights - More than 25% but not more than 50% with control over the trustees of a trust”

“MARSHALL WACE ASSET MANAGEMENT LIMITED (03384699) Active, Correspondence address: George House, 131 Sloane Street, London, SW1X 9AT, Role: Resigned Director, Appointed on: 2 July 1997, Resigned on: 24 May 2022, Occupation: Fund Manager Registered office address George House, 131 Sloane Street, London, SW1X 9AT Company status Active Company type Private limited Company Incorporated on 11 June 1997Nature of business (SIC) 66300 - Fund management activities Previous company names AGENTHOW LIMITED 11 Jun 1997 - 03 Jul 1997 2 charges registered

0 outstanding, 2 satisfied, 0 part satisfied

Charge code 0338 4699 0002 Created 7 August 2023 Delivered 15 August 2023 Status Satisfied on 26 June 2024 Persons entitled Citibank Europe PLC, UK Branch Brief description Contains fixed charge…

Charge code 0338 4699 0001 Created 14 December 2021 Delivered 17 December 2021 Status Satisfied on 7 June 2024 Persons entitled Coutts & Company Brief description Contains fixed charge…

0 active persons with significant control / 1 active statement

• Statement Active The company knows or has reasonable cause to believe that there is no registrable person or registrable relevant legal entity in relation to the company Notified on 16 August 2017

• Mwam Uk Ltd Ceased Correspondence address George House, 131 Sloane Street, London, England, SW1X 9AT Notified on 6 April 2016 Ceased on 16 August 2017 Governing law Companies Act 2006 Legal form Private Limited Company Place registered Companies House Registration number 07659458 Incorporated in Uk Nature of control Ownership of shares – 75% or more”

“ST PAUL'S THEOLOGICAL CENTRE (05543940) Active, Correspondence address: SW14, (sic) Role: Resigned Director, Appointed on: 12 July 2007, Resigned on: 4 September 2017, Occupation: Chairman Asset Management Registered office address Holy Trinity Brompton, Brompton Road, London, SW7 1JA Company status Active Company type Private Limited Company by guarantee without share capital use of 'Limited' exemption Incorporated on 23 August 2005 Accounts (Up to date) Nature of business (SIC) 85590 - Other education not elsewhere classified

0 active persons with significant control / 0 active statements

• Ms Patricia Margaret Neill Ceased Correspondence address Holy Trinity Brompton, Brompton Road, London, SW7 1JA Notified on 6 April 2016 Ceased on 26 July 2023 Date of birth November 1950 Nationality British Country of residence England Nature of control Ownership of shares – More than 25% but not more than 50%

• Mr Nicholas Knyvett Lee Ceased Correspondence address Holy Trinity Brompton, Brompton Road, London, SW7 1JA Notified on 6 April 2016 Ceased on 8 July 2023 Date of birth February 1954 Nationality British Country of residence United Kingdom Nature of control Ownership of shares – More than 25% but not more than 50%

• Reverend Nicholas Glynn Paul Gumbel Ceased Correspondence address Holy Trinity Brompton, Brompton Road, London, SW7 1JA Notified on 6 April 2016 Ceased on 31 August 2022 Date of birth April 1955 Nationality British Country of residence England Nature of control Ownership of shares – More than 25% but not more than 50%”

“STANDARDS BOARD FOR ALTERNATIVE INVESTMENTS LIMITED (06465317) Active, Correspondence address: New Bridge Street House, 30-34 New Bridge Street, London, EC4V 6BJ, Role: Resigned Director, Appointed on: 1 February 2008, Resigned on: 30 October 2016, Occupation: Chairman Nature of business (SIC) 82990 - Other business support service activities not elsewhere classified Previous company names HEDGE FUND STANDARDS BOARD LIMITED 07 Jan 2008 - 29 Nov 2017 Registered office address 6th Floor 2 London Wall Place, Barbican, London, United Kingdom, EC2Y 5AU Company status Active Company type Private company limited by guarantee without share capital Incorporated on 7 January 2008 Accounts (Up to date)

0 active persons with significant control / 1 active statement Statement Active The company knows or has reasonable cause to believe that there is no registrable person or registrable relevant legal entity in relation to the company”

“FREEDOM MUSIC LIMITED (08415044) Dissolved, Correspondence address: SW14, (sic) Role: Resigned Director, Appointed on: 22 February 2013, Resigned on: 22 February 2014, Occupation: Fund Manager Dissolved on 17 April 2018 Company type Private limited Company Incorporated on 22 February 2013 Accounts Last accounts made up to 29 February 2016 Accounts Overdue Non-compliant (s441 CA2006) Nature of business (SIC) 59200 - Sound recording and music publishing activities Previous company names LIBERTA MUSIC TRADING LIMITED 13 Aug 2015 - 03 Oct 2015 GIOVANNA MUSIC TRADING LIMITED 22 Feb 2013 - 13 Aug 2015

1 person with significant control / 0 statements

Miss Giovanna Marshall Correspondence address 1a, Melbourn Street, Royston, Hertfordshire, England, SG8 7BP Notified on 22 February 2017 Date of birth October 1990 Nationality British Country of residence England Nature of control Ownership of shares – 75% or more with control over the trustees of a trust”

“ARK UK PROGRAMMES (05932797) Active, Correspondence address: 65 Kingsway, London, England, WC2B 6TD, Role: Resigned Director, Appointed on: 19 September 2006, Resigned on: 1 September 2013, Occupation: Fund Manager Registered office address 1 Edcity Edcity Walk, London, United Kingdom, W12 7TF Company status Active Company type Private Limited Company by guarantee without share capital use of 'Limited' exemption Incorporated on 12 September 2006

Accounts (Up to date) Nature of business (SIC) 85600 - Educational support services 88990 - Other social work activities without accommodation not elsewhere classified Previous company names ARK SCHOOLS 12 Sep 2006 - 01 Sep 2010

2 charges registered

2 outstanding, 0 satisfied, 0 part satisfied

• Charge code 0593 2797 0002 Created 15 December 2016 Delivered 20 December 2016 Status Outstanding Persons entitled J.P. Morgan International Bank Limited Brief description Contains fixed charge…

• Debenture Created 29 July 2009 Delivered 14 August 2009 Status Outstanding Persons entitled The New Aylesbury Trust Limited Short particulars All present and future undertaking and assets whatever and…

1 active person with significant control / 0 active statements

Absolute Return For Kids (Ark) Active Correspondence address 1 Nicholas Road, London, England, W11 4AN Notified on 14 April 2016 Governing law Companies Act Legal form Uk Registered Company And Uk Registered Charity Place registered Companies House Registration number 4589451 Incorporated in England Nature of control Has significant influence or control”

“LIBERAL DEMOCRAT BUSINESS FORUM LIMITED (04018993) Active, Correspondence address: SW14, (sic) Role: Resigned Director, Appointed on: 13 September 2000, Resigned on: 24 June 2009, Occupation: Fund Manager Registered office address 5th Floor 1 Vincent Square, London, England, SW1P 2NP Company status Active Company type Private company limited by guarantee without share capital Incorporated on 21 June 2000 Accounts (Up to date) Nature of business (SIC) 94920 - Activities of political organisations

0 active persons with significant control / 1 active statement

• Statement Active The company knows or has reasonable cause to believe that there is no registrable person or registrable relevant legal entity in relation to the company Notified on 21 June 2023

• Anthony William Harris Ceased Correspondence address Vincent Square, Vincent Square, 5th Floor, London, England, SW1P 2PN Notified on 18 June 2018 Ceased on 29 June 2022 Date of birth June 1957 Nationality British Country of residence England Nature of control Ownership of voting rights - 75% or more Right to appoint or remove directors

• Mr Peter Dunphy Ceased Correspondence address 2nd Floor, 8-10 Great George Street, London, SW1P 3AE Notified on 6 April 2016 Ceased on 18 June 2018 Date of birth June 1966 Nationality Uk Country of residence England Nature of control Ownership of voting rights - 75% or more ”

“PRAGMA WEALTH MANAGEMENT LTD. (04191349) Active, Correspondence address: SW14, (sic) Role: Resigned Director, Appointed on: 14 June 2001, Resigned on: 21 October 2004, Occupation: Director Nature of business (SIC) 66300 - Fund management activities Previous company names CHARCO 877 LIMITED 30 Mar 2001 - 09 Jul 2001 Registered office address The Scalpel, 18th Floor, 52 Lime Street, London, United Kingdom, EC3M 7AF Company status Active Company type Private limited Company Incorporated on 30 March 2001 Accounts (Up to date)

1 charge registered

0 outstanding, 1 satisfied, 0 part satisfied

Rent deposit deed Created 16 May 2011 Delivered 18 May 2011 Status Satisfied on 14 August 2019 Persons entitled Ebury & Eccleston Street Limited Short particulars The sum of £12,989.16…

0 active persons with significant control / 1 active statement

Statement Active The company knows or has reasonable cause to believe that there is no registrable person or registrable relevant legal entity in relation to the company Notified on 3 May 2022

