Pascal Soriot - AstraZeneca UK Limited, AstraZeneca plc, Sustainable Markets Initiative Limited and British Pharma Group Limited (controlled by AstraZeneca UK Limited and GSK PLC).
The control of British Pharma Group Limited by AstraZeneca UK Limited and GSK PLC presents a clear conflict of interest and indicates related party status.
Pascal Soriot is the CEO of AstraZeneca PLC.
Work in progress - expect updates. Notify me of any errors encountered.
The AstraZeneca PLC Annual Reports 2023 and 2024, state:
“Other appointments: Pascal is on the Board of Sustainable Markets Initiative Limited”
The following records were copied from Companies House on 9 July 2024. They remain unchanged, as of 7 August 2025.
A search in Companies House using the name “Pascal Soriot”, returns just one identity, with four appointments (https://find-and-update.company-information.service.gov.uk/search?q=soriot):
Total number of appointments 4 - Born May 1959
1 Francis Crick Avenue, Cambridge, England, CB2 0AA”
The appointments held, by this unique URL, are:
“Pascal Claude Roland SORIOT
Total number of appointments 4
Date of birth May 1959
SUSTAINABLE MARKETS INITIATIVE LIMITED (14752095)
Company status Active Correspondence address 1 Francis Crick Avenue, Cambridge, England, CB2 0AA Role Active Director Appointed on 28 April 2023 Nationality French,Australian Country of residence Switzerland Occupation Director
ASTRAZENECA UK LIMITED (03674842)
Company status Active Correspondence address 1 Francis Crick Avenue, Cambridge Biomedical Campus, Cambridge, United Kingdom, CB2 0AA Role Active Director Appointed on 1 October 2012 Nationality French,Australian Country of residence Switzerland Occupation Chief Executive Officer
ASTRAZENECA PLC (02723534)
Company status Active Correspondence address 1 Francis Crick Avenue, Cambridge Biomedical Campus, Cambridge, United Kingdom, CB2 0AA Role Active Director Appointed on 1 October 2012 Nationality French,Australian Country of residence Switzerland Occupation Chief Executive Officer
BRITISH PHARMA GROUP LIMITED (02538510)
Company status Active Correspondence address 79 New Oxford Street, London, United Kingdom, WC1A 1DG Role Resigned Director Appointed on 1 September 2013 Resigned on 4 April 2025 Nationality French Country of residence Switzerland Occupation Company Director”
Summary of appointments: Pascal Soriot is an active director of Astrazeneca UK Limited and Astrazeneca plc, since 1 October 2012, and of Sustainable Markets Initiative Limited, since 28 April 2023. He is a resigned director of British Pharma Group Limited, he was appointed 1 September 2013 and he resigned on 4 April 2025.
The AstraZeneca reports correctly declare that AstraZeneca UK Limited is a subsidiary of AstraZeneca PLC. However, Pascal Soriot’s directorship of both companies is not made explicit in the annual reports. Whilst his directorship of Sustainable Markets Initiative Limited is correctly disclosed, as an “external appointment”, his directorship of British Pharma Group Limited is not disclosed, when it should be.
British Pharma Group Limited overview, in Companies House
BRITISH PHARMA GROUP LIMITED overview - GOV.UK (https://find-and-update.company-information.service.gov.uk/company/02538510)
“BRITISH PHARMA GROUP LIMITED
Company number 02538510
Registered office address
79 New Oxford Street, London, United Kingdom, WC1A 1DG
Company status
Active
Company type
Private company limited by guarantee without share capital
Incorporated on
10 September 1990
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 8 July 2026
due by 22 July 2026Last statement dated 8 July 2025
Nature of business (SIC)
94120 - Activities of professional membership organisations”
British Pharma Group Limited persons with significant control
“BRITISH PHARMA GROUP LIMITED
Persons with significant control: 2 active persons with significant control / 0 active statements
Astrazeneca Uk Limited, Active
Correspondence address 1 Francis Crick Avenue, Cambridge, England, CB2 0AA Notified on 6 April 2016 Governing law England Legal form Private Limited Company Place registered England & Wales Registration number 3674842 Incorporated in England Nature of control Ownership of shares – More than 50% but less than 75% Ownership of voting rights - More than 50% but less than 75% Right to appoint or remove directors
Gsk Plc Active
Correspondence address 79 New Oxford Street, London, United Kingdom, WC1A 1DG Notified on 6 April 2016 Governing law Companies Act 2006 Legal form Public Limited Company Place registered Companies House Registration number 03888792 Incorporated in England Nature of control Ownership of shares – More than 50% but less than 5% Ownership of voting rights - More than 50% but less than 75% Right to appoint or remove directors”
Summary: The persons with significant control of British Pharma Group Limited, Private company limited by guarantee without share capital, incorporated 10 September 1990, are Astrazeneca UK Limited and GSK PLC (https://find-and-update.company-information.service.gov.uk/company/02538510/persons-with-significant-control).
The Astrazeneca UK Limited Annual Reports are available from Astrazeneca UK Limited’s “Filing History” in Companies House: ASTRAZENECA UK LIMITED filing history - Find and update company information - GOV.UK.
The Annual Reports of Astrazeneca PLC for 2023 and 2024 were reviewed and each report fails to disclose ownership of shares of “More than 50% but less than 75%” of British Pharma Group Limited”.
Conflict of Interest: The control of British Pharma Group Limited by AstraZeneca UK Limited and GSK PLC presents a clear conflict of interest and indicates related party status.
As a result of this non-disclosure, each of these companies accounts are compromised. It is recommended that each of the directors is assessed for multiple identities to clarify whether they have additional directorships held in multiple identities that have not been disclosed.
British Pharma Group Limited
Here’s the full company profile, downloaded from Companies House, for British Pharma Group Limited:
British Pharma Group Limited is a “private company limited by guarantee without share capital” and both AstraZeneca UK Limited and GSK plc are recorded as persons with significant control (PSC), “more than 50% but less than 75%”, each with the right to appoint or remove directors and with significant voting control. This structure, even without share capital, still confers substantial influence to these companies as PSCs.
Does the guarantee company structure remove the conflict of interest?
No, the legal structure does not eliminate the conflict of interest.
A company limited by guarantee simply means members commit to contribute a nominal amount if the company is wound up and, typically, such companies are used for trade associations, clubs, or nonprofits. It does not have shareholders, but instead has “members.” However, being a PSC (even as a corporate entity) means exercising equivalent control—over key votes, directorships, and operations—regardless of shareholding.
The Companies House (and statutory) PSC regime is explicit: a company can be a PSC if it meets any of the control criteria (i.e., more than 25% voting rights, more than 25% right to appoint/remove directors), whether by shares or by guarantee. Thus, if British Pharma Group Limited undertakes any activities where AstraZeneca UK Limited and GSK plc could benefit or coordinate, even indirectly, that is still a related party relationship and, where material, a potential conflict of interest.
GSK declares that it is PSC of British Pharma Group Limited in the 2023 and 2024 annual reports. Does this mitigate the potential conflict of interest?
GSK’s disclosure of its 50% effective interest in British Pharma Group Limited in the 2023 and 2024 annual reports, available at GSK Corporate reports archive (https://www.gsk.com/en-gb/investors/financial-reports/corporate-reports-archive/) GSK aligns with the minimum requirements of UK GAAP and IFRS. Declaring the subsidiary and stating the percentage interest is standard compliance when control or joint control exists, even with less than 100% ownership.
