Helen Pitcher fails to declare interests held by her multiple identities in Companies House
Progress Report: Synthetic identity fraud letter of complaint
Below is the letter of complaint that I sent to the Judicial Appointments Commission about Helen Pitcher: 1) concealment of interests in multiple identities and 2) her failure to register these interests. I allege that this meets the definition of fraud and should be investigated by the police to determine the size and scope of her, and complicit colleagues’, fraud. I have been in communication with the Complaints Manager. He has sought an independent opinion on this complaint and I am awaiting the outcome.
Over half the JAC Commissioners have multiple identities registered, as do an even higher proportion of Police and Crime Commissioners, the devil’s in this detail. My MP, Lloyd Russell-Moyle has 5 identities registered, one without a hyphen, so he's not interested in assisting me in addressing this issue. In my letters of complaint I've been calling for;
a police investigation,
all those with synthetic identities to resign,
update Audit Standards to include checking for synthetic identities,
a mandatory audit rotation for all eligible businesses registered in the UK, and,
flagging an identity that has undergone deduplication in Companies House.
If my allegation is upheld, then a precedent is set that holding multiple identities in Companies House is evidence of synthetic identity fraud. Then, those implicated by this breach of trust, in the public and private sectors, should resign whilst criminal investigations are undertaken. In this way transparency, accountability and the rule of law might flourish.
Letter of complaint sent 15/6/23
By email: complaints@judicialappointments.gov.uk
Complaints Manager
Judicial Appointments Commission
5th Floor, Clive House
70 Petty France
London, SW1H 9EX
Failure to register interests in the Register of Interests by Helen Pitcher
Dear Sir/Madam,
Helen Pitcher OBE Chair of the Judicial Appointments Commission has registered the following appointments (registerofinterest-commissioners-2022-23-1.pdf (judicialappointments.gov.uk)):
• Chairman - Advanced Boardroom Excellence Ltd
• Chairman - Criminal Cases Review Commission
• Non-Executive Director at UB UK and C & C Group Plc, Chairman of the Remuneration and Nominations Committee (stepping down 13/6/23)
• Senior Independent Director and Chairman of the Remuneration and Nominations Committees
• OneHealth Group Ltd
• Director Perast Paradise Properties
• Trusteeship and President of KidsOut (a National Children's Charity)
• Chairman - Public Chairs’ Forum
• IAA ExCo VP of Global Clubs
• C&C Group shares and securities
Her biography is given as: Helen Pitcher OBE is currently chair of the: Criminal Case Review Commission: the Public Chairs Forum and; Advanced Boardroom Excellence Ltd. Ms Pitcher holds two Non-Executive roles: C and C Group and; UB UK (part of Yildz Holdings). Prior to this Ms Pitcher was: Chairman of Pladis Global between 2015-19; the Queen’s Counsel Selection Panel between 2009-17 and; Director at Saville Group PLC between 2008-13 (New Chair of Judicial Appointments Commission appointed - GOV.UK (www.gov.uk).
Helen Pitcher has 5 identities registered in Companies House. Her active appointments are numbered. Those not appearing in the Register of Interests are highlighted in bold.
1.SUSTAINABLE BOARDROOM EXCELLENCE LIMITED (09342325) Role ACTIVE Director. Appointed on 5 December 2014.
2. ADVANCED BOARDROOM EXCELLENCE LIMITED (08552252) Role ACTIVE Director
Appointed on 31 May 2013.
3. BALANCE IN BUSINESS LIMITED (14739365) Role ACTIVE Director
Appointed on 17 March 2023.
4. KIDS OUT TRADING LIMITED (04366968) Role ACTIVE Director
Appointed on 30 December 2020
5. PERAST PARADISE PROPERTIES LTD (12815811) Role ACTIVE Director
Appointed on 16 August 2020
6. UNITED BISCUITS (UK) LIMITED (02506007) Role ACTIVE Director
Appointed on 1 November 2018
7. KIDS OUT UK (03636219) Role ACTIVE Director
Appointed on 1 January 2021
8. ONE HEALTH GROUP PLC (04201068) Role ACTIVE Director
Appointed on 30 September 2019
No active appointments in this identity.
Failure to register interests.
Acknowledging that UB UK, as in the Register of Interests, may be a reference to United Biscuits (UK) Limited, however it is ambiguous and this business should be referenced with the correct name. Helen Pitcher has failed to correctly register her directorships of: Sustainable Boardroom Excellence Limited, Balance in Business Limited, Kids Out Trading Limited, United Biscuits (UK) Limited and Kids out UK. As this is a breach of the code of conduct, please investigate this for misconduct.
Companies disclosed, but not registered in Companies House.
Helen Pitcher's current appointments to C&C Group PLC, IAA ExCo and Global Clubs, and her past appointments to Saville Group PLC and Pladis Global, could not be located in Companies House. The reference to VP Global Clubs is ambiguous and her appointment could not be located. None of these named companies are registered with these names in Companies House. There are similarly named companies registered but Helen Pitcher is not a named director of these. Please will you clarify the names of the companies to which she refers in her Register of Interest and biography? Under what name is she registered as a director?
