Due Diligence on HMRC

Officials' fail to declare all their interests. Some have multiple identities. Audits compromised.

The people who are responsible for HM Revenue and Customs, are described in the HMRC organisation chart on the Government website. (Throughout this document click on the underlined text to be linked to the webpage referenced.)

Each officer is considered and the results are presented of:

• A search, in Companies House, for identities registered with each name, with the same date of birth, (this is accurate for most names, except for very common combinations of names);

• The interests held by each identity; and,

• A test of whether all their interests have been declared in their biography.

Permanent secretaries

1. Jim Harra – Chief Executive, First Permanent Secretary and Accounting Officer

A search on this name James Harra locates just one identity in Companies House.

James Alan HARRA personal appointments

Total number of appointments 1 Date of birth July 1962

REVENUE & CUSTOMS DIGITAL TECHNOLOGY SERVICES LIMITED (09679225) Company status Active Correspondence address Rcdtss Limited, Room 2e/07, 100 Parliament Street, London, United Kingdom, SW1A 2BQ Role RESIGNED Director Appointed on 9 July 2015 Resigned on 19 April 2018 Occupation Civil Servant.

This directorship is not disclosed in the biography of Jim Harra on the Government website. I conclude that James Harra has failed to register his interest in Revenue & Customs Digital Technology Services Limited and this is a breach of his obligations.

2. Angela MacDonald – Deputy Chief Executive, Second Permanent Secretary

A search in Companies House returned several identities registered with this name and various dates of birth. A manual search identified a record appointed as director of Aviva, which is mentioned in her biography, on the Government website.

Angela Jane MACDONALD personal appointments

Total number of appointments 1 Date of birth May 1970

AVIVA PENSION TRUSTEES UK LIMITED (02407799) Company status Active Correspondence address The Coach House, Back Lane Tollerton, York, North Yorkshire, YO61 1PZ Role RESIGNED Director Appointed on 8 May 2006 Resigned on 18 December 2006.

Angela MacDonald’s role is described as “Angela worked in a number of operational, sales and marketing roles at Aviva plc and its legacy companies”. The description in Angela MacDonald’s biography fails to be fully transparent as it omits that she was appointed as a director of Aviva Pension Trustees UK Limited. This omission could lead to conflicts of interest that have not been managed appropriately.

A search for Angela Jane MacDonald returned only one identity with this name and date of birth.

Executive Committee

HMRC’s Executive Committee is the department’s main executive forum. It oversees and assures all of HMRC’s work and is responsible for setting and delivering strategy. Read more about the Executive Committee.

3. Myrtle Lloyd – Director General Customer Services (Wellbeing Champion)

A search in Companies House returned no identities with the name Myrtle Lloyd. I conclude that Myrtle Lloyd has no interests registered in Companies House.

4. Penny Ciniewicz – Director General Customer Compliance (Race Champion)

A search in Companies House returned no identities with the surname Ciniewicz. I conclude that Penny Ciniewicz has no interests registered in Companies House.

5. Jonathan Athow – Director General Customer Strategy and Tax Design (Social Mobility Champion)

A search in Companies House returns one identity with the name Jonathan Athow.

Jonathan Thomas ATHOW

Total number of appointments 1 Date of birth November 1973

INSTITUTE FOR FISCAL STUDIES(THE) (00954616) Company status Active Correspondence address 7 Ridgmount Street., London, WC1E 7AE Role ACTIVE Director Appointed on 15 July 2014 Occupation Civil Servant.

This currently active position is omitted from Mr Athow’s biography on the Government website. Jonathan Athow fails to declare that he is a director of The Institute of Fiscal Studies, appointed 15 July 2014.

6. Esther Wallington – Chief People Officer (Age and Gender Champion)

A search for Esther Wallington returns two identities with the same date of birth.

Esther WALLINGTON identity 1

Total number of appointments 4 Date of birth December 1975

WALLINGTON STREET TILES LTD (14744054) Company status Active Correspondence address 68c, Westmoor Road, Enfield, England, EN3 7LF Role ACTIVE Director Appointed on 20 March 2023 Occupation Tiles

NATIONAL CENTRE FOR CIRCUS ARTS (02553293) Company status Active Correspondence address Coronet Street, London, N1 6HD Role ACTIVE Director Appointed on 10 May 2022 Occupation Civil Servant

CIRCUS SPACE PROPERTY COMPANY LIMITED (02803347) Company status Active Correspondence address Coronet Street, London, N1 6HD Role ACTIVE Director Appointed on 10 May 2022 Occupation Civil Servant

CIRCUS SPACE EVENTS LIMITED (04027679) Company status Active Correspondence address Coronet Street, London, N1 6HD Role ACTIVE Director Appointed on 10 May 2022 Occupation Civil Servant

Esther Jane WALLINGTON identity 2

Total number of appointments 1 Date of birth December 1975

REVENUE & CUSTOMS DIGITAL TECHNOLOGY SERVICES LIMITED (09679225) Company status Active Correspondence address Rcdts, Room 2e/09, 100 Parliament Street, London, England, England, SW1A 2BQ Role ACTIVE Director Appointed on 29 March 2019 Occupation Civil Servant

Civil Servant Esther Wallington, born December 1975, holds active appointments in two identities in Companies House. To Revenue & Customs Digital Technology Service, in one identity, since 19 March 2019, to Wallington Street Tiles Limited, since 20 March 2020 and to National Centre for Circus Arts, Circus Space Property Company Limited and Circus Space Events Limited, since 20 May 2022. None of these interests are declared in her biography on the Government website.

7. Justin Holliday – Chief Finance Officer, Tax Assurance Commissioner (Religion or Belief Champion)

A search for Justin Holliday returns two identities which include these names but have different dates of birth. Both are reproduced below:

Justin Andrew Cardale HOLLIDAY

Total number of appointments 1 Date of birth August 1969

REVENUE & CUSTOMS DIGITAL TECHNOLOGY SERVICES LIMITED (09679225) Company status Active Correspondence address Rcdtss Limited, Room 2c/04, 100 Parliament Street, London, United Kingdom, SW1A 2BQ Role ACTIVE Director Appointed on 9 July 2015 Occupation Civil Servant

Justin Harry HOLLIDAY Total number of appointments 1

Date of birth June 1971

666 HOLDINGS LIMITED (06677618) Company status Dissolved Correspondence address 2 Godra Bryn, Shwt Bettws, Bridgend, Mid Glamorgan, United Kingdom, CF32 8TU Role Director Appointed on 20 August 2008

Justin Holliday does not declare that he is a director of Revenue & Customs Digital Technology Services Limited in his biography on the Government website. I query whether he is, or is a related party of, Justin Harry Holliday? This could represent a conflict of interest with his role as Tax Assurance Commissioner (Religion or Belief Champion), since the name “666 Holdings” can not be associated with the public’s best interest.

8. Daljit Rehal – Chief Digital and Information Officer (Accessibility Champion)

A search in Companies House locates two identities with the same name and date of birth.

Daljit REHAL identity 1

Total number of appointments 3 Date of birth May 1964

R QUADRANT LIMITED (07743304) Company status Dissolved Correspondence address 193 Ardgowan Road, London, England, SE6 1UZ Role Director Appointed on 17 August 2011 Occupation It Director

PARAGON ANALYTICAL SERVICES LTD (06458878) Company status Dissolved Correspondence address 3 Woodplace Lane, Coulsdon, Surrey, CR5 1NE Role Director Appointed on 21 December 2007 Occupation Head Of Customer Retention

RED CHIP UK LTD (06307540) Company status Dissolved Correspondence address 3 Woodplace Lane, Coulsdon, Surrey, CR5 1NE Role Director Appointed on 10 July 2007 Occupation Programme Manager

Daljit Singh REHAL identity 2

Total number of appointments 2 Date of birth May 1964

REVENUE & CUSTOMS DIGITAL TECHNOLOGY SERVICES LIMITED (09679225) Company status Active Correspondence address Room 2e/09, 100 Parliament Street, London, United Kingdom, SW1A 2BQ Role ACTIVE Director Appointed on 4 November 2020 Occupation Dg Cdio

FOLIO EDUCATION TRUST (07627302) Company status Active Correspondence address Coombe Wood School, 30 Melville Avenue, South Croydon, England, CR2 7HY Role RESIGNED Director Appointed on 23 September 2020 Resigned on 7 February 2021 Occupation Chief Digital Information Officer Hmrc

Daljit Singh Rehal fails to declare that he is a current director of Revenue & Customs Digital Technology Services Limited and a resigned director of Folio Education Trust, R Quadrant Limited, Paragon Analytical Services Ltd and Red Chip UK LTD in his biography on the Government website.