However, best-practice transparency involves more than just stating share percentages:
Both UK GAAP and IFRS expect disclosure that enables users to understand the nature and extent of related party relationships. While there is no explicit legal mandate to name all co-owners of partially controlled subsidiaries, disclosing the identity of joint controllers—such as AstraZeneca in this case—provides stakeholders with vital context about significant overlapping influence and possible conflict of interest.
Omitting the identity of the other controller may fulfill the letter of the standard but not its spirit, as it reduces clarity for readers about the governance structure and risk profile of the group.
Does GSK’s current disclosure mitigate the potential conflict of interest?
GSK's reporting that it holds 50% control is technically correct and meets base compliance. However, not explicitly naming AstraZeneca as the other controller in the relevant annual report limits transparency and makes it harder for stakeholders to readily identify the shared influence between these two major industry competitors.
From a governance and risk perspective, this omission can mask potential related party conflicts, coordinated market activity, or reputational risk, even if there is no breach of technical disclosure standards.
Full mitigation of conflict-of-interest risk requires clear disclosure identifying all significant controllers, especially where joint control involves competitors or substantial industry stakeholders. This allows users of the accounts to make informed assessments of related party and governance risks.
In summary:
Reporting a 50% holding and classifying British Pharma Group Limited as a subsidiary complies with the relevant accounting standards. But best practice—and truly robust governance—would see GSK also name AstraZeneca as a co-controller, enhancing transparency and stakeholder trust, and ensuring that actual or perceived conflicts of interest are clearly flagged for scrutiny.
Astrazeneca fails to declare control of British Pharma Group in the AstraZeneca Annual Report 2023 and 2024.
Letter of complaint sent to AstraZeneca, Companies House and the FCA.
To:
The Company Secretary
AstraZeneca UK Limited
1 Francis Crick Avenue
Cambridge Biomedical Campus
Cambridge CB2 0AA
United Kingdom
And:
PricewaterhouseCoopers LLP (Auditor)
The Maurice Wilkes Building
St John's Innovation Park
Cowley Road
Cambridge CB4 0DS
CC:
Companies House (enquiries@companieshouse.gov.uk)
Financial Reporting Council (supervision@frc.org.uk)
Financial Conduct Authority (listingapplications@fca.org.uk, complaints.info@fca.org.uk)
Dear Company Secretary and Audit Partner,
I write to formally notify you of material omissions in the AstraZeneca UK Limited Annual Report for the year ended 31 December 2024 (published 7 August 2025, Companies House filing history: https://find-and-update.company-information.service.gov.uk/company/03674842/filing-history) and in the AstraZeneca PLC Annual Reports 2022-2025 (https://www.astrazeneca.com/investor-relations/annual-reports.html).
Key points requiring urgent revision:
Omission of Material Related Party:
British Pharma Group Limited (Companies House):
AstraZeneca UK Limited is recorded as a Person with Significant Control (PSC) jointly with GSK PLC, each holding the right to appoint/remove directors and voting control.
Nowhere in the 2024 statutory accounts (see pages 53–62 and Note 27) is this company disclosed as a subsidiary, associate, joint venture, or related party.
There is no mention whatsoever of this joint control with GSK PLC, concealing a major related party relationship and potential conflict of interest between two leading pharmaceutical competitors.
This omission is not only misleading to users of the accounts, auditors, and market stakeholders, it is contrary to the requirements of UK GAAP, IFRS, and the Companies Act 2006 regarding material related party and controlled undertaking disclosures.
Omission of Director External Roles:
Directorships held by Pascal Soriot (see Companies House: https://find-and-update.company-information.service.gov.uk/officers/cOlTVEeXmlbEtyexb3Km4oRdxtA/appointments):
Only the directorship at AstraZeneca UK Limited is disclosed (page 7). His role at AstraZeneca plc and his directorship/leadership in Sustainable Markets Initiative are not disclosed, despite being active and clearly declared at Companies House and in other corporate filings.
Requested Actions:
Immediate Supplementary Disclosure and Correction:
Please urgently submit a revised or supplementary filing to Companies House and notify all report recipients, explicitly:Disclosing AstraZeneca UK Limited’s joint PSC status and effective control of British Pharma Group Limited, and the existence of GSK PLC as the other controlling party.
Updating the related party note to reflect this relationship and adding a statement of any transactions or decisions influenced through this joint entity.
Updating directors’ disclosures for all external appointments as evidenced in Companies House.
Notification to Regulators:
Please confirm that you have notified your external auditor and the company’s Board of these omissions so that appropriate internal controls can be reviewed, and immediate dialogue with the FRC and (if applicable) the FCA is established regarding revision and restatement obligations.Public Confirmation:
Please publish a public confirmation of the steps taken to rectify these omissions so that market users, shareholders, and stakeholders can be reassured as to the reliability of AstraZeneca UK Limited’s governance and reporting.
Supporting Documentation:
Companies House PSC register for British Pharma Group Limited: https://find-and-update.company-information.service.gov.uk/company/02538510/persons-with-significant-control
Companies House directorship record for Pascal Soriot: https://find-and-update.company-information.service.gov.uk/officers/cOlTVEeXmlbEtyexb3Km4oRdxtA/appointments
Failure to revise the published annual report may expose AstraZeneca UK Limited and its directors to regulatory investigation, market censure, and reputational damage. Given the centrality of related party transparency to audit and governance standards, this matter requires immediate correction.
Review of AstraZeneca plc's published Annual Reports for 2022, 2023, and 2024 confirms that these disclosure failures are persistent and systemic. There is no reference in any report to Pascal Soriot's directorship of Sustainable Markets Initiative Limited, nor is there any mention of AstraZeneca UK Limited's joint control of, or PSC connection with, British Pharma Group Limited. These non-disclosures contravene both the letter and spirit of UK corporate governance and reporting requirements, and further underscore the need for comprehensive remedial action and a broader compliance review.
The repeated failure to disclose AstraZeneca UK Limited’s joint control of British Pharma Group Limited, and thereby its related party relationship with GSK PLC, constitutes a serious conflict of interests. This omission—present in multiple annual reports and periods—not only conceals a material governance arrangement from auditors, regulators, and stakeholders, but also results in the absence of required related party disclosures for both AstraZeneca UK Limited and AstraZeneca PLC. The systematic nature of these non-disclosures, spanning several years, demonstrates an intentional obfuscation of material facts, meeting the definition of fraudulent reporting under UK company law and accounting standards. I therefore formally allege that these actions constitute fraud and request this matter be rectified immediately, with full disclosures and acknowledgement of this conflict in all relevant statutory filings.
Please confirm receipt of this letter and outline the actions you intend to take within 7 days.
Yours faithfully,
[Alison Wright]
I accidently omitted my name and address. I will notify the recipients of my error and send a corrected complaint (13 August 2025).
Responses to my complaint from AstraZeneca (and letter to the auditor), the Financial Conduct Authority (FCA) and Companies House
I received acknowledgment from Andy Barnett, of AstraZeneca, and notification that he was on holiday, with an email provided for urgent matters. The emails to “supervision@frc.org.uk” and “info@fca.org.uk” were rejected. I assume that these email addresses are no longer current. On 8 August 2025 I forwarded my original email to IRDirectors@astrazeneca.com, copied to enquiries@companieshouse.gov.uk and listingapplications@fca.org.uk.
AstraZeneca
On 15 August 2025 I received the following response.
