Sir Paul Marshall, Alan McCormick, Lord Hill and Oliver Plunkett of Alliance for Responsible Citizenship Limited (ARC): Compliance Assessment

Legatum Institute and other interests; Breaches of laws, regulations and guidance present a high risk to the public's best interest.

Alliance for Responsible Citizenship Limited (ARC): Compliance Assessment.

Active directors: Sir Paul Marshall and Alan McCormick.

Resigned directors: Lord Hill and Oliver Plunkett.

Draft for public consultation. Individuals are identified who have breached sections of the Companies Act 2006, breaches that expose the public to the risk of money laundering, terrorism financing and people trafficking as they confound due diligence software. This method of fraud represents a high risk to the public’s best interests. Police investigation of my findings is required to include discovery of all financial transactions of the companies and individuals who are involved with identity and financial breaches. This compliance assessment was prepared with the assistance of Perplexity AI.

As with all my reports there is more information that needs to be included. This has some incomplete sections; evidence yet to be included and conclusions yet to be drawn.

1. Introduction and Purpose

This Compliance Assessment evaluates the directors of Alliance for Responsible Citizenship Limited, specifically; Sir Paul Marshall and Alan McCormick, and former directors Oliver Plunkett and Lord Hill of Oareford.

Table of contents.

1. Introduction and Purpose

2. Company Overview: Alliance for Responsible Citizenship Limited

3. Trading Disclosures Compliance Assessment of ARC Conference Invitation

4. Director Profiles including:

• Identification of interests

• Accounts Compliance Assessment

• Unique Identifier Compliance Assessment

• Openness and Transparency Assessment.

A. Sir Paul Marshall

B. Alan McCormick

C. Lord Hill of Oareford

D. Oliver Plunkett

Conclusion and Overall Compliance Assessment.

Context:

On 5th August 2024 I received a general email invitation from Jordan B. Peterson to the Alliance for Responsible Citizenship (ARC) conference, scheduled for 17-19 February 2025, in London. A copy of the invitation is provided in the image below, image 1: Invitation to the Alliance for Responsible Citizenship (ARC) Conference 2025.

Image 1: Invitation to the Alliance for Responsible Citizenship (ARC) Conference 2025, received 5/8/2023.

Upon reviewing the invitation I identified subtle breaches of Trading Disclosure legislation. The relevant guidance is outlined on Gov.uk under “Running a limited company: your responsibilities: Signs, stationery and promotional material.” This guidance is derived from the Trading Disclosures legislation and regulations, specifically Part 5 Chapter 6 Sections 82 to 85 of the Companies Act 2006 and PART 6 Regulations 20 to 29 of the Trading Disclosures of The Company, Limited Liability Partnership and Business Regulations 2015 (CTDR 2015). Non-compliance with these regulations can result in civil and criminal penalties for company directors.

The guidance, Running a limited company: your responsibilities: Signs, stationery and promotional material states:

“Running a limited company: your responsibilities -

Signs

You must display a sign showing your company name at your registered company address and wherever your business operates. If you’re running your business from home, you do not need to display a sign there. (…)

Stationery and promotional material

You must include your company’s name on all company documents, publicity and letters.

On business letters, order forms and websites, you must show:

• the company’s registered number

• its registered office address

• where the company is registered (England and Wales, Scotland or Northern Ireland)

• the fact that it’s a limited company (usually by spelling out the company’s full name including ‘Limited’ or ‘Ltd’)

If you want to include directors’ names, you must list all of them.

If you want to show your company’s share capital (how much the shares were worth when you issued them), you must say how much is ‘paid up’ (owned by shareholders).”

To assess whether a company is compliant with Company Trading Disclosures requirements (CTDR 2015), the company records in Companies House are located and compared with the information provided in the letter or website under review. In this way breaches, where they exist, can be identified.

Other compliance assessments.

Since 2022, I have been preparing compliance assessments focussing on compliance with the Companies Act 2006, specifically relating to: Integrity of annual accounts, compliance of individuals to holding one unique identifier in Companies House, and transparency of disclosures of interests.

Accounts Compliance:

Assessing whether, at a minimum, the annual accounts are “up to date” and that final accounts are up to date and have been delivered for dissolved companies as required by section 441 of the Companies Act 2006, duty to file accounts and reports with the registrar (s441:CA2006). This can be determined from the overview information provided by Companies House, in which overdue accounts are typically flagged with a warning sign.

Identity Compliance

Directors are required to maintain a single “unique identifier” in Companies House. Multiple unique identifiers for an individual obscures interests and compromises audits and Know Your Customer (KYC) checks. The presence of multiple “unique identifiers” represents a breach of Section 1082 of the Companies Act 2006, “Allocation of unique identifiers,” (S1082:CA2006). A search in Companies House on the name of the individual will typically return additional identities registered with the same name, a visual search can locate those with the same date of birth, if there are any.

Multiple identities cause “false non-match errors” in computer software, occurring during identity checks in “zero-trust”, cybersecure, systems. Therefore, the UK Government National Cyber Security Centre’s “Zero trust architecture design principles” also require people to be “uniquely identifiable” (Zero trust architecture design principles (ncsc.gov.uk)).

Transparency Compliance

Compliance is assessed by establishing whether all interests are disclosed in the Register of Interests, when available, or in biographies on associated company websites, using the principles derived from the House of Lords’ Code of Conduct (HLCC2023).

Principles for Disclosure of Directorship:

Complete Disclosure: Ensure all directorships are fully disclosed, without omissions, to provide a comprehensive view of business interests.

Consistency: Verify that information in the Register of Interests or biographies matches records in Companies House to avoid discrepancies.

Transparency: Clearly identify directorships, including company name, role, and, appointment/resignation dates for stakeholder understanding.

Accuracy: Maintain up-to-date and accurate details reflecting any changes in directorships promptly.

These principles can be tested by comparing the Register of Interests or biographies with appointments listed in Companies House.

This report will provide:

1. Trading Disclosure Compliance Assessments of the Alliance for Responsible Citizenship’s invitation and website, and related companies’ websites. Breaches are highlighted as “Non-compliant (CTDR 2015)”.

2. Unique Identity Compliance Assessments: Directors will be screened for multiple identities registered in Companies House. Breaches are highlighted as “Non-compliant (s1082:CA2006)”.

3. Accounts Compliance Assessments: Attention will be drawn to companies that have dissolved with accounts overdue, the risk being that unmonitored transactions may occur. Overdue accounts represents a breach of Section 441 of the Companies Act 2006. Breaches are highlighted as “Non-compliant (s441:CA2006)”.

4. Transparency and Openness Assessments: Interests disclosed in the Register of Interests, if available, and on biographies will be compared with interests registered in Companies House. Omissions are highlighted as “Non-compliant (HLCC2023)”.

This report aims to provide a comprehensive executive overview of compliance, related to trading disclosures, identity management, accounts, and transparency and openness, of the directors of Alliance for Responsible Citizenship Limited, based on the records viewed.

2. Alliance for Responsible Citizenship Limited

A search in Companies House for “Alliance for Responsible Citizenship” returns the company record (Alliance for Responsible Citizenship - Find https://find-and-update.company-information.service.gov.uk/search?q=Alliance+for+Responsible+Citizenship). The screenshot, below, shows the first two results only, see image 2: Search results for Alliance for Responsible Citizenship on 30/9/2024.

Image 2: Search results for Alliance for Responsible Citizenship on 30/9/2024.

The search record is reproduced below:

“ALLIANCE FOR RESPONSIBLE CITIZENSHIP LIMITED

10519995 - Incorporated on 12 December 2016

78 Pall Mall, London, England, SW1Y 5ES”

Note that the address on the invitation “78 Pall Mall, London, SW1Y 5ES”, omits “England” and refers to the same location as provided by Companies House as the registered address “78 Pall Mall, London, England, SW1Y 5ES”. This anomaly will be revisited Trading Disclosures compliance assessment, after considering the Companies House records in more detail.

Alliance for Responsible Citizenship Overview:

The records for this company are reached by clicking on the underlined name in Companies House (and herein). See image 3: Alliance for Responsible Citizenship Limited’s company overview record on 30/9/2024.

Image 3: Alliance for Responsible Citizenship Limited, record in Companies House on 30/09/2024

ALLIANCE FOR RESPONSIBLE CITIZENSHIP LIMITED overview:

“ALLIANCE FOR RESPONSIBLE CITIZENSHIP LIMITED Company number 10519995 Registered office address 78 Pall Mall, London, England, SW1Y 5ES Company status Active Company type Private limited Company Incorporated on 12 December 2016 Accounts Up to date Next accounts made up to 31 December 2023 due by 30 September 2024 Last accounts made up to 31 December 2022 Confirmation statement Up to date Next statement date 19 May 2025 due by 2 June 2025 Last statement dated 19 May 2024 Nature of business (SIC) 85520 - Cultural education Previous company names PROSPERITY UK 2017 LIMITED 12 Dec 2016 - 20 Jan 2023”

Alliance for Responsible Citizenship Limited officers:

The Companies House record has a tab called “people” (as seen in the image above) which provides the details of the officers (directors and secretary, if any) appointed to the company.

The officer details are copied below (the weblinks, associated to underlined text, are embedded in the data copied from Companies House).

ALLIANCE FOR RESPONSIBLE CITIZENSHIP LIMITED people:

“ALLIANCE FOR RESPONSIBLE CITIZENSHIP LIMITED

5 officers / 3 resignations

MARSHALL, Paul Roderick Clucas Correspondence address 78 Pall Mall, London, England, SW1Y 5ES Role Active Director Date of birth August 1959 Appointed on 12 December 2016 Nationality British Country of residence England Occupation Investment Manager

MCCORMICK, Alan James Correspondence address Legatum Plaza, Level 2, Gate Precinct 6, Dubai International Finance Centre, PO BOX 506625, Dubai, United Arab Emirates Role Active Director Date of birth June 1974 Appointed on 9 February 2023 Nationality British Country of residence United Arab Emirates Occupation Managing Director

PLUNKETT, Oliver Correspondence address C/o Wpo Limited, First Floor, 6 Grosvenor Street, London, United Kingdom, W1K 4PZ Role Resigned Secretary Appointed on 15 January 2017 Resigned on 19 January 2017

HILL, Jonathan Hopkin, The Rt Hon. The Lord Correspondence address 11 Charles Street, London, England, W1J 5DW Role Resigned Director Date of birth July 1960 Appointed on 31 January 2018 Resigned on 10 February 2023 Nationality British Country of residence England Occupation Self-Employed

PLUNKETT, Oliver Correspondence address 20 Eastbourne Terrace, London, England, W2 6LG Role Resigned Director Date of birth April 1972 Appointed on 19 January 2017 Resigned on 19 January 2018 Nationality British Country of residence England Occupation Company Director”

Summary of Active Directors:

Paul Roderick Clucas Marshall, born August 1959, was appointed on 12 December 2016, with occupation as Investment Manager. He uses the company’s registered address for his correspondence, 78 Pall Mall, London, England, SW1Y 5ES.

Alan James McCormick, born June 1974, appointed on 9 February 2023, is the Managing Director. He is British and resident in the United Arab Emirates. He gives his correspondence address as Legatum Plaza, Level 2, Gate Precinct 6, Dubai International Finance Centre, PO BOX 506625, Dubai, United Arab Emirates Role.

Summary of Resigned Individuals

Oliver Plunkett was appointed as secretary on 15 January 2017 and resigned on 19 January 2017. His correspondence address is C/o Wpo Limited, First Floor, 6 Grosvenor Street, London, United Kingdom, W1K 4PZ. On the same day, Oliver Plunkett, born April 1972, was appointed as a director, 19 January 2017, and resigned on 19 January 2018. He gave his occupation as Company Director and used a different correspondence address, 20 Eastbourne Terrace, London, England, W2 6LG.

Unusual activity: Oliver Plunkett:

1. Rapid Changes in Roles: Oliver Plunkett's brief tenure as secretary (four days) followed by his immediate appointment and subsequent resignation as a director within a year suggests unusual activity.

2. Different Correspondence Addresses: The use of different correspondence addresses for his roles as secretary and director might indicate an attempt to separate these roles or could simply reflect administrative choices. Oliver Plunkett’s correspondence address The address used as a secretary “C/o Wpo Limited, First Floor, 6 Grosvenor Street, London, United Kingdom, W1K 4PZ”, associates the Alliance for Responsible Citizenship Limited with “WPO Limited” and the address “First Floor, 6 Grosvenor Street, London, United Kingdom, W1K 4PZ”. These associations require testing for potential related party transactions.

3. Assumption of Identity: A human might assume that both roles were held by the same individual based on the name and company name aligning. However, if these two appointments are held in two separate “unique identifiers” computer software would identify these records as belonging to two different individuals. This will be explored further.

Jonathan Hopkin Hill, The Rt Hon. The Lord, born July 1960, was appointed as a director on 31 January 2018 and resigned on 10 February 2023. He gave his occupation as Self-Employed. He is British and resident in England. His correspondence address is 11 Charles Street, London, England, W1J 5DW.

Alliance for Responsible Citizenship Persons with significant control:

The Persons with significant control are accessible via the “People” tab, in the company record. This states:

ALLIANCE FOR RESPONSIBLE CITIZENSHIP LIMITED persons with significant control

“5 active persons with significant control / 0 active statements

Mr Philip Anthony Vassiliou Active Correspondence address PO Box 506625, Legatum Plaza, Level 2, Gate Precinct 6, PO BOX 506625, Dubai, United Arab Emirates (sic) Notified on 31 December 2024 Date of birth March 1977 Nationality British

Mr Alan James Mccormick Active Correspondence address Legatum Plaza, Level 2, Gate Precinct 6, PO BOX 506625, Dubai International Financial Centre, Dubai, United Arab Emirates Notified on 10 February 2023 Date of birth June 1974 Nationality British Country of residence United Arab Emirates Nature of control Has significant influence or control

Mr Christopher Lincoln Chandler Active Correspondence address Legatum Plaza, Level 2, Gate Precinct 6, PO BOX 506625, Dubai International Financial Centre, Dubai, United Arab Emirates Notified on 10 February 2023 Date of birth January 1960 Nationality New Zealander Country of residence United Arab Emirates Nature of control Has significant influence or control

Mr Richard Edward Douglas Active Correspondence address Legatum Plaza, Level 2, Gate Precinct 6, PO BOX 506625, Dubai International Financial Centre, Dubai, United Arab Emirates Notified on 10 February 2023 Date of birth May 1953 Nationality Cayman Islander Country of residence Cayman Islands Nature of control Has significant influence or control

Mr Paul Roderick Clucas Marshall Active Correspondence address 78 Pall Mall, London, England, SW1Y 5ES Notified on 12 December 2016 Date of birth August 1959 Nationality British Country of residence England Nature of control Ownership of shares – More than 25% but not more than 50% Ownership of voting rights - More than 25% but not more than 50%

Mr Mark Alan Stoleson Ceased Correspondence address Legatum Plaza, Level 2, Gate Precinct 6, PO BOX 506625, Dubai International Financial Centre, Dubai, United Arab Emirates Notified on 10 February 2023 Ceased on 31 December 2024 Date of birth July 1970 Nationality Maltese Country of residence United Arab Emirates Nature of control Has significant influence or control”

Prior to 31 December 2024, there were five “persons with significant control” of Alliance for Responsible Citizenship Limited, including the two active directors, Mr Alan James Mccormick, and Mr Paul Roderick Clucas Marshall, and Mr Christopher Lincoln Chandler (date of birth January 1960), Mr Richard Edward Douglas (date of birth May 1953) and Mr Mark Alan Stoleson (date of birth July 1970). Alan McCormick’s correspondence address is “78 Pall Mall, London, England, SW1Y 5ES”, the four other persons with significant control have correspondence address “Legatum Plaza, Level 2, Gate Precinct 6, PO BOX 506625, Dubai International Financial Centre, Dubai, United Arab Emirates”.

The active persons with significant control of Alliance for Responsible Citizenship, Mr Vassiliou, Mr Chandler, Mr Douglas and recently resigned, Mr Stoleson, will be considered towards the end of this report, which will be published in a several parts.

3. Trading Disclosures Compliance Assessment: ARC Conference invitation.

The information from Companies House, above, is sufficient to be able to apply the Trading Disclosures Compliance Assessment to the invitation I received from Jordan B. Peterson:

1. Company's Registered Name: “Alliance for Responsible Citizenship” omits “Limited” which is misleading as the name suggests it may be not for profit charity. Non-compliant (CTDR 2015).

2. Company Registration Number: No registration number provided. Non-compliant (CTDR 2015).

3. Place of Registration: Omitted. Non-compliant (CTDR 2015).

4. Registered Office Address: “78 Pall Mall, London, SW1Y 5ES” omits “England”, Non-compliant (CTDR 2015).

5. Directors' Names (all, if any): Since Jordan B. Peterson is not a director, no directors are named. Compliant (CTDR 2015).

6. Share Capital Information: (Shares worth and paid up, if either). Neither provided. Compliant (CTDR 2015).

Trading Disclosures Compliance Assessment: The invitation to the Alliance for Responsible Citizenship 2025 Conference (image 1) fails to meet four out of six Trading Disclosures requirements and is therefore four times non-compliant (CTDR 2015). These legal oversights are the responsibility of the two active directors, Paul Roderick Clucas Marshall, born August 1959 and Alan James McCormick, born June 1974. These are red flags for potential obfuscation.

4. Director Profiles:

The appointments associated with each officer’s unique identifier or identity can be accessed by clicking on their name in Companies House. This information is typically reviewed by auditors, due diligence software, and individuals conducting Know Your Customer (KYC) checks to identify potential "related party transactions." Auditors are obligated to monitor these transactions to prevent and detect fraud.

The companies associated with each director are listed below. Overdue accounts are highlighted as non-compliant under Section 441 of the Companies Act 2006 (s441:CA2006).

Formatting Notes:

• To streamline information from Companies House and avoid duplication, records have been consolidated, with some details omitted

• Assume the accounts and confirmation statement are “up to date”, unless stated otherwise.

• Italics indicates comments, while bold highlights legal breaches.

A. Sir Paul Marshall

The unique identifier record for Sir Paul Marshall holds all the appointments held by this unique identity. The full records are reproduced after the summary.

Summary of Sir Paul Marshall’s appointments: active, resigned from active companies, and dissolved.

