Dame June Raine, MHRA CEO, failed to declare that she was a director of Saffron Underwriting Limited from 21 January 2016 to 9 May 2023.
Conflict of interest. Evidence of fraud.
Key finding: Dame June Raine, MHRA chief executive office was concurrently a director of Saffron Underwriting Limited, from 21 January 2016 to 9 May 2023. There is no evidence that she disclosed to MHRA that she was a director of Saffron Underwriting. This breach undermines transparency and calls into question the accuracy of the Accounts.
Dame June Raine’s publicly available declarations of interest
Dame June Raine’s biography on the Government website (Dame June Raine DBE - GOV.UK (www.gov.uk)):
Biography
Dr June Raine DBE is CEO of the Medicines and Healthcare products Regulatory Agency. She trained in medicine in Oxford after completing a master’s degree by research in Pharmacology. Her interest in drug safety led to a career in medicines regulation which has spanned a number of roles in assessment, management and strategic development within the UK national authority. She was elected in 2012 as the first chair of the European Pharmacovigilance Risk Assessment Committee and is also co-Chair of the WHO Advisory Committee on Safety of Medicinal Products. Her special interests are in monitoring the outcomes of regulatory action, risk communication and patient involvement in the regulatory process.
Chief Executive
The chief executive chairs the Executive Committee, which is the highest decision-making body in the agency.
Previous roles in government
Director of Vigilance and Risk Management of Medicines
1999 to 2019
The Medicines and Healthcare products Regulatory Agency (MHRA) provides access to its current Register of Interests, as at May 2023, on its website (2_0523_MHRA_Board_Declarations_of_Interest_May_2023_FINAL.pdf (publishing.service.gov.uk)). Dame June Raine’s entry reads:
Dame June Raine, Chief Executive. World Health Organisation (WHO) Committee on Safety of Medicinal Products Member (Paid) No (Current) Yes.
Dame June Raine declares that as well as her role as Chief Executive of MHRA, she is also an unpaid member of the WHO Committee on Safety of Medicinal Products. She declares no other interests.
MHRA policy regarding Board declaration of interests
The Medicines and Healthcare products Regulatory Agency regulates medicines, medical devices and blood components for transfusion in the UK. The Senior Leadership team structure, at October 2023 is described in the organisation chart below (MHRA Senior Leadership team structure October 2023 (publishing.service.gov.uk)).
The governance is described (Our governance - Medicines and Healthcare products Regulatory Agency - GOV.UK (www.gov.uk)):
The Board
The unitary Board is responsible for advising on the strategic direction of the Agency, ensuring that targets set out in the business plan and agreed with ministers, are met.
The Board supports the Chief Executive in the effective delivery of services and overall performance by providing leadership, developing strategy, advising on the delivery of policies, maintaining high standards of corporate governance, scrutinising performance and ensuring that controls are in place to manage risk.
The Board does not have involvement in any regulatory decisions affecting medicines or medical devices. These are the responsibility of the Chief Executive and Executive Committee.
Regarding disclosure of interests, the Policy on Declaring and Managing Interests for Members of the MHRA Unitary Board Responsible Officer, available from the MHRA website (click underlined links), effective from March 2021, prescribes the following:
3.1 It is the responsibility of each individual to identify and to declare all relevant interests. The following types of interest must be declared by the Chair and members of the Board:
Their own financial interests in or payments from the pharmaceutical and medical devices industry or other relevant industries (financial interests are either personal or non-personal, and either specific to a product being discussed, or non-specific);
Financial interests in the pharmaceutical and medical devices industry held by members of their immediate family;
Any business interests or positions of authority outside of their role in the MHRA regardless of whether they are linked to the health sector or not 2
Any other matter that could affect their impartiality, or that could reasonably be perceived as affecting their impartiality.
Analysis: A directorship of a private limited company is a “business interests or positions of authority outside of their role in the MHRA regardless of whether they are linked to the health sector or not” and should be disclosed according to Section 3.1, Policy on Declaring and Managing Interests for Members of the MHRA Unitary Board Responsible Officer.
Conclusion: As Chief Executive Dame June Raine is responsible for all regulatory decisions affecting medicines or medical devices and she has a duty to disclose all of her and her immediate family’s interests.
Wikipedia was referenced for Dame June Raine’s full name and date of birth:
Dame June Munro Raine DBE (née Harris; born 1952), is a British doctor who is currently serving as the Chief Executive Officer of the Medicines and Healthcare products Regulatory Agency (MHRA) in the United Kingdom.
June Raine’s interests, registered in Companies House.
A search in Companies House on the name June Raine (June Raine - Find and update company information - GOV.UK (company-information.service.gov.uk)) locates one identity for June Munro Raine, date of birth June 1952. There is another June Raine registered, with date of birth June 1960, who may or may not be a related party.
Dame June Raine holds one identity with date of birth June 1952, the “search” record provides:
Total number of appointments 1 - Born June 1952
5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL
The Companies House “Appointments” record provides the following details (June Munro RAINE personal appointments - Find and update company information - GOV.UK (company-information.service.gov.uk):
Précised, this reads:
June Munro RAINE
Total number of appointments 1
Date of birth June 1952
SAFFRON UNDERWRITING LIMITED (03806044)
Company status Active Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL
Role RESIGNED Director Appointed on 21 January 2016 Resigned on 9 May 2023
June Munro Raine has one appointment to Saffron Underwriting Limited, company registration number 03806044, appointed on 21 January 2016 and resigned on 9 May 2023. This appointment was concurrent with her role as CEO of MHRA.
No evidence of disclosure of Saffron Underwriting Limited to MHRA
Evidence that Dame June Raine disclosed her directorship of Saffron Underwriting Limited to MHRA was not located. It is not referenced in the most recent Register of Interest May 2023, when it was still due, or in her biography.
If Dame June Raine failed to disclose that she was a director of Saffron Underwriting Limited from 21 January 2016 to 9 May 2023 in her biography on the Government website and in the MHRA register of interests, throughout this period, then a serious offence has been committed.
This directorship was concurrent with her role as the Director of Vigilance and Risk Management in the Medicines Division, from 21 January 2016 to September 2019 and since her appointment as CEO of MHRA, until her resignation from Saffron Underwriting Limited, on 9 May 2023. Dame June Raine has a duty to disclose this potential conflict of interest under section 3.1, Policy on Declaring and Managing Interests for Members of the MHRA Unitary Board Responsible Officer.
Saffron Underwriting Limited overview
Accessing the “Company overview” at Companies House (SAFFRON UNDERWRITING LIMITED overview - Find and update company information - GOV.UK (company-information.service.gov.uk)), the following information is displayed:
SAFFRON UNDERWRITING LIMITED
Registered office address 5th Floor 70 Gracechurch Street, London, England, EC3V 0XL Company status Active
Company type Private limited Company Incorporated on 13 July 1999
Accounts Next accounts made up to 31 December 2023 due by 30 September 2024 Last accounts made up to 31 December 2022
Confirmation statement Next statement date 25 July 2024 due by 8 August 2024 Last statement dated 25 July 2023
Nature of business (SIC)
65120 - Non-life insurance
65202 - Non-life reinsurance
Non-life insurance and reinsurance background information:
Non-life insurance, otherwise called general insurance, includes insurance policies that provide a guarantee of compensation for loss, damage or illness. (Non-life insurance industry in the United Kingdom (UK) - statistics & facts | Statista).
As of 2014, the leading reinsurance company, Lloyd's of London, received cessions in value of 6.7 billion euros. By the end of 2016, the reinsurance cession value for Lloyd's of London grew to 7.9 billion euros. Reinsurance cessions (non-life) for leading companies 2014-2016 | Statista (Published by Jennifer Rudden, Jan 11, 2022).
Summary
Saffron Underwriting Limited is private limited company incorporated on July 13, 1999, is currently active and has its registered office address at 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL. Its primary business activities, as per the Standard Industrial Classification (SIC) codes, include non-life insurance (SIC code 65120) and non-life reinsurance (SIC code 65202). The company's accounts, with the last set made up to December 31, 2022, and its confirmation statement, with the last statement dated July 25, 2023, are up to date. The next accounts are due by September 30, 2024, and the next confirmation statement is due by August 8, 2024.
Conclusion: Conflict of interest
By serving as a director of Saffron Underwriting Limited, which operates in the insurance industry, Dame June Raine may potentially be exposed to conflicts between her duties at MHRA and the interests of the insurance company. The insurance sector, particularly in the context of underwriting and reinsurance, often intersects with healthcare regulation, especially concerning liability, risk assessment, and claims management related to pharmaceutical products and medical devices.
Dame June Raine's dual roles could create situations where her decisions or actions at MHRA may be influenced by considerations related to Saffron Underwriting Limited, rather than being solely guided by the regulatory requirements and public health interests. This could undermine the impartiality and credibility of MHRA's regulatory processes and decision-making, eroding public trust and confidence in the agency's ability to safeguard public health.
Furthermore, the failure to disclose this directorship raises questions about transparency, accountability, and adherence to regulatory protocols within MHRA. It is essential for individuals in positions of authority within regulatory bodies to fully disclose any potential conflicts of interest to ensure transparency and maintain public confidence in the integrity of regulatory processes.
In summary, Dame June Raine's omission in declaring her directorship in Saffron Underwriting Limited represents a significant conflict of interest due to the potential for conflicting loyalties, compromised regulatory decisions, and erosion of public trust in the regulatory process.
Saffron Underwriting Officers
Accessing the “People” tab in the Companies House record for Saffron Underwriting Limited, provides the following details and weblinks for the officers (SAFFRON UNDERWRITING LIMITED people - Find and update company information - GOV.UK (company-information.service.gov.uk)):
SAFFRON UNDERWRITING LIMITED
8 officers / 3 resignations
ARGENTA SECRETARIAT LIMITED Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Secretary Appointed on 30 October 2002
BOWLES, David Charles Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Director Date of birth August 1968 Appointed on 7 May 2023 Nationality British Country of residence England Occupation Company Director
HARRIS, David Correspondence address Keep House, 5 Maberly Court Castle Hill, Saffron Walden, Essex, CB10 2EA Role ACTIVE Director Date of birth May 1925 Appointed on 31 October 2002 Nationality British Country of residence England Occupation Retired
APCL CORPORATE DIRECTOR NO.1 LIMITED Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Director Appointed on 7 May 2023 UK Limited Company Registration number 09080154
APCL CORPORATE DIRECTOR NO.2 LIMITED Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Director Appointed on 7 May 2023 UK Limited Company Registration number 09080184
HARRIS, Isobel Correspondence address Keep House, 5 Maberly Court, Saffron Walden, Essex, CB10 2EA Role RESIGNED Secretary Appointed on 13 July 1999 Resigned on 31 October 2002
HARRIS, David Correspondence address Keep House, 5 Maberly Court Castle Hill, Saffron Walden, Essex, CB10 2EA Role RESIGNED Director Date of birth May 1925 Appointed on 13 July 1999 Resigned on 31 October 2002 Nationality British Country of residence England Occupation Retired Dental Surgeon
RAINE, June Munro, Dr. Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role RESIGNED Director Date of birth June 1952 Appointed on 21 January 2016 Resigned on 9 May 2023 Nationality British Country of residence England Occupation Director
Summary of chronology of Saffron Underwriting Limited officers.
Isobel Harris (Resigned Secretary) - Appointed on 13 July 1999, Resigned on 31 October 2002
David Harris (Resigned Director) - Appointed on 13 July 1999, Resigned on 31 October 2002
Argenta Secretariat Limited (Active Secretary) - Appointed on 30 October 2002
David Harris (Active Director) - Appointed on 31 October 2002
June Munro Raine, Dr. (Resigned Director) - Appointed on 21 January 2016, Resigned on 9 May 2023
APCL Corporate Director No.1 Limited (Active Director) - Appointed on 7 May 2023
APCL Corporate Director No.2 Limited (Active Director) - Appointed on 7 May 2023
David Charles Bowles (Active Director) - Appointed on 7 May 2023.
During the period that Dame June Raine was director of Saffron Underwriting Limited, 21 January 2016 to 9 May 2023, her co-officers were Argenta Secretariat Limited, as secretary and David Harris. For the short period, 7 May 2023 to 9 May 2023 her co-directors were APCL Corporate Director No.1 Limited, APCL Corporate Director No.2 Limited and David Charles Bowles. These five officers remain active.
Saffron Underwriting Limited - persons with significant control
The persons with significant control information provides (SAFFRON UNDERWRITING LIMITED persons with significant control - Find and update company information - GOV.UK (company-information.service.gov.uk)):
1 active person with significant control / 0 active statements
Mr David Harris ACTIVE Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Notified on 6 April 2016 Date of birth May 1925 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 and remove directors
Summary of Dame June Raine's involvement with Saffron Underwriting Limited
Dame June Munro Raine, DBE, currently the Chief Executive Officer of the Medicines and Healthcare products Regulatory Agency (MHRA), held a concurrent position as a director at Saffron Underwriting Limited. This dual role, however, was not disclosed by Dame June Raine.
Key points:
Biographical Overview:
Dame June Raine, a distinguished British doctor, has served extensively in the Medicines Division of the MHRA and its predecessor in the Department of Health.
Her roles include being the CEO of the MHRA, chairing the Executive Committee—the highest decision-making body in the agency and a member of the World Health Organisation (WHO) Committee on Safety of Medicinal Products.
Companies House Record:
A search in Companies House reveals one identity for June Munro Raine, born in June 1952, with the same middle name, Munro.
Dame June Raine held an appointment at Saffron Underwriting Limited, starting on 21 January 2016 and resigning on 9 May 2023. This period overlapped with her tenure as the Director of Vigilance and Risk Management in the Medicines Division, from 21 January 2016 to September 2019 and then her appointment as CEO of the MHRA until her resignation on 9 May 2023.
Non-Disclosure in Government Biographies:
Dame June Raine does not disclose her directorship at Saffron Underwriting Limited in her biography on the Government website. It is not referenced as a current directorship in the Register of Interests dated May 2023, when she had a duty to declare it under the Companies Act 2006 and the MHRA Policy on Declaring and Managing Interests. No evidence that it was ever disclosed was located.
Saffron Underwriting Limited Overview:
Saffron Underwriting Limited operates in the non-life insurance sector, with its registered office at 5th Floor, 70 Gracechurch Street, London, EC3V 0XL.
It was incorporated on July 13, 1999.
It is active and the accounts and confirmation statement are up to date.
The omission in declaring her directorship in Saffron Underwriting Limited represents a significant conflict of interest due to the potential for conflicting loyalties, compromised regulatory decisions, and erosion of public trust in the regulatory process.
Officers at Saffron Underwriting Limited:
The current directors, unless specified, are:
Argenta Secretariat Limited (Secretary - Appointed on 30 October 2002)
David Harris (Appointed on 31 October 2002)
APCL Corporate Director No.1 Limited (Appointed on 7 May 2023)
APCL Corporate Director No.2 Limited ( Appointed on 7 May 2023)
David Charles Bowles (Appointed on 7 May 2023).
The resigned officers are:
Isobel Harris (Secretary - 13 July 1999 to 31 October 2002
David Harris (Director - 13 July 1999 to 31 October 2002
June Munro Raine, Dr. - 21 January 2016 to 9 May 2023.
David Harris resigned and was reappointed as director on 31 October 2002.
Significant Control:
Mr. David Harris is identified as the active person with significant control, holding ownership of shares and voting rights of 75% or more.
Related Party Transactions
When an auditor considers the linked directorate of each director, for related party transactions, it involves examining not only the directorships held by the specific individual under scrutiny but also those of their co-directors of the other interests. Related party transactions are transactions that occur between a company and its related parties, which can include key management personnel and their close family members, entities that are directly or indirectly controlled by, or control, or are under common control with the company.
In the context of auditing and corporate governance, understanding the linked directorate, which includes examining the directorships of co-directors, is crucial. This is because transactions with related parties, especially those involving directors or their close associates, can present risks of conflicts of interest and potential abuse of corporate resources. By considering the broader network of directorships, auditors aim to identify any transactions that might not be conducted at arm's length and could impact the fairness and transparency of the financial statements.
Analysing the directorships of co-directors, including those held in multiple identities, is a way to comprehensively assess the relationships and transactions that might influence the financial standing and decision-making within a company. This practice aligns with principles of corporate governance and transparency, helping to ensure that related party transactions are appropriately disclosed and, if necessary, subjected to additional scrutiny to prevent any undue influence or bias.
Twice a year a director confirms; that their details and disclosure of interests are accurate and up to date, and that there is no audit information of which the company’s auditor is not aware, to meet the requirements of the Annual Report and the Confirmation Statement. When an individual fails to disclose an interest to the auditor a person guilty of this offence is liable to a prison sentence (section 418 of the Companies Act 2006). Where there is evidence that an interest was not disclosed, then this is a breach of Section 418 and requires investigation.
Moving forward, a comprehensive high-level review will be conducted, beginning with an examination of the accounts made up to 31 December 2022. Subsequently, each director's records will be explored to identify their other interests and individuals or entities with significant control over them. This multifaceted approach aims to uncover potential conflicts of interest and ensure transparency in professional engagements.
Accounts of Saffron Underwriting Limited made up to 31 December 2022
Turning to the “filing history” for Saffron Underwriting Limited, the most recent accounts, “Full accounts made up to 31 December 2022” were accessed (SAFFRON UNDERWRITING LIMITED filing history - Find and update company information - GOV.UK (company-information.service.gov.uk)), these were uploaded to Companies House on 12 Oct 2023. The following information is provided on the cover page and page 1:
Company Registration Number: 03806044
Saffron Underwriting Limited
Annual Report 31 December 2022
Company Information
Directors:
Mr D Harris (Resigned 17 July 2023)
Dr J M Raine (Resigned on 9 May 2023)
Mr D C Bowles (Appointed on 7 May 2023)
APCL Corporate Director No. 1 Limited (Appointed on 7 May 2023)
APCL Corporate Director No. 2 Limited (Appointed on 7 May 2023).
Members’ Agent: Argenta Private Capital Limited (Regulated by the Financial Conduct Authority).
Company Secretary: Argenta Secretariat Limited
Registered Office: 5th Floor, 70 Gracechurch Street London EC3V 0XL
Auditor: PKF Littlehohn LLP 15 Westferry Circus Canary Wharf London E14 4HD
Anomalies:
The Full Accounts made up to 30 December 2022 present directors’ appointments:
Mr D C Bowles (Appointed on 7 May 2023)
APCL Corporate Director No. 1 Limited (Appointed on 7 May 2023)
APCL Corporate Director No. 2 Limited (Appointed on 7 May 2023),
and resignations:
Mr D Harris (Resigned 17 July 2023)
Dr J M Raine (Resigned on 9 May 2023).
These fall outside the scope of the period being presented, 1 January 2022 to 30 December 2022.
Referring to a summary of the directors of Saffron Underwriting Limited, (SAFFRON UNDERWRITING LIMITED people):
SAFFRON UNDERWRITING LIMITED
8 officers / 3 resignations
ARGENTA SECRETARIAT LIMITED Secretary Appointed on 30 October 2002
BOWLES, David Charles Director Date of birth August 1968 Appointed on 7 May 2023
HARRIS, David Director Date of birth May 1925 Appointed on 31 October 2002
APCL CORPORATE DIRECTOR NO.1 LIMITED Director Appointed on 7 May 2023 UK Limited Company Registration number 09080154
APCL CORPORATE DIRECTOR NO.2 LIMITED ACTIVE Director Appointed on 7 May 2023 UK Limited Company Registration number 09080184
HARRIS, Isobel Secretary Appointed on 13 July 1999 Resigned on 31 October 2002
HARRIS, David Director Date of birth May 1925 Appointed on 13 July 1999 Resigned on 31 October 2002 Occupation Retired Dental Surgeon
RAINE, June Munro, Dr. Director Date of birth June 1952 Appointed on 21 January 2016 Resigned on 9 May 2023
A discrepancy becomes apparent: The “Full accounts made up to 31 December 2022” (SAFFRON UNDERWRITING LIMITED filing history) state that “Mr D Harris (Resigned 17 July 2023)” whereas the Companies House record states “HARRIS, David ACTIVE Director Date of birth May 1925 Appointed on 31 October 2002”.
Statement on Anomalies in Saffron Underwriting Limited Accounts
The discrepancies identified in the "Full accounts made up to 31 December 2022" for Saffron Underwriting Limited introduce critical inconsistencies in the validity and accuracy of the financial reporting. These anomalies fall into two categories:
Events Outside the Accounting Period:
The accounts present director appointments and resignations that occurred outside the scope of the reporting period (1 January 2022 to 30 December 2022). This includes the appointments of Mr D C Bowles, APCL Corporate Director No. 1 Limited, and APCL Corporate Director No. 2 Limited on 7 May 2023, as well as the resignations of Mr D Harris on 17 July 2023 and Dr J M Raine on 9 May 2023.
Reporting events outside the financial period violates the principle of presenting a clear and accurate snapshot of the company's financial position during the specified timeframe.
Inaccurate Representation of Director Status:
The discrepancy between the statement "Mr D Harris (Resigned 17 July 2023)" in the accounts and the Companies House record stating "HARRIS, David ACTIVE Director" introduces a serious question regarding the accuracy of the reported information.
