Lord Waheed Alli, Donor to Keir Starmer: Compliance Assessment

Identity Fraud in common?

Executive Summary: Compliance Assessment of Lord Waheed Alli

This compliance assessment of Lord Waheed Alli reveals significant discrepancies and potential breaches of various laws and regulations, particularly concerning his directorships and company registrations. The key findings are:

1. Multiple Identities (Red Flag):
   Lord Alli has seven different identities registered in Companies House, violating Section 1082 of the Companies Act 2006, which requires individuals to maintain a single consistent identity across all company directorships.

2. Inconsistent Personal Details (Red Flag):
   Discrepancies in Lord Alli's personal details, including variations in date of birth (1962 vs 1964) raise concerns about the accuracy of information provided to Companies House.

3. Failure to Disclose Directorships (Red Flag):
   Lord Alli failed to disclose several directorships in his Register of Interests, violating Sections 167 and 182 of the Companies Act 2006 and the House of Lords Code of Conduct.

4. Potential Conflicts of Interest (Red Flag):
   Undisclosed directorships and complex corporate structures raise concerns about potential conflicts of interest that have not been properly declared or managed.

5. Inaccurate Register of Interests (Red Flag):
   Discrepancies between Lord Alli's Register of Interests and his actual directorships as recorded in Companies House indicate a failure to maintain an accurate and up-to-date register.

6. Categorization Issues (Orange Flag):
   Many of Lord Alli's interests are potentially miscategorized in his Register of Interests, raising questions about the accuracy of his disclosures.

7. Dissolved Companies and Overdue Accounts (Red Flags):
   Several companies associated with Lord Alli have been dissolved without filing final accounts or have overdue filings, violating various sections of the Companies Act 2006.

8. Anomalous Resignations and Appointments (Orange Flag):
   Instances of rapid resignation and reappointment in some companies raise questions about the purpose of these actions and potential undisclosed activities.

These findings indicate serious compliance issues and potential breaches of corporate governance regulations. The multiple identities and undisclosed interests are particularly concerning, as they could be used to conceal interests or complicate due diligence processes. Further investigation is recommended, particularly into potential conflicts of interest and the accuracy of Lord Alli's disclosures.

Limitations:
This assessment is based on publicly available information and may not be exhaustive. A more comprehensive review, including analysis of financial transactions, international interests, and co-director profiles, is recommended for a complete compliance picture.

Introduction

Lord Waheed Alli has recently made headlines for his donations to Keir Starmer. I have just published the first in a series of reports on Keir Starmer’s compliance. You can find the compliance assessment of Keir Starmer, here:

Keir Starmer: Compliance Assessment on Multiple Companies House identities.

Currently, I am drafting a report on The Death Penalty Project Limited, a company from which Keir Starmer resigned in 2020. However, due to the current interest in Lord Alli, I have prioritised preparing the following compliance assessment.

Lord Waheed Alli: Compliance Assessment

This report reviews Lord Waheed Alli’s Biography and Register of Interests. Note: Lord Ali’s biography is not populated with any information, Parliamentary career for Lord Alli - MPs and Lords - UK Parliament). This is a breach of Parliamentary Standards. One Red Flag.

Lord Ali’s Register of Interest is available on the UK Parliament website, Register of Interests for Lord Alli - MPs and Lords - UK Parliament (https://members.parliament.uk/member/3482/registeredinterests). His declarations will be compared with his appointments in Companies House.

Lord Waheed Alli, as at 15/9/2024 discloses the following interests in his Register of Interests:

“Category 1: Directorships

• Director, BM Creative Management Ltd (talent agent)

• Director, Silver Star Productions Ltd (production company) (unremunerated until 1 May 2024)

• Director, SGIK 3 Investments Limited (fashion company) (unremunerated but interest accrues)

• Director, Silvercloud Holdings Limited (holding company for Le Chameau Holdings Limited) (unremunerated until 1 May 2024)

Category 3: Person with significant control of a company (PSC)

• SGIF 2 investments Ltd (investment company)

• Silver Star Productions Ltd (production company)

• SGIK 3 Investments Limited (fashion company)

Category 4: Shareholdings (a)

• SGIF 2 investments Ltd (investment company)

• SGIK 3 Investments Limited (fashion company)

Category 4: Shareholdings (b)

• Olga TV Ltd (TV production)

• Ellipsis Entertainment Ltd

• Olio Exchange Limited

• Livia’s Health Foods Ltd

• Zound Industries International AB (audio accessories)

• Floom Limited (flower delivery)

• Jessie and James Limited (children’s clothing)

• TMIK Media Limited

• Shine Capital Advisor Fund

Category 5: Land and property

• Property in London N1 from which rental income is received

• Property in East Coast Demerara, Guyana from which rental income is received

Category 10: Non-financial interests (a)

• Director, Olga TV Ltd (production company)

• Director, Silvergate Media Ltd (production company) (interest ceased 4 December 2023)

• Director, Silvergate PPL Ltd (production company) (interest ceased 4 December 2023)

• Director, Hignell Gallery Ltd (sculpture gallery)

• Director, Silvergate BP Bidco (production company) (interest ceased 4 December 2023)

• Director, SGIF 2 investments Ltd (investment company)

• Director, Executive Pipeline Ltd (formerly MK-LF Partnership Limited) (executive coaching and training company)

• Chairman and a Director, 450 Holdings (investment vehicle)

• Director, Le Chameau Holdings Limited (luxury boot maker)

• Director, MAC (BVI) Limited (investment vehicle)

Category 10: Non-financial interests (e)

• Trustee, Charlie Parsons Foundation”

His date of birth is widely published to be November 1964.