Active Appointments:

1. Alliance for Responsible Citizenship Limited Appointed on: 12 December 2016

2. ARK Academies Projects Limited Appointed on: 15 May 2007

3. Marshall Wace LLP Appointed on: 1 September 2003

4. Absolute Return for Kids (ARK) Appointed on: 13 November 2002

5. Pimpernel and Partners Limited Appointed before: 15 March 1992

Resigned Appointments in Active Companies:

1. ARK Schools, Appointed on: 9 September 2004, Resigned on: 12 April 2024

2. Education Policy Institute, Appointed on: 7 December 2010, Resigned on: 1 January 2024

3. Marshall Wace Asset Management Limited, Appointed on: 2 July 1997, Resigned on: 24 May 2022

4. St Paul's Theological Centre, Appointed on: 12 July 2007, Resigned on: 4 September 2017

5. Standards Board for Alternative Investments Limited, Appointed on: 1 February 2008, Resigned on: 30 October 2016

6. ARK UK Programmes, Appointed on: 19 September 2006, Resigned on: 1 September 2013

7. Liberal Democrat Business Forum Limited, Appointed on: 13 September 2000, Resigned on: 24 June 2009

8. Pragma Wealth Management Ltd., Appointed on: 14 June 2001, Resigned on: 21 October 2004

9. BlackRock Investment Management (UK) Limited, Appointed on: 30 May 1995, Resigned on: 8 August 1997

10. Marshall Wace Asset Management Limited, Appointed on: 2 July 1997, Resigned on: 16 July 1997

Dissolved Appointments, all with accounts overdue:

1. MW Eaglewood Management Limited, Appointed on: 22 October 2013, Non-compliant (s441 CA2006).

2. MWAM NA Ltd, Appointed on: 6 June 2011. Non-compliant (s441 CA2006).

3. MWAM UK Ltd, Appointed on: 6 June 2011. Non-compliant (s441 CA2006).

4. Every Child a Chance Trust, Appointed on: 22 November 2007. Non-compliant (s441 CA2006).

5. Freedom Music Limited, Appointed on: 22 February 2013 Non-compliant (s441 CA2006).

The records from Companies House are copied below, précised and with details added from: the company overview, charges and register information, if any, and the person with significant control. These records are reached by clicking on the underlined company name. Officer details are considered separately, so are not included here. Text in italics has been added by the author.

“MARSHALL, Paul Roderick Clucas

Current appointments 5

Total number of appointments 20”

“ALLIANCE FOR RESPONSIBLE CITIZENSHIP LIMITED (10519995) Active, Correspondence address: 78 Pall Mall, London, England, SW1Y 5ES, Role: Active Director, Appointed on: 12 December 2016, Occupation: Investment Manager Registered office address Company status Active Company type Private limited company Incorporated on 12 December 2016 Accounts (Up to date) Next accounts made up to 31 December 2024 due by 30 September 2025 Last accounts made up to 31 December 2023 Confirmation statement Next statement date 19 May 2025 due by 2 June 2025 Last statement dated 19 May 2024 Nature of business (SIC) 85520 - Cultural education Previous company names PROSPERITY UK 2017 LIMITED 12 Dec 2016 - 20 Jan 2023”

“MW EAGLEWOOD MANAGEMENT LIMITED (08743417) Dissolved, Correspondence address: 1020 Eskdale Road, Winnersh, Wokingham, RG41 5TS, Role: Director, Appointed on: 22 October 2013, Occupation: Chairman Registered office address 1020 Eskdale Road, Winnersh, Wokingham, RG41 5TS Company status Dissolved Dissolved on 15 December 2018 Company type Private limited Company Incorporated on 22 October 2013 Accounts Last accounts made up to 29 February 2016 Accounts Overdue 1 March 2016 to 15 December 2018 (1y 9m) Non-compliant (s441 CA2006) Nature of business (SIC) 64205 - Activities of financial services holding companies Previous company names P2P PRINCIPALS LIMITED 22 Oct 2013 - 02 May 2014 1

Insolvency case Case number 1 — Members voluntary liquidation Commencement of winding up 22 December 2016 Dissolved on 15 December 2018 Practitioner Sean Kenneth Croston Grant Thornton Uk Llp 1020 Eskdale Road, Winnersh, Wokingham, RG41 5TS Appointed on 22 December 2016

There are no persons with significant control or statements available for this company.”

“MWAM NA LTD (07659460) Dissolved, Correspondence address: 30 Finsbury Square, London, England, EC2A 1AG, Role: Director, Appointed on: 6 June 2011, Occupation: Director Registered office address 30 Finsbury Square, London, England, EC2A 1AG Company status Dissolved Dissolved on 7 April 2022 Last accounts made up to 28 February 2019 Accounts Overdue 1March 2019 - 7 April 2022 (3y 1m) Non-compliant (s441 CA2006) Nature of business (SIC) 66300 - Fund management activities

1 Insolvency case Case number 1 — Members voluntary liquidation Commencement of winding up 6 November 2020 Dissolved on 7 April 2022 Practitioner Sean Kenneth Croston 30 Finsbury Square, London, EC2A 1AG Appointed on 6 November 2020

1 person with significant control / 0 statements Mwam North America Llp Correspondence address George House, 131 Sloane Street, London, United Kingdom, SW1X 9AT Notified on 24 April 2020 Governing law England And Wales Legal form Limited Liability Partnership Place registered Registrar Of Companies For England And Wales Registration number Oc430937 Incorporated in United Kingdom Nature of control Ownership of shares – 75% or more Ownership of voting rights - 75% or more Right to appoint or remove directors”

“MWAM UK LTD (07659458) Dissolved, Correspondence address 1020 Eskdale Road, Winnersh, Wokingham, RG41 5TS, Role Director, Appointed on: 6 June 2011, Occupation Director Registered office address 1020 Eskdale Road, Winnersh, Wokingham, RG41 5TS Company status Dissolved Dissolved on 23 November 2018 Company type Private limited Company Incorporated on 6 June 2011 Last accounts made up to 28 February 2017 Accounts Overdue 1 March 2017 - 23 November 2018 (1y 7m) Non-compliant (s441 CA2006) Nature of business (SIC) 66300 - Fund management activities 1 Insolvency case Case number 1 — Members voluntary liquidation Commencement of winding up 15 November 2017 Dissolved on 23 November 2018 Practitioner Sean Kenneth Croston Grant Thornton Uk Llp 1020 Eskdale Road, Winnersh, Wokingham, RG41 5TS Appointed on 15 November 2017

0 persons with significant control / 1 statement Statement The company knows or has reasonable cause to believe that there is no registrable person or registrable relevant legal entity in relation to the company Notified on 6 June 2017”

“EVERY CHILD A CHANCE TRUST (06434237) Dissolved, Correspondence address: The Adelphi 13th, (sic) Floor, 1-11 John Adam Street, London, United Kingdom, WC2N 6HT, Role: Director, Appointed on: 22 November 2007, Occupation: Chairman/Founding Partner Registered office address Kpmg Foundation, 15 Canada Square, London, United Kingdom, E14 5GL Company status Dissolved Dissolved on 20 August 2013 Company type Private Limited Company by guarantee without share capital use of 'Limited' exemption Incorporated on 22 November 2007 Last accounts made up to 30 September 2011 Accounts Overdue 1 October 2011 - 20 August 2013 (1y 10m) Non-compliant (s441 CA2006) Nature of business (SIC) 85200 - Primary education

There are no persons with significant control or statements available for this company.”

“ARK ACADEMIES PROJECTS LIMITED (04101629) Active, Correspondence address: The Yellow Building, 1 Nicholas Road, London, England, W11 4AN, Role: Active Director, Appointed on: 15 May 2007, Occupation: Fund Manager Registered office address 1 Edcity Edcity Walk, (sic) London, United Kingdom, W12 7TF Nature of business (SIC) 41100 - Development of building projects 81100 - Combined facilities support activities 85100 - Pre-primary education Previous company names ABSOLUTE RETURN FOR KIDS (ARK) TRADING LIMITED 30 Sep 2003 - 03 Jul 2007 TACT TRADING LIMITED 03 Nov 2000 - 30 Sep 2003

• Register of directors Information not on the public register since 16 December 2016

• Register of secretaries Information not on the public register since 16 December 2016

• Register of person(s) with significant control (PSCs) Information not on the public register since 16 December 2016

• Register of members Information not on the public register since 16 December 2016

Persons with significant control

Persons with significant control:1 active person with significant control / 0 active statements Ark Schools Active Correspondence address 1 Nicholas Road, London, England, W11 4AN Notified on 6 April 2016 Governing law The Laws Of England And Wales Legal form Private Company Limited By Guarantee Place registered England And Wales Companies Registry Registration number 05112090 Incorporated in England Nature of control Ownership of shares – 75% or more Ownership of voting rights - 75% or more”

“MARSHALL WACE LLP (OC302228) Active, Correspondence address: George House, 131 Sloane Street, London, England, SW1X 9AT, Role: Active LLP Member, Appointed on: 1 September 2003 Registered office address George House, 131 Sloane Street, London, England, SW1X 9AT Company status Active Company type Limited liability partnership Incorporated on 16 May 2002 Accounts (Up to date) Next accounts made up to 28 February 2024 due by 30 November 2024 Last accounts made up to 28 February 2023 Confirmation statement Next statement date 11 June 2025 due by 25 June 2025 Last statement dated 11 June 2024 1 charge registered 0 outstanding, 1 satisfied, 0 part satisfied Charge code OC30 2228 0001 Created 15 September 2015 Delivered 30 September 2015 Status Satisfied on 17 November 2021 Persons entitled Deutche (sic) Bank Ag Brief description Contains fixed charge…

24 active persons with significant control”

“ABSOLUTE RETURN FOR KIDS (ARK) (04589451) Active, Correspondence address: The Yellow Building, 1 Nicholas Road, London, England, W11 4AN, Role: Active Director, Appointed on: 13 November 2002, Occupation: Fund Manager Registered office address 1 Edcity Edcity (sic) Walk, London, United Kingdom, W12 7TF Company status Active Company type Private Limited Company by guarantee without share capital use of 'Limited' exemption Incorporated on 13 November 2002 Accounts (Up to date) Next accounts made up to 31 August 2024 due by 31 May 2025 Last accounts made up to 31 August 2023 Confirmation statement Next statement date 14 November 2024 due by 28 November 2024 Last statement dated 14 November 2023 Nature of business (SIC) 85600 - Educational support services 86900 - Other human health activities 1 charge registered 1 outstanding, 0 satisfied, 0 part satisfied Rent security deposit deed Created 5 January 2010 Delivered 9 January 2010 Status Outstanding Persons entitled A & a Kingsway Holdings Limited Short particulars The deposit account into which the initial deposit has been…

0 active persons with significant control / 1 active statement Statement Active The company knows or has reasonable cause to believe that there is no registrable person or registrable relevant legal entity in relation to the company Notified on 13 November 2016”

“PIMPERNEL AND PARTNERS LIMITED (02361343) Active, Correspondence address: 70 Upper Richmond Road, London, SW15 2RP, Role: Active Secretary, Appointed before: 15 March 1992 Registered office address 70 Upper Richmond Road, London, SW15 2RP Company status Active Company type Private limited Company Incorporated on 15 March 1989 Accounts (Up to date) Next accounts made up to 31 March 2024 due by 31 December 2024 Last accounts made up to 31 March 2023 Confirmation statement Next statement date 9 March 2025 due by 23 March 2025 Last statement dated 9 March 2024 Nature of business (SIC) 47791 - Retail sale of antiques including antique books in stores

1 active person with significant control / 0 active statements Mrs Sabina Marshall Active Correspondence address 70 Upper Richmond Road, London, England, SW15 2RP Notified on 6 April 2016 Date of birth December 1956 Nationality French Country of residence England Nature of control Ownership of shares – 75% or more”

“ARK SCHOOLS (05112090) Active, Correspondence address: George House 131, Sloane Street, London, SW1X 9AT, Role: Resigned Director, Registered office address 1 Edcity Edcity Walk, (sic) London, United Kingdom, W12 7TF Company status Active Company type Private Limited Company by guarantee without share capital use of 'Limited' exemption Incorporated on 26 April 2004 Accounts (Up to date) Next accounts made up to 31 August 2024 due by 31 May 2025 Last accounts made up to 31 August 2023 Confirmation statement Next statement date 18 April 2025 due by 2 May 2025 Last statement dated 18 April 2024Appointed on: 9 September 2004, Resigned on: 12 April 2024, Occupation: Fund Manager Nature of business (SIC) 85100 - Pre-primary education 85200 - Primary education 85310 - General secondary education Previous company names

• ARK ACADEMIES 10 Jul 2006 - 01 Sep 2010

• ABSOLUTE RETURN FOR KIDS (ARK) EDUCATION 12 May 2004 - 10 Jul 2006

• ABSOLUTE RETURN FOR KIDS (ARK) EDUCATION LIMITED 26 Apr 2004 - 12 May 2004

4 charges registered 4 outstanding, 0 satisfied, 0 part satisfied

• Charge code 0511 2090 0004 Created 25 October 2022 Delivered 7 November 2022 Status Outstanding Persons entitled The Secretary of State for Education of Sanctuary Buildings Brief description By way of legal mortgage the freehold property known as…

• Charge code 0511 2090 0003 Created 31 August 2018 Delivered 13 September 2018 Status Outstanding Persons entitled The Secretary of State for Education Brief description Freehold property at adair house 403 shooters hill london…

• Rent security deposit deed Created 27 August 2009 Delivered 5 September 2009 Status Outstanding Persons entitled Catchment Estates Limited Short particulars £5,966.06.

• Rent security deposit deed Created 27 August 2009 Delivered 5 September 2009 Status Outstanding Persons entitled Woodall Refrigeration Limited Short particulars £4,080.19.

1 active person with significant control / 0 active statements Absolute Return For Kids (Ark) Active Correspondence address 65 Kingsway, London, England, WC2B 6TD Notified on 1 September 2016 Governing law Charities Act 2011 Legal form Private Limited Company By Guarantee Without Share Capital Use Of 'Limited' Exemption Place registered Companies House Registration number 04589451 Incorporated in United Kingdom Nature of control Right to appoint or remove directors with control over the trustees of a trust”

“EDUCATION POLICY INSTITUTE (04579498) Active, Correspondence address: George House 131, Sloane Street, London, SW1X 9AT, Role: Resigned Director, Appointed on: 7 December 2010, Resigned on: 1 January 2024, Occupation: Asset Management Registered office address 150 Buckingham Palace Road, London, England, SW1W 9TR Company status Active Company type Private Limited Company by guarantee without share capital use of ‘Limited' exemption Incorporated on 1 November 2002 Accounts (Up to date) Nature of business (SIC)85590 - Other education not elsewhere classified Previous company names CENTRE FOR REFORM 01 Nov 2002 - 19 May 2016

0 active persons with significant control / 1 active statement

Statement Active The company knows or has reasonable cause to believe that there is no registrable person or registrable relevant legal entity in relation to the company Notified on 29 February 2024

Sir Paul Roderick Clucas Marshall Ceased Correspondence address Acacia House, 115 Mortlake High Street, London, United Kingdom, SW14 8HQ Notified on 1 November 2019 Ceased on 31 December 2023 Date of birth August 1959 Nationality British Country of residence England Nature of control Ownership of voting rights - More than 25% but not more than 50% with control over the trustees of a trust”

“MARSHALL WACE ASSET MANAGEMENT LIMITED (03384699) Active, Correspondence address: George House, 131 Sloane Street, London, SW1X 9AT, Role: Resigned Director, Appointed on: 2 July 1997, Resigned on: 24 May 2022, Occupation: Fund Manager Registered office address George House, 131 Sloane Street, London, SW1X 9AT Company status Active Company type Private limited Company Incorporated on 11 June 1997Nature of business (SIC) 66300 - Fund management activities Previous company names AGENTHOW LIMITED 11 Jun 1997 - 03 Jul 1997 2 charges registered

0 outstanding, 2 satisfied, 0 part satisfied

Charge code 0338 4699 0002 Created 7 August 2023 Delivered 15 August 2023 Status Satisfied on 26 June 2024 Persons entitled Citibank Europe PLC, UK Branch Brief description Contains fixed charge…

Charge code 0338 4699 0001 Created 14 December 2021 Delivered 17 December 2021 Status Satisfied on 7 June 2024 Persons entitled Coutts & Company Brief description Contains fixed charge…

0 active persons with significant control / 1 active statement

• Statement Active The company knows or has reasonable cause to believe that there is no registrable person or registrable relevant legal entity in relation to the company Notified on 16 August 2017

• Mwam Uk Ltd Ceased Correspondence address George House, 131 Sloane Street, London, England, SW1X 9AT Notified on 6 April 2016 Ceased on 16 August 2017 Governing law Companies Act 2006 Legal form Private Limited Company Place registered Companies House Registration number 07659458 Incorporated in Uk Nature of control Ownership of shares – 75% or more”

“ST PAUL'S THEOLOGICAL CENTRE (05543940) Active, Correspondence address: SW14, (sic) Role: Resigned Director, Appointed on: 12 July 2007, Resigned on: 4 September 2017, Occupation: Chairman Asset Management Registered office address Holy Trinity Brompton, Brompton Road, London, SW7 1JA Company status Active Company type Private Limited Company by guarantee without share capital use of 'Limited' exemption Incorporated on 23 August 2005 Accounts (Up to date) Nature of business (SIC) 85590 - Other education not elsewhere classified

0 active persons with significant control / 0 active statements

• Ms Patricia Margaret Neill Ceased Correspondence address Holy Trinity Brompton, Brompton Road, London, SW7 1JA Notified on 6 April 2016 Ceased on 26 July 2023 Date of birth November 1950 Nationality British Country of residence England Nature of control Ownership of shares – More than 25% but not more than 50%

• Mr Nicholas Knyvett Lee Ceased Correspondence address Holy Trinity Brompton, Brompton Road, London, SW7 1JA Notified on 6 April 2016 Ceased on 8 July 2023 Date of birth February 1954 Nationality British Country of residence United Kingdom Nature of control Ownership of shares – More than 25% but not more than 50%

• Reverend Nicholas Glynn Paul Gumbel Ceased Correspondence address Holy Trinity Brompton, Brompton Road, London, SW7 1JA Notified on 6 April 2016 Ceased on 31 August 2022 Date of birth April 1955 Nationality British Country of residence England Nature of control Ownership of shares – More than 25% but not more than 50%”

“STANDARDS BOARD FOR ALTERNATIVE INVESTMENTS LIMITED (06465317) Active, Correspondence address: New Bridge Street House, 30-34 New Bridge Street, London, EC4V 6BJ, Role: Resigned Director, Appointed on: 1 February 2008, Resigned on: 30 October 2016, Occupation: Chairman Nature of business (SIC) 82990 - Other business support service activities not elsewhere classified Previous company names HEDGE FUND STANDARDS BOARD LIMITED 07 Jan 2008 - 29 Nov 2017 Registered office address 6th Floor 2 London Wall Place, Barbican, London, United Kingdom, EC2Y 5AU Company status Active Company type Private company limited by guarantee without share capital Incorporated on 7 January 2008 Accounts (Up to date)

0 active persons with significant control / 1 active statement Statement Active The company knows or has reasonable cause to believe that there is no registrable person or registrable relevant legal entity in relation to the company”

“FREEDOM MUSIC LIMITED (08415044) Dissolved, Correspondence address: SW14, (sic) Role: Resigned Director, Appointed on: 22 February 2013, Resigned on: 22 February 2014, Occupation: Fund Manager Dissolved on 17 April 2018 Company type Private limited Company Incorporated on 22 February 2013 Accounts Last accounts made up to 29 February 2016 Accounts Overdue Non-compliant (s441 CA2006) Nature of business (SIC) 59200 - Sound recording and music publishing activities Previous company names LIBERTA MUSIC TRADING LIMITED 13 Aug 2015 - 03 Oct 2015 GIOVANNA MUSIC TRADING LIMITED 22 Feb 2013 - 13 Aug 2015

1 person with significant control / 0 statements

Miss Giovanna Marshall Correspondence address 1a, Melbourn Street, Royston, Hertfordshire, England, SG8 7BP Notified on 22 February 2017 Date of birth October 1990 Nationality British Country of residence England Nature of control Ownership of shares – 75% or more with control over the trustees of a trust”