Mrs Manuela Campedelli Ceased Correspondence address 1 Vere Street, London, United Kingdom, W1G 0DF Notified on 6 November 2018 Ceased on 25 April 2022 Date of birth March 1944 Nationality Italian Country of residence Italy Nature of control Ownership of shares – 75% or more Ownership of voting rights - 75% or more Right to appoint or remove directors”

“BLACKROCK INVESTMENT MANAGEMENT (UK) LIMITED (02020394) Active, Correspondence address: SW14, (sic) Role: Resigned Director, Appointed on: 30 May 1995, Resigned on: 8 August 1997, Occupation: Investment Director Registered office address 12 Throgmorton Avenue, London, EC2N 2DL Company status Active Company type Private limited Company Incorporated on 16 May 1986 Accounts Up to date Nature of business (SIC) 64999 - Financial intermediation not elsewhere classified 66300 - Fund management activities Previous company names MERRILL LYNCH INVESTMENT MANAGERS LIMITED 29 Sep 2000 - 02 Oct 2006 MERCURY ASSET MANAGEMENT LTD 30 Sep 1987 - 29 Sep 2000 MERCURY WARBURG INVESTMENT MANAGEMENT LTD. 01 Oct 1986 - 30 Sep 1987 TRUSHELFCO (NO. 978) LIMITED 16 May 1986 - 01 Oct 1986

1 active person with significant control / 0 active statements

Blackrock Finance Europe Limited Active Correspondence address 12 Throgmorton Avenue, London, United Kingdom, EC2N 2DL Notified on 17 August 2018 Governing law United Kingdom (England) Legal form Limited By Shares Place registered Companies House Registration number 07075607 Incorporated in England Nature of control Ownership of shares – 75% or more Ownership of voting rights - 75% or more Right to appoint or remove directors

Ultimately controlled through BLACKROCK INVESTMENT MANAGEMENT (UK) LIMITED, BLACKROCK FINANCE EUROPE LIMITED, BLACKROCK GROUP LIMITED, BLACKROCK FINCO UK LTD persons with significant control: Blackrock, Inc. Active Correspondence address 50 Hudson Yards, New York, Ny, United States, 10001 Notified on 6 April 2016 Governing law United States (Delaware) Legal form Corporation Place registered United States (Delaware) Registration number 32-0174431 Incorporated in Delaware Nature of control Ownership of shares – 75% or more as a member of a firm Ownership of voting rights - 75% or more as a member of a firm Right to appoint or remove directors as a member of a firm, see BLACKROCK GROUP LIMITED persons with significant control - Find and update company information - GOV.UK (company-information.service.gov.uk) ”

“MARSHALL WACE ASSET MANAGEMENT LIMITED (03384699) Active, Correspondence address: SW14, Role: Resigned Secretary, Appointed on: 2 July 1997, Resigned on: 16 July 1997, Occupation: Fund Manager Registered office address George House, 131 Sloane Street, London, SW1X 9AT Company status Active Company type Private limited Company Incorporated on 11 June 1997 Accounts Up to date Nature of business (SIC) 66300 - Fund management activities Previous company names AGENTHOW LIMITED11 Jun 1997 - 03 Jul 1997

2 charges registered

0 outstanding, 2 satisfied, 0 part satisfied

• Charge code 0338 4699 0002 Created 7 August 2023 Delivered 15 August 2023 Status Satisfied on 26 June 2024 Persons entitled Citibank Europe PLC, UK Branch Brief description Contains fixed charge…

• Charge code 0338 4699 0001 Created 14 December 2021 Delivered 17 December 2021 Status Satisfied on 7 June 2024 Persons entitled Coutts & Company Brief description Contains fixed charge…

0 active persons with significant control / 1 active statement

• Statement Active The company knows or has reasonable cause to believe that there is no registrable person or registrable relevant legal entity in relation to the company Notified on 16 August 2017

• Mwam Uk Ltd Ceased Correspondence address George House, 131 Sloane Street, London, England, SW1X 9AT Notified on 6 April 2016 Ceased on 16 August 2017 Governing law Companies Act 2006 Legal form Private Limited Company Place registered Companies House Registration number 07659458 Incorporated in Uk Nature of control Ownership of shares – 75% or more”

Accounts compliance conclusion:

Paul Roderick Clucas Marshall holds 20 appointments in this identity. Five of these are active and the accounts are up to date. There are ten resigned appointments in companies that are still active and these accounts are up to date. Five appointments are to companies which dissolved whilst he was an active director. These dissolved companies all have accounts overdue and/or final accounts not submitted, for which he is responsible. This describes five breaches of section 411 of the Companies Act 2006 relating to MW Eaglewood Management Limited, MWAM NA Ltd, MWAM UK Ltd, Every Child a Chance Trust, and Freedom Music Limited.

Similar names, “ARC” and “ARK”; potentially compromise section 66 of the Companies Act 2006.

The Alliance for Responsible Citizenship Limited refers to itself on its invitation and website as “ARC”. Absolute Return for Kids Limited uses the acronym “ARK” in other company registrations, as in ARK UK Programmes. There is potential for confusion between “ARC” and “ARK”. This is a potential breach of section 66 of the Companies Act.

Concerns and Risks

Paul Roderick Clucas Marshall holds extensive control over numerous companies. This raises concerns about potential conflicts of interest, governance challenges, and transparency issues. Particularly, five companies have been dissolved, with overdue accounts and / or final accounts not submitted, suggesting possible financial and operational risks.

Screening for multiple identities

A search in Companies House of the name “Paul Roderick Clucas MARSHALL” returns four identities with this name at the top of the search results, each with a different set of appointments and correspondence addresses (Paul Roderick Clucas MARSHALL - Find https://find-and-update.company-information.service.gov.uk/search/officers?q=Paul+Roderick+Clucas+MARSHALL). See image 4: Search results for Paul Roderick Clucas Marshall in Companies House on 30/09/2024.

Image 4: Search results for Paul Roderick Clucas Marshall in Companies House on 30/09/2024.

The twenty appointments listed above relate to the second identity listed here:

• “Sir Paul Roderick Clucas MARSHALL

  Total number of appointments 1 - Born August 1959

  131 Sloane Street, London, England, SW1X 9AT

• Paul Roderick Clucas MARSHALL

  Total number of appointments 20 - Born August 1959

  78 Pall Mall, London, England, SW1Y 5ES

• Sir Paul Roderick Clucas MARSHALL

  Total number of appointments 12 - Born August 1959

  6 Old Queen Street, London, England, SW1H 9HP

• Sir Paul Roderick Clucas MARSHALL

  Total number of appointments 1 - Born August 1959

  C/O Marshall Wace Llp, The Adelphi, 1-11 John Adam Street, London, United Kingdom, WC2N 6HT”

There are four unique identifiers (identities) registered in Companies House with the same four names, Paul Roderick Clucas Marshall, all born August 1959. If these are claimed identities of the same individual, then, Paul Marshall has committed three breaches of Section 1082 of the Companies Act 2006. This law requires a single unique identifier for each individual, and the existence of multiple identities raises concerns about compromised audits and possible involvement in organised crime. Only one identity / unique identifier is legitimate.

Paul Roderick Clucas MARSHALL additional identities

Below the Companies House records for these three additional identities, and a fourth named “Paul Marshall”, are expanded upon:

Sir Paul Roderick Clucas MARSHALL identity A

“Total number of appointments 1 - Born August 1959

CHURCH REVITALISATION TRUST (10754427) Company status Active Correspondence address 131 Sloane Street, London, England, SW1X 9AT Role Active Director Appointed on 4 May 2017 Nationality British Country of residence England Occupation None Registered office address Holy Trinity Brompton, Brompton Road, London, SW7 1JA Company status Active Company type Private Limited Company by guarantee without share capital use of 'Limited' exemption Incorporated on 4 May 2017. Accounts and Confirmations statement Up to date Nature of business (SIC) 94910 - Activities of religious organisations”

Paul Roderick Clucas MARSHALL identity B (This is the identity that is described above.)