Daljit Rehal declares in his biography that he “served as Global Digital and Data Services Director at Centrica”. However, this is misleading because he was not a director of CENTRICA PLC.

9. Alan Evans – General Counsel and Director General, Solicitor’s Office and Legal Services (LGBTI+ Champion)

A search on Alan Evans locates many identities with this name. His biography includes “Prior to working in Government, Alan practised as a commercial litigator in the City.” I searched the identities for occupations given as legal roles. There is a high likelihood that he is Alan Christopher Evans, date of birth March 1972.

Alan Christopher EVANS identity 1

Total number of appointments 1 Date of birth March 1972

SARACENS MULTI-ACADEMY TRUST (10646649) Company status Active Correspondence address Saracens High School, Corner Mead, London, England, NW9 4AS Role ACTIVE Director Appointed on 14 September 2017 Occupation Partner, Law Firm

Alan Christopher EVANS identity 2

Total number of appointments 1 Date of birth March 1972

TAYLOR WESSING LIMITED LIABILITY PARTNERSHIP (OC322935) Company status Active Correspondence address 5 New Street Square, London, EC4A 3TW Role ACTIVE LLP Member Appointed on 1 May 2007

On balance of probability, Alan Evans has two identities in Companies House and is an active director of Saracens Multi-Academy Trust and member of Taylor Wessing Limited Liability Partnership, and he has failed to disclose this transparently in his biography.

10. Carol Bristow – Director General Borders and Trade

A search locates six identities with this name, with different dates of birth. Carol Bristow’s biography does not include any private interests. If she is Carol Ann Bristow, then, based on the names, and failure to declare these interests, there may be some conflict with the public’s best interest:

Carol Ann BRISTOW

Total number of appointments 2 Date of birth January 1963

DESIGN IN MENTAL HEALTH NETWORK LIMITED (07305882) Company status Dissolved Correspondence address C/O Topping Partnership, 8 Exchange Quay, Salford Quays, Manchester, England, M5 3EJ Role Director Appointed on 6 July 2010 Occupation Service User Liaison Officer

DESIGN IN MENTAL HEALTH LIMITED (07307468) Company status Active Correspondence address C/O Topping Partnership, 8 Exchange Quay, Salford Quays, Manchester, England, M5 3EJ Role RESIGNED Director Appointed on 7 July 2010 Resigned on 21 October 2014N Occupation Service User Liaison Officer.

When a company is dissolved before a director resigns, there is a risk that they remain as signatories to a bank account in that company name. This risk applies to the director, Carol Ann Bristow, of Design in Mental Health Network Limited.

11. Joanna Rowland – Director General for Transformation - Income Tax Service Transformation (Carers Champion)

A search returns four identities with this name. None appear to fit with her biography as a past police officer. More information is required to determine if any of these registered identities belong to Joanna Rowland at HMRC.

12. Suzanne Newton – Director General for Transformation – Strategic Change

A search returns eleven identities with these names with various dates of birth. There is no biography of Suzanne Newton available on the Government website. Based on this information it can not be determined if any of these identities are hers.

13. Andrew Pemberton – Director of Communications (Sustainability Champion)

A search locates forty-one identities for Andrew Pemberton. Because there is no biography on the Government website, it has not been possible to determine whether any of these identities belong to the Director of Communications. Clarification is required.

14. Jonathan Russell – Chief Executive, Valuation Office Agency

A search locates 121 identities that include these names. His biography doesn’t provide any information that would suggest he is, or has been, a director of a company. More information is required.

Non-Executive Board members

15. Dame Jayne-Anne Gadhia (Lead Non-Executive, and Chair of the HMRC Board)

A search locates eleven identities registered for Jayne-Anne Ghadia all with the same date of birth, October 1961.

Jayne-Anne GADHIA identity 1

Total number of appointments 2 Date of birth October 1961

MFM INVESTMENT LTD (09088155) Company status Active Correspondence address 90-92, Pentonville Road, London, United Kingdom, N1 9HS Role ACTIVE Director Appointed on 13 January 2023 Occupation Chairwoman

MFM HOLDING LTD (09553255) Company status Active Correspondence address 90-92, Pentonville Road, London, United Kingdom, N1 9HS Role ACTIVE Director Appointed on 23 November 2022

Jayne-Anne GADHIA identity 2

Total number of appointments 1 Date of birth October 1961

JAGASH LTD (11580116) Company status Liquidation Correspondence address Third Floor, One London Square, Cross Lanes, Guildford, GU1 1UN Role ACTIVE Director Appointed on 20 September 2018

Jayne-Anne GADHIA identity 3

Total number of appointments 1 Date of birth October 1961

THE PRINCE'S SCHOOL OF TRADITIONAL ARTS (04970959) Company status Active Correspondence address 19-22 Charlotte Road, London, EC2A 3SG Role RESIGNED Director Appointed on 1 September 2018 Resigned on 23 March 2021 Country of residence Scotland Occupation Banker

Jayne-Anne GADHIA identity 4

Total number of appointments 1 Date of birth October 1961

THE PRINCE'S FOUNDATION (SC331738) Company status Active Correspondence address Dumfries House, Dumfries House Estate, Cumnock, Ayrshire, KA18 2NJ Role RESIGNED Director Appointed on 3 December 2015 Resigned on 23 March 2021 Occupation Chief Executive

Jayne-Anne GADHIA identity 5

Total number of appointments 4 Date of birth October 1961

GADHIAGROUP LIMITED (11384082) Company status Active Correspondence address 10 Norwich Street, London, England, EC4A 1BD Role ACTIVE Director Appointed on 14 August 2018 Occupation Consultant

USNOOP LIMITED (11797870) Company status Active Correspondence address 10 Norwich Street, London, United Kingdom, EC4A 1BD Role RESIGNED Director Appointed on 30 January 2019 Resigned on 7 August 2023

GADHIA CONSULTANTS LIMITED (11776010) Company status Active Correspondence address 10 Norwich Street, London, United Kingdom, EC4A 1BD Role RESIGNED Director Appointed on 2 July 2020 Resigned on 30 September 2021

GADHIA CONSULTANTS LIMITED (11776010) Company status Active Correspondence address 10 Norwich Street, London, United Kingdom, EC4A 1BD Role RESIGNED Director Appointed on 18 January 2019 Resigned on 24 October 2019

Jayne-Anne GADHIA identity 6

Total number of appointments 1 Date of birth October 1961

STAGECOACH GROUP LIMITED (SC100764) Company status Active Correspondence address 10 Dunkeld Road, Perth, Perthshire, PH1 5TW Role RESIGNED Director Appointed on 1 March 2019 Resigned on 31 July 2019

Jayne-Anne GADHIA identity 7

Total number of appointments 1 Date of birth October 1961

UK FINANCE LIMITED (10250295) Company status Active Correspondence address 1 Angel Court, London, England, EC2R 7HJ Role RESIGNED Director Appointed on 1 July 2017 Resigned on 26 September 2018 Country of residence Scotland Occupation Banking

Jayne-Anne GADHIA identity 8

Total number of appointments 1 Date of birth October 1961

SCOTTISH BUSINESS IN THE COMMUNITY LIMITED (SC080355) Company status Active Correspondence address 28 St. Andrew Square, Edinburgh, Scotland, EH2 1AF Role RESIGNED Director Appointed on 7 November 2013 Resigned on 31 March 2017 Country of residence Scotland Occupation Chief Executive Officer

Jayne-Anne GADHIA identity 9

Total number of appointments 7 Date of birth October 1961

VIRGIN MONEY GIVING LIMITED (02733492) Company status Active Correspondence address Jubilee House, Gosforth, Newcastle-Upon-Tyne, NE3 4PL Role RESIGNED Director Appointed on 6 December 2012 Resigned on 15 October 2018 Occupation Chief Executive Officer