Lord Alli’s Companies House Records

This Compliance report will focus on his Lord Waheed Alli’s records registered in Companies House. A search reveals several unique identifiers (or identities) under his name (https://find-and-update.company-information.service.gov.uk/search/officers?q=Waheed%20Alli).

These results, which include multiple instances of his name with different appointment details, are concerning. An image of the search results is copied below and the text of the identities, follows:

Companies House unique identifier records for Waheed Alli

Companies House unique identifier records for “Waheed Alli”

• “Waheed ALLI

  Total number of appointments 1 - Born October 1970

  C/O Ciret Ltd, Fulflood Road, Havant, United Kingdom, PO9 5AX

• Waheed ALLI

  Total number of appointments 1 - Born November 1964

  11 Buckingham Street, London, United Kingdom, WC2N 6DF

• Waheed ALLI

  Total number of appointments 1 - Born November 1964

  11 Buckingham Street, London, United Kingdom, WC2N 6DF

• Waheed ALLI

  Total number of appointments 1 - Born November 1964

  Penthouse 501, Floral Court Collection, 25 Floral Street, London, England, WC2E 9DS

• Waheed ALLI

  Total number of appointments 1 - Born November 1964

  Penthouse 501, Floral Court Collection, 25 Floral Street, London, England, WC2E 9DS

• Waheed ALLI

  Total number of appointments 1 - Born November 1964

  12th Floor, Brunel Building, 2 Canalside Walk, London, United Kingdom, W2 1DG

• Lord Waheed ALLI

  Total number of appointments 1 - Born November 1962

  Appt 41-42 Harlequin Court, 20 Tavistock Street, London, WC2E 7NZ

• Lord Waheed ALLI

  Total number of appointments 62 - Born November 1964

  21 Meard Street, London, United Kingdom, W1F 0EY”

There are six unique identifiers for the name "Waheed Alli" with a birthdate of November 1964. Additionally, there is a separate identity under the name "Lord Waheed Alli" with a birthdate of November 1962. This raises immediate compliance concerns.

Under Section 1082 of the Companies Act 2006, individuals are required to have a single unique identifier in Companies House records. Multiple identities can conceal interests and are a breach of transparency and accountability. Such discrepancies can enable illegal activities like money laundering, terrorism financing, and human trafficking.

The seven identities that are likely to belong to Lord Waheed Alli are expanded below, with the information on the appointment and company overview of the interest, as indented text.

Waheed Alli identity 1:

• “Waheed ALLI

  Total number of appointments 1 - Born November 1964

  11 Buckingham Street, London, United Kingdom, WC2N 6DF

  • 450 HOLDINGS (FC034333) Company status Active Correspondence address 11 Buckingham Street, London, United Kingdom, WC2N 6DF Role Active Director Appointed on 6 November 2022 Nationality British Country of residence United Kingdom Occupation Director

  • Overseas company address 47 St Helier, Jersey, JE1 0BD Company status Active Company type

    Overseas company First UK establishment opened on 21 March 2017 Accounts

    Required to publish accounts from 1 July to 30 June within 7 months under parent law Last accounts made up to 30 June 2022 Accounts overdue Previous company names MARWYN ACQUISITION COMPANY 07 May 2021 - 06 Feb 2023 WILMCOTE HOLDINGS 15 May 2017 - 07 May 2021 Company details in the country of incorporation Incorporated in CHANNEL ISLANDS Registration number 123424 Legal form Public Limited Company Parent registry Jersey Financial Services Commission Governing law Incoropated (sic) In Jersey Under The Companies (Jersey) Law 1991 Objects of the company Cash shell”

Compliance assessment: Identity 1

Lord Alli discloses that he is “Chairman and a Director, 450 Holdings (investment vehicle)” in his Register of Interests as a Category10: Non-financial interest (category a). Query whether this is the correct category? One Orange Flag.

The accounts are “Required to publish accounts from 1 July to 30 June within 7 months under parent law Last accounts made up to 30 June 2022”, this means that the accounts made up to 30 June 2023 where due by 30 January 2024. Therefore, as of 19 September 2024, the accounts are overdue by over 7 months and 19 days. One Red Flag.

This is an identity which is claimed by Lord Alli in his Register of Interests. This is a duplicated “unique identifier” as he has another identity with this name. This is a breach of Section 1082. One Red Flag.

Waheed Alli identity 2:

• “Waheed ALLI

  Total number of appointments 1 - Born November 1964

  11 Buckingham Street, London, United Kingdom, WC2N 6DF

  • MAC (BVI) LIMITED (FC040488) Company status Active Correspondence address 11 Buckingham Street, London, United Kingdom, WC2N 6DF Role Active Director Appointed on 19 April 2023 Nationality British Country of residence United Kingdom Occupation Director

  • Overseas company address Commerce House Wickhams Cay 1, Road Town, Tortola, Vg110, Virgin Islands, British Company status Active Company type Overseas company First UK establishment opened on 3 November 2022 Accounts Next accounts made up to 30 June 2024 Last accounts made up to 30 June 2023 Company details in the country of incorporation Incorporated in VIRGIN ISLANDS, BRITISH Registration number

    2110864 Legal form Limited Company Parent registry Register Of Corporate Affairs, Bvi Financial Services Commission Governing law Bvi Business Companies Act, 2004 Objects of the company Operations of the group”

Compliance assessment: Identity 2

Lord Alli discloses that he is “Director, MAC (BVI) Limited (investment vehicle)” in his Register of Interests as a Category10: Non-financial interest (category a). Query whether this is a Category 1 interest, rather than a Category 10 (a): Non-financial interest? One Orange Flag.