Total number of appointments 20 - Born August 1959

78 Pall Mall, London, England, SW1Y 5ES

Sir Paul Roderick Clucas MARSHALL identity C

Total number of appointments 12 - Born August 1959

6 Old Queen Street, London, England, SW1H 9HP

“Total number of appointments 12

Current appointments 6

UNHERD FOUNDATION (13640717) Company status Active Correspondence address 6 Old Queen Street, London, England, SW1H 9HP Role Active Director Appointed on 24 September 2021 Nationality British Country of residence United Kingdom Occupation Fund Manager Nature of business (SIC) 96090 - Other service activities not elsewhere classified

2 active persons with significant control / 0 active statements

Mr Winston Aubrey Aladar Marshall Active Correspondence address 6 Old Queen Street, London, England, SW1H 9HP Notified on 24 September 2021 Date of birth December 1987 Nationality British Country of residence England Nature of control Ownership of voting rights - More than 25% but not more than 50%

Sir Paul Roderick Clucas Marshall Active Correspondence address 6 Old Queen Street, London, England, SW1H 9HP Notified on 24 September 2021 Date of birth August 1959 Nationality British Country of residence England Nature of control Ownership of voting rights - More than 25% but not more than 50%

AREOPAGUS VENTURES LIMITED (13101043) Company status Active Correspondence address 6 Old Queen Street, London, United Kingdom, SW1H 9HP Role Active Director Appointed on 29 December 2020 Occupation Fund Manager Nature of business (SIC) 64303 - Activities of venture and development capital companies

1 active person with significant control / 0 active statements

Unherd Ventures Limited Active Correspondence address 6 Old Queen Street, London, United Kingdom, SW1H 9HP Notified on 20 December 2021 Governing law Companies Act Legal form Limited Company Place registered Register Of Companies Registration number 12044066 Incorporated in United Kingdom Nature of control Ownership of shares – 75% or more Ownership of voting rights - 75% or more Right to appoint or remove directors

Sir Paul Roderick Clucas Marshall Ceased Correspondence address 84 Eccleston Square, London, England, SW1V 1PX Notified on 29 December 2020 Ceased on 20 December 2021 Date of birth August 1959 Nationality British Country of residence England Nature of control Ownership of shares – 75% or more Ownership of voting rights - 75% or more Right to appoint or remove directors

BEIKONIC LTD (12301660) Company status Active Correspondence address Knighton House, Ramsbury, Marlborough, England, SN8 2QB Role Active Director Appointed on 8 June 2020 Occupation Fund Manager Nature of business (SIC) 70100 - Activities of head offices Previous company names SYCAMOREBROOK LIMITED 06 Nov 2019 - 25 Feb 2020

OLD QUEEN STREET VENTURES LTD (12044066) Company status Active Correspondence address 6 Old Queen Street, London, England, SW1H 9HP Role Active Director Appointed on 11 June 2019 Occupation Fund Manager Nature of business (SIC) 64209 - Activities of other holding companies not elsewhere classified Previous company names UNHERD VENTURES LTD 11 Jun 2019 - 24 May 2024

UNHERD INSIGHT LIMITED (11862026) Company status Active Correspondence address 6 Old Queen Street, London, England, SW1H 9HP Role Active Director Appointed on 5 March 2019 Occupation None Supplied Nature of business (SIC) 82990 - Other business support service activities not elsewhere classified

UNHERD LIMITED (10678659) Company status Active Correspondence address 6 Old Queen Street, London, England, SW1H 9HP Role Active Director Appointed on 24 April 2018 Occupation Fund Manager Nature of business (SIC) 58190 - Other publishing activities 63990 - Other information service activities not elsewhere classified

ALL PERSPECTIVES LTD (12227760) Company status Active Correspondence address The Point, 37 North Wharf Road, London, United Kingdom, W2 1AF Role Resigned Director Appointed on 6 April 2021 Resigned on 23 April 2024 Occupation Fund Manager Nature of business (SIC) 60200 - Television programming and broadcasting activities

EDCITY MANAGEMENT COMPANY LIMITED (11528726) Company status Active Correspondence address Marshall Wace Asset Management Limited, George House, 131 Sloane Street, London, United Kingdom, SW1X 9AT Role Resigned Director Appointed on 21 August 2018 Resigned on 18 October 2023 Occupation Fund Manager Nature of business (SIC) 68320 - Management of real estate on a fee or contract basis

B-IKONIC IBIZA LTD (14385962) Company status Active Correspondence address Knighton House, Ramsbury, Marlborough, United Kingdom, SN8 2QB Role Resigned Director Appointed on 29 September 2022 Resigned on 19 October 2022 Occupation Director Nature of business (SIC) 70100 - Activities of head offices

EDCITY OFFICE (11596797) Company status Active Correspondence address Marshall Wace Asset Management Limited, George House, 131 Sloane Street, London, United Kingdom, SW1X 9AT Role Resigned Director Appointed on 1 October 2018 Resigned on 20 July 2022 Occupation Fund Manager Nature of business (SIC) 68209 - Other letting and operating of own or leased real estate

ST PAUL'S THEOLOGICAL CENTRE (05543940) Company status Active Correspondence address Holy Trinity Brompton, Brompton Road, London, SW7 1JA Role Resigned Director Appointed on 24 April 2020 Resigned on 13 October 2021 Occupation Fund Manager Nature of business (SIC) 85590 - Other education not elsewhere classified

EDCITY DEVELOPMENT LIMITED (11511870) Company status Active Correspondence address Marshall Wace Asset Management Limited, George House, 131 Sloane Street, London, United Kingdom, SW1X 9AT Role Resigned Director Appointed on 10 August 2018 Resigned on 13 September 2021 Occupation Fund Manager Nature of business (SIC) 41100 - Development of building projects Previous company names EDCITY LIMITED 10 Aug 2018 - 21 Aug 2018”

Sir Paul Roderick Clucas MARSHALL identity D

Total number of appointments 1 - Born August 1959

C/O Marshall Wace Llp, The Adelphi, 1-11 John Adam Street, London, United Kingdom, WC2N 6HT

“ALLCHILD LIMITED (08991196) Company status Active Correspondence address C/O Marshall Wace Llp, The Adelphi, 1-11 John Adam Street, London, United Kingdom, WC2N 6HT Role Resigned Director Appointed on 10 April 2014 Resigned on 27 June 2017 Nationality British Country of residence United Kingdom Occupation Chief Investment Officer Nature of business (SIC) 85590 - Other education not elsewhere classified Previous company names WEST LONDON ZONE 10 Apr 2014 - 15 May 2024”

Paul MARSHALL identity E

Paul MARSHALL personal appointments - Find and update company information - GOV.UK (company-information.service.gov.uk)

Total number of appointments 1

FREEDOM MUSIC LIMITED (08415044) Company status Dissolved Correspondence address SW14 (sic) Role Resigned Secretary Appointed on 22 February 2013 Resigned on 22 February 2014

Potential conflict of interests

Analysis of potential conflicts of interest involving Sir Paul Marshall, focusing on the nature of business of the company appointments held in multiple identities, using SIC codes:

Identity A: Paul Roderick Clucas Marshall

• Church Revitalisation Trust (10754427)
  SIC: 94910 - Activities of religious organizations

Identity B: Paul Roderick Clucas Marshall

• Alliance for Responsible Citizenship Limited (10519995)
  SIC: 85520 - Cultural education

• ARK Academies Projects Limited (04101629)
  SIC: 41100 - Development of building projects, 85100 - Pre-primary education

• Marshall Wace LLP (OC302228)
  SIC: Not specified (likely financial services)

• Absolute Return for Kids (ARK) (04589451)
  SIC: 85600 - Educational support services, 86900 - Other human health activities

• Pimpernel and Partners Limited (02361343)
  SIC: 47791 - Retail sale of antiques including antique books in stores

• Ark Schools (05112090)
  SIC: 85100 - Pre-primary education, 85200 - Primary education, 85310 - General secondary education

• Education Policy Institute (04579498)
  SIC: 85590 - Other education not elsewhere classified

• Marshall Wace Asset Management Limited (03384699)
  SIC: 66300 - Fund management activities

• MW Eaglewood Management Limited (08743417) - Dissolved
  SIC: 64205 - Activities of financial services holding companies

• MWAM NA LTD (07659460) - Dissolved
  SIC: 66300 - Fund management activities

• MWAM UK LTD (07659458) - Dissolved
  SIC: 66300 - Fund management activities

• Every Child a Chance Trust (06434237) - Dissolved
  SIC: 85200 - Primary education

• Freedom Music Limited (08415044) - Dissolved
  SIC: 59200 - Sound recording and music publishing activities

• ARK UK Programmes (05932797)
  SIC: 85600 - Educational support services, 88990 - Other social work activities without accommodation not elsewhere classified

• Liberal Democrat Business Forum Limited (04018993)
  SIC: 94920 - Activities of political organisations

• Pragma Wealth Management Ltd. (04191349)
  SIC: 66300 - Fund management activities

• BlackRock Investment Management (UK) Limited (02020394)
  SIC: 64999 - Financial intermediation not elsewhere classified, 66300 - Fund management activities

• St Paul's Theological Centre (05543940)
  SIC: 85590 - Other education not elsewhere classified

• Standards Board for Alternative Investments Limited (06465317)
  SIC: 82990 - Other business support service activities not elsewhere classified

Identity C: Paul Roderick Clucas Marshall

• UnHerd Foundation (13640717)
  SIC: 96090 - Other service activities not elsewhere classified

• Areopagus Ventures Limited (13101043)
  SIC: 64303 - Activities of venture and development capital companies

• Beikonic Ltd (12301660)
  SIC: 70100 - Activities of head offices

• Old Queen Street Ventures Ltd (12044066)
  SIC: 64209 - Activities of other holding companies not elsewhere classified

• UnHerd Insight Limited (11862026)
  SIC: 82990 - Other business support service activities not elsewhere classified

• UnHerd Limited (10678659)
  SIC: 58190 - Other publishing activities, 63990 - Other information service activities not elsewhere classified

• All Perspectives Ltd (12227760)
  SIC: 60200 - Television programming and broadcasting activities

• EdCity Management Company Limited (11528726)
  SIC: 68320 - Management of real estate on a fee or contract basis

• B-Ikonic Ibiza Ltd (14385962)
  SIC: 70100 - Activities of head offices

• EdCity Office (11596797)
  SIC: 68209 - Other letting and operating of own or leased real estate

• EdCity Development Limited (11511870)
  SIC: 41100 - Development of building projects

Identity D: Sir Paul Roderick Clucas Marshall

• AllChild Limited (08991196)
  SIC: 85590 - Other education not elsewhere classified

Identity E: Paul MARSHALL

• Freedom Music Limited (08415044) Dissolved
  SIC: 59200 - Sound recording and music publishing activities

Based on the provided information, there is evidence suggesting that Sir Paul Roderick Clucas Marshall has placed potentially conflicting interests in separate identities, which could be interpreted as an attempt to conceal conflicts of interest. Here are the key observations:

1. Religious and Educational Activities:
   The Church Revitalisation Trust's religious focus (SIC 94910) may conflict with secular educational initiatives in ARK Academies, Ark Schools, and the Education Policy Institute. This could lead to tensions in curriculum development and resource allocation.

