JAC's Sarah Lee - multiple breaches
Synthetic identity fraud is a recently identified method of fraud.
22/6/2023
By email: complaints@judicialappointments.gov.uk
Complaints Manager
Judicial Appointments Commission
5th Floor, Clive House
70 Petty France
London, SW1H 9EX
Dear Complaints Manager,
I am writing to formally register a complaint regarding multiple breaches of ethical standards and omissions in the disclosure of directorship roles by Sarah Lee, a member of the Judicial Appointments Commission.
First I present her disclosures in the Register of Interest. Followed by her appointments as registered in Companies House. I then bring to your attention numbered points, each supported by specific records, demonstrating the breaches:
Sarah Lee's Register of Interests, registerofinterest-commissioners-2022-23-1.pdf (judicialappointments.gov.uk) reads: “Sarah Lee
• Partner at Slaughter and May –until 31 December 2020
• Non-Executive Director of the Financial Ombudsman Service –from 3 January 2021
• Non-Executive Director of The Independent Press Standards Organisation (IPSO) – from July 2021.
• Trustee and member of the Management Committee of the Royal Courts of Justice Legal Advice Bureau – until May 2019
• Governor of the Cripplegate Foundation – appointed October 2020”.
Her biography Sarah Lee – Judicial Appointments Commission Sarah Lee – Judicial Appointments Commission: “Sarah Lee was appointed to the Judicial Appointments Commission as a professional (solicitor) member on 9 April 2018 and reappointed on 9 April 2021.
Sarah qualified as a solicitor in 1990. She was appointed as a partner of Slaughter and May in 1999 and was Head of the Dispute Resolution Group and sat on the firm’s Partnership Board until May 2020; she retired as a partner in December 2020.
Her practice covered all aspects of major commercial disputes, often involving multiple jurisdictions.
Sarah is an accredited CEDR (Centre for Effective Dispute Accreditation) mediator, and is a Governor of the Cripplgate Foundation.
Sarah became a Non-Executive Director of the Financial Ombudsman Service in January 2021.”
registerofinterest-commissioners-2022-23-1.pdf (judicialappointments.gov.uk)
Sarah Lee's registration in Companies House, Sarah Tien Mee LEE personal appointments - Find and update company information - GOV.UK (company-information.service.gov.uk), active appointments are hsown in bold:
Sarah Tien Mee LEE
Current appointments 4
Total number of appointments 11
Date of birth December 1964
RARE RECRUITMENT LIMITED (05549110)
Company status Active
Correspondence address
8 Blackstock Mews, London, England, N4 2BT
Role ACTIVE Director
Appointed on 22 August 2022
Occupation Non Executive Director
INDEPENDENT PRESS STANDARDS ORGANISATION C.I.C. (02538908)
Company status Active
Correspondence address
Gate House, 1 Farringdon Street, London, EC4M 7LG
Role ACTIVE Director
Appointed on 1 July 2021
Occupation Lawyer
FINANCIAL OMBUDSMAN SERVICE LIMITED (03725015)
Company status Active
Correspondence address
Exchange Tower, Harbour Exchange Square, London, E14 9SR
Role ACTIVE Director
Appointed on 4 January 2021
Occupation Lawyer
CRIPPLEGATE FOUNDATION LIMITED (06129936)
Company status Active
Correspondence address
13 Elliotts Place, Islington, London, N1 8HX
Role ACTIVE Director
Appointed on 14 October 2020
THE RCJ AND ISLINGTON CITIZENS ADVICE BUREAUX (03110908)
Company status Active
Correspondence address
Slaughter And May, One Bunhill Row, London, United Kingdom, EC1Y 8YY
Role RESIGNED Director
Appointed on 16 May 2007
Resigned on 15 February 2019
TREXCO LIMITED (00461588)
Company status Active
Correspondence address
32 Noel Road, Islington, London, N1 8HA
Role RESIGNED Director
Appointed on 1 May 1999
Resigned on 15 December 2008
SLAUGHTER AND MAY SERVICES COMPANY (00785646)
Company status Active
Correspondence address