This is an identity which is claimed by Lord Alli in his Register of Interests. This is a duplicated “unique identifier” as he has another identity with this name. This is a breach of Section 1082. One Red Flag.

Waheed Alli identity 3:

• “Waheed ALLI

  Total number of appointments 1 - Born November 1964

  Penthouse 501, Floral Court Collection, 25 Floral Street, London, England, WC2E 9DS

  • LE CHAMEAU HOLDINGS LIMITED (08201708) Company status Active Correspondence address Penthouse 501, Floral Court Collection, 25 Floral Street, London, England, WC2E 9DS Role Active Director Appointed on 15 August 2023 Nationality British Country of residence England Occupation Company Director

  • Registered office address 16 Mill Street, Oakham, Rutland, England, LE15 6EA Company status Active Company type Private limited Company Incorporated on 4 September 2012 Accounts Up to date Nature of business (SIC) 70100 - Activities of head offices Previous company names DE FACTO 1978 LIMITED 04 Sep 2012 - 05 Oct 2012”

Compliance Assessment: identity 3

Lord Alli discloses that he is director of “Le Chameau Holdings Limited (luxury boot maker)” in his Register of Interests as a Category10: Non-financial interest (category a). Query whether this is a Category 1 interest, not Category 10 (a)? One orange flag.

This is an identity which is claimed by Lord Alli in his Register of Interests. This is a duplicated “unique identifier” as he has another identity with this name. This is a breach of Section 1082. One Red Flag.

Waheed Alli identity 4

• “Waheed ALLI

  Total number of appointments 1 - Born November 1964

  Penthouse 501, Floral Court Collection, 25 Floral Street, London, England, WC2E 9DS

  • SILVERCLOUD HOLDINGS LIMITED (08355140) Company status Active Correspondence address Penthouse 501, Floral Court Collection, 25 Floral Street, London, England, WC2E 9DS Role Active Director Appointed on 15 August 2023 Nationality British Country of residence England Occupation Company Director

  • Registered office address 11 Buckingham Street, London, WC2N 6DF Company status Active Company type Private limited Company Incorporated on 10 January 2013 Accounts Up to date Nature of business (SIC) 64209 - Activities of other holding companies not elsewhere classified Previous company names MARWYN LC HOLDINGS LIMITED 15 Nov 2019 - 16 Apr 2020 DE FACTO 2008 LIMITED 10 Jan 2013 - 15 Nov 2019”

Compliance Assessment: identity 4

Lord Alli correctly declares this interest as director of “Silvercloud Holdings Limited (holding company for Le Chameau Holdings Limited) (unremunerated until 1 May 2024)” as a Category 1: Directorship.

This is an identity which is claimed by Lord Alli in his Register of Interests. This is a duplicated “unique identifier” as he has another identity with this name. This is a breach of Section 1082. One Red Flag.

Waheed Alli identity 5

• “Waheed ALLI

  Total number of appointments 1 - Born November 1964

  12th Floor, Brunel Building, 2 Canalside Walk, London, United Kingdom, W2 1DG

  • SILVERGATE EGGLINGTON LIMITED (13278494) Company status Dissolved Correspondence address 12th Floor, Brunel Building, 2 Canalside Walk, London, United Kingdom, W2 1DG Role Resigned Director Appointed on 19 March 2021 Resigned on 22 June 2022 Nationality British Country of residence United Kingdom Occupation Company Chairman

  • Registered office address 12th Floor Brunel Building, 2 Canalside Walk, London, United Kingdom, W2 1DG Company status Dissolved Dissolved on 19 December 2023 Company type Private limited Company Incorporated on 19 March 2021 Accounts Last accounts made up to 31 March 2022 Final accounts not submitted Nature of business (SIC) 59113 - Television programme production activities”

Compliance assessment: Identity 5

Lord Alli resigned from Silvergate Egglington Limited on 22 June 2022 and it is not declared in the Register of Interests. Former interests that are "comparatively recently held" should be declared (Paragraph 113 of the Guide to the House of Lords' Code of Conduct, 2023). Since, two years and 3 months is comparatively recently. I conclude that Lord Alli should have disclosed his former role in Silvergate Egglington Limited in his Register of Interests. One Red Flag

Silvergate Egglington Limited dissolved on 19 December 2023. The last accounts were made up to 31 March 2022. Accounts are overdue for the period Lord Alli remained director. One Red Flag.

The final accounts have not been submitted. There is a risk that transactions are occurring without oversight. One Orange Flag.

“Silvergate” is a name used by several of Lord Alli’s companies. Therefore, we can conclude that this is another identity of Lord Alli. This is a duplicated “unique identifier”, as he has another identity with this name. This is a breach of Section 1082. One Red Flag.