2. Media and Education:
   Identity C includes directorships in UnHerd Foundation, UnHerd Insight Limited, and UnHerd Limited (media and publishing), while Identity B holds the directorship of Alliance for Responsible Citizenship Limited (cultural education). This separation could be interpreted as an attempt to keep media influence and educational initiatives separate. However, this could influence public opinion on educational policies, potentially conflicting with Marshall's roles in educational charities and institutions.

3. Financial and Venture Capital:
   Identity B includes membership in Marshall Wace LLP (fund management), while Identity C holds a directorship in Areopagus Ventures Limited (venture capital). This separation could be seen as an attempt to keep different financial interests distinct.

4. Financial and Educational Interests: Marshall's involvement in financial services (Marshall Wace LLP, Marshall Wace Asset Management) could influence investment decisions related to educational projects (ARK, Ark Schools), potentially prioritizing financial returns over educational outcomes.

5. Political Connections: His past involvement with the Liberal Democrat Business Forum could create perceived biases in his educational and media ventures, potentially compromising their independence.

6. Real Estate and Education:
   Identity C previously held directorships in EdCity Management Company Limited and EdCity Office (real estate management), while Identity B includes directorships in educational projects. This separation could be interpreted as an attempt to keep real estate interests separate from educational initiatives.

7. Broadcasting and Education:
   Identity C previously held a directorship in All Perspectives Ltd (television programming), while Identity B includes educational and cultural directorships. This separation could be seen as an attempt to keep broadcasting interests separate from educational initiatives.

8. Venture Capital and Media: Areopagus Ventures' activities could influence investment in media companies (UnHerd, All Perspectives), potentially compromising editorial independence.

9. Antiques and Education: Pimpernel and Partners' antique business could create conflicts in decisions about historical education or museum partnerships within educational initiatives.

10. Music and Education: Past involvement in Freedom Music Limited could influence decisions about music education programs in schools.

11. International Influence: B-Ikonic Ibiza suggests international business interests, which could conflict with UK-focused educational and cultural initiatives.

12. Policy Influence: Roles in the Education Policy Institute and Standards Board for Alternative Investments provide platforms to influence both education and financial sector policies, potentially creating conflicts between these sectors.

The deliberate creation of multiple identities with similar names and birth dates, combined with the strategic placement of potentially conflicting interests across these identities, strongly suggests an intentional effort to conceal conflicts of interest. This practice raises significant governance and transparency concerns

Summary of Active companies for Paul Roderick Clucas Marshall in Companies House, to be used for comparison with his declaration of interests:

Identity A. Paul Roderick Clucas Marshall Born August 1959 Address: 131 Sloane Street, London, SW1X 9AT

• Church Revitalisation Trust (10754427): Director, Appointed on 4 May 2017

Identity B Paul Roderick Clucas Marshall Born August 1959 Address: 78 Pall Mall, London, SW1Y 5ES

• Alliance for Responsible Citizenship Limited (10519995): Director, Appointed on 12 Dec 2016

• ARK Academies Projects Limited (04101629): Director, Appointed on 15 May 2007

• Marshall Wace LLP (OC302228): LLP Member, Appointed on 1 Sep 2003

• Absolute Return for Kids (ARK) (04589451): Director, Appointed on 13 Nov 2002

• Pimpernel and Partners Limited (02361343): Secretary, Appointed before 15 Mar 1992

Identity C. Paul Roderick Clucas Marshall Born August 1959 Address: 6 Old Queen Street, London, SW1H 9HP

• UnHerd Foundation (13640717): Director, Appointed on 24 Sep 2021

• Areopagus Ventures Limited (13101043): Director, Appointed on 29 Dec 2020

• Beikonic Ltd (12301660): Director, Appointed on 8 Jun 2020

• Old Queen Street Ventures Ltd (12044066): Director, Appointed on 11 Jun 2019

• UnHerd Insight Limited (11862026): Director, Appointed on 5 Mar 2019

• UnHerd Limited (10678659): Director, Appointed on 24 Apr 2018

The assessment of Sir Paul Marshall’s disclosure of interests will consider these active interests. Disclosure of past interests are not considered herein.

Sir Paul Marshall’s disclosures on the Alliance for Responsible Citizenship Limited’s website

The biography for Paul Roderick Clucas Marshall is copied below from the Alliance for Responsible Citizenship Limited’s website (Advisory Board — Alliance for Responsible Citizenship (ARC) https://www.arcforum.com/advisory-board):

“Sir Paul Marshall is CIO and Chairman of Marshall Wace LLP, founder and owner of UnHerd Media, and an investor in GB News Ltd. He is a founding Trustee of Ark, a children’s educational charity, and founder of the Marshall Institute at the LSE.”

Summary of Interests Disclosed on Alliance for Responsible Citizenship Limited's Website:

• Advisory Board of Alliance for Responsible Citizenship Limited

• CIO and Chairman of Marshall Wace LLP

• Founder and owner of UnHerd Media

• Investor in GB News Ltd

• Founding Trustee of Ark

• Founder of the Marshall Institute at the LSE

Transparency Assessment of directorships registered in Companies House compared to disclosure on the ARC website:

In this assessment company directorships that are omitted from Sir Paul Marshall’s biography will be notified as Non-compliant (HLCC2023) since they breach transparency principles as defined in the Lords’ Code of Conduct.

Identity A (Born August 1959, Address: 131 Sloane Street, London, SW1X 9AT)

• Church Revitalisation Trust (10754427) Director, Appointed on 4 May 2017

Marshall failed to disclose his active directorship at the Church Revitalisation Trust, a role held since 4 May 2017. Non-compliant (HLCC2023).

Identity B (Born August 1959, Address: 78 Pall Mall, London, SW1Y 5ES)

• Alliance for Responsible Citizenship Limited (10519995): Director, Appointed on 12 Dec 2016

Whilst Paul Roderick Clucas Marshall is named as a member of the “Advisory Board” on this company’s website, he failed to disclose that his role is as a director of Alliance for Responsible Citizenship Limited. Non-compliant (HLCC 2023).

• ARK Academies Projects Limited (04101629): Director, Appointed on 15 May 2007

Whilst he declares “Founding Trustee of Ark” his disclosure does not include his directorship of Ark Academies Projects Limited, appointed 15 May 2007. He has failed to disclose Ark Academies Projects Limited. Non-compliant (HLCC2023).

• Marshall Wace LLP (OC302228): LLP Member, Appointed on 1 Sep 2003

His declaration “CIO and Chairman of Marshall Wace LLP” infers that he is a member of Marshall Wace LLP. Compliant (HLCC2023).

• Absolute Return for Kids (ARK) (04589451): Director, Appointed on 13 Nov 2002

This company has the same name as the charity, of which he discloses he is a trustee. He has failed to declare that he is a director of a company called Absolute Return for Kids (ARK). Non-compliant (HLCC2023)

• Pimpernel and Partners Limited (02361343): Secretary, Appointed before 15 Mar 1992

Paul Roderick Clucas Marshall failed to declare that he is a director of Pimpernel and Partners since 15 March 1992. Non-compliant (HLCC2023)

Identity C (Born August 1959, Address: 6 Old Queen Street, London, SW1H 9HP)

Active appointments summary: UnHerd Foundation, UnHerd Insight Limited, UnHerd Limited Areopagus Ventures Limited, Beikonic Ltd, Old Queen Street Ventures Ltd.

Paul Roderick Clucas Marshall discloses that he is “founder and owner of UnHerd Media”. He has failed to disclose that he is a director of three companies with similar names, Unherd Foundation, Unherd Insight Limited and Unherd Limited; none of which are called “Unherd Media”. 3 times Non-compliant (HLCC2023)

Additionally, Paul Roderick Clucas Marshall has failed to disclose Areopagus Ventures Limited, Beikonic Ltd and Old Queen Street Ventures Ltd. 3 times non-compliant (HLCC2023)

(The appointments in identity D and E are not active.)