Urgent Request for Immediate Revision—Omissions in AstraZeneca UK Limited 2024 Annual Report: Undisclosed Directorships and Related Party Control
CA
To: alisonwright45@btinternet.com;
15/08/2025 15:12
Dear Ms. Wright,
Thank you for your email. We appreciate your commitment to transparency and regulatory compliance.
We have carefully reviewed the concerns raised in your message dated 8 August 2025, alongside the disclosures made in the accounts of AstraZeneca UK Limited and AstraZeneca PLC. Following this review, we are satisfied that there have been no material omissions in relation to the matters you highlighted.
We recognise the importance of accurate and transparent reporting and remain committed to upholding these standards. Should you have any further questions or require additional information, please don’t hesitate to get in touch.
Kind regards
Corporate Access
AstraZeneca UK Limited is a company incorporated in England and Wales with registered number:03674842 and its registered office at 1 Francis Crick Avenue, Cambridge Biomedical Campus, Cambridge, CB2 0AA.
This e-mail and its attachments are intended for the above named recipient only and may contain confidential and privileged information. If they have come to you in error, you must not copy or show them to anyone; instead, please reply to this e-mail, highlighting the error to the sender and then immediately delete the message. For information about how AstraZeneca UK Limited and its affiliates may process information, personal data and monitor communications, please see our privacy notice at www.astrazeneca.com
Escalation to PricewaterhouseCoopers Audit team 22 August 2025:
To: uk_auditteam@pwc.com
Cc: IRDirectors@astrazeneca.com, enquiries@companieshouse.gov.uk
Subject: Urgent Attention Required: Omission of British Pharma Group Limited from AstraZeneca UK Limited 2024 Annual Report—Request for Audit Qualification
Dear PricewaterhouseCoopers Audit Team,
I am contacting you in relation to a significant omission in the recently published 2024 Annual Report and Financial Statements of AstraZeneca UK Limited and AstraZeneca PLC. AstraZeneca has not declared its joint ownership (50–75%) of British Pharma Group Limited alongside GSK plc, despite this clearly constituting a notifiable and material interest under Companies Act and FRS 101 disclosure requirements for subsidiaries, joint ventures, and significant holdings. This entity (British Pharma Group Limited) does not appear on the list of investments or related party interests set out in note 27 or elsewhere in the audited accounts for 2024.
I have corresponded directly with AstraZeneca regarding this issue. Their response—copied below for your reference—does not substantively address the omission, risks, or regulatory implications. The email is unsigned by an unnamed individual and does not mention the related party status to GSK, provide any factual rebuttal, nor acknowledge the material compromise to the integrity and completeness of the annual report and consolidated financial statements for both AstraZeneca UK Limited and AstraZeneca PLC.
Given the explicit and ongoing nature of this reporting omissions, I am requesting that PricewaterhouseCoopers LLP, as statutory auditor of record, consider whether this constitutes a material departure from applicable law and accounting standards requiring a “qualified opinion for material omission of required related party disclosure” on AstraZeneca’s 2024 annual report.
A full copy of AstraZeneca’s response is attached below:
“Dear Ms. Wright,
Thank you for your email. We appreciate your commitment to transparency and regulatory compliance.
We have carefully reviewed the concerns raised in your message dated 8 August 2025, alongside the disclosures made in the accounts of AstraZeneca UK Limited and AstraZeneca PLC. Following this review, we are satisfied that there have been no material omissions in relation to the matters you highlighted.
We recognise the importance of accurate and transparent reporting and remain committed to upholding these standards. Should you have any further questions or require additional information, please don’t hesitate to get in touch.
Kind regards
Corporate Access
AstraZeneca UK Limited [...]”
My main observations are:
No acknowledgment of the related party status with GSK or the existence of British Pharma Group Limited as a jointly owned entity.
No rationale for exemption from disclosure, despite clear reporting obligations.
The lack of transparency and omission could mislead users of the accounts and undermine confidence in AstraZeneca's reported governance and risk control over group interests.
The potential implications extend to the listed group’s compliance with FCA disclosure rules and Companies Act requirements.
I respectfully request PricewaterhouseCoopers to:
Confirm receipt of this communication formally.
Review whether the omission of British Pharma Group Limited as a joint arrangement/related party interest is a material non-disclosure requiring a qualified audit opinion for the year ended 31 December 2024, and, if so, clarify the steps required to address this with regulators and the company’s board.
Advise what public clarification/amendment can be anticipated from AstraZeneca or yourselves as auditor, or whether this matter should be escalated further to the Financial Reporting Council (FRC) or FCA, given AstraZeneca’s stated view that “there have been no material omissions.”
If additional documentation is required, I am happy to provide supporting records, including filings at Companies House showing the continued existence and shareholdings of British Pharma Group Limited. My legal assessment of breach of statutory disclosure obligations by AstraZeneca UK Limited and AstraZeneca PLC, is attached, below.
I look forward to your response and thank you for your attention to this important matter of public, investor, and regulatory interest.
Yours sincerely,
Alison Wright.
Breach of Statutory Disclosure Obligations: Legal Assessment
1. Legal Framework—United Kingdom
a. Companies Act 2006 (UK):
AstraZeneca UK Limited, as a company incorporated under the Companies Act 2006 ("the Act"), is subject to statutory requirements regarding disclosure of information in its annual report and financial statements. The relevant provisions include, but are not limited to:
Section 415 (Contents of strategic report)
Section 414C (Contents of strategic report: non-financial information statement)
Section 416 (Directors' report)
Section 419 (Disclosure required in directors' report: information about directors)
Section 441 (Duty to deliver accounts and reports)
Section 496 (Auditor’s report on strategic report and directors’ report)
Furthermore, Schedule 7 of the Large and Medium-sized Companies and Groups (Accounts and Reports) Regulations 2008 (SI 2008 No. 410) sets out detailed reporting requirements regarding directors’ remuneration, related party transactions, and certain other key disclosures.
b. Potential Breach:
A failure by AstraZeneca UK Limited to disclose required information in its annual report or related statutory reports would constitute a breach of the above-mentioned sections of the Companies Act 2006. If directors or officers knowingly cause or permit such a non-disclosure, they may be in breach of their obligations under Section 172 (Duty to promote the success of the company) and Section 174 (Duty to exercise reasonable care, skill and diligence).
Pursuant to Section 451 (Civil penalty for failure to file accounts and reports), non-compliance with filing and disclosure duties can result in financial penalties and, under Section 1112 (General false statement offence), criminal sanctions may apply in cases of false statements or willful concealment.
2. International Law and Standards
While reporting entities are primarily governed by their domestic law, certain international principles apply for companies listed on foreign exchanges or with significant overseas operations, including:
International Financial Reporting Standards (IFRS): Failure to disclose required information (such as related party transactions or contingent liabilities) may constitute a breach of the IFRS standards (e.g., IAS 24 "Related Party Disclosures" and IAS 37 "Provisions, Contingent Liabilities and Contingent Assets").
US Securities and Exchange Commission (SEC): For companies listed in the US, non-disclosure may breach SEC regulations, notably under the Securities Exchange Act of 1934, Rule 10b-5 concerning material misstatements or omissions.
General Anti-bribery and Transparency Laws: Omission or suppression of material information may also raise concerns under, for example, the UK Bribery Act 2010 and the US Foreign Corrupt Practices Act (FCPA), particularly if it leads to a misleading or incomplete public record.
3. Consequences of Non-Disclosure
a. Civil and Criminal Liability:
The company and/or its directors may be subject to investigation by the UK authorities (such as the Financial Reporting Council or Companies House) for breaches of the Companies Act 2006 and related regulations.
