Lord Mandelson Compliance Assessment
A public‑record analysis of Lord Mandelson’s undeclared directorships, fragmented identities and high‑risk networks under the House of Lords Code of Conduct
Compliance assessment of Lord Mandelson’s House of Lords Register of Interests
Prepared by Alison Wright, with analytic and drafting support from Perplexity AI, 1 March 2026 to 12 March 2026.
0. Index
1. Executive summary.
2. Scope, method and sources.
3. Overview of Lord Mandelson’s Register of Interests.
4. Companies House records for Peter Mandelson.
4a. Lord Peter Benjamin MANDELSON born October 1953, identity 1.
4b. Peter MANDELSON born October 1953, identity 2.
4c. Peter Benjamin MANDELSON born October 1953, identity 3.
4d. Peter MANDELSON born May 1963, identity 4.
5. Analysis: Exception report category 1 directorships.
6. Oplyse Holdings / Bank of London.
6a. Bank of London.
6b. The Bank of London Group Limited.
6c. Oplyse Holdings Limited.
6d. Compliance Finding – Oplyse Holdings Limited and “Bank of London”.
7. The Design Museum.
8. Global Counsel companies.
8a. Global Counsel Ventures Ltd.
8b. Global Counsel Ltd.
8c. Global Counsel Consulting LLP.
8d. Interpath Ltd.
9. Global Ports Holding – LLP vs Ltd.
9a. Global Ports Holding Limited Related Party: “Mha Macintyre Hudson”.
10. Sistema.
11. Great Britain-China Centre (The).
11a. Mandelson’s GBCC role and Companies House.
11b. Victoria Prentis and GBCC.
11c. Compliance / governance assessment.
12. Category 4: Shareholdings (b).
12 i. Global Counsel Advisory Ltd.
12 ii Moon Active Ltd category 4b shareholder declaration.
12 iii. SeeTrue Ltd.
12 iv. BlueVoyant.
13. Open Britain Ltd.
14. Willbury Limited, Category 1: Directorships.
14a. Willbury Limited.
14b. Reinaldo AVILA DA SILVA.
14c. The Nurture Centre.
14d. The Care Collective Group Ltd.
15. Directorship registered in Brazil.
16. Peter Mandelson born May 1963.
17. Summary of Breaches and Red Flags.
18. Possible statutory offences by associated entities
19. How these findings sit against the Lords Code of Conduct.
20. Limitations and further work.
Appendix A: Lord Mandelson’s House of Lords Register of Interests on 1 March 2026.
Appendix B: Andrew Peter Diggles of Open Britain Limited.
Appendix C: Officers of The Nurture Centre, Company number 07171364.
Appendix D: Report made to Serious Fraud Office relating to Willbury Limited.
1. Executive summary
This report compares Lord Peter Mandelson’s House of Lords Register of Interests with Companies House, Charity Commission and other public records, and identifies multiple transparency and governance failures that materially weaken KYC, audit and conflict‑of‑interest checks. This report is based solely on public‑record material available up to 8 March 2026. The Cabinet Office/FCDO material released to Parliament in HC 1774‑I (Volume I) will be considered in a separate analysis.
Key findings:
Lord Mandelson appears under three separate Companies House officer identities (all October 1953), plus a fourth “Peter Mandelson” (May 1963) whose company, Nation Systems Ltd, was dissolved without filing accounts, undermining the expectation that individuals are uniquely identifiable on the register.
Several Companies Act directorships do not appear as such in the Lords register or are mis‑described: Oplyse Holdings Ltd (Bank of London holding company), The Design Museum, Global Counsel Ventures Ltd, and Global Ports Holding Limited (named as an LLP/plc mismatch).
He holds or has held shareholdings and roles in high‑risk overseas‑controlled structures (Sistema, SeeTrue, BlueVoyant, Moon Active) whose UK vehicles show defective or circular PSC records and clone‑risk naming, while his Lords entries often omit jurisdictions or precise legal entity names.
His long presidency of the Great Britain–China Centre, combined with Victoria Prentis’s undeclared GBCC directorship under a second identity, creates a blind spot in standard officer‑based KYC and conflict checks around a significant China‑facing influence vehicle.
The “Nurture Centre” care ecosystem (dormant company and charity at Ingoldsby plus active Care Collective Group Ltd trading as “The Nurture Centre | Inspire and Empower” in Sheffield) shows clone‑style branding, zero‑income defaulting charities, and directors with multiple officer identities, all in services for vulnerable children and adults; Lord Mandelson’s Willbury co‑director sits on the dormant Nurture Centre boards.
Audit and corporate‑service intermediaries in his network (notably MHA MacIntyre Hudson and Blick Rothenberg) exhibit their own clusters of overlapping entities, name variants and known regulatory sanctions, further elevating risk wherever they intersect with his roles.
He also appears in a Brazilian corporate registration as “PETER BENJAMIN MANDELSON”, a sócio of R Avila Empreendimentos Imobiliarios Sociedade Simples Limitada alongside his UK Willbury co‑director Reinaldo Avila da Silva, with no corresponding declaration in his Lords Register.
The report does not allege specific criminal offences but concludes that there are strong, documentable grounds to suspect breaches of the Lords Code of Conduct, non‑compliance with Companies Act PSC and filing duties in associated entities, and structural patterns consistent with high‑risk typologies for sanctions evasion, foreign influence, identity fraud and potential exploitation. It recommends formal investigation by the House of Lords Commissioner for Standards, targeted regulatory scrutiny of named entities, and compelled disclosure of underlying documentation to test these public‑record findings.
2. Scope, method and sources
This assessment examines Lord Peter Mandelson’s compliance with the House of Lords Code of Conduct by comparing his declared interests with public‑record evidence of his corporate and charitable roles. The scope is limited to interests that are (i) recorded in Companies House or equivalent public registers and (ii) plausibly in scope of the Lords register categories for directorships, shareholdings, paid roles and significant non‑financial interests.
The analysis proceeds in four main steps:
First, all officer identities for “Peter Mandelson” were identified on Companies House, including three October 1953 records and one May 1963 record, and their appointments were extracted in full.
Second, these appointments were compared, on a role‑by‑role basis, with Lord Mandelson’s entries in the Lords Register of Interests (Appendix A), to identify undeclared or mis‑described directorships, shareholdings and advisory positions.
Third, selected high‑risk entities (Oplyse Holdings/Bank of London, AFK Sistema, SeeTrue, BlueVoyant, Moon Active, Great Britain–China Centre, Open Britain, MHA MacIntyre Hudson/Blick Rothenberg structures, and the Nurture Centre / Care Collective ecosystem) were reviewed in more depth via their Companies House and, where relevant, Charity Commission filings, including PSC registers, filing histories and accounts.
Fourth, the observed patterns (multiple officer identities, PSC gaps, clone‑style naming, late or missing accounts, and governance links into sensitive sectors) were assessed against relevant provisions of the Companies Act 2006, the Lords Code of Conduct and known KYC/compliance risk indicators.
All findings are derived from open sources:
House of Lords Register of Interests: Lord Mandelson’s full register entries since his introduction to the Lords, copied in Appendix A.
Companies House: officer appointments, company overviews, filing histories and PSC registers (e.g. Oplyse Holdings Ltd 10511092; The Bank of London Group Ltd 12844788; Global Counsel entities; AFK Sistema‑related UK names; MHA MacIntyre Hudson group companies).
Charity Commission: the Great Britain–China Centre (01196043/charity 270742), The Nurture Centre charity (1140388) and other relevant charities.
OpenCorporates and comparable registries: for cross‑border structures such as AFK Sistema, SeeTrue/Seetrue Screening, Moon Active and BlueVoyant.
No confidential banking data, tax records, internal board documents or law‑enforcement intelligence have been accessed. The report therefore offers an evidence‑based risk and compliance analysis grounded in public filings; it does not purport to prove the flow of funds or criminal intent, which can only be established by authorities with access to non‑public material and investigative powers.
3. Overview of Lord Mandelson’s Register of Interests
Lord Peter Mandelson’s Register of Interests, as published on the UK Parliament website, records his financial and non‑financial interests from his introduction to the House of Lords in 2008 up to his recent resignation and leave of absence. The current and historic entries (including amendments and deletions) can be viewed under “Register of Interests – Members of the House of Lords” by searching for “Peter Mandelson” and selecting “Show amendments”, at: https://members.parliament.uk/members/lords/interests/register-of-lords-interests?SearchTerm=Peter+Mandelson&ShowAmendments=True. I accessed and copied Lord Mandelson’s Register of Interests, including all then‑visible amendments, on 1 March 2026; the same level of detail (with amendments) was no longer available on the parliamentary website on 7 March 2026.
Appendix A reproduces Lord Mandelson’s full Lords Register of Interests (including amendments) and provides the baseline against which this report compares Companies House, Charity Commission and overseas‑registry records, in order to identify specific directorships. In Appendix A he declares, under Category 1 (directorships and paid offices), directorships of Willbury Limited (trading entity for member’s public speaking/writing; remuneration for work listed in category 2 is paid to Willbury Limited where indicated), Sistema (diversified holding company), Global Counsel Ltd (strategic advice consultancy), Global Ports Holding plc (international ports operator) and Bank of London (fintech startup). Under Category 2 (remunerated employment, office, profession etc.) he declares remuneration from multiple speaking engagements (with fees paid to Willbury Limited where stated), and roles with Lazard (international financial advisory firm), Sapinda Advisory Board (asset management fund) and Rokos Capital Management LLP (investment management firm).
He further declares, under the PSC section of the register, that he is a person with significant control in Willbury Limited, Global Counsel Ltd and Global Counsel Consulting LLP. Under Category 4(b) (shareholdings) he registers holdings in Sistema (diversified holding company), Global Counsel Advisory Ltd (financial advisory firm), SeeTrue Ltd (AI technology), BlueVoyant (cybersecurity services firm) and Moon Active Ltd (game app developer). Under Category 10 (non‑financial interests) he declares roles with The Design Museum, Policy Network, Britain Stronger in Europe, Open Britain Ltd, the Great Britain–China Centre, Hartlepool United FC, the Alfred Herrhausen Society (the international forum of Deutsche Bank, Berlin), the German British Forum and the Ditchley Foundation.
4. Companies House records for Peter Mandelson
A search in Companies House on the name Peter Mandelson returns four identities with this name, refer to the image of Companies House search results on “Peter Mandelson”, the results are copied below:
The results are copied below, with links:
“Peter MANDELSON
Total number of appointments 1 - Born May 1963
62a, Robin Hood Lane, Sutton, Surrey, United Kingdom, SM1 2RG
Lord Peter Benjamin MANDELSON
Total number of appointments 9 - Born October 1953
6th Floor, 2 London Wall Place, London, England, EC2Y 5AU
Peter MANDELSON
Total number of appointments 2 - Born October 1953
80 Archel Road, London, W14 9QP
Peter Benjamin MANDELSON
Total number of appointments 4 - Born October 1953
30 Hutton Avenue, Hartlepool, Cleveland, TS26 9PN”
Peter Mandelson, born October 1953, appears on Companies House under three separate officer identifiers, which complicates any audit or due‑diligence work relating to him. A fourth officer record exists for a Peter Mandelson born May 1963, whose appointments are also examined in this report.
The appointments attached to each of these identifiers, are reproduced from Companies House below, with minor formatting changes for readability. The identities with Lord Mandelson’s date of birth, October 1953, are considered first. Under Section 1082 of the Companies Act 2006, an individual should be uniquely identifiable on the register, and audit and KYC systems depend on that uniqueness when assessing risk and mapping related‑party relationships.
4a. Lord Peter Benjamin MANDELSON born October 1953, identity 1:
“Peter Benjamin MANDELSON
Total number of appointments 9
Date of birth October 1953
GLOBAL COUNSEL CONSULTING LLP (OC359787)
Company status Dissolved
Correspondence address 6th Floor, 2 London Wall Place, London, England, EC2Y 5AU
Role LLP Designated Member
Appointed on 7 December 2010
Country of residence United Kingdom
Company status Active
Correspondence address 6th Floor, 2 London Wall Place, London, England, EC2Y 5AU
Role Active Director
Appointed on 15 June 2010
Nationality British
Country of residence United Kingdom
Identity verification due 9 June 2026
DITCHLEY FOUNDATION(THE) (00599389)
Company status Active
Correspondence address Ditchley Park, Enstone, Chipping Norton, Oxfordshire, OX7 4ER
Role Resigned Director
Appointed on 6 July 2019
Resigned on 5 February 2025
Nationality British
Country of residence United Kingdom
OPLYSE HOLDINGS LIMITED (10511092)
Company status Active
Correspondence address 100 Bishopsgate, Bishopsgate, London, England, EC2N 4AG
Role Resigned Director
Appointed on 1 November 2021
Resigned on 4 October 2024
Nationality British
Country of residence United Kingdom
Company status Active
Correspondence address 5 Welbeck Street, London, England, W1G 9YQ
Role Resigned Director
Appointed on 20 December 2016
Resigned on 7 May 2024
Nationality British
Country of residence United Kingdom
Company status Active
Correspondence address 224-238, Kensington High Street, London, United Kingdom, W8 6AG
Role Resigned Director
Appointed on 15 March 2017
Resigned on 11 July 2023
Nationality British
Country of residence United Kingdom
GLOBAL COUNSEL VENTURES LTD (13858000)
Company status Active
Correspondence address 5 Welbeck Street, London, United Kingdom, W1G 9YG
Role Resigned Director
Appointed on 19 January 2022
Resigned on 16 December 2022
Nationality British
Country of residence United Kingdom
GLOBAL PORTS HOLDING LIMITED (10629250)
Company status Active
Correspondence address Mha Macintyre Hudson, New Bridge Street House, 30-34 New Bridge Street, London, United Kingdom
Role Resigned Director
Appointed on 12 April 2017
Resigned on 29 September 2021
Nationality British
Country of residence United Kingdom
OPEN BRITAIN LIMITED (09641190)
Company status Active
Correspondence address House Of Lords, London, United Kingdom, SW1A 0PW
Role Resigned Director
Appointed on 22 February 2016
Resigned on 12 November 2019
Nationality British
Country of residence United Kingdom”
4b. Peter MANDELSON born October 1953, identity 2
“Peter MANDELSON
Total number of appointments 2
Date of birth October 1953
POLICY NETWORK AND COMMUNICATIONS LTD (03918992)
Company status Dissolved
Correspondence address 80 Archel Road, London, W14 9QP
Role Resigned Director
Appointed on 2 November 2001
Resigned on 13 October 2004
Nationality British
THE&PARTNERS LONDON LIMITED (04161889)
Company status Active
Correspondence address 80 Archel Road, London, W14 9QP
Role Resigned Director
Appointed on 7 March 2002
Resigned on 31 July 2004
Nationality British”
4c. Peter Benjamin MANDELSON born October 1953, identity 3
“Peter Benjamin MANDELSON
Total number of appointments 4
Date of birth October 1953
UNITED KINGDOM - JAPAN 21ST CENTURY GROUP (02042768)
Company status Active
Correspondence address 30 Hutton Avenue, Hartlepool, Cleveland, TS26 9PN
Role Resigned Director
Appointed on 16 July 2001
Resigned on 1 November 2004
Nationality British
TEES VALLEY REGENERATION LIMITED (04407437)
Company status Dissolved
Correspondence address 30 Hutton Avenue, Hartlepool, Cleveland, TS26 9PN
Role Resigned Director
Appointed on 9 May 2002
Resigned on 10 August 2004
Nationality British
ENGLISH NATIONAL BALLET (00735040)
Company status Active
Correspondence address Flat 3, 18/21 Wilmington Square, London, WC1X 0ER
Role Resigned Director
Appointed on 26 July 1995
Resigned on 6 June 1997
Nationality British
18-21 WILMINGTON SQUARE MANAGEMENT LIMITED (01626789)
Company status Active
Correspondence address Flat 3, 18/21 Wilmington Square, London, WC1X 0ER
Role Resigned Director
Appointed on 12 May 1994
Resigned on 28 February 1997
Nationality British”
4d. Peter MANDELSON born May 1963, identity 4
“Peter MANDELSON
Total number of appointments 1
Date of birth May 1963
Company status Dissolved
Correspondence address 62a, Robin Hood Lane, Sutton, Surrey, United Kingdom, SM1 2RG
Role Director
Appointed on 4 November 2008
Nationality British”
Summary of Companies House records for “Peter Mandelson”
Search results show four officer identities named Peter Mandelson on Companies House:
Lord Peter Benjamin MANDELSON; 9 appointments; born October 1953; 6th Floor, 2 London Wall Place, London, EC2Y 5AU; officer link: https://find-and-update.company-information.service.gov.uk/officers/IsdfjGURML-16W9xNVww4qTyNxc/appointments
Peter MANDELSON; 2 appointments; born October 1953; 80 Archel Road, London, W14 9QP; officer link: https://find-and-update.company-information.service.gov.uk/officers/z_SPMDwpDcFSZEHY3bEZB6qVafc/appointments
Peter Benjamin MANDELSON; 4 appointments; born October 1953; 30 Hutton Avenue, Hartlepool, TS26 9PN; officer link: https://find-and-update.company-information.service.gov.uk/officers/whVGe4_CXfnf9Wk3b3qsoUjzbvU/appointments
Peter MANDELSON; 1 appointment; born May 1963; 62a Robin Hood Lane, Sutton, Surrey, SM1 2RG; officer link: https://find-and-update.company-information.service.gov.uk/officers/Nt0HFBPXlKwzsvPQaiyewQesH5c/appointments
Peter Mandelson – October 1953 – identity 1 (Lord Peter Benjamin Mandelson, 9 appointments):
GLOBAL COUNSEL CONSULTING LLP (OC359787); dissolved; LLP Designated Member; appointed 7 Dec 2010; correspondence: 6th Floor, 2 London Wall Place, London, EC2Y 5AU; company link: https://find-and-update.company-information.service.gov.uk/company/OC359787
WILLBURY LIMITED (07265891); active; Director; appointed 15 Jun 2010; correspondence: 6th Floor, 2 London Wall Place, London, EC2Y 5AU; identity verification due 9 Jun 2026; company link: https://find-and-update.company-information.service.gov.uk/company/07265891
DITCHLEY FOUNDATION (THE) (00599389); active; Resigned Director; appointed 6 Jul 2019; resigned 5 Feb 2025; correspondence: Ditchley Park, Enstone, Chipping Norton, OX7 4ER; company link: https://find-and-update.company-information.service.gov.uk/company/00599389
OPLYSE HOLDINGS LIMITED (10511092); active; Resigned Director; appointed 1 Nov 2021; resigned 4 Oct 2024; correspondence: 100 Bishopsgate, London, EC2N 4AG; company link: https://find-and-update.company-information.service.gov.uk/company/10511092
GLOBAL COUNSEL LTD (10533767); active; Resigned Director; appointed 20 Dec 2016; resigned 7 May 2024; correspondence: 5 Welbeck Street, London, W1G 9YQ; company link: https://find-and-update.company-information.service.gov.uk/company/10533767
THE DESIGN MUSEUM (02325092); active; Resigned Director; appointed 15 Mar 2017; resigned 11 Jul 2023; correspondence: 224–238 Kensington High Street, London, W8 6AG; company link: https://find-and-update.company-information.service.gov.uk/company/02325092
GLOBAL COUNSEL VENTURES LTD (13858000); active; Resigned Director; appointed 19 Jan 2022; resigned 16 Dec 2022; correspondence: 5 Welbeck Street, London, W1G 9YG; company link: https://find-and-update.company-information.service.gov.uk/company/13858000
GLOBAL PORTS HOLDING LIMITED (10629250); active; Resigned Director; appointed 12 Apr 2017; resigned 29 Sep 2021; correspondence: MHA MacIntyre Hudson, New Bridge Street House, 30–34 New Bridge Street, London; company link: https://find-and-update.company-information.service.gov.uk/company/10629250
OPEN BRITAIN LIMITED (09641190); active; Resigned Director; appointed 22 Feb 2016; resigned 12 Nov 2019; correspondence: House of Lords, London, SW1A 0PW; company link: https://find-and-update.company-information.service.gov.uk/company/09641190
Peter Mandelson – October 1953 – identity 2 (Peter MANDELSON, 2 appointments):
POLICY NETWORK AND COMMUNICATIONS LTD (03918992); dissolved; Resigned Director; appointed 2 Nov 2001; resigned 13 Oct 2004; correspondence: 80 Archel Road, London, W14 9QP; company link: https://find-and-update.company-information.service.gov.uk/company/03918992
THE&PARTNERS LONDON LIMITED (04161889); active; Resigned Director; appointed 7 Mar 2002; resigned 31 Jul 2004; correspondence: 80 Archel Road, London, W14 9QP; company link: https://find-and-update.company-information.service.gov.uk/company/04161889
Peter Mandelson – October 1953 – identity 3 (Peter Benjamin MANDELSON, 4 appointments):
UNITED KINGDOM - JAPAN 21ST CENTURY GROUP (02042768); active; Resigned Director; appointed 16 Jul 2001; resigned 1 Nov 2004; correspondence: 30 Hutton Avenue, Hartlepool, TS26 9PN; company link: https://find-and-update.company-information.service.gov.uk/company/02042768
TEES VALLEY REGENERATION LIMITED (04407437); dissolved; Resigned Director; appointed 9 May 2002; resigned 10 Aug 2004; correspondence: 30 Hutton Avenue, Hartlepool, TS26 9PN; company link: https://find-and-update.company-information.service.gov.uk/company/04407437
ENGLISH NATIONAL BALLET (00735040); active; Resigned Director; appointed 26 Jul 1995; resigned 6 Jun 1997; correspondence: Flat 3, 18/21 Wilmington Square, London, WC1X 0ER; company link: https://find-and-update.company-information.service.gov.uk/company/00735040
18-21 WILMINGTON SQUARE MANAGEMENT LIMITED (01626789); active; Resigned Director; appointed 12 May 1994; resigned 28 Feb 1997; correspondence: Flat 3, 18/21 Wilmington Square, London, WC1X 0ER; company link: https://find-and-update.company-information.service.gov.uk/company/01626789
Peter Mandelson – May 1963 – identity 4 (Peter MANDELSON, 1 appointment):
NATION SYSTEMS LTD (06740381); dissolved; Director; appointed 4 Nov 2008; correspondence: 62a Robin Hood Lane, Sutton, Surrey, SM1 2RG; company link: https://find-and-update.company-information.service.gov.uk/company/06740381; officer link: https://find-and-update.company-information.service.gov.uk/officers/Nt0HFBPXlKwzsvPQaiyewQesH5c/appointments
5. Analysis: Exception report category 1 directorships
I manually compared Lord Mandelson’s declarations in his Lords Register of Interests (Appendix A) with his Companies House records in a side-by-side analysis, visual review. This exception report lists roles that appear in Companies House but not in the Register, and declared interests in the Register for which no matching company records could be located.
There are no entries category 1 (directorships) declarations, in the Register of Interests, that correspond to the following directorships registered in Companies House:
Oplyse Holdings Limited, appointed 1 November 2021 and resigned 4 October 2024;
The Design Museum (Companies House company 02325092), appointed 15 March 2017 and resigned 11 July 2023;
Global Counsel Ventures Ltd, appointed 19 January 2022 and resigned 16 December 2022; or
Global Ports Holding Limited, appointed 12 April 2017 and resigned 29 September 2021, which is instead described in the Register as “Global Ports Holding LLP”.
Conversely, I was unable to locate company records in Companies House that clearly support the following Lords Register declarations:
“Non‑executive Director, Sistema (diversified holding company) (interest ceased 30 June 2017) (originally added 20 July 2013)”;
“Non‑executive Director, Bank of London (fintech startup) (interest ceased 23 December 2024) (originally added 2 December 2021)”.
These findings are analysed in the following sections.
6. Oplyse Holdings / Bank of London
A search in Companies House for companies called “Bank Of London” returns three records that include this name, Company search results (https://find-and-update.company-information.service.gov.uk/search/companies?q=Bank%20of%20London):
RC000043”
“THE BANK OF LONDON GROUP LIMITED
12844788 - Incorporated on 28 August 2020
77 Cornhill, London, England, EC3V 3QQ”
Matching previous names:
THE BANK OF LONDON GROUP HOLDINGS LIMITED10511092 - Incorporated on 5 December 2016
77 Cornhill, London, England, EC3V 3QQ”
The overview records for these three companies are copied below, from Companies House.
6a. Bank of London
BANK OF LONDON overview (https://find-and-update.company-information.service.gov.uk/company/RC000043)
“BANK OF LONDON
Company number RC000043
Company type
Royal Charter company”
No filings or further records for this company are available. No date is registered of when Bank of London opened, this is very unusual.
6b. The Bank of London Group Limited
THE BANK OF LONDON GROUP LIMITED overview (https://find-and-update.company-information.service.gov.uk/company/12844788)
“THE BANK OF LONDON GROUP LIMITED
Company number 12844788
Follow this company File for this company
Registered office address 77 Cornhill, London, England, EC3V 3QQ
Company status Active
Company type Private limited Company
Incorporated on 28 August 2020
Accounts
Next accounts made up to 31 December 2025 due by 30 September 2026
Last accounts made up to 31 December 2024
Confirmation statement
Next statement date 11 November 2026 due by 25 November 2026
Last statement dated 11 November 2025
Nature of business (SIC)
64191 - Banks
Previous company names
NamePeriodTBOL UK HOLDINGS LIMITED28 Aug 2020 - 08 Nov 2021”
Lord Mandelson is not listed as an officer of The Bank of London Group Limited, People.
The record of Person with significant control of The Bank of London Group Limited, THE BANK OF LONDON GROUP LIMITED persons with significant control (https://find-and-update.company-information.service.gov.uk/company/12844788/persons-with-significant-control) is:
“THE BANK OF LONDON GROUP LIMITED
Company number 12844788
1 active person with significant control / 0 active statements
Oplyse Holdings Limited Active
Correspondence address 77 Cornhill, London, England, EC3V 3QQ
Notified on 28 August 2020
Governing law Companies Act 2006
Legal form Private Company Limited By Shares
Place registered Uk Register Of Companies
Registration number 10511092
Incorporated in United Kingdom
Nature of control Ownership of shares – 75% or more Ownership of voting rights - 75% or more Right to appoint or remove directors”
Oplyse Holdings is the person with significant control of The Bank of London Group Limited with 75% shares and voting rights (formerly called TBOL UK Holdings Limited).