The accounts suggest a resignation that, according to the Companies House record, did not occur. This misrepresentation compromises the reliability and truthfulness of the financial reporting.
Effect on the Validity of the Accounts:
These anomalies undermine the integrity of the financial reporting for Saffron Underwriting Limited. Financial statements are intended to provide a precise overview of a company's financial health within a defined period. The inclusion of events outside this timeframe and the misrepresentation of a director's status challenge the reliability and accuracy of the entire accounting report.
The consequence is a loss of confidence in the completeness and truthfulness of the financial information provided. Stakeholders relying on these accounts may be misled by inaccuracies, impacting their ability to make informed decisions about the company's performance and stability.
Turning to page 2 of the most recent accounts, made up to 31 December 2022.
Extracts read (emphasis in bold is mine):
The Company continues to write insurance business in the Lloyd’s insurance market as a Lloyd’s Corporate Capital Member.
The financial statements incorporate the annual accounting results of the Syndicates on which the Company participates for the 2020, 2021, and 2022 years of account, as well as any 2019 and prior run-off years. The 2020 year closed at 31 December 2022 with a result of £31,541 (2019 - £(15,890)). The 2021 and 2022 open underwriting accounts will normally close at 31 December 2023 and 2024 respectively.
Results and dividends totalling £Nil were paid on the year (2021- Nil).
The Company is principally exposed to financial risk through its participation on Lloyd’s Syndicates. It has delegated sole management and control of its underwriting through each Syndicate and it looks to the managing agents to implement appropriate policies , procedures and internal controls to manage each Syndicate’s exposures to insurance risk, credit risk, market risk and operational risk. The company is directly exposed to these risks, but they are not considered material for the assessment of the assets, liabilities, financial position and profit or loss of the Company.
Capacity (youngest underwriting year) 2022: £1,713,708 (2021: £1,675,497).
Anomaly
Reporting “2020 year closed at 31 December 2022” and including the results of prior years (such as 2019) in the financial statements for the current reporting period is not typical or in line with International Financial Reporting Standards (IFRS).
Concern:
Saffron Underwriting Limited cedes management and control of its participation on Lloyd's Syndicates to the managing agent, Argenta Private Capital Limited. Whether the arrangement is compliant depends on the extent to which it adheres to regulatory standards and industry best practices. A thorough review of the contractual agreements, regulatory frameworks, risk management practices, and oversight mechanisms is necessary to determine compliance.
Audit Considerations: The auditor's opinion on the financial statements should be carefully considered in light of the anomalies and concerns identified. Any qualifications or emphasis of matter in the auditor's report should be reviewed to understand the auditor's perspective on the issues raised.
Having neither the time or skills to scrutinise the financial statements in detail, there are 49 pages, I’ll skip to items that stood out as being anomalous.
Accuracy of figures.
The financial figures provided in the accounts raise doubts about their accuracy and credibility, particularly for a Lloyd's Corporate Capital member. Notably, the reported total assets for 2022 are listed as £5,701,726 (compared to £5,004,236 in 2021) (page 11), with audit fees stated at a remarkably low £300 (as per page 23). Such a nominal audit fee appears disproportionately low, potentially insufficient to cover even an hour of accounting services. Given the presence of other anomalies within these accounts, such as discrepancies in director appointments and resignations, it seems plausible that these figures may be misstated or missing unit indicators (e.g., '000s). Clarification is needed to confirm the accuracy and reliability of these financial figures.
Sizable unused tax losses
The unused tax losses carried forward as the Statement of Financial Position date are £137,226. Unused tax losses are expected to be recoverable against the future profits of the Company and have no expiry date.
The deferred tax expected to unwind within one year is £3,387. The deferred tax expected to unwind over one year is £34,324 (page 42).
Observation: The significant unused tax losses amounting to £137,226, suggests that the company may not be liable to pay taxes for several years, given the limited amount expected to "unwind" within one year.
Related Party Disclosures and Controlling Party.
The last page of the accounts (page 43) covers Related Party Transactions and discloses the Ultimate Controlling Party:
Related Party Disclosure (12): During the year the Directors made loans to and from the Company. At the Balance Sheet date the amount due (to)/from the Company was £12,588 (2021: £12,588).
Ultimate controlling party (13): The Company is controlled be the Estates of Mr D Harris, which holds 100% of the issued £1,000 ordinary shares capital.
Anomalies
Ambiguous Related Party Transactions: The disclosure regarding related party transactions lacks clarity and accuracy. It fails to specify whether the loans were made to or from the directors, creating ambiguity about the nature of the transactions. Additionally, it is highly unusual that the same amount of £12,588 is reported for both 2021 and 2022, raising concerns about the reliability of the information provided.
Ultimate Controlling Party: The statement identifying the ultimate controlling party as "the Estate of Mr D Harris" is questionable. According to the Companies House records, Mr David Harris, born in May 1925, is listed as a current director and a person with significant control. It is plausible that Mr Harris has passed away, and his estate is managing his affairs. However, if this is the case, Saffron Underwriting Limited has failed to update the records at Companies House accordingly. This would necessitate the resignation of Mr Harris and the appointment of the Estate as the person with significant control, along with the disclosure of the individuals managing the estate. The discrepancy between the information provided in the accounts and the Companies House records raises further concerns about the accuracy and completeness of the reporting.
Charges
The 2022 Accounts for Saffron Underwriting Limited include the statement:
The Company’s assets are primarily Funds at Lloyd’s to support its underwriting (page 38).
Saffron Underwriting Limited, however, carries a significant number of charges made out to Lloyd’s. Companies House maintains a register of all the charges applied to a company and there are 193 outstanding charges. The first three records are copied below (précised).
193 charges registered
193 outstanding, 0 satisfied, 0 part satisfied
Created 9 December 2009 Delivered 16 December 2009 Status Outstanding
Persons entitled
Lloyd's, the Trustees, the Beneficiaries and the Other Persons or Bodies
Short particulars
All moneys or other property at any time paid or…
Lloyd's american trust deed (the " trust deed")
Created 24 March 2009 Delivered 7 April 2009 Status Outstanding
Persons entitled
The American Trustee, All Policy Holders and Certain Other Persons or Bodies (As Defined on the Form M395)
Short particulars
All premiums and other moneys payable during the trust term…
Created 24 March 2009 Delivered 7 April 2009 Status Outstanding
Persons entitled
Lloyd's, and Certain Other Persons or Bodies (As Further Defined on Form M395)
Short particulars
All the present and future assets of the member comprised.
Concentration of charges with Lloyd's raises compliance concerns.
Considering that Saffron Underwriting Limited continues to write insurance business in the Lloyd’s insurance market as a Lloyd’s Corporate Capital Member, the concentration of 193 outstanding charges primarily with Lloyd's raises concerns about the circular nature of financial arrangements. Although registering charges is a legal requirement, the potential impact on the company's assets warrants further examination by independent tax and legal experts to ensure compliance with legislation.
Summary of findings, so far.
Key Findings Relating to Dame June Raine and Her Associates:
1. **Dame June Raine's Dual Role:** Dame June Munro Raine, DBE, concurrently served as the Chief Executive Officer (CEO) of the Medicines and Healthcare products Regulatory Agency (MHRA) while holding a directorship at Saffron Underwriting Limited. This dual role, spanning from 21 January 2016 to 9 May 2023, was not disclosed by Dame June Raine.
2. **Biographical Overview:** Dame June Raine, a distinguished British doctor, has held various roles within the Medicines Division of the MHRA and its predecessor in the Department of Health. Her tenure includes serving as the Director of Vigilance and Risk Management in the Medicines Division and subsequently as the current CEO of the MHRA.
3. **Non-Disclosure in Government Biographies:** Dame June Raine did not disclose her directorship at Saffron Underwriting Limited in her biography on the Government website. Additionally, it was not referenced as a current directorship in the Register of Interests dated May 2023, violating the Companies Act 2006 and the MHRA Policy on Declaring and Managing Interests.
4. **Saffron Underwriting Limited Overview:** Saffron Underwriting Limited is an active private limited company operating in the non-life insurance sector. It was incorporated on July 13, 1999, with its registered office at 5th Floor, 70 Gracechurch Street, London, EC3V 0XL.
5. **Officers at Saffron Underwriting Limited:** The current officers include Argenta Secretariat Limited (Secretary), David Harris (Director), APCL Corporate Director No.1 Limited, APCL Corporate Director No.2 Limited, and David Charles Bowles (Director). Notably, Dame June Raine served as a director from 21 January 2016 to 9 May 2023.
6. **Significant Control:** Mr. David Harris is identified as the active person with significant control, holding ownership of shares and voting rights of 75% or more in Saffron Underwriting Limited since 6 April 2016 .
7. **Anomalies in Financial Reporting:** The financial statements of Saffron Underwriting Limited for the year ending 31 December 2022 exhibit several anomalies, including events reported outside the accounting period, inaccurate representation of director status, and discrepancies in related party disclosures and controlling party identification.
8. **Concentration of charges with Lloyd's raises compliance concerns:** The company carries a significant number of charges primarily with Lloyd's, raising concerns about the nature of financial arrangements and compliance with legislation. The concentration of charges with the same entity suggests a circular nature of transactions that necessitates further examination by independent experts.
In conclusion, the findings highlight potential conflicts of interest, non-disclosure of directorships, and irregularities in financial reporting within the context of Dame June Raine's association with Saffron Underwriting Limited and its operations. These issues warrant thorough investigation and remedial action to ensure transparency, compliance, and integrity in regulatory governance and financial practices.
Records for each officer of Saffron Underwriting Limited will now be considered.
Mr David Harris (Saffron Underwriting Limited director and person with significant control)
Mr David Harris, date of birth May 1925, is 98 years old. He is a director of and the person with significant control of Saffron Underwriting Limited. The Final Accounts made up to 31 December 2022, however, state that it is the Estate of Mr Harris that has ultimate control, contradicting the record held by Companies House. The 2022 Accounts also erroneously describe Mr Harris as resigned on 17 July 2023, which was outside the accounting period, whereas he is described as still active in the Companies House record. These are two material misstatements.
A search, testing for multiple registered identities, located just one identity, with this name and date of birth May 1925, (David HARRIS - Find and update company information - GOV.UK (company-information.service.gov.uk)). The appointment details for his identity:
David HARRIS personal appointments - Find and update company information - GOV.UK (company-information.service.gov.uk)
Total number of appointments 2
Date of birth May 1925
SAFFRON UNDERWRITING LIMITED (03806044)
Company status Active Correspondence address Keep House, 5 Maberly Court Castle Hill, Saffron Walden, Essex, CB10 2EA Role ACTIVE Director Appointed on 31 October 2002 Nationality British Country of residence England Occupation Retired
SAFFRON UNDERWRITING LIMITED (03806044)
Company status Active Correspondence address Keep House, 5 Maberly Court Castle Hill, Saffron Walden, Essex, CB10 2EA Role RESIGNED Director Appointed on 13 July 1999 Resigned on 31 October 2002 Nationality British Country of residence England Occupation Retired Dental Surgeon
Mr. David Harris, born in May 1925 and currently 98 years old, is the individual with significant control over the directors of Saffron Underwriting Limited. A search for multiple registered identities yielded only one entry for David Harris, dated May 1925.
Summary of Anomalies:
Contradictory Ultimate Control: The Final Accounts for Saffron Underwriting Limited, made up to 31 December 2022, state that the Estate of Mr. David Harris has ultimate control, conflicting with the Companies House record where Mr. Harris is listed as the person with significant control. This discrepancy raises questions about the accurate representation of control within the company.
Erroneous Director Status: The 2022 Accounts incorrectly describe Mr. David Harris as having resigned on 17 July 2023, a date outside the accounting period. However, the Companies House record indicates that Mr. Harris is still active. These conflicting statements regarding Mr. Harris's directorial status constitute material misstatements in the financial reporting.
Singular Identity: Despite searching for multiple registered identities, only one entry for David Harris, born in May 1925, was found. This singular identity suggests a lack of evidence for any alternative identity or conflicting appointments.
Unusual Resignation and Reappointment: Mr. David Harris's directorial history at Saffron Underwriting Limited includes an unusual sequence of events where he apparently resigned and was reappointed on the same day, 31 October 2002. This anomaly prompts further investigation to understand the circumstances behind such actions, which could range from administrative errors to deliberate manoeuvres.
In conclusion, the anomalies encountered in the evidence pertaining to Mr. David Harris's directorship at Saffron Underwriting Limited raise concerns about the accuracy, consistency, and transparency of the company's governance and financial reporting processes. These discrepancies warrant thorough investigation and remediation to ensure compliance with regulatory standards and uphold the integrity of corporate practices.
Summary of anomalies:
David Harris, date of birth May 1925, has one identity, two appointments, one active. He is a director of Saffron Underwriting Limited, appointed on 13 July 1999, resigned on 31 October 2002, and reappointed on 31 October 2002. He is listed as the Person With Significant Control since 6 April 2016. This is contradicted in the 2022 Accounts where “The estate of Mr D Harris” is specified as having ultimate control. Other issues: Lloyd’s charges circularity, erroneous Director Status in 2022 Account, unusual resignation and reappointment on 31 October 2002.
Argenta Secretariat Limited (Saffron Underwriting Limited secretary)
ARGENTA SECRETARIAT LIMITED is a corporate identity and the active secretary of Saffron Underwriting Limited, appointed on 30 October 2002. This is one of 544 appointments, of which 426 are current (ARGENTA SECRETARIAT LIMITED personal appointments - Find and update company information - GOV.UK (company-information.service.gov.uk)).
ARGENTA SECRETARIAT LIMITED (corporate identity, as an officer)
Current appointments 426
Total number of appointments 544
[Five active interests, as an example:]
GRYPHON CAPITAL PARTNERS LIMITED (10320181) Company status Active Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Secretary Appointed on 9 August 2016 UK Limited Company What's this? Registration number 01479228
EAST YORKSHIRE UNDERWRITERS (WREN) LIMITED (03270932) Company status Active Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Secretary Appointed on 26 January 2009 UK Limited Company What's this? Registration number 01479228
HOMA UNDERWRITING LIMITED (03643222) Company status Active Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Secretary Appointed on 10 August 2002
REAL ALTERNATIVES LIMITED (07762862) Company status Active Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Secretary Appointed on 5 September 2011 UK Limited Company What's this? Registration number 1479228
CLIFTON 2011 LIMITED (07369980) Company status Active Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role RESIGNED Secretary Appointed on 8 September 2010 Resigned on 22 December 2021 UK Limited Company What's this? Registration number 1479228
With 426 active appointments, the corporate secretary has a span of control that is unusually numerous which introduces a range of risks that have to be mitigated within an audit.
Are there multiple "unique identifiers”, also referred to herein as “identities”, for Argenta Secretariat Limited? No (see below).
A search for other corporate officers with the name Argenta Secretariat Limited in Companies House (ARGENTA SECRETARIAT LIMITED - Find and update company information - GOV.UK (company-information.service.gov.uk)) returns only one identity. Since an entity is required to have just one “unique identifier” in Companies House, this meets the requirements of section 1082 of the Companies Act 2006.
Argenta Secretariat Limited (the company controlling the corporate identity, Argenta Secretariat Limited, which is the secretary of Saffron Underwriting Limited)
The record for the company, Argenta Secretariat Limited, was located in Companies House, by a search on the name. These are related parties to Dame June Raine since they control the secretary of the company of which she was a director. The officers are described here (ARGENTA SECRETARIAT LIMITED people - Find and update company information - GOV.UK (company-information.service.gov.uk)).
19 officers / 13 resignations
BURTON, Sarah Carol-Ann Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Secretary Appointed on 6 October 2020
BIRD, Trevor Robert Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Director Date of birth September 1955 Appointed on 3 August 2001 Nationality British Country of residence England Occupation Members Agent
BURTON, Sarah Carol-Ann Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Director Date of birth October 1976 Appointed on 6 October 2020 Nationality British Country of residence England Occupation Lawyer
FLACH, Robert Paul Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Director Date of birth March 1967 Appointed on 3 December 2018 Nationality British Country of residence England Occupation Director
HUDSON, Guy Bentley Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Director Date of birth November 1960 Appointed on 12 October 2015 Nationality British Country of residence England Occupation Names Director
WARNER, Marcus Gary Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Director Date of birth May 1973 Appointed on 12 October 2015 Nationality British Country of residence England Occupation Accountant
There is one active person with significant control of Argenta Secretariat Limited, (ARGENTA SECRETARIAT LIMITED persons with significant control - Find and update company information - GOV.UK (company-information.service.gov.uk)):
1 active person with significant control / 0 active statements
Argenta Private Capital Limited ACTIVE Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Notified on 6 April 2016
Summary:
Argenta Secretariat Limited's ownership of 544 appointments, with 426 currently active, signals a significant level and span of control. This, coupled with Dame June Raine's failure to disclose their shared interest in Saffron Underwriting Limited, heightens concerns regarding potential cartel-like behaviour.
There are six active officers of Argenta Secretariat Limited, with correspondence address, 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL. The secretary, is also a director.
Sarah Carol-Ann BURTON, secretary, appointed on 6 October 2020 and director, date of birth October 1976, appointed on 6 October 2020, occupation lawyer.
Trevor Robert BIRD, director, date of birth September 1955, appointed on 3 August 2001. Occupation, Members Agent.
Robert Paul FLACH, director, date of birth March 1967, appointed on 3 December 2018.
Guy Bentley HUDSON, director, date of birth November 1960, appointed on 12 October 2015. Occupation, Names Director.
Marcus Gary WARNER, director, date of birth May 1973, appointed on 12 October 2015. Occupation, Accountant.
The person with significant control is Argenta Private Capital Limited. This companies records were
Argenta Private Capital Limited (Argenta Secretariat Limited PSC)
The active officers of Argenta Private Capital Limited are (ARGENTA PRIVATE CAPITAL LIMITED people - Find and update company information - GOV.UK (company-information.service.gov.uk)):
51 officers / 40 resignations
CONNOR, Michael Sean Role ACTIVE Secretary Appointed on 27 January 2021
BOWDERY, Amy Cordelia Jane Role ACTIVE Director Date of birth August 1985 Appointed on 23 March 2022
BURCH, Nicola Monica Alexia Role ACTIVE Director Date of birth February 1966 Appointed on 23 March 2022
FLACH, Robert Paul Role ACTIVE Director Date of birth March 1967 Appointed on 14 September 2018
GLAZE, Philip James Francis Role ACTIVE Director Date of birth June 1964 Appointed on 23 March 2022
HUBBARD, Andrew John Role ACTIVE Director Date of birth July 1950 Appointed on 1 April 2013
HUDSON, Guy Bentley Role ACTIVE Director Date of birth November 1960 Appointed on 1 December 1998 Occupation Names' Director
JACKSON, Kevin Role ACTIVE Director Date of birth November 1966 Appointed 0n 4 November 2022
MOORE, Nicholas John Role ACTIVE Director Date of birth November 1979 Appointed on 31 December 2022
TONGUE, Katharine Louise Role ACTIVE Director Date of birth February 1982 Appointed on 10 November 2022
WARNER, Marcus Gary Role ACTIVE Director Date of birth May 1973 Appointed on 3 September 2003 Nationality Occupation Accountant.
Argenta Private Capital Limited is described as the “Members’ Agent” and as “Regulated by the Financial Conduct Authority” in the 2022 Accounts for Saffron Underwriting Limited. These FCA records will be accessed, later in this report.
The persons with significant control (PSC) of ARGENTA PRIVATE CAPITAL LIMITED is ARGENTA HOLDINGS LIMITED (ARGENTA PRIVATE CAPITAL LIMITED persons with significant control - Find and update company information - GOV.UK (company-information.service.gov.uk)).
The records for Argenta Holding Limited were accessed.
Argenta Holdings Limited (Argenta Private Capital PSC)
Argenta Holdings Limited officers are:
16 officers / 10 resignations
BURTON, Sarah Carol-Ann Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Secretary Appointed on 1 January 2021
ALLEN, Graham Kevin Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Director Date of birth October 1965 Appointed on 1 June 2013 Occupation Finance Director
ALTHOFF, Sven Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Director Date of birth May 1969 Appointed on 20 July 2017 Nationality German Country of residence Germany Occupation Director
BURFORD, Ian Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Director Date of birth October 1967 Appointed on 14 December 2023
MOORE, Nicholas John Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Director Date of birth November 1979 Appointed on 28 July 2022 Occupation Actuary
WHITER, John Lindsay Pearce Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Director Date of birth May 1950 Appointed on 6 September 2017 Occupation Accountant
Hannover Ruck Se (Argenta Holdings PSC)
The controlling party of ARGENTA HOLDINGS LIMITED (ARGENTA HOLDINGS LIMITED persons with significant control - Find and update company information - GOV.UK (company-information.service.gov.uk)) is:
1 active person with significant control / 0 active statements
Hannover Ruck Se ACTIVE Correspondence address 50 Karl-Wiechert-Allee, Hannover, Germany, 30625 Notified on 20 July 2017 Place registered Hannover Registration number Hrb 6778 Incorporated in Germany
Conclusion regarding Argenta Secretariat Limited (Secretary of Saffron Underwriting Limited:
Control Structure: Argent Secretariat Limited, acting as the secretary of Saffron Underwriting Limited, is ultimately controlled by Hannover Ruck Se, a German company. This control passes through various entities, including Argenta Secretariat Limited, Argenta Private Capital Limited, and Argenta Holdings Limited.