Fines, criminal penalties, and potential director disqualification orders may result from material non-compliance or willful concealment.
b. Contractual and Fiduciary Implications:
Breach of statutory disclosure requirements may also amount to a breach of directors’ fiduciary duties to the company and its shareholders.
c. Reputational and Market Risk:
Both regulatory authorities and investors increasingly expect full compliance with statutory and best-practice disclosure standards; non-compliance may lead to significant reputational harm, civil litigation, and market consequences.
4. Summary: Main UK Legal Breaches
Strategic Report Disclosure
Statute/Regulation: Companies Act 2006
Section Broken: s.414A, s.415, s.414C
Legal Effect: Civil/Criminal
Directors’ Report Disclosure
Statute/Regulation: Companies Act 2006
Section Broken: s.416–419
Legal Effect: Civil/Criminal
True and Fair View
Statute/Regulation: Companies Act 2006 / FRS 101/IFRS
Section Broken: s.393
Legal Effect: Civil/Criminal
Non-financial Information
Statute/Regulation: Companies Act 2006
Section Broken: s.414C
Legal Effect: Civil/Criminal
Director Duties (Fiduciary)
Statute/Regulation: Companies Act 2006
Section Broken: s.171–177
Legal Effect: Civil
Filing Obligations
Statute/Regulation: Companies Act 2006
Section Broken: s.441–451
Legal Effect: Civil/Criminal
False Statement
Statute/Regulation: Companies Act 2006
Section Broken: s.1112
Legal Effect: Criminal (if willful)
5. Conclusion
Non-disclosure or incomplete disclosure of material information required under UK law—and by international accounting standards—constitutes a breach of statutory duty under the Companies Act 2006, may be actionable as a breach of directors’ fiduciary duties, and, in some circumstances, may expose the company and its directors to both civil and criminal liability, subject to the degree and intent of the non-disclosure. Internationally, similar standards apply under IFRS and SEC rules, and non-compliance may have cross-jurisdictional ramifications for multinational groups.
Response to AstraZeneca on 22/8/2025:
To: Corporate Access, AstraZeneca UK Limited
CC: Companies House; Financial Reporting Council; Financial Conduct Authority; PricewaterhouseCoopers LLP (Auditor)
Subject: Re: Response to Complaint on Omissions in AstraZeneca UK Limited 2024 Annual Report—Material Disclosure Failures Remain Outstanding
Dear Corporate Access Team and Company Secretary,
Thank you for your response dated [insert date of their reply] regarding my formal notification of material omissions in the AstraZeneca UK Limited Annual Report for the year ended 31 December 2024.
Your reply states you are “satisfied that there have been no material omissions in relation to the matters you highlighted,” and expresses your commitment to transparency and regulatory compliance. However, you have not substantively addressed or rebutted the specific, evidenced concerns in my complaint regarding:
Omission of Material Related Party Information:
AstraZeneca UK Limited is publicly recorded at Companies House as a Person with Significant Control (PSC) of British Pharma Group Limited, jointly with GSK PLC.
This entity, and the joint control relationship with a major competitor, is nowhere disclosed in your 2024 statutory accounts (see pages 53–62 and Note 27), nor in those of AstraZeneca PLC for any relevant period.
There is no mention whatsoever of this arrangement in the related party, subsidiary, associate, or joint venture disclosures, as required by UK GAAP, IFRS (IAS 24), and the Companies Act 2006.
Omission of Director External Roles:
The directorships held by Pascal Soriot, including those at AstraZeneca PLC and the Sustainable Markets Initiative, are not disclosed in your annual reports, notwithstanding their active status and evidencing at Companies House.
At Law and Under Regulation:
Both the Companies Act 2006 (specifically s.409, s.414C, and s.414A), UK-adopted IFRS (notably IAS 24, Related Party Disclosures), and the FRC’s Guidance on the Strategic Report, require disclosure of all subsidiary, associate, and joint venture undertakings, Persons with Significant Control, and material related party relationships, including joint control arrangements and external director appointments, where material to the understanding of the entity’s affairs and to enable users to appreciate the impact of such relationships on the financial position.
Failure to make such disclosures, especially where the arrangements involve joint control with a market competitor, constitutes a material omission with respect to the duties of directors (s.172 and s.393, Companies Act 2006), auditor obligations, and proper market conduct under FCA Listing Rules and MAR, as well as broader legal duties of transparency required by both Companies House and the Financial Reporting Council.
Your Response Is Insufficient
Your generic reply does not address any of the specific, documented facts:
You provide no explanation for the absence of British Pharma Group Limited and the PSC relationship with GSK PLC from all required disclosures.
You do not reference, explain, or remedy the nondisclosure of director external roles.
You offer no detail as to whether the board or audit partner have actually reviewed these matters, nor any comfort to external stakeholders, auditors, or regulators that the issues have been corrected or will be.
Renewed Request for Immediate Remedial Action and Regulator Notification:
I therefore repeat and clarify my requests, in accordance with law, regulation and best practice:
That you provide a detailed, explicit answer as to why AstraZeneca UK Limited’s PSC relationship and joint control of British Pharma Group Limited, and the existence of GSK PLC as the other controlling party, is not disclosed in your 2024 accounts.
That you immediately submit a supplementary or amended filing to Companies House for the 2024 financial year clearly disclosing:
The nature of AstraZeneca UK Limited’s control and interest in British Pharma Group Limited;
The existence of GSK PLC’s joint control;
Any relevant transactions and their financial impact; and
Corresponding updates to the notes on related parties and controlled undertakings.
That you update the directors’ disclosures in your annual report for all current external directorships and roles, as required.
That you confirm the above issues have been specifically discussed and evaluated by your board and reporting auditor, and that notification has been given to the FRC and FCA regarding a potential need for restatement or late correction.
That you provide a substantive, reasoned written response to each point, not a generic assertion.
That you make a public statement clarifying the remedial action taken, in line with the principles of transparency and market integrity.
Failure to Address These Points Risks Significant Regulatory and Legal Consequences:
As set out in my original and supplemental correspondence, continued nondisclosure may expose AstraZeneca UK Limited and its directors to investigation and sanction by Companies House, the FCA, the FRC, and other bodies for breach of statute, accounting standards, and market abuse regulations. It further undermines the trust of market participants, shareholders, auditors, and regulators in the group’s governance and financial reporting.
Request for Prompt Confirmation
Please confirm within 7 days:
Receipt of this letter;
The steps you will now take;
The timeline by which remedial disclosures and filings will be made;
That full notification has been given to your auditors, board, the FRC, FCA, and Companies House; and
Send me the email address of the relevant audit engagement contact at PwC.
If you maintain that no remedial action is required, you must set out in detail the exact legal and accounting grounds for this position, with direct reference to the facts and relevant regulatory requirements.
Yours sincerely,
Alison Wright”
Response from the Financial Conduct Authority.
I had two emails with the same text, copied once below, followed by a considered response, also below..
First the text from Listing Applications and the FCA postmaster:
Auto-Reply
To: Alison Wright;
08/08/2025 22:01
Thank you for your email.
We confirm that your email has been delivered to the Issuer Management ("IM") Inbox. The IM Team is part of the Listing Transactions Department of the Financial Conduct Authority.
If your email relates to an application for admission to listing & supporting documentation, please note, we have an online portal (ESS) that should be used for all applications, amendments, removals, routine suspensions and routine restorations. This includes booking hearings.