Sir Paul Marshall omitted eleven active interests from his biography which are held in Companies House in three unique identifiers. These are:

• Identity A: Church Revitalisation Trust

• Identity B: Alliance for Responsible Citizenship Limited, ARK Academies Projects Limited, Absolute Return for Kids (ARK), Pimpernel and Partners Limited.

• Identity C: All active appointments omitted: UnHerd Foundation, UnHerd Insight Limited, UnHerd Limited, Areopagus Ventures Limited, Beikonic Ltd, Old Queen Street Ventures Ltd.

Identities B, C and E are claimed by Sir Paul Marshall:

Sir Paul Marshall declares interests on the ARC website that refers to companies registered to unique identities for Paul Roderick Clucas Marshall: Identity B includes Marshall Wace and ARK, and identity C, includes Unherd Media. Therefore, we can conclude that identities B and C are “claimed” identities of Sir Paul Marshall. Identity E holds an appointment as secretary at Freedom Music Limited, an interest to which he is appointed as director in identity B, so this is certainly another identity for the same individual.

Analysis to ascertain whether Sir Paul Marshall is associated to Church Revitalisation Trust (Identity A).

The website for the Church Revitalisation Trust was located using a search engine. Sir Paul Marshall’s biography is provided under “Trustees”, Meet our team (crtrust.co) (https://crtrust.co/about/meet-our-team/):

“Sir Paul Marshall is the Chairman and CIO of Marshall Wace, a hedge fund. He is also the Chairman of Ark Schools, a chain of 40 academies, and founder of the Education Policy Institute and of the Marshall Institute for Philanthropy and Social Entrepreneurship. Paul is married to Sabina and they have been worshipping at HTB since 1997. They have two children.”

Transparency Assessment of Sir Paul Marshall’s CRT biography:

Identity A: Whilst Sir Paul Marshall discloses that he is a trustee of Church Revitalisation Trust, he omits that he is a director of a company with the same name, held in his identity A. Non-compliant (HLCC2023).

Identity B: Whilst he discloses Marshall Wace, this is inaccurate as, he omits “LLP”. Non-compliant (HLCC2023). He discloses he is Chairman of Ark Schools and omits his directorships of ARK Academies Projects Limited and Absolute Return for Kids (ARK). 2 times non-compliant (HLCC2023). He omits Alliance for Responsible Citizenship Limited and Pimpernel and Partners Limited. 2 times non-compliant (HLCC2023).

Sir Paul Marshall fails to disclose any of the active appointments held in Identity C: UnHerd Foundation, Areopagus Ventures Limited, Beikonic Ltd, Old Queen Street Ventures Ltd, UnHerd Insight Limited, UnHerd Limited. 6 times Non-compliant (HLCC2023).

Summary of transparency assessment of Sir Paul Marshall’s biography on the Church Revitalisation Trust website:

Sir Paul Marshall omits that he is a director of a company called Church Revitalisation Trust in identity A. He inaccurately discloses interests held in identity B; “Marshall Wace”, omitting “LLP”, ARK Academies Projects Limited and Absolute Return for Kids (ARK), Alliance for Responsible Citizenship Limited and Pimpernel and Partners Limited. He omits all the active appointments held in Identity C: UnHerd Foundation, Areopagus Ventures Limited, Beikonic Ltd, Old Queen Street Ventures Ltd, UnHerd Insight Limited, UnHerd Limited. 12 times non-compliant (HLCC2023).

Trading Disclosures Compliance Assessment of the Church Revitalisation Trust website:

1. Company's Registered Name: Declares both the charity and the company with this name. Compliant (CDTR 2015)

2. Company Registration Number: Both provided. Compliant (CDTR 2015).

3. Place of Registration: Compliant (CDTR 2015).

4. Registered Office Address: "HTB” provided in the address, as shorthand for “Holy Trinity Brompton”. Non-compliant (CDTR 2015)

5. Directors' Names: Discrepancies. Non-compliant (CDTR 2015). See “Quick compliance review”, below.

6. Share Capital Information: None declared. Compliant (CDTR 2015).

Church Revitalisation Trust Website is non-compliant with Trading Disclosure regulations under CTDR 2015.

Quick compliance review of Church Revitalisation Trust:

The trustees are listed at the bottom of the webpage which describes all of “The Team” members associated with Church Revitalisation Trust (Meet our team (crtrust.co)). There are three team members who have the title “Director” e.g. “Mark Elsdon-Dew Director of Planting”, “Andrew Parsons Director of Building Development” and “Tom Lane Director of Network Development”. This is misleading as they are not directors of the Church Revitalisation Trust. The directors and secretary of Church Revitalisation Trust, however, are not disclosed on the website. Since they declare some “directors”, on the website, the Trust are obliged to declare all the actual directors as part of there Trading Disclosures obligations.

Note on Nicholas Glynn Paul GUMBEL:

Note that there is a Trustee listed on the Church Revitalisation Trust website, “Nicky Gumbel” who resigned on 31 August 2022, Nicholas Glynn Paul GUMBEL (company-information.service.gov.uk). Accessing the Charities Register, confirms that he is not listed as a trustee (CHURCH REVITALISATION TRUST - 1174882 (charitycommission.gov.uk). Since Nicholas Grumbel resigned 31 August 2022 he should no longer be listed on the website as a trustee. Non-compliant HLCC 2023.

In this identity Nicholas Gumbel is associated to eight companies, two of which are dissolved with accounts overdue and final accounts not submitted (Nicholas Glynn Paul GUMBEL personal appointments - GOV.UK (company-information.service.gov.uk)). These are: CARING FOR EX OFFENDERS (05265071) and HOLY TRINITY BROMPTON DEVELOPMENTS LIMITED (05559730). Two times non-compliant (s441:CA2006).

Nicholas (Nicky) Gumbel has two identities registered in Companies House (Nicholas Glynn Paul GUMBEL - Find). His second identity holds a directorship of The William Wilberforce Trust. (Nicky GUMBEL personal appointments). Non-compliant s1082:CA2006.

Compliance concern, a potential safe-guarding risk: Given the nature of business of these companies Nicholas Gumbel presents a potentially high risk to vulnerable people. This safeguarding implication urgently requires specific actions to address these risks.

The secretary of the Church Revitalisation Trust, Jonathan Mark SHIPPEN (company-information.service.gov.uk), appears to hold fourteen unique identifiers (Jonathan Mark SHIPPEN - Find (company-information.service.gov.uk)). Thirteen times non-compliant (s1082:CA2006). Further investigation is indicated as necessary,

Sir Paul Marshall Unique Identifier Compliance Assessment Conclusion

Sir Paul Marshall’s biography on the Church Revitalisation Trust (CRT) website discloses an interest that is appointed to his Identity B, Marshall Wace LLP. This confirms that Paul Roderick Clucas Marshall Identity A is a third identity of Sir Paul Marshall. He has breached section 1082 of the Companies Act 2006, which requires a single identity.

Given that Sir Paul Marshall has established three identities with the name Paul Roderick Clucas Marshall, born August 1959, the fourth identity, with the same names and date of birth, on balance of probabilities, is also an identity of Sir Paul Marshall. He has a fifth identity that is appointed to the same company as identity B, Freedom Music Limited, so certainly belongs to the same person. Three, likely four times non-compliant (s1082 CA2006).

Trading Disclosures Compliance Assessment: Alliance for Responsible Citizenship Limited website

The company website footer provides the following information: “Alliance for Responsible Citizenship Limited is a limited company incorporated in England and Wales. Company number: 10519995”. The contact details provides “78 Pall Mall, London, SW1Y 5ES, United Kingdom”.

1. Company's Registered Name: The website footer correctly displays "Alliance for Responsible Citizenship Limited." Compliant (CTDR 2015).

2. Company Registration Number: The registration number "10519995" is provided. Compliant (CTDR 2015).

3. Place of Registration: The company is identified as incorporated in England and Wales. Compliant (CTDR 2015).

4. Registered Office Address: The address "78 Pall Mall, London, SW1Y 5ES, United Kingdom" is listed. Compliant (CTDR 2015).

5. Directors' Names: Non-compliant. The company's website lists the directors as two of fifty-three members of ARC’s “Advisory Board," but does not disclose that they are directors of the company. This omission can be misleading, as stakeholders may not be aware of the directors' official roles and responsibilities within the company. Non-compliant (CTDR 2015).

6. Share Capital Information: Compliant. Since share capital information is not mentioned, this is compliant as it is not required unless share capital details are voluntarily disclosed. Compliant (CTDR 2015).

The website of the Alliance for Responsible Citizenship Limited has one breach of Trading Disclosure standards by publishing Sir Paul Marshall’s biography, as one of an Advisory Board with fifty-three members, without disclosing that he is a director.

Based on the provided information, Sir Paul Marshall failed to declare several interests across multiple identities, concealing significant conflicts of interest. Here's an analysis of the undeclared interests and the conflicts they reveal:

Undeclared Interests and Associated Conflicts

Religious and Educational Sector Conflicts

Sir Paul Marshall failed to disclose his directorship of the Church Revitalisation Trust (Identity A) while simultaneously holding positions in secular educational organizations (Identity B). This conceals potential conflicts between:

• Religious activities (SIC 94910) of the Church Revitalisation Trust

• Secular educational initiatives of ARK Academies Projects Limited (SIC 41100, 85100)

• Cultural education focus of Alliance for Responsible Citizenship Limited (SIC 85520)

These undisclosed connections could lead to conflicts in curriculum development, resource allocation, and overall educational philosophy.