“ARK UK PROGRAMMES (05932797) Active, Correspondence address: 65 Kingsway, London, England, WC2B 6TD, Role: Resigned Director, Appointed on: 19 September 2006, Resigned on: 1 September 2013, Occupation: Fund Manager Registered office address 1 Edcity Edcity Walk, London, United Kingdom, W12 7TF Company status Active Company type Private Limited Company by guarantee without share capital use of 'Limited' exemption Incorporated on 12 September 2006

Accounts (Up to date) Nature of business (SIC) 85600 - Educational support services 88990 - Other social work activities without accommodation not elsewhere classified Previous company names ARK SCHOOLS 12 Sep 2006 - 01 Sep 2010

2 charges registered

2 outstanding, 0 satisfied, 0 part satisfied

• Charge code 0593 2797 0002 Created 15 December 2016 Delivered 20 December 2016 Status Outstanding Persons entitled J.P. Morgan International Bank Limited Brief description Contains fixed charge…

• Debenture Created 29 July 2009 Delivered 14 August 2009 Status Outstanding Persons entitled The New Aylesbury Trust Limited Short particulars All present and future undertaking and assets whatever and…

1 active person with significant control / 0 active statements

Absolute Return For Kids (Ark) Active Correspondence address 1 Nicholas Road, London, England, W11 4AN Notified on 14 April 2016 Governing law Companies Act Legal form Uk Registered Company And Uk Registered Charity Place registered Companies House Registration number 4589451 Incorporated in England Nature of control Has significant influence or control”

“LIBERAL DEMOCRAT BUSINESS FORUM LIMITED (04018993) Active, Correspondence address: SW14, (sic) Role: Resigned Director, Appointed on: 13 September 2000, Resigned on: 24 June 2009, Occupation: Fund Manager Registered office address 5th Floor 1 Vincent Square, London, England, SW1P 2NP Company status Active Company type Private company limited by guarantee without share capital Incorporated on 21 June 2000 Accounts (Up to date) Nature of business (SIC) 94920 - Activities of political organisations

0 active persons with significant control / 1 active statement

• Statement Active The company knows or has reasonable cause to believe that there is no registrable person or registrable relevant legal entity in relation to the company Notified on 21 June 2023

• Anthony William Harris Ceased Correspondence address Vincent Square, Vincent Square, 5th Floor, London, England, SW1P 2PN Notified on 18 June 2018 Ceased on 29 June 2022 Date of birth June 1957 Nationality British Country of residence England Nature of control Ownership of voting rights - 75% or more Right to appoint or remove directors

• Mr Peter Dunphy Ceased Correspondence address 2nd Floor, 8-10 Great George Street, London, SW1P 3AE Notified on 6 April 2016 Ceased on 18 June 2018 Date of birth June 1966 Nationality Uk Country of residence England Nature of control Ownership of voting rights - 75% or more ”

“PRAGMA WEALTH MANAGEMENT LTD. (04191349) Active, Correspondence address: SW14, (sic) Role: Resigned Director, Appointed on: 14 June 2001, Resigned on: 21 October 2004, Occupation: Director Nature of business (SIC) 66300 - Fund management activities Previous company names CHARCO 877 LIMITED 30 Mar 2001 - 09 Jul 2001 Registered office address The Scalpel, 18th Floor, 52 Lime Street, London, United Kingdom, EC3M 7AF Company status Active Company type Private limited Company Incorporated on 30 March 2001 Accounts (Up to date)

1 charge registered

0 outstanding, 1 satisfied, 0 part satisfied

Rent deposit deed Created 16 May 2011 Delivered 18 May 2011 Status Satisfied on 14 August 2019 Persons entitled Ebury & Eccleston Street Limited Short particulars The sum of £12,989.16…

0 active persons with significant control / 1 active statement

Statement Active The company knows or has reasonable cause to believe that there is no registrable person or registrable relevant legal entity in relation to the company Notified on 3 May 2022

Mrs Manuela Campedelli Ceased Correspondence address 1 Vere Street, London, United Kingdom, W1G 0DF Notified on 6 November 2018 Ceased on 25 April 2022 Date of birth March 1944 Nationality Italian Country of residence Italy Nature of control Ownership of shares – 75% or more Ownership of voting rights - 75% or more Right to appoint or remove directors”

“BLACKROCK INVESTMENT MANAGEMENT (UK) LIMITED (02020394) Active, Correspondence address: SW14, (sic) Role: Resigned Director, Appointed on: 30 May 1995, Resigned on: 8 August 1997, Occupation: Investment Director Registered office address 12 Throgmorton Avenue, London, EC2N 2DL Company status Active Company type Private limited Company Incorporated on 16 May 1986 Accounts Up to date Nature of business (SIC) 64999 - Financial intermediation not elsewhere classified 66300 - Fund management activities Previous company names MERRILL LYNCH INVESTMENT MANAGERS LIMITED 29 Sep 2000 - 02 Oct 2006 MERCURY ASSET MANAGEMENT LTD 30 Sep 1987 - 29 Sep 2000 MERCURY WARBURG INVESTMENT MANAGEMENT LTD. 01 Oct 1986 - 30 Sep 1987 TRUSHELFCO (NO. 978) LIMITED 16 May 1986 - 01 Oct 1986

1 active person with significant control / 0 active statements

Blackrock Finance Europe Limited Active Correspondence address 12 Throgmorton Avenue, London, United Kingdom, EC2N 2DL Notified on 17 August 2018 Governing law United Kingdom (England) Legal form Limited By Shares Place registered Companies House Registration number 07075607 Incorporated in England Nature of control Ownership of shares – 75% or more Ownership of voting rights - 75% or more Right to appoint or remove directors

Ultimately controlled through BLACKROCK INVESTMENT MANAGEMENT (UK) LIMITED, BLACKROCK FINANCE EUROPE LIMITED, BLACKROCK GROUP LIMITED, BLACKROCK FINCO UK LTD persons with significant control: Blackrock, Inc. Active Correspondence address 50 Hudson Yards, New York, Ny, United States, 10001 Notified on 6 April 2016 Governing law United States (Delaware) Legal form Corporation Place registered United States (Delaware) Registration number 32-0174431 Incorporated in Delaware Nature of control Ownership of shares – 75% or more as a member of a firm Ownership of voting rights - 75% or more as a member of a firm Right to appoint or remove directors as a member of a firm, see BLACKROCK GROUP LIMITED persons with significant control - Find and update company information - GOV.UK (company-information.service.gov.uk) ”

“MARSHALL WACE ASSET MANAGEMENT LIMITED (03384699) Active, Correspondence address: SW14, Role: Resigned Secretary, Appointed on: 2 July 1997, Resigned on: 16 July 1997, Occupation: Fund Manager Registered office address George House, 131 Sloane Street, London, SW1X 9AT Company status Active Company type Private limited Company Incorporated on 11 June 1997 Accounts Up to date Nature of business (SIC) 66300 - Fund management activities Previous company names AGENTHOW LIMITED11 Jun 1997 - 03 Jul 1997

2 charges registered

0 outstanding, 2 satisfied, 0 part satisfied

• Charge code 0338 4699 0002 Created 7 August 2023 Delivered 15 August 2023 Status Satisfied on 26 June 2024 Persons entitled Citibank Europe PLC, UK Branch Brief description Contains fixed charge…

• Charge code 0338 4699 0001 Created 14 December 2021 Delivered 17 December 2021 Status Satisfied on 7 June 2024 Persons entitled Coutts & Company Brief description Contains fixed charge…

0 active persons with significant control / 1 active statement

• Statement Active The company knows or has reasonable cause to believe that there is no registrable person or registrable relevant legal entity in relation to the company Notified on 16 August 2017

• Mwam Uk Ltd Ceased Correspondence address George House, 131 Sloane Street, London, England, SW1X 9AT Notified on 6 April 2016 Ceased on 16 August 2017 Governing law Companies Act 2006 Legal form Private Limited Company Place registered Companies House Registration number 07659458 Incorporated in Uk Nature of control Ownership of shares – 75% or more”

Accounts compliance conclusion:

Paul Roderick Clucas Marshall holds 20 appointments in this identity. Five of these are active and the accounts are up to date. There are ten resigned appointments in companies that are still active and these accounts are up to date. Five appointments are to companies which dissolved whilst he was an active director. These dissolved companies all have accounts overdue and/or final accounts not submitted, for which he is responsible. This describes five breaches of section 411 of the Companies Act 2006 relating to MW Eaglewood Management Limited, MWAM NA Ltd, MWAM UK Ltd, Every Child a Chance Trust, and Freedom Music Limited.

Similar names, “ARC” and “ARK”; potentially compromise of section 66 of the Companies Act 2006.

The Alliance for Responsible Citizenship Limited refers to itself on its invitation and website as “ARC”. Absolute Return for Kids Limited uses the acronym “ARK” in other company registrations, as in ARK UK Programmes. There is potential for confusion between “ARC” and “ARK”. This is a potential breach of section 66 of the Companies Act.

Concerns and Risks

Paul Roderick Clucas Marshall holds extensive control over numerous companies. This raises concerns about potential conflicts of interest, governance challenges, and transparency issues. Particularly, five companies have been dissolved, with overdue accounts and / or final accounts not submitted, suggesting possible financial and operational risks.

Screening for multiple identities

A search in Companies House of the name “Paul Roderick Clucas MARSHALL” returns four identities with this name at the top of the search results, each with a different set of appointments and correspondence addresses (Paul Roderick Clucas MARSHALL - Find https://find-and-update.company-information.service.gov.uk/search/officers?q=Paul+Roderick+Clucas+MARSHALL). See image 4: Search results for Paul Roderick Clucas Marshall in Companies House on 30/09/2024.

Image 4: Search results for Paul Roderick Clucas Marshall in Companies House on 30/09/2024.

The twenty appointments listed above relate to the second identity listed here:

• “Sir Paul Roderick Clucas MARSHALL

  Total number of appointments 1 - Born August 1959

  131 Sloane Street, London, England, SW1X 9AT

• Paul Roderick Clucas MARSHALL

  Total number of appointments 20 - Born August 1959

  78 Pall Mall, London, England, SW1Y 5ES

• Sir Paul Roderick Clucas MARSHALL

  Total number of appointments 12 - Born August 1959

  6 Old Queen Street, London, England, SW1H 9HP

• Sir Paul Roderick Clucas MARSHALL

  Total number of appointments 1 - Born August 1959

  C/O Marshall Wace Llp, The Adelphi, 1-11 John Adam Street, London, United Kingdom, WC2N 6HT”

There are four unique identifiers (identities) registered in Companies House with the same four names, Paul Roderick Clucas Marshall, all born August 1959. If these are claimed identities of the same individual, then, Paul Marshall has committed three breaches of Section 1082 of the Companies Act 2006. This law requires a single unique identifier for each individual, and the existence of multiple identities raises concerns about compromised audits and possible involvement in organised crime. Only one identity / unique identifier is legitimate.

Paul Roderick Clucas MARSHALL additional identities

Below the Companies House records for these three additional identities, and a fourth named “Paul Marshall”, are expanded upon:

Sir Paul Roderick Clucas MARSHALL identity A

“Total number of appointments 1 - Born August 1959

CHURCH REVITALISATION TRUST (10754427) Company status Active Correspondence address 131 Sloane Street, London, England, SW1X 9AT Role Active Director Appointed on 4 May 2017 Nationality British Country of residence England Occupation None Registered office address Holy Trinity Brompton, Brompton Road, London, SW7 1JA Company status Active Company type Private Limited Company by guarantee without share capital use of 'Limited' exemption Incorporated on 4 May 2017. Accounts and Confirmations statement Up to date Nature of business (SIC) 94910 - Activities of religious organisations”

Paul Roderick Clucas MARSHALL identity B (This is the identity that is described above.)

Total number of appointments 20 - Born August 1959

78 Pall Mall, London, England, SW1Y 5ES

Sir Paul Roderick Clucas MARSHALL identity C

Total number of appointments 12 - Born August 1959

6 Old Queen Street, London, England, SW1H 9HP

“Total number of appointments 12

Current appointments 6

UNHERD FOUNDATION (13640717) Company status Active Correspondence address 6 Old Queen Street, London, England, SW1H 9HP Role Active Director Appointed on 24 September 2021 Nationality British Country of residence United Kingdom Occupation Fund Manager Nature of business (SIC) 96090 - Other service activities not elsewhere classified

2 active persons with significant control / 0 active statements

Mr Winston Aubrey Aladar Marshall Active Correspondence address 6 Old Queen Street, London, England, SW1H 9HP Notified on 24 September 2021 Date of birth December 1987 Nationality British Country of residence England Nature of control Ownership of voting rights - More than 25% but not more than 50%

Sir Paul Roderick Clucas Marshall Active Correspondence address 6 Old Queen Street, London, England, SW1H 9HP Notified on 24 September 2021 Date of birth August 1959 Nationality British Country of residence England Nature of control Ownership of voting rights - More than 25% but not more than 50%

AREOPAGUS VENTURES LIMITED (13101043) Company status Active Correspondence address 6 Old Queen Street, London, United Kingdom, SW1H 9HP Role Active Director Appointed on 29 December 2020 Occupation Fund Manager Nature of business (SIC) 64303 - Activities of venture and development capital companies 1 active person with significant control / 0 active statements

• Unherd Ventures Limited Active Correspondence address 6 Old Queen Street, London, United Kingdom, SW1H 9HP Notified on 20 December 2021 Governing law Companies Act Legal form Limited Company Place registered Register Of Companies Registration number 12044066 Incorporated in United Kingdom Nature of control Ownership of shares – 75% or more Ownership of voting rights - 75% or more Right to appoint or remove directors

• Sir Paul Roderick Clucas Marshall Ceased Correspondence address 84 Eccleston Square, London, England, SW1V 1PX Notified on 29 December 2020 Ceased on 20 December 2021 Date of birth August 1959 Nationality British Country of residence England Nature of control Ownership of shares – 75% or more Ownership of voting rights - 75% or more Right to appoint or remove directors

BEIKONIC LTD (12301660) Company status Active Correspondence address Knighton House, Ramsbury, Marlborough, England, SN8 2QB Role Active Director Appointed on 8 June 2020 Occupation Fund Manager Nature of business (SIC) 70100 - Activities of head offices Previous company names SYCAMOREBROOK LIMITED 06 Nov 2019 - 25 Feb 2020

OLD QUEEN STREET VENTURES LTD (12044066) Company status Active Correspondence address 6 Old Queen Street, London, England, SW1H 9HP Role Active Director Appointed on 11 June 2019 Occupation Fund Manager Nature of business (SIC) 64209 - Activities of other holding companies not elsewhere classified Previous company names UNHERD VENTURES LTD 11 Jun 2019 - 24 May 2024

UNHERD INSIGHT LIMITED (11862026) Company status Active Correspondence address 6 Old Queen Street, London, England, SW1H 9HP Role Active Director Appointed on 5 March 2019 Occupation None Supplied Nature of business (SIC) 82990 - Other business support service activities not elsewhere classified

UNHERD LIMITED (10678659) Company status Active Correspondence address 6 Old Queen Street, London, England, SW1H 9HP Role Active Director Appointed on 24 April 2018 Occupation Fund Manager Nature of business (SIC) 58190 - Other publishing activities 63990 - Other information service activities not elsewhere classified

ALL PERSPECTIVES LTD (12227760) Company status Active Correspondence address The Point, 37 North Wharf Road, London, United Kingdom, W2 1AF Role Resigned Director Appointed on 6 April 2021 Resigned on 23 April 2024 Occupation Fund Manager Nature of business (SIC) 60200 - Television programming and broadcasting activities

EDCITY MANAGEMENT COMPANY LIMITED (11528726) Company status Active Correspondence address Marshall Wace Asset Management Limited, George House, 131 Sloane Street, London, United Kingdom, SW1X 9AT Role Resigned Director Appointed on 21 August 2018 Resigned on 18 October 2023 Occupation Fund Manager Nature of business (SIC) 68320 - Management of real estate on a fee or contract basis

B-IKONIC IBIZA LTD (14385962) Company status Active Correspondence address Knighton House, Ramsbury, Marlborough, United Kingdom, SN8 2QB Role Resigned Director Appointed on 29 September 2022 Resigned on 19 October 2022 Occupation Director Nature of business (SIC) 70100 - Activities of head offices

EDCITY OFFICE (11596797) Company status Active Correspondence address Marshall Wace Asset Management Limited, George House, 131 Sloane Street, London, United Kingdom, SW1X 9AT Role Resigned Director Appointed on 1 October 2018 Resigned on 20 July 2022 Occupation Fund Manager Nature of business (SIC) 68209 - Other letting and operating of own or leased real estate

ST PAUL'S THEOLOGICAL CENTRE (05543940) Company status Active Correspondence address Holy Trinity Brompton, Brompton Road, London, SW7 1JA Role Resigned Director Appointed on 24 April 2020 Resigned on 13 October 2021 Occupation Fund Manager Nature of business (SIC) 85590 - Other education not elsewhere classified

EDCITY DEVELOPMENT LIMITED (11511870) Company status Active Correspondence address Marshall Wace Asset Management Limited, George House, 131 Sloane Street, London, United Kingdom, SW1X 9AT Role Resigned Director Appointed on 10 August 2018 Resigned on 13 September 2021 Occupation Fund Manager Nature of business (SIC) 41100 - Development of building projects Previous company names EDCITY LIMITED 10 Aug 2018 - 21 Aug 2018”

Sir Paul Roderick Clucas MARSHALL identity D

Total number of appointments 1 - Born August 1959

C/O Marshall Wace Llp, The Adelphi, 1-11 John Adam Street, London, United Kingdom, WC2N 6HT

“ALLCHILD LIMITED (08991196) Company status Active Correspondence address C/O Marshall Wace Llp, The Adelphi, 1-11 John Adam Street, London, United Kingdom, WC2N 6HT Role Resigned Director Appointed on 10 April 2014 Resigned on 27 June 2017 Nationality British Country of residence United Kingdom Occupation Chief Investment Officer Nature of business (SIC) 85590 - Other education not elsewhere classified Previous company names WEST LONDON ZONE 10 Apr 2014 - 15 May 2024”

Paul MARSHALL identity E

Paul MARSHALL personal appointments - Find and update company information - GOV.UK (company-information.service.gov.uk)

Total number of appointments 1

FREEDOM MUSIC LIMITED (08415044) Company status Dissolved Correspondence address SW14 (sic) Role Resigned Secretary Appointed on 22 February 2013 Resigned on 22 February 2014

Potential conflict of interests

Analysis of potential conflicts of interest involving Sir Paul Marshall, focusing on the nature of business of the company appointments held in multiple identities, using SIC codes:

Identity A: Paul Roderick Clucas Marshall

• Church Revitalisation Trust (10754427)
  SIC: 94910 - Activities of religious organizations

Identity B: Paul Roderick Clucas Marshall

• Alliance for Responsible Citizenship Limited (10519995)
  SIC: 85520 - Cultural education

• ARK Academies Projects Limited (04101629)
  SIC: 41100 - Development of building projects, 85100 - Pre-primary education

• Marshall Wace LLP (OC302228)
  SIC: Not specified (likely financial services)