32 Noel Road, Islington, London, N1 8HA
Role RESIGNED Director
Appointed on 1 May 1999
Resigned on 15 December 2008
TRUSEC LIMITED (00463885)
Company status Active
Correspondence address
32 Noel Road, Islington, London, N1 8HA
Role RESIGNED Director
Appointed on 1 May 1999
Resigned on 15 December 2008
SLAUGHTER AND MAY TRUST LIMITED (00335458)
Company status Active
Correspondence address
32 Noel Road, Islington, London, N1 8HA
Role RESIGNED Director
Appointed on 1 May 1999
Resigned on 15 December 2008
TRUCIDATOR NOMINEES LIMITED (00278109)
Company status Active
Correspondence address
32 Noel Road, Islington, London, N1 8HA
Role RESIGNED Director
Appointed on 1 May 1999
Resigned on 15 December 2008
SLAUGHTER AND MAY LIMITED (00535683)
Company status Active
Correspondence address
32 Noel Road, Islington, London, N1 8HA
Role RESIGNED Director
Appointed on 1 May 1999
Resigned on 15 December 2008
Please investigate the following breaches:
1.Failure to declare Rare Recruitment Limited. Sarah Lee has not included her active appointment to RARE RECRUITMENT LIMITED, appointed 22 August 2022, in the Register of Interests. Please investigate why she has not registered this interest and what conflicts of interests it presents? The company website, which lists Sarah Lee as a non-executive director is located here: Rare | Leaders in diversity graduate recruitment. | About (rarerecruitment.co.uk). This omission raises further questions about her transparency and adherence to disclosure requirements.
2. Inconsistencies and inaccuracies in Ms Lee's Slaughter and May engagements. The register of interest states “Partner at Slaughter and May –until 31 December 2020” and the biography describes that “She was appointed as a partner of Slaughter and May in 1999 and was Head of the Dispute Resolution Group and sat on the firm’s Partnership Board until May 2020; she retired as a partner in December 2020.”
a) There is no Slaughter and May Partnership registered, with this name, in Companies House. To describe herself as a Partner of Slaughter and May from 1999, sitting on the firm's Partnership Board until May 2020 and retiring as a partner in December 2020 is not an accurate description of Ms Lee's directorship roles.
b) Ms Lee was a director of six Slaughter and May companies, to which she was appointed to all of these on 1 May 1999 and resigned on 15 December 2008. These being:
SLAUGHTER AND MAY SERVICES COMPANY
SLAUGHTER AND MAY TRUST LIMITED
SLAUGHTER AND MAY LIMITED
TREXCO LIMITED
TRUSEC LIMITED
TRUCIDATOR NOMINEES LIMITED.
I note that Slaughter and May do not appear to report as a group. Whether these companies should report as a Group is a query that should be raised with Slaughter and May. The persons with significant control of each company inaccurately described their relationships. A forensic audit of these companies accounts, would be a proportionate action, within the scope of the investigation into Ms Lee’s incomplete disclosures.
Ms Lee's biography on the Judicial Appointments Commission website fails to mention her directorship roles in several companies. Specifically, she served as a director in the following companies: The RCJ and Islington Citizens Advice Bureaux, Trexco Limited, Slaughter and May Services Company, Trusec Limited, Slaughter and May Trust Limited, Trucidator Nominees Limited, and Slaughter and May Limited. Ms Lee is not registered as a Partner of Slaughter and May as she claims. These omissions cast doubt on the transparency and integrity of her disclosures.
c) From 15 December 2008 to May and December 2020, there is no registration in Sarah Lee's name which would explain why she claims to have been a partner of Slaughter and May during this period. Please investigate Ms Lee's claim to be a partner of Slaughter and May from 15 December 2008 to May and December 2020, which are not substantiated by the record.