Media and Education Sector Conflicts

Sir Paul Marshall omitted his directorships in media-related companies (Identity C) while holding positions in educational organizations (Identity B). This conceals conflicts between:

• Media influence through UnHerd Foundation, UnHerd Insight Limited, and UnHerd Limited

• Educational policy-making through Alliance for Responsible Citizenship Limited and ARK-related entities

This undisclosed overlap could lead to biased information dissemination and undue influence on educational policies.

Financial and Educational Sector Conflicts

The failure to disclose financial interests alongside educational roles conceals conflicts between:

• Investment activities through Areopagus Ventures Limited (SIC 64303) and Old Queen Street Ventures Ltd (SIC 64209)

• Educational initiatives through ARK Academies Projects Limited and Absolute Return for Kids (ARK)

This non-disclosure could hide potential conflicts in financial decision-making that may impact educational outcomes.

Political and Educational Conflicts

By not disclosing his involvement with the Liberal Democrat Business Forum Limited alongside his educational roles, Sir Paul Marshall concealed potential conflicts between:

• Political activities (SIC 94920)

• Educational policy-making and implementation through various ARK entities and the Alliance for Responsible Citizenship Limited

This omission could mask political influences on educational initiatives.

Implications of Concealed Conflicts

1. Compromised decision-making: The undisclosed conflicts could lead to biased decisions that prioritize certain interests over others without proper scrutiny.

2. Lack of transparency: Stakeholders are unable to make fully informed decisions due to the hidden interconnections between various sectors.

3. Potential misuse of resources: Resources from one sector (e.g., education) could be inappropriately directed to benefit interests in another sector (e.g., media or finance).

4. Undermined public trust: The deliberate concealment of these conflicts erodes public confidence in the integrity of educational, religious, and media institutions.

5. Regulatory concerns: The failure to disclose these conflicts may violate various regulatory requirements, potentially leading to legal and reputational consequences.

By maintaining multiple identities and selectively disclosing interests, Sir Paul Marshall has effectively created a complex web of influence across religious, educational, media, and financial sectors while concealing the full extent of his control and potential conflicts of interest

Beikonic Ltd and Beikonic LP: breach section 66

A search on Beikonic Ltd returns a second company with this name, registered as a Limited Partnership (https://find-and-update.company-information.service.gov.uk/search?q=Beikonic). The overview information is:

• BEIKONIC LP

  LP023602 - Registered on 19 March 2024

  48 Rose Square Fulham Road, London, England, SW3 6RS

• BEIKONIC LTD

  12301660 - Incorporated on 6 November 2019

  48 Rose Square Fulham Road, London, England, SW3 6RS

Breach: Beikonic Ltd is essentially the same name as Beikonic LP. This finding of duplicated company names is a breach of Section 66 of the Companies Act 2006 by the directors of Beikonic LP who registered this company on 19 March 2024. There is a risk of clone company fraud, related to Beikonic Ltd and Beikonic LP.

There is an anomaly with this company records in Companies House for Beikonic LP as there is no information relating to the officers of this company (https://find-and-update.company-information.service.gov.uk/company/LP023602). This is a breach of the Companies Act which requires that officers of companies are listed.

The certificate of registration of a Limited Partnership is provided in the filing history (BEIKONIC LP filing history (company-information.service.gov.uk).

Page 2 lists, as general partner, “Jka Seed Holding Limited” and states that the two limited partners are “Sir Paul Roderick Clucas Marshal and Damien Anthony Donohoe.” The general nature of business is given a “Carry on the business of an investor and, in particular, of identifying, negotiating, making, monitoring and realising investment and carry out all function and act in connection therewith, and such other activities as may be agreed by all the partners of the firm from time to time.” The form is presented by “King & Spalding International LLP, 125 Old Bond Street, London, EC2N1AR, United Kingdom”.

Further analysis of Damien Anthony Donohoe, partner at BEIKONIK LP.

Whilst Damien Anthony Donohoe is referenced in the incorporation document as a partner of Beikonik LP, he is not registered as a director of this company within the “Officers” record for this company. This is a breach of the Companies Act 2006.

A search for “Damien Anthony Donohoe” locates zero identities registered with this name (https://find-and-update.company-information.service.gov.uk/search/officers?q=Damien+Anthony+Donohoe).

A search of “Damien Donohoe” (https://find-and-update.company-information.service.gov.uk/search/officers?q=damien+donohoe) returns two identities which include these three names with date of birth

• Damien Patrick O' DONOHOE

  Total number of appointments 1 - Born April 1966

  26 Grosvenor Street, Mayfair, London, England, W1K 4QW

• Damien Patrick Thomas O DONOHOE

  Total number of appointments 5 - Born April 1966

  54 Emlyn Road, London, W12

The identity Damien Patrick Thomas O DONOHOE has a space after “O” whereas Damien Patrick O'DONOHOE has an apostrophe. These are materially the same names and with a date of birth in common there is sufficient evidence to conclude that these are two identities for the same person who is in breach of Section 1082 of the Companies Act 2006. Whether or not he is a related party of Damien Anthony Donohoe is inconclusive, clarification of this is requested.

A search of Damien Anthony O’Donohoe (https://find-and-update.company-information.service.gov.uk/search/officers?q=Damien+Anthony+O%27Donohoe) returns three identities with name and date of birth January 1981.

• Damien Anthony O'DONOHOE

  Total number of appointments 1 - Born February 1981

  48 Rose Square, Fulham Road, South Kensington, London, SW3 6RS

  • B-IKONIC IBIZA LTD (14385962) Role Active Director Appointed on

    29 September 2022

• Damien Anthony O'DONOHOE

  Total number of appointments 1 - Born January 1981

  Knighton House, Ramsbury, Marlborough, Wiltshire, SN8 2QB

  • BEIKONIC LTD (12301660) Role Active Director Appointed on 8 June 2020

• Damien Anthony O'DONOHOE

  Total number of appointments 1 - Born January 1981

  88/90 Baker Street, London, United Kingdom, W1U 6TQ

  • 1573 CIGARS LIMITED (14251253) Role Active Director Appointed on 22 July 2022 Registered office address International House International House (sic), 64 Nile Street, London, United Kingdom, N1 7SR Company status Active Company type Private limited Company Incorporated on 22 July 2022 Nature of business (SIC) 46350 - Wholesale of tobacco products

This is certainly the correct person as Damien O’Donohoe, partner of BEIKONIC LP because he is associated to BEIKONIC Ltd and B-Ikonic Ibiza Ltd and Sir Paul Roderick Clucas MARSHALL is a director of B-Ikonic Ibiza in his identity C.

The registered office address of 1573 CIGARS LIMITED contains an error, a duplication of “International House”. This is a breach of the Companies Act which requires a legitimate address, correctly presented. The duplication is a red flag for potential trafficking in illegal goods and persons, as duplications, like this, are also known as a code, evident to complicit customs officials and carriers in illegal supply chains.

Damien Anthony Donohoe born January 1981 breaches section 1082 of the Companies Act 2006 by having registered his companies under three unique identities in Companies House. He has compromised audits and KYC checks associated to him and his companies. He has also failed to register his directorship of BEIKONIC LP, as an officer in Companies House. He represents a high risk for money laundering, terrorism financing and people trafficking.

Further analysis of JKA Seed Holdings Limited and King Spalding International LLP, companies referenced within the incorporation documents of BEIKONIC LP.

JKA Seed Holding Limited

A search for JKA Seed Holding Limited, does not return a company registered with this name (https://find-and-update.company-information.service.gov.uk/search/companies?q=JKA+seed+holding+limited). However, it does return two companies with effectively the same name, JKA Holdings Limited and JKA Holdings Ltd:

• JKA HOLDINGS LIMITED

  12039558 - Dissolved on 28 March 2023

  Halfway Cottage, Bredons Hardwick, Tewkesbury, Gloucestershire, United Kingdom, GL20 7EE Dissolved on 28 March 2023 Incorporated on 7 June 2019 Accounts Last accounts made up to 30 June 2021 Nature of business (SIC) 68209 - Other letting and operating of own or leased real estate Accounts overdue made up to 30 June 2022 and to dissolution on 28 March 2023

• JKA HOLDINGS LTD

  06157537 - Dissolved on 10 February 2015

  21 Carlton Crescent, Southampton, Hampshire, SO15 2ET Dissolved on

  10 February 2015 Company type Private limited Company Incorporated on 13 March 2007 Accounts Last accounts made up to 31 July 2013 Accounts made up to 31 July 2014 and to dissolution on 10 February 2015 overdue Annual return Last annual return made up to 13 March 2014 Nature of business (SIC)

  64209 - Activities of other holding companies not elsewhere classified

  70100 - Activities of head offices

  Previous company names

  EURO MEDIA AND COMMUNICATIONS LTD 13 Mar 2007 - 10 Apr 2008

The officers appointed to JKA Holdings Limited and JKA Holdings Ltd breach section 441 of the Companies Act 2006 for failing to provide accounts made up to the dissolution of these companies. The officers of JKA Holdings Limited have potentially breached section 66 of the Companies Act 2006 by registering a company with a name that has already been used in the Companies House index, by JKA Holdings Ltd. The combined risk of potentially still active bank accounts and a potential clone company with potentially still active bank accounts requires investigation. Investigation should include assessing all the officers for multiple identities to discover their span of interests and control.