VIRGIN MONEY UNIT TRUST MANAGERS LIMITED (03000482) Company status Active Correspondence address Jubilee House, Gosforth, Newcastle-Upon-Tyne, NE3 4PLRole RESIGNED Director Appointed on 17 November 2016 Resigned on 15 October 2018 Occupation Chief Executive Officer

VIRGIN MONEY PERSONAL FINANCIAL SERVICE LIMITED (03072766) Company status Active Correspondence address Jubilee House, Gosforth, Newcastle-Upon-Tyne, NE3 4PL Role RESIGNED Director Appointed on 28 December 2016 Resigned on 15 October 2018 Occupation Chief Executive Officer

VIRGIN MONEY LIMITED (06952311) Company status Active Correspondence address Northern Rock House, Gosforth, Newcastle Upon Tyne, NE3 4PL Role RESIGNED Director Appointed on 1 January 2012 Resigned on 15 October 2018 Occupation Accountant

VIRGIN MONEY HOLDINGS (UK) LIMITED (03087587) Company status Active Correspondence address Jubilee House, Gosforth, Newcastle-Upon-Tyne, United Kingdom, NE3 4PL Role RESIGNED Director Appointed on 12 March 2007 Resigned on 15 October 2018 Occupation Accountant

BUSINESS IN THE COMMUNITY (01619253) Company status Active Correspondence address Jubilee House, Gosforth, Newcastle Upon Tyne, United Kingdom, NE3 4PL Role RESIGNED Director Appointed on 1 January 2016 Resigned on 8 February 2017 Occupation Chief Executive

BUSINESS IN THE COMMUNITY (01619253) Company status Active Correspondence address Jubilee House, Gosforth, Newcastle Upon Tyne, United Kingdom, NE3 4PL Role RESIGNED Director Appointed on 28 April 2014 Resigned on 8 June 2015 Occupation Chief Executive Officer

Jayne-Anne GADHIA identity 10

Total number of appointments 1 Date of birth October 1961

THE BRITISH INSPIRATION TRUST (07141817) Company status Active Correspondence address 2 Wellington Place, Leeds, West Yorkshire, LS1 4BZ Role RESIGNED Director Appointed on 1 May 2010 Resigned on 21 June 2011

Jayne-Anne GADHIA identity 11

Total number of appointments 23 Date of birth October 1961

BANK AND CLIENTS PLC (00980698) Company status Liquidation Correspondence address 30 King Street, London, England, EC2V 8EH Role RESIGNED Director Appointed on 27 January 2010 Resigned on 30 November 2014 Occupation Chief Executive Officer

THE VIRGIN FOUNDATION (02155645) Company status Active Correspondence address Hanover House, 14 Hanover Square, London, W1S 1HP Role RESIGNED Director Appointed on 8 July 2009 Resigned on 7 April 2012 Occupation Ceo

VIRGIN MONEY GIVING LIMITED (02733492) Company status Active Correspondence address Discovery House, Whiting Road, Norwich, Norfolk, NR4 7EJ Role RESIGNED Director Appointed on 11 February 2009 Resigned on 23 February 2012 Occupation Accountant

VIRGIN FINANCIAL SERVICES UK HOLDINGS LIMITED (03248191)Company Status Dissolved Correspondence address Discovery House, Whiting Road, Norwich, Norfolk, United Kingdom, NR4 6EJ Role RESIGNED Director Appointed on 2 May 2008 Resigned on 16 December 2011 Occupation Accountant

SENTEBALE (05747857) Company status Active Correspondence address The School House, 50 Brook Green, Hammersmith, London, W6 7RR Role RESIGNED Director Appointed on 15 December 2008 Resigned on 17 November 2011 Occupation Ceo

VIRGIN MONEY UNIT TRUST MANAGERS LIMITED (03000482) Company status Active Correspondence address The School House, 50 Brook Green, Hammersmith, London, W6 7RR Role RESIGNED Director Appointed on 30 March 2007 Resigned on 12 February 2009 Occupation Accountant

SAPPHIRE CARDS LIMITED (04232392) Company status Dissolved Correspondence address The School House, 50 Brook Green, Hammersmith, London, W6 7RR Role RESIGNED Director Appointed on 20 March 2007 Resigned on 12 February 2009 Occupation Accountant

VIRGIN MONEY PERSONAL FINANCIAL SERVICE LIMITED (03072766) Company status Active Correspondence address The School House, 50 Brook Green, Hammersmith, London, W6 7RR Role RESIGNED Director Appointed on 30 March 2007 Resigned on 12 February 2009 Occupation Accountant

VIRGIN MONEY MANAGEMENT SERVICES LIMITED (03072772) Company status Active Correspondence address The School House, 50 Brook Green, Hammersmith, London, W6 7RR Role RESIGNED Director Appointed on 20 March 2007 Resigned on 12 February 2009 Occupation Accountant

LOMBARD HOME LOANS LIMITED (01832919) Company status Dissolved Correspondence address 8 Whitehouse Terrace, The Grange, Edinburgh, Midlothian, EH9 2EU Role RESIGNED Director Appointed on 21 February 2005 Resigned on 10 January 2007 Occupation Bank Official

THE ONE ACCOUNT LIMITED (03414708) Company status Active Correspondence address 8 Whitehouse Terrace, The Grange, Edinburgh, Midlothian, EH9 2EU Role RESIGNED Director Appointed on 6 August 2001 Resigned on 10 January 2007 Occupation Chartered Accountant

DIRECT LINE FINANCIAL SERVICES (02372702) Company status Dissolved Correspondence address 8 Whitehouse Terrace, The Grange, Edinburgh, Midlothian, EH9 2EU Role RESIGNED Director Appointed on 1 March 2005 Resigned on 10 January 2007 Occupation Bank Official

VIRGIN MONEY UNIT TRUST MANAGERS LIMITED (03000482) Company status Active Correspondence address 8 Whitehouse Terrace, The Grange, Edinburgh, Midlothian, EH9 2EU Role RESIGNED Director Appointed on 16 December 1994 Resigned on 27 July 2001

RE LIFE LIMITED (03087584) Company status Dissolved Correspondence address 8 Whitehouse Terrace, The Grange, Edinburgh, Midlothian, EH9 2EU Role RESIGNED Director Appointed on 21 September 1995 Resigned on 27 July 2001

CHALLENGER (NORWICH) LIMITED (03427512) Company status Dissolved Correspondence address 8 Whitehouse Terrace, The Grange, Edinburgh, Midlothian, EH9 2EU Role RESIGNED Director Appointed on 21 November 1997 Resigned on 27 July 2001

VIRGIN MONEY PERSONAL FINANCIAL SERVICE LIMITED (03072766) Company status Active Correspondence address 8 Whitehouse Terrace, The Grange, Edinburgh, Midlothian, EH9 2EU Role RESIGNED Director Appointed on 13 July 1995 Resigned on 27 July 2001

VIRGIN MONEY HOLDINGS (UK) LIMITED (03087587) Company status Active Correspondence address 8 Whitehouse Terrace, The Grange, Edinburgh, Midlothian, EH9 2EU Role RESIGNED Director Appointed on 21 September 1995 Resigned on 27 July 2001

VIRGIN MONEY NOMINEES LIMITED (03346243) Company status Active Correspondence address 8 Whitehouse Terrace, The Grange, Edinburgh, Midlothian, EH9 2EU Role RESIGNED Director Appointed on 21 April 1997 Resigned on 27 July 2001

VIRGIN MONEY MANAGEMENT SERVICES LIMITED (03072772) Company status Active Correspondence address 8 Whitehouse Terrace, The Grange, Edinburgh, Midlothian, EH9 2EU Role RESIGNED Director Appointed on 11 January 1996 Resigned on 27 July 2001

RE LIFE LIMITED (03087584) Company status Dissolved Correspondence address 8 Whitehouse Terrace, The Grange, Edinburgh, Midlothian, EH9 2EU Role RESIGNED Secretary Appointed on 21 September 1995 Resigned on 23 April 1997

VIRGIN MONEY HOLDINGS (UK) LIMITED (03087587) Company status Active Correspondence address 8 Whitehouse Terrace, The Grange, Edinburgh, Midlothian, EH9 2EU Role RESIGNED Secretary Appointed on 21 September 1995 Resigned on 23 April 1997

VIRGIN MONEY PERSONAL FINANCIAL SERVICE LIMITED (03072766) Company status Active Correspondence address 8 Whitehouse Terrace, The Grange, Edinburgh, Midlothian, EH9 2EU Role RESIGNED Secretary Appointed on 13 July 1995 Resigned on 23 April 1997

VIRGIN MONEY MANAGEMENT SERVICES LIMITED (03072772) Company status Active Correspondence address 8 Whitehouse Terrace, The Grange, Edinburgh, Midlothian, EH9 2EU Role RESIGNED Secretary Appointed on 11 January 1996 Resigned on 27 June 1996

Dame Jayne-Anne biography provides the following:

Dame Jayne-Anne is the Lead Non-Executive at HM Revenue and Customs (HMRC), chairs the HMRC Board, and is Chair of Moneyfarm, Senior Independent Director at the Tate and a Senior Adviser both at UniCredit and at Vanquis Bank.