• Absolute Return for Kids (ARK) (04589451)
  SIC: 85600 - Educational support services, 86900 - Other human health activities

• Pimpernel and Partners Limited (02361343)
  SIC: 47791 - Retail sale of antiques including antique books in stores

• Ark Schools (05112090)
  SIC: 85100 - Pre-primary education, 85200 - Primary education, 85310 - General secondary education

• Education Policy Institute (04579498)
  SIC: 85590 - Other education not elsewhere classified

• Marshall Wace Asset Management Limited (03384699)
  SIC: 66300 - Fund management activities

• MW Eaglewood Management Limited (08743417) - Dissolved
  SIC: 64205 - Activities of financial services holding companies

• MWAM NA LTD (07659460) - Dissolved
  SIC: 66300 - Fund management activities

• MWAM UK LTD (07659458) - Dissolved
  SIC: 66300 - Fund management activities

• Every Child a Chance Trust (06434237) - Dissolved
  SIC: 85200 - Primary education

• Freedom Music Limited (08415044) - Dissolved
  SIC: 59200 - Sound recording and music publishing activities

• ARK UK Programmes (05932797)
  SIC: 85600 - Educational support services, 88990 - Other social work activities without accommodation not elsewhere classified

• Liberal Democrat Business Forum Limited (04018993)
  SIC: 94920 - Activities of political organisations

• Pragma Wealth Management Ltd. (04191349)
  SIC: 66300 - Fund management activities

• BlackRock Investment Management (UK) Limited (02020394)
  SIC: 64999 - Financial intermediation not elsewhere classified, 66300 - Fund management activities

• St Paul's Theological Centre (05543940)
  SIC: 85590 - Other education not elsewhere classified

• Standards Board for Alternative Investments Limited (06465317)
  SIC: 82990 - Other business support service activities not elsewhere classified

Identity C: Paul Roderick Clucas Marshall

• UnHerd Foundation (13640717)
  SIC: 96090 - Other service activities not elsewhere classified

• Areopagus Ventures Limited (13101043)
  SIC: 64303 - Activities of venture and development capital companies

• Beikonic Ltd (12301660)
  SIC: 70100 - Activities of head offices

• Old Queen Street Ventures Ltd (12044066)
  SIC: 64209 - Activities of other holding companies not elsewhere classified

• UnHerd Insight Limited (11862026)
  SIC: 82990 - Other business support service activities not elsewhere classified

• UnHerd Limited (10678659)
  SIC: 58190 - Other publishing activities, 63990 - Other information service activities not elsewhere classified

• All Perspectives Ltd (12227760)
  SIC: 60200 - Television programming and broadcasting activities

• EdCity Management Company Limited (11528726)
  SIC: 68320 - Management of real estate on a fee or contract basis

• B-Ikonic Ibiza Ltd (14385962)
  SIC: 70100 - Activities of head offices

• EdCity Office (11596797)
  SIC: 68209 - Other letting and operating of own or leased real estate

• EdCity Development Limited (11511870)
  SIC: 41100 - Development of building projects

Identity D: Sir Paul Roderick Clucas Marshall

• AllChild Limited (08991196)
  SIC: 85590 - Other education not elsewhere classified

Identity E: Paul MARSHALL

• Freedom Music Limited (08415044) Dissolved
  SIC: 59200 - Sound recording and music publishing activities

Based on the provided information, there is evidence suggesting that Sir Paul Roderick Clucas Marshall has placed potentially conflicting interests in separate identities, which could be interpreted as an attempt to conceal conflicts of interest. Here are the key observations:

1. Religious and Educational Activities:
   The Church Revitalisation Trust's religious focus (SIC 94910) may conflict with secular educational initiatives in ARK Academies, Ark Schools, and the Education Policy Institute. This could lead to tensions in curriculum development and resource allocation.

2. Media and Education:
   Identity C includes directorships in UnHerd Foundation, UnHerd Insight Limited, and UnHerd Limited (media and publishing), while Identity B holds the directorship of Alliance for Responsible Citizenship Limited (cultural education). This separation could be interpreted as an attempt to keep media influence and educational initiatives separate. However, this could influence public opinion on educational policies, potentially conflicting with Marshall's roles in educational charities and institutions.

3. Financial and Venture Capital:
   Identity B includes membership in Marshall Wace LLP (fund management), while Identity C holds a directorship in Areopagus Ventures Limited (venture capital). This separation could be seen as an attempt to keep different financial interests distinct.

4. Financial and Educational Interests: Marshall's involvement in financial services (Marshall Wace LLP, Marshall Wace Asset Management) could influence investment decisions related to educational projects (ARK, Ark Schools), potentially prioritizing financial returns over educational outcomes.

5. Political Connections: His past involvement with the Liberal Democrat Business Forum could create perceived biases in his educational and media ventures, potentially compromising their independence.

6. Real Estate and Education:
   Identity C previously held directorships in EdCity Management Company Limited and EdCity Office (real estate management), while Identity B includes directorships in educational projects. This separation could be interpreted as an attempt to keep real estate interests separate from educational initiatives.

7. Broadcasting and Education:
   Identity C previously held a directorship in All Perspectives Ltd (television programming), while Identity B includes educational and cultural directorships. This separation could be seen as an attempt to keep broadcasting interests separate from educational initiatives.

8. Venture Capital and Media: Areopagus Ventures' activities could influence investment in media companies (UnHerd, All Perspectives), potentially compromising editorial independence.

9. Antiques and Education: Pimpernel and Partners' antique business could create conflicts in decisions about historical education or museum partnerships within educational initiatives.

10. Music and Education: Past involvement in Freedom Music Limited could influence decisions about music education programs in schools.

11. International Influence: B-Ikonic Ibiza suggests international business interests, which could conflict with UK-focused educational and cultural initiatives.

12. Policy Influence: Roles in the Education Policy Institute and Standards Board for Alternative Investments provide platforms to influence both education and financial sector policies, potentially creating conflicts between these sectors.

The deliberate creation of multiple identities with similar names and birth dates, combined with the strategic placement of potentially conflicting interests across these identities, strongly suggests an intentional effort to conceal conflicts of interest. This practice raises significant governance and transparency concerns

Summary of Active companies for Paul Roderick Clucas Marshall in Companies House, to be used for comparison with his declaration of interests:

Identity A. Paul Roderick Clucas Marshall Born August 1959 Address: 131 Sloane Street, London, SW1X 9AT

• Church Revitalisation Trust (10754427): Director, Appointed on 4 May 2017

Identity B Paul Roderick Clucas Marshall Born August 1959 Address: 78 Pall Mall, London, SW1Y 5ES

• Alliance for Responsible Citizenship Limited (10519995): Director, Appointed on 12 Dec 2016

• ARK Academies Projects Limited (04101629): Director, Appointed on 15 May 2007

• Marshall Wace LLP (OC302228): LLP Member, Appointed on 1 Sep 2003

• Absolute Return for Kids (ARK) (04589451): Director, Appointed on 13 Nov 2002

• Pimpernel and Partners Limited (02361343): Secretary, Appointed before 15 Mar 1992

Identity C. Paul Roderick Clucas Marshall Born August 1959 Address: 6 Old Queen Street, London, SW1H 9HP

• UnHerd Foundation (13640717): Director, Appointed on 24 Sep 2021

• Areopagus Ventures Limited (13101043): Director, Appointed on 29 Dec 2020

• Beikonic Ltd (12301660): Director, Appointed on 8 Jun 2020

• Old Queen Street Ventures Ltd (12044066): Director, Appointed on 11 Jun 2019

• UnHerd Insight Limited (11862026): Director, Appointed on 5 Mar 2019

• UnHerd Limited (10678659): Director, Appointed on 24 Apr 2018

The assessment of Sir Paul Marshall’s disclosure of interests will consider these active interests. Disclosure of past interests are not considered herein.

Sir Paul Marshall’s disclosures on the Alliance for Responsible Citizenship Limited’s website

The biography for Paul Roderick Clucas Marshall is copied below from the Alliance for Responsible Citizenship Limited’s website (Advisory Board — Alliance for Responsible Citizenship (ARC) https://www.arcforum.com/advisory-board):

“Sir Paul Marshall is CIO and Chairman of Marshall Wace LLP, founder and owner of UnHerd Media, and an investor in GB News Ltd. He is a founding Trustee of Ark, a children’s educational charity, and founder of the Marshall Institute at the LSE.”

Summary of Interests Disclosed on Alliance for Responsible Citizenship Limited's Website:

• Advisory Board of Alliance for Responsible Citizenship Limited

• CIO and Chairman of Marshall Wace LLP

• Founder and owner of UnHerd Media

• Investor in GB News Ltd

• Founding Trustee of Ark

• Founder of the Marshall Institute at the LSE

Transparency Assessment of directorships registered in Companies House compared to disclosure on the ARC website:

In this assessment company directorships that are omitted from Sir Paul Marshall’s biography will be notified as Non-compliant (HLCC2023) since they breach transparency principles as defined in the Lords’ Code of Conduct.

Identity A (Born August 1959, Address: 131 Sloane Street, London, SW1X 9AT)

• Church Revitalisation Trust (10754427) Director, Appointed on 4 May 2017

Marshall failed to disclose his active directorship at the Church Revitalisation Trust, a role held since 4 May 2017. Non-compliant (HLCC2023).

Identity B (Born August 1959, Address: 78 Pall Mall, London, SW1Y 5ES)

• Alliance for Responsible Citizenship Limited (10519995): Director, Appointed on 12 Dec 2016

Whilst Paul Roderick Clucas Marshall is named as a member of the “Advisory Board” on this company’s website, he failed to disclose that his role is as a director of Alliance for Responsible Citizenship Limited. Non-compliant (HLCC 2023).

• ARK Academies Projects Limited (04101629): Director, Appointed on 15 May 2007

Whilst he declares “Founding Trustee of Ark” his disclosure does not include his directorship of Ark Academies Projects Limited, appointed 15 May 2007. He has failed to disclose Ark Academies Projects Limited. Non-compliant (HLCC2023).

• Marshall Wace LLP (OC302228): LLP Member, Appointed on 1 Sep 2003

His declaration “CIO and Chairman of Marshall Wace LLP” infers that he is a member of Marshall Wace LLP. Compliant (HLCC2023).

• Absolute Return for Kids (ARK) (04589451): Director, Appointed on 13 Nov 2002

This company has the same name as the charity, of which he discloses he is a trustee. He has failed to declare that he is a director of a company called Absolute Return for Kids (ARK). Non-compliant (HLCC2023)

• Pimpernel and Partners Limited (02361343): Secretary, Appointed before 15 Mar 1992

Paul Roderick Clucas Marshall failed to declare that he is a director of Pimpernel and Partners since 15 March 1992. Non-compliant (HLCC2023)

Identity C (Born August 1959, Address: 6 Old Queen Street, London, SW1H 9HP)

Active appointments summary: UnHerd Foundation, UnHerd Insight Limited, UnHerd Limited Areopagus Ventures Limited, Beikonic Ltd, Old Queen Street Ventures Ltd.

Paul Roderick Clucas Marshall discloses that he is “founder and owner of UnHerd Media”. He has failed to disclose that he is a director of three companies with similar names, Unherd Foundation, Unherd Insight Limited and Unherd Limited; none of which are called “Unherd Media”. 3 times Non-compliant (HLCC2023)

Additionally, Paul Roderick Clucas Marshall has failed to disclose Areopagus Ventures Limited, Beikonic Ltd and Old Queen Street Ventures Ltd. 3 times non-compliant (HLCC2023)

(The appointments in identity D and E are not active.)

Sir Paul Marshall omitted eleven active interests from his biography which are held in Companies House in three unique identifiers. These are:

• Identity A: Church Revitalisation Trust

• Identity B: Alliance for Responsible Citizenship Limited, ARK Academies Projects Limited, Absolute Return for Kids (ARK), Pimpernel and Partners Limited.

• Identity C: All active appointments omitted: UnHerd Foundation, UnHerd Insight Limited, UnHerd Limited, Areopagus Ventures Limited, Beikonic Ltd, Old Queen Street Ventures Ltd.

Identities B, C and E are claimed by Sir Paul Marshall:

Sir Paul Marshall declares interests on the ARC website that refers to companies registered to unique identities for Paul Roderick Clucas Marshall: Identity B includes Marshall Wace and ARK, and identity C, includes Unherd Media. Therefore, we can conclude that identities B and C are “claimed” identities of Sir Paul Marshall. Identity E holds an appointment as secretary at Freedom Music Limited, an interest to which he is appointed as director in identity B, so this is certainly another identity for the same individual.

Analysis to ascertain whether Sir Paul Marshall is associated to Church Revitalisation Trust (Identity A).

The website for the Church Revitalisation Trust was located using a search engine. Sir Paul Marshall’s biography is provided under “Trustees”, Meet our team (crtrust.co) (https://crtrust.co/about/meet-our-team/):

“Sir Paul Marshall is the Chairman and CIO of Marshall Wace, a hedge fund. He is also the Chairman of Ark Schools, a chain of 40 academies, and founder of the Education Policy Institute and of the Marshall Institute for Philanthropy and Social Entrepreneurship. Paul is married to Sabina and they have been worshipping at HTB since 1997. They have two children.”

Transparency Assessment of Sir Paul Marshall’s CRT biography:

Identity A: Whilst Sir Paul Marshall discloses that he is a trustee of Church Revitalisation Trust, he omits that he is a director of a company with the same name, held in his identity A. Non-compliant (HLCC2023).

Identity B: Whilst he discloses Marshall Wace, this is inaccurate as, he omits “LLP”. Non-compliant (HLCC2023). He discloses he is Chairman of Ark Schools and omits his directorships of ARK Academies Projects Limited and Absolute Return for Kids (ARK). 2 times non-compliant (HLCC2023). He omits Alliance for Responsible Citizenship Limited and Pimpernel and Partners Limited. 2 times non-compliant (HLCC2023).

Sir Paul Marshall fails to disclose any of the active appointments held in Identity C: UnHerd Foundation, Areopagus Ventures Limited, Beikonic Ltd, Old Queen Street Ventures Ltd, UnHerd Insight Limited, UnHerd Limited. 6 times Non-compliant (HLCC2023).

Summary of transparency assessment of Sir Paul Marshall’s biography on the Church Revitalisation Trust website:

Sir Paul Marshall omits that he is a director of a company called Church Revitalisation Trust in identity A. He inaccurately discloses interests held in identity B; “Marshall Wace”, omitting “LLP”, ARK Academies Projects Limited and Absolute Return for Kids (ARK), Alliance for Responsible Citizenship Limited and Pimpernel and Partners Limited. He omits all the active appointments held in Identity C: UnHerd Foundation, Areopagus Ventures Limited, Beikonic Ltd, Old Queen Street Ventures Ltd, UnHerd Insight Limited, UnHerd Limited. 12 times non-compliant (HLCC2023).

Trading Disclosures Compliance Assessment of the Church Revitalisation Trust website:

1. Company's Registered Name: Declares both the charity and the company with this name. Compliant (CDTR 2015)

2. Company Registration Number: Both provided. Compliant (CDTR 2015).

3. Place of Registration: Compliant (CDTR 2015).

4. Registered Office Address: "HTB” provided in the address, as shorthand for “Holy Trinity Brompton”. Non-compliant (CDTR 2015)

5. Directors' Names: Discrepancies. Non-compliant (CDTR 2015). See “Quick compliance review”, below.

6. Share Capital Information: None declared. Compliant (CDTR 2015).

Church Revitalisation Trust Website is non-compliant with Trading Disclosure regulations under CTDR 2015.

Quick compliance review of Church Revitalisation Trust:

The trustees are listed at the bottom of the webpage which describes all of “The Team” members associated with Church Revitalisation Trust (Meet our team (crtrust.co)). There are three team members who have the title “Director” e.g. “Mark Elsdon-Dew Director of Planting”, “Andrew Parsons Director of Building Development” and “Tom Lane Director of Network Development”. This is misleading as they are not directors of the Church Revitalisation Trust. The directors and secretary of Church Revitalisation Trust, however, are not disclosed on the website. Since they declare some “directors”, on the website, the Trust are obliged to declare all the actual directors as part of there Trading Disclosures obligations.

Note on Nicholas Glynn Paul GUMBEL:

Note that there is a Trustee listed on the Church Revitalisation Trust website, “Nicky Gumbel” who resigned on 31 August 2022, Nicholas Glynn Paul GUMBEL (company-information.service.gov.uk). Accessing the Charities Register, confirms that he is not listed as a trustee (CHURCH REVITALISATION TRUST - 1174882 (charitycommission.gov.uk). Since Nicholas Grumbel resigned 31 August 2022 he should no longer be listed on the website as a trustee. Non-compliant HLCC 2023.

In this identity Nicholas Gumbel is associated to eight companies, two of which are dissolved with accounts overdue and final accounts not submitted (Nicholas Glynn Paul GUMBEL personal appointments - GOV.UK (company-information.service.gov.uk)). These are: CARING FOR EX OFFENDERS (05265071) and HOLY TRINITY BROMPTON DEVELOPMENTS LIMITED (05559730). Two times non-compliant (s441:CA2006).

Nicholas (Nicky) Gumbel has two identities registered in Companies House (Nicholas Glynn Paul GUMBEL - Find). His second identity holds a directorship of The William Wilberforce Trust. (Nicky GUMBEL personal appointments). Non-compliant s1082:CA2006.

Compliance concern, a potential safe-guarding risk: Given the nature of business of these companies Nicholas Gumbel presents a potentially high risk to vulnerable people. This safeguarding implication urgently requires specific actions to address these risks.

The secretary of the Church Revitalisation Trust, Jonathan Mark SHIPPEN (company-information.service.gov.uk), appears to hold fourteen unique identifiers (Jonathan Mark SHIPPEN - Find (company-information.service.gov.uk)). Thirteen times non-compliant (s1082:CA2006). Further investigation is indicated as necessary,

Sir Paul Marshall Unique Identifier Compliance Assessment Conclusion

Sir Paul Marshall’s biography on the Church Revitalisation Trust (CRT) website discloses an interest that is appointed to his Identity B, Marshall Wace LLP. This confirms that Paul Roderick Clucas Marshall Identity A is a third identity of Sir Paul Marshall. He has breached section 1082 of the Companies Act 2006, which requires a single identity.

Given that Sir Paul Marshall has established three identities with the name Paul Roderick Clucas Marshall, born August 1959, the fourth identity, with the same names and date of birth, on balance of probabilities, is also an identity of Sir Paul Marshall. He has a fifth identity that is appointed to the same company as identity B, Freedom Music Limited, so certainly belongs to the same person. Three, likely four times non-compliant (s1082 CA2006).

Trading Disclosures Compliance Assessment: Alliance for Responsible Citizenship Limited website

The company website footer provides the following information: “Alliance for Responsible Citizenship Limited is a limited company incorporated in England and Wales. Company number: 10519995”. The contact details provides “78 Pall Mall, London, SW1Y 5ES, United Kingdom”.

1. Company's Registered Name: The website footer correctly displays "Alliance for Responsible Citizenship Limited." Compliant (CTDR 2015).

2. Company Registration Number: The registration number "10519995" is provided. Compliant (CTDR 2015).

3. Place of Registration: The company is identified as incorporated in England and Wales. Compliant (CTDR 2015).

4. Registered Office Address: The address "78 Pall Mall, London, SW1Y 5ES, United Kingdom" is listed. Compliant (CTDR 2015).