Related Parties to Dame June Raine: Directors of Saffron Underwriting Limited, Argenta Secretariat Limited, Argenta Private Capital Limited, Argenta Holdings Limited, and Hannover Ruck Sa are considered to be related parties to Dame June Raine.
Audit Implications: All directorships held by the directors of these companies would typically undergo audits for related party transactions and conflicts of interest. However, the failure of Dame June Raine to declare her interest in Saffron Underwriting Limited to MHRA raises concerns about whether any checks were undertaken.
Uncompleted Checks: Due to Dame June Raine's non-disclosure, critical checks that would normally be conducted for related party transactions and conflicts of interest may not have been completed. This lack of transparency could pose risks to the integrity of the audit process and corporate governance.
A method of fraud that is not well-described method, despite its widespread use of multiple “unique identifiers” registered at Companies House, in contravention of Section 1082 of the Companies Act 2006. These are the entities that are registered as officers, either as secretaries or directors, in Companies House. I refer to “unique identifiers” as identities.
The officers that are part of Dame June Raine’s linked directorate will be tested, by searching Companies House and manually reviewing the records to identify duplicated identities (unique identifiers) where they occur.
Argenta Secretariat Limited directors’ interests and test for multiple identities
Sarah Carol-Ann Burton (Argenta Secretariat Limited secretary and director)
BURTON, Sarah Carol-Ann Date of birth October 1976 Occupation Lawyer.
A search in Companies House using the term “Sarah Carol-Ann Burton” returns 7 identities registered with this name and the same correspondence address (Sarah Carol-Ann BURTON - Find and update company information - GOV.UK (company-information.service.gov.uk)).
The company names relating to these identities have been included, below, from the webpage referenced (links to company details are embedded in the information copied from Companies House).
Identity 1
Total number of appointments 1
5th Floor 70 Gracechurch Street, London, England, EC3V 0XL
NAMES TAXATION SERVICE LIMITED (00944768)
Secretary Appointed on 6 October 2020
Identity 2
Total number of appointments 11 - Born October 1976
5th Floor, 70 Gracechurch Street, London, United Kingdom, EC3V 0XL Director of:
ARGENTA INTERNATIONAL LIMITED (15182825) Appointed on
3 October 2023
FOUNTAIN CONTINUITY LIMITED (SC342435) Appointed on 6 November 2020
RESIDUAL SERVICES LIMITED (08148504) Appointed on 6 October 2020
ARGENTA LLP SERVICES LIMITED (05892019) Appointed on 6 October 2020
RESIDUAL SERVICES CORPORATE DIRECTOR LIMITED (08151905)
Appointed on 6 October 2020
APCL CORPORATE DIRECTOR NO.1 LIMITED (09080154) Appointed on 6 October 2020
ARGENTA SECRETARIAT LIMITED (01479228) Appointed on 6 October 2020
ARGENTA CONTINUITY LIMITED (05891993) Appointed on 6 October 2020
APCL CORPORATE DIRECTOR NO.2 LIMITED (09080184) Appointed on 6 October 2020
ARGENTA SYNDICATE MANAGEMENT LIMITED (03632880) Appointed on 10 September 2020
ARGENTA TAX & CORPORATE SERVICES LIMITED (02881854) Appointed on 1 August 2020
Identity 3
Total number of appointments 1
5th Floor 70 Gracechurch Street, London, England, EC3V 0XL
ARGENTA SECRETARIAT LIMITED (01479228) Secretary Appointed on
6 October 2020
Identity 4
Total number of appointments 1
5th Floor 70 Gracechurch Street, London, England, EC3V 0XL
ARGENTA SYNDICATE MANAGEMENT LIMITED (03632880) Secretary Appointed on 9 December 2020
Identity 5
Total number of appointments 1
5th Floor 70 Gracechurch Street, London, England, EC3V 0XL
ARGENTA HOLDINGS LIMITED (04973117) Secretary Appointed on
1 January 2021
Identity 6
Total number of appointments 1
5th Floor 70 Gracechurch Street, London, England, EC3V 0XL
ARGENTA TAX & CORPORATE SERVICES LIMITED (02881854)
Secretary Appointed on 18 November 2020
Identity 7
Total number of appointments 3 - Born October 1976
5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL
NAMES TAXATION SERVICE LIMITED (00944768) Active director Appointed on 31 December 2022
ARGENTA GENERAL PARTNER LIMITED (SC173830)
First Floor, 9 Haymarket Square, Edinburgh, Scotland, EH3 8RY
Role RESIGNED Director Appointed on 30 July 2020 Resigned on 19 June 2023
HOLMAN FENWICK WILLAN LLP (OC343361) LLP Member Friary Court, 65 Crutched Friars, London, EC3N 2AE Appointed on 10 September 2018 Resigned on 31 May 2020.
Summary
Sarah Carol-Ann Burton, Argenta Secretariat Limited secretary and director has 7 identities. Her appointment as secretary and director are held in two separate identities.
Sarah Carol-Ann Burton has nineteen appointments dispersed across seven identities.
Her first identity (Identity 7) was used to register her partnership membership of Holman Fenwick Willan LLP on 10 September 2018, She resigned on 31 May 2020. On 30 July 2020 she registered as a director of Argenta General Partners Limited.
On 1 August 2020 she registered her second identity (Identity 2, in my analysis) for her appointment to Argenta Tax & Corporate Services Limited. In this identity she became director of Argenta Syndicate Management Limited, on 10 September 2020. On 6 October 2020 she was appointed to seven companies in; Residual Services Limited, Argenta LLP Services Limited, Residual Services Corporate Director Limited, APCL Corporate Director No.1 Limited, Argenta Secretariat Limited, Argenta Continuity Limited, and, APCL Corporate Director No.2 Limited.
The same day, 6 October 2020 she established a third and fourth identity (Identity 1 and Identity 3) for single appointments as secretary to Names Taxation Service Limited and Argenta Secretariat Limited.
On 6 November 2020 she was appointed as a director of Fountain Continuity Limited, in Identity 2. On 18 November 2020 she was appointed a secretary of Argenta Tax & Corporate Services Limited in a fourth identity (Identity 6). On 9 December 2020 she was appointed as secretary of Argenta Syndicate Management Limited in a fifth identity (Identity 4). On 1 January 2021 she was appointed secretary of Argenta Holdings Limited in her sixth identity (Identity 5) which holds just one appointment. On 31 December 2022 she was appointed director of Names Taxation Service Limited, in her first identity (Identity 7). She resigned her directorship of Argenta General Partner Limited on 19 July 2023 held in her first identity. On 3 October 2023 she was appointed as director of Argenta International Limited in Identity 2.
Multiple identities breach section 1082 of the Companies Act 2006
Multiple identities (unique identifiers) breach section 1082 of the Companies Act 2006. Interests are effectively concealed from audits and due diligence compromising audits. The requirement of a unique identity for cyber security, anti money laundering and counter-terrorism financing legislation is breached.
Sarah Carol-Ann Burton has registered 7 (seven) identities to hold 19 (nineteen) appointments, in various companies, 17 (seventeen) of which are active. All seven identities are currently active.
This behaviour raises questions about transparency, accountability, and potential conflicts of interest. The use of multiple identities could potentially be indicative of attempts to conceal connections between different companies or to circumvent regulatory scrutiny. It may also suggest a lack of ethical conduct and adherence to corporate governance standards. Further investigation may be warranted to determine the motives behind the use of multiple identities and whether any legal or regulatory violations have occurred.
Trevor Robert Bird (Argenta Secretariat Limited)
BIRD, Trevor Robert Date of birth September 1955 Occupation Members Agent.
A search in Companies House for “Trevor Robert Bird”, returns just one identity with this name (Trevor Robert BIRD - Find and update company information - GOV.UK (company-information.service.gov.uk)). His active appointments are shown below:
Total number of appointments 15
Current appointments 5
Date of birth September 1955
FOUNTAIN CONTINUITY LIMITED (SC342435) Director Appointed on 6 November 2020 Occupation Insurance
THUNDER MOUNTAIN UNDERWRITING LIMITED (03853432) Director Appointed on 28 February 2012
ARGENTA SLP CONTINUITY LIMITED (SC271562) Director Appointed on 11 August 2008
ARGENTA GENERAL PARTNER LIMITED (SC173830) Director Appointed on 3 March 2008
ARGENTA SECRETARIAT LIMITED (01479228) Director Appointed on 3 August 2001 Occupation Members Agent.
Trevor Robert Bird correctly maintains just one identity registered in Companies House, demonstrating transparency in his corporate engagements. The officers associated with each of his 15 companies are also part of Dame June Raine’s linked directorate. This interconnection should be considered within MHRA’s audits as well as within the audit framework of Saffron Underwriting Limited. The interests of Trevor Robert Bird’s co-directors held in one or many unique identities, are not considered here, due to time constraints.
Robert Paul Flach (Argenta Secretariat Limited)
FLACH, Robert Paul Date of birth March 1967
A search in Companies House locates just one identity for Robert Paul Flach, (Robert Flach - Find and update company information - GOV.UK (company-information.service.gov.uk)
Total number of appointments 64
Current appointments 59 (a sample of 6 are copied below as an example).
RESIDUAL SERVICES LIMITED (08148504) Company status Active Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Director Appointed on 25 November 2020 Nationality British Country of residence England Occupation Director
RSL NO.2 LIMITED (03834855) Company status Active Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Director Appointed on 25 November 2020
RESIDUAL SERVICES CORPORATE DIRECTOR LIMITED (08151905) Company status Active Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Director Appointed on 25 November 2020
RSL NO.18 LIMITED (03806670) Company status Active Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Director Appointed on 25 November 2020
APCL CORPORATE DIRECTOR NO.2 LIMITED (09080184) Company status Active Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Director Appointed on 3 December 2018
ARGENTA CONTINUITY LIMITED (05891993) Company status Active Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Director Appointed on 3 December 2018.
Robert Paul Flach correctly maintains just one identity registered in Companies House, demonstrating transparency in his corporate engagements. To fully expand Robert Paul Flach’s linked directorate requires exploring each co-director’s interests held in all the unique identities that they have been registered, and so on. This is not included herein. Within an audit, presently, interests held in other unique identities are excluded from consideration for Related Party Transactions, as they are concealed, as if they belong to another person.
Guy Bentley Hudson (Argenta Secretariat Limited)
HUDSON, Guy Bentley Date of birth November 1960 Occupation Names Director
A manual search for identities named Guy Hudson with date of birth November 1960 located one identity (Guy HUDSON - Find and update company information - GOV.UK (company-information.service.gov.uk)).
Total number of appointments 15
Current appointments 11
OIMARA CAPITAL LIMITED (12510657) Director Appointed on 11 March 2020
KEADEEN UNDERWRITING LIMITED (03637680) Director Appointed on 6 June 2016 Occupation Names Director
ARGENTA LLP SERVICES LIMITED (05892019) Director Appointed on 5 November 2015
ARGENTA CONTINUITY LIMITED (05891993) Director Appointed on 5 November 2015
ARGENTA SECRETARIAT LIMITED (01479228) Director Appointed on 12 October 2015
5 WETHERALL PLACE MANAGEMENT LIMITED (02371674) 10 Waring House, Redcliffe Hill, Bristol, BS1 6TB Director Appointed on 16 November 2014
LAF CAPITAL LIMITED (06292126) Director Appointed on 18 September 2014
APCL CORPORATE DIRECTOR NO.1 LIMITED (09080154)Director Appointed on 10 June 2014
APCL CORPORATE DIRECTOR NO.2 LIMITED (09080184) Director Appointed on 10 June 2014
LUDWIG FUCHS LONDON LIMITED (07772439) Director Appointed on 13 September 2011
ARGENTA PRIVATE CAPITAL LIMITED (00741597) Director Appointed on 1 December 1998
Guy Bentley Hudson correctly maintains just one identity registered in Companies House. He gives his occupation as Names Director in his appointment to Argenta Secretariat Limited, however this is an inaccurate description as he is not an active director of Names Limited. This could be referenced to enable a permission that should be denied.
Marcus Gary Warner (Argenta Secretariat Limited)
WARNER, Marcus Gary Date of birth May 1973 Occupation Accountant
A search on “Marcus Warner” located one identity for Marcus Gary Warner (Marcus Warner - Find and update company information - GOV.UK (company-information.service.gov.uk)). A sample of his current appointments is shown below:
Total number of appointments 68
Current appointments 61
NAMES TAXATION SERVICE LIMITED (00944768) Company status Active Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Director Appointed on 25 May 2011 Occupation Accountant
ARGENTA TAX & CORPORATE SERVICES LIMITED (02881854) Director Appointed on 4 April 2011
SHEPPERDS TYE MANAGEMENT COMPANY LIMITED (06922210) 3 Shepperds Tye Drive, Billericay, Essex, CM12 9FL Role ACTIVE Director Appointed on 9 December 2009
Summary
Argenta Secretariat Limited, is both: a corporate identity that is secretary of Saffron Underwriting Limited, and a company controlled by a secretary and six directors.
There are six active officers of Argenta Secretariat Limited, with correspondence address, 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL. The secretary, is also a director.
Sarah Carol-Ann BURTON, is secretary, appointed on 6 October 2020, and director with date of birth October 1976, appointed on 6 October 2020. Her occupation is “lawyer”. She holds these positions at Argenta Secretariat Limited in two separate identities and has registered a total of seven identities named Sarah Carol-Ann Burton. Overall she has registered 7 (seven) identities to hold 19 (nineteen) appointments, in various companies, 17 (seventeen) of which are active. All seven identities are currently active.
Her co-directors each have just one identity registered, with that date of birth:
Trevor Robert BIRD, director, date of birth September 1955, appointed on 3 August 2001. Occupation, Members Agent. 15 appointments, 5 are current.
Robert Paul FLACH, director, date of birth March 1967, appointed on 3 December 2018. 64 appointments, 59 are current.
Guy Bentley HUDSON, director, date of birth November 1960, appointed on 12 October 2015. Occupation, Names Director. 15 appointments, 11 are current.
Marcus Gary WARNER, director, date of birth May 1973, appointed on 12 October 2015. Occupation, Accountant. 68 appointments, 61 are current.
This section illuminates the concerning practice of employing multiple identities by the secretary, Sarah Carol-Ann Burton, emphasising significant issues pertaining to transparency and accountability within corporate governance. By leveraging seven distinct identities for diverse roles encompassing directorships and secretarial duties, Ms. Burton orchestrates a convoluted network, obfuscating the interrelationships between her appointments. Such opacity heightens the vulnerability to synthetic identity fraud, posing a substantial threat by facilitating the concealment of vested interests from auditors and regulatory authorities.
In addition to the extensive control exerted by officers Robert Paul Flach and Marcus Gary Warner, with a combined total of 120 appointments, it's imperative to acknowledge the heightened susceptibility to conflicts of interest and potential abuse of power within Saffron Underwriting Limited. The substantial concentration of appointments under their purview amplifies apprehensions regarding the emergence of cartel-like behaviour, where concerted actions could distort market dynamics and impede fair competition. Given these risks, there is a pressing need for thorough scrutiny through independent audits to ensure regulatory compliance and uphold integrity within the insurance sector.
Argenta Private Capital Limited: Test for synthetic identities:
From the accounts referenced above we know that Argenta Private Capital Limited is the Managing Agent of Saffron Underwriting Limited and from Companies House we learnt that it is several hundred other companies. The active officers of Argenta Private Capital Limited are tested, below, for multiple identities (ARGENTA PRIVATE CAPITAL LIMITED people - Find and update company information - GOV.UK (company-information.service.gov.uk)):
Michael Sean Connor (Argenta Private Capital Limited)
CONNOR, Michael Sean Role ACTIVE Secretary Appointed on 27 January 2021.
A search locates 4 identities with the same three names and the same correspondence address (Michael Sean CONNOR - Find and update company information - GOV.UK (company-information.service.gov.uk)
Identity 1
Total number of appointments 1
5th Floor, 70 Gracechurch Street, London, United Kingdom, EC3V 0XL
ARGENTA INTERNATIONAL LIMITED (15182825) Secretary Appointed on 3 October 2023
Identity 2
Total number of appointments 1
5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL
ARGENTA PRIVATE CAPITAL LIMITED (00741597) Role ACTIVE
Secretary Appointed on 27 January 2021
Identity 3
Michael Sean CONNOR
Total number of appointments 1
12 Hildenbrook Farm, Riding Lane, Hildenborough, Kent, United Kingdom, TN11 9JN
LCM MARKETING SERVICES LIMITED (08579415) Secretary Appointed on 21 June 2013 Resigned on 21 October 2014
Identity 4 Michael Sean CONNOR
Total number of appointments 17 (2 active, shown below) - Born May 1966
5th Floor, 70, Gracechurch Street, London, England, EC3V 0XL
CBS PRIVATE CAPITAL SLP LIMITED (SC166607) Director Appointed on 29 June 2023
ARGENTA GENERAL PARTNER LIMITED (SC173830) Director Appointed on 19 June 2023
A quick look at the secretary of Argenta General Partner Limited, details:
DENTONS SECRETARIES LIMITED One Fleet Place, London, United Kingdom, EC4M 7WS Role ACTIVE Secretary Appointed on
8 December 2017
Total number of appointments 1300 Current appointments 338 (including:)
RAINE INTERNATIONAL HOLDINGS UK LIMITED (13780881) Secretary Appointed on 14 December 2022 Registration number 03929157
NOWVERTICAL UK HOLDINGS LTD (14540938) Secretary
Appointed on 14 December 2022 Registration number 03929157
The secretary of Argenta General Partner Limited is a corporate identity, Dentons Secretaries Limited. Dentons Secretaries Limited correctly holds just one identity (Dentons Secretaries Limited - Find and update company information - GOV.UK (company-information.service.gov.uk)). It holds an unusually large number of appointments “Total number of appointments 1300” of which 355 are current, which raises audit challenges.
Dentons Secretaries Limited is also secretary of Raine International Holdings UK Limited, which has the same name, with an unusual spelling, as Dame June Raine. Further investigation is required to understand the full scope of this interconnected network.
Summary:
Michael Sean Connor serves as an active secretary in Argenta Private Capital Limited since his appointment on 27 January 2021. A search reveals four identities associated with Michael Sean Connor, all sharing the same three names and correspondence address.
Identity 1: Michael Sean Connor serves as secretary in Argenta International Limited, appointed on 3 October 2023.
Identity 2: Michael Sean Connor is appointed as secretary in Argenta Private Capital Limited.
Identity 3: Michael Sean Connor previously served as secretary in LCM Marketing Services Limited from 21 June 2013 to 21 October 2014.
Identity 4: Michael Sean Connor holds 17 appointments, including active director roles in CBS Private Capital SLP Limited and Argenta General Partner Limited.
The secretary of Argenta General Partner Limited is a corporate entity, Dentons Secretaries Limited, with an unusually high number of appointments, posing audit challenges. Dentons Secretaries Limited is also the secretary of Raine International Holdings UK Limited, warranting further investigation into the interconnected network.
Amy Cordelia Jane Bowdery (Argenta Private Capital Limited)
BOWDERY, Amy Cordelia Jane Role ACTIVE Director Date of birth August 1985 Appointed on 23 March 2022
A search in Companies House returns just one identity (Amy Cordelia Jane BOWDERY - Find and update company information - GOV.UK (company-information.service.gov.uk)).
Total number of appointments 2
Date of birth August 1985
ARGENTA PRIVATE CAPITAL LIMITED (00741597) Director Appointed on 23 March 2022
59 HARVIST ROAD RTM LIMITED (06106616) Director Appointed on 4 April 2014 Resigned on 15 August 2022
Nicola Monica Alexia BURCH (Argenta Private Capital Limited)
BURCH, Nicola Monica Alexia Role ACTIVE Director Date of birth February 1966 Appointed on 23 March 2022 Total number of appointments 1
A search returns 4 identities (Nicola Monica Alexia BURCH - Find and update company information - GOV.UK (company-information.service.gov.uk)):
Identity 1
Total number of appointments 1 - Born February 1966
5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL
ARGENTA PRIVATE CAPITAL LIMITED (00741597) Director Appointed on 23 March 2022
Identity 2
Total number of appointments 1 - Born February 1966
30 Fenchurch Avenue, London, EC3M 5AD
ARK SYNDICATE MANAGEMENT LIMITED (05887810) Director Appointed on 1 January 2022
Identity 3
Total number of appointments 1 - Born February 1966
60 Threadneedle Street, London, EC2R 8HP
TALBOT UNDERWRITING LTD (02202362) Director Appointed on 7 April 2017 Resigned on 12 November 2021
Identity 4
Total number of appointments 3 - Born February 1966
100 Barbirolli Square, Manchester, , , M2 3AB
ADDLESHAW GODDARD LLP (OC318149) LLP Designated Member Appointed on 28 April 2006 Resigned on 30 April 2016
ADDLESHAW GODDARD (HONG KONG) LLP (OC378761) LLP Designated Member Appointed on 25 February 2013 Resigned on 21 June 2013
ADDLESHAW GODDARD (HONG KONG) LLP (OC378761) LLP Designated Member Appointed on 25 September 2012 Resigned on 27 November 2012
Summary:
Nicola Monica Alexia Burch holds multiple directorship appointments across various companies, with a total of four identities found through a search. The details of her appointments are as follows:
Identity 1: Director of Argenta Private Capital Limited, located at 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL. Appointed on 23 March 2022.