Waheed Alli identity 6

“Lord Waheed ALLI

Total number of appointments 1 - Born November 1962

Appt 41-42 Harlequin Court, 20 Tavistock Street, London, WC2E 7NZ

• QAM BUILDING MANAGEMENT LIMITED (06080860) Company status Active Correspondence address Appt 41-42 Harlequin Court, 20 Tavistock Street, London, WC2E 7NZ Role Resigned Secretary Appointed on 6 February 2007 Resigned on 21 November 2013 Nationality British Occupation Company Chairman Mp

• Registered office address 2 Leman Street, London, United Kingdom, E1W 9US Company status Active Company type Private limited Company Incorporated on 2 February 2007 Accounts Up to date Nature of business (SIC) 98000 - Residents property management”

Compliance assessment: Identity 6

Lord Alli resigned from QAM Building Management Limited on 21 November 2013. Former interests resigned over ten years ago are unlikely to be considered to be “comparatively recent”, under the Code of Conduct. Therefore Lord Alli was not obliged to declare this interest here.

This is a duplicated “unique identifier”, as Lord Alli has another identity with this name. This is a breach of Section 1082. Lord Alli used a different different date of birth November 1962 instead on November 1964 in this record. Two Red Flags.

Waheed Alli identity 7:

This identity has a total of 67 appointments, of which 8 are current (active). Below I have reproduced the current appointments and the records for appointments that Lord Alli declared as former interests.

“Lord Waheed ALLI

Total number of appointments 62 - Born November 1964

21 Meard Street, London, United Kingdom, W1F 0EY

Total number of appointments 67

Current appointments 8

EXECUTIVE PIPELINE LIMITED (08495647) Company status Active Correspondence address 21 Meard Street, London, United Kingdom, W1F 0EY Role Active Director Appointed on 9 March 2022 Nationality British Country of residence England Occupation Director"

Registered office address Office 430 33 Cavendish Square, London, England, W1G 0PW Company status Active Company type Private limited Company Incorporated on 19 April 2013 Accounts Up to date

Nature of business (SIC) 70229 - Management consultancy activities other than financial management Previous company names MK-LF PARTNERSHIP LIMITED 19 Apr 2013 - 26 Feb 2024”.

Compliance Assessment: (Identity 7) Executive Pipeline Ltd

Declared correctly as “Director, Executive Pipeline Ltd (formerly MK-LF Partnership Limited) (executive coaching and training company)”.

Query whether Category 10: Non-financial interest is the correct category, or whether Category 1: Directorships would be more accurate? One Orange Flag.

This is Lord Alli’s most frequently used unique identifier. It is an identity that is claimed by him as he has declared an associated interest, Executive Pipeline Ltd, in his Register of Interest.

“SGIK 3 INVESTMENTS LIMITED (12262539)

Company status Active Correspondence address Third Floor, 2 Glass Wharf, Bristol, United Kingdom, BS2 0EL Role Active Director Appointed on 15 October 2019 Nationality British Country of residence England Occupation Company Chairman Accounts Up to date Nature of business (SIC) 82990 - Other business support service activities not elsewhere classified Previous company names SILVERGATE INVESTMENTS 3 LIMITED 15 Oct 2019 - 27 Nov 2019” 1 active person with significant control / 0 active statements Lord Waheed Alli”.

Compliance assessment: (Identity 7) SGIK 3 Investments Limited

Declared correctly as “Director, SGIK 3 Investments Limited (fashion company) (unremunerated but interest accrues)”, and accurately as a Category 1: Directorship interest. It is disclosed also as a shareholding and, accurately, as Person with significant control.

“SILVER STAR PRODUCTIONS LTD (11382238) Company status Active Correspondence address Third Floor, 2 Glass Wharf, Bristol, United Kingdom, BS2 0EL Role Active Director Appointed on 25 May 2018 Nationality British Country of residence England Occupation Company Chairman Accounts Up to date Nature of business (SIC) 59113 - Television programme production activities” 1 active person with significant control / 0 active statements Lord Waheed Alli 2 charges registered 0 outstanding, 2 satisfied, Persons entitled Arbuthnot Latham & Co,. (sic) Limited”

Compliance assessment: (Identity 7): Silver Star Production Limited.

Lord Alli correctly declares “Director, Silver Star Productions Ltd (production company) (unremunerated until 1 May 2024)” as an interest in category 1: Directorship, and category 3: Person with significant control.

“SGIF 2 INVESTMENTS LIMITED (10681860)

Company status Active Correspondence address Third Floor, 2 Glass Wharf, Bristol, United Kingdom, BS2 0EL Role Active Director Appointed on 21 March 2017 Nationality British Country of residence England Occupation Company Chairman 1 active person with significant control / 0 active statements Lord Waheed Alli ”

Compliance assessment: (Identity 7): SGIF 2 Investments Limited.

Lord Alli correctly declares “SGIF 2 investments Ltd (investment company)” as a category 10: Non-financial interest (a), as category 3: Person with significant control and as a category 4: Shareholding (a) interest.

Query whether this would more accurately be described as a category 1: Directorships interest? One Orange Flag.

“HIGNELL GALLERY LIMITED (09475333) Company status Active Correspondence address Suite 105, 8 Shepherd Market, Mayfair, United Kingdom, W1J 7JY Role Active Director Appointed on 6 March 2015 Nationality British Country of residence England Occupation Company Chairman Accounts Up to date Nature of business (SIC) 47781 - Retail sale in commercial art galleries Previous company names SILVERGATE GALLERIES LIMITED 06 Mar 2015 - 12 Jun 2015”

Compliance assessment: (Identity 7): Hignell Gallery Limited.