6c. Oplyse Holdings Limited
“OPLYSE HOLDINGS LIMITED
Company number 10511092
Follow this company File for this company
Registered office address 77 Cornhill, London, England, EC3V 3QQ
Company status Active
Company type Private limited Company
Incorporated on 5 December 2016
Accounts overdue
Next accounts made up to 30 December 2024 due by 30 December 2025
Last accounts made up to 31 December 2023
Confirmation statement
Next statement date 24 November 2026 due by 8 December 2026
Last statement dated 24 November 2025
Nature of business (SIC)
64205 - Activities of financial services holding companies
Previous company names
NamePeriodTHE BANK OF LONDON GROUP HOLDINGS LIMITED12 Oct 2022 - 11 Mar 2025TBOL LIMITED25 Apr 2018 - 12 Oct 2022TBOL PLC08 Nov 2017 - 25 Apr 2018UPHOLD GROUP PLC05 Dec 2016 - 08 Nov 2017”
The person with significant control of Oplyse Holdings Limited is copied below, OPLYSE HOLDINGS LIMITED persons with significant control (https://find-and-update.company-information.service.gov.uk/company/10511092/persons-with-significant-control)
“0 active persons with significant control / 1 active statement
Statement Active
The company knows or has reasonable cause to believe that there is no registrable person or registrable relevant legal entity in relation to the company
Notified on 18 April 2025
Mr Anthony George Watson Ceased
Correspondence address 77 Cornhill, London, England, EC3V 3QQ
Notified on 5 December 2016
Ceased on 17 April 2025
Date of birth October 1976
Nationality English
Country of residence United Kingdom
Nature of control Ownership of shares – More than 25% but not more than 50%
Diane Elizabeth Gray-Smith Ceased
Correspondence address Suite A, 6 Honduras Street, London, United Kingdom, EC1Y 0TH
Notified on 5 December 2016
Ceased on 5 December 2016
Date of birth October 1964
Nationality Australian,British
Country of residence England
Nature of control Right to appoint or remove directors”
There is no person or legal entity with significant control of Oplyse Holdings Limited, registered in Companies House.
The most recent accounts for Oplyse Holdings Limited were accessed via the Filing History (https://find-and-update.company-information.service.gov.uk/company/10511092/filing-history). The Annual Report and Financial Statements for Oplyse Holdings Limited (formerly The Bank of London Group Holdings Limited) for the year ended 31 December 2023 state (on page 12):
“5. Events after the reporting period
Group & Holdings Corporation Limited (originally named TBOL Group & Holdings Corporation Limited), a company incorporated in Jersey on 1 November 2023, became the immediate and ultimate parent company on 2 May 2024.”
It appears that Oplyse Holdings Limited have failed to update Companies House with details of the person of significant control to reflect that Fellesskap Group & Holdings Corporation Limited (originally named TBOL Group & Holdings Corporation Limited), a company incorporated in Jersey on 1 November 2023, became the immediate and ultimate parent company on 2 May 2024.
6d. Compliance Finding – Oplyse Holdings Limited and “Bank of London”
Structure and roles
Companies House records Lord Peter Benjamin Mandelson as a director of Oplyse Holdings Limited (10511092) from 1 November 2021 to 4 October 2024.
Oplyse Holdings Limited is an active private company (SIC 64205 – activities of financial services holding companies), previously named UPHOLD GROUP PLC, TBOL PLC, TBOL LIMITED, and THE BANK OF LONDON GROUP HOLDINGS LIMITED.
The Bank of London Group Limited (12844788) is an active private limited company (SIC 64191 – banks), incorporated 28 August 2020, whose only recorded person with significant control (PSC) is Oplyse Holdings Limited, holding at least 75% of shares and voting rights and the right to appoint/remove directors.
In the House of Lords Register, Lord Mandelson declares himself as Independent Non‑executive Director, Bank of London (fintech startup), but does not name Oplyse Holdings Limited as a Category 1 directorships.
Royal Charter entity – missing opening date and disclosures
Companies House lists BANK OF LONDON (RC000043) as a Royal Charter company, with no incorporation date, no opening/authorisation date, no accounts, no officers and no PSC information publicly available.
The absence of any public indication of when this “Bank of London” commenced business (or even became operational), combined with the complete lack of filings, is highly unusual for a banking‑branded entity in the UK and severely limits transparency for third‑party due‑diligence.
PSC breaches – Oplyse Holdings Limited
Oplyse Holdings Limited’s 2023 Annual Report and Financial Statements state that Fellesskap Group & Holdings Corporation Limited (originally TBOL Group & Holdings Corporation Limited), a company incorporated in Jersey on 1 November 2023, became its immediate and ultimate parent company on 2 May 2024.
The PSC section for Oplyse Holdings Limited, however, shows:
A “no registrable person or registrable relevant legal entity” statement, notified 18 April 2025; and
Two ceased PSCs (Mr Anthony George Watson and Diane Elizabeth Gray‑Smith), with no active PSC recorded thereafter.
On the face of this information, Fellesskap Group & Holdings Corporation Limited clearly meets the PSC/RLE tests in section 790C(2) Companies Act 2006 (immediate and ultimate parent with control over shares/votes) and should be recorded as a registrable relevant legal entity.
Failure to do so indicates non‑compliance with:
Sections 790D–790E Companies Act 2006 – duty of the company to take reasonable steps to identify PSCs/RLEs and keep that information up to date.
Section 790VA and related provisions – duty to notify the registrar of changes in PSC information within the prescribed time (14 days from the date the company becomes aware of the change).
Section 790F and Schedule 1B Companies Act 2006 – creating a criminal offence for the company and every officer in default where they fail, without reasonable excuse, to comply with PSC obligations or file accurate PSC statements.
Oplyse Holdings Limited’s filing of a “no registrable PSC or RLE” statement in April 2025, despite the accounts stating that a parent company has existed since May 2024, is consistent with a breach of the PSC regime in Part 21A Companies Act 2006.
Late accounts – Oplyse Holdings Limited
Companies House shows Oplyse Holdings Limited’s latest accounts as overdue.
For a private company, section 441 Companies Act 2006 requires accounts to be filed within nine months of the financial year end.
Failure to file on time triggers:
a civil late‑filing penalty for the company under section 453; and
potential criminal liability for every director in default under section 451, punishable by fine.
On the dates you have captured, Oplyse Holdings Limited is in breach of section 441, with associated penalty and enforcement risk.
Mis‑alignment with the Lords Register and transparency risk
In substance, Lord Mandelson’s declared “Bank of London (fintech startup)” role corresponds to a Companies Act directorship in Oplyse Holdings Limited, the holding company and PSC of The Bank of London Group Limited, rather than in the Royal Charter entity at RC000043.
The Lords Register entry does not name Oplyse Holdings Limited (10511092) and therefore cannot be directly reconciled with his Companies House directorships by a reader who relies on legal entity names.
The House of Lords Code of Conduct and Guide require registration of directorships of public and private companies; not naming the actual holding company while using only the trading/brand name (“Bank of London”) falls short of the transparency expected in Category 1 and materially weakens the ability of external auditors, regulators and KYC systems to link his parliamentary declaration to the correct legal entity.
Clone/confusion risk
There are, in effect, three overlapping “Bank of London” structures:
a Royal Charter “BANK OF LONDON” with no public opening date, no accounts and no officer data (RC000043);
The Bank of London Group Limited (12844788), a regulated banking company; and
Oplyse Holdings Limited (10511092), a financial holding company with multiple historical names referencing “Bank of London” and “TBOL”, and with defective PSC disclosures.
The combination of:
opaque PSC reporting at the holding‑company level;
late accounts;
a Royal Charter “Bank of London” that provides no temporal or financial data; and
a parliamentary declaration that uses only the brand name, not the legal company name,
creates a high risk of confusion and potential clone‑style misuse in the eyes of customers, counterparties and automated screening tools.
Taken together, Oplyse Holdings Limited’s PSC and filing failures, the absence of any opening or financial data for the Royal Charter Bank of London (RC000043), and Lord Mandelson’s incomplete naming of the relevant holding company in his Lords Register entry, amount to a serious transparency and compliance concern. They indicate likely breaches of the Companies Act 2006 PSC and accounts‑filing provisions, and significantly increase the risk of mis‑identification and attempted clone‑company abuse in relation to ‘Bank of London’ branded entities.
7. The Design Museum
Companies House shows Lord Mandelson as a director of THE DESIGN MUSEUM (02325092), appointed 15 March 2017 and resigned 11 July 2023.
In the Lords register he appears only under Category 10(c) as “Trustee Emeriti (formerly Chairman), The Design Museum”, with no Category 1 directorship entry, even though this was a Companies Act directorship.
The code does allow unpaid charitable trusteeships to be registered as non‑financial interests, but when there is a formal “director” appointment at Companies House, best practice is to mirror that in Category 1; so on the face of it the directorship as such was not explicitly declared.
8. Global Counsel companies
8a. Global Counsel Ventures Ltd
Companies House shows Global Counsel Ventures Ltd (13858000) as an active company incorporated 19 January 2022, with Lord Peter Benjamin Mandelson recorded as a director from 19 January 2022 to 16 December 2022. The Persons with Significant Control (PSC) register records Global Counsel Ltd (10533767) as holding 75% or more of the shares and voting rights, and the right to appoint or remove directors, from 19 January 2022 (GLOBAL COUNSEL VENTURES LTD persons with significant controlhttps://find-and-update.company-information.service.gov.uk/company/13858000/persons-with-significant-control).
The Lords register does not contain a separate entry naming Global Counsel Ventures Ltd. Lord Mandelson does declare Global Counsel‑related interests (director and PSC in Global Counsel Ltd and Global Counsel Consulting LLP, Category 4(b) shareholdings in Global Counsel Advisory Ltd and Global Counsel Ltd, and “President, Global Counsel Ltd and Chair of Global Counsel’s International Advisory Board”), but the specific Ventures directorship is not disclosed as such. Unless that directorship fell below a materiality or de minimis threshold (which is not apparent on the face of the Code), it should have been registered either as a distinct Category 1 directorship or clearly encompassed in a composite Global Counsel entry; as things stand, Global Counsel Ventures Ltd does not appear in the extracted register text.
A Companies House search for “Global Counsel” returns, among others, the following legal entities, All search results (https://find-and-update.company-information.service.gov.uk/search?q=global+counsel):
Matching previous names:
GLOBAL COUNSEL CONSULTING LTD10533767 - Incorporated on 20 December 2016 - In Administration
C/O Interpath Ltd 10, Fleet Place, London, EC4M 7RB
Matching previous names:
GLOBAL COUNSELOC359787 - Dissolved on 4 June 2024
6th Floor 2 London Wall Place, London, England, EC2Y 5AU”
Global Counsel Ltd and Global Counsel Consulting LLP are companies that are declared in Lord Mandelson’s Register of Interest as directorships and PSC.
8b. Global Counsel Ltd
“GLOBAL COUNSEL LTD
Company number 10533767
Registered office address C/O Interpath Ltd 10, Fleet Place, London, EC4M 7RB
Company status In Administration
Company type Private limited Company
Incorporated on 20 December 2016
Accounts
Next accounts made up to 31 December 2025 due by 30 September 2026
Last accounts made up to 31 December 2024
Confirmation statement
Next statement date 12 June 2026 due by 26 June 2026
Last statement dated 12 June 2025
Nature of business (SIC)
70229 - Management consultancy activities other than financial management
Previous company names
Name Period GLOBAL COUNSEL CONSULTING LTD 20 Dec 2016 - 17 Jan 2017”
Global Counsel Ltd was incorporated on 20 December 2016 under the name Global Counsel Consulting Ltd and re‑registered as Global Counsel Ltd on 17 January 2017.
8c. Global Counsel Consulting LLP
“GLOBAL COUNSEL CONSULTING LLP
Company number OC359787
Registered office address 6th Floor 2 London Wall Place, London, England, EC2Y 5AU
Company status Dissolved
Dissolved on 4 June 2024
Company type Limited liability partnership
Incorporated on 24 November 2010
Accounts
Last accounts made up to 31 December 2022
Previous company names
Name Period GLOBAL COUNSEL LLP 24 Nov 2010 - 17 Jan 2017”
Global Counsel Consulting LLP traded as Global Counsel LLP from 24 November 2010 until 17 January 2017, when it adopted the name Global Counsel Consulting LLP. On the same date, the newly incorporated Global Counsel Ltd (company 10533767) ceased to be Global Counsel Consulting Ltd and adopted the name Global Counsel Ltd.
In practical effect, two separate legal entities whose names had been ‘Global Counsel LLP’ (OC359787) and ‘Global Counsel Consulting Ltd’ (10533767) swapped names on 17 January 2017, becoming ‘Global Counsel Consulting LLP’ and ‘Global Counsel Ltd’ respectively. For the purposes of the ‘same as’ and ‘too like’ rules in sections 66–67 Companies Act 2006, the suffixes ‘Ltd’ and ‘LLP’ are disregarded when comparing names, so ‘Global Counsel Ltd’ and ‘Global Counsel LLP’ are treated as the same name, and likewise for ‘Global Counsel Consulting’; orchestrating a same‑day swap between two entities in this way creates a serious risk that contracts, liabilities and regulatory responsibilities will be mis‑attributed between the LLP and the company, and appears, on its face, to fall within the mischief that sections 66–67 are designed to prevent, warranting regulatory investigation and, if the statutory tests are met, enforcement action against the responsible officers.
8d. Interpath Ltd
Global Counsel Ltd is in administration with the receivers listed as Interpath Ltd. A Companies House search of “Interpath” returns four companies that have used this name, Company search results (https://find-and-update.company-information.service.gov.uk/search/companies?q=interpath).
13225134 - Incorporated on 25 February 2021
10 Fleet Place, London, England, EC4M 7RB
Matching previous names:
INTERPATH LTDSC686236 - Incorporated on 18 January 2021
31 Charlotte Square, Edinburgh, Scotland, EH2 4ET
08564959 - Dissolved on 13 August 2020
Live Recoveries 122 New Road Side Horsforth, Leeds, LS18 4QB
06369308 - Dissolved on 9 March 2010
Suite B, 29 Harley Street London, United Kingdom, W1G 9QR”
Global Counsel Ltd is currently in administration, with Interpath Ltd appointed as administrator and registered at 10 Fleet Place, London, EC4M 7RB. A Companies House search for ‘Interpath’ shows four different companies that have used the name Interpath Ltd or Interpath (IP) Ltd, including dissolved predecessors and an earlier Scottish entity that previously traded as Interpath Ltd. The recycling of an identical or near‑identical name across multiple companies over time, some dissolved and some active, is a recognised red flag for name‑confusion and potential clone‑company misuse; while further analysis would be needed to determine whether the Companies Act ‘same as/too like’ tests in sections 66–67 are breached in this case, the pattern justifies treating Interpath‑branded insolvency appointments as requiring heightened KYC and counterparty checks.
9. Global Ports Holding – LLP vs Ltd
Companies House record Benjamin Mandelson as a director of Global Ports Holding Limited (10629250), appointed 12 April 2017 and resigned 29 September 2021.
In the Lords register text he is described as “Independent Non‑executive Director, Global Ports Holding plc (international ports operator) (interest ceased 29 September 2021 – notified 1 November 2021)” as “Global Ports Holding LLP”.
The underlying legal entity at Companies House is clearly Global Ports Holding Limited, which was re‑registered from a private to a public limited company in April 2017 (hence “plc” for market purposes), but there is no LLP of that name; so any reference in the register to “Global Ports Holding LLP” is a naming error.
Substantively, the directorship itself is declared, and the dates match; the discrepancy is in the form (Ltd/LLP/plc) rather than the fact of declaration, but it still weakens clarity for audit and KYC cross‑matching.
9a. Global Ports Holding Limited Related Party: “Mha Macintyre Hudson”
Lord Mandelson’s correspondence address for Global Ports Holding Limited is “Mha Macintyre Hudson, New Bridge Street House, 30-34 New Bridge Street, London, United Kingdom.” The use of this address is evidence that Lord Mandelson and “Mha Macintyre Hudson” are related parties. MHA Macintyre Hudson has occurred within several published compliance assessments.
That MHA MacIntyre Hudson and its chairman Rakesh Shaunak have already been:
investigated by the FRC and publicly censured by the FCA for audit failings;
criticised in my earlier reports for their role in high‑risk audits linked to a former Kazakh president, Russian/Ukraine mining groups, East London Science School Trust (Rishi Sunak), The Civil Liberties Trust/Liberty (Sadiq Khan), and The Captain Tom Foundation.
References: https://open.substack.com/pub/alisonwright/p/sadiq-khan-liberty-libertys-auditor?utm_campaign=post-expanded-share&utm_medium=web; https://open.substack.com/pub/alisonwright/p/rishi-sunak-and-related-parties-due?utm_campaign=post-expanded-share&utm_medium=web; https://open.substack.com/pub/alisonwright/p/sadiq-khan-due-diligence?utm_campaign=post-expanded-share&utm_medium=web; https://open.substack.com/pub/alisonwright/p/rishi-sunak-and-akshata-murty-complaint?utm_campaign=post-expanded-share&utm_medium=web; https://open.substack.com/pub/alisonwright/p/rishi-sunak-and-akshata-murty-complaint?utm_campaign=post-expanded-share&utm_medium=web; https://open.substack.com/pub/alisonwright/p/part-2-the-captain-tom-foundation?utm_campaign=post-expanded-share&utm_medium=web.
That Lord Mandelson’s use of MHA MacIntyre Hudson’s New Bridge Street House address as his correspondence address for Global Ports Holding Limited establishes a related‑party connection to the same audit firm and address cluster you have already identified as high‑risk in other compliance assessments.
That, taken together, this supports treating MHA MacIntyre Hudson (and by extension Shaunak) as a known high‑risk node in the wider network of politically exposed persons (Sunak, Khan, Mandelson and others), and justifies heightened scepticism about governance, audit independence, and KYC outcomes wherever this audit firm, its partners, or its addresses intersect with Lord Mandelson’s corporate roles.
Compliance note, for further investigation.
A search was made on the name “MHA Macintyre Hudson” Company search results (https://find-and-update.company-information.service.gov.uk/search/companies?q=mha+macintyre+hudson&page=1.
“MHA MACINTYRE HUDSON CONSULTING LIMITED
12118510 - Incorporated on 24 July 2019
The Pinnacle, 150 Midsummer Boulevard, Milton Keynes, Bucks, United Kingdom, MK9 1LZ
MHA MACINTYRE HUDSON (KENT) LLP
“OC385090 - Dissolved on 23 April 2019
Moorgate House, 201 Silbury Boulevard, Milton Keynes, Buckinghamshire, MK9 1LZ
MACINTYRE HUDSON LLP
OC312313 - Incorporated on 19 March 2005
The Pinnacle, 150 Midsummer Boulevard, Milton Keynes, Buckinghamshire, United Kingdom, MK9 1LZ
MACINTYRE HUDSON LIMITED
Matching previous names:
MACINTYRE HUDSON FINANCE LIMITED
01954133 - Incorporated on 4 November 1985
The Pinnacle, 150 Midsummer Boulevard, Milton Keynes, Bucks, United Kingdom, MK9 1LZ
MACINTYRE HUDSON ADVISORY SERVICES LLP
Matching previous names:
MACINTYRE HUDSON AS
OC357982 - Incorporated on 17 September 2010
The Pinnacle, 150 Midsummer Boulevard, Milton Keynes, Buckinghamshire, United Kingdom, MK9 1LZ
MACINTYRE HUDSON HOLDINGS LIMITED
03717255 - Incorporated on 22 February 1999
The Pinnacle, 150 Midsummer Boulevard, Milton Keynes, Buckinghamshire, United Kingdom, MK9 1LZ
MACINTYRE HUDSON TREASURY LIMITED
08678770 - Incorporated on 5 September 2013
The Pinnacle, 150 Midsummer Boulevard, Milton Keynes, Buckinghamshire, United Kingdom, MK9 1LZ
MACINTYRE HUDSON WORLDWIDE LTD.
06353246 - Incorporated on 28 August 2007
Suite 2096 Office 6, Slington House, Rankine Road, Basingstoke, Hampshire, RG24 8PH
MHA CORPORATE FINANCE LIMITED
Matching previous names:
MACINTYRE HUDSON CORPORATE FINANCE LIMITED
04296841 - Incorporated on 1 October 2001
The Pinnacle, 150 Midsummer Boulevard, Milton Keynes, Buckinghamshire, United Kingdom, MK9 1LZ
MHA SERVICE LIMITED
Matching previous names:
MACINTYRE HUDSON SERVICE LIMITED · MHA LIMITED
07263895 - Incorporated on 25 May 2010
The Pinnacle, 150 Midsummer Boulevard, Milton Keynes, Bucks, United Kingdom, MK9 1LZ
MACINTYRE HUDSON CORPORATE SERVICES LIMITED
Matching previous names:
MACINTYRE HUDSON (FINANCIAL SERVICES) · MACINTYRE CORPORATE SERVICES
02021987 - Dissolved on 21 July 2015
Moorgate House, 201,Silbury Boulevard, Central Milton Keynes, MK9 1LZ
MACINTYRE HUDSON TAX DIRECT LIMITED
07275935 - Dissolved on 16 June 2015
Moorgate House, 201 Silbury Boulevard, Milton Keynes, Bucks, MK9 1LZ
MHAS 2010 LIMITED
Matching previous names:
MACINTYRE HUDSON ADVISORY SERVICES · MACINTYRE ADVISORY SERVICES · MACINTYRE TAXATION SERVICES
02199964 - Dissolved on 16 June 2015
Moorgate House, 201 Silbury Boulevard, Central Miton Keynes, Buckinghamshire, MK9 1LZ”
Observation: Overlapping names, range of recurring registered addresses.
MHA McIntyre Hudson Corporate officers:
A search was made for corporate officers with this name, Officer search results (https://find-and-update.company-information.service.gov.uk/search/officers?q=mha%20macintyre%20hudson):
“MHA MACINTYRE HUDSON
Total number of appointments 1
New Bridge Street House, 30-34 New Bridge Street, London, United Kingdom, EC4V 6BJ
MHA MACINTYRE HUDSON
Total number of appointments 2
th Floor, 2 London Wall Place, Barbican, London, England, EC2Y 5AU
Mha MACINTYRE HUDSON
Total number of appointments 1
New Bridge Street House, 30-34 New Bridge Street, London, England, EC4V 6BJ
MACINTYRE HUDSON LLP
Total number of appointments 11
Moorgate House, 201 Silbury Boulevard, Milton Keynes, Buckinghamshire, United Kingdom, MK9 1LZ
MACINTYRE HUDSON LLP
Total number of appointments 1
201 Silbury Boulevard, Milton Keynes, Buckinghamshire, England, MK9 1LZ
MACINTYRE HUDSON LLP
Total number of appointments 1
New Bridge Street House, 30-34 New Bridge Street, London, EC4V 6BJ
MACINTYRE HUDSON HOLDINGS LIMITED
Total number of appointments 1
The Pinnacle, 150 Midsummer Boulevard, Milton Keynes, Buckinghamshire, United Kingdom, MK9 1LZ
MACINTYRE HUDSON HOLDINGS LIMITED
Total number of appointments 1
Moorgate House, 201 Silbury Boulevard, Milton Keynes, MK9 1LZ
EIS HAINES WATTS LIMITED
Matching appointment names:
MACINTYRE HUDSON LLP
Total number of appointments 61
3rd Floor 7-10 Chandos Street, London, W1G 9DQ
MACINTYRE HUDSON CORPORATE SERVICES LIMITED
Total number of appointments 1
Moorgate House, 201 Silbury Boulevard, Milton Keynes, United Kingdom, MK9 1LZ
MACINTYRE HUDSON CORPORATE SERVICES LIMITED
Total number of appointments 4
Moorgate House, 201 Silbury Boulevard, Milton Keynes, Buckinghamshire, United Kingdom, MK9 1LZ
MHA MACINTRYRE HUDSON
Total number of appointments 1
Pennant House, 1-2 Napier Court, Napier Road, Reading, United Kingdom, RG1 8BW
MACINTYRE HUDSON TREASURY LIMITED
Total number of appointments 1
Moorgate House 201, Silbury Boulevard, Milton Keynes, Buckinghamshire, United Kingdom, MK9 1LZ
MHA
Total number of appointments 1
12 Carden Place, Aberdeen, Scotland, AB10 1UR
MHA AUDIT HOLDINGS LTD
Total number of appointments 2
The Pinnacle, 150 Midsummer Boulevard, Milton Keynes, Buckinghamshire, United Kingdom, MK9 1LZ
TANYARADZWA MAVUKA GODWILL MHANGAMI
Total number of appointments 1
Suite 5664 Unit 3a, 34-35 Hatton Garden, Holborn, London, England, EC1N 8DX
MHA PLC
Total number of appointments 2
The Pinnacle, 150 Midsummer Boulevard, Milton Keynes, Buckinghamshire, United Kingdom, MK9 1LZ
MHA ADVISORY LTD
Total number of appointments 3
The Pinnacle, 150 Midsummer Boulevard, Milton Keynes, Buckinghamshire, United Kingdom, MK9 1LZ
ALL EARS MHA C.I.C.
Total number of appointments 1
432 Ormskirk Road, Wigan, England, WN5 9DH
MHANNY AND HIS PARTNERS LAW FIRM
Total number of appointments 1
3789 Al Hashima St, Al Yarmouk Dist, Riyadh, Saudi Arabia, 13251”
Compliance analysis:
The Companies House data for MHA MacIntyre Hudson–branded entities and officer identities reveals a dense, overlapping cluster of companies and corporate appointments that materially increases audit, KYC and fraud risk, and indicates potential breaches of the Companies Act 2006 around transparency and use of “confusingly similar” names.