Identity 2: Director of Ark Syndicate Management Limited, situated at 30 Fenchurch Avenue, London, EC3M 5AD. Appointed on 1 January 2022.
Identity 3: Former Director of Talbot Underwriting Ltd, previously located at 60 Threadneedle Street, London, EC2R 8HP. Resigned on 12 November 2021.
Identity 4: Former LLP Designated Member of Addleshaw Goddard LLP and Addleshaw Goddard (Hong Kong) LLP, with multiple appointments and resignations.
Conclusion:
The discovery of four identities associated with Nicola Monica Alexia Burch raises concerns regarding potential violations of section 1082 of the Companies Act 2006.
Robert Paul Flach (Argenta Private Capital Limited)
FLACH, Robert Paul Role ACTIVE Director Date of birth March 1967 Appointed on 14 September 2018.
Covered above with Argenta Secretariat Limited directors (1 identity: 64 appointments)
Philip James Francis Glaze (Argenta Private Capital Limited)
GLAZE, Philip James Francis Role ACTIVE Director Date of birth June 1964 Appointed on 23 March 2022
A search on Philip Glaze returns just one identity (Philip GLAZE - Find and update company information - GOV.UK (company-information.service.gov.uk)) https://find-and-update.company-information.service.gov.uk/search/officers?q=Philip+GLAZE
ARGENTA PRIVATE CAPITAL LIMITED (00741597) Director Appointed on 23 March 2022
HSBC GLOBAL ASSET MANAGEMENT (UK) LIMITED (01917956) Director Appointed on 12 October 2016 Resigned on 28 February 2020 Chief Investment Officer
Andrew John Hubbard (Argenta Private Capital Limited)
HUBBARD, Andrew John Role ACTIVE Director Date of birth July 1950 Appointed on 1 April 2013
A search returns one identity with this date of birth. (Andrew John HUBBARD - Find and update company information - GOV.UK (company-information.service.gov.uk)). Note that there are nine identities with this combination of names, which is unusually high, including a secretary with no date of birth. There is a risk that he claims other identities with this name but a different date of birth. Andrew John Hubbard’s appointments in his claimed identity are:
Total number of appointments 7
Current appointments 3
ARGENTA PRIVATE CAPITAL LIMITED (00741597) Director Appointed on 1 April 2013
WAVERTON PROPERTY LLP (OC371215) LLP Member Appointed on 4 April 2012
ALPHA DIVING LTD (07021022) Director Appointed on 16 September 2009
ASTA MANAGING AGENCY LTD (01918744) Director Appointed on 1 April 2014 Resigned on 30 June 2023
NORTH JOHN STREET LLP (OC380183) LLP Member Appointed on 3 April 2013 Resigned on 5 April 2022
MAZARS LLP (OC308299) 121 Downs Court Road, Purley, , , CR8 1BH Role RESIGNED LLP Member Appointed on 31 August 2004 Resigned on 31 December 2012
MAZARS PGC INTERIMS LIMITED (04575184) Director Appointed on 21 October 2003 Resigned on 3 December 2012
Whilst Andrew John Hubbard has been a director of Argenta Private Capital Limited since April 2013 he has concurrently held appointments to: North John Street LLP, from 3 April 2013 to 5 April 2022; Waverton Properties LLP, since 4 April 2012; Alpha Diving Ltd, since 16 September 2009, Asta Managing Agency Ltd between 1 April 2014 and 30 June 2023. Further analysis is required to determine whether these interests were declared.
Guy Bentley Hudson (Argenta Private Capital Limited)
HUDSON, Guy Bentley Role ACTIVE Director Date of birth November 1960 Appointed on 1 December 1998 Occupation Names' Director
Described above, relating to Argenta Secretariat Limited. 1 identity, 15 appointments, 11 of which are current.
These interests would have been assessed for related party transactions by the auditors of MHRA, if Dame June Raines had declared her interest in Saffron Underwriting Limited.
Kevin Jackson (Argenta Private Capital Limited)
JACKSON, Kevin Role ACTIVE Director Date of birth November 1966 Appointed 0n 4 November 2022.
Kevin Jackson only has one identity registered with date of birth November 1966, located in a search (Kevin JACKSON - Find and update company information - GOV.UK (company-information.service.gov.uk). Kevin Jackson has
Total number of appointments 8
Current appointments 5
ARGENTA PRIVATE CAPITAL LIMITED (00741597) Director Appointed on 4 November 2022
FOUNTAIN CONTINUITY LIMITED (SC342435) Director Appointed on 6 November 2020 Occupation Administration Manager
CBS PRIVATE CAPITAL SLP LIMITED (SC166607) 10 Fernbank Close, Chatham, Kent, United Kingdom, ME5 9NH Director Appointed on 21 November 2011 Administration Manager
ARGENTA SLP CONTINUITY LIMITED (SC271562) Director Appointed on 4 November 2011 Administration Manager
ARGENTA GENERAL PARTNER LIMITED (SC173830) Director Appointed on 4 November 2011
Nicholas John Moore (Argenta Private Capital Limited)
MOORE, Nicholas John Role ACTIVE Director Date of birth November 1979 Appointed on 31 December 2022. A search located just one identity registered with date of birth November 1979 (Nicholas John MOORE - Find and update company information - GOV.UK (company-information.service.gov.uk)).
Total number of appointments 16
Current appointments 16. (All active)
Date of birth November 1979
ARGENTA INTERNATIONAL LIMITED (15182825) Director Appointed on 13 October 2023
ARGENTA NO.17 LIMITED (15181000) Director Appointed on 2 October 2023
ARGENTA NO.16 LIMITED (15180936) Director Appointed on 2 October 2023
INTER HANNOVER (NO.2) LIMITED (12116622) Director Appointed on 3 July 2023
ARGENTA PRIVATE CAPITAL LIMITED (00741597) Director Appointed on 31 December 2022
ARGENTA UNDERWRITING NO. 1 LIMITED (05308160)
Director Appointed on 31 December 2022
ARGENTA UNDERWRITING NO.2 LIMITED (02974694) Director Appointed on 31 December 2022
ARGENTA UNDERWRITING NO.3 LIMITED (05661867) Director Appointed on 31 December 2022
ARGENTA UNDERWRITING NO. 4 LIMITED (05934931) Director Appointed on 31 December 2022
ARGENTA UNDERWRITING NO.7 LIMITED (07066530) Director Appointed on 31 December 2022
ARGENTA UNDERWRITING NO.9 LIMITED 07390456) Director Appointed on 31 December 2022
ARGENTA UNDERWRITING NO.10 LIMITED (07792027) Director Appointed on 31 December 2022
ARGENTA UNDERWRITING NO.11 LIMITED (07792037) Director Appointed on 31 December 2022
INTER HANNOVER (NO.1) LIMITED (07036902) Director Appointed on 31 December 2022
ARGENTA HOLDINGS LIMITED (04973117) Director Appointed on 28 July 2022 Actuary
ARGENTA SYNDICATE MANAGEMENT LIMITED (03632880) Director Appointed on 31 July 2012 Actuary
Katharine Louise Tongue (Argenta Private Capital Limited)
TONGUE, Katharine Louise Role ACTIVE Director Date of birth February 1982 Appointed on 10 November 2022. A search for Katherine Louise Tongue located 2 identities, (Katharine TONGUE - Find and update company information - GOV.UK (company-information.service.gov.uk)).
Identity 1
Total number of appointments 2
Current appointments 2
ARGENTA PRIVATE CAPITAL LIMITED (00741597) Director Appointed on 10 November 2022
ARGENTA TAX & CORPORATE SERVICES LIMITED (02881854) Director Appointed on 1 November 2019
Identity 2
Katharine Louise TONGUE personal appointments - Find and update company information - GOV.UK (company-information.service.gov.uk)
Total number of appointments 1
ARGENTA GENERAL PARTNER LIMITED (SC173830) Director Appointed on 19 June 2023 Occupation Tax Adviser
Interests in one identity are concealed from the other for the purposes of audit and due diligence. This compromises audits associated with her Katherine Louise Tongue.
Marcus Gary Walker (Argenta Private Capital Limited)
WARNER, Marcus Gary Role ACTIVE Director Date of birth May 1973 Appointed on 3 September 2003 Nationality Occupation Accountant.
A search locates just one identity with this date of birth, May 1973 (Marcus WARNER - Find and update company information - GOV.UK (company-information.service.gov.uk)).
Marcus Gary WARNER
Total number of appointments 68
Current appointments 61 (A sample of these are included.)
Date of birth May 1973
N1258 LIMITED (09589095) Director Appointed on 30 November 2023
TIGERSTOOTH LIMITED (09097087) Director Appointed on 30 November 2023
N600 LIMITED (04311828) Director Appointed on 16 October 2023
ARGENTA GENERAL PARTNER LIMITED (SC173830) Director Appointed on 19 June 2023
SIRIUS UNDERWRITING LIMITED (03818787) Director Appointed on 3 February 2021
Summary of Argenta Private Capital Limited (PSC of Argenta Secretariat Limited)
There are nine active officers:
Michael Sean CONNOR, Secretary Appointed on 27 January 2021. A search reveals he has four identities sharing the same three names and correspondence address:
Identity 1, secretary in Argenta International Limited, appointed on 3 October 2023;
Identity 2, secretary in Argenta Private Capital Limited;
Identity 3, secretary in LCM Marketing Services Limited from 21 June 2013 to 21 October 2014; and,
Identity 4, 17 appointments, 2 active roles in CBS Private Capital SLP Limited and Argenta General Partner Limited. A total of 4 active appointments in 3 identities.
The secretary of Argenta General Partner Limited is a corporate entity, Dentons Secretaries Limited, has 338 active appointments, posing audit challenges. Dentons Secretaries Limited is also the secretary of Raine International Holdings UK Limited. Query whether this is also associated to Dame June Raine.
Amy Cordelia Jane BOWDERY, director, date of birth August 1985, appointed on 23 March 2022. One identity only was located with one active and one resigned appointment, 59 Harvist Road RTM Limited (4 April 2014 to 15 August 2022).
Nicola Monica Alexia BURCH, director, date of birth February 1966, appointed on 23 March 2022. Four identities were located through a search, the first two, listed, are active:
Identity 1: Director of Argenta Private Capital Limited, appointed on 23 March 2022.
Identity 2: Director of Ark Syndicate Management Limited, appointed on 1 January 2022.
Identity 3: Former Director of Talbot Underwriting Ltd, 7 April 2017 to 12 November 2021
Identity 4: Former LLP Designated Member of Addleshaw Goddard LLP (28 April 2006 Resigned on 30 April 2016) and Addleshaw Goddard (Hong Kong) LLP, (25 September 2012 to 7 November 2012 and 25 February 2013 to 21 June 2013).
Robert Paul FLACH, director, date of birth March 1967, appointed on 14 September 2018. Also a director of Argenta Secretariat Limited directors he has one identity: 64 appointments.
Philip James Francis GLAZE, director, date of birth June 1964, appointed on 23 March 2022. A search on Philip Glaze returns just one identity with one active appointment and one resigned appointment to HSBC Global Asset Management (UK) Limited, from 12 October 2016 to 28 February 2020, his occupation was given as Chief Investment Officer.
Andrew John HUBBARD, director, date of birth July 1950, appointed on 1 April 2013 has one identity. He has concurrently held appointments to: North John Street LLP, from 3 April 2013 to 5 April 2022; Waverton Properties LLP, since 4 April 2012; Alpha Diving Ltd, since 16 September 2009, Asta Managing Agency Ltd between 1 April 2014 and 30 June 2023. Further analysis is required to determine whether these interests were declared. This name occurs with unusual frequency. Further analysis on whether they may be related parties is recommended.
Guy Bentley HUDSON, director, date of birth November 1960, appointed on 1 December 1998 Occupation Names' Director. Also a director of Argenta Secretariat Limited. 1 identity, 15 appointments, 11 of which are current.
Kevin JACKSON, director, date of birth November 1966, appointed on 4 November 2022. One identity, 11 appointments, 5 of which are active; Argenta Private Capital Limited, Fountain Continuity Limited, CBS Private Capital SLP Limited, Argenta SLP Continuity Limited, Argenta General Partner Limited.
Nicholas John MOORE, director, date of birth November 1979, appointed on 31 December 2022 has one identity with 16 active appointments: Argenta International Limited, Argenta No.17 Limited, Argenta No.16 Limited, Inter Hannover (No.2) Limited, Argenta Private Capital Limited, Argenta Underwriting No. 1 Limited, Argenta Underwriting No.2 Limited, Argenta Underwriting No.3 Limited, Argenta Underwriting No. 4 Limited, Argenta Underwriting No.7 Limited, Argenta Underwriting No.9 Limited, Argenta Underwriting No.10 Limited, Argenta Underwriting No.11 Limited, Inter Hannover (No.1) Limited, Argenta Holdings Limited, Argenta Syndicate Management Limited.
Katharine Louise TONGUE, director, date of birth February 1982, appointed on 10 November 2022 has 2 identities
Identity 1, 2 appointments both active: Argenta Private Capital Limited (since 10 November 2022) and Argenta Tax & Corporate Services Limited (1 November 2019
Identity 2, 1 appointment, Argenta General Partner Limited appointed on 19 June 2023, occupation Tax Adviser.
Marcus Gary WARNER, director, date of birth May 1973, appointed on 3 September 2003, occupation Accountant. He has one identity with 68 appointments, of which 61 are active. A sample of these are N1258 Limited, Tigerstooth Limited, N600 Limited, Argenta General Partner Limited, Sirius Underwriting Limited.
Conclusion Argenta Private Capital Limited
Three officers have multiple identities and active interests:
Michael Sean Connor, Secretary, has 4 identities, each with an active interest:
Argenta International Limited
Argenta Private Capital Limited
CBS Private Capital SLP Limited
Argenta General Partner Limited
Nicola Monica Alexia Burch, Director, has 4 identities, 2 have an active appointment:
Argenta Private Capital Limited
Ark Syndicate Management Limited
Katharine Louise Tongue, Director, has 2 identities holding 3 active appointments
Argenta Private Capital Limited
Argenta Tax & Corporate Services Limited
Argenta General Partner Limited
The effect of holding multiple identities is twofold: it compromises the accounts of these companies directly, and by association, it compromises the accounts of the companies that the other directors hold.
In conclusion, the analysis reveals multiple instances where directors and officers of Argenta Private Capital Limited hold positions across various companies, raising concerns about transparency and potential breaches of Section 1082 of the Companies Act. Michael Sean Connor, for instance, is associated with four identities, potentially allowing for the manipulation of company structures. Furthermore, the extensive network of appointments, particularly by corporate entities like Dentons Secretaries Limited, poses challenges for audits and oversight. The presence of directors with numerous active appointments, such as Nicholas John Moore and Marcus Gary Warner, underscores the need for closer scrutiny to ensure compliance and prevent conflicts of interest. Additionally, the frequency of certain names, like Andrew John Hubbard, warrants further investigation to determine any potential related-party transactions. Overall, the findings highlight the importance of robust governance mechanisms to uphold accountability and integrity within corporate structures.
Argenta Holdings Limited officers Test for multiple identities:
16 officers / 10 resignations
There are six active officers of Argenta Holdings Limited:
1/6 Sarah Carol-Ann Burton (Argenta Secretariat and Argenta Holdings Limited)
BURTON, Sarah Carol-Ann Argenta Holding Limited Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Secretary Appointed on 1 January 2021
Sarah Carol-Ann Burton is the secretary of Argenta Secretariat Limited and her interests are described above. She has 7 identities, holding 19 appointments, in various companies, 17 of which are active. All seven identities are currently active.
2/6 Graham Kevin Allen (Argenta Holdings Limited)
ALLEN, Graham Kevin Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Director Date of birth October 1965 Appointed on 1 June 2013 Occupation Finance Director
A search located just one identity for Graham Allen with date of birth October 1965 (Graham Kevin ALLEN - Find and update company information - GOV.UK (company-information.service.gov.uk)).
Total number of appointments 20
Current appointments 16
Date of birth October 1965
ARGENTA INTERNATIONAL LIMITED (15182825) Director Appointed on 13 October 2023
ARGENTA NO.17 LIMITED (15181000) Director Appointed on 2 October 2023
ARGENTA NO.16 LIMITED (15180936) Director Appointed on 2 October 2023
INTER HANNOVER (NO.2) LIMITED (12116622) Director Appointed on 3 July 2023
INTER HANNOVER (NO.1) LIMITED (07036902) Director Appointed on 18 January 2021 Finance Director
DYNASTIC UNDERWRITING LIMITED (03627335) Director Appointed on 18 January 2021 Finance Director
ARGENTA UNDERWRITING NO. 1 LIMITED (05308160) Director Appointed on 10 April 2019 Finance Director
ARGENTA UNDERWRITING NO.11 LIMITED (07792037) Director Appointed on 10 April 2019 Finance Director
ARGENTA UNDERWRITING NO. 4 LIMITED (05934931) Director Appointed on 10 April 2019 Finance Director
ARGENTA UNDERWRITING NO.10 LIMITED (07792027) Director Appointed on 10 April 2019 Finance Director
ARGENTA UNDERWRITING NO.7 LIMITED (07066530) Director Appointed on 10 April 2019 Finance Director
ARGENTA UNDERWRITING NO.9 LIMITED (07390456) Director Appointed on 10 April 2019 Finance Director
ARGENTA UNDERWRITING NO.2 LIMITED (02974694) Director Appointed on 10 April 2019 Finance Director
ARGENTA UNDERWRITING NO.3 LIMITED (05661867) Director Appointed on 10 April 2019 Finance Director
ARGENTA HOLDINGS LIMITED (04973117) Director Appointed on 1 June 2013 Finance Director
ARGENTA SYNDICATE MANAGEMENT LIMITED (03632880) Director Appointed on 5 November 2002 Finance Director
3/6 Sven Althoff (Argenta Holdings Limited)
ALTHOFF, Sven Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Director Date of birth May 1969 Appointed on 20 July 2017 Nationality German Country of residence Germany Occupation Director.
A search locates 3 identities for Sven Althoff, date of birth May 1969 (Sven ALTHOFF - Find and update company information - GOV.UK (company-information.service.gov.uk)).
Identity 1
Sven Althoff
Total number of appointments 3
Date of birth May 1969
ARGENTA SYNDICATE MANAGEMENT LIMITED (03632880) Company status Active Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Director Appointed on 31 August 2017 Nationality German Country of residence Germany Occupation Director
ARGENTA HOLDINGS LIMITED (04973117) Company status Active Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Director Appointed on 20 July 2017 Nationality German Country of residence Germany Occupation Director
APOLLO SYNDICATE MANAGEMENT LIMITED (09181578) Company status Active Correspondence address One Bishopsgate, London, United Kingdom, EC2N 3AQ Role RESIGNED Director Appointed on 1 November 2014 Resigned on 7 March 2019 Nationality German Country of residence Germany Occupation Ned
Identity 2
Sven ALTHOFF (Sven ALTHOFF personal appointments - Find and update company information - GOV.UK (company-information.service.gov.uk))
Total number of appointments 1
Date of birth May 1969
HANNOVER RE UK LIFE BRANCH (FC038918)
Karl-Wiechert-Allée 50, Hannover, Lower Saxony 30625, Germany Director Appointed on 23 September 2021 Nationality German Country of residence Germany Occupation Director
Identity 3
Sven ALTHOFF (Sven ALTHOFF personal appointments - Find and update company information - GOV.UK (company-information.service.gov.uk))
Total number of appointments 1
Date of birth May 1969
INTEGRA INSURANCE SOLUTIONS LIMITED (06760260) Currer House, Currer Street, Bradford, West Yorkshire, BD1 5BA Director Appointed on 20 September 2011 Resigned on 15 March 2018 Nationality German Country of residence Germany Occupation Managing Director
Conclusion: Sven Althoff has registered three identities in contravention Section 1082 of the Companies Act 2006. One identity holds active interests in Argenta Syndicate Management Limited (since 31 August 2017) and Argenta Holdings Limited (since 20 July 2017) and a resigned interest in Apollo Syndicate Management Limited (1 Novembuiop[.er 2014 to 7 March 2019). A second identity is appointed to Hannover RE UK Life Branch (since 23 September 2021). A third identity holds a resigned appointment to Integra Insurance Solutions Limited (20 September 2011 to 15 March 2018).
Case study of how multiple identities deceive audit software.