5. Directors' Names: Non-compliant. The company's website lists the directors as two of fifty-three members of ARC’s “Advisory Board," but does not disclose that they are directors of the company. This omission can be misleading, as stakeholders may not be aware of the directors' official roles and responsibilities within the company. Non-compliant (CTDR 2015).

6. Share Capital Information: Compliant. Since share capital information is not mentioned, this is compliant as it is not required unless share capital details are voluntarily disclosed. Compliant (CTDR 2015).

The website of the Alliance for Responsible Citizenship Limited has one breach of Trading Disclosure standards by publishing Sir Paul Marshall’s biography, as one of an Advisory Board with fifty-three members, without disclosing that he is a director.

Based on the provided information, Sir Paul Marshall failed to declare several interests across multiple identities, concealing significant conflicts of interest. Here's an analysis of the undeclared interests and the conflicts they reveal:

Undeclared Interests and Associated Conflicts

Religious and Educational Sector Conflicts

Sir Paul Marshall failed to disclose his directorship of the Church Revitalisation Trust (Identity A) while simultaneously holding positions in secular educational organizations (Identity B). This conceals potential conflicts between:

• Religious activities (SIC 94910) of the Church Revitalisation Trust

• Secular educational initiatives of ARK Academies Projects Limited (SIC 41100, 85100)

• Cultural education focus of Alliance for Responsible Citizenship Limited (SIC 85520)

These undisclosed connections could lead to conflicts in curriculum development, resource allocation, and overall educational philosophy.

Media and Education Sector Conflicts

Sir Paul Marshall omitted his directorships in media-related companies (Identity C) while holding positions in educational organizations (Identity B). This conceals conflicts between:

• Media influence through UnHerd Foundation, UnHerd Insight Limited, and UnHerd Limited

• Educational policy-making through Alliance for Responsible Citizenship Limited and ARK-related entities

This undisclosed overlap could lead to biased information dissemination and undue influence on educational policies.

Financial and Educational Sector Conflicts

The failure to disclose financial interests alongside educational roles conceals conflicts between:

• Investment activities through Areopagus Ventures Limited (SIC 64303) and Old Queen Street Ventures Ltd (SIC 64209)

• Educational initiatives through ARK Academies Projects Limited and Absolute Return for Kids (ARK)

This non-disclosure could hide potential conflicts in financial decision-making that may impact educational outcomes.

Political and Educational Conflicts

By not disclosing his involvement with the Liberal Democrat Business Forum Limited alongside his educational roles, Sir Paul Marshall concealed potential conflicts between:

• Political activities (SIC 94920)

• Educational policy-making and implementation through various ARK entities and the Alliance for Responsible Citizenship Limited

This omission could mask political influences on educational initiatives.

Implications of Concealed Conflicts

1. Compromised decision-making: The undisclosed conflicts could lead to biased decisions that prioritize certain interests over others without proper scrutiny.

2. Lack of transparency: Stakeholders are unable to make fully informed decisions due to the hidden interconnections between various sectors.

3. Potential misuse of resources: Resources from one sector (e.g., education) could be inappropriately directed to benefit interests in another sector (e.g., media or finance).

4. Undermined public trust: The deliberate concealment of these conflicts erodes public confidence in the integrity of educational, religious, and media institutions.

5. Regulatory concerns: The failure to disclose these conflicts may violate various regulatory requirements, potentially leading to legal and reputational consequences.

By maintaining multiple identities and selectively disclosing interests, Sir Paul Marshall has effectively created a complex web of influence across religious, educational, media, and financial sectors while concealing the full extent of his control and potential conflicts of interest

Beikonic Ltd and Beikonic LP: breach section 66

A search on Beikonic Ltd returns a second company with this name, registered as a Limited Partnership (https://find-and-update.company-information.service.gov.uk/search?q=Beikonic). The overview information is:

• BEIKONIC LP

  LP023602 - Registered on 19 March 2024

  48 Rose Square Fulham Road, London, England, SW3 6RS

• BEIKONIC LTD

  12301660 - Incorporated on 6 November 2019

  48 Rose Square Fulham Road, London, England, SW3 6RS

Breach: Beikonic Ltd is essentially the same name as Beikonic LP. This finding of duplicated company names is a breach of Section 66 of the Companies Act 2006 by the directors of Beikonic LP who registered this company on 19 March 2024. There is a risk of clone company fraud, related to Beikonic Ltd and Beikonic LP.

There is an anomaly with this company records in Companies House for Beikonic LP as there is no information relating to the officers of this company (https://find-and-update.company-information.service.gov.uk/company/LP023602). This is a breach of the Companies Act which requires that officers of companies are listed.

The certificate of registration of a Limited Partnership is provided in the filing history (BEIKONIC LP filing history (company-information.service.gov.uk).

Page 2 lists, as general partner, “Jka Seed Holding Limited” and states that the two limited partners are “Sir Paul Roderick Clucas Marshal and Damien Anthony Donohoe.” The general nature of business is given a “Carry on the business of an investor and, in particular, of identifying, negotiating, making, monitoring and realising investment and carry out all function and act in connection therewith, and such other activities as may be agreed by all the partners of the firm from time to time.” The form is presented by “King & Spalding International LLP, 125 Old Bond Street, London, EC2N1AR, United Kingdom”.

Further analysis of Damien Anthony Donohoe, partner at BEIKONIK LP.

Whilst Damien Anthony Donohoe is referenced in the incorporation document as a partner of Beikonik LP, he is not registered as a director of this company within the “Officers” record for this company. This is a breach of the Companies Act 2006.

A search for “Damien Anthony Donohoe” locates zero identities registered with this name (https://find-and-update.company-information.service.gov.uk/search/officers?q=Damien+Anthony+Donohoe).

A search of “Damien Donohoe” (https://find-and-update.company-information.service.gov.uk/search/officers?q=damien+donohoe) returns two identities which include these three names with date of birth

• Damien Patrick O' DONOHOE

  Total number of appointments 1 - Born April 1966

  26 Grosvenor Street, Mayfair, London, England, W1K 4QW

• Damien Patrick Thomas O DONOHOE

  Total number of appointments 5 - Born April 1966

  54 Emlyn Road, London, W12

The identity Damien Patrick Thomas O DONOHOE has a space after “O” whereas Damien Patrick O'DONOHOE has an apostrophe. These are materially the same names and with a date of birth in common there is sufficient evidence to conclude that these are two identities for the same person who is in breach of Section 1082 of the Companies Act 2006. Whether or not he is a related party of Damien Anthony Donohoe is inconclusive, clarification of this is requested.

A search of Damien Anthony O’Donohoe (https://find-and-update.company-information.service.gov.uk/search/officers?q=Damien+Anthony+O%27Donohoe) returns three identities with name and date of birth January 1981.

• Damien Anthony O'DONOHOE

  Total number of appointments 1 - Born February 1981

  48 Rose Square, Fulham Road, South Kensington, London, SW3 6RS

  • B-IKONIC IBIZA LTD (14385962) Role Active Director Appointed on

    29 September 2022

• Damien Anthony O'DONOHOE

  Total number of appointments 1 - Born January 1981

  Knighton House, Ramsbury, Marlborough, Wiltshire, SN8 2QB

  • BEIKONIC LTD (12301660) Role Active Director Appointed on 8 June 2020

• Damien Anthony O'DONOHOE

  Total number of appointments 1 - Born January 1981

  88/90 Baker Street, London, United Kingdom, W1U 6TQ

  • 1573 CIGARS LIMITED (14251253) Role Active Director Appointed on 22 July 2022 Registered office address International House International House (sic), 64 Nile Street, London, United Kingdom, N1 7SR Company status Active Company type Private limited Company Incorporated on 22 July 2022 Nature of business (SIC) 46350 - Wholesale of tobacco products

This is certainly the correct person as Damien O’Donohoe, partner of BEIKONIC LP because he is associated to BEIKONIC Ltd and B-Ikonic Ibiza Ltd and Sir Paul Roderick Clucas MARSHALL is a director of B-Ikonic Ibiza in his identity C.

The registered office address of 1573 CIGARS LIMITED contains an error, a duplication of “International House”. This is a breach of the Companies Act which requires a legitimate address, correctly presented. The duplication is a red flag for potential trafficking in illegal goods and persons, as duplications, like this, are also known as a code, evident to complicit customs officials and carriers in illegal supply chains.

Damien Anthony Donohoe born January 1981 breaches section 1082 of the Companies Act 2006 by having registered his companies under three unique identities in Companies House. He has compromised audits and KYC checks associated to him and his companies. He has also failed to register his directorship of BEIKONIC LP, as an officer in Companies House. He represents a high risk for money laundering, terrorism financing and people trafficking.

Further analysis of JKA Seed Holdings Limited and King Spalding International LLP, companies referenced within the incorporation documents of BEIKONIC LP.

JKA Seed Holding Limited

A search for JKA Seed Holding Limited, does not return a company registered with this name (https://find-and-update.company-information.service.gov.uk/search/companies?q=JKA+seed+holding+limited). However, it does return two companies with effectively the same name, JKA Holdings Limited and JKA Holdings Ltd:

• JKA HOLDINGS LIMITED

  12039558 - Dissolved on 28 March 2023

  Halfway Cottage, Bredons Hardwick, Tewkesbury, Gloucestershire, United Kingdom, GL20 7EE Dissolved on 28 March 2023 Incorporated on 7 June 2019 Accounts Last accounts made up to 30 June 2021 Nature of business (SIC) 68209 - Other letting and operating of own or leased real estate Accounts overdue made up to 30 June 2022 and to dissolution on 28 March 2023

• JKA HOLDINGS LTD

  06157537 - Dissolved on 10 February 2015

  21 Carlton Crescent, Southampton, Hampshire, SO15 2ET Dissolved on

  10 February 2015 Company type Private limited Company Incorporated on 13 March 2007 Accounts Last accounts made up to 31 July 2013 Accounts made up to 31 July 2014 and to dissolution on 10 February 2015 overdue Annual return Last annual return made up to 13 March 2014 Nature of business (SIC)

  64209 - Activities of other holding companies not elsewhere classified

  70100 - Activities of head offices

  Previous company names

  EURO MEDIA AND COMMUNICATIONS LTD 13 Mar 2007 - 10 Apr 2008

The officers appointed to JKA Holdings Limited and JKA Holdings Ltd breach section 441 of the Companies Act 2006 for failing to provide accounts made up to the dissolution of these companies. The officers of JKA Holdings Limited have potentially breached section 66 of the Companies Act 2006 by registering a company with a name that has already been used in the Companies House index, by JKA Holdings Ltd. The combined risk of potentially still active bank accounts and a potential clone company with potentially still active bank accounts requires investigation. Investigation should include assessing all the officers for multiple identities to discover their span of interests and control.

Further analysis of these companies’ officers is required because they are associated to BEIKONIC LP, with reference to the incorporation of this company, however this is not correctly registered in the officer record in Companies House, which is a breach of the Companies Act 2006.

King Spalding International LLP

KING & SPALDING INTERNATIONAL LLP

Company number OC303151

Registered office address 8 Bishopsgate, London, England, EC2N 4BQ Company status Active Company type Limited liability partnership Incorporated on 10 October 2002 Accounts Up to date 106 officers / 66 resignations (https://find-and-update.company-information.service.gov.uk/company/OC303151/officers)

There are forty active officers of King & Spalding International LLP. These officers also require assessment for multiple identities. There are too many active officers to analyse manually, herein. Therefore, The first officer listed in the Companies House record for King & Spalding International LLP, William Francis Charnley is analysed below, only.

William Francis CHARNLEY

(https://find-and-update.company-information.service.gov.uk/officers/2IlYAOIQ3PVt5RyMecUZFlff9sQ/appointment)

Total number of appointments 15

Current appointments 5

Date of birth August 1960

KING & SPALDING INTERNATIONAL LLP (OC303151) Company status Active Correspondence address 8 Bishopsgate, London, England, EC2N 4BQ Role Active LLP Designated Member Appointed on 6 July 2012 Country of residence England 106 officers / 67 resignations 0 active persons with significant control / 1 active statement

K K S STRATEGY LLP (OC306533) Company status Active Correspondence address King & Spalding International Llp, 125 Old Broad Street, London, EC2N 1AR Role Active LLP Designated Member Appointed on 1 April 2008 Country of residence England 6 officers / 3 resignations

• The person with significant control of KKS Strategy is Mrs Katrina Kostic Samen date of birth November 1960 (K K S STRATEGY LLP persons with significant control).

• Katrina Kostic Samen has four identities registered: Katrina KOSTIC - SAMEN, Katrina Kostic SAMEN, Katrina Kostic SAMEN and Katrina KOSTIC SAMEN, presenting her name surname in three different ways, “Kostic - Samen”, “Samen” and Kostic Samen”. Multiple identities cause false non-match errors in audit and KYC software, breaching section 1082, and compromises audits breaching Section 441 of the Companies Act 2006.

• In the latter identity, Katrina KOSTIC SAMEN, she is a resigned officer of BRITISH COUNCIL FOR OFFICES Nature of business (SIC) 94120 - Activities of professional membership organisations 94990 - Activities of other membership organisations not elsewhere classified.

• This company name implies an official connection with a government department through the use of the names “British Council” which is the name of the UK Government foreign development organisation. Clarification of whether this is an approved use is necessary. If not, this is a serious breach representing a potential public security risk.

ZEUS FILMS LLP (OC301879) Company status Active Correspondence address 11 Pilgrim Street, London, EC4V 6RW Role Active LLP Member Appointed on 25 March 2003 Country of residence United Kingdom Registered office address Parcels Building, 14 Bird Street, London, United Kingdom, W1U 1BU Company status Active Incorporated on 3 April 2002

80 officers / 7 resignations

Charges 6 charges registered 6 outstanding Persons entitled Barclays Bank PLC

THE MUSCOVY COMPANY LIMITED (03821028) Company status Active Correspondence address King & Spalding International Llp, 125 Old Broad Street, London, England, EC2N 1AR Role Active Secretary Appointed on 17 August 1999 Nationality British Occupation Solicitor Incorporated on 6 August 1999 Nature of business (SIC) 74990 - Non-trading company Previous company names STOCKIMAGE LIMITED 21 Jun 2001 - 01 Aug 2001 STOCKIMAGE LIMITED 06 Aug 1999 - 21 Jun 2001

THE MUSCOVY COMPANY LIMITED (03821028) Company status Active Correspondence address King & Spalding International Llp, 125 Old Broad Street, London, England, EC2N 1AR Role Active Director Appointed on 17 August 1999 Nationality British Country of residence England Occupation Solicitor

Testing for multiple identities for William Francis Charnley.

A search in Companies House on the name William Francis Charnley locates five identities with these three names and date of birth August 1960 (https://find-and-update.company-information.service.gov.uk/search/officers?q=William+Francis+Charnley) . These are:

1. William Francis CHARNLEY

   Total number of appointments 1 - Born August 1960

   Drapers' Hall, Throgmorton Avenue, London, United Kingdom, EC2N 2DQ

2. William Francis CHARNLEY

   Total number of appointments 1 - Born August 1960

   DR J BARKER, Hughes Hall, , University Of Cambridge, Wollaston Road, Cambridge, England, CB1 2EW

3. William Francis CHARNLEY

   Total number of appointments 15 - Born August 1960

   8 Bishopsgate, London, England, EC2N 4BQ

4. William Francis CHARNLEY

   Total number of appointments 1 - Born August 1960

   16 City Business Centre, Hyde Street, Winchester, England, SO23 7TA

5. William Francis CHARNLEY

   Total number of appointments 2 - Born August 1960

   Grange Hatfield, Mosquito Way, Hatfield, England, AL10 9US

There is prima facie evidence that William Francis Charnley breaches section 1082 of the Companies Act 2006 by having registered his appointments under 5 separate identities. Further investigation of the companies held in these identities is warranted since the registration of multiple identities has compromised all audits associated with William Francis Charnley. Further analysis is required but not undertaken in this report.

The next identity returned is the search for William Francis Charnley in Companies house is:

• DICK FRANCIS FILMS LIMITED

  Total number of appointments 1

  HILLIER HOPKINS LLP, 2a, Alton House Office Park, Gatehouse Way, Gatehouse Industrial Area, Aylesbury, Buckinghamshire, England, HP19 8YF

This is included in the report as it features “Hillier Hopkins LLP” in the registered address for Dick Francis Films Limited. Hillier Hopkins LLP is a name that appears in the search for identities of another resigned director of Alliance for Responsible Citizenship Limited, Lord Hopkin Hill (appointed on 31 January 2018 resigned on 10 February 20230). This is an incidental finding that may or may not be relevant, but it is a statistical anomaly that requires further investigation.

Sir Paul Roderick Clucas Marshall, Damien Anthony Donohoe, JKA Seed Holding Limited and King Spalding International LLP are responsible for a section 66 breach of the Companies Act by Beikonic LP. Each entity is associated with further breaches as identified above. They represent a high risk to the public’s best interest and their criminal conduct requires urgent investigation.

Summary of Compliance Assessment outcomes of Paul Roderick Clucas Marshall.

Unique identifier non-compliance: Sir Paul Roderick Clucas Marshall, born August 1959, has established five unique identifiers in Companies House. Four times non-compliant (s1082 CA2006).

Accounts non-compliance: Sir Paul Marshall is director of five dissolved companies with accounts overdue, held in one of his four identities, identity B: MW Eaglewood Management Limited, MWAM NA Ltd, MWAM UK Ltd, Every Child a Chance Trust and Freedom Music Limited. Five times non-compliant (s441:CA2006).

Transparency assessments:

1. Alliance for Responsible Citizenship: Sir Paul Marshall omits eleven active directorships, in his biography on the Alliance for Responsible Citizenship Limited’s website. Eleven times non-compliant (HLCC2023). The omitted directorships include:

• Identity A: Church Revitalisation Trust.

• Identity B: Alliance for Responsible Citizenship Limited, ARK Academies Projects Limited, Absolute Return for Kids (ARK) and Pimpernel and Partners Limited. 4 omissions.

• Identity C: UnHerd Foundation, UnHerd Insight Limited, UnHerd Limited, Areopagus Ventures Limited, Beikonic Ltd and Old Queen Street Ventures Ltd. 6 omissions.

2. Church Revitalisation Trust: Sir Paul Marshall omits twelve active directorships, in his biography on the Church Revitalisation Trust website. Twelve times non-compliant (HLCC2023). The omitted directorships include:

• Identity A: Church Revitalisation Trust.

• Identity B: Marshal Wace LLP, Alliance for Responsible Citizenship Limited, ARK Academies Projects Limited, Absolute Return for Kids (ARK) and Pimpernel and Partners Limited. 5 omissions.

• Identity C: UnHerd Foundation, UnHerd Insight Limited, UnHerd Limited, Areopagus Ventures Limited, Beikonic Ltd and Old Queen Street Ventures Ltd. 6 omissions.

3. Trading Disclosures Compliance Assessment:

1. Alliance for Responsible Citizenship Limited conference 2025 invitation. The invitation to the Alliance for Responsible Citizenship 2025 Conference (image 1) fails to meet four out of six Trading Disclosures requirements. Four times non-compliant (CTDR 2015).