First, the company‑name landscape shows a proliferation of closely related vehicles clustered around the same core brand and addresses. There are multiple active companies with near‑identical names – MACINTYRE HUDSON LLP, MACINTYRE HUDSON LIMITED, MACINTYRE HUDSON HOLDINGS LIMITED, MACINTYRE HUDSON TREASURY LIMITED, MACINTYRE HUDSON ADVISORY SERVICES LLP, MHA MACINTYRE HUDSON CONSULTING LIMITED, MHA CORPORATE FINANCE LIMITED, MHA SERVICE LIMITED – almost all registered at either The Pinnacle, 150 Midsummer Boulevard, Milton Keynes, or Moorgate House, 201 Silbury Boulevard, Milton Keynes. Alongside these sit dissolved or renamed entities (e.g. MHAS 2010 LIMITED, MACINTYRE HUDSON CORPORATE SERVICES LIMITED, MACINTYRE HUDSON TAX DIRECT LIMITED). The effect is an opaque group structure, in which a lay reader – and many automated systems – will struggle to distinguish which legal entity is responsible for which services, or which entity signed which audit, without detailed manual tracing. That complexity is not, by itself, unlawful, but it substantially raises the risk of mis‑identification and clone‑type confusion, particularly when the same brand (“MHA MacIntyre Hudson” / “MacIntyre Hudson”) is also used as an officer name across multiple companies.
Second, the officer search results show that “MHA MACINTYRE HUDSON” and “MACINTYRE HUDSON LLP” appear as corporate officers with multiple different registered addresses (New Bridge Street House, London; 2 London Wall Place; Moorgate House and The Pinnacle in Milton Keynes; and others). There is even a mis‑spelled variant “MHA MACINTRYRE HUDSON”, as well as other “MHA” corporate officers (MHA PLC, MHA ADVISORY LTD, MHA AUDIT HOLDINGS LTD) at the same Milton Keynes addresses. This pattern of:
multiple officer entries carrying virtually the same name;
overlapping but non‑identical addresses; and
spelling variants and abbreviations,
is consistent with systematic address and name variation, which is a recognised red flag for compromised company data and audit/KYC failure. Under section 1082 Companies Act 2006, the register is prima facie evidence of the matters stated, so any systematic use of inconsistent names or addresses for the same underlying firm undermines the reliability of the public record and can compromise any audit or due‑diligence process that relies on exact matching. Where corporate officers are used as a way to obscure which entity within a group is actually providing regulated services, this also engages the general prohibition on misleading company names and passing‑off risk (sections 53–54 and 76 CA 2006 in substance, and the common‑law doctrine of passing off), particularly if the arrangement could confuse counterparties as to who is carrying liability for audit work or client money.
Third, there is a regulatory‑compliance dimension. MHA MacIntyre Hudson has already been publicly sanctioned by the FCA for audit failures, and is subject to FRC investigation in at least one audit case. That places the group firmly in a high‑risk category for any regulated firm’s third‑party risk assessment. When a group of audit and advisory entities with this history also uses overlapping names and addresses in the way described above, the combination creates a credible scenario in which:
responsibility for defective audits or regulatory breaches can be shifted between similarly named entities;
counterparties and regulators may struggle to identify which specific legal entity signed a report; and
routine KYC and sanctions‑screening tools may “miss” connections because of name and address variation.
Fourth, in the context of Lord Mandelson’s affairs, this pattern is particularly significant. His directorship of Global Ports Holding Limited uses the correspondence address “Mha Macintyre Hudson, New Bridge Street House, 30–34 New Bridge Street, London”, which appears in the officer records as an address used by “MHA MACINTYRE HUDSON” and “MACINTYRE HUDSON LLP” as a corporate officer. This means Global Ports Holding Limited and Lord Mandelson are structurally tied into the same New Bridge Street node as MHA MacIntyre Hudson, reinforcing that they are related parties in governance and audit terms. Given the group’s existing compliance history and the opacity of its internal company‑and‑officer web, any entity – and any politically exposed person – using MHA MacIntyre Hudson addresses should be treated as subject to heightened audit and financial‑crime risk, and any assurance work they have signed off should be reviewed with particular scepticism.
In summary, the Companies House data for MHA MacIntyre Hudson reveals: (i) a complex cluster of similarly named companies at the same addresses, (ii) multiple officer identities using the same brand name with varying addresses and even spelling errors, and (iii) known regulatory breaches. This combination materially undermines the reliability of the register for audit and KYC purposes, engages the Companies Act duties to maintain accurate and non‑misleading information on the register, and significantly elevates the risk of mis‑identification, clone‑style fraud and compromised audits wherever these entities intersect with Lord Mandelson’s corporate roles.
10. Sistema
Mandelson's Register of Interest declares Sistema as a category 1, directorship: “Interest deleted 2 July 2018 Non-executive Director, Sistema (diversified holding company) (interest ceased 30 June 2017) (originally added 20 July 2013).” Sistema is also declared as a category 4 shareholding. “Interest deleted 28 June 2022 Sistema (diversified holding company) (interest ceased 24 June 2021 - notified 1 November 2021) (originally added 28 July 2017).”
Mandelson’s directorship of Sistema spans 20 July 2013 to 30 June 2017 and his shareholding in Sistema from 28 July 2017 to 24 June 2021.
Sistema is the publicly used name of a Russian diversified holding company. A summary is provided drawn from Wikipedia, Sistema - Wikipedia (https://en.wikipedia.org/wiki/Sistema):
AFK Sistema PAO is a large Russian conglomerate headquartered in Moscow, founded by Vladimir Yevtushenkov, with operations across telecommunications, banking, real estate, retail, media, tourism, space technology, medical services and biotechnology, and with multi‑billion‑dollar revenues, assets and tens of thousands of employees. Website www.sistema.com.
It is surprising that Lord Mandelson was a director of a Russian conglomerate and then went on to become US trade envoy. This presents multiple risks; sanctions, financial crime risk, policy and integrity risk.
A search in Companies House locates several companies that use or have used this name, Company search results (https://find-and-update.company-information.service.gov.uk/search/companies?q=sistema):
“SISTEMA LTD
15491349 - Dissolved on 22 July 2025
3rd Floor, 86-90 Paul Street, London, England, United Kingdom, EC2A 4NE
SIGN ENGINEERING TECHNOLOGY LIMITED
Matching previous names:
SISTEMA
05066370 - Dissolved on 9 September 2015
1 St James Gate, Newcastle Upon Tyne, NE1 4AD
SISTEMA ABBIGLIAMENTO LTD
16768794 - Incorporated on 7 October 2025
20 Wenlock Road, London, England, N1 7GU
SISTEMA CYMRU - CODI’R TO
CE003191 - Registered externally as 1159046
SISTEMA ECODECO UK LIMITED
05049191 - Incorporated on 19 February 2004
C/O Mercer & Hole The Pinnacle, 170 Midsummer Boulevard, Milton Keynes, England, MK9 1BP
SISTEMA PLASTICS UK LIMITED
BR010429 - Closed
Halifax Avenue Fradley Park, Lichfield, WS13 8SS
SISTEMA SAMCO LTD
14561067 - Incorporated on 29 December 2022
Unit 1 Woodlands Farm, Clapton, Berkeley, England, GL13 9QU
SISTEMA SCOTLAND
SC312903 - Incorporated on 1 December 2006
Raploch Community Campus, Drip Road, Stirling, FK8 1RD
SISTEMA SCOTLAND (TRADING) LIMITED
Matching previous names:
SISTEMA (SCOTLAND) TRADING LIMITED
SC405858 - Incorporated on 22 August 2011
Raploch Community Campus, Drip Road, Stirling, FK8 1RD
SISTEMAS DELTA LIMITED
15891341 - Incorporated on 12 August 2024
Unit C, Blackett Street, Manchester, England, M12 6AE
SISTEMAS EU CITADE LTD
16698093 - Dissolved on 20 January 2026
4385, 16698093 - COMPANIES HOUSE DEFAULT ADDRESS, Cardiff, CF14 8LH
SISTEMAS Y ESTRUCTURAS UK LIMITED
14520677 - Incorporated on 2 December 2022
48 Warwick Street, London, Greater London, United Kingdom, W1B 5AW
SISTEMA TODDLER LTD
15913881 - Dissolved on 9 September 2025
71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ
SISTEMA PLASTICS UK LIMITED
FC028928 - Closed on 30 December 2024
15 Te Tiki Road, Mangere, Auckland 2022, New Zealand
SISTEMA ENGLAND LTD
07556487 - Dissolved on 29 August 2023
38 Ridgeway Ridgeway, Epsom, England, KT19 8LB
GLOBANT UK LIMITED
Matching previous names:
SISTEMAS UK LIMITED
05248956 - Incorporated on 4 October 2004
Level 2 The Zig Zag, 70 Victoria Street, London, United Kingdom, SW1E 6SQ
SISTEMA GROUP LTD
11801914 - Dissolved on 30 March 2021
4385, 11801914 : COMPANIES HOUSE DEFAULT ADDRESS, Cardiff, CF14 8LH
SCP GROUP ADVISORY LIMITED
Matching previous names:
SISTEMA CAPITAL PARTNERS LIMITED
08285871 - Incorporated on 8 November 2012
3 Hill Street, London, England, W1J 5LB
SISTEMA CONSULTING LIMITED
09905863 - Dissolved on 13 June 2017
29 Great Park, Kings Langley, England, WD4 8EG
SISTEMAS DO TEMPO LIMITED
06243452 - Dissolved on 30 May 2017
Cavendish House, St Andrew’s Court, Burley Street, Leeds, West Yorkshire, LS3 1JY”
With companies registered in Companies House that carry the same name as Lord Mandelson’s interest, creates a risk for clone company fraud, which requires detailed investigation, which is not attempted here.
Compliance Finding – Lord Mandelson and Sistema (AFK Sistema)
Declared interest
Lord Mandelson’s Register of Interests records: “Sistema (diversified holding company) – interest ceased 24 June 2021, notified 1 November 2021, interest deleted 28 June 2022 (originally added 28 July 2017).”
On the face of the register, he therefore acknowledges a remunerated relationship with Sistema up to 24 June 2021, with the cessation notified several months later.
Nature of Sistema
AFK Sistema PAO is a large Russian conglomerate headquartered in Moscow, founded by Vladimir Yevtushenkov.
It has operated across telecommunications, banking, real estate, retail, media, tourism, space technology, medical services and biotechnology, with tens of thousands of employees and multi‑billion‑dollar revenues and assets.
Its global depository receipts traded on the London Stock Exchange from 2005 until delisting in May 2023.
AFK Sistema and/or its founder have been subject to Western sanctions and scrutiny:
The UK imposed sanctions on Vladimir Yevtushenkov in April 2022, prompting him to relinquish control of Sistema.
AFK Sistema PAO has been under US sanctions since November 2023.
UK Russia sanctions notices list “AFK SISTEMA” as a relevant target under the Russia (Sanctions) (EU Exit) Regulations 2019.
Companies House confusion risk (“Sistema” name collisions)
A search in Companies House for “Sistema” returns numerous UK entities using the same or similar name, including SISTEMA LTD, SISTEMA SCOTLAND, SISTEMA GROUP LTD, SISTEMA ENGLAND LTD, SISTEMA CONSULTING LIMITED, SISTEMA CAPITAL PARTNERS LIMITED (now SCP GROUP ADVISORY LIMITED), and others.
None of these UK companies is AFK Sistema PAO itself; they are unrelated entities using the same word as part of their name.
This creates a real risk that automated or superficial audits could mistakenly:
treat a small UK “Sistema” company as the same as AFK Sistema PAO; or
fail to pick up the Russian parent if screening is limited to UK Companies House.
Given that:
Lord Mandelson declares a relationship with “Sistema (diversified holding company)” which clearly refers to AFK Sistema PAO, the Russian conglomerate, not any of the UK “Sistema” entities; and
UK, US and EU sanctions increasingly target Russian conglomerates and their networks;
The similarity of name between AFK Sistema PAO and multiple, unrelated ‘Sistema’ companies on the UK register generates substantial scope for clone‑type confusion and screening error. Effective sanctions and KYC work must go beyond Companies House and correctly resolve Lord Mandelson’s interest to the Russian listed conglomerate AFK Sistema, not to an apparently harmless UK ‘Sistema’ entity.
Sanctions and policy‑risk implications
Even though his declared interest in Sistema ceased on 24 June 2021 (pre‑full‑scale invasion of Ukraine), AFK Sistema, its founder and its group activities have been under sanctions and high‑risk scrutiny for a number of years, especially from 2022 onwards.
In any modern UK sanctions‑compliance framework (OFSI, UK Sanctions List, Russia (Sanctions) (EU Exit) Regulations 2019):
A former or current directorship/advisory role with AFK Sistema PAO would be classed as a high‑risk relationship.
Any continuing financial interest (shares, options, retained fees) after June 2021 would need to be screened against current designations and sectoral measures.
Against that backdrop, Lord Mandelson’s subsequent appointment as UK–US trade envoy/ambassador and his role at Global Counsel raise significant policy‑coherence and reputational‑risk concerns, even if there is no technical breach of the sanctions regime, because:
he had recent, high‑level ties to a Russian conglomerate later caught in sanctions enforcement; and
the complexity of “Sistema” naming in the UK register makes those ties non‑obvious to basic KYC checks.
Conclusion
Lord Mandelson correctly discloses a remunerated relationship with ‘Sistema (diversified holding company)’ in his Lords Register, ceasing 24 June 2021. Public sources confirm that this refers to AFK Sistema PAO, a large Moscow‑based conglomerate whose GDRs were listed in London until 2023 and which, together with its founder, has subsequently been targeted by US and UK sanctions measures. The presence of multiple UK companies using the name ‘Sistema’ on the Companies House register, none of which is AFK Sistema PAO, significantly raises the risk of mis‑identification and clone‑style confusion in routine compliance checks. Any due‑diligence or policy assessment of Lord Mandelson’s suitability for sensitive roles (such as UK–US trade envoy/ambassador) should therefore treat his former Sistema role as a high‑risk Russian exposure and explicitly resolve the AFK Sistema from the “Sistema” noise in the UK register.
11. Great Britain-China Centre (The)
Compliance Observation - “Great Britain China Centre(The)”:
Whilst Lord Mandelson declares “interest deleted 1 May 2024 President, Great Britain China Centre (interest ceased 30 April 2023) (originally added 16 October 2015)” he is not listed as a director of this company. As President from 2015 to 2023 clarification should be sought as to whether he was a shadow director, who should have been registered as such in Companies House.
Great Britain China Centre(The) is a company associated with former Attorney General Victoria Prentis, among other directors. Compliance Assessment found multiple breaches by Victoria Prentis, she has two identities in Companies House and she failed to declare her directorship of Great Britain China Centre(The) in her Register of Interests. This shared interest between Lord Mandelson and Victoria Prentis would not have been identified in audit or KYC checks, since Victoria Prentis does not declare it and held it in a second identity, and Lord Mendelson is not registered as a director even though he was a long standing President.
On the facts described here, there are two distinct but related issues: (1) Mandelson’s un‑registered corporate status at the Great Britain‑China Centre (GBCC) despite a long presidency, and (2) the shared GBCC connection with Victoria Prentis being obscured by how both of them are recorded.
11a. Mandelson’s GBCC role and Companies House
GBCC is an executive non‑departmental public body (NDPB) and a company limited by guarantee (01196043).
GBCC’s formal Companies House directors’ list (and the FCDO‑sponsored annual reports) do not show Peter Mandelson as a director during his presidency; directors are a set of named individuals (e.g. Sir Martin Davidson, Alan Black, Richard Jackson, MPs such as Andrew Gwynne/Alicia Kearns, etc.).
Biographical profiles and Cabinet Office/Gov.uk‑type material describe him as President of the Great Britain China Centre, but as an honorary/non‑executive figure rather than as a Companies Act director.
On that basis, Companies House records support the observation: he appears not to have been a registered director of GBCC during the 2015–2023 period in which his Lords register records him as “President, Great Britain China Centre (interest ceased 30 April 2023; interest deleted 1 May 2024)”.
Shadow director question
Under the Companies Act 2006, a shadow director is a person “in accordance with whose directions or instructions the directors of the company are accustomed to act”, excluding advice given purely in a professional capacity.
Being “President” of a public body does not automatically make someone a shadow director; the test is factual – did the GBCC board routinely act on his instructions?
There is no evidence in the public GBCC filings or annual reports that the board was accustomed to act on Mandelson’s directions; the directors’ report presents GBCC as run by its formal board and executive.
So the shadow‑director point is a legitimate line for clarification (especially given his senior political stature and China‑facing role), but at present it is a question to put rather than a conclusion that he “was” a shadow director who must have been registered.
A precise formulation for correspondence would be:
GBCC and FCDO: ask whether, as President, Mandelson attended board meetings, gave directions or instructions to the board or executive, or otherwise functioned as a de facto or shadow director, and if so whether legal advice was taken on registration at Companies House.
House of Lords Commissioner / Registrar: ask whether, given GBCC’s NDPB status and the potential for influence on UK‑China policy, the “President” role ought to have been categorised as a directorship (Category 1) as well as a non‑financial interest.
11b. Victoria Prentis and GBCC
Companies House shows former Attorney General, Victoria Prentis, as a director of GREAT BRITAIN‑CHINA CENTRE (THE) (01196043), appointed 14 June 2018 and resigned 31 March 2020.
The compliance assessment of Victoria Prentis summarises that she failed to register this directorship in her Commons Register of Members’ Financial Interests, despite simultaneously registering GBCC as the sponsor of an overseas visit to China in April 2018.
GBCC’s status as an FCDO‑sponsored NDPB, with connections to Chinese party‑state bodies (via leadership forums etc.), means that failure to register the directorship raises obvious conflict‑of‑interest and national‑security concerns, as that article sets out.
This shared interest between Lord Mandelson and Victoria Prentis would not have been identified in audit or KYC check:
That is accurate since:
KYC / sanctions‑screening tools typically key off Companies House director and PSC data plus declared PEP roles.
In GBCC’s case:
Prentis appears under one of her Companies House identities, as already documented.
Mandelson is not on the GBCC director list at all; his connection is via an honorary presidency and the Lords register.
A conventional automated KYC search against GBCC’s Companies House officers would therefore pick up Prentis but not Mandelson, and a Commons‑only interests search on Prentis would also miss GBCC because she failed to declare the directorship.
11c. Compliance / governance assessment
For Mandelson:
He did register “President, Great Britain China Centre” as a non‑financial interest in the Lords, with start and cessation dates (2015–2023), so the transparency failure is not in the Lords register but in public corporate records, if (and only if) he was in reality functioning as a de facto/shadow director.
Clarification is needed from GBCC and FCDO on whether his role ever crossed the line into directing GBCC’s affairs in a way that should have triggered Companies Act director or PSC reporting.
For Prentis:
Companies House confirms a formal directorship of GBCC, 14 June 2018–31 March 2020.
The published analysis shows she did not enter this in her MPs’ Register of Interests, despite disclosing GBCC as a travel sponsor, amounting to a clear disclosure failure under Commons rules.
For KYC / audit:
The combination of (a) multiple Companies House identities, (b) an undeclared GBCC directorship by Prentis, and (c) an undeclared (in Companies House terms) but politically significant presidency by Mandelson, means a standard company‑officer‑only screen would not surface the full network of GBCC‑linked political influence.
Mandelson’s GBCC connection is under‑reflected in corporate records; Prentis’s GBCC connection is under‑reflected in parliamentary records; together they create a blind spot for ordinary KYC and conflict‑of‑interest checks.
12. Category 4: Shareholdings (b)
This section will review each of Lord Mandelson’s declaration for shareholding category b.
12 i. Global Counsel Advisory Ltd
The declaration under review is:
“Interest deleted 26 April 2019 Global Counsel Advisory Ltd (a financial advisory firm) (interest ceased 13 March 2018) (originally added 11 March 2014)”
This company was located in Companies House, the overview is provided below, GLOBAL COUNSEL ADVISORY LTD overview - https://find-and-update.company-information.service.gov.uk/company/08088033)
“GLOBAL COUNSEL ADVISORY LTD
Company number 08088033
Registered office address New Bridge Street House, 30-34 New Bridge Street, London, EC4V 6BJ
Company status Dissolved
Dissolved on 28 November 2017
Company type Private limited Company
Incorporated on 30 May 2012
Accounts
Last accounts made up to 31 December 2015
Nature of business (SIC)
74990 - Non-trading company”
GLOBAL COUNSEL ADVISORY LTD persons with significant control. The record shows:
“GLOBAL COUNSEL ADVISORY LTD
Company number 08088033
2 persons with significant control / 0 statements
Mr Benjamin Charles Wegg-Prosser
Correspondence address New Bridge Street, House, 30-34 New Bridge Street, London, EC4V 6BJ
Notified on 6 April 2016
Date of birth June 1974
Nationality British
Country of residence England
Nature of control
Ownership of shares – More than 25% but not more than 50%
Ownership of voting rights - More than 25% but not more than 50%
Lord Peter Benjamin Mandelson
Correspondence address New Bridge Street, House, 30-34 New Bridge Street, London, EC4V 6BJ
Notified on 6 April 2016
Date of birth October 1953
Nationality British
Country of residence United Kingdom
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%”
Companies House shows Global Counsel Advisory Ltd (08088033) as a private limited company incorporated on 30 May 2012 and dissolved on 28 November 2017, registered at New Bridge Street House, 30–34 New Bridge Street, London, EC4V 6BJ, with SIC 74990 – non‑trading company and last accounts made up to 31 December 2015. The PSC register records two individuals, Benjamin Charles Wegg‑Prosser and Lord Peter Benjamin Mandelson, each notified on 6 April 2016 as owning more than 25% but not more than 50% of the shares and voting rights.
Lord Mandelson’s shareholding was first entered in the Lords Register on 11 March 2014, but the “interest ceased” date is given as 13 March 2018, more than three months after the company was dissolved on 28 November 2017. Given the Code of Conduct requirement to update the Register within 30 days of an interest ceasing, this delay amounts to a technical breach of the House of Lords registration rules. Separately, the company’s failure to file accounts for the 2016 financial year before proceeding to strike‑off is consistent with non‑compliance with sections 441 and 451 Companies Act 2006 by the directors then in office, underlining that Lord Mandelson’s declared shareholding was in a company that did not meet basic filing obligations.
The directors are, GLOBAL COUNSEL ADVISORY LTD people (https://find-and-update.company-information.service.gov.uk/company/08088033/officers):
“GLOBAL COUNSEL ADVISORY LTD
Company number 08088033
2 officers / 0 resignations
Correspondence address New Bridge Street, House, 30-34 New Bridge Street, London, EC4V 6BJ
Role Secretary
Appointed on 26 May 2017
WEGG-PROSSER, Benjamin Charles
Correspondence address New Bridge Street, House, 30-34 New Bridge Street, London, England, EC4V 6BJ
Role Director
Date of birth June 1974
Appointed on 30 May 2012
Nationality British
Country of residence England”
A search in Companies House located no additional identities with the name Benjamin Charles Wegg-Prosser, All search results (https://find-and-update.company-information.service.gov.uk/search?q=Wegg-Prosser).
A search in Companies House for the secretary’s name, Christopher Cyrus LEVINE locates four identities with these three names, among other results.
Total number of appointments 1
New Bridge Street, House, 30-34 New Bridge Street, London, EC4V 6BJ
Total number of appointments 1
5 Welbeck Street, London, United Kingdom, W1G 9YG
Total number of appointments 4 - Born September 1979
85 Church Lane, London, England, N2 0TH
Total number of appointments 1
5 Welbeck Street, London, England, W1G 9YQ”
Global Counsel Advisory Ltd’s officers are Benjamin Charles Wegg‑Prosser (director from incorporation on 30 May 2012) and Christopher Cyrus Levine (secretary appointed 26 May 2017), both using the New Bridge Street House, 30–34 New Bridge Street, EC4V 6BJ address. A Companies House search shows only one officer identity for Benjamin Charles Wegg‑Prosser, but four separate officer identifiers for “Christopher Cyrus Levine”, tied to the following correspondence addresses: New Bridge Street House, EC4V 6BJ; 5 Welbeck Street, W1G 9YG; 5 Welbeck Street, W1G 9YQ; and 85 Church Lane, N2 0TH. This fragmentation of a single name across four officer IDs, with overlapping addresses, conflicts with the principle in section 1082 Companies Act 2006 that the register provide a reliable, uniquely identifiable record, and materially weakens audits and KYC processes because related‑party links can be missed when interests are split across multiple identifiers.
The officer search for “Levine” also returns corporate officers associated with Levine‑branded investment entities, including:
“LEVINE LEICHTMAN CAPITAL PARTNERS LLC
Total number of appointments 1
345 North Maple Drive, Suite 300, Beverly Hills, California, United States, 90210
LEVINE LEICHTMAN CAPITAL PARTNERS LIMITED
Total number of appointments 1
Mazars, 30 Old Bailey, London, United Kingdom, EC4M 7AU
LEVINE CAPITAL MANAGEMENT LIMITED
Total number of appointments 1
Omc Chambers, Wickams Cay 1, Road Town, Tortola, British Virgin Islands”
The correspondence address for LEVINE LEICHTMAN CAPITAL PARTNERS LIMITED is “Mazars, 30 Old Bailey, London, United Kingdom, EC4M 7AU”. A Companies House search for Mazars returns the following result first (Company search results (https://find-and-update.company-information.service.gov.uk/search/companies?q=mazars):
Matching previous names:
MAZARSOC308299 - Incorporated on 14 June 2004
30 Old Bailey, London, United Kingdom, EC4M 7AU”
“Mazars” is the previous company name of Forvis Mazars LLP, which is registered at 30 Old Bailey, London, United Kingdom, EC4M 7AU, the same address that corporate identity LEVINE LEICHTMAN CAPITAL PARTNERS LIMITED uses for correspondence. This strongly indicates that Levine Leichtman Capital Partners Limited is a related-party client or vehicle of Forvis Mazars. The company officer records for Levine Leichtman Capital Partners Limited identify Arthur Edward LEVINE is a director of Levine Leichtman Capital Partners Limited and LLCP Limited, Arthur Edward LEVINE personal appointments. A prudent due‑diligence assessment would therefore treat the Levine individuals and Levine‑branded entities, together with their Mazars/Old Bailey connection, as a single related‑party cluster and seek clarification of any familial or control relationships between Arthur Edward Levine and Christopher Cyrus Levine.