From 2007 to 2018 she was the CEO of Virgin Money.

A chartered accountant, she spent 6 years at Norwich Union (now Aviva) before becoming one of the founders of Virgin Direct in 1995. Three years later, she set up the Virgin One account, which was acquired by the Royal Bank of Scotland in 2001. She subsequently spent 5 years at RBS before returning to Virgin as CEO of Virgin Money.

In 2012 Jayne Anne led Virgin Money’s acquisition of Northern Rock before listing the combined business in 2014. In 2018, the combined Virgin Money business was sold to CYGB. Following the sale of Virgin Money, Jayne-Anne joined Salesforce from 2019 to 2021. She left Salesforce to focus on her own fintech, Snoop, which was sold to Vanquis Bank in July 2023.

Dame Jayne-Anne Gadhia fails to declare the following interests:

Jayne-Anne GADHIA identity 1

MFM INVESTMENT LTD ACTIVE Director Appointed on 13 January 2023

MFM HOLDING LTD ACTIVE Director Appointed on 23 November 2022

Jayne-Anne GADHIA identity 2

JAGASH LTD Liquidation ACTIVE Director Appointed on 20 September 2018

Jayne-Anne GADHIA identity 3

THE PRINCE'S SCHOOL OF TRADITIONAL ARTS RESIGNED Director Appointed on 1 September 2018 Resigned on 23 March 2021

Jayne-Anne GADHIA identity 4

THE PRINCE'S FOUNDATION RESIGNED Director Appointed on 3 December 2015 Resigned on 23 March 2021

Jayne-Anne GADHIA identity 5

GADHIAGROUP LIMITED ACTIVE Director Appointed on 14 August 2018

GADHIA CONSULTANTS LIMITED RESIGNED Director Appointed on 2 July 2020 Resigned on 30 September 2021

GADHIA CONSULTANTS LIMITED RESIGNED Director Appointed on 18 January 2019 Resigned on 24 October 2019

Jayne-Anne GADHIA identity 6

STAGECOACH GROUP LIMITED RESIGNED Director Appointed on 1 March 2019 Resigned on 31 July 2019

Jayne-Anne GADHIA identity 7

UK FINANCE LIMITED RESIGNED Director Appointed on 1 July 2017 Resigned on 26 September 2018

Jayne-Anne GADHIA identity 8

SCOTTISH BUSINESS IN THE COMMUNITY LIMITED RESIGNED Director Appointed on 7 November 2013 Resigned on 31 March 2017

Jayne-Anne GADHIA identity 9

BUSINESS IN THE COMMUNITY RESIGNED Director Appointed on 1 January 2016 Resigned on 8 February 2017

BUSINESS IN THE COMMUNITY RESIGNED Director Appointed on 28 April 2014 Resigned on 8 June 2015

Jayne-Anne GADHIA identity 10

THE BRITISH INSPIRATION TRUST RESIGNED Director Appointed on 1 May 2010 Resigned on 21 June 2011

Jayne-Anne GADHIA identity 11

BANK AND CLIENTS PLC Liquidation RESIGNED Director Appointed on 27 January 2010 Resigned on 30 November 2014

SENTEBALE RESIGNED Director Appointed on 15 December 2008 Resigned on 17 November 2011 Occupation Ceo

SAPPHIRE CARDS LIMITED RESIGNED Director Appointed on 20 March 2007 Resigned on 12 February 2009 Occupation Accountant

LOMBARD HOME LOANS LIMITED RESIGNED Director Appointed on 21 February 2005 Resigned on 10 January 2007 Occupation Bank Official

THE ONE ACCOUNT LIMITED RESIGNED Director Appointed on 6 August 2001 Resigned on 10 January 2007 Occupation Chartered Accountant

DIRECT LINE FINANCIAL SERVICES RESIGNED Director Appointed on 1 March 2005 Resigned on 10 January 2007 Occupation Bank Official

RE LIFE LIMITED RESIGNED Director Appointed on 21 September 1995 Resigned on 27 July 2001

CHALLENGER (NORWICH) LIMITED RESIGNED Director Appointed on 21 November 1997 Resigned on 27 July 2001

RE LIFE LIMITED RESIGNED Secretary Appointed on 21 September 1995 Resigned on 23 April 1997

Dame Jayne-Anne’s biography provides the following information regarding Virgin Money. The interest declared has been matched, below, with the interest in Companies House, as part of a process of elimination to identity which interests she did not disclose:

“From 2007 to 2018 she was the CEO of Virgin Money.”

This interest is held in identity 9:

VIRGIN MONEY HOLDINGS (UK) LIMITED RESIGNED Director Appointed on 12 March 2007 Resigned on 15 October 2018

“A chartered accountant, she spent 6 years at Norwich Union (now Aviva) before becoming one of the founders of Virgin Direct in 1995.”

This relates to two appointments, as secretary and director of Virgin Money Holdings (UK) Limited, which was called Virgin Direct Limited from 26 Sep 1995 to 04 Feb 2002. An interest held in identity 11:

VIRGIN MONEY HOLDINGS (UK) LIMITED RESIGNED Secretary Appointed on 21 September 1995 Resigned on 23 April 1997.

VIRGIN MONEY HOLDINGS (UK) LIMITED RESIGNED Director Appointed on 21 September 1995 Resigned on 27 July 2001

“Three years later, she set up the Virgin One account, which was acquired by the Royal Bank of Scotland in 2001.” She subsequently spent 5 years at RBS before returning to Virgin as CEO of Virgin Money.”

From 27 July 2001 to 20 March 2007 there are no appointments in Companies House that were active in this period.

Dame Jayne-Anne’s return “to Virgin as CEO of Virgin Money” coincides with three appointments, the fist two held in identity 9, the third held in identity 11:

VIRGIN MONEY UNIT TRUST MANAGERS LIMITED RESIGNED Director Appointed on 30 March 2007 Resigned on 12 February 2009 Occupation Accountant

VIRGIN MONEY PERSONAL FINANCIAL SERVICE LIMITED RESIGNED Director Appointed on 30 March 2007 Resigned on 12 February 2009 Accountant

VIRGIN MONEY MANAGEMENT SERVICES LIMITED RESIGNED Director Appointed on 20 March 2007 Resigned on 12 February 2009 Occupation Accountant

For full transparency, each of these companies should have been named in the Dame Jayne-Anne’s biography.

“In 2012 Jayne Anne (sic) led Virgin Money’s acquisition of Northern Rock before listing the combined business in 2014.

In 2018, the combined Virgin Money business was sold to CYGB. Following the sale of Virgin Money, Jayne-Anne joined Salesforce from 2019 to 2021.”

The disclosures relate to the timeframe of the following appointments held in identity 9:

VIRGIN MONEY GIVING LIMITED RESIGNED Director Appointed on 6 December 2012 Resigned on 15 October 2018

VIRGIN MONEY UNIT TRUST MANAGERS LIMITED RESIGNED Director Appointed on 17 November 2016 Resigned on 15 October 2018

VIRGIN MONEY PERSONAL FINANCIAL SERVICE LIMITED RESIGNED Director Appointed on 28 December 2016 Resigned on 15 October 2018

VIRGIN MONEY LIMITED RESIGNED Director Appointed on 1 January 2012 Resigned on 15 October 2018

Dame Jayne-Anne fails to accurately declare her interests associated to the companies that use the names “Virgin Money”.