2. Alliance for Responsible Citizenship Limited website. The website of the Alliance for Responsible Citizenship Limited breaches of Trading Disclosure standards by publishing Sir Paul Marshall’s biography, as one of an Advisory Board with fifty-three members, without disclosing that he is a director. Non-compliant (CTDR 2015)

3. Church Revitalisation Trust website. There are two breaches of Trading disclosure standards, errors in the registered address and director disclosure anomalies. Two times non-compliant (CTDR 2015). A quick compliance review found breaches relating to Nicholas Glynn Paul Gumbel who has resigned, non-compliant (HLCC 2023). He is also a director of two dissolved companies with accounts overdue, Caring For Ex Offenders and Holy Trinity Brompton Developments Limited. Two times non-compliant (s441:CA2006). Nicholas Gumbel has two identities registered, concealing The William Wilberforce Trust from audits of his other identity. Non-compliant s1082:CA2006. The secretary of Church Revitalisation Trust, Jonathan Mark appears to have fourteen unique identifiers. Thirteen times non-compliant (s1082:CA 2006).

Risks Associated with Non-Compliance.

The compliance assessment of Paul Roderick Clucas Marshall reveals significant risks associated with non-compliance, particularly concerning multiple identities, overdue accounts, and transparency failures. These issues pose substantial threats to public interest and corporate governance integrity.

1. Multiple Identities: The establishment of multiple (five) unique identifiers compromises audits and Know Your Customer (KYC) processes, concealing interests and potentially facilitating organised crime activities such as money laundering, people trafficking, and terrorism financing. Misleading information used to gain additional identities may constitute fraud by false representation under Section 2 of the Fraud Act 2006 and failing to disclose interests under Section 3 of the same Act. These breaches necessitate further investigation.

2. Risks to Public Interest:

   • Synthetic Identity Fraud: The presence of multiple identities coinciding with failure to declare interests held in other identities is evidence of synthetic identity fraud to obscure true ownership, control, and financial activities.

   • Clone Company Fraud: Similar company names and addresses across identities may facilitate clone company fraud, deceiving stakeholders and increasing financial and reputational risks.

   • Conflict of Interest: Multiple directorships under different identities obscure potential conflicts of interest, compromising transparency and stakeholder decision-making.

   • Governance and Accountability: Managing multiple companies under different identities undermines governance and accountability, leading to poor oversight and risk management.

   • Financial Risks: Complex financial oversight involving multiple identities can obscure financial liabilities and misrepresent a company’s financial health, posing systemic risks.

3. Actionable Steps:

   • Regulatory Investigation: Immediate regulatory scrutiny is necessary to investigate potential fraudulent activities and enforce compliance with the Companies Act 2006.

   • Enhanced Due Diligence: Stakeholders should conduct enhanced due diligence when engaging with entities associated with Paul Roderick Clucas Marshall to mitigate risks.

   • Public Awareness: Raising awareness about the risks associated with synthetic identity fraud and clone company fraud can help protect investors and the public from deceptive practices.

Conclusion

The compliance assessment highlights significant non-compliance issues involving Paul Roderick Clucas Marshall, including multiple unique identifiers, overdue accounts in dissolved companies, and transparency failures in directorship disclosures. These breaches pose serious risks to public interest by potentially facilitating fraudulent activities and undermining corporate governance integrity. Immediate corrective actions are recommended to address these issues, enhance compliance practices, and protect public interest. Regulatory bodies should prioritize investigations into these breaches to ensure accountability and transparency in business operations.

Further analysis is required. Specifically, a compliance assessment of Sir Paul Marshall’s registrations in the Register of Charities has not been completed. Scanning ahead, anomalies in unique identity management in the Charity Register, raise further concerns of non-compliance.

Limitations: He has a total of 46 appointments, 12 of which are active. Here we have considered just two of his active appointments. Compliance assessments are outstanding on Sir Paul Marshall’s other directorships in Companies House.

Further research required for records for Sir Paul Marshall’s disclosure on the Alliance for Responsible Citizenship website “Founder of the Marshall Institute at the LSE”.

Sir Paul Marshall's related parties that still require assessment:

1. Persons with significant control:

• Mr Philip Anthony Vassiliou (person with significant control of Alliance for Responsible Citizenship Limited)

• Alan James McCormick (person with significant control of Alliance for Responsible Citizenship Limited)

• Christopher Lincoln Chandler (person with significant control of Alliance for Responsible Citizenship Limited)

• Richard Edward Douglas (person with significant control of Alliance for Responsible Citizenship Limited)

• Mrs Sabina Marshall (person with significant control of Pimpernel and Partners Limited)

• Mark Alan Stoleson (recently ceased being person with significant control of Alliance for Responsible Citizenship Limited)

2. Practitioners of liquidated companies:

• Sean Kenneth Croston (practitioner for MW Eaglewood Management Limited and MWAM UK Ltd)

• Clive Morris (Managing Director of Marshall Peters Limited, an insolvency practice)

• Paul A Palmer (Director of Marshall Peters Limited, an insolvency practice)

3. Lenders to any company:

• Barclays Bank PLC (charge holder for Zeus Films LLP)

• Citibank Europe PLC, UK Branch (charge holder for Marshall Wace Asset Management Limited)

• Coutts & Company (charge holder for Marshall Wace Asset Management Limited)

• KKR (major shareholder in Marshall Wace)

4. Entities using a company name in correspondence addresses, registered addresses, or occupations:

• Marshall Wace Asset Management Limited (used in correspondence addresses for multiple companies, e.g. Edcity Management Company Limited

• King & Spalding International LLP (used in correspondence addresses for multiple companies e.g. K K S Strategy LLP)

• WPO Limited (mentioned in a correspondence address for Oliver Plunkett)

• Legatum Group (co-owner of GB News with Paul Marshall)

• UnHerd Media (mentioned as founded and owned by Sir Paul Marshall)

• Old Queen Street Ventures (mentioned as a vehicle for potential acquisitions)

• Legatum Plaza (used in correspondence address for multiple persons with significant control)

5. Other related parties requiring assessment:

• Ken Griffin (reported to be joining Sir Paul Marshall's consortium to bid for the Telegraph Group)

• Jordan B. Peterson (associated with Alliance for Responsible Citizenship)

• Oliver Plunkett (former director of Alliance for Responsible Citizenship Limited)

• Lord Hill of Oareford (former director of Alliance for Responsible Citizenship Limited)

• Winston Aubrey Aladar Marshall (person with significant control of UnHerd Foundation)

• Damien Anthony O'Donohoe (director of B-IKONIC IBIZA LTD and BEIKONIC LTD)

• JKA Seed Holding Limited (general partner in BEIKONIC LP)

• William Francis Charnley (officer at King & Spalding International LLP)

• Todd Builione (hired by Marshall Wace to run North American business)

• Sequoia Trust (charitable trust under Sir Paul Marshall's control)

This list includes additional related parties identified from the search results, such as persons with significant control, business partners, and entities associated with Sir Paul Marshall's various ventures. Further investigation into these parties may reveal additional connections and potential conflicts of interest.

Methodological Limitations

This compliance assessment, while thorough in its approach, has several limitations that should be considered when interpreting the results:

Manual Data Collection and Transcription

• Records have been manually copied and sometimes précised, which may introduce human error or unintentional omissions.

• The manual nature of data collection limits the scope of the assessment, potentially missing relevant information.

Incomplete Assessment of Related Parties

• Not all directors and associated companies have been fully assessed, particularly:

  • Practitioners of liquidated companies

  • Lenders to any company

  • Entities using a company name in correspondence addresses, registered addresses, or occupations

Limited Search for Multiple Identities

• Searches for multiple identities are conducted manually, which may result in missed identities.

• Not all variations of names have been checked, potentially overlooking some identity duplications.

Scope of Company and Individual Analysis

• The assessment focuses primarily on the first director, limiting the comprehensive understanding of the entire organization's compliance status.

• Time constraints may have prevented a deeper analysis of all identified companies and individuals.

Reliance on Public Records

• The assessment relies heavily on publicly available information from Companies House, which may not always be up-to-date or complete.

Complexity of Corporate Structures

• The intricate network of companies and individuals makes it challenging to fully map all relationships and potential conflicts of interest.

Limited Historical Context

• The assessment may not fully capture historical changes in company structures, directorships, or compliance status.

Interpretation of Compliance Standards

• The application of compliance standards (e.g., HLCC2023, CTDR 2015) may be subject to interpretation, especially in complex cases.

Potential for Overlooked Breaches

• The complexity and volume of data increase the risk of overlooking certain compliance breaches or misinterpreting relationships between entities.

Lack of Direct Verification

• The assessment relies on secondary sources without direct verification from the individuals or companies involved.

Time Sensitivity of Information

• Company information and compliance statuses can change rapidly, potentially making some findings outdated by the time of report completion.

These limitations underscore the need for caution in drawing definitive conclusions and highlight the importance of ongoing, comprehensive compliance monitoring.

End of section.

The other active director of Alliance For Responsible Citizenship Limited is Alan James McCormick, he is considered next.

B. MCCORMICK, Alan James

The Alliance for Responsible Citizenship Limited record for Alan James McCormick reads:

“Correspondence address Legatum Plaza, Level 2, Gate Precinct 6, Dubai International Finance Centre, PO BOX 506625, Dubai, United Arab Emirates Role Active Director Date of birth June 1974 Appointed on 9 February 2023 Nationality British Country of residence United Arab Emirates Occupation Managing Director

Total number of appointments 1”

An audit or KYC software would conclude that Alan James McCormick has no other interests registered in Companies House.

Screening for multiple identities

A search on the name Alan James McCormick returns six identities with this name and date of birth (Alan James MCCORMICK personal appointments - Find https://find-and-update.company-information.service.gov.uk/officers/HYR9BLVLWpUqeHmHtIMWE_o5PNg/appointments). See image 5: Search result for Alan James McCormick in Companies House on 30/9/2024:

Image 5: Search result for Alan James McCormick in Companies House on 30/9/2024

These identities are copied below and expanded with the information from the appointments page for each identity, which is indented.

Identity 1:

• “Alan James MCCORMICK

  Total number of appointments 0 - Born June 1974

  506625, Level 3, Legatum Plaza, Difc, Dubai, Uae Level 3, Legatum Plaza, Dubai International Financial Centre, Dubai, Dubai, United Arab Emirates, 506625

  • CATALITIX ADVISORS LTD (09876203) Company status Dissolved Correspondence address PO Box 506625, Level 3, Legatum Plaza, Difc, Dubai, Uae, Level 3, Legatum Plaza, Dubai International Financial Centre, Dubai, Dubai, United Arab Emirates, 506625 Role Director Appointed on 15 May 2017 Nationality British Country of residence United Arab Emirates Occupation Business Executive Registered office address 11 Charles Street, London, W1J 5DW

    Company status Dissolved Dissolved on 28 November 2017 Company type Private limited Company Incorporated on 17 November 2015 Accounts Last accounts made up to 31 December 2016 Accounts overdue Non-compliant (s441:CA2006) Nature of business (SIC) 70229 - Management consultancy activities other than financial management

    Previous company names CATALITIX LIMITED 17 Nov 2015 - 09 Dec 2015”

Identity 2:

• “Alan James MCCORMICK

  Total number of appointments 0 - Born June 1974

  11 Charles Street, London, United Kingdom, W1J 5DW

  • THE LEGATUM INSTITUTE FOUNDATION (07430903) Company status Dissolved Correspondence address 11 Charles Street, London, United Kingdom, W1J 5DW Role Director Appointed on 5 November 2010 Nationality British Country of residence United Arab Emirates Occupation Managing Director Registered office address 11 Charles Street, London, W1J 5DW Dissolved on 19 December 2023 Company type Private Limited Company by guarantee without share capital use of 'Limited' exemption Incorporated on 5 November 2010 Accounts Last accounts made up to 31 December 2021 Accounts overdue Non-compliant (s441:CA2006) Nature of business (SIC) 85590 - Other education not elsewhere classified”

Identity 3:

• “Alan James MCCORMICK

  Total number of appointments 1 - Born June 1974

  Legatum Plaza, Level 2, Gate Precinct 6, Dubai International Finance Centre, PO BOX 506625, Dubai, United Arab Emirates

  • ALLIANCE FOR RESPONSIBLE CITIZENSHIP LIMITED (10519995) Company status Active Correspondence address Legatum Plaza, Level 2, Gate Precinct 6, Dubai International Finance Centre, PO BOX 506625, Dubai, United Arab Emirates Role Active Director Appointed on 9 February 2023 Nationality British Country of residence United Arab Emirates Occupation Managing Director Registered office address 78 Pall Mall, London, England, SW1Y 5ES Nature of business (SIC) 85520 - Cultural education Previous company names PROSPERITY UK 2017 LIMITED 12 Dec 2016 - 20 Jan 2023”

Identity 4:

• “Alan James MCCORMICK

  Total number of appointments 2 - Born June 1974

  495 Green Lanes, Palmers Green, London, N13 4BS

• Total number of appointments 3

  Date of birth June 1974

  • THE END FUND (06350698) Company status Active Role Active Director Appointed on 10 January 2011 Occupation Trustee Registered office address 495 Green Lanes, Palmers Green, London, N13 4BS Company type Private Limited Company by guarantee without share capital use of Limited' exemption Incorporated on 22 August 2007 Accounts (up to date) Confirmation statement (up to date) Nature of business (SIC) 82990 - Other business support service activities not elsewhere classified Previous company names CAPITAL FOR GOOD 22 Aug 2007 - 18 May 2011

  • LEGATUM INSTITUTE (FC028686) Company status Converted / Closed Correspondence address Level 9, Convection Tower, Dubai Convention Centre, 71082 Dubai, United Arab Emirates Role Director Appointed on 24 January 2010 Nationality British Country of residence United Arab Emirates Occupation Managing Director Overseas company address PO Box 897GT, PROSPERITY INTERNATIONAL, One Capital Place Grand Caynan (sic), Cayman Islands, British West Indies Closed on 13 June 2018 Company type Overseas company First UK establishment opened on 20 October 2008 Accounts Last accounts made up to 31 December 2016 Accounts overdue Non-compliant (s441:CA2006) Previous company names PROSPERITY INTERNATIONAL 01 Dec 2008 - 26 Mar 2010 Incorporated in CAYMAN ISLANDS Registration number CR 159810 Legal form Private Limited Liability Parent registry Registrar Of Companies Governing law Companies Law Cap 22 (Cayman Islands) Objects of the company Philanthropic development Insolvency details excluded for brevity 1 UK establishments 0 open, 1 closed PROSPERITY INTERNATIONAL BR010247 Town: London Status: closed

  • THE FREEDOM FUND UK (08926428) Company status Active Correspondence address Lower Ground Floor, Caledonia House, 223 Pentonville Road, London, England, N1 9NG Role Resigned Director Appointed on 6 March 2014 Resigned on 9 November 2023 Nationality British Country of residence United Arab Emirates Occupation Director Registered office address Lower Ground Floor, Caledonia House, 223 Pentonville Road, London, England, N1 9NG Company type Private Limited Company by guarantee without share capital use of 'Limited' exemption Incorporated on 6 March 2014 Accounts overdue Next accounts made up to 31 December 2023 due by 30 September 2024 Last accounts made up to 31 December 2022 Confirmation statement Next statement date 17 March 2025 due by 31 March 2025 Last statement dated 17 March 2024 Nature of business (SIC)

    63990 - Other information service activities not elsewhere classified”

Breaches:

Overdue Accounts of "The Freedom Fund UK" (08926428):
The company has overdue accounts for the period ending 31 December 2023, with the filing deadline being 30 September 2024. This is a breach of Section 441 of the Companies Act 2006 (s441:CA2006).

The Freedom Fund website was assessed for compliance with Trading Disclosure regulations under CTDR 2015.

https://www.freedomfund.org/ provides the following legal information: “The Freedom Fund is a United States 501(c)(3) public charity (EIN number 30-0805768). The Freedom Fund UK is a company limited by guarantee registered in England and Wales (company number 08926428) and a registered UK charity (registration number 1158838).”

1. Company's Registered Name: The Freedom Fund UK - Compliant

2. Company Registration Number: 08926428 - Compliant

3. Place of Registration: Registered in England and Wales - Compliant

4. Registered Office Address: “Lower Ground (sic), Caledonia House
   223 Pentonville Rd
   London N1 9NG
   United Kingdom” (https://www.freedomfund.org/contact/). “Floor” is omitted from the registered address provided on the company website. Non-compliant

5. Directors' Names (all if any): There is a mention of individual directors in press releases, eg. Havovi Wadia, https://www.freedomfund.org/news/the-freedom-fund-announces-new-appointment-of-havovi-wadia-as-new-director-of-programs/ and https://www.freedomfund.org/news/freedom-fund-announces-appointment-amol-mehra-new-managing-director-lead-work-north-america/, however, no comprehensive disclosure of all the directors is made on the website, despite name some. Therefore, non-compliant.

   Share Capital Information: None disclosed. Compliant

The Freedom Fund UK website is non-compliant with Trading Disclosure regulations under CTDR 2015 because it publishes a different registered address to the address recorded in Companies House, omitting “Floor” in the first line and the names of some of the directors is published, but not all of the directors. This is a breach of transparency requirements.

Identity 5:

• “Alan James MCCORMICK

  Total number of appointments 1 - Born June 1974

  PO BOX 506625, Legatum Plaza, Level 2, Dubai International Financial Centre, Dubai, United Arab Emirates

  • PROSPERITY INSTITUTE LIMITED (14543238) Company status Active Correspondence address PO BOX 506625, Legatum Plaza, Level 2, Dubai International Financial Centre, Dubai, United Arab Emirates Role Resigned Director Appointed on 15 December 2022 Resigned on 3 January 2024 Nationality British Country of residence United Arab Emirates Occupation Managing Director And Partner Registered office address 11 Charles Street, London, United Kingdom, W1J 5DW Company status Active Company type Private limited Company Incorporated on 15 December 2022 Accounts (up to date) Confirmation statement (up to date) Nature of business (SIC) 85590 - Other education not elsewhere classified Previous company names

    LEGATUM INSTITUTE LIMITED 17 Mar 2023 - 23 May 2024

    MANDEVILLE RESEARCH LIMITED 14 Feb 2023 - 17 Mar 2023

    11 CHARLES ST LIMITED 15 Dec 2022 - 14 Feb 2023”

Identity 6:

• “Alan James MCCORMICK

  Total number of appointments 1

  Level 9, Convention Tower, Dubai Convention Centre, Dubai, United Arab Emirates, 71093

  • HAZELDINE FILMS LTD. (04183598) Company status Active Correspondence address Level 9, Convention Tower, Dubai Convention Centre, Dubai, United Arab Emirates, 71093 Role Resigned Secretary Appointed on 2 April 2001 Resigned on 3 August 2021 Nationality British Occupation Consultant Registered office address First Floor Flat, 50 Carlton Hill, London, England, NW8 0ES Company status Active Company type Private limited Company Incorporated on 20 March 2001 Accounts (up to date) Confirmation statement (up to date) Nature of business (SIC) 59111 - Motion picture production activities Previous company names HAZELDINIAN FILMS LIMITED 20 Mar 2001 - 12 Sep 2003”

Compliance assessment for Hazeldine Films Ltd and directors’ compliance assessment remains outstanding.

Additional unique identifiers as “Alan McCormick.