Lord Alli declares “Director, Hignell Gallery Ltd (sculpture gallery)” as a Category 10: Non-financial interest (a). Strictly speaking, he should have spelt “Limited” in full in his Register of Interests, as this is how it is named in Companies House. Whilst it is a minor breach, it is a breach. One Red Flag.

Query whether this would more accurately be described as a category 1: Directorships interest? One Orange Flag.

“THE CHARLIE PARSONS FOUNDATION (07502040) Company status Active Correspondence address 21 Meard Street, London, United Kingdom, W1F 0EY Role Active Director Appointed on 21 January 2011 Nationality British Country of residence England Occupation Company Chairman Accounts Up to date Nature of business (SIC) 88990 - Other social work activities without accommodation not elsewhere classified 1 active person with significant control / 0 active statements Mr Charles Andrew Parsons Notified on 6 April 2016 Date of birth August 1958”

Compliance assessment: (Identity 7): The Charlie Parsons Foundation.

Lord Alli declares “Trustee, Charlie Parsons Foundation” as a category 10: Non-financial interest (e). This relates to an appointment in the Register of Charities. He fails to declare this interest as a category 1: Director of a company called “The Charlie Parsons Foundation.” One Red Flag.

“OLGA TV LIMITED (05636001) Company status Active Correspondence address Third Floor, 2 Glass Wharf, Bristol, United Kingdom, BS2 0EL Role Active Director Appointed on 16 January 2006 Nationality British Country of residence England Occupation Company Chairman Accounts Up to date Nature of business (SIC) 59113 - Television programme production activities Previous company names NEWINCCO 495 LIMITED 25 Nov 2005 - 17 Jan 2006 5 charges registered 0 outstanding, 5 satisfied Persons entitled Associated British Ports Holdings Limited”.

Compliance assessment: (Identity 7): Olga TV Limited

Lord Alli declares “Director, Olga TV Ltd (production company)” as a category 10: Non-financial interest (a) and a category 4: Shareholding (a). Query whether this should be declared as a category 1: directorship? One Orange Flag.

“BM CREATIVE MANAGEMENT LIMITED (05635995) Company status Active Correspondence address Third Floor, 2 Glass Wharf, Bristol, United Kingdom, BS2 0EL Role Active Director Appointed on 9 January 2006 Nationality British Country of residence England Occupation Company Chairman Nature of business (SIC) 82990 - Other business support service activities not elsewhere classified Previous company names NEWINCCO 493 LIMITED 25 Nov 2005 - 12 Jan 2006 1 active person with significant control / 0 active statements Sgif 2 Investments Limited

2 charges registered 2 outstanding, Persons entitled Mount Eden Land Limited”

Compliance assessment: (Identity 7) BM Creative Management Limited

Lord Alli declared “Director, BM Creative Management Ltd (talent agent)” as a category 1 Directorship. He should have declared “Limited” rather than “Ltd”. This apparently minor breach may cause false non-match errors in software. One Red Flag.

Lord Alli is the person with significant control of SGIF 2 Investments Limited, which is the PSC of BM Creative Management Limited. Therefore he should have disclosed that he is the person with significant control of BM Creative Management Limited, as a category 3 interest. One Red Flag.

“SILVERGATE BP BIDCO LIMITED (10135656) Company status Active Correspondence address 21 Meard Street, London, England, W1F 0EY Role resigned Director Appointed on 28 June 2022 Resigned on 4 December 2023 Nationality British Country of residence England Occupation Parliamentarian 2 active persons with significant control Columbia Pictures Corporation Limited and Waheed Alli Date of birth November 1964”

Compliance assessment: (Identity 7) Silvergate BP Bidco Limited.

Lord Alli declares this former appointment “Director, Silvergate BP Bidco (production company) (interest ceased 4 December 2023)” as a category 10, non-financial interest. Query whether this should be a category 1 interest. One Orange Flag.

Lord Alli fails to include “Limited” in his disclosure of the registered name in his Register of Interest. This inaccuracy is a breach of the Companies Act. One Red Flag.

Lord Alli is one of two persons with significant control of Silvergate BP Bidco Limited. He fails to disclose this active category 3, person with significant control, interest. One Red Flag. This is a serious breach as it has the effect of concealing his active association with Columbia Pictures Corporation Limited.

Query whether Lord Alli’s association to Columbia Pictures Corporation Limited, with which he shares significant control of Silvergate BP Bidco Limited, should be disclosed as a related party. One Orange Flag.

“SILVERGATE MEDIA LIMITED (07767497) Company status Active Correspondence address 21 Meard Street, London, England, W1F 0EY Role Resigned Director Appointed on 28 June 2022 Resigned on 4 December 2023 Nationality British Country of residence England Occupation Parliamentarian Nature of business (SIC) 59113 - Television programme production activities 1 active person with significant control / 0 active statements Silvergate Bp Bidco Limited”

Compliance assessment: (Identity 7) Silvergate Media Limited

Lord Alli declares “Director, Silvergate Media Ltd (production company) (interest ceased 4 December 2023)” as a catefory 10 non-financial interest. Query whether this should be a category 1 interest. One Orange Flag.

The registered name is “Silvergate Media Limited” whereas Lord Alli has declared this company in his Register of Interests using the truncated “Ltd”. This minor inaccuracy is a breach. One Red Flag.