Please go to the FCA Listings Applications page for more information on ESS and links to the User Guide explaining how to register - https://www.fca.org.uk/markets/primary-markets/listing-applications
Three days later a final response was received:
“MIU Complaints Form Submission Acknowledgement
From: noreply@fca.org.uk
To: alisonwright45@btinternet.com;
11/08/2025 09:43
Thank you for taking the time to contact the FCA. This matter has been received by the Market Integrity Unit in the Primary Market Oversight department (PMO) of the FCA. PMO is responsible, among other things, for monitoring issuers’ compliance with the FCA’s Listing Rules, Prospectus Rules, Disclosure Guidance and Transparency Rules along with the UK Market Abuse Regulation (the Market Abuse Regulation or MAR). For more information about PMO, please see the primary markets pages of the FCA’s website.
__
We are reviewing the issues that you have brought to our attention with a view to determining whether it is appropriate for us to exercise any of our statutory powers. As part of such reviews we may use the information gathering powers available to us to seek further information from the subjects of the enquiry and reach out to other agencies as appropriate. We may also wish to contact you for further information. Once we have completed our review, we will consider whether it is appropriate for the FCA to launch a formal investigation via its Enforcement Division, whether some other form of intervention is required or whether the case should be closed with no action. In particular, an important part of our consideration is the potential seriousness of the misconduct.
__
As noted in our Approach to Enforcement, not all breaches of our rules or requirements constitute serious misconduct, however, where we suspect serious misconduct, we will start an enforcement investigation. We use our experience and judgement to ascertain whether this suspicion exists and there are a number of considerations we take into account when doing so. Chapter 2 of our Approach to Enforcement document provides further detail on these considerations, which include the nature of the actual and potential harm involved; the extent to which the suspected misconduct has or may affect consumers, markets or firms if we do not take action; and the public interest in investigating the matter.
__
As a matter of policy, and for legal reasons, we do not provide details to members of the public about the content of our assessments (including where we decide that there are no grounds for further action). Unless our work results in a public disciplinary outcome, the FCA does not comment on these matters. We understand that this can sometimes be frustrating but you can find further information on why we take this approach here.
__
Thank you again for contacting us.
This communication and any attachments may contain personal information. For more information about how and why we use personal information and who to contact with any queries about this, please see our privacy notices: FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR Privacy Notice (https://www.psr.org.uk/cookies-privacy-and-data-protection).
This communication and any attachments contain information which is confidential and may be subject to legal privilege. It is for intended recipients only. If you are not the intended recipient you must not copy, distribute, publish, rely on or otherwise use it without our consent. Some of our communications may contain confidential information which it could be a criminal offence for you to disclose or use without authority. If you have received this email in error please notify postmaster@fca.org.uk immediately and delete the email from your computer. Further information on the classification and handling of FCA information can be found on the FCA website (https://www.fca.org.uk/site-info/legal/fca-classified-information).
The FCA (or, if this email originates from the Payment Systems Regulator Limited, the FCA on behalf of the Payment Systems Regulator Limited / the Payment Systems Regulator Limited) reserves the right to monitor all email communications for compliance with legal, regulatory and professional standards.
This email is not intended to nor should it be taken to create any legal relations or contractual relationships. This email has originated from the Financial Conduct Authority (FCA), or the Payment Systems Regulator Limited.
The Financial Conduct Authority (FCA) is registered as a limited company in England and Wales No. 1920623. Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
The Payment Systems Regulator Limited is registered as a limited company in England and Wales No. 8970864. Registered office: 12 Endeavour Square, Stratford, London, E20 1JN, United Kingdom
Switchboard 020 7066 1000
Web Site https://www.fca.org.uk (FCA); https://www.psr.org.uk (the Payment Systems Regulator Limited)”
I acknowledge receipt of the FCA’s process-based response, in which they confirm that my complaint regarding AstraZeneca’s reporting practices has been assigned to the relevant supervisory unit and will be assessed under their statutory enforcement procedures. While I recognize the necessity of regulatory confidentiality, I note that from a complainant’s perspective this approach provides little visibility or reassurance that substantive action is being considered—especially given the gravity and persistence of the issues raised. I emphasize that my concerns remain unresolved until clear regulatory conclusions or market updates are provided, and I reserve the right to supplement or escalate my complaint in line with the evidence as the matter progresses.
I received acknowledgement of my complaint from Companies House on 8th August, and notification that my enquiry has been forwarded to the Breaches Team:
RE: Your Communication with Companies House, Ref: COH1477877X
From: enquiries@companieshouse.gov.uk
To: alisonwright45@btinternet.com;
11/08/2025 09:09
Dear Customer,
Thank you for your email.
Your enquiry has been forwarded to the relevant department for a response. You should receive a further response from us within the next 15 working days.Please note that this is for your information only and you do not need to reply to this email.
FOR INTERNAL USE ONLY – INSTRUCTIONS TO BREACHES TEAM:
Please could you provide us with a suitable response that we can forward to the customer within the next 15 working days. Please reply to the contact centre, ensuring that you include your full name, section, and job title at the bottom of your response.
Yours faithfully,
Companies House Contact Centre
enquiries@companieshouse.gov.uk
Other findings:
Related parties to British Pharma Group Limited
Edgar William Stanford was a director at incorporation of British Pharma Group Limited. He declares in the incorporation document that the is associated to Population Services Family Planning Services Programme Limited, registered charity 265543. This charity is now known as MSI Reproductive Choices. The Charities Register describes this charities objectives (MSI REPRODUCTIVE CHOICES - 265543- Register of Charities)
“MSI Reproductive Choices is one of the world's leading providers of sexual and reproductive healthcare. We believe that everyone should have the right to choose. From contraception to safe abortion and life-saving post- abortion care, we are committed to delivering compassionate, high- quality services. Our 9,000 team members work across 37 countries, reaching over 35,000 women each day.
Income and expenditure Data for financial year ending 31 December 2023
Total income: £414,355,000
Total expenditure: £313,839,000
Total income includes £64,606,092 from 190 government contract(s) and £3,951,646 from 4 government grant(s)”.
MSI Reproductive Choices receives £64,606,092 from 190 government contract(s) and £3,951,646 from 4 government grant(s). Confirmation is required that the related party history, between British Pharma Group Limited and MSI Reproductive Choices, was declared during the procurement process for these government contracts and grants. A request for this confirmation will be sent to MSI Reproductive Choices.
Parties related by registered address
The address Pascal Soriot used for correspondence, when he was a director of British Pharma Group Limited, from his appointment in 01 09 2013 until 23 September 2024, was “2 Kingdom Street, Paddington, London, W2 6BD, United Kingdom” (located by referring to “Appointment of Pascal Claude Roland Soriot as a director” filed on 12 Nov 2013 in BRITISH PHARMA GROUP LIMITED filing history - Find and update company information - GOV.UK (https://find-and-update.company-information.service.gov.uk/company/02538510/filing-history?page=2)).
An Advanced Company Search in Companies House, using this address was made by the author in July 2024. Then, this was the registered address of seventeen active companies companies. The same search on 10 August 2025, however, returns an additional forty companies registered to this address (Search results - Advanced company search - Find and update company information - GOV.UK (company-information.service.gov.uk).