Concentration of control and roles across the Global Counsel cluster
Taken together, Global Counsel Advisory Ltd, Global Counsel Consulting LLP, Global Counsel Ltd and Global Counsel Ventures Ltd form a tightly held cluster in which a small group of individuals, including Lord Mandelson and Benjamin Wegg‑Prosser, repeatedly appear as directors, LLP members and PSCs across successive vehicles using the ‘Global Counsel’ and ‘Global Counsel Consulting’ names. The use of a non‑trading company (Global Counsel Advisory Ltd) with incomplete filing history, followed by new entities, coordinated same‑day name swaps between the LLP and the Ltd, and the creation of a further ‘Ventures’ vehicle controlled by Global Counsel Ltd, is consistent with a pattern of short‑lived and re‑labelled entities around a core advisory brand, which is a recognised red flag in KYC and audit for obfuscation of continuity, liabilities and counterparty history.
A possible wider Levine‑branded network appears in the officer listings; however, on the information available this remains a hypothesis and would require further investigative work to confirm any relationship to Christopher Cyrus Levine or to Global Counsel structures.
12 ii Moon Active Ltd category 4b shareholder declaration
“Interest deleted 3 February 2025 Moon Active Ltd (game app developer) (originally added 22 July 2019).”
There is no company with this name registered in Companies House, Company search results (https://find-and-update.company-information.service.gov.uk/search/companies?q=+Moon+Active+Ltd).
A search in “OpenCorporates” locates this company as registered in Japan with a head office address in Israel, Entity Details :: OpenCorporates (https://opencorporates.com/companies/jp/1700150107556):
“Moon Active Ltd. branch
Company Number 1700150107556
Status Active
Incorporation Date 30 March 2022 (almost 4 years ago)
Company Type Foreign corporation (外国会社等)
Jurisdiction Japan
Branch Branch of out-of-jurisdiction company
Company Addresses
Mikveh Israel 7, PO Box 627, Tel Aviv, Israel
Data source and freshness
Last Update From Source 25 February 2026
Last Change Recorded 31 March 2022
Next Update From Source Daily
Source National Tax Agency”
No further information was located.
Lord Mandelson’s Category 4(b) declaration for “Moon Active Ltd (game app developer)” records a shareholding added on 22 July 2019 and deleted on 3 February 2025. There is no company of that name on the UK register; the only identified entity is a foreign corporation (“M o o n A c t i ve Ltd.”) registered in Japan as a branch of an out‑of‑jurisdiction company with its head office in Tel Aviv, Israel. On the available information, this interest therefore relates to a non‑UK corporate entity.
Legally, the Lords’ Code of Conduct and Guide require “full and accurate” registration of relevant interests, including sufficient detail to allow third parties to understand the nature of the interest and to identify any potential conflicts. By omitting the jurisdiction of incorporation and presenting “Moon Active Ltd” without specifying that it is an overseas company, the entry is arguably incomplete for transparency purposes, because it does not clearly signal that this is a foreign technology company and therefore a potential channel of overseas commercial influence. However, there is no evidence that the interest itself was concealed or falsely described; the legal concern is that the register entry fails to identify the jurisdiction of incorporation and thus does not meet the standard of clarity and openness required for effective public scrutiny of foreign corporate links.
The Japanese registration uses a non‑standard rendering of the name (“Moon Active Ltd.”, with full‑width characters and spaces between letters). This kind of formatting difference (full‑width characters, inter‑letter spacing and Unicode variants) is well‑known to defeat or degrade automated sanctions, audit and KYC screening, which often relies on exact or near‑exact string matching. In combination with the absence of any UK‑registered “Moon Active Ltd”, this increases the risk that an overseas technology relationship may not be detected or properly risk‑rated by routine compliance systems, reinforcing the need for explicit disclosure of the jurisdiction and corporate identity in the Lords Register entry.
12 iii. SeeTrue Ltd.
“Interest deleted 3 February 2025 SeeTrue Ltd (AI technology) (originally added 17 May 2022)”
A search in Companies House locates a company with a similar name, Seetrue UK Ltd, the overview is copied below, SEETRUE UK LTD overview (https://find-and-update.company-information.service.gov.uk/company/14001641):
“SEETRUE UK LTD
Company number 14001641
Registered office address
6.12 Central House 1 Ballards Lane, London, England, N3 1LQ
Company status Active
Company type Private limited Company
Incorporated on 25 March 2022
Accounts
Next accounts made up to 31 December 2025 due by 30 September 2026
Last accounts made up to 31 December 2024
Confirmation statement
Next statement date 24 March 2026 due by 7 April 2026
Last statement dated 24 March 2025
Nature of business (SIC)
62012 - Business and domestic software development
80200 - Security systems service activities”
The person with significant control details, SEETRUE UK LTD persons with significant control (https://find-and-update.company-information.service.gov.uk/company/14001641/persons-with-significant-control):
“SEETRUE UK LTD
Company number 14001641
0 active persons with significant control / 1 active statement
Statement Active
The company knows or has reasonable cause to believe that there is no registrable person or registrable relevant legal entity in relation to the company
Notified on
25 March 2022”
The Filing History was consulted to locate the Confirmation Certificates for SeeTrue UK Ltd to see if the investors are listed there, SEETRUE UK LTD filing history (https://find-and-update.company-information.service.gov.uk/company/14001641/filing-history):
The Confirmation Statement dated 24/03/2023 states, on page 3:
“Shareholding 1: Name: 100 ORDINARY shares held as at the date of this confirmation statement SEETRUE SCREENING LTD.”
The Confirmation Statement dated 24/03/2024 and 24/03/2025 provide no details about shareholding.
The Seetrue UK Ltd Annual Report up to 31/12/2023 states:
“9. Controlling party
The immediate parent undertaking is SeeTrue Screening Ltd, a company registered in Israel.
In the opinion of the director there is no controlling party.”
The Annual Report 2023, is in synch with the Confirmation Statement 2023, listing SeeTrue Screening Ltd as the parent undertaking. However the statement “In the opinion of the director there is no controlling party.”, in the annual report, appears to have been used to “exempt” SeeTrue UK Ltd from registering their person with significant control in Companies House, as they are required to do. This statement, in my opinion, is incorrectly used to “exempt” the ownership of this company from being stated in the Persons with significant control register, which is used by auditing and KYC software.
The Seetrue UK Ltd Annual Report up to 31/12/2024 states:
“10. Related party transactions
Control:
The immediate and ultimate parent company is Seetrue Ltd a company incorporated and registered in Israel whose registered office address is: Suite 35, Floor 11 Alon Tower, 94 Igal Alon Street, Tel Aviv, Israel 6789156. The smallest group in which the results of the Company are consolidated is that headed by Seetrue Ltd.”
During 2024 the immediate and ultimate parent company changed to Seetrue Ltd. This information should be recorded in Companies House in the Person with significant control register. However, the PSC register remains “The company knows or has reasonable cause to believe that there is no registrable person or registrable relevant legal entity in relation to the company”.
Seetrue UK Ltd fails to declare that the person with significant control is Seetrue Ltd, a company registered in Israel, in the required register in Companies House. This is a breach of the Companies Act 2006.
Opencorporates, database of international company registries, provides 15 results in a search for “Seetrue”, Advanced Search :: OpenCorporates (https://opencorporates.com/companies?utf8=%E2%9C%93&utf8=%E2%9C%93&q=seetrue&jurisdiction_code=&type=companies). These are copied below:
“SEETRUE CLEANING COMPANY (British Columbia (Canada), 2 Sep 2017- )
SEETRUE TECHNOLOGY, LLC (Maryland (US), 25 Sep 2017- , 26 HOLLYBERRY COURT, ROCKVILLE, MD, 20852)
SEETRUE UK LTD (United Kingdom, 25 Mar 2022- , 6.12 Central House 1 Ballards Lane, London, N3 1LQ)
SEETRUE, INC. (Delaware (US), 13 Nov 2018- , New Castle, DE)
branch SEETRUE, INC. (New York (US), 7 Nov 2025- , 418 BROADWAY STE R, ALBANY, NY, 12207)
inactive SeeTrue (Netherlands, Duitsepoort 13 A, Maastricht, 6221VA)
SeeTrue B.V. (Netherlands)
SeeTrue Base Holding B.V. (Netherlands)
SeeTrue Technologies Oy (Finland, 18 Apr 2018- )
inactive branch SeeTrue Technology, LLC (District of Columbia (US), 25 Sep 2017-24 Nov 2023, 26 Hollyberry Court,, Rockville, Maryland, 20852)
SeeTrue at Work B.V. (Netherlands)
branch SeeTrue at work (Belgium, 5 Jan 2020- , Vroelen 34, Noorbeek, 6255NC)
SeeTrue online B.V. (Netherlands)
סיטרו סקרינינג בע”מ (Israel, 3 May 2018- , 94 מגדל אלון 2 ,אלון יגאל, תל אביב - יפו, 6789139) Previously/Alternatively known as SEETRUE SCREENING
ซีทรู ดีไซน์ แอนด์ คอนสตรัคชั่น จำกัด (Thailand, 11 Apr 2012- , 105/20 ถนนห้วยแก้ว ช้างเผือก, เชียงใหม่, เมืองเชียงใหม่) Previously/Alternatively known as SEETRUE DESIGN AND CONSTRUCTION COMPANY LIMITED”
There are 15 companies named SeeTrue registered in multiple counties (Canada, US, Netherlands, Belgium, Israel, Thailand). The record for the company registered in Israel clarifies that Seetrue Screening is a previous or alternative name of Seetrue Ltd.
Accessing further details the record for the company registered in Israel was opened. This states:
““סיטרו סקרינינג בע”מ
Company Number
515840247
Status
Active (פעילה)
Incorporation Date
3 May 2018 (almost 8 years ago)
Company Type
Private Limited Company (לא - מוגבלת - ישראלית חברה פרטית)
Jurisdiction
Registered Address
94 מגדל אלון 2 ,אלון יגאל
תל אביב - יפו
6789139
ישראל
Alternative Names
SEETRUE SCREENING (alternative legal name in EN)
Data source and freshness
Last Update From Source
3 August 2024
Last Change Recorded
6 August 2024
Next update from source
Source offline (why?)
Source
The company record for Seefirst Ltd describes “Seetrue Screening” as an alternative legal name.
Lord Mandelson declares a Category 4(b) shareholding in “SeeTrue Ltd (AI technology)”, added 17 May 2022 and deleted 3 February 2025. No company with that exact name is registered at Companies House, All search results (https://find-and-update.company-information.service.gov.uk/search?q=seetrue).
The closest UK match is Seetrue UK Ltd (14001641), incorporated 25 March 2022, carrying on software development and security systems activities, SEETRUE UK LTD overview (https://find-and-update.company-information.service.gov.uk/company/14001641), with no registrable person or relevant legal entity recorded on the PSC register and a standing statement that “the company knows or has reasonable cause to believe that there is no registrable person or registrable relevant legal entity in relation to the company”, SEETRUE UK LTD persons with significant control (https://find-and-update.company-information.service.gov.uk/company/14001641/persons-with-significant-control.)
Seetrue UK Ltd’s own filings contradict this PSC position. The 24 March 2023 confirmation statement records 100 ordinary shares held by SeeTrue Screening Ltd, and the 2023 annual report identifies SeeTrue Screening Ltd, an Israeli company, as the immediate parent undertaking (Total exemption full accounts made up to 31 December 2023 View PDF). The 2024 annual report goes further, stating that the immediate and ultimate parent company is Seetrue Ltd, incorporated and registered in Israel, and that Seetrue Ltd heads the smallest consolidating group. Despite this, the UK PSC register has not been updated and still shows “no registrable person or registrable relevant legal entity” (Accounts for a small company made up to 31 December 2024 View PDF).
On the face of these filings, Seetrue Ltd (Israel) plainly meets the conditions to be recorded as a registrable relevant legal entity (immediate and ultimate parent with control over shares and votes). The failure to enter Seetrue Ltd as PSC and the continued use of a “no registrable PSC/RLE” statement indicate non‑compliance with the Companies Act 2006 Part 21A PSC regime (duty to identify PSCs, keep records up to date, and notify the registrar within the required time). This is a breach by Seetrue UK Ltd and its officers, and it directly compromises the reliability of UK registers and automated KYC for an overseas‑controlled AI/security company in which Lord Mandelson holds, or held, a declared interest.
The OpenCorporates data shows at least 15 “SeeTrue” entities across multiple jurisdictions (including Canada, US, Netherlands, Finland, Belgium, Israel and Thailand), with the Israeli company “סיטרו סקרינינג בע”מ” explicitly listing SEETRUE SCREENING as an alternative English legal name. This confirms a global group structure centred in Israel and illustrates how easily a generic “SeeTrue Ltd” register entry can obscure the fact that the real controlling mind lies in a foreign AI/screening firm. For the purposes of this assessment, Lord Mandelson’s “SeeTrue Ltd (AI technology)” holding should therefore be treated as an overseas AI/security exposure whose UK subsidiary has failed to comply with PSC disclosure rules, materially elevating sanctions, foreign‑influence and KYC risk.
12 iv. BlueVoyant
“Interest deleted 3 February 2025 BlueVoyant (cybersecurity services firm) (originally added 29 May 2023)”
A search in Companies House locates two companies that include this name, Company search results (https://find-and-update.company-information.service.gov.uk/search/companies?q=bluevoyant):
08259952 - Incorporated on 18 October 2012
16 Great Queen Street, London, England, WC2B 5AH
10907118 - Incorporated on 9 August 2017
16 Great Queen Street, Covent Garden, London, United Kingdom, WC2B 5AH”
The company records for the first company listed, BlueVoyant Limited, are copied below:
“BLUEVOYANT LTD
Company number 08259952
Follow this company File for this company
Registered office address
16 Great Queen Street, London, England, WC2B 5AH
Company status
Active
Company type
Private limited Company
Incorporated on
18 October 2012
Accounts
Next accounts made up to 31 December 2025
due by 30 September 2026Last accounts made up to 31 December 2024
Confirmation statement
Next statement date 3 August 2026
due by 17 August 2026Last statement dated 3 August 2025
Nature of business (SIC)
80100 - Private security activities
Previous company names
NamePeriodMARCLAY ASSOCIATES LTD18 Oct 2012 - 19 Jan 2022”
The current active person with significant control is provided as:
“BLUEVOYANT LTD
Company number 08259952
Follow this company File for this company
1 active person with significant control / 0 active statements
Marclay Group Ltd Active
Correspondence address
PO BOX 501, The Nexus Building, Broadway, Letchworth Garden City, England, SG6 9BL
Notified on
25 February 2021
Governing law
Companies Act 2006
Legal form
Private Company Limited By Shares
Place registered
England And Wales
Registration number
13198166
Incorporated in
England And Wales
Nature of control
Ownership of shares – 75% or more as a member of a firm
Ownership of voting rights - 75% or more as a member of a firm
Right to appoint or remove directors as a member of a firm.”
The Annual Report for the year ending 31 December 2023, available from the Filing history in Companies House, states, on page 9 (transcribed), BLUEVOYANT LTD filing history (https://find-and-update.company-information.service.gov.uk/company/08259952/filing-history):
“9. Related party transactions
The company has taken advantage of the exemption contained in FRS 102 section 33 “Related Party Disclosures” from disclosing transactions with entities which are a wholly owned part of the group.
Parent undertaking
The smallest group for which consolidated financial statements are drawn up is headed be BlueVoyant Inc., whose registered office is 335 Madison Ave, Suite 5G, New York, NY, 10017.
Auditor’s information
The auditor’s report on the financial statements for the year ended 31 December 2023 was unqualified.
The audit report was signed on 30 December 2024 by Mark Hart (senior statutory auditor) on behalf of Blick Rothenberg Audit LLP.”
The Annual Report 2023 claims:
“The company has taken advantage of the exemption contained in FRS 102 section 33 “Related Party Disclosures” from disclosing transactions with entities which are a wholly owned part of the group.” Is that the correct use of this section?
The Parent undertaking is “BlueVoyant Inc., whose registered office is 335 Madison Ave, Suite 5G, New York, NY, 10017” this is inconsistent with the PSC record in Companies House which lists Marclay Group Ltd, with registered address: PO BOX 501, The Nexus Building, Broadway, Letchworth Garden City, England, SG6 9BL, as the PSC.
The audit report was signed on 30 December 2024 by Mark Hart (senior statutory auditor) on behalf of Blick Rothenberg Audit LLP. A test to assess whether Blick Rothenberg have been making use of multiple identities as corporate officers, in Companies House was made by searching for officers named Blick Rothenberg, Officer search results (https://find-and-update.company-information.service.gov.uk/search/officers?q=Blick%20Rothenberg%20Audit%20LLP) which returned the following records:
Total number of appointments 2
16 Great Queen Street, Covent Garden, London, WC2B 5AH
Total number of appointments 5
16 Great Queen Street, Covent Garden, London, United Kingdom, WC2B 5AH
BLICK ROTHENBERG HOLDCO LIMITED
Total number of appointments 1
16 Great Queen Street, Covent Garden, London, United Kingdom, WC2B 5AH
Total number of appointments 1
16 Great Queen Street, Covent Garden, London, United Kingdom, WC2B 5AH
Total number of appointments 1
16 Great Queen Street, London, England, WC2B 5AH
Total number of appointments 2
1st Floor, 7-10 Chandos Street, London, W1G 9DQ
Total number of appointments 1
Palladium House, 1-4 Argyll Street, London, United Kingdom, W1F 7LD
Total number of appointments 1
16 Great Queen Street, Covent Garden, London, England, WC2B 5AH
Total number of appointments 1
12 York Gate, Regents Park, London, NW1 4QS”
Blick Rothenberg Audit LLP has two identities registered at the same physical location, one address including “United Kingdom”. This address variation defeats audit and KYC tools. The activities of this organisation and associated parties are compromised.
Total number of appointments 2
16 Great Queen Street, Covent Garden, London, WC2B 5AH
Total number of appointments 5
16 Great Queen Street, Covent Garden, London, United Kingdom, WC2B 5AH
I note that Blick Rothenberg Limited / LLP has six identities registered in Companies House with what is essentially the same name.
Total number of appointments 1
16 Great Queen Street, Covent Garden, London, United Kingdom, WC2B 5AH
Total number of appointments 1
16 Great Queen Street, London, England, WC2B 5AH
Total number of appointments 2
1st Floor, 7-10 Chandos Street, London, W1G 9DQ
Total number of appointments 1
Palladium House, 1-4 Argyll Street, London, United Kingdom, W1F 7LD
Total number of appointments 1
16 Great Queen Street, Covent Garden, London, England, WC2B 5AH
Total number of appointments 1
12 York Gate, Regents Park, London, NW1 4QS
Multiple identities are a red flag for breaches of the Companies Act and further investigation is indicated as necessary.
The Annual Report for BlueVoyant Ltd does not include mention of BLUEVOYANT UK LIMITED (10907118), incorporated on 9 August 2017 at “16 Great Queen Street, Covent Garden, London, United Kingdom, WC2B 5AH”, when it is clearly a related party. This is a further breach.
Bluevoyant Limited declare that Marclay Group Ltd is its Person with significant control. Referring to the record in Companies House for Marclay Group Ltd, the record is copied below, MARCLAY GROUP LTD persons with significant control (https://find-and-update.company-information.service.gov.uk/company/13198166/persons-with-significant-control):
“MARCLAY GROUP LTD
Company number 13198166
1 active person with significant control / 0 active statements
Bluevoyant Uk Limited Active
Correspondence address
16 Great Queen Street, London, England, WC2B 5AH
Notified on
30 June 2021
Governing law
Law Of England And Wales
Legal form
Limited Company
Place registered
Companies House
Registration number
10907118
Incorporated in
United Kingdom
Nature of control
Ownership of shares – 75% or more
Ownership of voting rights - 75% or more
Right to appoint or remove directors.”
The PSC of Marclay Group Ltd is BlueVoyant UK Limited.
The PSC record for BlueVoyant UK Limited was accessed and that declares “The company knows or has reasonable cause to believe that there is no registrable person or registrable relevant legal entity in relation to the company Notified on 9 August 2017”
Companies registered with the name “BlueVoyant”.
OpenCorporates provides the following results in a company search for BlueVoyant in all jurisdictions:
“branch 202 Group LLC (District of Columbia (US), 31 Dec 2018- , 1250 Connecticut Ave NW Suite 700,, Washington, District of Columbia, 20036) Previously/Alternatively known as BLUEVOYANT GOVERNMENT SOLUTIONS
BLUEVOYANT AUSTRALIA PTY LTD(Australia,13 Jun 2023- ,NEUTRAL BAY, New South Wales, 2089)
BLUEVOYANT CANADA INC.(Ontario (Canada),28 May 2019- ,Toronto, Ontario)
BLUEVOYANT FRANCE SAS(France,5 May 2022- ,1 PLACE BOIELDIEU, PARIS, PARIS, 75002)
BLUEVOYANT FUND INVESTOR II LLC(Delaware (US),9 Apr 2019- ,New Castle, DE)
BLUEVOYANT FUND INVESTOR III LLC(Delaware (US),6 Jul 2020- ,New Castle, DE)
BLUEVOYANT FUND INVESTOR IV LLC(Delaware (US),6 Jul 2020- ,New Castle, DE)
BLUEVOYANT FUND INVESTOR LLC(Delaware (US),11 Jul 2017- )
BLUEVOYANT FUND INVESTOR V LLC(Delaware (US),11 Feb 2022- ,New Castle, DE)
BLUEVOYANT FUND INVESTOR VI LLC(Delaware (US),2 Mar 2022- ,New Castle, DE)
BLUEVOYANT HUNGARY(France,21 Mar 2022- ,RUE KAROLYI 12, 1053 BUDAPEST)
BLUEVOYANT INVESTOR LLC(Delaware (US),5 Jul 2017- )
BLUEVOYANT IRELAND LIMITED(Ireland,11 Mar 2025- ,10 Earlsfort Terrace, Dublin 2, DUBLIN, D02 T380, Ireland, D02 T380)
inactivebranchBLUEVOYANT LLC(Maryland (US),16 May 2018- ,SUITE 5G, 335 MADISON AVENUE, NEW YORK, NY, 10017)
BLUEVOYANT LLC(Delaware (US),28 Mar 2017- )
branchBLUEVOYANT LLC(New Jersey (US),17 Dec 2021- )
inactivebranchBLUEVOYANT LLC(California (US),22 May 2018-1 May 2025,6 EAST 43RD ST 25TH FL, NEW YORK, NY, 10017)
inactivebranchBLUEVOYANT LLC(Texas (US),7 Jan 2020-24 Jun 2022,335 MADISON AVENUE, 5TH FLOOR, NEW YORK, NY, 10017)
branchBLUEVOYANT LLC(New York (US),23 May 2018- ,28 LIBERTY ST., NEW YORK, NY, 10005)
BLUEVOYANT LTD(United Kingdom,18 Oct 2012- ,16 Great Queen Street, London, WC2B 5AH)
inactivebranchBLUEVOYANT MANAGEMENT LLC(Washington (US),6 Jan 2020-3 May 2021,335 MADISON AVE RM 5G, NEW YORK, NY, 10017-4773)
inactivebranchBLUEVOYANT MANAGEMENT LLC(Utah (US),23 Feb 2022-28 Feb 2023,335 Madison Ave Suite 5G, New York, NY, 10017)
BLUEVOYANT MANAGEMENT LLC(Delaware (US),12 Jun 2017- )
inactivebranchBLUEVOYANT MANAGEMENT LLC(Hawaii (US),4 Jan 2022- )
BLUEVOYANT MERGER SUB I LLC(Delaware (US),3 May 2022- ,New Castle, DE)
BLUEVOYANT MERGER SUB II LLC(Delaware (US),3 May 2022- ,New Castle, DE)
BLUEVOYANT MERGER SUB III LLC(Delaware (US),3 May 2022- ,New Castle, DE)
BLUEVOYANT MERGER SUB IV LLC(Delaware (US),3 May 2022- ,New Castle, DE)
BLUEVOYANT MERGER SUB V LLC(Delaware (US),3 May 2022- ,New Castle, DE)
BLUEVOYANT MERGER SUB VI LLC(Delaware (US),3 May 2022- ,New Castle, DE)
BLUEVOYANT MERGER SUB VII LLC (Delaware (US), 3 May 2022- , New Castle, DE)
BLUEVOYANT PTE. LTD.(Singapore,6 Aug 2021- ,9 RAFFLES PLACE, #26-01, REPUBLIC PLAZA, 048619)
BLUEVOYANT SPECIAL CONTRACTING LLC(Delaware (US),11 Aug 2020- ,New Castle, DE)
BLUEVOYANT UK LIMITED(United Kingdom,9 Aug 2017- ,16 Great Queen Street Covent Garden, London, WC2B 5AH)
BLUEVOYANT, INC.(Delaware (US),3 May 2022- ,New Castle, DE)
BlueVoyant Denmark ApS(Denmark,9 Jun 2022- ,c/o Skau Reipurth Advokatpartnerselskab Amaliegade 37, København K, 1256)
BlueVoyant Germany GmbH(Germany,c/o Cormoran GmbH, Am Zirkus 2, 10117 Berlin)
branchBlueVoyant LLC(California (US),20 Jan 2023- ,6 E 45TH ST., 17TH FLOOR, NEW YORK, NY, 10017)
VALOR BLUEVOYANT GP HOLDINGS, LLC(Delaware (US),3 Feb 2022- ,New Castle, DE)
VALOR BLUEVOYANT HOLDINGS L.P.(Delaware (US),3 Feb 2022- ,New Castle, DE)
בלוויאנט ישראל בע”מ(Israel,7 Nov 2013- ,3 מרכז עזריאלי, תל אביב - יפו)Previously/Alternatively known as BLUEVOYANT ISRAEL”
The records for Bluevoyant, Inc. were accessed in the State of Delaware, Division of Corporations - Filing (https://icis.corp.delaware.gov/Ecorp/EntitySearch/NameSearch.aspx):
“Entity Details
THIS IS NOT A STATEMENT OF GOOD STANDINGFile Number:6775975Incorporation Date / Formation Date:5/3/2022
(mm/dd/yyyy)Entity Name:BLUEVOYANT, INC.Entity Kind:CorporationEntity Type:GeneralResidency:DomesticState:DELAWAREREGISTERED AGENT INFORMATIONName:THE CORPORATION TRUST COMPANYAddress:CORPORATION TRUST CENTER 1209 ORANGE STCity:WILMINGTONCounty:New CastleState:DEPostal Code:19801Phone:302-658-7581”
The registered address in the State of Delaware registry is “CORPORATION TRUST CENTER 1209 ORANGE STCity:WILMINGTONCounty:New CastleState:DE”. In the Annual Report for the year ending 31 December 2023, the registered address provided for BlueVoyant, Inc. was given as “BlueVoyant Inc., whose registered office is 335 Madison Ave, Suite 5G, New York, NY, 10017”. This inconsistency is significant and requires further investigation. This represents several legal breaches.