Lord Alli is a person with significant control of Silvergate BP Bidco Limited, which is the PSC of Silvergate Media Limited. Therefore he is the PSC of Silvergate Media Limited and he has failed to declare this. One Red Flag.

“SILVERGATE PPL LIMITED (07767488) Company status Active Correspondence address 21 Meard Street, London, England, W1F 0EY Role Resigned Director Appointed on 28 June 2022 Resigned on 4 December 2023 Nationality British Country of residence England Occupation Parliamentarian Nature of business (SIC) 59113 - Television programme production activities Previous company names POTTER PRODUCTIONS LIMITED 08 Sep 2011 - 20 Oct 2011 1 active person with significant control / 0 active statements Silvergate Media Limited”

Compliance assessment: (Identity 7) Silvergate PPL Limited

Lord Alli declares “Director, Silvergate PPL Ltd (production company) (interest ceased 4 December 2023)” at a category 10 non-financial interest. Query whether this should be a category 1 interest. One Orange Flag.

The full name “Limited” is the registered name, this inaccuracy in the Register of Interest referring to “Ltd” is a breach. One Red Flag.

Lord Alli fails to declare that he is a person with significant control of Silvergate PPL Ltd, since he is a PSC of Silvergate BP Bidco Limited, which is PSC of Silvergate Media Ltd, the PSC of Silvergate PPL Ltd. One Red Flag.

In this identity, Lord Alli has an earlier appointment to Silvergate PPL Limited:

“ALLI, Waheed, Lord Correspondence address 12th Floor, Brunel Building, 2 Canalside Walk, London, United Kingdom, W2 1DG Role Resigned Director Date of birth November 1964 Appointed on 8 September 2011 Resigned on 22 June 2022 Nationality British Country of residence England Occupation Director”

Lord Alli resigned from Silvergate PPL Limited on 22 June 2022 and was reappointed on 28 June 2022. This is anomalous behaviour. Query what contracts were signed during resignation period? One Orange Flag.

With a total of 67 appointments, to this identity of Lord Alli, the following appointments are selected as a sample of his remaining appointments which are too numerous to assess all in this report.

SILVERGATE MEDIA DEVELOPMENTS LIMITED (08280892) Company status Dissolved Correspondence address Fourth Floor, York House, 23 Kingsway, London, United Kingdom, WC2B 6UJ Role Director Appointed on 5 November 2012 Nationality British Country of residence England Occupation Director Dissolved on 1 May 2018 Company type Private limited Company Incorporated on 5 November 2012 Accounts Last accounts made up to 31 March 2017 Accounts Overdue Nature of business (SIC) 64209 - Activities of other holding companies not elsewhere classified Previous company names SILVERGATE MEDIA HOLDINGS LIMITED 05 Nov 2012 - 05 Feb 2014 1 person with significant control Silvergate Group Holdings Limited”

Compliance assessment: (Identity 7) Silvergate Media Development Limited

Lord Alli was an active director of Silvergate Media Development Limited when it dissolved on 1 May 2018. The accounts are made up to 31 March 2017. Therefore the accounts to 31 March 2018 and the final accounts are overdue. Two Red Flags.

There is a risk that bank accounts relating to this company are still active and unmonitored. One Orange Flag.

“SILVERGATE GROUP HOLDINGS LIMITED (09843362) Company status Active Correspondence address 12th Floor, Brunel Building, 2 Canalside Walk, London, United Kingdom, W2 1DG Role Resigned Director Appointed on 27 October 2015 Resigned on 23 May 2022 Nationality British Country of residence England Occupation Company Chairman Accounts Up to date Nature of business (SIC) 70100 - Activities of head offices 1 active person with significant control Columbia Pictures Corporation Limited Notified on 27 April 2023”.

Compliance assessment: (Identity 7) Silvergate Group Holdings Limited

Lord Alli resigned from Silvergate Group Holdings Limited on 23 May 2022. Since this is a recent appointment, this should be declared in his Register of Interests. One Red Flag.

The omission of this interest conceals Lord Alli’s association to Colombia Pictures Corporation Limited.

“KOOVS PLC (08166410) Company status Dissolved Correspondence address 2nd Floor, 110 Cannon Street, London, EC4N 6EU Role Director Appointed on 2 August 2012 Nationality British Country of residence England Occupation Director Dissolved on 17 March 2023 Company type Public limited Company Incorporated on 2 August 2012 Accounts Last accounts made up to 31 March 2019 Accounts overdue Nature of business (SIC) 70100 - Activities of head offices 74100 - Specialised design activities Previous company names KOOVS LIMITED 24 Jan 2014 - 27 Feb 2014 SILVERGATE RETAIL LIMITED 16 Aug 2012 - 24 Jan 2014 DE FACTO 1985 LIMITED 02 Aug 2012 - 16 Aug 2012

2 charges registered 1 outstanding, Persons entitled Lord Waheed Alli

1 Insolvency case Case number 1 — In administration Administration started 10 December 2019 Administration ended 17 December 2022

Practitioner Geoffrey Paul Rowley 2nd Floor 110 Cannon Street, London, EC4N 6EU

Practitioner Jason Daniel Baker 2nd Floor, 110 Cannon Street, London, EC4N 6EU Ceased to act 20 June 2022

Practitioner David Paul Hudson 2nd Floor 110 Cannon Street, London, EC4N 6EU”

Compliance assessment: (Identity 7) Koovs PLC

Lord Alli was an active director when Koovs PLC was dissolved on 17 March 2023. Since this is a recent appointment Koovs PLC should have been declared in Lord Alli’s Register of Interests, however, he failed to register Koovs PLC in breach of the Code of Conduct and Companies Act. One Red Flag.