The following interests are not declared in Dame Jayne-Anne’s biography, which are held in identity 11.

THE VIRGIN FOUNDATION RESIGNED Director Appointed on 8 July 2009 Resigned on 7 April 2012 Occupation Ceo

VIRGIN MONEY GIVING LIMITED RESIGNED Director Appointed on 11 February 2009 Resigned on 23 February 2012

VIRGIN FINANCIAL SERVICES UK HOLDINGS LIMITED RESIGNED Director Appointed on 2 May 2008 Resigned on 16 December 2011

VIRGIN MONEY NOMINEES LIMITED RESIGNED Director Appointed on 21 April 1997 Resigned on 27 July 2001

VIRGIN MONEY MANAGEMENT SERVICES LIMITED RESIGNED Director Appointed on 11 January 1996 Resigned on 27 July 2001

VIRGIN MONEY PERSONAL FINANCIAL SERVICE LIMITED RESIGNED Secretary Appointed on 13 July 1995 Resigned on 23 April 1997

VIRGIN MONEY PERSONAL FINANCIAL SERVICE LIMITED RESIGNED Director Appointed on 13 July 1995 Resigned on 27 July 2001

VIRGIN MONEY UNIT TRUST MANAGERS LIMITED RESIGNED Director Appointed on 16 December 1994 Resigned on 27 July 2001

VIRGIN MONEY MANAGEMENT SERVICES LIMITED RESIGNED Secretary Appointed on 11 January 1996 Resigned on 27 June 1996

No appointments in Companies House are related to:

Dame Jayne-Anne is the Lead Non-Executive at HM Revenue and Customs (HMRC), chairs the HMRC Board, and is Chair of Moneyfarm, Senior Independent Director at the Tate and a Senior Adviser both at UniCredit and at Vanquis Bank.

The biography includes “She left Salesforce to focus on her own fintech, Snoop, which was sold to Vanquis Bank in July 2023.”

Held in identity 5 is the following registration:

USNOOP LIMITED RESIGNED Director Appointed on 30 January 2019 Resigned on 7 August 2023

Usnoop Limited has not had any name changes. Dame Jayne-Anne has disclosed a variation on the name of her company, by the removal of “U” in her biography. If anyone were to search for “Snoop” in Companies House, they would not locate the record for “Usnoop”. This is evidence of obfuscation.

Dame Jayne-Anne failed to declare Usnoop Limited. Instead she recorded “Usnoop” as “Snoop”, which is false representation that has a material impact on her transparency and accountability.

Summary of Dame Jayne-Anne’s undeclared interests

Dame Jayne-Anne has registered eleven identities in Companies House. This compromises audits associated to her. She fails to disclose:

• Two active directorships held in Jayne-Anne GADHIA identity 1 to MFM INVESTMENT LTD, since 13 January 2023, and MFM HOLDING LTD since 23 November 2022.

• One active directorship held in Jayne-Anne GADHIA identity 2 to JAGASH LTD since 20 September 2018, a company in liquidation.

• One resigned directorship held in Jayne-Anne GADHIA identity 3 to THE PRINCE'S SCHOOL OF TRADITIONAL ARTS from1 September 2018 to 23 March 2021.

• One resigned directorship held in Jayne-Anne GADHIA identity 4 to THE PRINCE'S FOUNDATION RESIGNED from 3 December 2015 to 23 March 2021.

• Three directorships held in Jayne-Anne GADHIA identity 5; one active directorship to GADHIAGROUP LIMITED since 14 August 2018, and two resigned directorships to GADHIA CONSULTANTS LIMITED from January 2019 to 24 October 2019 and from 2 July 2020 to 30 September 2021.

• One resigned directorship held in Jayne-Anne GADHIA identity 6 to

  STAGECOACH GROUP LIMITED from 1 March 2019 to 31 July 2019.

• One resigned directorship held in Jayne-Anne GADHIA identity 7 to UK FINANCE LIMITED from 1 July 2017 to 26 September 2018.

• One resigned directorship held in Jayne-Anne GADHIA identity 8 to SCOTTISH BUSINESS IN THE COMMUNITY LIMITED from 7 November 2013 to 31 March 2017.

• Two resigned directorships held in Jayne-Anne GADHIA identity 9 to

  BUSINESS IN THE COMMUNITY from 28 April 2014 to 8 June 2015 and from 1 January 2016 to 8 February 2017.

• One resigned directorship held in Jayne-Anne GADHIA identity 10 to THE BRITISH INSPIRATION TRUST from 1 May 2010 to 21 June 2011.

• Nine resigned appointments held in Jayne-Anne GADHIA identity 11 to:

  • BANK AND CLIENTS PLC Liquidation from 27 January 2010 to 30 November 2014

  • SENTEBALE RESIGNED from 15 December 2008 to 17 November 2011

  • SAPPHIRE CARDS LIMITED from 20 March 2007 to 12 February 2009

  • LOMBARD HOME LOANS LIMITED from 21 February 2005 to 10 January 2007

  • THE ONE ACCOUNT LIMITED from 6 August 2001 to 10 January 2007

  • DIRECT LINE FINANCIAL SERVICES from 1 March 2005 to 10 January 2007

  • RE LIFE LIMITED from 21 September 1995 to 27 July 2001

  • CHALLENGER (NORWICH) LIMITED from 21 November 1997 to 27 July 2001

  • RE LIFE LIMITED Secretary from 21 September 1995 to 23 April 1997

• There are several Virgin interests which are not disclose accurately. This includes directorships held in identity 9:

  • VIRGIN MONEY GIVING LIMITED from 6 December 2012 to 15 October 2018

  • VIRGIN MONEY UNIT TRUST MANAGERS LIMITED from 17 November 2016 to 15 October 2018

  • VIRGIN MONEY PERSONAL FINANCIAL SERVICE LIMITED from 28 December 2016 to 15 October 2018

• Virgin interests which are not disclosed accurately in identity 11:

  • THE VIRGIN FOUNDATION from 8 July 2009 to 7 April 2012

  • VIRGIN MONEY GIVING LIMITED RESIGNED from 11 February 2009 to 23 February 2012

  • VIRGIN FINANCIAL SERVICES UK HOLDINGS LIMITED from 2 May 2008 to 16 December 2011

  • VIRGIN MONEY NOMINEES LIMITED from 21 April 1997 to 27 July 2001

  • VIRGIN MONEY MANAGEMENT SERVICES LIMITED from 11 January 1996 to 27 July 2001

  • VIRGIN MONEY PERSONAL FINANCIAL SERVICE LIMITED from 13 July 1995 to 23 April 1997

  • VIRGIN MONEY PERSONAL FINANCIAL SERVICE LIMITED from 13 July to 27 July 2001

  • VIRGIN MONEY UNIT TRUST MANAGERS LIMITED from 16 December 1994 to 27 July 2001

  • VIRGIN MONEY MANAGEMENT SERVICES LIMITED Secretary from 11 January 1996 to 27 June 1996.

• The directorship held in identity 5 to USNOOP LIMITED from 30 January 2019 to 7 August 2023 is incorrectly declared as “Snoop” in Dame Jayne-Anne’s biography. This is evidence of obfuscation. Dame Jayne-Anne failed to declare Usnoop Limited. Instead she recorded “Usnoop” as “Snoop”, which is false representation that has a material impact on her transparency and accountability.

Late addition

A search on “Ghadia”, instead of “Gadhia”, a result of mistyping Dame Jayne-Anne’s name, returns a twelfth identity for Dame Jayne-Anne, date of birth 1961.