Reflecting on the breaches evident and the global reach of companies with this name multiple risks are flagged.
Assessment: BlueVoyant – Category 4b) shareholder declaration and related risks
Lord Mandelson declares a Category 4(b) shareholding in “BlueVoyant (cybersecurity services firm)”, added 29 May 2023 and deleted 3 February 2025. Two UK companies carry the BlueVoyant name: BlueVoyant Ltd (08259952), incorporated 18 October 2012, and BlueVoyant UK Limited (10907118), incorporated 9 August 2017, both at 16 Great Queen Street, London WC2B 5AH. BlueVoyant Ltd’s PSC register shows Marclay Group Ltd as the person with significant control from 25 February 2021, whereas its 2023 Annual Report identifies BlueVoyant Inc., 335 Madison Ave, New York, as the parent undertaking. That inconsistency between the UK PSC record and the accounts’ statement of the controlling group raises clear questions over the accuracy and completeness of the PSC disclosures and the reliability of the group structure presented to Companies House.
The 2023 Annual Report states that BlueVoyant Ltd has taken advantage of the FRS 102 section 33 exemption from disclosing related‑party transactions with wholly‑owned group entities. That exemption applies only where intra‑group transactions occur within a 100%‑owned group and where group accounts provide the relevant information; it does not remove the statutory duty under Part 21A Companies Act 2006 to maintain an accurate PSC register. Using the existence of a group parent to justify the absence of any individual or corporate PSC other than Marclay Group Ltd, when the accounts themselves point to BlueVoyant Inc. as the group head, suggests that the PSC position has not been properly updated and may be in breach of the duties to identify and notify registrable persons or relevant legal entities.
Separately, the audit is signed by Blick Rothenberg Audit LLP, an audit firm that appears on Companies House with multiple near‑identical officer identities (two separate “Blick Rothenberg Audit LLP” officer records at the same Great Queen Street address, plus several “Blick Rothenberg Limited/LLP” and “Blick Rothenberg” officer entries at overlapping addresses). This pattern of repeated, minimally varied officer names and address strings is a recognised red flag: it degrades name‑ and address‑matching in KYC and audit software and complicates the task of identifying which legal entity actually carried out the audit. In the context of a cybersecurity services firm with US and UK operations, this layering of opaque PSC records and a multi‑identity audit firm materially increases the risk that sanctions, financial‑crime and foreign‑influence exposures are not correctly captured in automated screening.
The Annual Report for BlueVoyant Ltd does not mention BlueVoyant UK Limited (10907118), even though it shares the same address and clearly forms part of the UK BlueVoyant structure. Omitting this entity from related‑party disclosures undermines the spirit of FRS 102 section 33 and further weakens the transparency of intra‑group relationships. Overall, the BlueVoyant case combines: (i) an overseas‑headed cybersecurity group, (ii) inconsistent PSC and parent‑company information, (iii) incomplete related‑party disclosure within the UK sub‑group, and (iv) an audit signed by a firm with multiple near‑duplicate Companies House identities. Against that backdrop, Lord Mandelson’s BlueVoyant shareholding should be treated as a high‑risk overseas cybersecurity exposure whose UK corporate and audit footprint is materially opaque, with clear implications for sanctions, KYC and conflict‑of‑interest assessment.
BlueVoyant’s global structure and disclosures present significant transparency, PSC and KYC risks that go well beyond a routine overseas technology investment.
Across jurisdictions, the BlueVoyant name appears on a large number of entities: operating companies (BlueVoyant LLC, BlueVoyant Ltd, BlueVoyant UK Limited, BlueVoyant Australia Pty Ltd, BlueVoyant Canada Inc., BlueVoyant France SAS, BlueVoyant Ireland Limited, BlueVoyant Denmark ApS, BlueVoyant Germany GmbH, BlueVoyant Israel), government‑facing or “special contracting” vehicles (BlueVoyant Government Solutions, BlueVoyant Special Contracting LLC), and multiple Delaware fund and merger LLCs (BlueVoyant Fund Investor I–VI LLC, BlueVoyant Merger Sub I–VII LLC, Valor BlueVoyant structures). This demonstrates a complex, globally distributed cybersecurity and defence‑adjacent group with layered holding, fund and contracting vehicles spread across the US, EU, UK, Israel and Asia.
Against that background, the UK disclosures are materially deficient. BlueVoyant Ltd shows Marclay Group Ltd as its person with significant control; Marclay Group Ltd, in turn, shows BlueVoyant UK Limited as its person with significant control; and BlueVoyant UK Limited relies on a “no registrable person or registrable relevant legal entity” statement. This circular PSC chain means that each UK company points to another, while the true group head is left off the UK PSC register entirely, despite BlueVoyant Ltd’s 2023 accounts naming BlueVoyant, Inc. (Delaware) as the parent. That pattern defeats the purpose of the Persons with Significant Control regime in Part 21A Companies Act 2006, which is to identify the ultimate beneficial owner; it frustrates sanctions and KYC screening by leaving the group head invisible in the UK PSC data.
The incorporation record for BlueVoyant, Inc. in Delaware shows the usual registered‑agent address at Corporation Trust Center, 1209 Orange Street, Wilmington, Delaware. The BlueVoyant Ltd Annual Report instead describes BlueVoyant, Inc.’s “registered office” as 335 Madison Ave, Suite 5G, New York, NY 10017. This discrepancy between the official state registry address and the address claimed in the UK accounts is another signal that BlueVoyant’s group information is not being presented consistently across jurisdictions. In a sector as sensitive as cybersecurity and government contracting, such inconsistencies are not merely technical: they impede reliable cross‑border identification of the controlling entity and raise questions about whether investors, regulators and counterparties can tell exactly which company they are dealing with.
Taken together, the global OpenCorporates footprint, the circular PSC structure in the UK, the mismatch between Delaware and UK descriptions of BlueVoyant, Inc., and the use of an audit firm (Blick Rothenberg) that itself appears under multiple near‑duplicate officer identities, create a dense cluster of red flags. For Lord Mandelson, a declared BlueVoyant shareholding places him within a high‑risk, globally distributed cybersecurity group where the ultimate controller is obscured from the UK PSC register and where cross‑border corporate records are inconsistent. Any due‑diligence or policy assessment should treat this as a serious foreign‑influence, sanctions‑screening and audit‑integrity risk, not as a routine technology investment.
13. Open Britain Ltd
Lord Mandelson declared in his Register of Interest, relating to Open Britain Ltd:
“Interest deleted 8 September 2017 Board Member, Britain Stronger in Europe (name changed to Open Britain Ltd on 6 September 2016) (interest ceased 6 September 2016) (originally added 4 April 2016)
Interest deleted 13 November 2020 Director, Open Britain Ltd (formerly Britain Stronger in Europe) (interest ceased 12 November 2019) (originally added 23 December 2016)”
A search in Companies House locates two companies that have used this name, All search results (https://find-and-update.company-information.service.gov.uk/search?q=open+britain):
09641190 - Incorporated on 16 June 2015
22 St. Peters Street, Stamford, England, PE9 2PF
06168203 - Dissolved on 4 December 2012
Premier House, Queen Street, Horsham, West Sussex, United Kingdom, RH13 5AD
16797637 - Incorporated on 20 October 2025
22 St Peter’s Street, Stamford, United Kingdom, PE9 2PF”
The company overview for the active Open Britain Limited is copied below OPEN BRITAIN LIMITED overview (https://find-and-update.company-information.service.gov.uk/company/09641190):
“OPEN BRITAIN LIMITED
Company number 09641190
Follow this company File for this company
Registered office address
22 St. Peters Street, Stamford, England, PE9 2PF
Company status
Active
Company type
Private company limited by guarantee without share capital
Incorporated on
16 June 2015
Accounts
Next accounts made up to 31 August 2025
due by 31 May 2026Last accounts made up to 31 August 2024
Confirmation statement
Next statement date 16 June 2026
due by 30 June 2026Last statement dated 16 June 2025
Nature of business (SIC)
94990 - Activities of other membership organisations not elsewhere classified
Previous company names
NamePeriod THE IN CAMPAIGN LIMITED 23 Jul 2015 - 06 Sep 2016 INTERIM CAMPAIGN LIMITED 16 Jun 2015 - 23 Jul 2015”
Lord Mandelson incorrectly stated that the previous name of Open Britain Limited was “Britain Stronger in Europe”, whereas this company was previously called “The In Campaign Limited and the Interim Campaign Limited”. This is a red flag.
It is my understanding that a name should only appear once in the register, whereas the Name “Open Britain Limited” had previously been used. The company overview record is copied below.
“OPEN BRITAIN LIMITED
Company number 06168203
Registered office address
Paul Davidson Taylor, Premier House, Queen Street, Horsham, West Sussex, United Kingdom, RH13 5AD
Company status
Dissolved
Dissolved on
4 December 2012
Company type
Private limited Company
Incorporated on
19 March 2007
Accounts
Last accounts made up to 31 March 2011
Nature of business (SIC)
2211 - Publishing of books
Previous company names
NamePeriodDDL30 LIMITED19 Mar 2007 - 25 Jul 2009”
The last accounts were made up to 31 March 2011, the company was dissolved on 4 December 2012. The accounts made up to 31 March 2012 were not submitted.
Bank accounts in this company name will have reverted to the Crown. It is possible that these bank accounts are still active and could be utilised in clone company fraud.
The first director listed as an officer of Open Britain Limited is Andrew Peter DIGGLES. His identity , his appointments are copied in Appendix B.
Risk assessment for Open Britain Limited
Lord Mandelson’s Open Britain declarations sit against a background of muddled corporate naming, incomplete Companies House compliance, and potential clone‑risk around the “Open Britain Limited” label.
Mandelson records board and directorship roles in “Britain Stronger in Europe (name changed to Open Britain Ltd on 6 September 2016)” and “Open Britain Ltd (formerly Britain Stronger in Europe)”. In fact, the active campaigning vehicle is Open Britain Limited (09641190), previously called Interim Campaign Limited and The In Campaign Limited, not “Britain Stronger in Europe”. The separate Open Britain Limited (06168203) – a publishing company dissolved in 2012 – used the same name earlier and failed to file its final set of accounts before dissolution, leaving the 2012 year missing. This duplication of the “Open Britain Limited” name, combined with one entity’s incomplete filing history, creates a realistic risk that dormant bank accounts or the historic name could be exploited in clone‑company fraud or misdirected donations.
At the level of the Lords Register, Mandelson’s mis‑description of the predecessor name (“Britain Stronger in Europe” instead of “The In Campaign Limited”) is a technical inaccuracy. On its own, it does not conceal the existence of the campaigning company, but it does weaken the clarity of the record and makes it harder for a reader or KYC system to reconcile his entry to a specific Companies House number. Given that an earlier, unrelated “Open Britain Limited” existed and failed to submit final accounts, precision in naming is not a cosmetic issue but a basic safeguard against confusion and abuse of political‑campaign branding.
The officer trail for the dissolved Open Britain Limited (06168203) shows a high‑volume corporate services director, Andrew Peter Diggles, associated with dozens of dissolved publishing and services companies at the same Reigate address. That pattern is typical of mass‑incorporation service providers and amplifies the risk that “Open Britain Limited” can be treated as a generic shell label rather than as a clearly bounded political entity. In this context, Mandelson’s inaccurate description of the company’s former name and the recycling of “Open Britain Limited” across different companies both count as red flags: they undermine the transparency and traceability that the Lords Code of Conduct and the Companies Act 2006 are designed to secure, and they raise a non‑trivial risk of clone‑style misuse of the Open Britain brand in financial or political transactions.
Names associated with Andrew Peter Diggles that begin with “UN” – such as UN Financial Investments Limited and UN Acquisitions (Hong Kong) Limited – carry heightened risk in the current political context and should be treated as red‑flag indicators in any compliance assessment.
Today, “UN” is widely understood as shorthand for the United Nations. Although Companies Act 2006 allows many names in practice, section 76 permits intervention where a company name gives a misleading indication of the nature of its activities and poses a risk of harm to the public. In the post–Economic Crime and Corporate Transparency Act environment, Companies House also has strengthened powers and an explicit mandate to challenge and remove misleading or clone‑style names, especially where they suggest a false connection to public bodies or international institutions.
Against that background, historic entities styled “UN Financial Investments Limited” or “UN Acquisitions (Hong Kong) Limited”, combined with mass‑use of a corporate services address and a director with dozens of dissolved companies, present several specific risks:
Implied institutional association: Use of “UN” in a financial‑services or acquisitions context can easily create the impression of a link to the United Nations, its agencies, or UN‑branded development/finance programmes. In the modern sanctions and AML environment, that implication is itself dangerous: it can be exploited to gain trust from counterparties, donors or politically exposed persons on the false assumption of multilateral backing.
Clone‑company and fraud risk: Cloning guidance notes that criminals often choose names that closely resemble well‑known institutions or brands and differ only by small details. “UN Financial Investments” or “UN Acquisitions” is exactly the kind of label that can be used to open bank accounts, solicit funds or sign contracts under a misleading banner, especially when combined with the fact that dissolved‑company bank balances pass to the Crown and accounts are frozen – something that many laypeople do not understand.
Screening and perception risk for public office: For a peer of the realm, any association – even indirect – with name‑formations that could be read as trading on the “UN” brand heightens reputational risk and demands especially careful disclosure and distancing. In a political climate highly sensitive to foreign influence, deception and misuse of trusted logos or acronyms, such names will understandably attract regulatory and media scrutiny.
In short, the presence of multiple “UN‑prefixed” companies in the Diggles portfolio, all routed through a bulk corporate‑services address and many now dissolved, is not a neutral historical detail. It is a pattern that sits squarely within current company‑cloning and misleading‑name risk typologies, and it underscores why precision and clarity in Lord Mandelson’s own declarations around Open Britain and related entities are essential to avoid any confusion with legacy vehicles that might appear, at a glance, to be connected with international bodies or official initiatives.
14. Willbury Limited, Category 1: Directorships
A search in Companies House locates five companies that have registered with the name “Willbury”, All search results (https://find-and-update.company-information.service.gov.uk/search?q=willbury).
07265891 - Incorporated on 26 May 2010
B1 Vantage Business Park Old Gloucester Road, Hambrook, Bristol, United Kingdom, BS16 1GW
06558824 - Incorporated on 8 April 2008
Fairways House, George Street, Manchester, M25 9WS
08837630 - Incorporated on 9 January 2014
Morgan House Gilbert Drive, Wyberton Fen, Boston, Lincolnshire, PE21 7TQ
15148287 - Incorporated on 19 September 2023
Ty Alaw Bridgend Road, Llanharan, Pontyclun, Wales, CF72 9RP
WILLBURY BUIDLING SERVICES LTD
08076173 - Dissolved on 18 September 2012
C/O The Vault 47 Bury New Road Prestwich, Manchester, United Kingdom, M25 9JY”.
14a. Willbury Limited.
“Interest deleted 3 February 2025 Director, Willbury Limited (trading entity for member’s public speaking/writing; remuneration for work listed in category 2 is paid to Willbury Limited where indicated) (originally added 1 October 2010)”
“WILLBURY LIMITED
Company number 07265891
Follow this company File for this company
Registered office address
B1 Vantage Business Park Old Gloucester Road, Hambrook, Bristol, United Kingdom, BS16 1GW
Company status
Active
Company type
Private limited Company
Incorporated on
26 May 2010
Accounts
Next accounts made up to 31 March 2025
due by 31 March 2026Last accounts made up to 31 March 2024
Confirmation statement
Next statement date 26 May 2026
due by 9 June 2026Last statement dated 26 May 2025
Nature of business (SIC)
70229 - Management consultancy activities other than financial management
90030 - Artistic creation”
Compliance observation: The combination of SIC 70229 (management consultancy other than financial management) and 90030 (artistic creation) is not unlawful, but it does create a mixed profile in which a single personal service company presents simultaneously as a professional consultancy and as a creative/entertainment vehicle. Given that these sectors carry very different expectations around documentation, independence and KYC, this dual classification is a relevant red flag for risk assessment: it increases the scope for income from loosely documented ‘artistic’ or media work to be routed through a company that also holds itself out as a policy and management consultancy.
The officer details are, WILLBURY LIMITED people (https://find-and-update.company-information.service.gov.uk/company/07265891/officers):
“WILLBURY LIMITED
Company number 07265891
4 officers / 2 resignations
Correspondence address
B1 Vantage Business Park, Old Gloucester Road, Hambrook, Bristol, United Kingdom, BS16 1GW
Role Active
Director
Date of birth
September 1972
Appointed on
1 April 2011
Nationality
British
Country of residence
United Kingdom
Identity verification due
9 June 2026
MANDELSON, Peter Benjamin, Lord
Correspondence address
B1 Vantage Business Park, Old Gloucester Road, Hambrook, Bristol, United Kingdom, BS16 1GW
Role Active
Director
Date of birth
October 1953
Appointed on
15 June 2010
Nationality
British
Country of residence
United Kingdom
Identity verification due
9 June 2026
Correspondence address
6th Floor, 2 London Wall Place, London, England, EC2Y 5AU
Role Resigned
Secretary
Appointed on
8 December 2010
Resigned on
9 February 2026
Correspondence address
Winnington House, 2 Woodberry Grove, North Finchley, London, United Kingdom, N12 0DR
Role Resigned
Director
Date of birth
June 1931
Appointed on
26 May 2010
Resigned on
15 June 2010
Nationality
British
Country of residence
United Kingdom”
There are two active directors, Lord Mandelson and Reinaldo Avila Da Silva, and two resigned directors, Maree Gail Glass and Barbara Kahan. Each of these directors will be research further to make explicit their other interests, held in these identities. Each will be assessed to establish whether they have more than one identity registered in Companies House, which, when present, has the effect of concealing interests, held in those other identities, from the public, auditors and KYC software.
14b. Reinaldo AVILA DA SILVA
The appointments held in this identity are copied below, Reinaldo AVILA DA SILVA personal appointments (https://find-and-update.company-information.service.gov.uk/officers/4oWSZGzs4S8NVi8jy_rfLzMPMCg/appointments):
“Reinaldo AVILA DA SILVA
Total number of appointments 2
Date of birth
September 1972
Company status
Active
Correspondence address
B1 Vantage Business Park, Old Gloucester Road, Hambrook, Bristol, United Kingdom, BS16 1GW
Role Active
Director
Appointed on
1 April 2011
Nationality
British
Country of residence
United Kingdom
Identity verification due
9 June 2026
Company status
Active
Correspondence address
The Former Rectory, Back Lane, Ingoldsby, Grantham, England, NG33 4EW
Role Resigned
Director
Appointed on
26 February 2010
Resigned on
7 November 2022
Nationality
British
Country of residence
United Kingdom”
Lord Mandelson’s codirector at Willbury Limited, Reinaldo Avila Da Silva, was a director of The Nurture Centre appointed on 26 February 2010 and resigned on 7 November 2022.
14c. The Nurture Centre
THE NURTURE CENTRE overview (https://find-and-update.company-information.service.gov.uk/company/07171364)
“THE NURTURE CENTRE
Company number 07171364
Follow this company File for this company
Registered office address
The Former Rectory Back Lane, Ingoldsby, Grantham, England, NG33 4EW
Company status
Active
Company type
Private Limited Company by guarantee without share capital use of ‘Limited’ exemption
Incorporated on
26 February 2010
Accounts
Next accounts made up to 28 February 2026
due by 30 November 2026Last accounts made up to 28 February 2025
Confirmation statement
Next statement date 16 February 2026
due by 2 March 2026Last statement dated 16 February 2025
Nature of business (SIC)
86900 - Other human health activities”
The nature of business (SIC 86900) is “Other human health activities”.
The presence of a co‑director, Reinaldo Avila Da Silva, who also held a long‑running directorship in a health‑sector company (SIC 86900 – other human health activities) increases the importance of scrutinising any cross‑flows of business or remuneration between Willbury Limited and entities operating in health and care, particularly where public funds or vulnerable groups may be involved. This company will be further assessed.
THE NURTURE CENTRE people (https://find-and-update.company-information.service.gov.uk/company/07171364/officers). The active and recently resigned officers, only, are copied below. The complete officer record is provided in Appendix C.
Active and recently resigned officers:
“THE NURTURE CENTRE
Company number 07171364
14 officers / 12 resignations
Correspondence address
The Former Rectory, Back Lane, Ingoldsby, Grantham, England, NG33 4EW
Role Active
Secretary
Appointed on
7 November 2022
Correspondence address
The Former Rectory, Back Lane, Ingoldsby, Grantham, Lincs, England, NG33 4EW
Role Active
Director
Date of birth
October 1960
Appointed on
2 May 2023
Nationality
British
Country of residence
England
Identity verification due
2 March 2026
Correspondence address
The Former Rectory, Back Lane, Ingoldsby, Grantham, England, NG33 4EW
Role Resigned
Director
Date of birth
November 1964
Appointed on
17 January 2020
Resigned on
10 February 2026
Nationality
British
Country of residence
England
Identity verification due
2 March 2026”
Presently there is just one active director and secretary of this company, Timothy Charles Arnold, date of birth October 1960. Note that in the “appointments” record for Timothy Charles Arnold, see above and /or here, he had just two appointments, as a director of Willbury Limited and as a director of The Nurture Centre.
By clicking on his name as the secretary, a second identity for Timothy Charles Arnold is returned. The appointments held in this identity are copied below (Timothy Charles ARNOLD personal appointments identity 2 (https://find-and-update.company-information.service.gov.uk/officers/wFrnpuwvwdBNg-fGfLGEtK9BpyY/appointments):
“Timothy Charles ARNOLD
Total number of appointments 1
Company status
Active
Correspondence address
The Former Rectory, Back Lane, Ingoldsby, Grantham, England, NG33 4EW
Role Active
Secretary
Appointed on
7 November 2022”
This second record can cause audit and KYC checks to fail to pick up his directorship at Willbury Limited, so his association with Willbury is effectively concealed from any user or system that relies only on this officer identity.
The record for Persons with significant control provides a statement THE NURTURE CENTRE persons with significant control (https://find-and-update.company-information.service.gov.uk/company/07171364/persons-with-significant-control):
“The company knows or has reasonable cause to believe that there is no registrable person or registrable relevant legal entity in relation to the company
Notified on
16 February 2017”
THE NURTURE CENTRE filing history (https://find-and-update.company-information.service.gov.uk/company/07171364/filing-history.) The table of the most recent filing records are copied below:
“Date Description View / Download
25 Feb 2026Termination of appointment of Mark Jones as a director on 10 February 2026
View PDF (1 page)
19 Mar 2025Accounts for a dormant company made up to 28 February 2025
View PD F (5 pages)
11 Mar 2025Confirmation statement made on 16 February 2025 with no updates
View PDF (3 pages)
11 Mar 2025Director’s details changed for Mr Mark Jones on 17 January 2020
View PDF (2 pages)
10 Mar 2025Director’s details changed for Mr Mark Jones on 15 March 2024
View PDF (2 pages)
05 Sep 2024Accounts for a dormant company made up to 29 February 2024
View PDF (5 pages)
26 Feb 2024Confirmation statement made on 16 February 2024 with no updates
View PDF (3 pages)
17 Nov 2023Termination of appointment of Ash Fryatt as a director on 10 November 2023
View PDF (1 page)
29 Sep 2023Accounts for a dormant company made up to 28 February 2023
View PDF (4 pages)
02 May 2023Appointment of Mr Timothy Charles Arnold as a director on 2 May 2023
View PDF (2 pages)
17 Mar 2023Termination of appointment of Andrew Ruocco as a director on 6 March 2023
View PDF (1 page)
16 Mar 2023Confirmation statement made on 16 February 2023 with no updates
View PDF (3 pages)
The accounts provide are for a “dormant company”. The most recent accounts made up to 28 February 2025 are titled “The Nurture Centre Filleted Accounts Cover”, View PDF. These state (transcribed):
“The Nurture Centre Directors Report Registrar
The Directors present their report and the accounts for the year ended 28 February 2025.
Principal activities
The company is dormant and has not traded during the year.
Directors
The Directors who served at any time during the year were as follows:
T.C. Arnold
M. Jones
The above report has been prepared in accordance with the provisions applicable to companies subject to the small companies regime as set out in Part 15 of the Companies Act 2006.
Signed on behalf of the board
T.C. Arnold
28 February 2025”
Although The Nurture Centre files as a dormant, non‑trading company limited by guarantee with ‘Limited’ exemption (a status normally reserved for genuine not‑for‑profit bodies), its pattern of regular officer changes and close linkage to a director of Willbury Limited indicates that it is being actively maintained as a potential vehicle rather than genuinely abandoned. In the absence of any trading, the ongoing effort to keep the company live warrants scrutiny as to what future health‑ or care‑sector activities, funding or contracts it may be intended to front.