Koovs PLC presented accounts made up to 31 March 2019 and dissolved on 17 March 2023. The accounts to 31 March 2020, 2021, 2022 and final accounts, made up to 17 March 2023, are overdue. These are serious breaches of the Companies Act. 4 Red Flags.

Koovs PLC is dissolved with one charge outstanding to Lord Alli. This is anomalous. An explanation is sought. One Orange Flag.

There are anomalies with the Practitioners handling the Administration of this insolvency case. Administration ended 17 December 2022 yet Geoffrey Paul Rowley and David Paul Hudson have failed to notify that they have ceased to act on behalf of this company. Two Orange Flags.

Geoffrey Paul Rowley appears to have four unique identifiers registered in Companies House (https://find-and-update.company-information.service.gov.uk/search/officers?q=Geoffrey%20Paul%20Rowley). Three Red Flags.

David Paul Hudson is a frequently occurring name with different dates of birth. It is recommended that these are considered further (https://find-and-update.company-information.service.gov.uk/search/officers?q=David+Paul+Hudson). One Orange Flag.

“VAMPIRE SQUID PRODUCTIONS LIMITED (07767492) Company status Active Correspondence address 12th Floor, Brunel Building, 2 Canalside Walk, London, United Kingdom, W2 1DG Role resigned Director Appointed on 8 September 2011 Resigned on 26 September 2022 Nationality British Country of residence England Occupation Director Nature of business (SIC 59113 - Television programme production activities Previous company names OCTONAUTS PRODUCTIONS LIMITED 08 Sep 2011 - 20 Oct 2011”

Compliance assessment: (Identity 7) Vampire Squid Productions Limited

Lord Alli resigned from Vampire Squid Productions Limited on 26 September 2022. Since this is a recently resigned position, within two years, this interest should have been declared in the Register of Interests. Lord Alli failed to register his recent directorship at Vampire Squid Productions Limited. One Red Flag.

Lord Alli holds 67 appointments in this identity. Anomalies have been found with every interest reviewed. This is an indicator that investigation for fraud is required. This is not an exhaustive accounts of Lord Alli’s anomalous behaviour.

Query whether a related party?

“Waheed ALLI

Total number of appointments 1 - Born October 1970

C/O Ciret Ltd, Fulflood Road, Havant, United Kingdom, PO9 5AX

O5A LIMITED (15812210) Company status Active Correspondence address C/O Ciret Ltd, Fulflood Road, Havant, United Kingdom, PO9 5AX Role Active Director Appointed on 1 July 2024 Nationality British, Nigerian Country of residence England Occupation Quantity Surveyor

Registered office address C/O Ciret Ltd, Fulflood Road, Havant, United Kingdom, PO9 5AX Company status Active Company type Private limited Company Incorporated on 1 July 2024 Accounts Up to date Nature of business (SIC) 86900 - Other human health activities”

With nature of business “Other human health activities” if this Waheed Alli with date of birth October 1970 is a related party of Lord Waheed Alli, this cross-over between TV programming and “other human health activities” would present a conflict of interest to the public best interest. One Orange Flag.

Summary of Findings:

Lord Waheed Alli's compliance assessment reveals numerous serious breaches of company law and parliamentary disclosure requirements:

1. Identity misrepresentation:
   Evidence: Seven distinct identities were identified for Lord Waheed Alli in Companies House records, with varying dates of birth (1962 and 1964) and addresses.
   Breach: This violates Section 1082 of the Companies Act 2006, which requires individuals to maintain a single consistent identity across all company directorships.

2. Failure to Disclose Directorships and Persons with Significant Control (PSC) Status:
   Evidence: Major Disclosure Failures:

   • Undisclosed Person with Significant Control (PSC) status in multiple companies, including:

     • BM Creative Management Limited

     • Silvergate BP Bidco Limited (shared with Columbia Pictures Corporation Limited)

     • Three other Silvergate companies via complex organizational structure

   • Failure to disclose directorship in The Charlie Parsons Foundation

   • Non-disclosure of recent directorships in dissolved companies (e.g., Koovs PLC, Vampire Squid Productions Limited)
     Breach: This violates Sections 167 and 182 of the Companies Act 2006 and the House of Lords Code of Conduct.

3. Inaccurate Register of Interests:
   Evidence: Misclassification and Inaccurate Reporting:

   • Several directorships incorrectly categorized as "Non-financial interests" in Register of Interests

   • Consistent use of "Ltd" instead of "Limited" in company names, potentially causing compliance software errors

   • Discrepancies in reporting of Silvergate companies' status and control
     Breach: This violates the House of Commons Code of Conduct for public officials and potentially the Companies Act 2006.

4. Financial Irregularities:

   Evidence: Multiple instances of overdue accounts, including:

• 450 Holdings (overdue by 7+ months)

• Silvergate Media Development Limited (dissolved with overdue accounts)

• Koovs PLC (accounts overdue since 2019, dissolved with outstanding issues)

• Risk of unmonitored active bank accounts for dissolved companies

Breach: This violates various sections of the Companies Act 2006 regarding proper filing and dissolution procedures.