d) I tested the hypothesis that she acted as a director of a corporate identity, for example, as one of the corporate identities called Trusec Limited. There are several corporate identities registered with this name, however, these do not coincide with the dates under consideration. I note that one of the corporate identities of Trusec Limited is active in two companies, TRUCIDATOR LIMITED and INTERNATIONAL FINANCE FACILITY FOR IMMUNISATION COMPANY (05857343), appointed on 20 November 2014 TRUSEC LIMITED personal appointments - Find and update company information – GOV and has been a secretary of 44 companies with this identity. I request that this relationship be escalated for consideration by the ongoing public Inquiry regarding the Government's COVID-19 response. A duplicated corporate identity with this name is registered to a further 1468 companies, 7 of which are active, TRUSEC LIMITED personal appointments - Find and update company information - GOV.UK (company-information.service.gov.uk). The potential for conflicts of interest given this span of control raises further questions about Ms Lee's suitability to be appointed to the Joint.
3. Inaccurate use of Slaughter and May's name. Between 16 May 2007 and 15 February 2019 she was a director of The RCJ and Islington Citizens Advice Bureau and using Slaughter and May's name in the address. THE RCJ AND ISLINGTON CITIZENS ADVICE BUREAUX (03110908) Slaughter And May, One Bunhill Row, London, United Kingdom, EC1Y 8YY Appointed on 16 May 2007, resigned on 15 February 2019; This registration is using a legal name in an address which is an inappropriate use. The website for this company does not disclose the names of the directors and trustees , About us | RCJ advice. It provides three services; Civil Law, Family Law and Citizens Advice Islington. This breaches transparency requirements, an issue that should be raised with the company(ies).
4. Breach of Separation of Duties. When a director of the Judicial Appointments Committee simultaneously holds positions as a Non-Executive Director of the Financial Ombudsman Service and The Independent Press Standards Organisation (IPSO), it raises concerns about a potential breach of the principle of separation of duties. The arguments against this arrangement are as follows:
Conflict of Interest: The director's involvement in both the Judicial Appointments Committee and these external organizations can create conflicts of interest. The Judicial Appointments Committee is responsible for ensuring the impartiality and fairness of judicial appointments, while the Financial Ombudsman Service and IPSO deal with financial and press-related matters respectively. The director's dual roles may compromise their ability to act objectively and without bias.
Competing Priorities: Serving in multiple roles can result in competing priorities and divided attention. The director may face conflicting responsibilities, commitments, and loyalties, potentially compromising their ability to fulfil their duties effectively in each position. This situation may raise concerns about their ability to devote adequate time and attention to the specific responsibilities of the Judicial Appointments Committee.
Influence and Perception: The simultaneous presence of the director in these different roles can create a perception of undue influence or favouritism. It may raise questions about the director's ability to make unbiased decisions within the Judicial Appointments Committee, as their involvement in other organizations could potentially create conflicts or biases that could undermine the integrity of the committee's decision-making process.
Overall, the concern regarding the breach of separation of duties arises from the potential for conflicts of interest, divided attention, and the perception of compromised impartiality. Upholding the principle of separation of duties is essential to maintain the integrity, independence, and credibility of the Judicial Appointments Committee.
The issues with this record is not limited to the points I've raised. I am also concerned about the range of Slaughter and May companies, they are not all covered herein. Complex company structures present a high risk for breaching anti-money laundering and terrorism financing and request that you investigate potential breaches or request the appropriate authority to do so.
It is crucial to ensure that the investigation into my complaint is conducted by individuals who do not have multiple identities registered in Companies House themselves. I have observed and reported several breaches involving multiple identities within the investigative body, which raises concerns about potential biases or conflicts. Please extend this request to cover tall of the complaints that I have sent to you regarding breaches by Commissioners of the Judicial Appointment Committee.
Yours sincerely
Alison Wright.