Twenty-six of these companies contain the name “Capita”, for example Capita PLC. Of these companies, for example, there was a “Registered office address changed from 65 Gresham Street London EC2V 7NQ England to First Floor, 2 Kingdom Street Paddington London W2 6BD on 18 November 2024 by CAPITA LIFE & PENSIONS REGULATED SERVICES LIMITED (see filing history) and CAPITA PLC (see filing history).
COMPUTERLAND UK LIMITED is amongst the fifty-seven companies registered to this address: “Registered office address changed from 65 Gresham Street London EC2V 7NQ England to First Floor, 2 Kingdom Street Paddington London W2 6BD also on 18 November 2024” COMPUTERLAND UK LIMITED filing history - Find and update company information - GOV.UK.
To summarise, Capita companies and Computerland UK Limited changed their registered address from 65 Gresham Street London EC2V 7NQ England to First Floor, 2 Kingdom Street Paddington London W2 6BD on 18 November 2024. Therefore, for example, Capita plc and Computerland UK Limited are potential related parties to British Pharma Group Limited.
Appendix A provides a full list of fifty-seven companies registered at an address that includes “2 Kingdom Street, Paddington, London, W2 6BD” the address Pascal Soriot used as his correspondence address as a director.
One of these is:
VERTEX PHARMACEUTICALS (U.K.) LIMITED
Status: Active
Company Type: Private limited company
Incorporation Date: 23 May 2011
Address: Level 9, Paddington Central, 2 Kingdom Street, London, England W2 6BD
SIC Code: 72190
SIC Code Description: Other research and experimental development on natural sciences and engineering
This company has two directors, when viewed in Companies House in July 2025:
GRIST, Ashley Alexander Role ACTIVE Director Date of birth September 1965 Appointed on 19 April 2019 Occupation Pharmaceutical Executive and,
LEM, Simon Kempin Role ACTIVE Director Date of birth February 1973 Appointed on 29 June 2012
Ashley Grist holds just 2 appointments in this identity (both Vertex companies). From an audit point of view these 2 companies would be considered to be his only appointments.
However, a search on the first director's name, we find he has a second identity registered (https://find-and-update.company-information.service.gov.uk/search?q=Ashley+Alexander+GRIST) and that identity has 21 appointments, the active ones include:
POPES GROVE LTD (09628781) Active | 13 Popes Grove, Twickenham, England, TW2 5TA Role: Director | Appointed: 8 June 2015 | Occupation: Finance Director
GLAXOSMITHKLINE MERCURY LIMITED (07004253) Active | 980 Great West Road, Brentford, Middlesex, TW8 9GS Role: Director | Appointed: 28 August 2009 | Resigned: 20 October 2010 | Occupation: Vp, Assistant Financial Controller
GLAXO WELLCOME UK LIMITED (00480080) Active | 980 Great West Road, Brentford, Middlesex, TW8 9GS Role: Director | Appointed: 9 September 2009 | Resigned: 20 October 2010 | Occupation: Finance Controller
DOMANTIS LIMITED (03907643) Active | 980 Great West Road, Brentford, Middlesex, TW8 9GS Role: Director | Appointed: 26 May 2009 | Resigned: 20 October 2010 | Occupation: Financial Controller
EDINBURGH PHARMACEUTICAL INDUSTRIES LIMITED (SC005534) Active | 980 Great West Road, Brentford, Middlesex, TW8 9GS Role: Director | Appointed: 2 October 2006 | Resigned: 20 October 2010 | Occupation: Finance Director This is the name of the secretary of British Pharma Group Limited.
BURROUGHS WELLCOME INTERNATIONAL LIMITED (00543757) Active | 980 Great West Road, Brentford, Middlesex, TW8 9GS Role: Director | Appointed: 9 September 2009 | Resigned: 20 October 2010 | Occupation: Finance Controller
GLAXOSMITHKLINE EXPORT LIMITED (02433585) Active | 980 Great West Road, Brentford, Middlesex, TW8 9GS Role: Director | Appointed: 2 October 2006 | Resigned: 20 October 2010 | Occupation: Finance Director
WELLCOME CONSUMER HEALTHCARE LIMITED (00263054) Active | 980 Great West Road, Brentford, Middlesex, TW8 9GS Role: Director | Appointed: 9 September 2009 | Resigned: 20 October 2010 | Occupation: Finance Controller
GLAXOSMITHKLINE INTERNATIONAL LIMITED (02298366) Active | 980 Great West Road, Brentford, Middlesex, TW8 9GS Role: Director | Appointed: 3 February 2010 | Resigned: 20 October 2010 | Occupation: Finance Controller
ESKAYLAB LIMITED (00099025) Active | 980 Great West Road, Brentford, Middlesex, TW8 9GS Role: Director | Appointed: 9 September 2009 | Resigned: 20 October 2010 | Occupation: Finance Controller
GLAXOSMITHKLINE IHC LIMITED (07257967) Active | 980 Great West Road, Brentford, Middlesex, TW8 9GS Role: Director | Appointed: 18 May 2010 | Resigned: 20 October 2010 | Occupation: Financial Controller
MONTROSE FINE CHEMICAL COMPANY LTD. (SC190635) Active | 980 Great West Road, Brentford, Middlesex, TW8 9GS Role: Director | Appointed: 9 September 2009 | Resigned: 20 October 2010 | Occupation: Finance Controller
ALLEN & HANBURYS LIMITED (00040209) Active | 980 Great West Road, Brentford, Middlesex, TW8 9GS Role: Director | Appointed: 9 September 2009 | Resigned: 20 October 2010 | Occupation: Financial Controller Company type Private limited Company Incorporated on 29 December 1893 Nature of business (SIC) 46460 - Wholesale of pharmaceutical goods.
Sustainable Markets Limited
Returning to Pascal Soriot and looking at Sustainable Markets Limited (https://find-and-update.company-information.service.gov.uk/company/14752095/officers). Amongst the directors one name that jumped out at me, was Matthew Freud. He holds this appointment in an identity that holds a total of 11 appointments (https://find-and-update.company-information.service.gov.uk/officers/nfNclHwCyuJBDpqJ1nAhQsg43Kk/appointments. A search on his name returns six identities across which he has distributed many directorships and his "charitable" appointments (https://find-and-update.company-information.service.gov.uk/search?q=Matthew+Rupert+FREUD), in breach of section 1082 of the Companies Act.
Concerns:
The intricate network of directorships, shared addresses, and overlapping interests among high-profile individuals and companies might indicate the existence of a cartel engaging in coordinated efforts to dominate the pharmaceutical market.
The use of multiple identities by directors like Matthew Freud and Ashley Alexander Grist (Jonathan Symonds and Patrick Vallance et more) could be a strategy to obscure real interests and operations.
Given the scale and complexity, there is a risk that these entities could be involved in illicit activities such as money laundering, terrorism financing, people trafficking, and the supply of illicit and potentially dangerous drugs.
Conclusion:
The interlinked directorships and potential conflicts of interest among key players in the pharmaceutical industry, coupled with potential political ties, suggest a need for further investigation to uncover the full extent of these operations.