A search on “Alan McCormick” locates additional identities registered without the middle name and a statistically unlikely number of identities registered with this name and different dates of birth (Alan McCormick - Find https://find-and-update.company-information.service.gov.uk/search/officers?q=Alan+McCormick). Further investigation of these is recommended but not undertaken here. There is one identity called Alan McCormick, with the same date of birth as Alan James McCormick, June 1974:

Identity 7:

• Alan MCCORMICK

  Total number of appointments 1 - Born June 1974

  Level 2, Legatum Plaza, Dubai International Financial Centre, Dubai, United Arab Emirates

  • ALL PERSPECTIVES LTD (12227760) Role Active Director Appointed on 6 April 2021

  • Registered office address The Point, 37 North Wharf Road, London, United Kingdom, W2 1AF Company status Active Company type Private limited Company Incorporated on 25 September 2019 Accounts Next accounts made up to 31 May 2024 due by 28 February 2025 Last accounts made up to 31 May 2023 Confirmation statement Next statement date 24 September 2025 due by 8 October 2025 Last statement dated 24 September 2024 Nature of business (SIC) 60200 - Television programming and broadcasting activities

This identity for Alan McCormick uses a correspondence address “Level 2, Legatum Plaza, Dubai International Financial Centre, Dubai, United Arab Emirates” which is the same address that Alan James McCormick, with the same date of birth, June 1974, uses as his correspondence address for his appointment to ALLIANCE FOR RESPONSIBLE CITIZENSHIP LIMITED. Therefore this is a seventh identity for the same individual. Note that Sir Paul Marshall is also a director of All Perspectives Limited (see above).

Summary of the companies held in each of Alan James McCormick's seven identities:

Identity 1:

• CATALITIX ADVISORS LTD (09876203) - Dissolved

Identity 2:

• THE LEGATUM INSTITUTE FOUNDATION (07430903) - Dissolved

Identity 3:

• ALLIANCE FOR RESPONSIBLE CITIZENSHIP LIMITED (10519995) - Active

Identity 4:

• THE END FUND (06350698) - Active

• LEGATUM INSTITUTE (FC028686) - Converted/Closed

• THE FREEDOM FUND UK (08926428) - Active (Resigned)

Identity 5:

• PROSPERITY INSTITUTE LIMITED (14543238) - Active (Resigned)

Identity 6:

• HAZELDINE FILMS LTD. (04183598) - Active (Resigned)

Identity 7:

• ALL PERSPECTIVES LTD (12227760) - Active

This distribution of companies across multiple identities raises significant compliance concerns, particularly regarding the transparency of Alan James McCormick's business interests and potential conflicts of interest. The use of multiple identities can complicate audits, compromise Know Your Customer (KYC) checks, and potentially conceal related party transactions

Unique Identifier compliance update:

Alan James McCormick, born June 1974, has registered seven separate identities in Companies House. 6 times non-compliant s1082:CA2006.

Risk: The presence of seven different identities is a breach of Section 1082 of the Companies Act 2006, which requires directors to maintain a single unique identifier. This non-compliance can obscure true business interests and complicate audits and Know Your Customer (KYC) checks.

Accounts compliance assessment:

Alan James McCormick, is associated with companies that have dissolved without producing final accounts 3 times non-compliant s441:CA2006:

• Identity 1: Catalitix Advisors Ltd

• Identity 2: The Legatum Institute Foundation

• Identity 4: Legatum Institute.

Accounts non-compliance risk: The risk is that there may be bank accounts still operational in these company names that are potentially being used for fraudulent purposes.

Risk of Fraud: The existence of multiple identities with minor variations may facilitate synthetic identity fraud, obscuring true ownership and control. This poses a risk to stakeholders and could be used for fraudulent activities such as money laundering or tax evasion.

Section 66 Compliance assessment: Legatum Institute.

Summary of facts: Alan McCormick declares The Legatum Institute Foundation and Legatum Institute as active interests on the Alliance for Responsible Citizenship website. His appointments to these are held in identities 2 and 4. The records in Companies House show that these companies have ceased operations.

The evidence above shows that Legatum Institute, incorporated in Cayman Islands, was registered in Companies House on 5 November 2010 and it closed on 13 June 2018. The last accounts were made up to 31 December 2016. Therefore, it dissolved with accounts overdue and final accounts were not submitted which breaches Section 441 of the Companies Act 2006 (LEGATUM INSTITUTE overview GOV.UK (company-information.service.gov.uk)).

The Legatum Institute record states “Prosperity International” is its UK establishment, number BR010247, LEGATUM INSTITUTE - UK Establishments GOV.UK (company-information.service.gov.uk). This establishment has the following overview record:

“PROSPERITY INTERNATIONAL UK establishment number BR010247 UK establishment office address 11 Charles Street, London, W1J 5DP Status Closed Opened on 20 October 2008 Type of business 11 Charles Street London W1j 5dp (sic) This is a UK establishment of LEGATUM INSTITUTE Company number FC028686 Fining History Transactions are available from the filing history of the overseas company LEGATUM INSTITUTE”

Alan McCormick is appointed to PROSPERITY INSTITUTE LIMITED (14543238) in identity 5 (Active Correspondence address PO BOX 506625, Legatum Plaza, Level 2, Dubai International Financial Centre, Dubai, United Arab Emirates Role Resigned Director Appointed on 15 December 2022 Resigned on 3 January 2024 Nationality British Country of residence United Arab Emirates Occupation Managing Director And Partner Registered office address 11 Charles Street, London, United Kingdom, W1J 5DW Company status Active Company type Private limited Company Incorporated on 15 December 2022 Accounts (up to date) Confirmation statement (up to date) Nature of business (SIC) 85590 - Other education not elsewhere classified) and this was previously called LEGATUM INSTITUTE LIMITED 17 Mar 2023 - 23 May 2024.

Potential for Clone Company Fraud: The establishment of two entities with the same name is prohibited by section 66 of the Companies Act 2006. Dual bank accounts in the same company name obscure transparency and present high potential for clone company fraud.

1. PROSPERITY INTERNATIONAL (BR010247)

2. LEGATUM INSTITUTE previously known as PROSPERITY INTERNATIONAL (FC028686) 01 Dec 2008 - 26 Mar 2010. Closed on 13 June 2018.

3. PROSPERITY INSTITUTE LIMITED (14543238) previously called LEGATUM INSTITUTE LIMITED 17 Mar 2023 - 23 May 2024. Active

Breaches:

1. The name "Prosperity International" is associated to two company numbers: the previous name of Legatum Institute, FC028686, and Prosperity International, an UK establishment, number BR010247. Non-compliant (s66:CA2006)

2. The name “Legatum Institute” is associated to two company numbers FC028686 and 14543238 where, it is the previous name of the active company called Prosperity Institute Limited. Non-compliant (s66:CA2006)

UK Establishment Breach:

The overview of PROSPERITY INTERNATIONAL UK establishment number BR010247 provides: “Type of business 11 Charles Street London W1j 5dp (sic)”. The “Type of Business” is not provided, instead, the office address is given, with the postcode not written in capitals as it would normally be. Omitting the type of business from the Companies House records is a breach of section 1046 of the Companies Act 2006, Duty to register particulars, which requires disclosure of business activities. Non-compliant (s1046 :CA2006).

Banking Risks: The UK Establishment office address of Prosperity International (PROSPERITY INTERNATIONAL overview) is the same address as the registered address of The Legatum Institute Foundation, “11 Charles Street, London, W1J 5DP.” This record could potentially have been used to establish a bank account in the name Prosperity International posing risks of dual accounts and clone company fraudulent activities involving Legatum Institute (Company number FC028686).

Clone company fraud is further indicated by the registration of Prosperity Institute Limited, previously called Legatum Institute Limited a company where Alan James McCormick was a director from 15 December 2022 to 3 January 2024 (see identity 5).

The Companies Act prohibits the use of same or misleadingly similar names within the Companies House index, section 66 of the Companies Act 2006(s66:CA2006). In this report we have encountered the following companies:

Section 66 of the Companies Act 2006 aims to prevent confusion and protect the public and other businesses from potential misrepresentation. The use of such similar names, especially when considering the name changes and the active status of some of these entities, appears to be a breach of this section.

Persons with Significant Control (PSC) Compliance:

The last accounts filed for Legatum Institute, year ended 31 December 2016, are located in “Filing History”. The directors’ report, of these account, is copied below, image 6, Legatum Institute Report of the Directors Year ended 31 December 2016.

Image 6 Legatum Institute Report of the Directors Year ended 31 December 2016 signed 20.9/2017

The Directors Report states “The company relies upon its parent company to provide funds to meet its on-going operational costs and other obligations.” The accounts disclose “Loan from parent company US$49,451,795 (31 December 2016).”

The name of the “parent company” of Legatum Institute is not included in the accounts.

No persons with significant control are specified in the Companies House records. This is where the parent company should be specified, and is not, refer to, LEGATUM INSTITUTE persons with significant control. I conclude that Legatum Institute has a parent company which has not been identified in the Companies House records as the person with significant control of Legatum Institute. This is a breach of section 790M of the Companies Act 2006. Non-compliant (s790M:CA2006). This section mandates that companies identify and record individuals or entities with significant control over them. The absence of such information raises concerns about transparency and accountability, potentially masking the true ownership and control structure.

Legatum Institute’s Initial branch registration subscribers, Cardinal Investments Limited and Bluejay Investments Ltd:

The “Initial branch registration” for Legatum Institute, previously called Prosperity International, is available in “Filing History” (uploaded 1 December 2008). It lists two subscribers: “Cardinal Investments Limited and Bluejay Investments Ltd.”, both located a “PO Box 897GT, Grand Cayman, Cayman Islands, British West Indies.” (LEGATUM INSTITUTE filing history GOV.UK (company-information.service.gov.uk)). Refer to image 7, below, for the initial branch registration of Prosperity International, page 28. 13 December 2005.

Image 7: Initial branch registration of Prosperity International, page 28. 13 December 2005

Cardinal Investments Limited and Bluejay Investments Ltd. require further investigation such as screening for registrations in Companies House. Early findings are described in Appendix A.

Incomplete Registration Documentation:

The “Initial branch registration” of Prosperity International is missing a signature from “Vernecia Mcfield PO Box 897GT, Grand Cayman, Occupation: Administrator” who was supposed to witness to the signatures of the two subscribers on 13 December 2005. This omission is shown in image 7, above.

Legal Breach: The incomplete registration documentation due to missing signatures renders the registration invalid. This constitutes a breach of Section 107 of the Companies Act 2006, which requires proper execution of documents for company registration. Non-compliant (s107:CA2006). Additional investigation into Vernecia Mcfield's role and identity is necessary but has not yet been conducted.

Within the filing history is the “Notice of termination” of winding up of an overseas company for Legatum Institute (FCO028686) provides Prosperity International (BR010267) as the UK Establishment. Compliant. The Presenter is given as “Christine Blackman, Withers LLP, 16 Old Bailey, London EC4M 7EG. DX 160 London/Chancery Lane.”

The officer records of Withers LLP are located in Companies House, WITHERS LLP people - GOV.UK (company-information.service.gov.uk). Christine Blackman is not listed as a partner of Withers LLP.

Potential Legal Breaches

1. Misrepresentation:

   • If Christine Blackman is not actually a partner at Withers LLP, as claimed in the filing, this could constitute a misrepresentation. While this does not directly breach a specific section of the Companies Act 2006, it could violate general principles of accuracy and truthfulness required in legal filings.

2. Fraud Act 2006:

   • If the misrepresentation was intentional and aimed at gaining some advantage or causing loss, it might fall under the Fraud Act 2006. Specifically, Section 2 of the Fraud Act addresses fraud by false representation.

3. Professional Conduct:

   • If Christine Blackman is a legal professional, misrepresenting her role or affiliation could breach professional conduct rules set by regulatory bodies such as the Solicitors Regulation Authority (SRA) in the UK.

The details of the insolvency case are:

LEGATUM INSTITUTE

Company number FC028686 1 Insolvency case

Case number 1 — Foreign insolvency

Practitioner Martin Trott
Windward 1 Regatta Office Park, Grand Cayman, Cayman Islands, KY1 1103

Appointed on 11 December 2017

Practitioner Christopher Kennedy
The R And H Trust Co Ltd Po Box 897 Windward 1, Regatta Office Park, George Town, Grand Cayman, Cayman Islands, KY1-1103

Appointed on 11 December 2017

Further Investigation Required:

• Screening for company registrations in the names of Martin Trott and Christopher Kennedy and The R And H Trust Co Ltd is necessary to identify any potential conflicts of interest or additional roles that could impact the insolvency proceedings. This step is crucial to ensure transparency and accountability in managing the insolvency process. (Not yet done)

Potential Legal and Compliance Issues:

• The involvement of overseas practitioners in the insolvency process may require compliance with both local and international regulations. Ensuring that all parties adhere to relevant legal frameworks is essential to prevent any breaches that could complicate the resolution of the insolvency case.

The Legatum Institute Foundation

The Legatum Institute Foundation, registered office address 11 Charles Street, London, W1J 5DW was incorporated on 5 November 2010 and dissolved on 19 December 2023. The last accounts were made up to 31 December 2021. Therefore, the accounts to end of 2022 and final accounts are overdue. There are no persons with significant control notified in the company records (THE LEGATUM INSTITUTE FOUNDATION persons with significant control GOV.UK (company-information.service.gov.uk).

The Legatum Institute Foundation Accounts made up to 31 December 2021 (available in the filing history) present accounts for the company and charity, number 1140719, which has the same name.

The Accounts 2021 of The Legatum Institute Foundation, under “Trustees Annual Report”, provide:

“Going Concern: The Institute’s core activities are currently funded from Legatum Foundation Limited. Legatum Foundation Limited has reconfirmed a funding commitment through to the end of December 2024 and, for this reason, the Trustees consider it a going concern.

Reserves: Due to ongoing financial support of Legatum Foundation Limited, the Institute has funding for the next 3 years. As at the year-end, the Institute had positive free reserves of £687,000 (2021: £583,000).”

No concern was raised in these accounts that suggested that the company and charity would soon be dissolved.

The Accounts make it explicit that Legatum Foundation Limited provides financial support as if it were the parent company. Therefore Legatum Foundation Limited should be declared as the person with significant control of The Legatum Institute Foundation. Since Legatum Foundation Limited is not declared as the Person with significant control of The Legatum Institute Foundation, The Legatum Foundation Institute is in breach of section 790M of the Companies Act 2006. Non-compliant (s790M: CA2006).

The websites listed in The Legatum Institute Foundation Accounts made up to 31 December 2021 include; www.li.com, www.prosperity.com, www.usprosperity.com and www.socailmetriccommission.co.uk.

Legatum Foundation Limited

A search in Companies House on the term “Legatum Foundation Limited”, does not locate a company with this name, Legatum Foundation Limited - Find GOV.UK (company-information.service.gov.uk). The company to which the The Legatum Institute Foundation accounts refer, may be associated in another country.

A search using “OpenCorporates”, a consolidated view of companies registered in most countries, locates two records for Legatum Foundation Limited, Companies matching 'legatum foundation limited' :: OpenCorporates:

• inactive Legatum Foundation Limited (Dubai (UAE))

  • Company Number 0164 Status Dissolved Jurisdiction Dubai (UAE)

• Legatum Foundation Limited (Bermuda) Trademarks: RAZOO SPEEDGRANTING RAZOO

  • Company Number 38060 Status Active Incorporation Date 1 March 2006 (over 18 years ago)

    Jurisdiction Bermuda Business Classification Text TRUSTEE COMPANY Agent Name RAWLINSON & HUNTER Directors / Officers RAWLINSON & HUNTER, agent RAWLINSON & HUNTER, agent Source Bermuda Registrar of Companies, https://www.roc.gov.bm/roc/rocweb.nsf..., 10 Jan 2017

Legatum Foundation Limited (Dubai)

Accessing the Public Register for Dubai, DIFC, and searching on Legatum returns the following entry for Legatum Foundation Limited (Public Register (difc.ae):

• “Registered #0164

  Legatum Foundation Limited

  De-registered

  Non - financial

  Strategic Consultancy Services

• Registered #0101

  Legatum Ventures Limited Active Non - financial

  Proprietary Capital Management Location:Unit 201 , Level 2, Gate District Building 06, Dubai International Financial Centre, Dubai, United Arab Emirates

• Registered #0004

  Legatum Global Holdings Limited Active Non - financial Holding Company

  Location:Unit 201 , Level 2, Gate District Building 06, Dubai International Financial Centre, Dubai, United Arab Emirates

• Registered #0005

  Legatum Global Realty Limited De-registered Non - financial Holding Company

  Location:Unit 301 , Level 3, Gate Precinct Building 6, Dubai International Financial Centre, Dubai, United Arab Emirates

• Registered #0010

  Legatum Limited Active Non - financial Provision of Adminstration, office and information technology support services

  Location:Unit 201 , Level 2, Precinct Building - 6, Dubai International Financial Centre, Dubai, United Arab Emirates

• Registered #5685

  Legatum Operating Partnership LLP Active Non - financial Holding Company;

  Location:Unit 201 , Level 2, Precinct Building - 6, Dubai International Financial Centre, Dubai, United Arab Emirates”

Analysis:

Company registrations: The search in the Dubai International Financial Centre (DIFC) registry reveals six companies with "Legatum" in their name. Of these, four are active, and two are deregistered. This includes "Legatum Foundation Limited," (the parent of Legatum Institute Foundation) which is deregistered and does not provide a specific location.

Early Establishment: The low registration numbers (e.g., #0164 for Legatum Foundation Limited) suggest that these entities were among the first companies established in Dubai's DIFC, indicating a long-standing presence in the region.

Address Variations: The active companies share a similar address format, all referencing "Precinct Building 6" or variations like "Gate Precinct Building 6." These slight differences in address formatting (e.g., "6" vs. "06," inclusion of "Gate") could raise concerns about potential obfuscation through software errors.

The records for Legatum Foundation Limited provide more detail (I’ve copied the search record and added the additional detail below and hyperlink to this record):

• “Registered #0164

  Legatum Foundation Limited

  De-registered

  Non - financial

  Strategic Consultancy Services

• Public Register Detail (difc.ae)

  Legatum Foundation Limited www.legatum.com/

  Entity Overview

  Activities: Consultancy Services

  Entity Details

  Current name: Legatum Foundation Limited

  Trading name: Legatum Foundation Limited

  Type of License:Non Regulated

  Legal Structure:Recognised Company

  Date of registration:03.04.2006

  Date of Dissolution:25.10.2011

  License validity:03.04.2015

  DNFBP(Designated Non-Financial Businesses and Professions):No

• Director:

  McCormick Alan

  TROY WISEMAN

  Mark Alan Stoleson

  Philip Vassiliou

  Stephen Cutts

  Company Secretary:

  DARRIN RUSSELL ARTHUR PAYNE

  DONNA OUTERBRIDGE”

Analysis is required.

Legatum Foundation Limited (Bermuda)

There are 59 officer registrations, internationally, for “Rawlinson & Hunter”. The majority are registered in Bermuda and active “52 Bermuda, 2 Cyprus, 1 Denmark, 4 United Kingdom. (Company officers with names matching 'RAWLINSON & HUNTER' :: Page 1 :: OpenCorporates.