Responsibilities of Companies House and Individuals in Addressing Synthetic Identities
Given the gravity of this matter, I have initiated communication with Companies House to gain a better understanding of the reasons behind the occurrence of these duplicate identities and to explore potential remedies.
Companies House serves as the registrar for companies in the UK, responsible for maintaining accurate records of company directors. Their de-duplication system analyses officer names, dates of birth, and usual residential addresses (URAs) to associate appointments with the same individual. If all criteria are not met and the information is deemed inconsistent, the appointments remain separate. (Source: Registrars Functions Caseworker, Companies House, 22 May 2023)
Synthetic identities emerge when different names, dates of birth, or usual residential addresses are submitted, causing the Companies House de-duplication system to fail in recognising that these identities belong to the same person.
Synthetic identities represent an undesired outcome, resulting from false non-match errors within the Companies House system. They are commonly known as "synthetic identities" in IT systems terminology.
Companies House, as the system administrator, bears a fundamental duty to actively monitor and minimise the creation of synthetic identities.
It is within the authority and duty of Companies House to de-duplicate these records and ensure the integrity of the system.
Synthetic identities pose a significant risk as they can be exploited to conceal interests during audits and due diligence checks conducted on appointments associated with the other identity/identities.
Companies House's failure to de-duplicate synthetic identities facilitates synthetic identity fraud, undermining the integrity of the system.
Individuals have a responsibility to provide accurate information and keep it up to date, ensuring the authenticity and reliability of the records.
If a synthetic identity is created in error, the director holds the duty to promptly correct the record and provide accurate information.
Failure to declare interests held in synthetic identities serves as evidence that the individual provided inaccurate information to register the synthetic identity, raising concerns about their compliance with disclosure requirements and potential attempts to conceal financial interests.
To address this a policy mandating an audit rotation and the disclosure of all identities by each company officer is recommended as a requirement. All personnel involved in audits and due diligence for anti-money laundering and counter-terrorism financing to receive training and certification in identifying synthetic identities and reporting them.
Please investigate my allegation that Helen Pitcher has used multiple identities, registered in Companies House, to conceal significant interests which she subsequently failed to declare. Failing to register all of her interests is a breach of the code and this is misconduct. Registering interests that are not correctly registered in Companies House is misleading and could mislead audits and anti-money laundering and counter-terrorism financing due diligence.
Yours sincerely,
Alison Wright.
I’d appreciate your support in raising this issue amongst family, friends and colleagues through sharing this article. Please use Companies House to do your own due diligence on the people holding positions of power in your area and write a letter of complaint if you find evidence of synthetic identity fraud. I’d welcome receiving a copy at alisonwright45@btinternet.com. If you write “Due diligence on [name]” in the subject, it’ll help me to keep track of the reports.
Complaint resubmitted today, with text below.
In explanation, I submitted this complaint before I'd worked out which section of the Companies Act was breached by having multiple identities. I was hindered in identifying Section 1082 (Unique identifiers) as I was using ChatGPT, thinking that it was referencing the law. However, ChatGPT was providing me with hyper-realistic text of the law, which OpenAI has admitted was "misinformation". This issue has still not been corrected.
Now, I need to go back through my complaints, prior to finding Section 1082 which requires "Unique Identifiers" and resubmit them.
First is the Judicial Appointments Commission:
"Dear Ms. Barling and Mr. Thomson,
Thank you for your response regarding my concerns about the declarations of interests by Commissioners of the Judicial Appointments Commission (JAC).
I wish to bring to your attention a specific legal breach that has significant implications: Section 1082 of the Companies Act mandates the use of unique identifiers for individuals involved in company records. The presence of multiple identities for over half the Board members constitutes a breach of this section. This situation compromises the integrity of accounts and KYC processes, obstructs proper audits, and increases risks related to financial misconduct.
Furthermore, this breach directly contravenes several Nolan Principles:
1. Integrity: Multiple identities obscure transparency and accountability, potentially allowing individuals to evade scrutiny and influence decisions improperly.
2. Accountability: The lack of unique identifiers hinders effective oversight and accountability, as it becomes challenging to trace individuals' actions and responsibilities accurately.
3. Openness: Transparency is compromised when individuals can operate under multiple identities, which may conceal conflicts of interest or undisclosed relationships.
4. Honesty: The existence of multiple identities raises questions about the accuracy and truthfulness of declarations made by Commissioners.
Given these breaches, I urge the JAC to reconsider its stance on this matter. Addressing these issues is crucial for maintaining public trust and ensuring that the Commission operates in accordance with legal requirements and ethical standards.
I appreciate your attention to this matter and look forward to your response.
Sincerely,
Alison Wright"