5. Anomalous Resignations and Appointments:
   Evidence: In the case of Silvergate PPL Limited, Lord Alli resigned and was reappointed within a week.
   Concern: This raises questions about the purpose of this temporary resignation and potential undisclosed activities during this period.

6. Potential Conflicts of Interest:

   • Undisclosed relationship with Columbia Pictures Corporation Limited through shared PSC status

   • Complex organisational structures potentially concealing other conflicts.

These issues represent significant breaches of the Companies Act 2006, the House of Lords Code of Conduct, and general principles of transparency and accountability expected of a peer. The multiple identities, undisclosed interests, and financial irregularities raise serious concerns about potential fraud, conflicts of interest, and the integrity of Lord Alli's business dealings. Further investigation is warranted, particularly into the dissolved companies with outstanding financial issues and the full extent of Lord Alli's relationship with major corporations like Columbia Pictures.

Recommendations:

1. Immediate Consolidation of Identities:
   Lord Alli should work with Companies House to consolidate his multiple identities into a single, accurate record in compliance with Section 1082 of the Companies Act 2006.

2. Implementation of Identity Tracking System at Companies House:
   Companies House must implement a robust tracking system that maintains a historical record of multiple identities when they are de-duplicated. This system should:

   • Preserve the history of all consolidated identities

   • Provide a clear audit trail of changes made during de-duplication

   • Allow authorized users to view the full history of an individual's identities

   • Ensure that evidence of previously held multiple identities is not lost after consolidation

3. Update to Auditing Standards:
   Professional auditing bodies should update their standards to address the issue of multiple identities in company records. New guidelines should:

   • Require auditors to check for and report on multiple identities of key individuals

   • Provide procedures for tracing the history of de-duplicated identities

   • Establish protocols for assessing the risk associated with individuals who have held multiple identities

4. Full Disclosure Review:
   Conduct a comprehensive review of all Lord Alli's directorships and PSC statuses, ensuring full disclosure in the Register of Interests, including recently resigned positions.

5. Audit of Company Filings:
   Initiate an audit of all companies where Lord Alli holds or has held positions, particularly focusing on those with overdue accounts or irregular dissolution processes.

6. Investigation into Anomalous Activities:
   Further investigate instances of rapid resignation and reappointment, such as in Silvergate PPL Limited, to ensure compliance with corporate governance standards.

7. Enhanced Due Diligence:
   Implement more rigorous due diligence processes for Lord Alli's business activities, particularly in light of the complex corporate structures and potential conflicts of interest identified.

8. Regulatory Compliance Training:
   Recommend that Lord Alli and his associates undergo additional training on regulatory compliance, focusing on the importance of accurate disclosures and maintaining consistent identity records.

9. Independent Compliance Audit:
   Commission an independent compliance audit to thoroughly review all of Lord Alli's business interests, ensuring full transparency and adherence to both legal requirements and ethical standards expected of a member of the House of Lords.

10. Legislative Review:
    Initiate a review of current legislation to ensure it adequately addresses the issues of multiple identities and provides clear guidelines for their resolution and ongoing management.

These recommendations address the critical need for maintaining historical records of multiple identities, even after de-duplication, and highlight the importance of updating auditing standards to properly address this issue. This approach will enhance transparency, improve accountability, and provide a more comprehensive view of an individual's corporate involvement over time.

Limitations

There is much more work to be done to fully understand Lord Alli's complete compliance profile. Key areas of omission include:

1. Co-Director Identity Testing: A thorough assessment of Lord Alli’s co-directors has yet to be conducted. It is possible that they, too, hold multiple identities, which could exacerbate compliance issues or raise further concerns about transparency and governance.

2. Potential for Clone Company Fraud: While the possibility of clone company fraud has been noted due to the frequent use of the same names across multiple entities, this has not been fully investigated. Given the complexity of the control structures, there is a risk that transactions may be funnelled between similarly named companies without proper oversight.

3. Accounts and Auditors: The financial accounts of the companies and the roles of auditors have not been examined. A detailed review of financial records and auditing practices could reveal further risks or irregularities, particularly related to compliance with corporate reporting standards.

4. Accuracy of Directorship Records: This report does not verify whether the directorships and roles Lord Alli holds are accurate or exhaustive. Further investigation could uncover additional roles or inconsistencies that have not yet been accounted for.

5. International Interests: The review focuses on UK records, but Lord Alli’s international business interests or potential foreign directorships have not been examined. This could leave out critical components of his global compliance profile.

6. Transaction Flows Between Entities: The review has not yet analysed potential financial transactions between the companies connected to Lord Alli. There is a risk that one company’s activities could impact others, especially where names or business functions overlap.

These limitations highlight the need for a more exhaustive review that delves into the financial, governance, and structural details of Lord Alli’s business dealings.

Call for Pro-Bono Team to Assist with Further Investigation

This compliance review has uncovered significant discrepancies that require a more in-depth investigation, far beyond what a single individual can reasonably undertake. I am actively recruiting a pro-bono team to conduct further analysis, including co-director checks, potential clone company fraud assessments, and detailed audits of accounts and transactions. If you have the necessary skills and are interested in assisting with this task, please reach out to collaborate on this critical project.

Collaboration: This report has been prepared by Alison Wright with assistance from ChatGPT and Perplexity.AI.