A person or audit software entering the first identity will see that Sven Althoff is a director of two active Argenta Companies. Checking these, the audit will locate that the person with significant control of Argenta Holdings Limited is “Hannover Ruck Se. Correspondence address, 50 Karl-Wiechert-Allee, Hannover, Germany, 30625. Notified on 20 July 2017. Place registered, Hannover Registration number Hrb 6778, incorporated in Germany.” The audit trail then needs to check the German Registry and may well give up, as I did when I located this information (above in this document), because, a search in Companies House on this name locates no record (Hannover Ruck Se - Find and update company information - GOV.UK (company-information.service.gov.uk), see image:
The auditor or software would not be aware that under a second identity for Sven Thoff, he holds a directorship to Hannover RE UK Life Branch (since 23 September 2021) (Sven ALTHOFF personal appointments).
When this record for Hannover RE UK Life Branch is entered, by clicking on the link, the records for HANNOVER RÜCK SE Company number FC038918 are revealed, see image.
HANNOVER RÜCK SE (FC038918) Overseas company address Karl-Wiechert-Allée 50, Hannover, Lower Saxony 30625, Germany Company status Active Company type Overseas company First UK establishment opened on 1 November 2012 Last accounts made up to 31 December 2022
Previous company names HANNOVER RE UK LIFE BRANCH23 Sep 2021 - 20 Jun 2022
Company details in the country of incorporation Incorporated in GERMANY Registration number HRB 6778 Legal form Socetas Europea (Public Company Limited By Shares) Parent registry Lowe Saxony District Court Hannover Governing law German Objects of the company Reinsurance and other classes of insurance
Anomaly in Sven Althoff Identity 2.
The record for Sven Althoff (Identity 2) in Companies House, Sven ALTHOFF personal appointments contains a material misstatement, since it lists an appointment as Hannover RE UK Life Branch. However, this is the previous name of HANNOVER RÜCK SE. This misstatement in Sven Althoff’s record can only be achieved through complicity with Companies House, as this record should include only the current name of this company HANNOVER RÜCK SE and not Hannover RE UK Life Branch.
Explanation of why this company was not located in the search, earlier.
The “Ü” in RÜCK meant that the record for HANNOVER RÜCK SE was not located with a search on HANNOVER RUCK SE. This is a normal, but under recognised, limitation of search engines.
Misstatement of person with significant control record for Argenta Holdings Limited.
Above, we located the record for Argenta Holdings Limited, person with significant control, see image below:
The person with significant control of Argenta Holdings Limited is incorrectly spelt in the Companies House record as “Hannover Ruck Se” instead of Hannover RÜCK SE. This had the result of Hannover RÜCK SE not being located in a search using “Hannover Ruck SE”. This misspelling interrupts the transparency of the persons with significant control of Argenta Holding Limited. As shown in my analysis near the beginning of this report.
If the record for Argenta Holdings Limited had been correctly referenced the persons with significant control, I would have located Hannover RÜCK SE. I would then have presented the officers of Hannover RÜCK SE, as these are the persons with ultimate control of Argenta Secretariat Limited.
HANNOVER RÜCK SE people - Find and update company information - GOV.UK (company-information.service.gov.uk)
8 officers / 0 resignations
ALTHOFF, Sven Correspondence address Karl-Wiechert-Allée 50, Hannover, Lower Saxony 30625, Germany Role ACTIVE Director Date of birth May 1969 Appointed on 23 September 2021 Nationality German Country of residence Germany Occupation Director
CHÈVRE, Claude Jacques Correspondence address Karl-Wiechert-Allée 50, Hannover, Lower Saxony 30625, Germany Role ACTIVE Director Date of birth August 1967 Appointed on 23 September 2021 Nationality Swiss Country of residence Germany Occupation Director
HENCHOZ, Jean-Jacques Correspondence address Karl-Wiechert-Allée 50, Hannover, Lower Saxony 30625, Germany Role ACTIVE Director Date of birth September 1964 Appointed on 23 September 2021 Nationality Swiss Country of residence Germany Occupation Director
JUNGSTHÖFEL, Clemens Correspondence address Karl-Wiechert-Allée 50, Hannover, Lower Saxony 30625, Germany Role ACTIVE Director Date of birth September 1970 Appointed on 23 September 2021 Nationality German Country of residence Germany Occupation Director
MILLER, Klaus Wilhelm Correspondence address Karl-Wiechert-Allée 50, Hannover, Lower Saxony 30625, Germany Role ACTIVE Director Date of birth August 1960 Appointed on 23 September 2021 Nationality German Country of residence Germany Occupation Director
OOI, Sharon Joanne Correspondence address 20 Gracechurch Street, London, United Kingdom, EC3V 0BG Role ACTIVE Director Date of birth March 1972 Appointed on 1 January 2023 Nationality Singaporean Country of residence United Kingdom Occupation Director
PICKEL, Michael Benedikt Correspondence address Karl-Wiechert-Allée 50, Hannover, Lower Saxony 30625, Germany Role ACTIVE Director Date of birth December 1960 Appointed on 23 September 2021 Nationality German Country of residence Germany Occupation Lawyer
SEHM, Silke Correspondence address Karl-Wiechert-Allée 50, Hannover, Lower Saxony 30625, Germany Role ACTIVE Director Date of birth August 1968 Appointed on 23 September 2021 Nationality German Country of residence Germany Occupation Director
The statement given within “persons with significant control” of HANNOVER RÜCK SE states “There are no persons with significant control or statements available for this company.” (HANNOVER RÜCK SE persons with significant control - Find and update company information - GOV.UK (company-information.service.gov.uk)). Therefore the directors listed above have ultimate control of Argenta Secretariat Limited.
Due diligence on the directors of HANNOVER RÜCK SE.
8 officers / 0 resignations
Sven Althoff (HANNOVER RÜCK SE)
ALTHOFF, Sven Correspondence address Karl-Wiechert-Allée 50, Hannover, Lower Saxony 30625, Germany Role ACTIVE Director Date of birth May 1969 Appointed on 23 September 2021 Nationality German Country of residence Germany Occupation Director (repeated from above).
Sven Althoff has registered three identities in contravention Section 1082 of the Companies Act 2006. One identity holds active interests in Argenta Syndicate Management Limited (since 31 August 2017) and Argenta Holdings Limited (since 20 July 2017) and a resigned interest in Apollo Syndicate Management Limited (1 November 2014 to 7 March 2019). A second identity is appointed to Hannover RE UK Life Branch (since 23 September 2021). A third identity holds a resigned appointment to Integra Insurance Solutions Limited (20 September 2011 to 15 March 2018).
Claude Jacques CHÈVRE
CHÈVRE, Claude Jacques Correspondence address Karl-Wiechert-Allée 50, Hannover, Lower Saxony 30625, Germany Role ACTIVE Director Date of birth August 1967 Appointed on 23 September 2021 Nationality Swiss Country of residence Germany Occupation Director.
Claude Jacques CHÈVRE holds only this one appointment in this identity (Claude Jacques CHÈVRE personal appointments - Find and update company information - GOV.UK (company-information.service.gov.uk)).
A search on the name Claude Jacques CHÈVRE (Claude Jacques CHÈVRE - Find and update company information - GOV.UK (company-information.service.gov.uk)) locates two identities. Identity 2 holds
Claude Jacques CHÈVRE
Total number of appointments 1
Date of birth August 1967
HANNOVER RE UK LIFE BRANCH (FC031096) Company status Converted / Closed Correspondence address 50 Karl-Wiechert-Allee, Hannover, Lower Saxony 30625, Germany Role Director Appointed on 3 December 2012 Nationality Swiss Country of residence Germany Occupation Director
The second identity for Claude Jacques CHÈVRE shows that he is appointed as a director of a “Converted / Closed company” HANNOVER RE UK LIFE BRANCH (FC031096). The overview for this company provides:
HANNOVER RE UK LIFE BRANCH Company number FC031096
Overseas company address Branch Registration, Refer To Parent Registry
Company status Converted / Closed
Closed on 30 May 2013
Company type Overseas company
First UK establishment opened on 1 November 2012
Accounts Last accounts made up to 31 December 2011
Company details in the country of incorporation Incorporated in GERMANY Registration number HRB 6778 Legal form Public Company Limited By Shares Parent registry Lower Saxony District Court Hannover Objects of the company
The purpose of the company is to cobduct (sic) the business of transport insurance and
There is an anomaly evident in that the “Last accounts made up to 31 December 2011” which is prior to the establishment of the company on 1 November 2012 and final accounts up to the date of closure on 30 May 2013 are not submitted. This is a breach of the Companies Act 2006.
This company has another board of directors, that did not resign and have not submitted accounts and require further consideration: HANNOVER RE UK LIFE BRANCH people - Find and update company information - GOV.UK (company-information.service.gov.uk). These are not analysed here.
This is the second occurrence of the name HANNOVER RE UK LIFE BRANCH.
Recalling, from the overview information on HANNOVER RÜCK SE (FC038918):
HANNOVER RÜCK SE (FC038918) Overseas company address Karl-Wiechert-Allée 50, Hannover, Lower Saxony 30625, Germany Company status Active Company type Overseas company First UK establishment opened on 1 November 2012 Last accounts made up to 31 December 2022
Previous company names HANNOVER RE UK LIFE BRANCH 23 Sep 2021 - 20 Jun 2022
Conclusion.
HANNOVER RE UK LIFE BRANCH is a name that has been used twice in the Companies House registry. It is registered in Companies House as the name of an overseas branch of a company, now convert / closed, incorporated in GERMANY, Registration number HRB 6778, and this has a company registration number FC031096. HANNOVER RE UK LIFE BRANCH is also the previous name of HANNOVER RÜCK SE, with registration number FC038918, which provides no information on its person with significant control.
Using the same name twice in the Companies House registry constitutes a breach of the Companies Act 2006. This practice poses significant risks, especially if the closed company still operates a bank account using its registration number, potentially leading to confusion, financial discrepancies, and regulatory violations.
It is this record that is deceptive:
The controlling party of ARGENTA HOLDINGS LIMITED (ARGENTA HOLDINGS LIMITED persons with significant control - Find and update company information - GOV.UK (company-information.service.gov.uk)) is:
1 active person with significant control / 0 active statements
Hannover Ruck Se ACTIVE Correspondence address 50 Karl-Wiechert-Allee, Hannover, Germany, 30625 Notified on 20 July 2017 Place registered Hannover Registration number Hrb 6778 Incorporated in Germany
The record of the controlling party of ARGENTA HOLDINGS LIMITED should have referred to HANNOVER RÜCK SE instead of Hannover Ruck Se. This is a material misstatement that obscures the link to HANNOVER RÜCK SE, which is registered in Companies House.
Returning to the remaining directors of HANNOVER RÜCK SE:
Jean-Jacques HENCHOZ (HANNOVER RÜCK SE)
HENCHOZ, Jean-Jacques Correspondence address Karl-Wiechert-Allée 50, Hannover, Lower Saxony 30625, Germany Role ACTIVE Director Date of birth September 1964 Appointed on 23 September 2021 Nationality Swiss Country of residence Germany Occupation Director
Jean-Jacques HENCHOZ has only one interest held in this identity. A search on his name reveals that he has registered two identities (Jean-Jacques HENCHOZ - Find and update company information - GOV.UK (company-information.service.gov.uk)).
His second identity holds one resigned appointment (Jean-Jacques HENCHOZ personal appointments - Find and update company information - GOV.UK (company-information.service.gov.uk):
Jean-Jacques HENCHOZ
Total number of appointments 1
Date of birth September 1964
SWISS RE EUROPE S.A. (FC027979) Company status Active Correspondence address 50/60, Mythenquai, Zurich, Ch8022, Switzerland Role RESIGNED Director Appointed on 17 April 2012 Resigned on 22 August 2018 Nationality Swiss Country of residence Switzerland Occupation Company Director
This is a potential conflict of interest between Jen-Jacques Henchoz’s previous role as director of Swiss RE Europe S.A and his current role as director of HANNOVER RÜCK SE, particularly since his interest in both companies is normally concealed since these appointments are held in two separate identities.
The directors of Swiss RE Europe S.A. are therefore related parties of Dame June Raine, via Jean-Jacques, director of HENCHOZ (HANNOVER RÜCK SE), a person with ultimate control of Argenta Secretariat Limited the secretary of Saffron Underwriting, and should be included within any audit involving Dame June Raine (SWISS RE EUROPE S.A. people - Find and update company information - GOV.UK (company-information.service.gov.uk)). This is not included herein.
Clemens JUNGSTHÖFEL (HANNOVER RÜCK SE)
JUNGSTHÖFEL, Clemens Correspondence address Karl-Wiechert-Allée 50, Hannover, Lower Saxony 30625, Germany Role ACTIVE Director Date of birth September 1970 Appointed on 23 September 2021 Nationality German Country of residence Germany Occupation Director.
Clemens JUNGSTHÖFEL has just one appointment in this identity.
A search on his name locates only this one identity (Clemens JUNGSTHÖFEL - Find and update company information - GOV.UK (company-information.service.gov.uk)).
Klaus Wilhelm MILLER (HANNOVER RÜCK SE)
MILLER, Klaus Wilhelm Correspondence address Karl-Wiechert-Allée 50, Hannover, Lower Saxony 30625, Germany Role ACTIVE Director Date of birth August 1960 Appointed on 23 September 2021 Nationality German Country of residence Germany Occupation Director.
Klaus Wilhelm MILLER holds just one appointment in this identity.
A search on his name locates a total of four identities (Klaus Wilhelm MILLER - Find and update company information - GOV.UK (company-information.service.gov.uk)).
Identity 2
Total number of appointments 1
Date of birth August 1960
HANNOVER LIFE REASSURANCE (UK) LIMITED (01752067) Company status Dissolved Correspondence address Hannover House, Station Parade, Virginia Water, Surrey, GU25 4AA Role Director Appointed on 8 February 2011 Nationality German Country of residence Germany Occupation Actuary
Identity 3
Total number of appointments 1
Date of birth August 1960
HANNOVER RE UK LIFE BRANCH (FC031096) Company status Converted / Closed Correspondence address 50 Karl-Wiechert-Allee, Hannover, Lower Saxony 30625, Germany Role Director Appointed on 3 December 2012 Nationality German Country of residence Germany Occupation Director
Identity 4
Klaus Wilhelm MILLER
Total number of appointments 1
Date of birth August 1960
SCOR GLOBAL LIFE REINSURANCE SERVICES UK LIMITED (04502492) Company status Dissolved Correspondence address Helene-Weber-Allee 18, Munich, D-80637, Germany, FOREIGN Role RESIGNED Director Appointed on 4 August 2003 Resigned on 5 March 2008 Nationality German Occupation Managing Director
Klaus Wilhelm Miller has registered four identities in Companies House in breach of Section 1082 of Companies Act 2006 which requires individuals to establish one unique identifier (identity). The effect of multiple identities is to conceals interests from audits, compromising our systems of accountability. Klaus Wilhelm Millar holds three active appointments in three separate identities. This compromises the audits of each company; HANNOVER LIFE REASSURANCE (UK) LIMITED (01752067),
Sharon Joanne OOI (HANNOVER RÜCK SE)
OOI, Sharon Joanne Correspondence address 20 Gracechurch Street, London, United Kingdom, EC3V 0BG Role ACTIVE Director Date of birth March 1972 Appointed on 1 January 2023 Nationality Singaporean Country of residence United Kingdom Occupation Director.
Sharon Joanne OOI only has one interest appointed to this identity.
A search on the name locates only one identity (Sharon Joanne OOI - Find and update company information - GOV.UK (company-information.service.gov.uk)).
Michael Benedikt PICKEL (HANNOVER RÜCK SE)
PICKEL, Michael Benedikt Correspondence address Karl-Wiechert-Allée 50, Hannover, Lower Saxony 30625, Germany Role ACTIVE Director Date of birth December 1960 Appointed on 23 September 2021 Nationality German Country of residence Germany Occupation Lawyer.
This is the only appointment held in this identity.
A search on his name locates 3 identities with this name (Michael Benedikt PICKEL - Find and update company information - GOV.UK (company-information.service.gov.uk). The other identities are:
Identity 2
Total number of appointments 1
Date of birth December 1960
HANNOVER RE UK LIFE BRANCH (FC031096) Company status Converted / Closed Correspondence address 50 Karl-Wiechert-Allee, Hannover, Lower Saxony 30625, Germany Role Director Appointed on 3 December 2012 Nationality German Country of residence Germany Occupation Director
Identity 3
Michael Benedikt PICKEL
Total number of appointments 1
Date of birth December 1960
HANNOVER RE HOLDINGS (UK) LIMITED (12785014) Company status Active Correspondence address 20 Gracechurch Street, London, England, EC3V 0BG Role ACTIVE Director Appointed on 1 August 2020 Nationality German Country of residence Germany Occupation Lawyer
Michael Benedikt PICKEL has registered three identities in Companies House in breach of Section 1082 of the Companies Act 2006 which requires individuals to establish one unique identifier (identity) and not multiple identities as this conceals interests from audits.
Silke SEHM (HANNOVER RÜCK SE)
SEHM, Silke Correspondence address Karl-Wiechert-Allée 50, Hannover, Lower Saxony 30625, Germany Role ACTIVE Director Date of birth August 1968 Appointed on 23 September 2021 Nationality German Country of residence Germany Occupation Director
There is only one appointment to this identity.
A search on his name returns just one identity (Silke SEHM - Find and update company information - GOV.UK (company-information.service.gov.uk))
Auditor of HANNOVER RÜCK SE
The Full accounts made up to 31 December 2022 were accessed from the Filing History records (HANNOVER RÜCK SE filing history - Find and update company information - GOV.UK (company-information.service.gov.uk)). The audit report was located on page 51, the signature page is copied below.
The public auditors responsible for approving the Audit Report in the 2022 Accounts for HANNOVER RÜCK SE are Mathias Rocker and Dennis Schnittger of PricewaterhouseCoopers GmbH. However, neither of the auditors have signed the Audit Report in the 2022 Accounts. The Audit Report not being signed renders the 2022 Accounts for HANNOVER RÜCK SE non-compliant.
Conclusion of case study.
Sven Althoff's case presents a complex web of identity misuse, regulatory breaches, and potential conflicts of interest within the financial sector. His registration of multiple identities violates Section 1082 of the Companies Act 2006, undermining the integrity and transparency of corporate governance practices. The discovery of active and resigned directorships across different entities raises serious concerns regarding regulatory compliance and ethical conduct.
The use of duplicate names like "HANNOVER RE UK LIFE BRANCH" not only constitutes a breach of the Companies Act 2006 but also poses significant risks to financial transparency and regulatory oversight. The misleading information within Companies House records, particularly regarding the person with significant control of Argenta Holdings Limited, obscures the true ownership structure and exposes vulnerabilities in the regulatory framework.
Furthermore, the involvement of directors associated with HANNOVER RÜCK SE in multiple entities suggests potential conflicts of interest that could compromise decision-making processes and corporate governance standards. The lack of audit compliance, as evidenced by the absence of signatures on the 2022 Accounts for HANNOVER RÜCK SE, further undermines trust in financial reporting and regulatory enforcement mechanisms.
These findings underscore the urgent need for enhanced regulatory oversight, robust compliance measures, and greater transparency within the financial sector. Addressing these systemic weaknesses is essential to safeguarding investor interests, maintaining market integrity, and upholding public trust in the financial system. Regulatory authorities must take proactive steps to address identity misuse, strengthen audit standards, and enforce compliance with corporate governance regulations to prevent similar lapses in the future.
The actual person of significant control of Argenta Holdings Limited, is HANNOVER RÜCK SE, not HANNOVER RUCK SE as stated in the record (ARGENTA HOLDINGS LIMITED persons with significant control - Find and update company information - GOV.UK (company-information.service.gov.uk)).