Further analysis of these companies’ officers is required because they are associated to BEIKONIC LP, with reference to the incorporation of this company, however this is not correctly registered in the officer record in Companies House, which is a breach of the Companies Act 2006.

King Spalding International LLP

KING & SPALDING INTERNATIONAL LLP

Company number OC303151

Registered office address 8 Bishopsgate, London, England, EC2N 4BQ Company status Active Company type Limited liability partnership Incorporated on 10 October 2002 Accounts Up to date 106 officers / 66 resignations (https://find-and-update.company-information.service.gov.uk/company/OC303151/officers)

There are forty active officers of King & Spalding International LLP. These officers also require assessment for multiple identities. There are too many active officers to analyse manually, herein. Therefore, The first officer listed in the Companies House record for King & Spalding International LLP, William Francis Charnley is analysed below, only.

William Francis CHARNLEY

(https://find-and-update.company-information.service.gov.uk/officers/2IlYAOIQ3PVt5RyMecUZFlff9sQ/appointment)

Total number of appointments 15

Current appointments 5

Date of birth August 1960

KING & SPALDING INTERNATIONAL LLP (OC303151) Company status Active Correspondence address 8 Bishopsgate, London, England, EC2N 4BQ Role Active LLP Designated Member Appointed on 6 July 2012 Country of residence England 106 officers / 67 resignations 0 active persons with significant control / 1 active statement

K K S STRATEGY LLP (OC306533) Company status Active Correspondence address King & Spalding International Llp, 125 Old Broad Street, London, EC2N 1AR Role Active LLP Designated Member Appointed on 1 April 2008 Country of residence England 6 officers / 3 resignations

• The person with significant control of KKS Strategy is Mrs Katrina Kostic Samen date of birth November 1960 (K K S STRATEGY LLP persons with significant control).

• Katrina Kostic Samen has four identities registered: Katrina KOSTIC - SAMEN, Katrina Kostic SAMEN, Katrina Kostic SAMEN and Katrina KOSTIC SAMEN, presenting her name surname in three different ways, “Kostic - Samen”, “Samen” and Kostic Samen”. Multiple identities cause false non-match errors in audit and KYC software, breaching section 1082, and compromises audits breaching Section 441 of the Companies Act 2006.

• In the latter identity, Katrina KOSTIC SAMEN, she is a resigned officer of BRITISH COUNCIL FOR OFFICES Nature of business (SIC) 94120 - Activities of professional membership organisations 94990 - Activities of other membership organisations not elsewhere classified.

• This company name implies an official connection with a government department through the use of the names “British Council” which is the name of the UK Government foreign development organisation. Clarification of whether this is an approved use is necessary. If not, this is a serious breach representing a potential public security risk.

ZEUS FILMS LLP (OC301879) Company status Active Correspondence address 11 Pilgrim Street, London, EC4V 6RW Role Active LLP Member Appointed on 25 March 2003 Country of residence United Kingdom Registered office address Parcels Building, 14 Bird Street, London, United Kingdom, W1U 1BU Company status Active Incorporated on 3 April 2002

80 officers / 7 resignations

Charges 6 charges registered 6 outstanding Persons entitled Barclays Bank PLC

THE MUSCOVY COMPANY LIMITED (03821028) Company status Active Correspondence address King & Spalding International Llp, 125 Old Broad Street, London, England, EC2N 1AR Role Active Secretary Appointed on 17 August 1999 Nationality British Occupation Solicitor Incorporated on 6 August 1999 Nature of business (SIC) 74990 - Non-trading company Previous company names STOCKIMAGE LIMITED 21 Jun 2001 - 01 Aug 2001 STOCKIMAGE LIMITED 06 Aug 1999 - 21 Jun 2001

THE MUSCOVY COMPANY LIMITED (03821028) Company status Active Correspondence address King & Spalding International Llp, 125 Old Broad Street, London, England, EC2N 1AR Role Active Director Appointed on 17 August 1999 Nationality British Country of residence England Occupation Solicitor

Testing for multiple identities for William Francis Charnley.

A search in Companies House on the name William Francis Charnley locates five identities with these three names and date of birth August 1960 (https://find-and-update.company-information.service.gov.uk/search/officers?q=William+Francis+Charnley) . These are:

1. William Francis CHARNLEY

   Total number of appointments 1 - Born August 1960

   Drapers' Hall, Throgmorton Avenue, London, United Kingdom, EC2N 2DQ

2. William Francis CHARNLEY

   Total number of appointments 1 - Born August 1960

   DR J BARKER, Hughes Hall, , University Of Cambridge, Wollaston Road, Cambridge, England, CB1 2EW

3. William Francis CHARNLEY

   Total number of appointments 15 - Born August 1960

   8 Bishopsgate, London, England, EC2N 4BQ

4. William Francis CHARNLEY

   Total number of appointments 1 - Born August 1960

   16 City Business Centre, Hyde Street, Winchester, England, SO23 7TA

5. William Francis CHARNLEY

   Total number of appointments 2 - Born August 1960

   Grange Hatfield, Mosquito Way, Hatfield, England, AL10 9US

There is prima facie evidence that William Francis Charnley breaches section 1082 of the Companies Act 2006 by having registered his appointments under 5 separate identities. Further investigation of the companies held in these identities is warranted since the registration of multiple identities has compromised all audits associated with William Francis Charnley. Further analysis is required but not undertaken in this report.

The next identity returned is the search for William Francis Charnley in Companies house is:

• DICK FRANCIS FILMS LIMITED

  Total number of appointments 1

  HILLIER HOPKINS LLP, 2a, Alton House Office Park, Gatehouse Way, Gatehouse Industrial Area, Aylesbury, Buckinghamshire, England, HP19 8YF

This is included in the report as it features “Hillier Hopkins LLP” in the registered address for Dick Francis Films Limited. Hillier Hopkins LLP is a name that appears in the search for identities of another resigned director of Alliance for Responsible Citizenship Limited, Lord Hopkin Hill (appointed on 31 January 2018 resigned on 10 February 20230). This is an incidental finding that may or may not be relevant, but it is a statistical anomaly that requires further investigation.

Sir Paul Roderick Clucas Marshall, Damien Anthony Donohoe, JKA Seed Holding Limited and King Spalding International LLP are responsible for a section 66 breach of the Companies Act by Beikonic LP. Each entity is associated with further breaches as identified above. They represent a high risk to the public’s best interest and their criminal conduct requires urgent investigation.

Summary of Compliance Assessment outcomes of Paul Roderick Clucas Marshall.

Unique identifier non-compliance: Sir Paul Roderick Clucas Marshall, born August 1959, has established five unique identifiers in Companies House. Four times non-compliant (s1082 CA2006).

Accounts non-compliance: Sir Paul Marshall is director of five dissolved companies with accounts overdue, held in one of his four identities, identity B: MW Eaglewood Management Limited, MWAM NA Ltd, MWAM UK Ltd, Every Child a Chance Trust and Freedom Music Limited. Five times non-compliant (s441:CA2006).

Transparency assessments:

1. Alliance for Responsible Citizenship: Sir Paul Marshall omits eleven active directorships, in his biography on the Alliance for Responsible Citizenship Limited’s website. Eleven times non-compliant (HLCC2023). The omitted directorships include:

• Identity A: Church Revitalisation Trust.

• Identity B: Alliance for Responsible Citizenship Limited, ARK Academies Projects Limited, Absolute Return for Kids (ARK) and Pimpernel and Partners Limited. 4 omissions.

• Identity C: UnHerd Foundation, UnHerd Insight Limited, UnHerd Limited, Areopagus Ventures Limited, Beikonic Ltd and Old Queen Street Ventures Ltd. 6 omissions.

2. Church Revitalisation Trust: Sir Paul Marshall omits twelve active directorships, in his biography on the Church Revitalisation Trust website. Twelve times non-compliant (HLCC2023). The omitted directorships include:

• Identity A: Church Revitalisation Trust.

• Identity B: Marshal Wace LLP, Alliance for Responsible Citizenship Limited, ARK Academies Projects Limited, Absolute Return for Kids (ARK) and Pimpernel and Partners Limited. 5 omissions.

• Identity C: UnHerd Foundation, UnHerd Insight Limited, UnHerd Limited, Areopagus Ventures Limited, Beikonic Ltd and Old Queen Street Ventures Ltd. 6 omissions.