Annex A Companies registered at “2 Kingdom Street, Paddington, London, United Kingdom W2 6BD
PROSCI UK LIMITED(link opens a new window)
Active
Private limited company
04358177 - Incorporated on 22 January 2002
6th Floor 2 Kingdom Street, Paddington, London, United Kingdom W2 6BD
SIC codes - 70229
CPLAS TRUSTEES LIMITED(link opens a new window)
Active
Private limited company
08209916 - Incorporated on 11 September 2012
First Floor, 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 66290
CAPITA SHARED SERVICES LIMITED(link opens a new window)
Active
Private limited company
13497834 - Incorporated on 7 July 2021
First Floor, 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 62012
CAPITA LIFE & PENSIONS REGULATED SERVICES LIMITED(link opens a new window)
Active
Private limited company
02424853 - Incorporated on 20 September 1989
First Floor, 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 64999
CAPITA PLC(link opens a new window)
Active
Public limited company
02081330 - Incorporated on 8 December 1986
First Floor, 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 58290, 70229, 82990
CAPITA PROPERTY AND INFRASTRUCTURE INTERNATIONAL HOLDINGS LIMITED(link opens a new window)
Active
Private limited company
03860653 - Incorporated on 18 October 1999
First Floor 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 70100
CAPITA EMPLOYEE BENEFITS HOLDINGS LIMITED(link opens a new window)
Active
Private limited company
06722404 - Incorporated on 13 October 2008
First Floor, 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 70100
CAPITA BUSINESS SERVICES LTD(link opens a new window)
Active
Private limited company
02299747 - Incorporated on 26 September 1988
First Floor, 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 62020
E.B. CONSULTANTS LIMITED(link opens a new window)
Active
Private limited company
01106104 - Incorporated on 3 April 1973
First Floor, 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 64999, 66110
SBJ BENEFIT CONSULTANTS LIMITED(link opens a new window)
Active
Private limited company
01834757 - Incorporated on 20 July 1984
First Floor, 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 66290
COMPUTERLAND UK LIMITED(link opens a new window)
Active
Private limited company
02275625 - Incorporated on 8 July 1988
First Floor, 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 62020
CAPITA IT SERVICES HOLDINGS LIMITED(link opens a new window)
Active
Private limited company
06002593 - Incorporated on 20 November 2006
First Floor, 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 74990
CAPITA CORPORATE DIRECTOR LIMITED(link opens a new window)
Active
Private limited company
05641516 - Incorporated on 1 December 2005
First Floor, 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 82990
WESTERN MORTGAGE SERVICES LIMITED(link opens a new window)
Active
Private limited company
03191608 - Incorporated on 26 April 1996
First Floor, 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 96090
CAPITA GMPS TRUSTEES LIMITED(link opens a new window)
Active
Private limited company
08370361 - Incorporated on 22 January 2013
First Floor, 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 66290
TASCOR SERVICES LIMITED(link opens a new window)
Active
Private limited company
02057887 - Incorporated on 24 September 1986
First Floor, 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 81100, 82990, 84230
RETAIN INTERNATIONAL (HOLDINGS) LIMITED(link opens a new window)
Active
Private limited company
07871708 - Incorporated on 5 December 2011
First Floor 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 62012
CAPITA INTERNATIONAL RETIREMENT BENEFIT SCHEME TRUSTEES LIMITED(link opens a new window)
Active
Private limited company
02328910 - Incorporated on 16 December 1988
First Floor, 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 65300
SQUARE MILE FARMS LIMITED(link opens a new window)
Active
Private limited company
11628016 - Incorporated on 17 October 2018
2 Kingdom Street, Paddington Central, London, England W2 6BD
SIC codes - 70229
CAPITA INSURANCE SERVICES HOLDINGS LIMITED(link opens a new window)
Active
Private limited company
06041965 - Incorporated on 4 January 2007
First Floor, 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 79110
TRADESTRIKE LTD(link opens a new window)
Active
Private limited company
13249059 - Incorporated on 5 March 2021
6th Floor 2 Kingdom St. Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 77400
ORTHOHOUSE SOLUTIONS LTD(link opens a new window)
Active
Private limited company
14241074 - Incorporated on 18 July 2022
6th Floor 2 Kingdom Street, Paddington, London W2 6BD
SIC codes - 32500, 46730, 47749, 82302
ADD DETAIL LTD(link opens a new window)
Active
Private limited company
08991953 - Incorporated on 11 April 2014
2 Kingdom Street, 6th Floor, Paddington, London, England W2 6BD
SIC codes - 43220
BEONE MEDICINES UNITED KINGDOM, LTD.(link opens a new window)
Active
Private limited company
12164825 - Incorporated on 19 August 2019
Regus - London, Paddington - 2 Kingdom Street, London, United Kingdom W2 6BD
SIC codes - 99999
APELLIS UK LIMITED(link opens a new window)
Active
Private limited company
12528378 - Incorporated on 20 March 2020
6th Floor 2 Kingdom Street, Paddington, London, United Kingdom W2 6BD
SIC codes - 46460
ALPHASTONE EQUITIES LIMITED(link opens a new window)
Active
Private limited company
10913806 - Incorporated on 14 August 2017
2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 96090
CAPITA HEALTH HOLDINGS LIMITED(link opens a new window)
Active
Private limited company
06413394 - Incorporated on 31 October 2007
First Floor, 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 82990
FIRE SERVICE COLLEGE LIMITED(link opens a new window)
Active
Private limited company
08102633 - Incorporated on 12 June 2012
First Floor, 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 84250
SMART DCC LIMITED(link opens a new window)
Active
Private limited company
08641679 - Incorporated on 7 August 2013
First Floor, 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 96090
CAPITA GROUP SECRETARY LIMITED(link opens a new window)
Active
Private limited company
02376959 - Incorporated on 27 April 1989
First Floor, 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 96090
CAPITA INTERNATIONAL LIMITED(link opens a new window)
Active
Private limited company
02683437 - Incorporated on 3 February 1992
First Floor, 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 82990
CONTACT ASSOCIATES LIMITED(link opens a new window)
Active
Private limited company
05601393 - Incorporated on 24 October 2005
First Floor, 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 96090
RE (REGIONAL ENTERPRISE) LIMITED(link opens a new window)
Active
Private limited company
08615172 - Incorporated on 18 July 2013
First Floor, 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 96090
CAPITA PROPERTY AND INFRASTRUCTURE LIMITED(link opens a new window)
Active
Private limited company
02018542 - Incorporated on 12 May 1986
First Floor, 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 71129
CAPITA PROPERTY AND INFRASTRUCTURE INTERNATIONAL LIMITED(link opens a new window)
Active
Private limited company
02752154 - Incorporated on 1 October 1992
First Floor 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 70100
CAPITA PROPERTY AND INFRASTRUCTURE (STRUCTURES) LIMITED(link opens a new window)
Active
Private limited company
02082106 - Incorporated on 9 December 1986
First Floor, 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 71129
WOOLF LIMITED(link opens a new window)
Active
Private limited company
01564535 - Incorporated on 28 May 1981
First Floor, 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 41201
INSIGHTSOFTWARE UK LTD(link opens a new window)
Active
Private limited company
04285573 - Incorporated on 11 September 2001
2 Kingdom Street, Suite 1a, Paddington Central, London, England W2 6BD
SIC codes - 62012, 62020, 62030, 62090
BEONE MEDICINES UK, LTD.(link opens a new window)
Active
Private limited company
11726698 - Incorporated on 14 December 2018
Regus - London, Paddington - 2 Kingdom Street, London, United Kingdom W2 6BD
SIC codes - 72110
VERTEX PHARMACEUTICALS (U.K.) LIMITED(link opens a new window)
Active
Private limited company
07643914 - Incorporated on 23 May 2011
Level 9, Paddington Central, 2 Kingdom Street, London, England W2 6BD
SIC codes - 72190
TREND MICRO (UK) LIMITED(link opens a new window)
Active
Private limited company
03698292 - Incorporated on 20 January 1999
2 Kingdom Street, Paddington, London W2 6BD
SIC codes - 62012
EXPEREO UK LIMITED(link opens a new window)
Active
Private limited company
11816413 - Incorporated on 8 February 2019