Jayne-Anne GHADIA identity 12

Total number of appointments 1 Date of birth October 1961

UNICREDIT S.P.A. (FC007432) Company status Active Correspondence address Tower A, Piazza Gae Aulenti No.3, Milan, Italy, 20154 Role ACTIVE Director Appointed on 15 April 2021

UNICREDIT S.P.A. charges Persons entitled:

Trustees of the Banca Di Roma Retirement Benefits Scheme

Deutsche Bank

Ag Abn Amro N.V. (The Beneficiary)

Dame Jayne-Anne Gadhia declares in her biography that she is “a Senior Adviser at UniCredit”. She has a twelfth identity in Companies House which holds an active interest to UNICREDIT S.P.A., using a different spelling of her name, “Ghadia” instead of “Gadhia”.

Dame Jayne-Anne fails to declare that she is a director of UNICREDIT S.P.A., since 15 April 2021, and she has used a different spelling of her name to register this interest in Companies House, this is evidence of obfuscation. Her directorship of Unicredit SPA represents a potential conflict of interest with her role at HMRC.

Conclusion regarding Dame Jayne-Anne

Dame Jayne-Anne has established twelve identities in Companies House, one using a misspelling of her name, and she has failed to disclose all of the interests held in each of these identities, as expanded above. Multiple identities conceal interests. If the owner fails to disclose these interests this is evidence that the identities were created with the intention of concealing interests and this is evidence of fraud by false representation (Section 2 Fraud Act 2006). Failing to register her interests is evidence of fraud by failing to disclose information (Section 3 Fraud Act 2006).

Of particular concern is that she has five active directorships that she has failed to disclose MFM INVESTMENT LTD, MFM HOLDING LTD, JAGASH LTD, GADHIAGROUP LIMITED and UNICREDIT S.P.A., which was registered with the spelling “Ghadia” instead of “Gadhia”.

She incorrectly registered her company Usnoop Limited as “Snoop” in her biography, which renders the records of Usnoop difficult to locate. This is evidence of obfuscation.

I allege that there is sufficient evidence to support that there be a police investigation into the conduct of Dame Jane-Anne relating to her registration of multiple identities and her failure to declare past and current interests, her obfuscation around Usnoop Limited, and any conflicts, or mutual, interests arising.

Dame Jayne-Anne Gadhia / Ghadia also requires further investigation for fraud by false representation, by using a different spelling of her name, fraud by failing to disclose information in her biography, and fraud by abuse of position.

There are only four other identities registered in Companies House with the name Ghadia. These are:

Rajnikant GHADIA Total number of appointments 0 - Born December 1956 6 Deans Drive, Stanmore, Middlesex, United Kingdom, HA7 1HD

Rakesh GHADIA Total number of appointments 0 125 Moseley Avenue, Coventry, CV6 1HS

Tushar GHADIA Total number of appointments 1 - Born March 1982 17 Bryanston Square, London, United Kingdom, W1H 2DP

Rai GHADIA Total number of appointments 1 EDWARD FINK, 12 Cornwall Gardens, London, United Kingdom, United Kingdom, SW7 4AN

Disclosure by Jayne-Anne Gadhia / Ghadia of her related parties is recommended.

16. Michael Hearty (non-executive board member with responsibility for the Union)

Michael Hearty’s biography declares no private interests:

Michael Hearty is a Non-Executive Director at HMRC. He is a highly experienced, professionally qualified, senior manager with extensive strategic and operational leadership experience in 2 large and complex UK government departments: the Department for Work and Pensions and the Department for Education, the latter at Board level. More recently, he spent 5 years on the Board of the Welsh Government, the executive arm of devolved government in Wales, where he provided strategic advice, challenge and support directly to both the First Minister and Finance Minister for Wales on a range of strategic and finance matters. Widely respected for integrity, strategic insight and pragmatism, with particular strengths in transformational change, leadership development and partnership working, Michael is also an experienced non-executive director, having advised high profile organisations such as the Department of Health and Public Health England. Michael was a member of CIPFA’s Council for 4 years and is currently a member of the CIPFA Standards and Financial Reporting Board.

A search in Companies House for “Michael Hearty” returns six identities that include these names, with different dates of birth. There is one identity that contains appointments related to Education which could be his.

Michael John HEARTY

Total number of appointments 3 Date of birth May 1959

MJRT EXECUTIVE LTD (09879509) Company status Dissolved Correspondence address 280 Victoria Road West, Thornton Cleveleys, Lancashire, United Kingdom, FY5 3QD Role Director Appointed on 19 November 2015 Occupation Consultant

BUILDING SCHOOLS FOR THE FUTURE INVESTMENTS (BSFI) LIMITED (05584965) Company status Dissolved Correspondence address 280 Victoria Road West, Cleveleys, Lancashire, FY5 3QD Role RESIGNED Director Appointed on 30 November 2006 Resigned on 31 March 2009

BUILDING SCHOOLS FOR THE FUTURE INVESTMENTS (BRISTOL) LIMITED (05799633) Company status Active Correspondence address 280 Victoria Road West, Cleveleys, Lancashire, FY5 3QD Role RESIGNED Director Appointed on 28 June 2006 Resigned on 26 June 2008

If this identity belongs to Michael Hearty at HMRC, then he has failed to declare these directorships. Clarification is sought.

17. Juliette Scott

Juliette Scott’s biography reads (company names in bold):

Juliette is currently a Non-Executive Director for HMRC. She is also a Non-Executive Board Member at Versus Arthritis (formerly known as Arthritis Research UK) and provides advisory services through her consultancy business. Juliette was previously at eBay - firstly on the Board of eBay UK as the Director of Customer Insight, and latterly was responsible for customer insight and analytics across Europe. Juliette was introduced into the world of data insight through her time at dunnhumby (sic) where she worked in senior roles across many areas of the Tesco business.

A search in Companies House returns seven identities that include the names Juliette Scott, with different dates of birth. The second in the list holds a directorship of Versus Arthritis, which is listed in Juliette Scott’s biography.

Juliette Maria SCOTT

Total number of appointments 2 Date of birth October 1967

SPELLINS CONSULTING SERVICES LIMITED (08091734) Company status Active Correspondence address Suite 2a1, Northside House, Mount Pleasant, Barnet, England, EN4 9EB Role ACTIVE Director Appointed on 15 January 2018 Occupation Self-Employed

VERSUS ARTHRITIS (00490500) Company status Active Correspondence address Copeman House, St. Marys Gate, Chesterfield, Derbyshire, United Kingdom, S41 7TD Role RESIGNED Director Appointed on 19 April 2014 Resigned on 2 March 2023

Juliette Scott fails to declare that she is an active director of Spellins Consulting Services Limited in her biography on the Government website.

Juliette Scott declares that she was “on the Board of eBay UK”. The directors of EBAY (UK) LIMITED are listed in Companies House and these do not include Juliette Scott. Clarification of this seemingly false disclosure is necessary.

18. Paul Morton

Paul Morton was appointed as an HM Revenue and Customs non-executive director in September 2019. He was Tax Director of the Office of Tax Simplification from March 2017 to January 2019. Before that he was Tax Director for RELX Group plc (formerly Reed Elsevier), the global information and analytics group, for 12 years. He was actively engaged with the Organisation for Economic Co-operation and Development (OECD) and tax policy makers in the UK, US and the Netherlands and at EU level on tax policy matters relating to the digital economy and many other aspects of tax policy. Previously, he was a tax manager and adviser at Royal Dutch Shell in a number of UK and overseas roles over 16 years. He moved to Shell from KPMG, where he focused on international tax and insurance companies. He began his career in tax - after reading Microbiology at University College London - when he joined the Inland Revenue as a tax inspector.

A search in Companies House on Paul Morton returns many identities with this name. To narrow down the search the directors of RELX GROUP PLC were reviewed as “he was Tax Director for RELX Group plc”. However, Paul Morton does not appear as a director of RELX Group Plc in the records at Companies House. There is insufficient information available to identify Paul Morton’s interests in Companies House. Further information is required, such as the month and year of his birth.

19. Patricia Gallan

Patricia Gallan QPM is a Non-Executive Director at HMRC. She is a former British police officer who was Assistant Commissioner Specialist Crime and Operations of the Metropolitan Police in London until 2018. She previously served as Deputy Assistant Commissioner (Specialist Operations – Security and Protection) and also Deputy Assistant Commissioner (Professionalism) from 2012 to 2015, Assistant Chief Constable (Operations Support) of Merseyside Police from February 2006 to 2012, and also served as temporary Deputy Chief Constable of the force from October 2009 to February 2010. She was Assistant Chief Constable at the National Crime Squad from January 2005 to February 2006.