3. Trading Disclosures Compliance Assessment:

1. Alliance for Responsible Citizenship Limited conference 2025 invitation. The invitation to the Alliance for Responsible Citizenship 2025 Conference (image 1) fails to meet four out of six Trading Disclosures requirements. Four times non-compliant (CTDR 2015).

2. Alliance for Responsible Citizenship Limited website. The website of the Alliance for Responsible Citizenship Limited breaches of Trading Disclosure standards by publishing Sir Paul Marshall’s biography, as one of an Advisory Board with fifty-three members, without disclosing that he is a director. Non-compliant (CTDR 2015)

3. Church Revitalisation Trust website. There are two breaches of Trading disclosure standards, errors in the registered address and director disclosure anomalies. Two times non-compliant (CTDR 2015). A quick compliance review found breaches relating to Nicholas Glynn Paul Gumbel who has resigned, non-compliant (HLCC 2023). He is also a director of two dissolved companies with accounts overdue, Caring For Ex Offenders and Holy Trinity Brompton Developments Limited. Two times non-compliant (s441:CA2006). Nicholas Gumbel has two identities registered, concealing The William Wilberforce Trust from audits of his other identity. Non-compliant s1082:CA2006. The secretary of Church Revitalisation Trust, Jonathan Mark appears to have fourteen unique identifiers. Thirteen times non-compliant (s1082:CA 2006).

Risks Associated with Non-Compliance.

The compliance assessment of Paul Roderick Clucas Marshall reveals significant risks associated with non-compliance, particularly concerning multiple identities, overdue accounts, and transparency failures. These issues pose substantial threats to public interest and corporate governance integrity.

1. Multiple Identities: The establishment of multiple unique identifiers compromises audits and Know Your Customer (KYC) processes, concealing interests and potentially facilitating organised crime activities such as money laundering, people trafficking, and terrorism financing. Misleading information used to gain additional identities may constitute fraud by false representation under Section 2 of the Fraud Act 2006 and failing to disclose interests under Section 3 of the same Act. These breaches necessitate further investigation.

2. Risks to Public Interest:

   • Synthetic Identity Fraud: The presence of multiple identities coinciding with failure to declare interests held in other identities is evidence of synthetic identity fraud to obscure true ownership, control, and financial activities.

   • Clone Company Fraud: Similar company names and addresses across identities may facilitate clone company fraud, deceiving stakeholders and increasing financial and reputational risks.

   • Conflict of Interest: Multiple directorships under different identities obscure potential conflicts of interest, compromising transparency and stakeholder decision-making.

   • Governance and Accountability: Managing multiple companies under different identities undermines governance and accountability, leading to poor oversight and risk management.

   • Financial Risks: Complex financial oversight involving multiple identities can obscure financial liabilities and misrepresent a company’s financial health, posing systemic risks.

3. Actionable Steps:

   • Regulatory Investigation: Immediate regulatory scrutiny is necessary to investigate potential fraudulent activities and enforce compliance with the Companies Act 2006.

   • Enhanced Due Diligence: Stakeholders should conduct enhanced due diligence when engaging with entities associated with Paul Roderick Clucas Marshall to mitigate risks.

   • Public Awareness: Raising awareness about the risks associated with synthetic identity fraud and clone company fraud can help protect investors and the public from deceptive practices.

Conclusion

The compliance assessment highlights significant non-compliance issues involving Paul Roderick Clucas Marshall, including multiple unique identifiers, overdue accounts in dissolved companies, and transparency failures in directorship disclosures. These breaches pose serious risks to public interest by potentially facilitating fraudulent activities and undermining corporate governance integrity. Immediate corrective actions are recommended to address these issues, enhance compliance practices, and protect public interest. Regulatory bodies should prioritize investigations into these breaches to ensure accountability and transparency in business operations.

Further analysis is required. Specifically, a compliance assessment of Sir Paul Marshall’s registrations in the Register of Charities has not been completed. Scanning ahead, anomalies in unique identity management in the Charity Register, raise further concerns of non-compliance.

Limitations: He has a total of 46 appointments, 12 of which are active. Here we have considered just two of his active appointments. Compliance assessments are outstanding on Sir Paul Marshall’s other directorships in Companies House.

Further research required for records for Sir Paul Marshall’s disclosure on the Alliance for Responsible Citizenship website “Founder of the Marshall Institute at the LSE”.

Sir Paul Marshall's related parties that still require assessment:

1. Persons with significant control:

• Alan James McCormick (person with significant control of Alliance for Responsible Citizenship Limited)

• Christopher Lincoln Chandler (person with significant control of Alliance for Responsible Citizenship Limited)

• Richard Edward Douglas (person with significant control of Alliance for Responsible Citizenship Limited)

• Mark Alan Stoleson (person with significant control of Alliance for Responsible Citizenship Limited)

• Mrs Sabina Marshall (person with significant control of Pimpernel and Partners Limited)

2. Practitioners of liquidated companies:

• Sean Kenneth Croston (practitioner for MW Eaglewood Management Limited and MWAM UK Ltd)

• Clive Morris (Managing Director of Marshall Peters Limited, an insolvency practice)

• Paul A Palmer (Director of Marshall Peters Limited, an insolvency practice)

3. Lenders to any company:

• Barclays Bank PLC (charge holder for Zeus Films LLP)

• Citibank Europe PLC, UK Branch (charge holder for Marshall Wace Asset Management Limited)

• Coutts & Company (charge holder for Marshall Wace Asset Management Limited)

• KKR (major shareholder in Marshall Wace)

4. Entities using a company name in correspondence addresses, registered addresses, or occupations:

• Marshall Wace Asset Management Limited (used in correspondence addresses for multiple companies, e.g. Edcity Management Company Limited

• King & Spalding International LLP (used in correspondence addresses for multiple companies e.g. K K S Strategy LLP)

• WPO Limited (mentioned in a correspondence address for Oliver Plunkett)

• Legatum Group (co-owner of GB News with Paul Marshall)

• UnHerd Media (mentioned as founded and owned by Sir Paul Marshall)

• Old Queen Street Ventures (mentioned as a vehicle for potential acquisitions)

• Legatum Plaza (used in correspondence address for multiple persons with significant control)

5. Other related parties requiring assessment:

• Ken Griffin (reported to be joining Sir Paul Marshall's consortium to bid for the Telegraph Group)

• Jordan B. Peterson (associated with Alliance for Responsible Citizenship)

• Oliver Plunkett (former director of Alliance for Responsible Citizenship Limited)

• Lord Hill of Oareford (former director of Alliance for Responsible Citizenship Limited)

• Winston Aubrey Aladar Marshall (person with significant control of UnHerd Foundation)

• Damien Anthony O'Donohoe (director of B-IKONIC IBIZA LTD and BEIKONIC LTD)

• JKA Seed Holding Limited (general partner in BEIKONIC LP)

• William Francis Charnley (officer at King & Spalding International LLP)

• Todd Builione (hired by Marshall Wace to run North American business)

• Sequoia Trust (charitable trust under Sir Paul Marshall's control)

This list includes additional related parties identified from the search results, such as persons with significant control, business partners, and entities associated with Sir Paul Marshall's various ventures. Further investigation into these parties may reveal additional connections and potential conflicts of interest.

Methodological Limitations

This compliance assessment, while thorough in its approach, has several limitations that should be considered when interpreting the results:

Manual Data Collection and Transcription

• Records have been manually copied and sometimes précised, which may introduce human error or unintentional omissions.

• The manual nature of data collection limits the scope of the assessment, potentially missing relevant information.

Incomplete Assessment of Related Parties

• Not all directors and associated companies have been fully assessed, particularly:

  • Practitioners of liquidated companies

  • Lenders to any company

  • Entities using a company name in correspondence addresses, registered addresses, or occupations

Limited Search for Multiple Identities

• Searches for multiple identities are conducted manually, which may result in missed identities.

• Not all variations of names have been checked, potentially overlooking some identity duplications.

Scope of Company and Individual Analysis

• The assessment focuses primarily on the first director, limiting the comprehensive understanding of the entire organization's compliance status.

• Time constraints may have prevented a deeper analysis of all identified companies and individuals.

Reliance on Public Records

• The assessment relies heavily on publicly available information from Companies House, which may not always be up-to-date or complete.

Complexity of Corporate Structures

• The intricate network of companies and individuals makes it challenging to fully map all relationships and potential conflicts of interest.

Limited Historical Context

• The assessment may not fully capture historical changes in company structures, directorships, or compliance status.

Interpretation of Compliance Standards

• The application of compliance standards (e.g., HLCC2023, CTDR 2015) may be subject to interpretation, especially in complex cases.

Potential for Overlooked Breaches

• The complexity and volume of data increase the risk of overlooking certain compliance breaches or misinterpreting relationships between entities.

Lack of Direct Verification

• The assessment relies on secondary sources without direct verification from the individuals or companies involved.

Time Sensitivity of Information

• Company information and compliance statuses can change rapidly, potentially making some findings outdated by the time of report completion.

These limitations underscore the need for caution in drawing definitive conclusions and highlight the importance of ongoing, comprehensive compliance monitoring.

End of section.

The other active director of Alliance For Responsible Citizenship Limited is Alan James McCormick, he is considered next.