Letter sent today, 28 May 2025: "Dear Ms Bainsfair and Mr Chalmers,
Thank you for publishing my consultation response (Submission 29) and for your March 2025 report, Recognising and Responding to Early Warning Signs in Public Sector Bodies. I welcome the report’s focus on systemic failures in oversight and accountability, which closely aligns with my concerns about identity fragmentation and its impact on ethical standards in public institutions.
While I recognise the significant progress made through the Economic Crime and Corporate Transparency Act 2023 and the introduction of identity verification at Companies House, I remain concerned that the transition to the new system could erase historical evidence of duplicate identities. This poses a risk to audit trails, the investigation of past misconduct, and the detection of conflicts of interest that may have been enabled by identity loopholes.
Request for a Cross-Agency Working Group
Given the systemic nature of these risks, I respectfully urge the Committee to recommend the establishment of a cross-agency working group to address the ethical and operational implications of fragmented identities in the UK’s public and corporate sectors. Such a group could draw on expertise from Companies House, the Public Sector Fraud Authority, Action Fraud, the National Crime Agency, the National Cyber Security Centre, and other relevant bodies.
The working group could:
Review how legacy identity data is handled during the transition to the new Companies House system, ensuring that evidence of past identity fragmentation is preserved for audit and enforcement purposes.
Assess the risks of identity fragmentation for fraud, conflicts of interest, and public trust in governance.
Develop best practice guidance for public bodies on identifying and mitigating risks arising from synthetic or fragmented identities.
Make recommendations for further regulatory or legislative action if required.
I would welcome the opportunity to present to this group, sharing first-hand experience of how identity loopholes in Companies House have enabled fraud and the concealment of interests, including the creation of clone companies. I believe this perspective could help inform practical solutions and raise awareness of the real-world impact of these issues.
Strengthening the House of Lords Code of Conduct
I am particularly concerned about the recent revisions to the House of Lords Code of Conduct, which have removed the requirement to declare non-financial interests and weakened the overall transparency framework. In light of the Committee’s remit to uphold the Seven Principles of Public Life and promote best practice, I urge you to make the following recommendations:
The Lords’ Code should be realigned with the Companies Act 2006 by requiring full disclosure of all directorships, paid or unpaid, and all relevant non-financial interests.
Treat Complaints as Valuable Feedback:
Adopt the CSPL’s own recommendation to maintain robust registration systems and ensure that concerns and complaints are used as opportunities to improve standards and transparency.
Audit Historical Identity Fragmentation:
Public bodies, including Parliament, should investigate cases where individuals hold multiple Companies House identities (such as Baroness Manningham-Buller’s NW1/SW1A records) to ensure there are no undeclared conflicts of interest. This should include systematic cross-referencing of the Lords’ Register of Interests with Companies House data to identify and address any gaps.
Amend the April 2025 Code:
Remove Section 3’s exemption for non-financial interests and reinstate Appendix B’s detailed definitions of registrable interests. Introduce clear penalties for peers who fail to reconcile fragmented identities or provide accurate declarations.
These steps are essential to restore public confidence, ensure compliance with statutory obligations, and prevent the recurrence of systemic failures identified in your recent report.
Thank you again for your leadership in promoting ethical standards in public life. I hope these suggestions will be of value as you continue your important work advising the Prime Minister and shaping best practice across the public sector.
Letter sent today, 28 May 2025: "Dear Ms Bainsfair and Mr Chalmers,
Thank you for publishing my consultation response (Submission 29) and for your March 2025 report, Recognising and Responding to Early Warning Signs in Public Sector Bodies. I welcome the report’s focus on systemic failures in oversight and accountability, which closely aligns with my concerns about identity fragmentation and its impact on ethical standards in public institutions.
While I recognise the significant progress made through the Economic Crime and Corporate Transparency Act 2023 and the introduction of identity verification at Companies House, I remain concerned that the transition to the new system could erase historical evidence of duplicate identities. This poses a risk to audit trails, the investigation of past misconduct, and the detection of conflicts of interest that may have been enabled by identity loopholes.