A search in Companies House on the name Patricia Gallan returns two identities with these two names and both with date of birth October 1965.

Patricia GALLAN identity 1

Total number of appointments 1 Date of birth October 1965

DRAPERS' MULTI-ACADEMY TRUST (07035556) Company status Active Correspondence address 35 Ballards Lane, London, England, N3 1XW Role ACTIVE Director Appointed on 17 October 2022

Patricia Ferguson GALLAN identity 2

Total number of appointments 1 Date of birth October 1965

REDTHREAD YOUTH LIMITED (03131121) Company status Active Correspondence address 158 Buckingham Palace Road, 158 Buckingham Palace Road, London, England, SW1W 9TR Role RESIGNED Director Appointed on 24 July 2019 Resigned on 31 July 2023 Occupation Retired Police Officer

Since Patricia Gallan identity gives occupation as “Retired Police Officer” in identity 2, we can certain that this identity belongs to the HMRC official, who states role this in her biography. Since identity 1 and 2 have the same date of birth and Gallan is an uncommon surname we can be certain that both identities belong to Patricia Gallan at HMRC. Therefore, Patricia Gallan has failed to declare that she is an active director of DRAPERS' MULTI-ACADEMY TRUST, since 17 October 2022, in one identity, and a resigned director of REDTHREAD YOUTH LIMITED, appointed from 24 July 2019 to 31 July 2023, in a second identity.

20. David Cooper

Biography

David Cooper was appointed as Non-Executive Director at HMRC in May 2021, and is an experienced CIO and business transformation leader.

His previous role in Mitie, as the Chief Transformation and Technology Officer, saw him responsible for both the group technology function and the company shared services functions. Prior to that David was the Group CIO for Centrica and British Gas, driving efficiencies and new technology solutions.

Earlier career highlights, as a CIO, focused on the consolidation of IT systems and processes of several acquired companies for TalkTalk and being an early employee of mobile operator 3UK where he was Chief Operations and Technology Officer running customer service, retentions and debt management functions alongside his IT and technology role.

David holds a PhD in Physics, began his working life in research with BT and has facilitated connections between education and industry as a visiting professor at Royal Holloway University.

A search in Companies House for David Cooper returns hundreds of identities. too daunting a task to attempt now. He has not been a director of Mittie Limited. More information such as the month and year of his birth are required.

21. Jen Tippin

Biography

Jen is the Chief People and Transformation Officer for Natwest Group and a member of the Group Executive Committee. She is responsible for the people strategy and transformation plan as well as customer journeys, investment, property and supply chain services. Jen is passionate about inclusion and is the Executive Sponsor for ‘Rainbow’, the Group’s LGBTQ+ employee led network, and for wellbeing groupwide.

Before joining NatWest Group, Jen spent 15 years at Lloyds Banking Group. She was Group Director, People and Productivity responsible for HR, efficiency, sourcing, supply chain management and property. Before that, she was the Group Organisation Design and Cost Management Director, Group Customer Services Director and MD, Business Banking serving over a million small business customers. She has extensive experience running large scale business, customer and operational teams as well as leading significant transformational change.

Before working in financial services, she worked in the engineering and airline sectors.

Jen has significant board and committee chair experience. She has served on both private and public sector boards, including the NHS and charitable organisations.

She has three children.

A search for Jen Tippin in Companies House returns two identities for Jennifer Louise Tippin, with the same date of birth, September 1973.

Jennifer Louise TIPPIN identity 1

Total number of appointments 3 Date of birth September 1973

FINANCIAL SERVICES SKILLS COMMISSION LIMITED (12590553) Company status Active Correspondence address Natwest Group, 250 Bishopsgate, London, England, EC2M 4AA Role ACTIVE Director Appointed on 20 January 2022 Occupation Chief People And Transformation Officer

MORGAN SINDALL GROUP PLC (00521970) Company status Active Correspondence address Kent House, 14-17 Market Place, London, United Kingdom, W1W 8AJ Role ACTIVE Director Appointed on 1 March 2020 Occupation Group People And Productivity Director

LLOYDS BANK CORPORATE MARKETS PLC (10399850) Company status Active Correspondence address 25 Gresham Street, London, United Kingdom, EC2V 7HN Role RESIGNED Director Appointed on 14 March 2018 Resigned on 24 April 2020 Occupation Group People And Productivity Director

Jennifer Louise TIPPIN identity 2

Total number of appointments 1 Date of birth September 1973

NEW LONDON CHILDREN'S CHOIR LIMITED (02762287) Company status Active Correspondence address 225 Warren House, Beckford Close, London, W14 8TR Role RESIGNED Director Appointed on 12 May 2004 Resigned on 31 January 2011

Jen Tippin fails to declare in her biography her active directorships under identity 1 to Financial Services Skills Commission Limited, since 20 January 2022, and Morgan Sindall Group PLC, since 1 March 2020. She fails to include her directorship of New London Children’s Choir Limited from 12 May 2004 to 31 January 2011, held in her second identity, in her biography. She declares “Lloyds Banking Group” instead of Lloyds Bank Corporate Markets PLC, which is a material misstatement.

Non-Executive committee members

22. Elizabeth Fullerton-Rome

Biography

Elizabeth Fullerton-Rome is a Non-Executive Director of HMRC. She is also a Non-Executive Director of the Taxation Disciplinary Board and a Trustee and Treasurer of the Walpole Society. She has held senior positions at international financial services organisations and has extensive experience in strategy, audit, risk management, regulatory compliance, corporate governance and business transformation for large and complex groups.

A search of Elizabeth Fullerton-Rome in Companies House returns one identity with six appointments.

Elizabeth Roman FULLERTON-ROME

Total number of appointments 6 Date of birth September 1971

VOCALINK LIMITED (06119048) Company status Active Correspondence address 1 Angel Lane, London, United Kingdom, EC4R 3AB Role ACTIVE Director Appointed on 27 June 2022

HAMPDEN AGENCIES LIMITED (02970319) Company status Active Correspondence address 5th Floor, 40 Gracechurch Street, London, England, EC3V 0BT Role ACTIVE Director Appointed on 3 September 2020

GREAT AMERICAN INTERNATIONAL INSURANCE (UK) LIMITED (02714031) Company status Active Correspondence address 32 Queen Square, Bristol, England, BS1 4ND Role ACTIVE Director Appointed on 20 May 2020 Occupation Chartered Accountant

THE TAXATION DISCIPLINARY BOARD LIMITED (04210063) Company status Active Correspondence address 30 The Taxation Disciplinary Board Limited, Monck Street, London, England, SW1P 2AP Role RESIGNED Director Appointed on 1 June 2017 Resigned on 31 May 2023 Occupation Chartered Accountant

ARCH UNDERWRITING AT LLOYD'S LTD (06645822) Company status Liquidation Correspondence address SW11 Role RESIGNED Director Appointed on 15 October 2008 Resigned on 31 July 2014 Occupation Insurance Executive

ARCH EUROPE INSURANCE SERVICES LTD (06645619) Company status Active Correspondence address SW11 Role RESIGNED Director Appointed on 15 October 2008 Resigned on 31 July 2014 Occupation Insurance Executive

Elizabeth Fullerton-Rome has failed to record her active directorships of: VOCALINK LIMITED, since 27 June 2022; HAMPDEN AGENCIES LIMITED since 3 September 2020; and, GREAT AMERICAN INTERNATIONAL INSURANCE (UK) LIMITED since 20 May 2020.

Elizabeth Fullerton-Rome fails to disclose that she was a director of: ARCH UNDERWRITING AT LLOYD'S LTD from 15 October 2008 to 31 July 2014; and, ARCH EUROPE INSURANCE SERVICES LTD from 15 October 2008 to 31 July 2014.

Elizabeth Fullerton-Rome has failed to update her biography with her resignation of her directorship of THE TAXATION DISCIPLINARY BOARD LIMITED on 31 May 2023 .