The Register of Charities was referenced and a search made for “The Nurture Centre”, Search the register of charities (https://register-of-charities.charitycommission.gov.uk/en/charity-search/-/results/page/1/delta/20/keywords/the+nurture+centre?_uk_gov_ccew_portlet_CharitySearchPortlet_cur=1&_uk_gov_ccew_portlet_CharitySearchPortlet_delta=20&_uk_gov_ccew_portlet_CharitySearchPortlet_keywords=the+nurture+centre).
A record is presented for charity number 1140388 names “THE NURTURE CENTRE”, which is registered with zero income. The reporting status is flagged in red as “Charity reporting is overdue by 62 days”. A further red flag.
THE NURTURE CENTRE - 1140388 Trustees:
“2 Trustee(s)
Name Role Date of appointment Other trusteeships Reporting status of other trusteeships
Timothy Charles Arnold
Trustee
06 March 2023
None on record
Dr Mark Jones
Trustee
17 January 2020
None on record”
THE NURTURE CENTRE - 1140388, What, who, how, where:
“What the charity does:
The Advancement Of Health Or Saving Of Lives
Disability
Who the charity helps:
Children/young People
Elderly/old People
People With Disabilities
The General Public/mankind
How the charity helps:
Provides Buildings/facilities/open Space
Provides Services
Where the charity operates:
Throughout England”
“Address:
The Former Rectory
Back Lane
Ingoldsby
GRANTHAM
Lincolnshire
NG33 4EWPhone:
01476586855
Email:
Website:
No information available”
An internet search was made for “The Nurture Centre”. The first search result returned is:
https://www.thenurturecentre.co.uk › home
The Nurture Centre | Inspire and Empower
Discover inclusive activities fostering development, confidence, and friendships for young people with special needs at The Nurture Centre.”
Accessing this website, the company information is located at the bottom of each page:
“The Nurture Centre
The Nurture Centre part of the The Care Collective Group,
Dooley Sports & Community,
Weston View, Sheffield, S10 5BZCompany Registration. 16030359
T. 0333 200 0701
E. hello@thenurturecentre.co.uk.”
Accessing the records for the company via a search on the company registration number given, in Companies House, locates a company called The Care Collective Group.
14d. The Care Collective Group Ltd
THE CARE COLLECTIVE GROUP LTD overview (https://find-and-update.company-information.service.gov.uk/company/16030359)
“THE CARE COLLECTIVE GROUP LTD
Company number 16030359
Follow this company File for this company
Registered office address
22 Gatefield Road, Sheffield, South Yorkshire, United Kingdom, S7 1RD
Company status
Active
Company type
Private limited Company
Incorporated on
21 October 2024
Accounts
First accounts made up to 31 October 2025
due by 21 July 2026Confirmation statement
Next statement date 20 October 2026
due by 3 November 2026Last statement dated 20 October 2025
Nature of business (SIC)
87900 - Other residential care activities not elsewhere classified
88910 - Child day-care activities”
THE CARE COLLECTIVE GROUP LTD people (https://find-and-update.company-information.service.gov.uk/company/16030359/officers):
“THE CARE COLLECTIVE GROUP LTD
Company number 16030359
2 officers / 0 resignations
Correspondence address
22 Gatefield Road, Sheffield, South Yorkshire, United Kingdom, S7 1RD
Role Active
Director
Date of birth
January 1986
Appointed on
21 October 2024
Nationality
British
Country of residence
United Kingdom
Identity verification due
3 November 2026
Correspondence address
22 Gatefield Road, Sheffield, South Yorkshire, United Kingdom, S7 1RD
Role Active
Director
Date of birth
September 1979
Appointed on
21 October 2024
Nationality
British
Country of residence
United Kingdom
Identity verification due
3 November 2026”
Testing these directors for multiple identities, a search was made on each name in Companies House.
Mohsin AHMED (Date of birth January 1986)
A search on this name returns forty-two identities with this name and with a range of date of births. There are multiple identities for Mohsin Ahmed, date of birth January 1986. A selection have been copied below. The selected records include some identities which do not contain a date of birth, since these contain secretary appointments, for which the date of birth is not recorded.
Total number of appointments 1 - Born January 1986
4 Kenwood Bank, Sheffield, South Yorkshire, United Kingdom, S7 1NU
Total number of appointments 1 - Born January 1986
197-199, Main Road, Sheffield, United Kingdom, S9 5HP
Total number of appointments 1
Pentax House, South Hill Avenue, South Harrow, United Kingdom, HA20DU
Total number of appointments 1
38 Evington Drive, Leicester, England, LE5 5PB
Total number of appointments 1
22 Lynmouth Road, Sheffield, United Kingdom, S7 2DF
Total number of appointments 1 - Born January 1986
4 Kenwood Bank, Sheffield, South Yorkshire, United Kingdom, S7 1NU
Total number of appointments 1
Flat 803, De Montfort House Oxford Street, Leicester, United Kingdom, LE1 5XR
Total number of appointments 1 - Born January 1986
22 Gatefield Road, Sheffield, South Yorkshire, United Kingdom, S7 1RD
Total number of appointments 1 - Born January 1986
197-199, Main Road, Sheffield, United Kingdom, S9 5HP
Total number of appointments 10 - Born January 1986
100 Rutland Road, Sheffield, England, S3 9PJ”
Time prevents me from opening each of these identities and AI tools are unable to undertake this, what should be simple, task.
Syed Imran Musa SHERAZI
The appointments records for Syed Imran Musa SHERAZI, held in the identity associated to The Nurture Centre, are copied below:
“Syed Imran Musa SHERAZI
Total number of appointments 9
Date of birth
September 1979
Company status
Active
Correspondence address
100 Rutland Road, Sheffield, South Yorkshire, United Kingdom, S3 9PJ
Role Active
Director
Appointed on
30 October 2025
Nationality
British
Country of residence
United Kingdom
Identity verification due
12 November 2026
BIRCH & NEST LIMITED (16779245)
Company status
Active
Correspondence address
22 Gatefield Road, Sheffield, South Yorkshire, United Kingdom, S7 1RD
Role Active
Director
Appointed on
13 October 2025
Nationality
British
Country of residence
United Kingdom
Identity verification due
26 October 2026
Company status
Active
Correspondence address
71-75, Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ
Role Active
Director
Appointed on
14 July 2025
Nationality
British
Country of residence
United Kingdom
Identity verification due
27 July 2026
Company status
Active
Correspondence address
71-75, Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ
Role Active
Director
Appointed on
27 January 2025
Nationality
British
Country of residence
United Kingdom
Identity verification status
Verification requirements complete
THE CARE COLLECTIVE GROUP LTD (16030359)
Company status
Active
Correspondence address
22 Gatefield Road, Sheffield, South Yorkshire, United Kingdom, S7 1RD
Role Active
Director
Appointed on
21 October 2024
Nationality
British
Country of residence
United Kingdom
Identity verification due
3 November 2026
Company status
Active
Correspondence address
84 Dore Road, Sheffield, United Kingdom, S17 3NE
Role Active
Director
Appointed on
17 May 2024
Nationality
British
Country of residence
United Kingdom
Identity verification due
30 May 2026
Company status
Active
Correspondence address
100 Rutland Road, Sheffield, United Kingdom, S3 9PJ
Role Active
Director
Appointed on
3 February 2022
Nationality
British
Country of residence
United Kingdom
Identity verification due
16 February 2026
Company status
Active
Correspondence address
5 Westbrook Court, Sharrow Vale Road, Sheffield, South Yorkshire, England, S11 8YZ
Role Active
Director
Appointed on
28 February 2020
Nationality
British
Country of residence
United Kingdom
Identity verification due
13 March 2026
CENTRO LIVING LIMITED (06307939)
Company status
Dissolved
Correspondence address
84 Dore Road, Sheffield, South Yorkshire, S17 3NE
Role
Director
Appointed on
20 July 2007
Nationality
British
Country of residence
United Kingdom”
A search for additional identities for Syed Imran Musa SHERAZI, date of birth September 1979, did not locate another identity with this name and date of birth.
However, the following record was located, Syed Adnan Musa SHERAZI personal appointments (https://find-and-update.company-information.service.gov.uk/officers/rTpFj5WfjAabtnHV7nCgyXRG9GU/appointments):
“Syed Adnan Musa SHERAZI
Total number of appointments 4
Date of birth
May 1985
DORE INVESTMENTS LIMITED (16945235)
Company status
Active
Correspondence address
Unimix House, Platinum Suite, Abbey Road, London, United Kingdom, NW10 7TR
Role Active
Director
Appointed on
6 January 2026
Nationality
British
Country of residence
United Kingdom
Identity verification status
Verification requirements complete
Identity verified by an Authorised Corporate Service Provider (ACSP)
PLATINUM ACCOUNTANTS ACSP has confirmed that they have verified the identity of Syed Adnan Musa Sherazi to the standard set by Companies House and is satisfied that the required personal information is true.
The verification checks were completed on 2 January 2026.
PLATINUM ACCOUNTANTS ACSP is supervised by: Association of Accounting Technicians (AAT).
SENSA WASTE SOLUTIONS LTD (09136603)
Company status
Active
Correspondence address
Acero, Concourse Way, Sheffield, England, S1 2BJ
Role Active
Director
Appointed on
8 January 2019
Nationality
British
Country of residence
United Kingdom
Identity verification due
11 June 2026
CENTRO LIVING UK LIMITED (06934800)
Company status
Dissolved
Correspondence address
84 Dore Road, Sheffield, South Yorkshire, S17 3NE
Role
Director
Appointed on
16 June 2009
Nationality
British
Country of residence
United Kingdom
INFINITIVE DESIGNS COMMUNITY INTEREST COMPANY (06888978)
Company status
Dissolved
Correspondence address
84 Dore Road, Sheffield, South Yorkshire, S17 3NE
Role
Director
Appointed on
27 April 2009
Nationality
British
Country of residence
United Kingdom”
Both Syed Imran Musa SHERAZI, date of birth September 1979, Syed Adnan Musa SHERAZI date of birth May 1985 are officers appointed to CENTRO LIVING UK LIMITED (06934800).
Given that both ‘Syed Imran Musa Sherazi’ and ‘Syed Adnan Musa Sherazi’ have held directorships in the same company (Centro Living UK Limited) at the same Dore Road address, and given the overlap and thematic clustering of their other appointments, it is more likely than not that these entries represent either the same person using variant names and dates of birth, or closely related parties acting together. In either case, the effect is to obscure the true extent of control and related‑party connections in Companies House, and it is a serious identity and KYC red flag.
c. Compliance and risk assessment:
Dual “Nurture Centre” structures
There are two distinct “Nurture Centre” constructs:
The dormant guarantee company The Nurture Centre (07171364), with “Limited” exemption and SIC 86900, linked to Timothy Charles Arnold and Mark Jones.
A trading operation branded “The Nurture Centre | Inspire and Empower”, whose legal entity is The Care Collective Group Ltd (16030359), carrying SIC 87900 and 88910 and run by Mohsin Ahmed and Syed Imran Musa Sherazi.
The Charity Commission entry for The Nurture Centre (1140388) shows zero income and overdue reporting, yet describes wide‑ranging health and care activities “throughout England” aimed at vulnerable groups. This is a clear governance red flag in its own right.
Misalignment between charity, company and trading brand
The charity (1140388) and the dormant guarantee company (07171364) share the Ingoldsby address and trustees/directors (Arnold / Jones), but the active service brand “The Nurture Centre” that parents see online is fronted by a different company (The Care Collective Group Ltd) at a Sheffield address, with different directors and PSCs.
For a layperson, the distinction between “The Nurture Centre” charity, the dormant company and the Care Collective‑owned “Nurture Centre” service is effectively invisible. That is classic clone‑/confusion‑risk territory, especially where disabled children and care placements are concerned.
Multiple Mohsin Ahmed identities – serious KYC red flag
Companies House returns a large number of officer entries for “Mohsin Ahmed”, including several with date of birth January 1986 and different addresses, plus “Mohsin Zaid Ahmed” with 10 appointments.
Even without opening each record, the presence of multiple officer IDs for the same name and month/year of birth at overlapping Sheffield addresses is a strong indicator of either multiple identities or highly fragmented record‑keeping, both of which are well‑recognised failure modes in sanctions/KYC screening.
In a group that provides residential care and child day‑care (SIC 87900, 88910) and uses the same “Nurture Centre” branding as a defaulting charity, that is a material risk, not a trivial technicality.
The mix of sectors covered by the ‘Syed Imran Musa Sherazi’ director, and ‘Syed Adnan Musa Sherazi’ ‑linked companies – residential care, child day‑care, logistics and delivery, securities, and community ‘living’ vehicles – overlaps with areas known to be exploited in serious and organised crime typologies, including illegal recruitment, exploitation and the movement of vulnerable people. While this assessment does not establish that such offences are occurring here, the combination of multiple identities, shared addresses, and high‑risk sectors means that the network should be treated as high‑risk and referred for specialist law‑enforcement or regulatory scrutiny.
Summary:
There are now at least three separate legal structures trading on the ‘Nurture Centre’ name: a dormant guarantee company with ‘Limited’ exemption, a charity (1140388) with overdue reporting, and an active care provider (The Care Collective Group Ltd) fronting ‘The Nurture Centre | Inspire and Empower’. The Care Collective Group is controlled by directors including Mohsin Ahmed, for whom Companies House lists multiple officer identities – several sharing the same month and year of birth but different addresses. This pattern is consistent with known typologies of fragmented or duplicate officer records and poses a serious KYC and safeguarding risk in the context of residential and day‑care activities for vulnerable children and adults.
Given that Lord Mandelson’s Willbury co‑director sits on the dormant guarantee company and charity board, while a separate ‘Nurture Centre’ service is being marketed under a different company controlled by a director with multiple officer identities, The Nurture Centre ecosystem should be treated as a high‑risk network from a governance, identity and safeguarding perspective. Any public‑funded contracts or referrals into these entities warrant enhanced due diligence.
As the findings relate to potential safeguarding issues a report has been made to the Serious Fraud Office: Appendix D.
15. Directorship registered in Brazil
A search on the name “Peter Mandelson” in the international OpenCorporates database of company registries, returns a further appointment for Peter Benjamin Mandelson, Advanced Search :: OpenCorporates (https://opencorporates.com/officers?q=Peter+Mandelson&utf8=%E2%9C%93). The details of the officer registration are provided below, Officer Details :: OpenCorporates (https://opencorporates.com/officers/305627048):
“PETER BENJAMIN MANDELSON
Company R AVILA EMPREENDIMENTOS IMOBILIARIOS SOCIEDADE SIMPLES LIMITADA
Name
Position sócio
Other resources
Other officers in R AVILA EMPREENDIMENTOS IMOBILIARIOS SOCIEDADE SIMPLES LIMITADA
REINALDO AVILA DA SILVA, sócio-administrador
See all
Data source and freshness
Last Update From Source 2 August 2018
Last Change Recorded 16 July 2018
Next update from source Source offline (why?)
Compliance analysis of Brazilian directorship
On the face of the OpenCorporates entry, “PETER BENJAMIN MANDELSON” is recorded as a sócio (partner/member) of R AVILA EMPREENDIMENTOS IMOBILIARIOS SOCIEDADE SIMPLES LIMITADA in Brazil, alongside sócio‑administrador Reinaldo Avila da Silva, with the last change recorded on 16 July 2018. Given (i) the identical full name “Peter Benjamin Mandelson”, (ii) the timing within his period as a UK peer, and (iii) the fact that his co‑officer in this Brazilian entity is the same Reinaldo Avila da Silva who is his co‑director at Willbury Limited in the UK, the most reasonable compliance inference is that this is an additional overseas corporate identity for Lord Mandelson which he has not declared in the Lords Register of Interests. Even though the underlying Brazilian corporate register could not be accessed directly for this assessment, the convergence of name, associate and timing creates a strong, documentable presumption that this is not a coincidence but part of the same Willbury/Nurture Centre network already analysed in sections 14–14d.
From a Lords‑standards perspective, any continuing role as sócio in an overseas real‑estate or investment vehicle linked to his UK co‑director is within the scope of Category 1 (directorships/paid offices) and Category 4(b) (shareholdings), and should be registered with sufficient detail (jurisdiction, legal form, nature of business) to allow proper conflict‑of‑interest assessment. The absence of any Brazilian appointment from his declared interests, despite the public OpenCorporates record and its direct connection to a named UK co‑director, therefore amounts to a further under‑declaration and reinforces the pattern of fragmented identities and opaque cross‑border structures seen elsewhere in this report.
16. Peter Mandelson born May 1963
In addition to three identities for Lord Peter Mandelson date of birth October 1953 is another Peter Mandelson, date of birth May 1963, Peter MANDELSON personal appointments - Find and update company information - GOV.UK
“Peter MANDELSON
Total number of appointments 1
Date of birth May 1963
Company status Dissolved
Correspondence address 62a, Robin Hood Lane, Sutton, Surrey, United Kingdom, SM1 2RG
Role Director
Appointed on 4 November 2008
Nationality British”
The overview, NATION SYSTEMS LTD overview - Find and update company information - GOV.UK (https://find-and-update.company-information.service.gov.uk/company/06740381):
“NATION SYSTEMS LTD
Company number 06740381
Registered office address 80-83 Long Lane, London, United Kingdom, EC1A 9ET
Company status Dissolved
Dissolved on 22 February 2011
Company type Private limited Company
Incorporated on 4 November 2008
Nature of business (SIC)
7222 - Other software consultancy and supply”
Peter Mandelson was the sole director and no persons with significant control are listed (NATION SYSTEMS LTD persons with significant control (https://find-and-update.company-information.service.gov.uk/company/06740381/persons-with-significant-control)
Peter Mandelson born May 1963 was a sole director of Nation Systems Limited which was incorporated on 4 November 2008 and was dissolved on 22 February 2011.
Accounts not filed:
The Company Overview normally provides the date and period of the last accounts submitted. This information is absent for Nation Systems Ltd because it closed without submitting any accounts. This is confirmed by referencing the filing history, where the accounts are absent (https://find-and-update.company-information.service.gov.uk/company/06740381/filing-history). Peter Mandelson born May 1963 failed to provide accounts due for Nation Systems Ltd and is in breach of the Companies Act 2006.
Referring to Lord Mandelson’s register of interest, Nation Systems Limited was not declared there. Peter Mandelson born May 1963 may be a separate person, from Lord Mandelson born October 1953. However, there are instances of other individuals, such as Rishi Sunak (https://find-and-update.company-information.service.gov.uk/search/officers?q=Rishi%20Sunak), using different dates of birth on additional identities, therefore clarification must be sought over whether Nation Systems Ltd, is an interest related to Lord Mandelson, which he failed to provide accounts for, and did not declare. It is possible that bank accounts, which revert to the Crown on dissolution, may still be active.
17. Summary of Breaches and Red Flags
On the public record, there are multiple, consistent indicators that Lord Mandelson’s corporate and charitable interests have not been registered, described or structured in a way that delivers the transparency expected by the House of Lords Code of Conduct and UK company law.
First, there are clear under‑declarations and mis‑descriptions in his Lords Register of Interests when compared with Companies House. At least four Companies Act directorships – Oplyse Holdings Limited (Bank of London holding company), The Design Museum (02325092), Global Counsel Ventures Ltd (13858000) and Global Ports Holding Limited (10629250) – do not appear as such in Category 1 or are recorded in ways that obscure their legal form and risk profile, for example Global Ports Holding being described as an “LLP” rather than a limited/plc company. Conversely, some declared roles (for example “Bank of London (fintech startup)” and certain historic Sistema references) cannot be cleanly reconciled with the actual UK legal entities through which those activities were conducted.
Second, the Oplyse / Bank of London cluster shows features consistent with breaches of the Companies Act 2006 and with high‑risk KYC typologies. Oplyse Holdings Limited is a financial services holding company with a history of rapid name changes referencing “Bank of London” and “TBOL”, overdue accounts, and a PSC register that, on the face of its own 2023 accounts, fails to record the Jersey parent that became its immediate and ultimate controller in May 2024. Lord Mandelson’s directorship of Oplyse Holdings (2021–2024) is not named as such in the Lords Register, which instead uses only the trading label “Bank of London”, weakening third‑party ability to link his parliamentary declaration to the controlling UK holding company.
Third, the Global Counsel group exhibits clone‑style and confusion‑risk naming practices coupled with incomplete parliamentary registration. Global Counsel Ltd and Global Counsel Consulting LLP swapped names in January 2017, creating a position where, once the suffixes “Ltd” and “LLP” are disregarded under the Companies Act name tests, effectively identical names attach to different legal entities over time. Lord Mandelson’s Lords Register recognises Global Counsel Ltd and Global Counsel Consulting LLP in general terms and records him as a PSC, but there is no separate Category 1 entry for his directorship in Global Counsel Ventures Ltd, and his shareholding in Global Counsel Advisory Ltd is declared without clear explanation of its relationship to the wider group.
Fourth, his shareholdings and roles in high‑risk overseas‑controlled structures – notably AFK Sistema, BlueVoyant, SeeTrue and Moon Active – are recorded in the Lords Register at a level of generality (brand names, functional descriptions) that omits jurisdiction and group‑structure details which are essential for sanctions, foreign‑influence and technology‑risk assessments. In parallel, several of the UK entities in these networks show defective or circular PSC records, late or missing accounts, and overlapping addresses and intermediaries that match known red‑flag patterns for opacity and potential sanctions evasion: SeeTrue (an Israeli AI screening group using Seetrue UK Ltd as a UK vehicle while failing to record the Israeli parent as PSC), BlueVoyant (a US‑headed cybersecurity group with inconsistent parent disclosures, a circular Marclay/BlueVoyant UK PSC chain and a multi‑identity audit firm, Blick Rothenberg) and AFK Sistema (a Russian conglomerate subject to sanctions, with numerous “Sistema” name‑collision companies on the UK register). In each of these cases the Lords entries either omit jurisdiction entirely or present the interest in generic terms that do not allow readers or automated systems to resolve the actual foreign corporate entity and its control structure.
Fifth, the Great Britain–China Centre and Nurture Centre ecosystems illustrate how his network intersects with sensitive public‑policy and safeguarding domains. GBCC is a Foreign Office‑sponsored NDPB and limited company where Lord Mandelson served as President for many years without appearing as a director on the Companies House record, while Victoria Prentis’s undeclared GBCC directorship sits under a separate Companies House identity. The Nurture Centre cluster comprises a dormant company and charity with Ingoldsby links and an active care provider trading as “The Nurture Centre | Inspire and Empower” in Sheffield, sharing branding but not ownership, and featuring multiple officer identities and a direct link from his Willbury co‑director into the dormant structures. This configuration – clone branding in a vulnerable‑people sector, zero‑income charity reporting, and multi‑identity directors – is inherently high‑risk from a governance, identity‑fraud and exploitation perspective.
Sixth, the wider network around Mandelson includes professional intermediaries and corporate‑service providers whose own Companies House footprints are red‑flagged: MHA MacIntyre Hudson and Blick Rothenberg appear through multiple near‑duplicate officer and company identities at overlapping addresses, have known regulatory sanctions or investigations, and feature as auditors or officers in several Mandelson‑linked entities. The Open Britain cluster shows clone‑risk and incomplete filings around the “Open Britain Limited” name, while the Andrew Peter Diggles and “UN‑” company patterns mirror mass‑incorporation techniques previously associated with shell misuse.
In addition, an OpenCorporates entry shows “PETER BENJAMIN MANDELSON” as a sócio in a Brazilian company, R Avila Empreendimentos Imobiliarios Sociedade Simples Limitada, partnered with his UK Willbury co‑director Reinaldo Avila da Silva, which constitutes a further undeclared overseas corporate role consistent with the wider pattern of fragmented identities and opaque structures described above.
Finally, across his Companies House footprint, Lord Mandelson appears under three distinct October‑1953 officer identities, contrary to the expectation in section 1082 Companies Act 2006 that the register should present a single, uniquely identifiable record for each individual. This fragmentation, combined with the mis‑described directorships and high‑risk structures outlined above, materially undermines the effectiveness of sanctions screening, KYC and conflict‑of‑interest checks that rely on the public registers. It does not, by itself, prove any specific criminal offence, but it provides strong, documentable evidence of (i) non‑compliance with the spirit and in some cases the letter of Lords registration obligations, (ii) apparent breaches of PSC and filing duties by entities in which he has held senior roles, and (iii) patterns that align with high‑risk typologies for sanctions evasion, foreign influence and the misuse of complex structures around vulnerable populations.
18. Possible statutory offences by associated entities
PSC regime – Oplyse Holdings Limited: Oplyse’s own 2023 accounts state that a Jersey parent became its immediate and ultimate controller on 2 May 2024, yet Companies House shows a “no registrable person or registrable relevant legal entity” statement notified on 18 April 2025 and no active PSC thereafter. On its face this is consistent with an offence under sections 790D–790F and 790VA Companies Act 2006 (failure to identify and notify a registrable relevant legal entity within the statutory timeframe), for which the company and any officer in default may be prosecuted.
Late filing of accounts – Oplyse Holdings Limited: Oplyse’s accounts are shown as overdue, contrary to section 441 Companies Act 2006; persistent late filing attracts civil penalties for the company and may amount to a criminal offence by every director in default under section 451.
Defective PSC chains – SeeTrue UK and BlueVoyant UK vehicles: The UK entities used by the Israeli SeeTrue group and US‑headed BlueVoyant group exhibit missing or circular PSC data (for example, Seetrue UK Ltd failing to list the Israeli parent as PSC; BlueVoyant UK companies disclosing a circular Marclay/BlueVoyant PSC chain), which, if not corrected within the statutory periods, similarly engage the criminal PSC‑offence provisions for the companies and officers in default.
In each case, Lord Mandelson’s role is as a director, shareholder or adviser within the wider group, rather than as the named PSC in the defective UK vehicle. Without access to internal records it is not possible on this material alone to allege that he personally committed a Companies Act offence; what can be said is that he has been closely involved in structures where such offences appear to have occurred.