Returning to due diligence on the directors of Argenta Holdings Limited:
Ian Burford (Argenta Holdings Limited)
BURFORD, Ian Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Director Date of birth October 1967 Appointed on 14 December 2023
There are 3 identities registered for Ian BURFORD (Ian BURFORD - Find and update company information - GOV.UK (company-information.service.gov.uk)
Identity 1
Total number of appointments 9
Current appointments 2
Date of birth October 1967
ARGENTA HOLDINGS LIMITED (04973117) 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Director Appointed on 14 December 2023
ARGENTA SYNDICATE MANAGEMENT LIMITED (03632880) 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Director Appointed on 4 October 2021
FIDELIS UNDERWRITING LIMITED (09753615) The Leadenhall Building, 34th Floor, 122 Leadenhall Street, London, United Kingdom, EC3V 4AB Director Appointed on 12 December 2019 Resigned on 12 April 2021 Fidelis Uk Ceo
FIDELIS EUROPEAN HOLDINGS LIMITED (11144963) The Leadenhall Building, 122 Leadenhall Street, London, United Kingdom, EC3V 4AB Director Appointed on 12 August 2019 Resigned on 12 April 2021
FIDELIS MARKETING LIMITED (09522701) The Leadenhall Building, 34th Floor, 122 Leadenhall Street, London, United Kingdom, EC3V 4AB Director Appointed on 12 August 2019 Resigned on 12 April 2021
PERIGON PRODUCT RECALL LIMITED (12067625) Fidelis, 34th Floor The Leadenhall Building, 122 Leadenhall Street, London, United Kingdom, EC3V 4AB Director Appointed on 12 September 2019 Resigned on 12 April 2021
AXIS UNDERWRITING LIMITED (03043816) 21 Lombard Street, London, United Kingdom, EC3V 9AH Director Appointed on 7 October 2016 Resigned on 31 May 2017 Underwriter
NOVAE SYNDICATES LIMITED (02082070) Dissolved 21 Lombard Street, London, United Kingdom, EC3V 9AH Director Appointed on 27 September 2011 Resigned on 1 March 2017 Underwriter
N I C L LIMITED (05673327) The Dell, Avery Lane Oakham, Maidstone, Kent, ME15 8RZ Director Appointed on 4 February 2008 Resigned on 11 October 2010 Underwriter
Identity 2
Ian BURFORD (Ian BURFORD personal appointments - Find and update company information - GOV.UK (company-information.service.gov.uk))
Total number of appointments 2
Date of birth October 1967
PINE WALK CAPITAL LIMITED (10846939) Fidelis, 34th Floor, The Leadenhall Building, 122 Leadenhall Street, London, United Kingdom, EC3V 4AB Director Appointed on 31 July 2019 Resigned on 12 April 2021
RADIUS SPECIALTY LIMITED (10877650) Fidelis, 34th Floor, The Leadenhall Building, 122 Leadenhall Street, London, United Kingdom, EC3V 4AB Director Appointed on 24 July 2019 Resigned on 12 April 2021
Identity 3
Ian BURFORD (Ian BURFORD personal appointments - Find and update company information - GOV.UK (company-information.service.gov.uk)) https://find-and-update.company-information.service.gov.uk/officers/l9VIOqOSfCYayZS25iNLNh9x8S8/appointments
Total number of appointments 1
Date of birth October 1967
AXIS CORPORATE CAPITAL UK II LIMITED (03045763)
21 Meadowdown Close, Hempstead, Gillingham, Kent, ME7 3SU Director Appointed on 1 January 2000 Resigned on 9 April 2002 Underwriter
Conclusion. Ian Burford has registered three identities in breach of Section 1082 of the Companies Act 2006.
Nicholas John Moore (Argenta Private Capital Limited and Argenta Holdings Limited)
MOORE, Nicholas John Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Director Date of birth November 1979 Appointed on 28 July 2022 Occupation Actuary
Described above, he has 1 identity with 16 active appointments.
John Lindsay Pearce WHITER (Argenta Holdings Limited)
WHITER, John Lindsay Pearce Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Director Date of birth May 1950 Appointed on 6 September 2017 Occupation Accountant
A search locates two identities (John Lindsay Pearce WHITER - Find and update company information - GOV.UK (company-information.service.gov.uk)).
Identity 1
John Lindsay Pearce WHITER (John Lindsay Pearce WHITER personal appointments - Find and update company information - GOV.UK (company-information.service.gov.uk)) https://find-and-update.company-information.service.gov.uk/officers/30FOcdJoZxLdx3NUf8vLT23sI-Q/appointments
Total number of appointments 1
THE BUOYS MANAGEMENT LIMITED (03525021) Woodbury House, Garvock Drive, Sevenoaks, England, TN13 2LT Role ACTIVE Secretary Appointed on 26 February 2018
Identity 2
John Lindsay Pearce WHITER
Total number of appointments 39
Current appointments 4
Date of birth May 1950
CONTINUUM ADVISORY PARTNERS LIMITED (14189636) Becket House, 36, Old Jewry, London, England, EC2R 8DD Role ACTIVE Director Appointed on 16 January 2023 Non-Executive Director
ARGENTA HOLDINGS LIMITED (04973117) 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Director Appointed on 6 September 2017 Accountant
THE BUOYS MANAGEMENT LIMITED (03525021) Woodbury House, Garvock Drive, Sevenoaks, England, TN13 2LT Role ACTIVE Director Appointed on 7 February 2017 Chartered Accountant
OASIS TRANSFORMATION LIMITED (06764875) 2nd Floor The Oasis Centre 1, Kennington Road, London, England, SE1 7QP Role Director Appointed on 2 September 2013
OASIS EDUCATION (07366557) 75 Westminster Bridge Road, London, SE1 7HS Director Appointed on 7 October 2010 Nationality Chartered Accountant
ARGENTA SYNDICATE MANAGEMENT LIMITED (03632880) 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Director Appointed on 23 July 2009 Accountant
ED BROKING GROUP LIMITED (07254605) 2 Minster Court, Mincing Lane, London, England, EC3R 7PD Role RESIGNED Director Appointed on 9 July 2010 Resigned on 31 March 2022
PIIQ RISK PARTNERS LIMITED (00856973) 2 Minster Court, Mincing Lane, London, England, EC3R 7PD Role RESIGNED Director Appointed on 22 March 2011 Resigned on 31 March 2022
OASIS INTERNATIONAL ASSOCIATION (04255992) 62 Bishopsgate, London, United Kingdom, EC2N 4AW Role RESIGNED Director Appointed on 23 February 2010 Resigned on 1 September 2020 Accountant
OASIS INTERNATIONAL FOUNDATION (10530208) 2nd Floor The Oasis Centre, 1 Kennington Road, London, SE1 7QP Role RESIGNED Director Appointed on 16 December 2016 Resigned on 1 September 2020
OASIS COMMUNITY LEARNING (05398529) Active Correspondence address 75 Westminster Bridge Road, London, United Kingdom, SE1 7HS Role RESIGNED Director Appointed on 14 December 2009 Resigned on 25 March 2020 Chartered Accountant
OASIS CHARITABLE TRUST (02818823) Active 1 Kennington Road, London, SE1 7QP Role RESIGNED Director Appointed on 17 July 2009 Resigned on 25 January 2017 Chartered Accountant
OASIS IT SERVICES LTD (05720249) Active 75 Westminster Bridge Road, London, United Kingdom, SE1 7HS Role RESIGNED Director Appointed on 7 October 2010 Resigned on 17 November 2016 Chartered Accountant
EAST LONDON SMALL BUSINESS CHARITY LIMITED (02837557) Company status Liquidation Correspondence address Meades, Lake Street, Mark Cross, East Sussex, TN6 3NT Role RESIGNED Director Appointed on 9 February 2000 Resigned on 6 March 2014 Chartered Accountant
EAST LONDON SMALL BUSINESS CENTRE LIMITED (01400613) Company status Liquidation Meades, Lake Street, Mark Cross, East Sussex, TN6 3NT Role RESIGNED Director Appointed on 9 February 2000 Resigned on 6 March 2014 Chartered Accountant
ROODLANE MEDICAL LIMITED (06395903) Company status Active Correspondence address Meades, Lake Street, Mark Cross, East Sussex, TN6 3NT Role RESIGNED Director Appointed on 20 December 2007 Resigned on 22 July 2011 Finance Director
ED BROKING HOLDINGS (LONDON) LIMITED (00998625) Company status Active Meades, Lake Street, Mark Cross, East Sussex, TN6 3NT Role RESIGNED Director Appointed on 1 July 2009 Resigned on 9 July 2010
AON HOLDINGS LIMITED (02265140) Active Correspondence address Meades, Lake Street, Mark Cross, East Sussex, TN6 3NT Role RESIGNED Director Appointed on 1 February 1994 Resigned on 31 March 2009 Chartered Accountant
BENFIELD LIMITED (01170753) Company status Dissolved Meades, Lake Street, Mark Cross, East Sussex, TN6 3NT Role RESIGNED Director Appointed on 5 February 1999 Resigned on 31 March 2009 Chartered Accountant
BENFIELD GREIG LIMITED (03134925) Dissolved Meades, Lake Street, Mark Cross, East Sussex, TN6 3NT Role RESIGNED Director Appointed on 6 February 1996 Resigned on 27 March 2009 Chartered Accountant
BENFIELD CAPITAL LIMITED (03819547) Dissolved Meades, Lake Street, Mark Cross, East Sussex, TN6 3NT Role RESIGNED Director Appointed on 24 February 2000 Resigned on 27 March 2009 Chartered Accountant
GREIG FESTER INVESTMENT HOLDINGS LIMITED (00485154) Dissolved Meades, Lake Street, Mark Cross, East Sussex, TN6 3NT Role RESIGNED Director Appointed on 28 May 1999 Resigned on 20 March 2009 Chartered Accountant
BENFIELD GREIG CANADIAN HOLDINGS LIMITED (03722026) Dissolved Meades, Lake Street, Mark Cross, East Sussex, TN6 3NT Role RESIGNED Director Appointed on 28 June 1999 Resigned on 20 March 2009 Chartered Accountant
GREIG FESTER (PROPERTIES) LIMITED (00863029) Dissolved Meades, Lake Street, Mark Cross, East Sussex, TN6 3NT Role RESIGNED Director Appointed on 28 May 1999 Resigned on 20 March 2009 Chartered Accountant
GREIG FESTER GROUP LIMITED (01166699) Dissolved Meades, Lake Street, Mark Cross, East Sussex, TN6 3NT Role RESIGNED Director Appointed on 28 May 1999 Resigned on 20 March 2009 Chartered Accountant
BENFIELD GREIG HOLDINGS LIMITED (02673231) Dissolved Director Appointed on 28 May 1999 Resigned on 28 November 2008 Chartered Accountant
BENFIELD FINANCE (05114394) Dissolved Meades, Lake Street, Mark Cross, East Sussex, TN6 3NT Role RESIGNED Director Appointed on 8 June 2004 Resigned on 28 November 2008 Chartered Accountant
BENFIELD GREIG CANADIAN HOLDINGS LIMITED (03722026) Dissolved Meades, Lake Street, Mark Cross, East Sussex, TN6 3NT Role RESIGNED Secretary Appointed on 28 June 1999 Resigned on 22 September 2006
AON SECURITIES LIMITED (03317553) Active Meades, Lake Street, Mark Cross, East Sussex, TN6 3NT Role RESIGNED Director Appointed on 30 January 1998 Resigned on 31 January 2006 Chartered Accountant
BENFIELD ADVISORY HOLDINGS LIMITED (03885861) Dissolved Meades, Lake Street, Mark Cross, East Sussex, TN6 3NT Role RESIGNED Director Appointed on 24 February 2000 Resigned on 31 January 2006 Chartered Accountant
BLUESURE LIMITED (03940496) Dissolved Meades, Lake Street, Mark Cross, East Sussex, TN6 3NT Role RESIGNED Director Appointed on 19 May 2000 Resigned on 20 May 2005 Chartered Accountant
CLOSE PREMIUM FINANCE NO. 1 LIMITED (04054458) Dissolved Meades, Lake Street, Mark Cross, East Sussex, TN6 3NT Role RESIGNED Director Appointed on 2 October 2000 Resigned on 9 November 2004 Chartered Accountant
BSI SPEEDWAY LIMITED (03369723) Liquidation 37 Blackheath Park, London, SE3 9RW Role RESIGNED Director Appointed on 21 July 1997 Resigned on 1 July 2004 Chartered Accountant
WILDNET GROUP LIMITED (03466186) Dissolved 37 Blackheath Park, London, SE3 9RW Role RESIGNED Director Appointed on 9 July 1998 Resigned on 13 April 2004 Chartered Accountant
HUME CAPITAL INVESTMENTS LIMITED (04196006) Dissolved 37 Blackheath Park, London, SE3 9RW Role RESIGNED Director Appointed on 22 July 2003 Resigned on 10 March 2004 Finance Director
CHELSEA STADIUM LIMITED (SC138894) Active 29 Dry Hill Road, Tonbridge, Kent, TN9 1LU Role RESIGNED Director Appointed on 11 May 1995 Resigned on 29 July 1997 Finance Director
CHELSEA STADIUM LIMITED (SC138894) Active 29 Dry Hill Road, Tonbridge, Kent, TN9 1LU Role RESIGNED Secretary Appointed on 11 May 1995 Resigned on 1 November 1996
MAZARS TRUSTEE COMPANY LIMITED (02614235) Active 29 Dry Hill Road, Tonbridge, Kent, TN9 1LU Role RESIGNED Director Appointed on 19 June 1992 Resigned on 31 January 1994 Chartered Accountant
WOOL QUAY NOMINEES LIMITED (01032415) Active 29 Dry Hill Road, Tonbridge, Kent, TN9 1LU Role RESIGNED Director Appointed before 6 April 1992 Resigned on 31 January 1994 Chartered Accountant
Expanding on John Lindsay Pearce WHITER’s active interests:
CONTINUUM ADVISORY PARTNERS LIMITED (14189636) Becket House, 36, Old Jewry, London, England, EC2R 8DD Role ACTIVE Director Appointed on 16 January 2023 Non-Executive Director
Analysis to be completed.
THE BUOYS MANAGEMENT LIMITED (03525021) Woodbury House, Garvock Drive, Sevenoaks, England, TN13 2LT Role ACTIVE Director Appointed on 7 February 2017 Chartered Accountant
The Buoys Management Limited Overview
Registered office address 1 Cedar Office Park Cobham Road, Ferndown Industrial Estate, Wimborne, England, BH21 7SB Company status Active Company type Private limited Company Incorporated on 11 March 1998 Accounts 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 11 March 2024 due by 25 March 2024 Last statement dated 11 March 2023 Nature of business (SIC) 98000 - Residents property management
The officers of The Buoys Management Limited (THE BUOYS MANAGEMENT LIMITED people - Find and update company information - GOV.UK (company-information.service.gov.uk)):
The Buoys Management Limited
Officers:16 officers / 12 resignations
WHITER, John Lindsay Pearce Correspondence address Woodbury House, Garvock Drive, Sevenoaks, England, TN13 2LT Role ACTIVE Secretary Appointed on 26 February 2018
WOODLEY & ASSOCIATES LIMITED Correspondence address Bourne Gardens, Exeter Park Road, Bournemouth, England, BH2 5BD Role ACTIVE Secretary Appointed on 16 May 2023 Registration number 11844104
PLESTER, George Correspondence address 3 The Buoys, 65 Banks Road, Poole, Dorset, England, BH13 7PP Role ACTIVE Director Date of birth April 1938 Appointed on 2 June 2014 Nationality British Country of residence Belgium Occupation Retired
WHITER, John Lindsay Pearce Correspondence address Woodbury House, Garvock Drive, Sevenoaks, England, TN13 2LT Role ACTIVE Director Date of birth May 1950 Appointed on 7 February 2017 Chartered Accountant
PERRINS, George Henry Correspondence address Linden House 16 Flaghead Road, Canford Cliffs, Poole, Dorset, BH13 7JW Role RESIGNED Secretary Appointed on 11 March 1998 Resigned on 31 August 2001
PHILLPOT, Karen Correspondence address 1 The Buoys, 65 Banks Road, Poole, Dorset, England, BH13 7PP Role RESIGNED Secretary Appointed on 1 April 2014 Resigned on 26 February 2018
SETHNA, Hilda Correspondence address 10 Woodcote Lane, Purley, Surrey, CR8 3HA Role RESIGNED Secretary Appointed on 20 August 2001 Resigned on 14 March 2005
SETHNA, Pearl Correspondence address 7 Lavender Road, Croydon, Surrey, CR0 3BH Role RESIGNED Secretary Appointed on 14 March 2005 Resigned on 1 June 2014
SWIFT INCORPORATIONS LIMITED Correspondence address 26 Church Street, London, NW8 8EP Role RESIGNED Nominee Secretary Appointed on 11 March 1998 Resigned on 11 March 1998
MUCKLOW, Jason John Correspondence address Beau Sejour Rue De Fremont, St John, Jersey, JE3 4DA Role RESIGNED Director Date of birth May 1969 Appointed on 11 March 1998 Resigned on 31 August 2001
PERRINS, George Henry Correspondence address Linden House 16 Flaghead Road, Canford Cliffs, Poole, Dorset, BH13 7JW Role RESIGNED Director Date of birth March 1948 Appointed on 11 March 1998 Resigned on 31 August 2001 Solicitor
PHILLPOT, Karen Correspondence address 1 The Buoys 65, Banks Road, Sand Banks, Poole, Dorset, BH13 7PP Role RESIGNED Director Date of birth December 1957 Appointed on 29 October 2004 Resigned on 1 August 2018 Housewife
SETHNA, Hilda Correspondence address 10 Woodcote Lane, Purley, Surrey, CR8 3HA Role RESIGNED Director Date of birth October 1943 Appointed on 20 August 2001 Resigned on 14 March 2005 Occupational Therapy
SETHNA, Pearl Correspondence address 7 Lavender Road, Croydon, Surrey, CR0 3BH Role RESIGNED Director Date of birth November 1969 Appointed on 14 March 2005 Resigned on 1 June 2014 Sports Development Officer
SMITH, Hilary Jeanne Correspondence address Comeragh Court Comeragh Close, Woking, Surrey, GU22 0LZ Role RESIGNED Director Date of birth July 1951 Appointed on 13 November 2001 Resigned on 29 June 2016.
WALSH, Simon Paul Correspondence address Little Pipers Hadley Green Road, Monkin Hadley, Barnet, Hertfordshire, EN5 5PY Role RESIGNED Director Date of birth June 1965 Appointed on 20 August 2001 Resigned on 29 October 2004 Occupation Trading Of Confectionery Direc.
The persons with significant control are copied below:
4 active persons with significant control / 0 active statements
Mr John Lindsay Pearce Whiter ACTIVE Correspondence address Tylers, 47 Kippington Road, Sevenoaks, Kent, England, TN13 2LL Notified on 11 March 2020 Date of birth May 1950 Nationality British Country of residence England
Nature of control
Ownership of shares – More than 50% but less than 75%
Ownership of voting rights - More than 50% but less than 75%
Right to appoint or remove directors
Mrs Janet Dulcie Sarah Whiter ACTIVE Correspondence address Tylers, 47 Kippington Road, Sevenoaks, Kent, England, TN13 2LL Notified on 11 March 2020 Date of birth February 1948 Nationality British Country of residence England
Nature of control
Ownership of shares – More than 50% but less than 75%
Ownership of voting rights - More than 50% but less than 75%
Right to appoint or remove directors
Mr George Plester ACTIVE Correspondence address 3 The Buoys, 65 Banks Road, Poole, Dorset, England, BH13 7PP Notified on 26 February 2018 Date of birth April 938 Nationality British Country of residence Belgium
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%
Mrs Marie Teresa Plester ACTIVE Correspondence address 3 The Buoys, 65 Banks Road, Poole, Dorset, England, BH13 7PP Notified on 26 February 2018 Date of birth August 1942 Nationality British Country of residence Belgium
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%
Anomaly with distribution of shares and voting rights
There are four persons with significant control of The Buoys Management Limited. There is an anomaly with the distribution of the ownership of shares and voting rights. Added together, distribution of more than 150% but not more than 250% of shares and voting rights are described, which exceeds the total available shares and voting rights by between 50% and 150% .
Accounts for The Buoys Management Limited are unrealistic
The most recent accounts, “Micro accounts made up to 31 December 2023”, were opened via the filing history tab (THE BUOYS MANAGEMENT LIMITED filing history - Find and update company information - GOV.UK (company-information.service.gov.uk)). The balance sheet is reproduced below:
Analysis
The balance sheet of Buoys Management Ltd reports net assets of £3. This is unrealistic for a company with two employees, two secretaries, two directors and four persons with significant control. It is more likely that the units are missing from these accounts, so, this could be £3 million, £3 billion, £3 trillion or more. The Buoys Management Limited present implausible accounts, this is an anomaly that requires forensic investigation.
The accounts do not list the officers active in the year, and, the accounts are unsigned. These are further breaches of the Companies Act 2006.
OASIS TRANSFORMATION LIMITED (06764875) 2nd Floor The Oasis Centre 1, Kennington Road, London, England, SE1 7QP Role Director Appointed on 2 September 2013
To be analysed:
RSM
In a search on John Whiter (John WHITER - Find and update company information - GOV.UK (company-information.service.gov.uk)) https://find-and-update.company-information.service.gov.uk/search/officers?q=John+WHITER, Barnaby John Wakinshaw WHITER was returned (Barnaby John Wakinshaw WHITER personal appointments - Find and update company information - GOV.UK (company-information.service.gov.uk)) https://find-and-update.company-information.service.gov.uk/officers/q8BydUpUlXoBb4a44Dl7xGqKtaw/appointments
His appointments are included because they include “RSM” which are the initials linked to Raine Limited (Appendix 3).
Confirmation is requested of whether Barnaby John Wakinshaw WHITER is a related party of John Lindsay Pearce WHITER.
Barnaby John Wakinshaw WHITER:
Total number of appointments 3
Date of birth June 1970
RSM UK TAX AND ADVISORY SERVICES LLP (OC325348) 2 Bloomsbury Street, London, , , (sic) WC1B 3ST Resigned LLP Member Appointed on 1 April 2007 Resigned on 6 June 2008
RSM UK CORPORATE FINANCE LLP (OC325347) 2 Bloomsbury Street, London, , , (sic) WC1B 3ST Role RESIGNED LLP Member Appointed on 1 April 2007 Resigned on 6 June 2008
RSM UK GROUP LLP (OC325346) 2 Bloomsbury Street, London, , , (sic) WC1B 3ST Role RESIGNED LLP Member Appointed on 1 April 2007 Resigned on 1 April 2007
End
For information, the company website for the Argenta Group was located through a search on the internet. The “About us” description, on the website, is copied below (Our Business (argentagroup.com)).