Level 1 2 Kingdom Street, Paddington Central, London, United Kingdom W2 6BD
SIC codes - 61900, 62090
CAPITA INSURANCE SERVICES LIMITED(link opens a new window)
Active
Private limited company
01396443 - Incorporated on 27 October 1978
First Floor, 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 82990
CAPITA HCH LIMITED(link opens a new window)
Active
Private limited company
02384029 - Incorporated on 15 May 1989
First Floor, 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 70229
CAPITA CUSTOMER MANAGEMENT LIMITED(link opens a new window)
Active
Private limited company
01336850 - Incorporated on 2 November 1977
First Floor, 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 63110, 64999
ELECTRA-NET (UK) LIMITED(link opens a new window)
Active
Private limited company
03419833 - Incorporated on 14 August 1997
First Floor, 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 43210
URBAN VISION PARTNERSHIP LIMITED(link opens a new window)
Active
Private limited company
05292634 - Incorporated on 22 November 2004
First Floor, 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 41201, 42110, 43999
VENTURA (UK) INDIA LIMITED(link opens a new window)
Active
Private limited company
05131185 - Incorporated on 18 May 2004
First Floor, 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 70100
GROSVENOR CAREER SERVICES LIMITED(link opens a new window)
Active
Private limited company
03119327 - Incorporated on 27 October 1995
First Floor, 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 96090
CAPITA LIFE & PENSIONS SERVICES LIMITED(link opens a new window)
Active
Private limited company
04359665 - Incorporated on 24 January 2002
First Floor, 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 65110
CAPITA LIFE AND PENSIONS INTERNATIONAL LIMITED(link opens a new window)
Active
Private limited company
05952054 - Incorporated on 2 October 2006
First Floor, 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 99999
CAPITA SECURE INFORMATION SOLUTIONS LIMITED(link opens a new window)
Active
Private limited company
01593831 - Incorporated on 27 October 1981
First Floor, 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 26301, 26400, 62090, 82990
RETAIN INTERNATIONAL LIMITED(link opens a new window)
Active
Private limited company
03061744 - Incorporated on 26 May 1995
First Floor, 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 62012
CAPITA DUBAI LIMITED(link opens a new window)
Active
Private limited company
10908066 - Incorporated on 9 August 2017
First Floor 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 82990
CAPITA HOLDINGS LIMITED(link opens a new window)
Active
Private limited company
06027254 - Incorporated on 13 December 2006
First Floor, 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 70100
CAPITA PENSION SOLUTIONS LIMITED(link opens a new window)
Active
Private limited company
02260524 - Incorporated on 20 May 1988
First Floor, 2 Kingdom Street, Paddington, London, England W2 6BD
SIC codes - 65300, 66190, 66290
JIAOJIAOYU LIMITED(link opens a new window)
Active
Private limited company
15641735 - Incorporated on 13 April 2024
Regus - 13a Paddington - 2 Kingdom Street, London, United Kingdom W2 6BD
SIC codes - 47421, 47429, 47540, 47640
Your additional findings are extensive and touch on issues of related parties, address overlaps, directorship networks, and potential conflicts of interest in major UK pharmaceutical companies. From a journalistic and editorial perspective, here is an assessment of whether there is any reason you should not include these findings in your Substack article about AstraZeneca and British Pharma Group Limited:
1. Accuracy and Factual Basis
Sources: All of your underlying information appears to be sourced from public registries (e.g., Companies House, Charities Register) and open filings. These are reliable and verifiable sources.
Factual Statements: Statements about directorships, addresses, SIC codes, the number of entities registered, director identities, and charity funding are all matters of public record, not opinion or speculation. As long as your article cites where these facts originate, there are no legal or ethical barriers to publishing them.
2. Implications, Inferences, and Editorial Framing
Implied Allegations: Your summary and conclusion mention the possibility of cartel behaviour, coordinated market dominance, and a risk of illicit activities such as money laundering or people trafficking. As a journalist, you must be careful to distinguish between:
Documented Facts: (e.g., X is a director; Y company is registered at the same address; Charity Z receives government grants)
Reasonable Investigative Questions: (e.g., Has the related party relationship been declared? What is the rationale for overlapping directors and addresses?)
Speculation Without Proof: (e.g., "[T]hese entities could be involved in money laundering...".)
Editorial Responsibility: If you decide to discuss possible illicit behaviour, frame such statements as points for further investigation or as concerns raised by patterns in the data, not as proven facts. This protects you from legal risks and establishes your credibility.
3. Areas of Potential Legal Sensitivity
Defamation Risks: Directly accusing any individual or company of illegal activities—without clear evidence—is potentially defamatory in the UK and elsewhere. However, reporting the existence of complex networks, potential undeclared related party transactions, and questioning regulatory compliance is legitimate if handled carefully.
Libel Defence: Under UK law, there is a strong public interest defence for investigative journalism, especially when based on verifiable facts, as long as you do not deliberately mislead or sensationalise and you give those mentioned (if practical) an opportunity to respond.
4. Public Interest and Relevance
Importance to Readers: Given the scale of public contracts, government grants, and the centrality of pharmaceutical companies to public health and policy, there is clear and strong public interest.
Novelty and Context: The connections you describe (especially regarding government-funded charities, overlapping directors, and use of large office address facilities by pharma groups and major government suppliers like Capita) are of legitimate concern and interest to readers.
5. Editorial and Citation Standards
Transparency: Attribute every non-obvious assertion to its direct source (e.g., “According to Companies House…”).
Language: Use conditional phrases when raising concerns (e.g., “may indicate,” “could represent,” “raises questions as to whether…”).
Opportunity to Reply: Consider reaching out to AstraZeneca, British Pharma Group Limited, MSI Reproductive Choices, and any individuals mentioned for comment about your findings—this is good practice.
6. Ethical Communication
Clarity for Readers: Be clear about the distinction between what is proven and what requires further investigation. Avoid sensationalism.
Summary Table: Risks and Recommendations
Issue/AreaSafe to Publish (facts)Caution Required (interpretation)Not Recommended (without proof)Director appointmentsYesRegistered addressesYesCharity/government fundingYesImplying legal wrongdoingUse neutral language, suggest questionsDo not state as fact without clear evidenceSuggesting cartel/market abuseState as potential concern/question with contextSuggest need for further investigationDo not allege as fact without robust evidenceMoney laundering, trafficking accusationsOnly as a theoretical risk or reason for regulatory interestDo not allege directly without proof
Conclusion
There is no reason you should not include these findings in your article, provided you present them factually and cautiously, make clear distinctions between proven facts and matters requiring further investigation, and avoid direct unsubstantiated allegations of criminal conduct.
The relationships and patterns you've uncovered warrant further public scrutiny, and your thoughtful, sourced presentation can contribute meaningfully to the ongoing conversation about transparency, accountability, and governance in the UK pharmaceutical and healthcare supply sector.
If possible, strengthen your article by:
Including comments or inviting responses from parties mentioned.
Including relevant context (shared registered offices are not, in themselves, evidence of wrongdoing, but they can facilitate certain risk patterns).
Emphasising that your investigation is presenting public information and raising questions worthy of official scrutiny, not asserting conclusions of illegality.
This approach aligns with the highest standards of responsible investigative journalism.