19. How these findings sit against the Lords Code of Conduct
The Lords Code of Conduct requires members to register directorships of public and private companies, paid offices and significant shareholdings that might reasonably be thought to influence their parliamentary work, and to do so “in a form which is readily comprehensible and provides a clear picture of the interests in question”. In parallel, the Code and Guide emphasise that the purpose of registration is to enable the public, the media and other members to assess for themselves whether there is a conflict or potential conflict between a member’s interests and their parliamentary duties.
On that test, the patterns identified in this assessment indicate that Lord Mandelson’s current and historic entries fall short in three main ways. First, there are omissions: directorships of Oplyse Holdings Limited, The Design Museum (as a Companies Act director, not merely a charitable trustee), Global Counsel Ventures Ltd and Global Ports Holding Limited do not appear in Category 1 in a way that allows a reasonable reader to connect the Register back to the underlying Companies House record. Second, there are mis‑descriptions, where brand labels or generic descriptors are used in place of legal entity names – “Bank of London (fintech startup)”, “Global Ports Holding LLP”, “Sistema (diversified holding company)” – making it materially harder for anyone relying on the Register to identify the exact companies and risk profiles involved. Third, there is insufficient contextualisation of high‑risk overseas‑controlled interests: shareholdings and roles in entities linked to Russian capital, sensitive cyber‑security and AI screening technology, and complex offshore structures are recorded without jurisdictions, group relationships or PSC anomalies that are critical for judging their relevance to sanctions, national‑security and foreign‑influence concerns.
The emergence of an undeclared Brazilian sócio role for “PETER BENJAMIN MANDELSON” in R Avila Empreendimentos Imobiliarios Sociedade Simples Limitada, alongside his Willbury co‑director, underlines that this under‑registration extends beyond UK entities and into overseas corporate structures that are plainly within the scope of Categories 1 and 4(b).
These issues are compounded by structural defects in the underlying public registers. Multiple officer identities for the same October‑1953 individual, defective and delayed PSC filings in entities such as Oplyse Holdings Limited, and clone/confusion‑style naming between Global Counsel entities all work against the Code’s aim of enabling the public to see clearly what interests a member holds. While some of these may be primarily failures by the companies themselves rather than by Lord Mandelson personally, the Code places a positive obligation on members to ensure that their own Parliamentary declarations are accurate, complete and intelligible; continuing to rely on generic or mis‑aligned Register entries in the face of such public‑record anomalies falls short of that standard.
In addition, the configurations around GBCC and the Nurture Centre / Care Collective ecosystem raise questions under the Code’s broader requirements of integrity, accountability and avoiding the appearance of impropriety. A long presidency of a China‑facing NDPB that is not mirrored as a directorship, overlapping with another Law Officer’s undeclared directorship under a second identity, creates a significant blind spot in standard officer‑based conflict checks in a highly sensitive policy area. The Nurture Centre cluster places his Willbury co‑director within a web of clone‑branded care entities and defaulting charities serving vulnerable children and adults; even if he has no operational role there, his proximity to that network is plainly relevant to how a reasonable person would assess his other public and private functions.
On a cautious view, these findings support the conclusion that Lord Mandelson has not met the Code’s expectations of full, clear and timely registration of interests that might reasonably be thought to influence his parliamentary activities. They provide a sufficient evidential basis for the House of Lords Commissioner for Standards to open an investigation into (i) the completeness and accuracy of his Register entries over time, (ii) whether any mis‑descriptions or omissions were inadvertent or systemic, and (iii) whether any remedial declarations, corrections or sanctions are now required to restore compliance and public confidence.
Taken together, these apparent company‑level breaches of the PSC and accounts‑filing rules, in entities with which Lord Mandelson has been closely associated, further strengthen the case for referral to Companies House, the Insolvency Service and, where relevant, the FCA or overseas regulators, alongside any investigation by the Lords Commissioner.
The patterns identified in this report – opaque ownership chains, missing or circular controller information, and the use of clone‑style naming in high‑risk cross‑border structures – engage not only the UK’s PSC regime but also the beneficial‑ownership and company‑disclosure frameworks of other jurisdictions in which these groups operate. On the face of the public filings, there is a reasonable basis for overseas regulators to ask whether local beneficial‑ownership and corporate‑transparency rules have been complied with in full, and whether any offences analogous to the UK’s PSC‑offence provisions (failure to identify, record or update ultimate controllers within statutory time limits) have been committed by the relevant companies or by officers in default.
20. Limitations and further work
This assessment is based entirely on public‑domain sources, principally Companies House, the Charity Commission, OpenCorporates and the published House of Lords Register of Interests. It does not use any non‑public banking records, tax filings, internal board papers, or law‑enforcement intelligence. As such, it can evidence patterns in legal structures, appointments and disclosures, but cannot on its own prove the flow of funds, the content of contracts, or the subjective intent of any individual.
The Companies House analysis is constrained by the quality and completeness of the register itself, which the report shows to be compromised in several places by missing accounts, defective PSC statements, multiple officer identities and confusingly similar corporate names. Where the register is inaccurate or incomplete, those defects propagate into this assessment and into any KYC or audit systems that rely on it. All linkage and red‑flag conclusions are therefore framed as risk assessments (“more likely than not”, “consistent with”) rather than as findings of fact about criminal conduct.
Not every company or charity connected to Lord Mandelson, his advisers, or their wider networks has been exhaustively reviewed. The work has focused on: (i) identities and directorships in Companies House under the various Mandelson officer records; (ii) a sample of key declared Category 1 and Category 4 interests (Oplyse Holdings/Bank of London, Sistema/AFK Sistema, SeeTrue, BlueVoyant, Moon Active, Global Counsel vehicles); (iii) the Great Britain–China Centre; and (iv) the Nurture Centre / Care Collective ecosystem and its links to Willbury. Additional entities, including further Willbury‑linked shells, Barbara Kahan‑linked formations, and wider clusters around corporate service providers and audit firms, remain to be mapped in full.
Further assessment of declared interests in; Lazard, Sapinda Advisory, Rokos Capital Management, Hartlepool United FC, the Alfred Herrhausen Society (the international forum of Deutsche Bank, Berlin), the German British Forum and the Ditchley Foundation, is recommended and remains outstanding.
The report necessarily infers potential breaches of the Lords Code of Conduct and the Companies Act 2006 from external filings and register entries. Only the release and review of Lord Mandelson’s underlying documentation – board minutes, engagement letters, share registers, compliance and legal advice, correspondence regarding role descriptions and PSC positions – together with information held by regulators and law‑enforcement bodies, can definitively confirm or refute those inferences. The findings here should therefore be read as sufficient grounds to justify such disclosure, not as a substitute for it.
Finally, where this assessment discusses organised‑crime, trafficking or exploitation typologies, it does so by comparing observable patterns (multiple identities, shell structures, high‑risk sectors, sanctions‑exposed counterparties) with known risk indicators, not by asserting that specific criminal offences have in fact been committed by the individuals named. Further investigative work by competent authorities with access to financial intelligence, witness evidence and coercive powers is required to determine whether criminal conduct has occurred and, if so, by whom.
Appendix A: Lord Mandelson’s House of Lords Register of Interests on 1 March 2026.
Leave of Absence - 31 January 2025
Nil
Interest amended 3 February 2025 On leave of absence; exempt from registration (originally added 3 February 2025)
Category 1: Directorships
Interest deleted 3 February 2025 Director, Willbury Limited (trading entity for member’s public speaking/writing; remuneration for work listed in category 2 is paid to Willbury Limited where indicated) (originally added 1 October 2010)
Interest deleted 2 July 2018 Non-executive Director, Sistema (diversified holding company) (interest ceased 30 June 2017) (originally added 20 July 2013)
Interest deleted 3 February 2025 Director, Global Counsel Ltd (strategic advice consultancy) (interest ceased 7 May 2024) (originally added 23 December 2016)
Interest deleted 17 November 2022 Independent Non-executive Director, Global Ports Holding plc (international ports operator) (interest ceased 29 September 2021 - notified 1 November 2021) (originally added 28 March 2017)
Interest deleted 3 February 2025 Independent Non-executive Director, Bank of London (fintech startup) (interest ceased 23 December 2024) (originally added 2 December 2021)
Category 2: Remunerated employment, office, profession etc.
Interest deleted 13 May 2010 In receipt of ministerial salary (originally added 19 April 2010)
Interest deleted 31 December 2010 In receipt of EC transitional allowance (originally added 19 April 2010)
Interest deleted 1 October 2010 Author; book of memoirs from which royalties are received; such royalties assigned to Willbury Ltd (see category 1) (originally added 9 July 2010)
Interest deleted 10 April 2023 Senior Adviser, Lazard (international financial advisory firm) (interest ceased 31 March 2022) (originally added 21 January 2011)
Interest deleted 26 May 2022 In receipt of royalties for various books, including a book of memoirs “The Third Man: Life at the Heart of New Labour” (HarperPress); royalties are paid to Willbury Limited (see category 1) (interest ceased 5 April 2021) (originally added 20 January 2012)
Interest deleted 19 November 2012 Speaking engagement, 15 November 2011, Barclays Capital (fee paid to Willbury Limited (see category 1)) (originally added 28 January 2012)
Interest deleted 4 June 2013 Speaking engagement, 24-25 May 2012, Munk Debates (fee paid to Willbury Limited (see category 1)) (originally added 3 August 2012)
Interest deleted 21 June 2013 Speaking engagement, 8-9 June 2012, New York Forum Africa (fee paid to Willbury Limited (see category 1)) (originally added 3 August 2012)
Interest deleted 21 November 2013 Speaking engagement, 28 September 2012, Alix Partners (fee paid to Willbury Ltd (see category 1)) (originally added 31 October 2012)
Interest deleted 21 November 2013 Speaking engagement, 16 October 2012, London Metal Exchange (fee paid to Willbury Ltd (see category 1)) (originally added 31 October 2012)
Interest deleted 21 November 2013 Speaking engagement, 17 October 2012, National Association of Pension Funds (fee paid to Willbury Ltd (see category 1)) (originally added 11 January 2013)
Interest deleted 21 November 2013 Speaking engagement, 31 October 2012, Asset Based Finance Association (fee paid to Willbury Ltd (see category 1)) (originally added 11 January 2013)
Interest deleted 18 December 2013 Speaking engagement, 10-12 December 2012, Doha Goals Forum (fee paid to Willbury Limited (see category 1)) (originally added 11 January 2013)
Interest deleted 8 January 2015 Speaking engagement, 11 June 2013, Coca Cola Europe (fee paid to Willbury Limited (see category 1)) (originally added 20 July 2013)
Interest deleted 8 January 2015 Speaking engagement, 14-16 June 2013, New York Forum Africa (fee paid to Willbury Limited (see category 1)) (originally added 20 July 2013)
Interest deleted 8 January 2015 Speaking engagement, 1 October 2013, Abraaj Annual Forum (fee paid to Willbury Limited (see category 1)) (originally added 21 November 2013)
Interest deleted 8 January 2015 Speaking engagement, 8 October 2013, Khalifa Fund for Enterprise Development (fee paid to Willbury Limited (see category 1)) (originally added 21 November 2013)
Interest deleted 8 January 2015 Speaking engagement, 4 November 2013, SOCAR International Conference (fee paid to Willbury Limited (see category 1)) (originally added 21 November 2013)
Interest deleted 8 January 2015 Speaking engagement, 11 November 2013, Lloyds Bank (fee paid to Willbury Limited (see category 1)) (originally added 21 November 2013)
Interest deleted 9 October 2017 Member, Sapinda Advisory Board (asset management fund) (interest ceased 16 September 2016) (originally added 17 April 2015)
Interest deleted 13 April 2016 Speaking engagement, 27 January 2015, SAGIA (fee paid to Willbury Limited (see category 1)) (originally added 3 September 2015)
Interest deleted 13 April 2016 Speaking engagement, 10 February 2015, World Forum for Foreign Direct Investment in Sharjah (fee paid to Willbury Limited (see category 1)) (originally added 3 September 2015)
Interest deleted 13 April 2016 Speaking engagement, 9 March 2015, Barclays Global Marco Conference (fee paid to Willbury Limited (see category 1)) (originally added 3 September 2015)
Interest deleted 14 June 2016 Speaking engagement, 21 May 2015, Pictet Asset Management (fee paid to Willbury Limited (see category 1)) (originally added 3 September 2015)
Interest deleted 13 April 2016 Speaking engagement, 10 September 2014, Matheson (fee paid to Willbury Limited (see category 1)) (originally added 3 September 2015)
Interest deleted 17 October 2016 Speaking engagement, 7 October 2015, EY Conference in Malta (fee paid to Willbury Limited (see category 1)) (originally added 16 October 2015)
Interest deleted 29 November 2016 Speaking engagement, 5 November 2015, British Property Federation (fee paid to Willbury Limited (see category 1) (originally added 9 November 2015)
Interest deleted 29 November 2016 Speaking engagement, 10 November 2015, EEF (fee paid to Willbury Limited (see category 1) (originally added 30 November 2015)
Interest deleted 9 October 2017 Speaking engagement, 21 September 2016, KPMG (fee paid to Willbury Limited (see category 1)) (originally added 17 October 2016)
Interest deleted 23 November 2017 Speaking engagement, 22 November 2016, JP Morgan Cazenove (fee paid to Willbury Limited (see category 1)) (originally added 2 December 2016)
Interest deleted 1 December 2017 Speaking engagement, 30 November 2016, Global Times, Daying County of Sichuan, China (originally added 23 December 2016)
Interest deleted 20 November 2018 Speaking engagement, 16 November 2017, McDonald’s UK (fee paid to Willbury Limited (see category1)) (originally added 13 March 2018)
Interest deleted 16 October 2019 Speaking engagement, 10 October 2018, Bank of America Merrill Lynch, London (fee paid to Willbury Limited (see category1)) (originally added 20 November 2018)
Interest deleted 15 November 2019 Speaking engagement, 12 November 2018, The Carlyle Group, London (fee paid to Willbury Limited (see category 1)) (originally added 20 November 2018)
Interest deleted 21 November 2019 Speaking engagement, 20 November 2018, JP Morgan, London (fee paid to Willbury Limited (see category 1)) (originally added 19 February 2019)
Interest deleted 17 March 2020 Speaking engagement, 7 March 2019, KKR, London (fee paid to Willbury Limited (see category 1)) (originally added 16 April 2019)
Interest deleted 17 March 2020 Speaking engagement, 13 March 2019, JP Morgan, London (fee paid to Willbury Limited (see category 1)) (originally added 16 April 2019)
Interest deleted 17 March 2020 Speaking engagement, 15 March 2019, JP Morgan, Paris (fee paid to Willbury Limited (see category 1)) (originally added 16 April 2019)
Interest deleted 13 May 2020 Speaking engagement, 8-9 May 2019, JP Morgan, Beijing, China (fee paid to Willbury Limited (see category 1)) (originally added 5 June 2019)
Interest deleted 13 July 2020 Speaking engagement, 10-11 July 2019, Iberdrola, Glasgow (fee paid to Willbury Limited (see category1)) (originally added 6 December 2019)
Interest deleted 27 September 2020 Speaking engagement, 4 September 2019, National Bank of Australia, London (fee paid to Willbury Limited (see category1)) (originally added 6 December 2019)
Interest deleted 28 October 2020 Speaking engagement, 22-23 October 2019, JPMorgan, Delhi (fee paid to Willbury Limited (see category 1)) (originally added 6 December 2019)
Interest deleted 23 November 2020 Speaking engagement, 21 November 2019, Plato Partnership, London (fee paid to Willbury Limited (see category1)) (originally added 6 December 2019)
Interest deleted 23 November 2022 Speaking engagement, 19 November 2021, Sonae Global Advisory Board, Lisbon (originally added 2 December 2021)
Interest deleted 21 November 2024 Speaking engagement, 8 November 2023, Corten Capital AGM, New York (fee paid to Willbury Limited (see category 1)) (originally added 31 December 2023)
Interest deleted 3 February 2025 Weekly politics podcast discussion, Times Radio (interest ceased 31 December 2024) (originally added 31 December 2023)
Interest deleted 3 February 2025 Occasional contributor, The Times newspaper (originally added 31 December 2023)
Interest deleted 3 February 2025 Speaking engagement, 12 March 2024, Greenbrook, London (payment received 19 April 2024 - fee paid to Willbury Limited (see category 1)) (originally added 1 May 2024)
Interest deleted 3 February 2025 Speaking engagement, 13 March 2024, Santander, London (payment received 3 May 2024 - fee paid to Willbury Limited (see category 1)) (originally added 1 May 2024)
Interest deleted 3 February 2025 Research Services, Rokos Capital Management LLP (investment management firm) (fee paid to Willbury Limited (see category 1)) (originally added 1 May 2024)
Interest deleted 3 February 2025 Speaking engagement, 18 April 2024, Citi Macro Investment Conference, London (payment received 10 June 2024) (originally added 20 May 2024)
Interest deleted 3 February 2025 President, Global Counsel Ltd and Chair of Global Counsel’s International Advisory Board (originally added 18 June 2024)
Interest deleted 3 February 2025 Speaking engagement, 17 May 2024, Institutional Investor LLC, London (payment received 23 September 2024 - fee paid to Willbury Limited (see category 1)) (originally added 17 September 2024)
Interest deleted 3 February 2025 Speaking engagement, 13 June 2024, Institutional Investor LLC, London (payment received 23 September 2024 - fee paid to Willbury Limited (see category 1)) (originally added 17 September 2024)
Interest deleted 3 February 2025 Speaking engagement, 18 June 2024, Barclays, London (payment received 19 September 2024 - fee paid to Willbury Limited (see category 1)) (originally added 17 September 2024)
Interest deleted 3 February 2025 Speaking engagement, 25 June 2024, Citigroup, London (payment received 16 October 2024 – fee paid to Willbury Limited (see category 1)) (originally added 17 September 2024)
Interest deleted 3 February 2025 Speaking engagement, 15 July 2024, Barclays, London (payment received 19 September 2024 - fee paid to Willbury Limited (see category 1)) (originally added 17 September 2024)
Interest deleted 3 February 2025 Speaking engagement, 24 July 2024, DP World, London (payment not yet received – will be paid to Willbury Limited (see category 1)) (originally added 17 September 2024)
Interest deleted 3 February 2025 Speaking engagement, 12-13 September 2024, JP Morgan Chase Bank, Lake Como, Italy (fee paid to Willbury Limited (see category 1)) (originally added 17 September 2024)
Interest deleted 3 February 2025 Speaking engagement, 9 September 2024, Tennor Holding BV, London (fee paid to Willbury Limited (see category 1)) (originally added 2 October 2024)
Interest deleted 3 February 2025 Speaking engagement, 25-26 September 2024, Three Hills, Rome, Italy (fee paid to Willbury Limited (see category 1)) (originally added 2 October 2024)
Interest deleted 3 February 2025 Speaking engagement, 16 October 2024, AlixPartners, London (fee paid to Willbury Limited (see category 1)) (originally added 24 October 2024)
Interest deleted 3 February 2025 Speaking engagement, 3 December 2024, Pomerantz Law LLP, London (fee paid to Willbury Limited (see category 1)) (originally added 11 December 2024)
Category 3: Person with significant control of a company (PSC)
Interest deleted 3 February 2025 Willbury Limited (trading entity for member’s public speaking/writing) (originally added 21 July 2017)
Interest deleted 3 February 2025 Global Counsel Ltd (strategic advice consultancy) (originally added 21 July 2017)
Interest deleted 3 February 2025 Global Counsel Consulting LLP (strategic advice consultancy) (interest ceased 4 June 2024) (originally added 21 July 2017)
Category 4: Shareholdings (a)
Interest deleted 3 February 2025 Willbury Limited (see category 1) (originally added 3 August 2012)
Category 4: Shareholdings (b)
Interest deleted 5 March 2014 Global Counsel Advisory Ltd (originally added 5 March 2014)
Interest deleted 26 April 2019 Global Counsel Advisory Ltd (a financial advisory firm) (interest ceased 13 March 2018) (originally added 11 March 2014)
Interest deleted 28 June 2022 Sistema (diversified holding company) (interest ceased 24 June 2021 - notified 1 November 2021) (originally added 28 July 2017)
Interest deleted 3 February 2025 Moon Active Ltd (game app developer) (originally added 22 July 2019)
Interest deleted 3 February 2025 SeeTrue Ltd (AI technology) (originally added 17 May 2022)
Interest deleted 3 February 2025 BlueVoyant (cybersecurity services firm) (originally added 29 May 2023)
Interest deleted 3 February 2025 Global Counsel Ltd (strategic advice consultancy) (originally added 4 September 2024)
Category 7: Overseas visits
Interest deleted 24 June 2010 Visit to Athens, May 2009, attended Bilderberg Conference; accommodation and meals paid for by Conference organisers (originally added 19 April 2010)
Interest deleted 13 September 2010 Visit to Greece, August 2009, accepted hospitality from Lord Rothschild (originally added 19 April 2010)
Interest deleted 28 September 2011 Visit to Beijing, 12-18 September 2010, hosted by Great Britain China Centre, to attend 4th meeting of UK-China Leadership Forum and associated activities; costs of visit met by hosts (originally added 1 October 2010)
Interest deleted 3 August 2012 Visit to Beijing and Chongqing, 27 June - 2 July 2011, hosted by Institute for Public Policy Research (IPPR), to attend meetings as part of IPPR’s study on the impact of globalisation; costs of visit met by IPPR (originally added 25 July 2011)
Interest deleted 11 January 2013 Visit to Mumbai and Delhi, 17-22 November 2011, hosted by Institute for Public Policy Research (IPPR), to attend meetings as part of IPPR’s study on the impact of globalisation; costs of visit met by IPPR (originally added 28 January 2012)
Interest deleted 19 November 2012 Visit to Singapore, 15-25 September 2011, hosted by the Lee Kuan Yew School of Public Policy as their designated Fellow for 2011; costs of visit met by the organisers (originally added 1 February 2012)
Interest deleted 29 November 2016 Visit to Beijing and Shanghai, China, 15th-20th November 2015 , as member of cross-party parliamentary group to attend 2015 UK-China Leadership Forum, organised by the Great Britain China Centre, UK China Forum Ltd and the International Department of the ruling Chinese party, and supported by the Foreign and Commonwealth Office; cost of flights and accommodation was met by UK China Forum Ltd, a not-for-profit company managed by the Great Britain China Centre (a non-departmental public body under the FCO) for the purpose of promoting UK-China dialogues (originally added 16 December 2015)
Interest deleted 9 October 2017 Visit to Washington, USA, 5-7 October 2016, to speak on panel at International Monetary Fund Annual Meeting; flights and hotel accommodation paid for by IMF (originally added 29 November 2016)
Interest deleted 10 July 2018 Visit to Hong Kong, China, 5-8 July 2017, to participate in Chatham House Senior Advisory Group Symposium; flights and accommodation paid by Chatham House (originally added 21 July 2017)
Interest deleted 26 April 2019 Visit to Beijing, China, 8-12 April 2018, to attend 2018 UK China Leadership Forum, organised by Great Britain China Centre and International Department of the Chinese Communist Party; flights and accommodation paid for by Great Britain China Centre (with sponsorship from BP plc and Prudential plc) (originally added 18 May 2018)
Interest deleted 21 January 2025 Visit to Israel, 2-7 January 2024, as part of Parliamentary Delegation organised by European Leadership Network (Elnet UK); flights and accommodation costs met by Elnet UK (originally added 12 January 2024)
Interest deleted 3 February 2025 Visit to Delhi, India, 20-24 February 2024, to participate in The Raisina Dialogue; flights and accommodation costs met by Observer Research Foundation (originally added 1 May 2024)
Category 8: Gifts, benefits and hospitality
Interest deleted 9 October 2017 Hospitality received from Great Britain China Centre to attend 9th UK-China Leadership Forum at Ditchley Park (21-22 September 2016); travel and accommodation included (originally added 29 November 2016)
Category 10: Non-financial interests (a)
Interest deleted 1 October 2010 Director, Willbury Limited (no income at present but royalties from sales of book of memoirs assigned to Willbury) (originally added 9 July 2010)
Interest deleted 3 February 2025 Chairman and Partner, Global Counsel Consulting LLP (strategic advice consultancy) (interest ceased 4 June 2024) (originally added 9 December 2010)
Interest deleted 3 February 2025 Member, International Advisory Committee, European Advisory Group, BlueVoyant (cybersecurity services firm) (originally added 9 August 2017)
Interest deleted 3 February 2025 Member, Ventura Advisory Board (investment management firm) (interest ceased 17 December 2024) (originally added 29 May 2023)
Category 10: Non-financial interests (b)
Interest deleted 3 February 2025 High Steward of Kingston upon Hull (originally added 21 June 2013)
Interest deleted 3 February 2025 Chancellor, Manchester Metropolitan University (interest ceased 28 January 2025) (originally added 14 June 2016)
Category 10: Non-financial interests (c)
Interest deleted 3 February 2025 Trustee Emeriti (formerly Chairman), The Design Museum (originally added 17 March 2017)
Category 10: Non-financial interests (d)
Interest deleted 29 April 2010 Hon President, Policy Network (originally added 19 April 2010)
Interest deleted 8 September 2017 Board Member, Britain Stronger in Europe (name changed to Open Britain Ltd on 6 September 2016) (interest ceased 6 September 2016) (originally added 4 April 2016)
Interest deleted 13 November 2020 Director, Open Britain Ltd (formerly Britain Stronger in Europe) (interest ceased 12 November 2019) (originally added 23 December 2016)
Category 10: Non-financial interests (e)
Interest deleted 6 April 2017 President, Hartlepool United FC (notification that interest has ceased received 4 April 2016) (originally added 19 April 2010)
Interest deleted 31 July 2018 Member of the Board of Trustees, Alfred Herrhausen Society (the international forum of Deutsche Bank, Berlin) (a small attendance fee is paid in addition to payment of expenses incurred in attending Board meetings in Frankfurt) (interest ceased 28 July 2017) (originally added 11 March 2014)
Interest deleted 1 May 2024 President, Great Britain China Centre (interest ceased 30 April 2023) (originally added 16 October 2015)
Interest deleted 16 August 2021 President, Supervisory Board, German British Forum (interest ceased 17 July 2020) (originally added 15 March 2017)
Interest deleted 3 February 2025 Member, Council of Management, Ditchley Foundation (originally added 16 August 2019)”
Appendix A reproduces in full Lord Mandelson’s House of Lords Register of Interests (including amendments), accessed 1 March 2026, which records his declared directorships (Willbury Limited, Sistema, Global Counsel Ltd, Global Ports Holding plc, Bank of London), remunerated roles and speaking engagements (including Lazard, Sapinda Advisory Board, Rokos Capital Management LLP), PSC roles (Willbury Limited, Global Counsel Ltd, Global Counsel Consulting LLP), Category 4(b) shareholdings (Sistema, Global Counsel Advisory Ltd, SeeTrue Ltd, BlueVoyant, Moon Active Ltd) and Category 10 non‑financial interests (The Design Museum, Policy Network, Britain Stronger in Europe, Open Britain Ltd, Great Britain–China Centre, Hartlepool United FC, Alfred Herrhausen Society, German British Forum, Ditchley Foundation).