Argenta Group in numbers
£920m underwriting capacity for 2023
Over £3.8bn of investor capacity for 2023 managed by APCL, Targeted returns on capital in excess of 10%
215 employees in London
30 employees in Australia
Who we are
Argenta Holdings Ltd, a wholly owned subsidiary of Hannover Re, is an underwriting and insurance services group operating in the Lloyd’s Market.
The Group includes Argenta Syndicate Management Ltd (ASML), a Lloyd’s Managing Agent, Argenta Private Capital Ltd (APCL), a specialist insurance investment adviser providing a range of products and advice to individual and corporate investors at Lloyd’s and Argenta Underwriting Asia Pte Ltd, which includes Argenta Underwriting Australia, an approved cover holder for Argenta’s Lloyd’s Syndicate 2121.
Argenta Syndicate Management Ltd (ASML)
ASML manages the affairs of Lloyd’s Syndicate 2121 and SPA 6134. Syndicate 2121, which benefits from Lloyd’s S&P credit rating of A+, provides both insurance and reinsurance solutions across a broad cross section of classes.
Business is underwritten on a global basis although the Syndicate’s primary markets are the US, the UK and the Asia Pacific region. SPA 6134, set up in 2018, underwrites a quota share reinsurance of business written by Syndicate 2121.
ASML is authorised by the Prudential Regulation Authority and regulated by the Financial Cond1uct Authority and the Prudential Regulation Authority.
Argenta Private Capital Ltd (APCL)
APCL provides private, institutional and corporate investors the opportunity to invest directly in the Lloyd’s of London insurance market. APCL specialises in creating tax efficient investment portfolios for a worldwide client base. Every investment portfolio is tailor-made to suit clients’ circumstance and appetite for risk. APCL currently manages over £3.8 billion of investor capacity. Dating back to 1962, we have consistently been at the forefront of innovation in the Lloyd’s market.
APCL also provides tax compliance, structuring and planning advice to private and corporate clients as well as complementary tax, accounting and company secretarial services.
The dedicated research team provides market leading analysis and forecasts for every underwriting syndicate that our clients have exposure to at Lloyd's, helping inform investment decisions.
APCL is authorised and regulated by the Financial Conduct Authority.
Argenta Underwriting Asia Pte Ltd
Argenta Underwriting Asia Pte Ltd offers access to worldwide insurance and reinsurance solutions.
Argenta Underwriting Australia (AUA) was established in 2015 as a branch of Argenta Underwriting Asia Pte Ltd.
Located on the Lloyd’s Sydney platform, AUA operates as an approved coverholder for Argenta's Lloyd's Syndicate 2121. As such, AUA is able to offer local access to the full range of products available from Argenta’s Lloyd’s Syndicate 2121.
Argenta Underwriting Asia Pte Ltd trades as Argenta Underwriting Australia. Argenta Underwriting Asia Pte Ltd is registered by the Monetary Authority of Singapore (MAS) as an approved Lloyd's Asia Scheme service company.
Secretarial control of a large number of companies, as seen in the case of Argenta Secretariat Limited, can pose additional risks. For example:
Potential for Conflicts of Interest:
With a broad span of control, there's an increased likelihood of conflicts of interest. The secretary may be involved in decision-making processes for multiple companies with potentially competing interests, raising ethical concerns.
Difficulty Ensuring Compliance:
Ensuring compliance with legal and regulatory requirements becomes more challenging with a high number of companies. It may be difficult to stay abreast of changes in legislation, resulting in unintentional non-compliance.
Limited Capacity for Due Diligence:
A secretary overseeing a large number of companies may have limited capacity for thorough due diligence. This could lead to insufficient scrutiny of company activities, potentially exposing companies to legal or reputational risks.
Risk of Cartel Coordination:
In extreme cases, if a single entity has control over the secretarial functions of multiple companies, there could be a risk of cartel-like coordination, where information or decisions are shared to the detriment of fair competition.
Potential for Fraud:
A secretary with control over many companies might be in a position to exploit vulnerabilities for fraudulent activities, especially if there are inadequate checks and balances in place.
Impact on Corporate Governance:
Excessive control by a single entity may undermine the principles of good corporate governance. Independence and diversity in governance roles are considered essential for effective oversight and decision-making.
Concerns About Data Security:
Handling a large volume of sensitive corporate data may pose challenges in terms of data security. A breach in data security could have severe consequences for multiple companies.
Regulatory Scrutiny:
Regulators may scrutinise situations where a single entity holds significant control over the secretarial functions of numerous companies. This could lead to investigations into compliance and potential conflicts of interest.
In summary, while it's not inherently problematic for a corporate service provider to offer secretarial services to multiple companies, the scale of such control must be managed carefully to mitigate the risks outlined above. Regulatory authorities and stakeholders may need to monitor such situations to ensure that corporate governance standards are maintained and potential risks are addressed.
The revelation that Argenta Secretariat Limited, a corporate secretary with an extensive span of control, served as the secretary for Saffron Underwriting Limited, where Dame June Raine, the CEO of the Medicines and Healthcare products Regulatory Agency (MHRA), was a director, raises important questions about transparency and potential conflicts of interest.
Observations:
Lack of Declaration:
The failure of Dame June Raine to disclose her directorship at Saffron Underwriting Limited, where Argenta Secretariat Limited serves as the corporate secretary, is concerning. Such omissions can raise questions about transparency and adherence to disclosure norms.
Potential Conflict of Interest:
The corporate secretary plays a crucial role in the governance and compliance of a company. When a secretary is associated with a regulatory figure such as the CEO of MHRA, it introduces a potential conflict of interest, especially in industries as sensitive as healthcare and pharmaceuticals.
Impact on Regulatory Integrity:
Regulatory bodies, like the MHRA, are expected to maintain the highest standards of integrity and transparency. Any association with entities in industries under regulatory purview should be disclosed to uphold public trust in the regulatory process.
Corporate Governance and Accountability:
The situation underscores the importance of robust corporate governance practices and the need for individuals in key regulatory positions to be accountable for their associations outside of their regulatory roles.
Potential Repercussions:
Depending on the specific regulations and guidelines governing such disclosures, there may be legal and professional repercussions for the failure to declare such associations.
In conclusion, the lack of disclosure of Dame June Raine's directorship at Saffron Underwriting Limited, where Argenta Secretariat Limited is the corporate secretary, raises important ethical and governance questions. Transparency, especially in regulatory leadership, is paramount to maintaining public trust in the integrity of regulatory processes. It would be pertinent for relevant authorities to investigate and address any potential conflicts of interest to ensure the accountability of regulatory leaders.
Returning, to look at the appointments of the other directors of Saffron Underwriting Limited.
David Charles Bowles
David Charles Bowles is an active director of Saffron Underwriting Limited, appointed on 7 May 2023. He holds a total of 108 appointments, 102 of which are currently active (David Charles BOWLES personal appointments - Find and update company information - GOV.UK (company-information.service.gov.uk)). The first nine appointments are listed below, as an example:
David Charles BOWLES
Current appointments 102
Total number of appointments 108
Date of birth August 1968
RIMU CAPITAL LIMITED (03635307) Company status Active Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Director Appointed on 1 November 2023 Nationality British Country of residence England Occupation Company Director
NORMANMAX STRATEGIC PARAMETRICS LIMITED (15169662) Company status Active Correspondence address 5th Floor, 70 Gracechurch Street, London, United Kingdom, EC3V 0XL Role ACTIVE Director Appointed on 27 September 2023 Nationality British Country of residence England Occupation Administrator
ICC RE LIMITED (15163073) Company status Active Correspondence address 5th Floor, 70 Gracechurch Street, London, United Kingdom, EC3V 0XL Role ACTIVE Director Appointed on 25 September 2023 Nationality British Country of residence England Occupation Administrator
CORPUS LCM LIMITED (15152257) Company status Active Correspondence address 5th Floor, 70 Gracechurch Street, London, United Kingdom, EC3V 0XL Role ACTIVE Director Appointed on 21 September 2023 Nationality British Country of residence England Occupation Administrator
CORPUS UK HOLDINGS LIMITED (15140443) Company status Active Correspondence address 5th Floor, 70 Gracechurch Street, London, United Kingdom, EC3V 0XL Role ACTIVE Director Appointed on 15 September 2023 Nationality British Country of residence England Occupation Administrator
OTCIC LIMITED (15113141) Company status Active Correspondence address 5th Floor, 70 Gracechurch Street, London, United Kingdom, EC3V 0XL Role ACTIVE Director Appointed on 4 September 2023 Nationality British Country of residence England Occupation Administrator
LIU CORPORATE MEMBER LIMITED (15091070) Company status Active Correspondence address 5th Floor, 70 Gracechurch Street, London, United Kingdom, EC3V 0XL Role ACTIVE Director Appointed on 23 August 2023 Nationality British Country of residence England Occupation Administrator
WILDFIRE DEFENSE CORPORATE MEMBER LIMITED (14883633) Company status Active Correspondence address 5th, Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Director Appointed on 22 May 2023 Nationality British Country of residence England Occupation Director
SAFFRON UNDERWRITING LIMITED (03806044) Company status Active Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Director Appointed on 7 May 2023 Nationality British Country of residence England Occupation Company Director
David Charles Bowles is a director of 102 active companies, including Saffron Underwriting Limited. This is a span of control that presents risks of insider trading and for being a cartel.
A search to monitor for multiple identities found that David Charles Bowles has one identity registered with date of birth August 1968 (David BOWLES - Find and update company information - GOV.UK (company-information.service.gov.uk)).
David Charles Bowles assumes the directorship of an extensive portfolio, overseeing 102 active companies, which includes Saffron Underwriting Limited. This substantial span of control raises concerns regarding potential risks, notably in relation to insider trading and the risk of collusion, evoking considerations akin to cartel behaviour. Mr. Bowles, who shares directorship with Dame June Raine in Saffron Underwriting Limited, may be exposed to conflicts of interest and challenges in ensuring impartial decision-making across this broad spectrum of companies. The shared directorship with individuals in influential positions, such as Dame June Raine, underscores the potential for interconnected interests that warrant regulatory scrutiny for adherence to principles of fair competition and ethical business practices.
APCL CORPORATE DIRECTOR NO.1 LIMITED
APCL CORPORATE DIRECTOR NO.1 LIMITED is a corporate identity of Company Registration number 09080154, and it is an active director of Saffron Underwriting Limited, appointed on 7 May 2023.
The appointments associated to this identity are (APCL CORPORATE DIRECTOR NO.1 LIMITED personal appointments - Find and update company information - GOV.UK (company-information.service.gov.uk)) not listed here.
Current appointments 111
Total number of appointments 144
Several appointments are to the same companies as David Charles Bowles.
A search for duplicate identities for this corporate director (APCL CORPORATE DIRECTOR NO.1 LIMITED - Find and update company information - GOV.UK (company-information.service.gov.uk)) provides the following entries:
APCL CORPORATE DIRECTOR NO.1 LIMITED
09080154 - Incorporated on 10 June 2014
5th Floor 70 Gracechurch Street, London, England, EC3V 0XL
APCL CORPORATE DIRECTOR NO.1 LIMITED
Total number of appointments 141
5th Floor, 70, Gracechurch Street, London, England, EC3V 0XL
APCL CORPORATE DIRECTOR NO.2 LIMITED
09080184 - Incorporated on 10 June 2014
5th Floor 70 Gracechurch Street, London, England, EC3V 0XL
APCL CORPORATE DIRECTOR NO.2 LIMITED
Total number of appointments 124
5th Floor, 70, Gracechurch Street, London, England, EC3V 0XL
APCL Corporate Director No.1 Limited is registered as a company and as one corporate entity. Similarly, APCL Corporate Director No.2 Limited is registered as a company and has one corporate identity.
The span of control of this corporate director exceeds normal cross-directorships. This is known as over-boarding and is a red flag for potentially operating as a cartel.
The active directors of APCL Corporate Director No.1 Limited are:
11 officers / 6 resignations
ARGENTA SECRETARIAT LIMITED Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Secretary Appointed on 10 June 2014 UK Limited Company What's this? Registration number 1479228
BURTON, Sarah Carol-Ann Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Director Date of birth October 1976 Appointed on 6 October 2020 Nationality British Country of residence England Occupation Lawyer
FLACH, Robert Paul Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Director Date of birth March 1967 Appointed on 3 December 2018 Nationality British Country of residence England Occupation Director
HUDSON, Guy Bentley Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Director Date of birth November 1960 Appointed on 10 June 2014 Nationality British Country of residence England Occupation Names Director
WARNER, Marcus Gary Correspondence address 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL Role ACTIVE Director Date of birth May 1973 Appointed on 10 June 2014 Nationality British Country of residence England Occupation Accountant.
The persons with significant control information (APCL CORPORATE DIRECTOR NO.1 LIMITED persons with significant control - Find and update company information - GOV.UK (company-information.service.gov.uk))
1 active person with significant control / 0 active statements
Argenta Private Capital Limited ACTIVE
Correspondence address
5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL
Notified on 6 April 2016
Need to look at appointments and check for duplicated identities.
APCL CORPORATE DIRECTOR NO.2 LIMITED
APCL CORPORATE DIRECTOR NO.2 LIMITED is a corporate identity of Company Registration number 09080184 and is an active director of Saffron Underwriting Limited, appointed on 7 May 2023.
The officers and person with significant control of this company are the same as for APCL Corporate Director No.1 Limited.
In the search for “APCL Corporate Director No.1 Limited” it is noted that there are many companies that include the name “APCL”
07686807 - Incorporated on 29 June 2011
Accountshelp, Regus, 1 Elmfield Park, Bromley, England, BR1 1LU
13090313 - Dissolved on 30 May 2023
3-7 Temple Avenue, Suite 140 Temple Chambers, London, England, EC4Y 0DA
13774706 - Incorporated on 30 November 2021
Horton House, Exchange Flags, Liverpool, England, L2 3YL
13867708 - Incorporated on 24 January 2022
3rd Floor Horton House, Exchange Flags, Liverpool, England, L2 3YL
13778648 - Incorporated on 2 December 2021
Third Floor Horton House, Exchange Flags, Liverpool, England, L2 3YL
14787688 - Incorporated on 10 April 2023
2nd Floor College House, 17 King Edwards Road,, Ruislip,, London,, United Kingdom, HA4 7AE
10726068 - Incorporated on 13 April 2017
C/O. Novatech Uk Unit 2, Angel Park, Drum Industrial Estate, Chester-Le-Street, Co. Durham, England, DH2 1AQ
13778689 - Incorporated on 2 December 2021
Third Floor Horton House, Exchange Flags, Liverpool, England, L2 3YL
14078331 - Incorporated on 29 April 2022
4 Garden House Close, Failsworth, Manchester, England, M35 0TX
SC554744 - Incorporated on 16 January 2017
1 Eagle Street, Glasgow, Scotland, G4 9XA
12586517 - Dissolved on 12 October 2021
5 Cottingham Road, Manchester, England, M12 4BN
11635922 - Dissolved on 24 March 2020
14 Sylvester Court, Beverley, United Kingdom, HU17 8DZ
SC554738 - Dissolved on 26 November 2019
1 Eagle Street, Craighall Business Park, Glasgow, Scotland, G4 9XA
There is potential for “clone company fraud”, that needs to be examined. This is not attempted here.
Summary (comprised of sections copied from above, in this document, with some edits).
Key Findings Relating to Dame June Raine and Her Associates:
1. **Dame June Raine's Dual Role:** Dame June Munro Raine, DBE, concurrently served as the Chief Executive Officer (CEO) of the Medicines and Healthcare products Regulatory Agency (MHRA) while holding a directorship at Saffron Underwriting Limited. This dual role, spanning from 21 January 2016 to 9 May 2023, was not disclosed by Dame June Raine.
2. **Biographical Overview:** Dame June Raine, a distinguished British doctor, has held various roles within the Medicines Division of the MHRA and its predecessor in the Department of Health. Her tenure includes serving as the Director of Vigilance and Risk Management in the Medicines Division and subsequently as the current CEO of the MHRA.
3. **Non-Disclosure in Government Biographies:** Dame June Raine did not disclose her directorship at Saffron Underwriting Limited in her biography on the Government website. Additionally, it was not referenced as a current directorship in the Register of Interests dated May 2023, violating the Companies Act 2006 and the MHRA Policy on Declaring and Managing Interests.
4. **Saffron Underwriting Limited Overview:** Saffron Underwriting Limited is an active private limited company operating in the non-life insurance sector. It was incorporated on July 13, 1999, with its registered office at 5th Floor, 70 Gracechurch Street, London, EC3V 0XL.
5. **Officers at Saffron Underwriting Limited:** The current officers include Argenta Secretariat Limited (Secretary), David Harris (Director), APCL Corporate Director No.1 Limited, APCL Corporate Director No.2 Limited, and David Charles Bowles (Director). Notably, Dame June Raine served as a director from 21 January 2016 to 9 May 2023.
6. **Significant Control:** Mr. David Harris is identified as the active person with significant control, holding ownership of shares and voting rights of 75% or more in Saffron Underwriting Limited since 6 April 2016 .
7. **Anomalies in Financial Reporting:** The financial statements of Saffron Underwriting Limited for the year ending 31 December 2022 exhibit several anomalies, including events reported outside the accounting period, inaccurate representation of director status, and discrepancies in related party disclosures and controlling party identification.
8. **Concentration of charges with Lloyd's raises compliance concerns:** The company carries a significant number of charges primarily with Lloyd's, raising concerns about the nature of financial arrangements and compliance with legislation. The concentration of charges with the same entity suggests a circular nature of transactions that necessitates further examination by independent experts.
Summary of officers of Saffron Underwriting Limited
David Harris
David Harris, date of birth May 1925, has one identity, two appointments, one active. He is a director of Saffron Underwriting Limited, appointed on 13 July 1999, resigned on 31 October 2002, and reappointed on 31 October 2002. He is listed as the Person With Significant Control since 6 April 2016. This is contradicted in the 2022 Accounts where “The estate of Mr D Harris” is specified as having ultimate control. Other issues: Lloyd’s charges circularity, ambiguous related party transactions and erroneous Director status in 2022 Accounts, unusual resignation and reappointment on 31 October 2002.
Argenta Secretariat Limited
Argenta Secretariat Limited's ownership of 544 appointments, with 426 currently active, signals a significant level and span of control. This, coupled with Dame June Raine's failure to disclose their shared interest in Saffron Underwriting Limited, heightens concerns regarding potential cartel-like behaviour.
Conclusion regarding Argenta Secretariat Limited (Secretary of Saffron Underwriting Limited:
Control Structure: Argent Secretariat Limited, acting as the secretary of Saffron Underwriting Limited, is ultimately controlled by Hannover Ruck Se, a German company. This control passes through various entities, including Argenta Secretariat Limited, Argenta Private Capital Limited, and Argenta Holdings Limited.
Related Parties to Dame June Raine: Directors of Saffron Underwriting Limited, Argenta Secretariat Limited, Argenta Private Capital Limited, Argenta Holdings Limited, and Hannover Ruck Sa are considered to be related parties to Dame June Raine.
Audit Implications: All directorships held by the directors of these companies would typically undergo audits for related party transactions and conflicts of interest. However, the failure of Dame June Raine to declare her interest in Saffron Underwriting Limited to MHRA raises concerns about whether any checks were undertaken.
Uncompleted Checks: Due to Dame June Raine's non-disclosure, critical checks that would normally be conducted for related party transactions and conflicts of interest may not have been completed. This lack of transparency could pose risks to the integrity of the audit process and corporate governance.
Argenta Secretariat Limited, is both: a corporate identity that is secretary of Saffron Underwriting Limited, and a company controlled by a secretary and six directors.
There are six active officers of Argenta Secretariat Limited, with correspondence address, 5th Floor, 70 Gracechurch Street, London, England, EC3V 0XL. The secretary, is also a director.
Sarah Carol-Ann BURTON, is secretary, appointed on 6 October 2020, and director with date of birth October 1976, appointed on 6 October 2020. Her occupation is “lawyer”. She holds these positions at Argenta Secretariat Limited in two separate identities and has registered a total of seven identities named Sarah Carol-Ann Burton. Overall she has registered 7 (seven) identities to hold 19 (nineteen) appointments, in various companies, 17 (seventeen) of which are active. All seven identities are currently active.
Her co-directors each have just one identity registered, with that date of birth:
Trevor Robert BIRD, director, date of birth September 1955, appointed on 3 August 2001. Occupation, Members Agent. 15 appointments, 5 are current.
Robert Paul FLACH, director, date of birth March 1967, appointed on 3 December 2018. 64 appointments, 59 are current.
Guy Bentley HUDSON, director, date of birth November 1960, appointed on 12 October 2015. Occupation, Names Director. 15 appointments, 11 are current.