23. Thomas Taylor

Biography

Tom is currently Chair of the NHS Counter Fraud Authority, a Non-Executive Board Member for the Northern Ireland Government Department of Finance (where he is Chair of NI Statistics & Research Agency Audit Committee and a Member of the Departmental Audit Committee) and a Non-Executive Director at the Department for Levelling Up, Housing and Communities. He is also an Independent Member of Her Majesty’s Revenue & Customs Audit Committee and a Board Mentor for Criticaleye Ltd.

From 2015 to 2018 Tom was Wales Chair for the Consumer Council for Water - the Consumer Watchdog for over three million residents of Wales and Herefordshire. From 2012 – 2018 Tom was a Non-Executive Director for the English Education Regulator the Office of Qualifications and Examinations Regulation (where he was Chair of the Finance Committee and a member of the Enforcement Committee).

He has worked in the energy, health, education, water, agriculture, environment, and manufacturing sectors of our economy. He has more than 32 years’ experience working at Board level in the public, private and third sectors as a Chair, Non-Executive Director, Chief Executive, Finance Director and Commercial Director.

He is a Fellow of the Chartered Institute of Certified Accountants, a Fellow of the Chartered Institute of Public Finance and Accountancy, a Fellow of the Institute of Directors, a Fellow of the Chartered Management Institute, and a Fellow of the Healthcare Finance Managers Association.

A search in Companies House for Thomas Taylor returns many identities with these common names. A search for Criticaleye Ltd returns three companies with this name; CRITICALEYE (EUROPE) LIMITED, CRITICALEYE INVESTMENTS PLC and CRITICALEYE MANAGEMENT LIMITED. Thomas Taylor is not appointed as a director of any of these companies. As a “Board Mentor for Criticaleye Limited” he may meet the definition of a shadow director and be required to register as such. This requires further clarification. There is insufficient information to determine whether or not Thomas Taylor has any identities in Companies House.

Summary

The biography and interests of 23 people listed in HMRC’s organisation chart were reviewed in Companies House and compared to their biographies on the Government website.

There is one officer who has not failed to declare their interests, and this is because they have no appointments in Companies House, (3.) Myrtle Lloyd – Director General Customer Services (Wellbeing Champion).

There are 6 officers for whom records could not be located in Companies House because their names occur frequently; their month and year of birth are required in order to be able to complete due diligence. These are:

• (11.) Joanna Rowland – Director General for Transformation - Income Tax Service Transformation (Carers Champion)

• (12.) Suzanne Newton – Director General for Transformation – Strategic Change

• (13.) Andrew Pemberton – Director of Communications (Sustainability Champion)

• (14.) Jonathan Russell – Chief Executive, Valuation Office Agency

• (18.) Paul Morton - HM Revenue and Customs non-executive director.

• (20.) David Cooper - Non-Executive Director at HMRC.

More information is required to determine the accuracy of these officers’ disclosures.

The following chart (Table 1) summarises these findings for the officers for whom identities were located in Companies House: Officials with multiple breaches are shown in red:

Both of the Permanent Secretaries responsible for HMRC fail to register interests:

• (1.) Jim Harra, active directorship of Revenue & Customs Digital Technology Services Limited.

• (2.) Angela MacDonald, resigned director of Aviva Pension Trustees UK Limited.

Six members of the Executive Committee fail to register interests:

• (5.) Jonathan Athow, active director of The Institute of Fiscal Studies,.

• (6.) Esther Wallington – Chief People Officer (Age and Gender Champion) Revenue & Customs Digital Technology Service, Wallington Street Tiles Limited, National Centre for Circus Arts, Circus Space Property Company Limited and Circus Space Events Limited. In addition, she has two identities in Companies House which compromise audits and due diligence associated to her.

• (7.) Justin Holliday – Chief Finance Officer, Tax Assurance Commissioner (Religion or Belief Champion) Revenue & Customs Digital Technology Services Limited. Query whether he is a related party to Justin Holliday at 666 Holdings.

• (8.) Daljit Rehal – Chief Digital and Information Officer Revenue & Customs Digital Technology Services Limited and a resigned director of Folio Education Trust, R Quadrant Limited, Paragon Analytical Services Ltd and Red Chip UK LTD. He has two identities. He was not a director of Centrica PLC as his declaration suggests.

• (9.) Alan Evans – General Counsel and Director General, Solicitor’s Office and Legal Services (LGBTI+ Champion) Saracens Multi-Academy Trust and member of Taylor Wessing Limited Liability Partnership.

• (10.) Carol Bristow – Director General Borders and Trade Design in Mental Health Network Limited and Design in Mental Health Limited.

Five Non-Executive Board members have failed to register interests:

• (15.) Dame Jayne-Anne Gadhia (Lead Non-Executive, and Chair of the HMRC Board) Twelve identities in Companies House, using two spellings of her surname. Active directorships: MFM Investment Ltd, MFM Holding Ltd, Jagash Ltd, Gadhiagroup Ltd and UniCredit S.P.A.. She incorrectly registered her company Usnoop Limited as “Snoop”. She has failed to declare too many past directorships to list.

• (16.) Michael Hearty (non-executive board member with responsibility for the Union) Query: MJRT Executive Ltd, dissolved; Building Schools for the Future Investments (BSFI) Limited and, Building Schools for the Future (Bristol) Limited. Clarification is sought.

• (17.) Juliette Scott Spellins Consulting Services Limited. Unconfirmed declaration “on the Board of eBay UK”.

• (19.) Patricia Gallan active director of Draper’s Multi-academy Trust, in one identity, and a resigned director of Redthread Youth Limited, in a second identity.

• (21.) Jen Tippin, two identities: active directorships under identity 1 to Financial Services Skills Commission Limited and Morgan Sindall Group PLC. Identity 2: Directorship of New London Children’s Choir Limited. She declares “Lloyds Banking Group” instead of Lloyds Bank Corporate Markets PLC.

Neither of the Non-Executive committee members are transparent.

• (22.) Elizabeth Fullerton-Rome Vocalink Limited, Hampden Agencies Limited and, Great American International Insurance (UK) Limited. Past director of: Arch Underwriting at Lloyd’s Ltd and, Arch Europe Insurance Services Ltd. Elizabeth Fullerton-Rome has failed to update her biography with her resignation of her directorship of The Taxation Disciplinary Board Limited.

• (23.) Thomas Taylor is not appointed as a director of any Criticaleye company, as his biography suggests, “Board Mentor for Criticaleye Limited” Is he a shadow director? Insufficient information to determine identities in Companies House.

A more detailed analysis of Revenue & Customs Digital Technology Services Limited, which is common to several officers, and the other undisclosed interests, is required. I plan to revisit these.

Conclusion

Based on the findings from the due diligence on officials at UK HM Revenue and Customs, it's evident that a significant number of key individuals within the organization have failed to properly register their interests and directorships. This non-disclosure of affiliations and identities raises serious concerns about transparency, compliance, and potential conflicts of interest among the top officials responsible for overseeing HMRC.

The failure to disclose active and resigned directorships, multiple identities in Companies House, incorrect or incomplete company registrations, and unclear declarations point towards potential lapses in ethical conduct and transparency within the leadership of HMRC.

These findings highlight the following key issues:

1. Non-disclosure of Directorships: Several officials hold directorships in various organisations but have not disclosed these affiliations properly.

2. Multiple Identities: Many officials have multiple identities registered in Companies House, leading to compromises in audits and due diligence processes.

3. Incomplete or Incorrect Declarations: Declarations of past directorships and affiliations are either insufficient or inaccurate, which raises questions about the integrity of these declarations.

4. Unclear or Unconfirmed Declarations: Some declarations lack clarity or cannot be confirmed, which adds to the lack of transparency surrounding the roles and affiliations of these officials.

In conclusion, the findings suggest a concerning lack of transparency and compliance among the leadership of HMRC. The failure to disclose affiliations, directorships, and multiple identities within Companies House presents a risk of conflicts of interest and compromises due diligence processes. Urgent action, including further investigation and appropriate corrective measures, such as resignations, is necessary to ensure the integrity, transparency, and ethical conduct of officials within HMRC. Immediate steps should be taken to rectify these issues and uphold the organisation's commitment to transparency and accountability.