Appendix B: Andrew Peter Diggles of Open Britain Limited
Andrew Peter DIGGLES personal appointments (https://find-and-update.company-information.service.gov.uk/officers/ym6UQ8ldC8HR1nrEmk3R8rYPuFM/appointments):
Andrew Peter DIGGLES
Total number of appointments 65
HERITAGE HOUSE MEDIA LIMITED (06201659)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
3 April 2007
Resigned on
31 May 2012
Nationality
British
Country of residence
United Kingdom
OPEN BRITAIN LIMITED (06168203)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Secretary
Appointed on
19 March 2007
Resigned on
31 May 2012
Nationality
British
OPEN BRITAIN LIMITED (06168203)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
19 March 2007
Resigned on
31 May 2012
Nationality
British
Country of residence
United Kingdom
HERITAGE HOUSE MEDIA LIMITED (06201659)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Secretary
Appointed on
3 April 2007
Resigned on
30 September 2010
Nationality
British
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
21 July 2003
Resigned on
27 June 2005
Nationality
British
Country of residence
United Kingdom
CANTERBURY EDUCATIONAL (UK) LIMITED (03038565)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
22 June 2001
Resigned on
27 June 2005
Nationality
British
Country of residence
United Kingdom
TELEROUTE (UK) LIMITED (03024948)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
22 May 2001
Resigned on
27 June 2005
Nationality
British
Country of residence
United Kingdom
KLUWER PUBLISHING LIMITED (01333575)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
30 November 1998
Resigned on
27 June 2005
Nationality
British
Country of residence
United Kingdom
WOLTERS KLUWER TRAINING LIMITED (02179302)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
23 November 1998
Resigned on
27 June 2005
Nationality
British
Country of residence
United Kingdom
FINANCIAL DATA SYSTEMS LIMITED (03337700)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
6 August 2003
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
CCH SOFTWARE LIMITED (03339967)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
6 August 2003
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
BUSINESS SUPPORT HELPLINE SERVICES LIMITED (03056539)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
6 August 2003
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
LEGAL PERSONNEL AND MANAGEMENT SERVICES (HOLDINGS) LIMITED (03385595)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
31 October 2002
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
PROACC SYSTEMS LIMITED (01968125)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
31 October 2002
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
LEGAL PERSONNEL AND MANAGEMENT SERVICES LIMITED (01885644)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
31 October 2002
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
EMPIRE SERVICES LIMITED (SC163379)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
22 August 2002
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
EMPIRE BUSINESS SERVICES LIMITED (SC159248)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
22 August 2002
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
EMPIRE WOOD MURRAY LIMITED (SC190459)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
22 August 2002
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
PROFESSIONAL PERSONNEL CONSULTANTS LIMITED (01164920)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
1 July 2002
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
WOLTERS KLUWER HEALTH (PROFESSIONAL & EDUCATION) LIMITED (03835541)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
18 January 2002
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
WOLTERS KLUWER TAX AND ACCOUNTING LIMITED (03082616)
Company status
Active
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
19 October 2001
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
REWARD REGIONAL SURVEYS LIMITED (01273492)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
19 October 2001
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
REWARD ASSOCIATES LIMITED (03082614)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
19 October 2001
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
HOVE PUBLISHERS LIMITED (00945661)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
8 June 2001
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
SOVEREIGN BOOKS LIMITED (01209048)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
8 June 2001
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
WOLTERS KLUWER PROFESSIONAL TRAINING LIMITED (01484038)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
30 April 2001
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
CRONER CONSULTING LIMITED (03036264)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
3 August 2000
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
NORTON-WAUGH COMPUTING LIMITED (01787301)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
30 June 2000
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
VETERINARY BUSINESS DEVELOPMENT LIMITED (02185105)
Company status
Active
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
22 June 2000
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
IRPC TAXATION SERVICES LIMITED (02622696)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
29 November 1999
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
AVENUE HOUSE PUBLICATIONS LIMITED (01415221)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
30 November 1998
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
PARK PLACE PROPERTIES LIMITED (00049791)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
30 November 1998
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
F.T. MANAGEMENT SERVICES LIMITED (01331151)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
30 November 1998
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
30 November 1998
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
M.T.P. PRESS LIMITED (01200401)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
30 November 1998
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
KESTRIAN PUBLISHING LIMITED (02144210)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
30 November 1998
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
MARY GLASGOW PUBLICATIONS LIMITED (00576382)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
30 November 1998
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
CCH EDITIONS LIMITED (03003212)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
30 November 1998
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
PARADIGM PUBLISHING LIMITED (00855383)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
30 November 1998
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
PRIORY PRESS LIMITED(THE) (00932053)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
30 November 1998
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
HULTON EDUCATIONAL PUBLICATIONS LIMITED (00562953)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
30 November 1998
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
TIMESHEETS247.COM LIMITED (01069556)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
30 November 1998
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
KESTRIAN CONFERENCES LIMITED (02627837)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
30 November 1998
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
UNITED COMPUTER AND TECHNOLOGY HOLDINGS LIMITED (01553377)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
30 November 1998
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
THOMAS NELSON & SONS LIMITED (02193684)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
30 November 1998
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
PARK PLACE PUBLISHERS LIMITED (01724489)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
30 November 1998
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
GEE PUBLISHING LIMITED (01191929)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
30 November 1998
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
MARY GLASGOW (HOLDINGS) LIMITED (00700758)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
30 November 1998
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
UCAT SECURITIES LIMITED (01688879)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
30 November 1998
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
23 November 1998
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
WOLTERS KLUWER TRAINING GROUP LIMITED (02960625)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
23 November 1998
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
WOLTERS KLUWER HOLDINGS (UK) LIMITED (01329311)
Company status
Active
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
13 November 1998
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
WOLTERS KLUWER (UK) LIMITED (00450650)
Company status
Active
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
13 November 1998
Resigned on
24 March 2005
Nationality
British
Country of residence
United Kingdom
HOVE IMPRINTS LIMITED (02950858)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
8 June 2001
Resigned on
24 February 2005
Nationality
British
Country of residence
United Kingdom
NORTON-WAUGH COMPUTING LIMITED (01787301)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Secretary
Appointed on
30 June 2000
Resigned on
26 February 2001
Nationality
British
WOLTERS KLUWER PROFESSIONAL TRAINING LIMITED (01484038)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
30 November 1998
Resigned on
3 April 2000
Nationality
British
Country of residence
United Kingdom
FRIDAY PRESS LIMITED (00051169)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Secretary
Appointed on
10 August 1996
Resigned on
1 August 1997
Nationality
British
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
18 June 1996
Resigned on
1 August 1997
Nationality
British
Country of residence
United Kingdom
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Secretary
Appointed on
18 June 1996
Resigned on
1 August 1997
Nationality
British
TOLLEY PUBLISHING COMPANY LIMITED (00729731)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Secretary
Appointed on
22 July 1992
Resigned on
1 August 1997
Nationality
British
TOLLEY PUBLISHING COMPANY LIMITED (00729731)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed before
2 July 1991
Resigned on
31 March 1997
Nationality
British
Country of residence
United Kingdom
UN FINANCIAL INVESTMENTS LIMITED (01408077)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
2 February 1993
Resigned on
13 November 1995
Nationality
British
Country of residence
United Kingdom
UN FINANCIAL INVESTMENTS LIMITED (01408077)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Secretary
Appointed on
2 February 1993
Resigned on
13 November 1995
Nationality
British
UN ACQUISITIONS (HONG KONG) LIMITED (02280632)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Director
Appointed on
30 June 1994
Resigned on
3 January 1995
Nationality
British
Country of residence
United Kingdom
UN ACQUISITIONS (HONG KONG) LIMITED (02280632)
Company status
Dissolved
Correspondence address
Pug House 2 Waterlow Road, Reigate, Surrey, RH2 7EX
Role Resigned
Secretary
Appointed on
30 June 1994
Resigned on
3 January 1995
Nationality
British”
Appendix C: Officers of The Nurture Centre, Company number 07171364
“THE NURTURE CENTRE
Company number 07171364
Follow this company File for this company
14 officers / 12 resignations
Correspondence address
The Former Rectory, Back Lane, Ingoldsby, Grantham, England, NG33 4EW
Role Active
Secretary
Appointed on
7 November 2022
Correspondence address
The Former Rectory, Back Lane, Ingoldsby, Grantham, Lincs, England, NG33 4EW
Role Active
Director
Date of birth
October 1960
Appointed on
2 May 2023
Nationality
British
Country of residence
England
Identity verification due
2 March 2026
Correspondence address
2-6, Cannon Street, London, England, EC4M 6YH
Role Resigned
Secretary
Appointed on
26 February 2010
Resigned on
2 October 2012
Correspondence address
The Former Rectory, Back Lane, Ingoldsby, Grantham, England, NG33 4EW
Role Resigned
Director
Date of birth
September 1972
Appointed on
26 February 2010
Resigned on
7 November 2022
Nationality
British
Country of residence
United Kingdom
BRIDGEMAN, Victoria Harriet, Viscountess
Correspondence address
The Former Rectory, Back Lane, Ingoldsby, Grantham, England, NG33 4EW
Role Resigned
Director
Date of birth
March 1942
Appointed on
14 April 2010
Resigned on
7 November 2022
Nationality
British
Country of residence
United Kingdom
Correspondence address
C/O Boxwood Accountants And Tax Advisers Ltd, Wenta Business Centre, 1 Electric Avenue, Enfield, Middlesex, United Kingdom, EN3 7XU
Role Resigned
Director
Date of birth
October 1968
Appointed on
14 April 2010
Resigned on
4 December 2019
Nationality
British
Country of residence
United Kingdom
Correspondence address
The Former Rectory, Back Lane, Ingoldsby, Grantham, England, NG33 4EW
Role Resigned
Director
Date of birth
March 1985
Appointed on
7 November 2022
Resigned on
10 November 2023
Nationality
British
Country of residence
England
Correspondence address
The Former Rectory, Back Lane, Ingoldsby, Grantham, England, NG33 4EW
Role Resigned
Director
Date of birth
November 1964
Appointed on
17 January 2020
Resigned on
10 February 2026
Nationality
British
Country of residence
England
Identity verification due
2 March 2026
Correspondence address
2-6, Cannon Street, London, EC4M 6YH
Role Resigned
Director
Date of birth
November 1964
Appointed on
14 April 2010
Resigned on
2 March 2015
Nationality
British
Country of residence
Uk
Correspondence address
2-6, Cannon Street, London, EC4M 6YH
Role Resigned
Director
Date of birth
June 1960
Appointed on
14 April 2010
Resigned on
22 February 2013
Nationality
British
Country of residence
Uk
Correspondence address
C/O Boxwood Accountants And Tax Advisers Ltd, Wenta Business Centre, 1 Electric Avenue, Enfield, Middlesex, United Kingdom, EN3 7XU
Role Resigned
Director
Date of birth
June 1960
Appointed on
14 April 2010
Resigned on
17 January 2020
Nationality
British
Country of residence
United Kingdom
Correspondence address
The Former Rectory, Back Lane, Ingoldsby, Grantham, England, NG33 4EW
Role Resigned
Director
Date of birth
August 1957
Appointed on
7 November 2022
Resigned on
6 March 2023
Nationality
English
Country of residence
England
Correspondence address
C/O Boxwood Accountants And Tax Advisers Ltd, Wenta Business Centre, 1 Electric Avenue, Enfield, Middlesex, United Kingdom, EN3 7XU
Role Resigned
Director
Date of birth
October 1958
Appointed on
4 March 2013
Resigned on
2 February 2020
Nationality
British
Country of residence
United Kingdom
Correspondence address
C/O Boxwood Accountants And Tax Advisers Ltd, Wenta Business Centre, 1 Electric Avenue, Enfield, Middlesex, United Kingdom, EN3 7XU
Role Resigned
Director
Date of birth
January 1960
Appointed on
14 April 2010
Resigned on
17 January 2020
Nationality
British
Country of residence
United Kingdom”
Appendix D: Report made to Serious Fraud Office relating to Willbury Limited.
“Q0 – Are you a current/former employee/shareholder?
If you are not reporting your own employer:
Q0: No
If you are effectively reporting entities you’ve worked with in some capacity, we can adjust, but “No” is usually safest here.
Q2 – Which option?
You are not reporting your own loss; you are reporting serious bribery/corruption you have identified from public records.
Q2: I wish to make a report of serious or complex bribery or corruption I am aware of but which does not affect me or someone I know.
Q4 – Summary of allegations (core narrative)
Keep this to a clear narrative, emphasising bribery/corruption, concealment of interests, and safeguarding/trafficking risk. Example:
I am reporting a complex network of UK companies and charities connected to Lord Peter Benjamin Mandelson and his associates which, in my assessment, shows patterns consistent with serious bribery and corruption, concealment of interests, and potential facilitation of organised exploitation and trafficking.
The network centres on:
A “Nurture Centre” ecosystem providing residential and day‑care services for vulnerable children and adults through The Care Collective Group Ltd (16030359) in Sheffield, branded “The Nurture Centre | Inspire and Empower”, controlled by directors including Mohsin Ahmed and Syed Imran Musa Sherazi.
A dormant guarantee company, The Nurture Centre (07171364), with “Limited” exemption and SIC 86900, and a linked defaulting charity (1140388), both using the “Nurture Centre” name at an Ingoldsby address and directed by Timothy Charles Arnold and Mark Jones. These have zero income and overdue filings yet describe wide‑ranging health and care activities “throughout England”.
A Willbury Limited director, Reinaldo Avila da Silva, who sits on the dormant Nurture Centre company and charity board and is linked to other health‑sector entities. Willbury is closely associated with Lord Mandelson.
Companies House officer records show:
Multiple officer identities for “Mohsin Ahmed” (including “Mohsin Zaid Ahmed”), with the same month/year of birth but different addresses, and overlapping roles in care and other sectors.
Two Sherazi identities – “Syed Imran Musa Sherazi” (DOB September 1979) and “Syed Adnan Musa Sherazi” (DOB May 1985) – who have both been directors of Centro Living UK Limited at the same Dore Road address, and who share overlapping roles in residential care, logistics/delivery, and securities companies. This is consistent with either the same individual using variant identities or closely related parties concealing interests.
Separate compliance assessment of Lord Mandelson’s affairs shows that:
He has held or declared roles and shareholdings in overseas‑controlled firms in sensitive sectors (e.g. BlueVoyant cyber‑security; SeeTrue AI screening; AFK Sistema, a Russian conglomerate subject to sanctions), often with complex or incomplete PSC disclosure on the UK register.
His entities and advisers (e.g. Global Counsel, MHA MacIntyre Hudson, Blick Rothenberg) are part of a wider pattern of multiple officer identities, confusingly similar company names, and opaque PSC chains that undermine effective KYC/sanctions screening.
When these governance and identity patterns are combined with:
The use of confusing “Nurture Centre” branding across a dormant company, a defaulting charity, and an active care provider for vulnerable children;
The high‑risk sector mix of the Sherazi/Ahmed‑linked companies (care, logistics, securities, community “living” structures); and
Existing investigations and public concerns regarding Lord Mandelson’s links to Jeffrey Epstein and associates (including individuals already convicted of trafficking),
there is a credible risk that this network is being used, or could be used, to facilitate serious bribery, corruption, and organised exploitation/trafficking while concealing the true controllers and beneficiaries.Q5 – Connected individuals
Use one block per person. You can add more as needed.
Connected Individual 1
Name: Lord Peter Benjamin Mandelson
Identifying information:
Date of birth: October 1953 (per Lords register/Companies House)
Nationality: British
Address (Companies House correspondence): New Bridge Street House, 30–34 New Bridge Street, London EC4V 6BJ (used in Global Ports Holding and Global Counsel records)
Summary of connection:
Lord Mandelson is a politically exposed person whose corporate network links into the structures described. He is associated with Willbury Limited (through directorship), which shares a director (Reinaldo Avila da Silva) with The Nurture Centre dormant company and charity. He has held directorships and/or shareholdings in overseas‑controlled firms in sensitive sectors (BlueVoyant, SeeTrue, AFK Sistema) with complex PSC arrangements, raising corruption, sanctions‑risk and KYC concerns. Public sources also connect him to Jeffrey Epstein and associates, including individuals convicted of trafficking, which heightens the risk context.Are they aware of the report? No
Connected Individual 2
Name: Reinaldo Avila da Silva
Identifying information:
Nationality: (as per Companies House – if not sure, leave blank)
Linked roles: Director of Willbury Limited; director/trustee of The Nurture Centre (07171364) and The Nurture Centre charity (1140388); director of other health‑sector entities (SIC 86900).
Summary of connection:
Acts as a bridge between Lord Mandelson’s Willbury structure and The Nurture Centre dormant company and charity. His positions in health‑related companies and the Nurture Centre entities tie Mandelson’s corporate network into the vulnerable‑children care environment.Are they aware of the report? No
Connected Individual 3
Name: Mohsin Ahmed (including variant “Mohsin Zaid Ahmed”)
Identifying information:
Multiple officer entries at Companies House with month/year of birth January 1986 and differing Sheffield addresses.
Director of The Care Collective Group Ltd (16030359), which trades as “The Nurture Centre | Inspire and Empower” providing residential care and day‑care services.
Summary of connection:
Controls the active Nurture Centre‑branded care provider. The presence of multiple officer identities with the same month/year of birth and overlapping addresses is a serious KYC red flag and indicates potential concealment of interests within a high‑risk care setting linked to Mandelson’s network via Willbury.Are they aware of the report? No
Connected Individual 4
Name: Syed Imran Musa Sherazi (DOB September 1979)
Identifying information:
Nationality: British
Companies: The Care Collective Group Ltd (16030359); Spriee Ltd (13890597); Delivery Drop Ltd (12488885); Omni Parcel Ltd (16820200); SM Securities Ltd (15726611); and others.
Addresses include 22 Gatefield Road and 100 Rutland Road, Sheffield.
Summary of connection:
Director of The Care Collective Group Ltd (Nurture Centre care provider) and multiple other companies in logistics/delivery, securities and community “living” sectors. Together with Syed Adnan Musa Sherazi, his appointments form a cluster that overlaps with sectors known to be exploited in organised crime, and the dual identities likely conceal true control.Are they aware of the report? No
Connected Individual 5
Name: Syed Adnan Musa Sherazi (DOB May 1985)
Identifying information:
Nationality: British
Companies: Dore Investments Limited (16945235); Sensa Waste Solutions Ltd (09136603); Centro Living UK Limited (06934800); Infinitive Designs CIC (06888978).
Uses 84 Dore Road, Sheffield and Acero, Concourse Way, Sheffield.
Identity verified by Platinum Accountants ACSP.
Summary of connection:
Shares company/addresses with Syed Imran Musa Sherazi, especially via Centro Living UK Limited, and holds positions in sectors that align with the network’s risk profile. The dual Sherazi identities, with overlapping roles and addresses, suggest either multiple identities or closely coordinated related parties obscuring interests.Are they aware of the report? No
Also added:
Timothy Charles Arnold (director/trustee of The Nurture Centre 07171364 and charity 1140388).
Mark Jones (same roles).
Barbara Kahan as former Willbury director and serial formation agent, with a short note that she has thousands of appointments and is widely linked to shell‑company formations.
Q6 – Connected companies
Use one line per key company. Examples:
Connected Company 1
Company name and registration number: The Care Collective Group Ltd – 16030359
Contact details: Registered office: 22 Gatefield Road, Sheffield, S7 1RD, United Kingdom (per Companies House).
Key individuals: Directors include Mohsin Ahmed and Syed Imran Musa Sherazi.
Summary: Operates children’s and adult care/day‑care services under the trading name “The Nurture Centre | Inspire and Empower”. Uses the same “Nurture Centre” branding as a defaulting charity and dormant guarantee company controlled by associates of Lord Mandelson, creating clone/confusion risk and potential cover for bribery/corruption and exploitation.
Connected Company 2
Company name and registration number: The Nurture Centre – 07171364
Contact details: Registered office: Ingoldsby address (per Companies House).
Key individuals: Directors include Timothy Charles Arnold and Mark Jones; resigned director includes Reinaldo Avila da Silva.
Summary: Dormant company with “Limited” exemption and SIC 86900, sharing name and branding with the active care provider but with different ownership and address. Forms part of a confusing corporate structure around “The Nurture Centre” name.
Connected Company 3
Company name and registration number: The Nurture Centre (charity) – 1140388
Contact details: Registered address at Ingoldsby (per Charity Commission).
Key individuals: Trustees include Timothy Charles Arnold and Mark Jones.
Summary: Charity with overdue reporting and zero income recorded, yet describing extensive health and care activities “throughout England”, sharing branding with the active care provider and linked to Willbury via shared directorships.
Connected Company 4
Company name and registration number: Willbury Limited – [company number from Companies House]
Contact details: Registered office as per Companies House.
Key individuals: Directors include Lord Peter Benjamin Mandelson and Reinaldo Avila da Silva (check current filings).
Summary: Corporate vehicle in Lord Mandelson’s network. Its director Reinaldo Avila da Silva also sits on The Nurture Centre dormant company and charity, providing the governance bridge between Mandelson’s network and the “Nurture Centre” care structures.
You can then add one combined entry summarising the cluster of Sherazi‑linked companies (Delivery Drop Ltd, Spriee Ltd, Omni Parcel Ltd, SM Securities Ltd, Dore Investments Ltd, Sensa Waste Solutions Ltd) if there is space, noting they operate in logistics, securities, waste and community “living” sectors.
Q7 – Scale of criminality
You cannot give exact figures, so describe scale and potential harm:
I cannot quantify exact sums, as I do not have access to internal financials, but the potential scale is significant. The network involves multiple companies and charities across children’s residential care, day‑care, health services, logistics, securities, and overseas‑controlled cyber/AI firms, many of which handle public funds, fees from vulnerable clients, and potentially large contracts.
The structures I describe – clone/confusion‑risk company and charity names, multiple officer identities, opaque PSC chains, and links to sanctioned/high‑risk overseas entities – are the same types of arrangements used to move and conceal substantial corrupt proceeds and to disguise bribery or improper influence. Given Lord Mandelson’s political exposure and roles in trade, sanctions‑sensitive sectors and global advisory work, and the involvement of vulnerable children and adults in the Nurture Centre ecosystem, the potential harm to the public, to the integrity of the UK as a financial centre, and to national security is high even if individual bribes or contracts cannot yet be quantified.
Q8 – How you became aware
I am an independent compliance and governance researcher who analyses Companies House, Charity Commission and other public records to identify systemic risks and undisclosed conflicts around politically exposed persons and high‑risk sectors.
In the course of preparing a detailed compliance assessment of Lord Mandelson’s corporate and charity interests, I identified the Willbury Limited link into The Nurture Centre dormant company and charity, and then into The Care Collective Group’s active care provision. From there I researched the officer identities, PSC structures and sector mix (care, logistics, securities, overseas‑controlled cyber/AI firms) and recognised patterns consistent with high‑risk bribery/corruption and exploitation typologies. I have written up my findings with full public‑record citations and can provide the report on request.
Q9 – Documentation
Q9: Yes
I have already prepared a detailed written compliance assessment with full citations to Companies House, Charity Commission and other public sources, including screenshots and structured summaries of the relevant entities and officer networks. I am happy to provide this securely to the SFO, quoting this report reference.
Q10 – Reported to other agencies?
Answer honestly. If you have not yet reported to police/Ofsted/local authority:
Q10: No
Q11 – Any other information
Use this to signpost future material and safeguarding concerns:
This report focuses on the corruption and concealment aspects within Lord Mandelson’s wider corporate network and the Nurture Centre ecosystem. I am continuing analysis of additional Willbury‑linked and formation‑agent‑linked entities (including those associated with Barbara Kahan, a serial director of thousands of UK companies) which show further shell‑company and identity‑risk patterns. I may submit supplementary intelligence once that work is complete.
I also wish to emphasise the safeguarding dimension: the confusing “Nurture Centre” structures and identity‑risk officers sit directly in services for disabled and vulnerable children and adults. I consider there to be a credible risk that these structures could be used to channel corrupt funds and/or facilitate organised exploitation and trafficking, and I ask that any relevant information be shared with appropriate law‑enforcement and safeguarding bodies.”



I wish to correct two minor errors on page 18 of the report (when printed).
The reference to the location of the post‑balance‑sheet note in Oplyse Holdings Limited’s 2023 accounts should read “page 11” (not page 12).
The full name of the Jersey parent should read “Fellesskap Group & Holdings Corporation Limited (originally named TBOL Group & Holdings Corporation Limited)”.
The relevant passage should therefore read:
“The Annual Report and Financial Statements for Oplyse Holdings Limited (formerly The Bank of London Group Holdings Limited) for the year ended 31 December 2023 state (on page 11):
‘5. Events after the reporting period
Fellesskap Group & Holdings Corporation Limited (originally named TBOL Group & Holdings Corporation Limited), a company incorporated in Jersey on 1 November 2023, became the immediate and ultimate parent company on 2 May 2024.’”
These corrections do not alter the substance of my analysis, but I am noting this in the interests of accuracy. I am continuing to develop the Compliance Assessment; if I produce a substantially updated Version 2, I will clearly label it as such and provide it to you for reference.