Marcus Gary WARNER, director, date of birth May 1973, appointed on 12 October 2015. Occupation, Accountant. 68 appointments, 61 are current.
This section illuminates the concerning practice of employing multiple identities by the secretary, Sarah Carol-Ann Burton, emphasising significant issues pertaining to transparency and accountability within corporate governance. By leveraging seven distinct identities for diverse roles encompassing directorships and secretarial duties, Ms. Burton orchestrates a convoluted network, obfuscating the interrelationships between her appointments. Such opacity heightens the vulnerability to synthetic identity fraud, posing a substantial threat by facilitating the concealment of vested interests from auditors and regulatory authorities.
In addition to the extensive control exerted by officers Robert Paul Flach and Marcus Gary Warner, with a combined total of 120 appointments, it's imperative to acknowledge the heightened susceptibility to conflicts of interest and potential abuse of power within Saffron Underwriting Limited. The substantial concentration of appointments under their purview amplifies apprehensions regarding the emergence of cartel-like behaviour, where concerted actions could distort market dynamics and impede fair competition. Given these risks, there is a pressing need for thorough scrutiny through independent audits to ensure regulatory compliance and uphold integrity within the insurance sector.
Summary of Argenta Private Capital Limited (PSC of Argenta Secretariat Limited)
There are nine active officers of Argenta Private Capital Limited:
Michael Sean CONNOR, Secretary Appointed on 27 January 2021. A search reveals he has four identities sharing the same three names and correspondence address:
Identity 1, secretary in Argenta International Limited, appointed on 3 October 2023;
Identity 2, secretary in Argenta Private Capital Limited;
Identity 3, secretary in LCM Marketing Services Limited from 21 June 2013 to 21 October 2014; and,
Identity 4, 17 appointments, 2 active roles in CBS Private Capital SLP Limited and Argenta General Partner Limited. A total of 4 active appointments in 3 identities.
The secretary of Argenta General Partner Limited is a corporate entity, Dentons Secretaries Limited, has 338 active appointments, posing audit challenges. Dentons Secretaries Limited is also the secretary of Raine International Holdings UK Limited. Query whether this is also associated to Dame June Raine.
Amy Cordelia Jane BOWDERY, director, date of birth August 1985, appointed on 23 March 2022. One identity only was located with one active and one resigned appointment, 59 Harvist Road RTM Limited (4 April 2014 to 15 August 2022).
Nicola Monica Alexia BURCH, director, date of birth February 1966, appointed on 23 March 2022. Four identities were located through a search, the first two, listed, are active:
Identity 1: Director of Argenta Private Capital Limited, appointed on 23 March 2022.
Identity 2: Director of Ark Syndicate Management Limited, appointed on 1 January 2022.
Identity 3: Former Director of Talbot Underwriting Ltd, 7 April 2017 to 12 November 2021
Identity 4: Former LLP Designated Member of Addleshaw Goddard LLP (28 April 2006 Resigned on 30 April 2016) and Addleshaw Goddard (Hong Kong) LLP, (25 September 2012 to 7 November 2012 and 25 February 2013 to 21 June 2013).
Robert Paul FLACH, director, date of birth March 1967, appointed on 14 September 2018. Also a director of Argenta Secretariat Limited directors he has one identity: 64 appointments.
Philip James Francis GLAZE, director, date of birth June 1964, appointed on 23 March 2022. A search on Philip Glaze returns just one identity with one active appointment and one resigned appointment to HSBC Global Asset Management (UK) Limited, from 12 October 2016 to 28 February 2020, his occupation was given as Chief Investment Officer.
Andrew John HUBBARD, director, date of birth July 1950, appointed on 1 April 2013 has one identity. He has concurrently held appointments to: North John Street LLP, from 3 April 2013 to 5 April 2022; Waverton Properties LLP, since 4 April 2012; Alpha Diving Ltd, since 16 September 2009, Asta Managing Agency Ltd between 1 April 2014 and 30 June 2023. Further analysis is required to determine whether these interests were declared. This name occurs with unusual frequency. Further analysis on whether they may be related parties is recommended.
Guy Bentley HUDSON, director, date of birth November 1960, appointed on 1 December 1998 Occupation Names' Director. Also a director of Argenta Secretariat Limited. 1 identity, 15 appointments, 11 of which are current.
Kevin JACKSON, director, date of birth November 1966, appointed on 4 November 2022. One identity, 11 appointments, 5 of which are active; Argenta Private Capital Limited, Fountain Continuity Limited, CBS Private Capital SLP Limited, Argenta SLP Continuity Limited, Argenta General Partner Limited.
Nicholas John MOORE, director, date of birth November 1979, appointed on 31 December 2022 has one identity with 16 active appointments: Argenta International Limited, Argenta No.17 Limited, Argenta No.16 Limited, Inter Hannover (No.2) Limited, Argenta Private Capital Limited, Argenta Underwriting No. 1 Limited, Argenta Underwriting No.2 Limited, Argenta Underwriting No.3 Limited, Argenta Underwriting No. 4 Limited, Argenta Underwriting No.7 Limited, Argenta Underwriting No.9 Limited, Argenta Underwriting No.10 Limited, Argenta Underwriting No.11 Limited, Inter Hannover (No.1) Limited, Argenta Holdings Limited, Argenta Syndicate Management Limited.
Katharine Louise TONGUE, director, date of birth February 1982, appointed on 10 November 2022 has 2 identities
Identity 1, 2 appointments both active: Argenta Private Capital Limited (since 10 November 2022) and Argenta Tax & Corporate Services Limited (1 November 2019
Identity 2, 1 appointment, Argenta General Partner Limited appointed on 19 June 2023, occupation Tax Adviser.
Marcus Gary WARNER, director, date of birth May 1973, appointed on 3 September 2003, occupation Accountant. He has one identity with 68 appointments, of which 61 are active. A sample of these are N1258 Limited, Tigerstooth Limited, N600 Limited, Argenta General Partner Limited, Sirius Underwriting Limited.
Summary of Argenta Private Capital Limited (PSC of Argenta Secretariat Limited)
There are nine active officers:
Michael Sean CONNOR, Secretary Appointed on 27 January 2021. A search reveals he has four identities sharing the same three names and correspondence address:
Identity 1, secretary in Argenta International Limited, appointed on 3 October 2023;
Identity 2, secretary in Argenta Private Capital Limited;
Identity 3, secretary in LCM Marketing Services Limited from 21 June 2013 to 21 October 2014; and,
Identity 4, 17 appointments, 2 active roles in CBS Private Capital SLP Limited and Argenta General Partner Limited. A total of 4 active appointments in 3 identities.
The secretary of Argenta General Partner Limited is a corporate entity, Dentons Secretaries Limited, has 338 active appointments, posing audit challenges. Dentons Secretaries Limited is also the secretary of Raine International Holdings UK Limited. Query whether this is also associated to Dame June Raine, since the company and the person have the same name, “Raine”.
Amy Cordelia Jane BOWDERY, director, date of birth August 1985, appointed on 23 March 2022. One identity only was located with one active and one resigned appointment, 59 Harvist Road RTM Limited (4 April 2014 to 15 August 2022).
Nicola Monica Alexia BURCH, director, date of birth February 1966, appointed on 23 March 2022. Four identities were located through a search, the first two, listed, are active:
Identity 1: Director of Argenta Private Capital Limited, appointed on 23 March 2022.
Identity 2: Director of Ark Syndicate Management Limited, appointed on 1 January 2022.
Identity 3: Former Director of Talbot Underwriting Ltd, 7 April 2017 to 12 November 2021
Identity 4: Former LLP Designated Member of Addleshaw Goddard LLP (28 April 2006 Resigned on 30 April 2016) and Addleshaw Goddard (Hong Kong) LLP, (25 September 2012 to 7 November 2012 and 25 February 2013 to 21 June 2013).
Robert Paul FLACH, director, date of birth March 1967, appointed on 14 September 2018. Also a director of Argenta Secretariat Limited directors he has one identity: 64 appointments.
Philip James Francis GLAZE, director, date of birth June 1964, appointed on 23 March 2022. A search on Philip Glaze returns just one identity with one active appointment and one resigned appointment to HSBC Global Asset Management (UK) Limited, from 12 October 2016 to 28 February 2020, his occupation was given as Chief Investment Officer.
Andrew John HUBBARD, director, date of birth July 1950, appointed on 1 April 2013 has one identity. He has concurrently held appointments to: North John Street LLP, from 3 April 2013 to 5 April 2022; Waverton Properties LLP, since 4 April 2012; Alpha Diving Ltd, since 16 September 2009, Asta Managing Agency Ltd between 1 April 2014 and 30 June 2023. Further analysis is required to determine whether these interests were declared. This name occurs with unusual frequency. Further analysis on whether they may be related parties is recommended.
Guy Bentley HUDSON, director, date of birth November 1960, appointed on 1 December 1998 Occupation Names' Director. Also a director of Argenta Secretariat Limited. 1 identity, 15 appointments, 11 of which are current.
Kevin JACKSON, director, date of birth November 1966, appointed on 4 November 2022. One identity, 11 appointments, 5 of which are active; Argenta Private Capital Limited, Fountain Continuity Limited, CBS Private Capital SLP Limited, Argenta SLP Continuity Limited, Argenta General Partner Limited.
Nicholas John MOORE, director, date of birth November 1979, appointed on 31 December 2022 has one identity with 16 active appointments: Argenta International Limited, Argenta No.17 Limited, Argenta No.16 Limited, Inter Hannover (No.2) Limited, Argenta Private Capital Limited, Argenta Underwriting No. 1 Limited, Argenta Underwriting No.2 Limited, Argenta Underwriting No.3 Limited, Argenta Underwriting No. 4 Limited, Argenta Underwriting No.7 Limited, Argenta Underwriting No.9 Limited, Argenta Underwriting No.10 Limited, Argenta Underwriting No.11 Limited, Inter Hannover (No.1) Limited, Argenta Holdings Limited, Argenta Syndicate Management Limited.
Katharine Louise TONGUE, director, date of birth February 1982, appointed on 10 November 2022 has 2 identities
Identity 1, 2 appointments both active: Argenta Private Capital Limited (since 10 November 2022) and Argenta Tax & Corporate Services Limited (1 November 2019
Identity 2, 1 appointment, Argenta General Partner Limited appointed on 19 June 2023, occupation Tax Adviser.
Marcus Gary WARNER, director, date of birth May 1973, appointed on 3 September 2003, occupation Accountant. He has one identity with 68 appointments, of which 61 are active. A sample of these are N1258 Limited, Tigerstooth Limited, N600 Limited, Argenta General Partner Limited, Sirius Underwriting Limited.
Argenta Private Capital Limited is the person with significant control of Argenta Secretariat Limited.
Argenta Private Capital Limited
Three officers have multiple identities, in breach of Section 1082 (CA2006), and hve active interests:
Michael Sean Connor, Secretary, has 4 identities, each with an active interest:
Argenta International Limited
Argenta Private Capital Limited
CBS Private Capital SLP Limited
Argenta General Partner Limited
Nicola Monica Alexia Burch, Director, has 4 identities, 2 have an active appointment:
Argenta Private Capital Limited
Ark Syndicate Management Limited
Katharine Louise Tongue, Director, has 2 identities holding 3 active appointments
Argenta Private Capital Limited
Argenta Tax & Corporate Services Limited
Argenta General Partner Limited
The effect of holding multiple identities is twofold: it compromises the accounts of these companies directly, and by association, it compromises the accounts of the companies that the other directors hold.
In conclusion, the analysis reveals multiple instances where directors and officers of Argenta Private Capital Limited hold positions across various companies, raising concerns about transparency and potential breaches of Section 1082 of the Companies Act 2006. Michael Sean Connor, for instance, is associated with four identities, potentially allowing for the manipulation of company structures. Furthermore, the extensive network of appointments, particularly by corporate entities like Dentons Secretaries Limited, poses challenges for audits and oversight. The presence of directors with numerous active appointments, such as Nicholas John Moore and Marcus Gary Warner, underscores the need for closer scrutiny to ensure compliance and prevent conflicts of interest. Additionally, the frequency of certain names, like Andrew John Hubbard, warrants further investigation to determine any potential related-party transactions. Overall, the findings highlight the importance of robust governance mechanisms to uphold accountability and integrity within corporate structures.
Appendix
Analysis of Director Resignations and Reappointments: Legitimate Practices vs. Potential Misconduct
Legitimate reasons for a director resigning and being reappointed on the same day may include administrative procedures, legal requirements, technicalities, strategic decisions, or ensuring continuity in leadership. These reasons are typically aligned with the company's best interests, compliance with regulations, or operational needs.
Illegitimate reasons, on the other hand, may involve fraudulent or deceptive practices such as concealing misconduct, circumventing regulations, falsifying records, engaging in insider dealings, or evading accountability. These reasons serve personal interests or involve unethical behaviour detrimental to the company or its stakeholders.
To ascertain whether the resignation and reappointment are legitimate or illegitimate, evidence such as:
Company records: Reviewing the official company records, including board meeting minutes, resolutions, and documentation related to the director's actions, can provide insights into the circumstances surrounding the resignation and reappointment.
Communication trails: Examining any communications, emails, or memos exchanged between the director, other board members, or company executives may reveal the motivations or discussions leading to the resignation and reappointment.
Regulatory filings: Analysing regulatory filings or disclosures made by the company, particularly those related to changes in directorship or corporate governance, can help identify any irregularities or discrepancies.
Financial transactions: Investigating any financial transactions or activities associated with the director, including changes in compensation, stock ownership, or related-party transactions, may uncover potential conflicts of interest or misconduct.
Independent audits or investigations: Conducting independent audits or investigations, possibly by external auditors or legal advisors, can provide an impartial assessment of the circumstances surrounding the director's actions and determine whether they comply with legal and ethical standards.
By thoroughly examining such evidence, stakeholders can better understand the reasons behind the director's resignation and reappointment and assess whether they align with the company's interests and ethical standards or raise concerns about potential wrongdoing.
Appendix B
An example of how duplicate identities confuse software.
I asked ChatGPT Open AI, to describe the chronology of the officers appointed to Saffron Underwriting Limited, see image below:
The response demonstrates the issue that software has with recognising that some individuals have multiple unique identities. Refer to ChatGPT’s response, in the image below, taking note of the errors ChatGPT introduces in record 6:
This response demonstrates two issues with contemporary AI technology. The principle that people have a unique identity has been used by ChatGPT to stress that the second occurrence of David Harris, in this list of officers, must be a “different individual”, even though both entries had the same date of birth. ChaGPT made a bold statement based on a false assumption.
Additionally, in record 6 for “Dave Harris (different individual)”, ChatGPT inserted the wrong date of appointment, “7 May 2023” instead of “31 October 2002”, which was the same day he resigned his first appointment to the same company. This error highlights the potential for inaccuracies in AI-generated outputs.
From a software point of view, duplicate entries cause false matches and false non-matches and, in ChatGPT’s case, it tried to reconstruct a version of reality that fits with what is “normal”. ChatGPT's attempt to create a coherent narrative, based on the flawed assumption that two people with the same name can’t be the same director, even though they had the same date of birth, resulted in it misrepresenting the facts. This underscores the importance of thorough verification and validation processes in information processing algorithms, such as Companies House deduplication process.
Appendix 3
Raine Limited and Sovereign Harbour Limited are the persons with significant control of SA 1 DEVELOPMENTS LLP (SA 1 DEVELOPMENTS LLP persons with significant control - Find and update company information - GOV.UK (company-information.service.gov.uk)).
SA 1 DEVELOPMENTS LLP
Company number OC307955
Registered office address
Pwc 8th Floor, Central Square, 29 Wellington Street, Leeds, West Yorkshire, LS1 4DL
Company status
Liquidation
Company type
Limited liability partnership
Incorporated on
11 May 2004
Accounts overdue
Next accounts made up to 31 December 2018
due by 30 September 2019Last accounts made up to 31 December 2017
Confirmation statement overdue
Next statement date 20 October 2018
due by 3 November 2018Last statement dated 20 October 2017
Previous company names
Previous company names Name Period QUEST (SA 1) LLP20 May 2004 - 18 Jan 2012 QUEST PROPERTY (HUDDERSFIELD) LLP11 May 2004 - 20 May 2004
The active directors are
8 officers / 6 resignations
RAINE LIMITED
Correspondence address
Crown House, Birch Street, Wolverhampton, United Kingdom, WV1 4JX
Role ACTIVE
LLP Designated Member
Appointed on
30 December 2011
UK Limited Company What's this?
Registration number
416147
CARILLION CONSTRUCTION LIMITED (IN LIQUIDATION)
Correspondence address
Carillion House, 84 Salop Street, Wolverhampton, United Kingdom, WV3 0SR
Role ACTIVE
LLP Member
Appointed on
10 July 2018
UK Limited Company What's this?
Registration number
594581
There are 14 active companies registered to the same registered address:
WILLIAMS FAMILY INVESTMENTS
Active
Private unlimited company
12037418 - Incorporated on 6 June 2019
SM, Fifth Floor Central Square 29 Wellington Street, Leeds, West Yorkshire LS1 4DL
SIC codes - 64991
JOINT MOTION HEALTHCARE LIMITED
Active
Private limited company
12200210 - Incorporated on 11 September 2019
Central Square, 5th Floor, 29 Wellington Street, Leeds, West Yorkshire, United Kingdom LS1 4DL
SIC codes - 86220
INVERGRANGE RADIOLOGY LIMITED
Active
Private limited company
12559243 - Incorporated on 16 April 2020
Central Square, 5th Floor, 29 Wellington Street, Leeds, West Yorkshire, United Kingdom LS1 4DL
SIC codes - 86220
P & S YOUNG LIMITED
Active
Private limited company
06996945 - Incorporated on 20 August 2009
Rsm Central Square, 5th Floor, 29 Wellington Street, Leeds, West Yorkshire, United Kingdom LS1 4DL
SIC codes - 82990
SLATER & CRABTREE LIMITED
Active
Private limited company
00223606 - Incorporated on 3 August 1927
Central Square 29 Wellington Street, Leeds, West Yorkshire LS1 4DL
SIC codes - 25620
LINK SCHEME LTD
Active
Private limited company
08774124 - Incorporated on 13 November 2013
Rsm Central Square, 5th Floor, 29 Wellington Street, Leeds, West Yorkshire, United Kingdom LS1 4DL
SIC codes - 82990
P & S YOUNG PROPERTIES LIMITED
Active
Private limited company
14343854 - Incorporated on 8 September 2022
Rsm Central Square, 5th Floor, 29 Wellington Street, Leeds, West Yorkshire, United Kingdom LS1 4DL
SIC codes - 68209
OXFORD HELICOPTER SERVICES LLP
Active
Limited liability partnership
OC423178 - Incorporated on 29 June 2018
Rsm Central Square, 5th Floor, 29 Wellington Street, Leeds, West Yorkshire, United Kingdom LS1 4DL
TURNER FAMILY INVESTMENTS LIMITED
Active
Private limited company
11225001 - Incorporated on 26 February 2018
Rsm Fifth Floor, Central Square, 29 Wellington Street, Leeds, West Yorkshire, United Kingdom LS1 4DL
SIC codes - 74990
CALIBRE CARE PARTNERS LIMITED
Active
Private limited company
11050638 - Incorporated on 7 November 2017
Rsm, Central Square, 5th Floor, 29, Wellington Street, Leeds, West Yorkshire, United Kingdom LS1 4DL
SIC codes - 86220
LINK SCHEME HOLDINGS LTD
Active
Private limited by guarantee without share capital
10535808 - Incorporated on 21 December 2016
Rsm Central Square, 5th Floor, 29 Wellington Street, Leeds, West Yorkshire, United Kingdom LS1 4DL
SIC codes - 82990
YOUR HANDS LIMITED
Active
Private limited company
07702068 - Incorporated on 12 July 2011
Rsm Central Square, 5th Floor, 29 Wellington Street, Leeds, West Yorkshire, United Kingdom LS1 4DL
SIC codes - 86900
BLUESTAKE
Active
Private unlimited company without share capital
12560198 - Incorporated on 16 April 2020
5th Floor, Central Square, 29 Wellington Street, Leeds, West Yorkshire, United Kingdom LS1 4DL
SIC codes - 64304
JCC BUILDING SERVICES LLP
Active
Limited liability partnership
OC348321 - Incorporated on 2 September 2009
Rsm Central Square, 5th Floor, 29 Wellington Street, Leeds, West Yorkshire, United Kingdom LS1 4DL
Limitations
As an IT Systems Engineer with directorship experience in a multi-national IT company, I have knowledge derived from collaboration with legal experts and accountants. This practical experience informs my approach to due diligence, allowing me to identify potential breaches within Saffron Underwriting's records. However, the constraints of time and the complexity of the task limit the thoroughness of this analysis. Therefore, seeking the opinion of auditors and legal professionals is imperative to fully grasp the scope and significance of any identified anomalies.
This is truly an astoundingly comprehensive investigation.
At a minimum, thanks to Alison's work, June Raine has been part of some sort of scam.
It is surely enough to raise questions about her recent role as CEO of MHRA, potential grift and general Trustafarian activities. Thank you, Alison.