Request for a Cross-Agency Working Group
Given the systemic nature of these risks, I respectfully urge the Committee to recommend the establishment of a cross-agency working group to address the ethical and operational implications of fragmented identities in the UK’s public and corporate sectors. Such a group could draw on expertise from Companies House, the Public Sector Fraud Authority, Action Fraud, the National Crime Agency, the National Cyber Security Centre, and other relevant bodies.
The working group could:
Review how legacy identity data is handled during the transition to the new Companies House system, ensuring that evidence of past identity fragmentation is preserved for audit and enforcement purposes.
Assess the risks of identity fragmentation for fraud, conflicts of interest, and public trust in governance.
Develop best practice guidance for public bodies on identifying and mitigating risks arising from synthetic or fragmented identities.
Make recommendations for further regulatory or legislative action if required.
I would welcome the opportunity to present to this group, sharing first-hand experience of how identity loopholes in Companies House have enabled fraud and the concealment of interests, including the creation of clone companies. I believe this perspective could help inform practical solutions and raise awareness of the real-world impact of these issues.
Strengthening the House of Lords Code of Conduct
I am particularly concerned about the recent revisions to the House of Lords Code of Conduct, which have removed the requirement to declare non-financial interests and weakened the overall transparency framework. In light of the Committee’s remit to uphold the Seven Principles of Public Life and promote best practice, I urge you to make the following recommendations:
Reinstate Mandatory Non-Financial Interest Declarations:
The Lords’ Code should be realigned with the Companies Act 2006 by requiring full disclosure of all directorships, paid or unpaid, and all relevant non-financial interests.
Treat Complaints as Valuable Feedback:
Adopt the CSPL’s own recommendation to maintain robust registration systems and ensure that concerns and complaints are used as opportunities to improve standards and transparency.
Audit Historical Identity Fragmentation:
Public bodies, including Parliament, should investigate cases where individuals hold multiple Companies House identities (such as Baroness Manningham-Buller’s NW1/SW1A records) to ensure there are no undeclared conflicts of interest. This should include systematic cross-referencing of the Lords’ Register of Interests with Companies House data to identify and address any gaps.
Amend the April 2025 Code:
Remove Section 3’s exemption for non-financial interests and reinstate Appendix B’s detailed definitions of registrable interests. Introduce clear penalties for peers who fail to reconcile fragmented identities or provide accurate declarations.
These steps are essential to restore public confidence, ensure compliance with statutory obligations, and prevent the recurrence of systemic failures identified in your recent report.
Thank you again for your leadership in promoting ethical standards in public life. I hope these suggestions will be of value as you continue your important work advising the Prime Minister and shaping best practice across the public sector.
Yours sincerely,
Alison Wright"
My submission was included, partly redacted, in Accountability within Public Bodies
Open consultation responses
(Consultation period 25 March 2024 – 14 June 2024) https://www.gov.uk/government/publications/cspl-early-warning-signs-report-responses-to-open-consultation. However action to mitigate my trying to flag the warning signs of establishment identity fraud was not included in the subsequent report, published here on 25th March 2025: https://www.gov.uk/government/news/public-sector-must-get-better-at-recognising-and-responding-to-signs-of-trouble-doug-chalmers-committee-on-standards-in-public-life. Lessons have not been learnt.
Re: Response to consultation: Accountability within public bodies - acting on early warning signs
PS
To: alisonwright45@btinternet.com;
26/04/2024 09:23
Dear Alison Wright
Thank you for your email of 25 April with your response to our consultation on "Accountability within public bodies - acting on early warning signs" .
Kind regards.
CSPL Secretariat
Committee on Standards in Public Life
E: public@public-standards.gov.uk 1 Horse Guards Road, London, SW1A 2HQ
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