There are 16 company registrations, internationally for “RAWLINSON & HUNTER” (Companies matching 'RAWLINSON & HUNTER' :: OpenCorporates. These are:

• “GLOBAL FIDUCIARY (NZ) LIMITED (New Zealand, 24 Sep 2002- , Floor 3, 32 Mahuhu Crescent, Auckland Central, Auckland, 1010) Previously/Alternatively known as RAWLINSON AND HUNTER TRUSTEES NZ LIMITED

• Geneva Holding Company (GHC) SA (Switzerland, rue de l'Athénée, 34, Genève, 1206) Previously/Alternatively known as RAWLINSON AND HUNTER SA

• Geneva Tax & Audit (GTA) SA (Switzerland, rue de l'Athénée, 34, Genève, 1206) Previously/Alternatively known as RAWLINSON AND HUNTER AUDIT SA

• Geneva Trust Company (GTC) SA (Switzerland, rue de l'Athénée, 34, Genève, 1206) Previously/Alternatively known as RAWLINSON AND HUNTER TRUSTEES SA

• R&H TRANSITION LIMITED (United Kingdom, 3 Dec 1987- , Eighth Floor 6 New Street Square, London, EC4A 3AQ) Previously/Alternatively known as RAWLINSON AND HUNTER LIMITED

• RAWLINSON & HUNTER (SINGAPORE) PTE. LIMITED (Singapore, 1 Aug 2011- , 30 CECIL STREET, #18-02/03, PRUDENTIAL TOWER, 049712)

• RAWLINSON & HUNTER AUDIT LLP (United Kingdom, 28 Jan 2014- , Eighth Floor 6 New Street Square New Fetter Lane, London, EC4A 3AQ)

• inactive RAWLINSON & HUNTER COMPANY (Ireland, 23 Aug 1984-17 Jun 1994, STAPLETON HOUSE, REAR 89 SOUTH MALL, CORK., CORK, CORK)

• RAWLINSON & HUNTER LLP (United Kingdom, 31 Jan 2020- , Eighth Floor, 6 New Street Square New Fetter Lane, London, EC4A 3AQ)

• inactive RAWLINSON & HUNTER SERVICES LIMITED (United Kingdom, 7 Jan 2010-21 Jul 2023, Resolve Advisory Limited 22 York Buildings, London, WC2N 6JU)

• Rawlinson & Hunter (Guernsey) Limited (Guernsey, 1 Feb 2013- , Trafalgar Court 3rd Floor West Wing Les Banques St Peter Port GUERNSEY GY1 2JA)

• Rawlinson & Hunter (Switzerland) AG (Switzerland, Bellevueplatz, 5, Zürich, 8001) Previously/Alternatively known as RAWLINSON AND HUNTER ZURICH AG

• Rawlinson & Hunter (Switzerland) SA, succursale de Genève (Switzerland, Rue du Mont-Blanc, 4, Genève, 1201)

• Rawlinson & Hunter Limited (Bermuda, 9 Sep 2002- )

• Rawlinson & Hunter Limited (Guernsey, 15 Aug 1997- , Trafalgar Court 3rd Floor West Wing Les Banques St Peter Port GUERNSEY GY1 2JA)

• inactive Rawlinson and Hunter (Isle of Man, 1 Jun 1987-16 Sep 1999, 38/42 Athol Street, Douglas)”

Of these four are registered in the UK:

• R&H TRANSITION LIMITED (United Kingdom, 3 Dec 1987- , Eighth Floor 6 New Street Square, London, EC4A 3AQ) Previously/Alternatively known as RAWLINSON AND HUNTER LIMITED

• RAWLINSON & HUNTER AUDIT LLP (United Kingdom, 28 Jan 2014- , Eighth Floor 6 New Street Square New Fetter Lane, London, EC4A 3AQ)

• RAWLINSON & HUNTER LLP (United Kingdom, 31 Jan 2020- , Eighth Floor, 6 New Street Square New Fetter Lane, London, EC4A 3AQ)

• inactive RAWLINSON & HUNTER SERVICES LIMITED (United Kingdom, 7 Jan 2010-21 Jul 2023, Resolve Advisory Limited 22 York Buildings, London, WC2N 6JU)

Of these, three refer to the same location but with variations through the inclusion of “New Fetters Lane” in two and inconsistent commas in each address:

• Eighth Floor 6 New Street Square, London, EC4A 3AQ

• Eighth Floor 6 New Street Square New Fetter Lane, London, EC4A 3AQ

• Eighth Floor, 6 New Street Square New Fetter Lane, London, EC4A 3AQ

This misuse of addresses, introducing variations which cause false non-match errors represents a breach of the Companies Act 2006, section 853A.

Section 853A: This section requires companies to deliver a confirmation statement to Companies House, which must include accurate and up-to-date information about the company's registered office address and other key details. Inconsistent address records can lead to false non-match errors, complicating audits and due diligence processes.

This represents a significant risk given the Rawlinson & Hunter LLP is an international accountancy firm.

Trading disclosures assessment of Rawlinson & Hunter LLP (outstanding).

Legatum Institute website

A search locates an active website for "Legatum Institute". About - Legatum Institute (li.com)https://li.com/about/ which states:

"The partners of global investment firm Legatum: Christopher Chandler, Mark Stoleson, Alan McCormick and Philip Vassiliou founded the Legatum Institute in its original guise over 15 years ago, in 2007.

From inception, the Legatum Institute’s vision has been to “help others prosper” through its policy and educational work.  With a focus on world-class research, writing and convening, the purpose of the Legatum Institute is to unlock how individuals, families, communities, and nations can become more prosperous.

The Legatum Institute stands alongside Legatum’s other major philanthropic and humanitarian endeavours such as the END Fund, the Freedom Fund, the Luminos Fund, and many others."

Breaches: Misrepresentation and Transparency:

The continued operation of a website for "Legatum Institute" despite its inactive status misleads stakeholders, breaching trading disclosure requirements under Part 5, Chapter 6, Sections 82 to 85 of the Companies Act 2006 and The Company, Limited Liability Partnership and Business Names (Trading Disclosures) Regulations 2015. Non-compliant (s82-85:CA2006) (CTDR 2015).

These regulations require accurate representation of a company's status in all communications.

Trading disclosures compliance assessment: Legatum Institute.

The Legatum Institute website is operational, which would appear to be a breach since the companies Legatum Institute and The Legatum Foundation Limited were dissolved.

1. Company's Registered Name: “Legatum Institute” Correct name but uncompliant since it closed on 13 June 2018. Non-compliant (CTDR 2015)

2. Company Registration Number: Not provided. Non-compliant (CTDR 2015)

3. Place of Registration: Not provided. Non-compliant (CTDR 2015)

4. Registered Office Address: Provides “11 Charles Street, London, W1J 5DW, United Kingdom” on website and not the registered address is: “PO Box 897GT, PROSPERITY INTERNATIONAL, One Capital Place Grand Caynan, Cayman Islands, British West Indies”. Non-compliant (CTDR 2015)

5. Directors' Names: “The partners of global investment firm Legatum: Christopher Chandler, Mark Stoleson, Alan McCormick and Philip Vassiliou founded the Legatum Institute in its original guise over 15 years ago, in 2007.” Whereas, Christopher Chandler has never been appointed as an officer or person with significant control of LEGATUM INSTITUTE. The inclusion of an individual's name as a founder or key figure without formal appointment or registration could potentially mislead stakeholders about their role and authority within the company. Non-compliant (CTDR 2015)

6. Share Capital Information: Neither provided. Compliant

Summary of breaches by Legatum Institute of Trading Disclosure requirements: The Legatum Institute website is five time non-compliant with regards to Trading Disclosures (CTDR2015): The company closed on13 June 2018. The company registration number and place of registration are not provided and an incorrect registered office address is given. The directors names incorrectly include Christopher Chandler, when he was not appointed to this company.

Transparency compliance assessment of Alan McCormick's Biography:

Alan McCormick's biography on the Alliance For Responsible Citizenship (ARC) website provides an overview of his professional achievements and affiliations (Advisory Board — Alliance for Responsible Citizenship (ARC) https://www.arcforum.com/advisory-board). However, a detailed examination reveals several interests and directorships that are not disclosed or not disclose correctly in his profile.

Biography as presented:

“Alan McCormick is a Partner of the investment group Legatum. With his partners, he founded the END Fund, Freedom Fund, Luminos Fund, the Legatum Center for Entrepreneurship at MIT, and the Legatum Institute Foundation. He is also the co-creator of the Legatum Prosperity Index and Chairman of GB News.”

Interests and Identities Excluded from His Biography

Given the various identities and appointments associated with Alan James McCormick, his biography omits several key details that could be considered significant, especially when considering the risks of clone company fraud. Here are the interests excluded from his biography:

Undisclosed and Incorrectly Disclosed Interests:

1. Alliance For Responsible Citizenship Limited: Director (Appointed 9 Feb 2023, Active, Legatum Plaza, Level 2, Gate Precinct 6, Dubai International Finance Centre, PO BOX 506625, Dubai, UAE). He is listed as a member of the “Advisory Board” for Alliance for Responsible Citizenship Limited but does not disclose his directorship. Trading Disclosures non-compliant (CTDR 2015).

2. The Legatum Institute Foundation: Director (Appointed 5 Nov 2010, Dissolved, Dissolved on 19 December 2023, 11 Charles Street, London, UK, W1J 5DW). This interest is inaccurately declared omitting “The”. The biography has not been updated with dissolution of company on 19 December 2023. 2 times non-compliant (HLCC2023)

3. The End Fund: Director (Appointed 10 Jan 2011, Active, 495 Green Lanes, Palmers Green, London, N13 4BS). Incorrectly omits “The” in the biography. Non-compliant (HLCC2023).

4. The Freedom Fund UK: Director (Appointed 6 Mar 2014, Resigned 9 Nov 2023, Active, 495 Green Lanes, Palmers Green, London, N13 4BS). Incorrectly omits “The” in biography. Non-compliant (HLCC2023).

5. Prosperity Institute Limited: Director (Appointed 15 Dec 2022, Resigned 3 Jan 2024, Active, PO BOX 506625, Legatum Plaza, Level 2, Dubai International Financial Centre, Dubai, UAE). Recent past association omitted. Non-compliant (HLCC2023).

6. Hazeldine Films Ltd: Director (Appointed 2 Apr 2001, Resigned 3 Aug 2021, Active, Level 9, Convention Tower, Dubai Convention Centre, Dubai, UAE, 71093). Recent past association omitted. Non-compliant (HLCC2023)

7. All Perspectives Ltd Director Appointed on 6 April 2021 Level 2, Legatum Plaza, Dubai International Financial Centre, Dubai, United Arab Emirates This interest is omitted. Non-compliant (HLCC2023).

There are seven breaches of Transparency standards (HLC2023) within Alan McCormick’s biography on the Legatum website relating to interests that are registered in Companies House. The risk is that seemingly minor variations in company names can cause false non-match errors in auditing and due diligence software, avoiding traceability mechanisms that are designed to keep the public safe from fraud.

There are no records for a company with the name of his declaration of “Legatum Prosperity Index” Legatum Prosperity Index - Find. This is the only mention of prosperity

Anomalies: Luminos Fund and GB News

Luminos Fund could not be located in a search in Companies House (Luminos Fund - Find and update company information https://find-and-update.company-information.service.gov.uk/search/companies?q=Luminos+Fund). Further investigation is required because this declaration has the potential to be used to verify an association, that is not supported by registration in Companies House. This could enable a transaction to be approved when it should not have been approved. This presents a risk for potential serious organised crime. Non-compliant (HLCC 2023).

Alan McCormick declares that he is Chairman of GB News. The records for the director and persons with significant control of GB News were accessed, GB NEWS LIMITED people (https://find-and-update.company-information.service.gov.uk/company/12859339/officers). These are copied below:

“GB NEWS LIMITED

Company number 12859339

4 officers / 2 resignations

FRANGOPOULOS, Angelos Marcelo Correspondence address The Point, 37 North Wharf Road, London, United Kingdom, W2 1AF Role Active Director Date of birth July 1965 Appointed on 12 October 2021 Nationality Australian Country of residence United Kingdom Occupation Chief Executive Officer

SCHIPPER, Marc Herman Correspondence address The Point, 37 North Wharf Road, London, United Kingdom, W2 1AF Role Active Director Date of birth June 1973 Appointed on 12 October 2021 Nationality Dutch Country of residence England Occupation Chief Operating Officer

COLE, Andrew James Correspondence address Riverbank House, 2 Swan Lane, London, United Kingdom, EC4R 3TT Role Resigned Director Date of birth October 1966 Appointed on 4 September 2020 Resigned on 12 October 2021 Nationality British,American Country of residence United States Occupation Chief Executive

SCHNEIDER, Mark Lyle Correspondence address Riverbank House, 2 Swan Lane, London, United Kingdom, EC4R 3TT Role Resigned Director Date of birth July 1955 Appointed on 4 September 2020 Resigned on 21 August 2022 Nationality American Country of residence England Occupation Business Consultant

1 active person with significant control / 0 active statements

All Perspectives Ltd Active

Correspondence address Riverbank House, 2 Swan Lane, London, England, EC4R 3TT Notified on 4 September 2020 Registration number 12227760 Incorporated in United Kingdom Nature of control

• Ownership of shares – 75% or more

• Ownership of voting rights - 75% or more

• Right to appoint or remove directors”

Alan McCormick discloses that he is chairman of the Board of Directors of GB News. He is not a director of GB News Limited however, he is a director of the company which has significant control over GB News Limited, that is All Perspectives Ltd. It has already been noted that he failed to declare his directorship of All Perspectives Ltd, held in “identity 7”.

The record for the persons with significant control of All Perspective Ltd provides the following details:

“ALL PERSPECTIVES LTD

5 active persons with significant control / 0 active statements

Philip Vassiliou Active Correspondence address Level 2, Legatum Plaza, Dubai International Finance Centre, Dubai, United Arab Emirates Notified on 31 December 2024 Date of birth March 1977 Nationality British Country of residence United Arab Emirates Nature of control Has significant influence or control over the trustees of a trust

Sir Paul Roderick Clucas Marshall Active Correspondence address 2 Swan Lane, London, England, EC4R 3TT Notified on 16 August 2022 Date of birth August 1959 Nationality British Country of residence England Nature of control Ownership of shares – More than 25% but not more than 50% Ownership of voting rights - More than 25% but not more than 50%

Mr Richard Edward Douglas Active Correspondence address PO Box 506, Unit 201, Level 2, Gate Precinct Building 6, Dubai International Financial Centre, Dubai, United Arab Emirates Notified on 6 June 2022 Date of birth May 1953 Nationality Cayman Islander Country of residence Cayman Islands Nature of control Has significant influence or control over the trustees of a trust

Mr Alan James Mccormick Active Correspondence address Level 2, Legatum Plaza, Dubai International Financial Centre, Dubai, United Arab Emirates Notified on 6 April 2021 Date of birth June 1974 Nationality British Country of residence United Arab Emirates Nature of control Has significant influence or control over the trustees of a trust

Mr Christopher Lincoln Chandler Active Correspondence address Level 2, Legatum Plaza, Dubai International Financial Centre, Dubai, United Arab Emirates Notified on 6 April 2021 Date of birth January 1960 Nationality New Zealander Country of residence United Arab Emirates Nature of control Has significant influence or control over the trustees of a trust

Mr Mark Alan Stoleson Ceased Correspondence address Level 2, Legatum Plaza, Dubai International Financial Centre, Dubai, United Arab Emirates Notified on 6 April 2021 Ceased on 31 December 2024 Date of birth July 1970 Nationality Maltese Country of residence United Arab Emirates Nature of control Has significant influence or control over the trustees of a trust

Discovery Communications Europe Limited Ceased Correspondence address Discovery House, Chiswick Park Building 2, 566 Chiswick High Road, London, England, W4 5YB Notified on 6 April 2021 Ceased on 16 August 2022 Governing law Companies Act 2006 Legal form Private company Place registered Companies House, Uk Registration number 05039068 Incorporated in England And Wales Nature of control Ownership of shares – More than 25% but not more than 50% Ownership of voting rights - More than 25% but not more than 50%

Mr Mark Lyle Schneider Ceased Correspondence address 8 Clifford Street, Mayfair, London, W1S 2LQ Notified on 25 September 2019 Ceased on 6 April 2021 Date of birth July 1955 Nationality American Country of residence England Nature of control Ownership of shares – More than 25% but not more than 50% Ownership of voting rights - More than 25% but not more than 50%

Mr Andrew Cole Ceased Correspondence address 8 Clifford Street, Mayfair, London, W1S 2LQ Notified on 25 September 2019 Ceased on 6 April 2021 Date of birth October 1966 Nationality British,American Country of residence United States Nature of control Ownership of shares – More than 25% but not more than 50% Ownership of voting rights - More than 25% but not more than 50%

Upon comparing the Persons with Significant Control (PSC) for All Perspectives Ltd and Alliance for Responsible Citizenship Limited, prior to 31 December 2024, when Philip Vassiliou was appointed and Mr Stoleson ceased to have control, we find several similarities and some differences:

Similarities, prior to 31 December 2024:

1. Both companies have the same five individuals listed as PSCs:

   • Sir Paul Roderick Clucas Marshall

   • Mr Richard Edward Douglas

   • Mr Mark Alan Stoleson

   • Mr Alan James McCormick

   • Mr Christopher Lincoln Chandler

2. The personal details (date of birth, nationality, country of residence) for each individual are identical across both companies.

3. Four of the five PSCs (Douglas, Stoleson, McCormick, and Chandler) use correspondence addresses in Dubai for both companies.

Differences:

1. Sir Paul Marshall's correspondence address differs:

   • For All Perspectives Ltd: 2 Swan Lane, London, England, EC4R 3TT

   • For Alliance for Responsible Citizenship Limited: 78 Pall Mall, London, England, SW1Y 5ES

2. The nature of control varies:

   • In All Perspectives Ltd, Sir Paul Marshall has ownership of shares and voting rights (25-50%), while the others have "significant influence or control over the trustees of a trust"

   • In Alliance for Responsible Citizenship Limited, all five individuals are listed as having "significant influence or control"

3. The notification dates for the PSCs differ between the two companies.

4. There are slight variations in how the Dubai addresses are formatted, though they appear to refer to the same location (Legatum Plaza, Dubai International Financial Centre) which can cause errors in audit software, obscuring relationships.

Assessments of the directors of All Perspectives Limited

The officers are:

ALL PERSPECTIVES LTD people (https://find-and-update.company-information.service.gov.uk/company/12227760/officers)

13 officers / 8 resignations

AGNEW, Theodore Thomas More, Lord Correspondence address The Point, 37 North Wharf Road, London, United Kingdom, W2 1AF Role Active Director Date of birth January 1961 Appointed on 23 April 2024 Nationality British Country of residence United Kingdom Occupation Company Director

FARMER, George Correspondence address The Point, 37 North Wharf Road, London, United Kingdom, W2 1AF Role Active Director Date of birth July 1990 Appointed on 27 September 2023 Nationality British Country of residence United States Occupation Director

LINNELL, Matthew Correspondence address Level 2, Legatum Plaza, Dubai International Finance Centre, Dubai, United Arab Emirates Role Active Director Date of birth March 1993 Appointed on 31 December 2024 Nationality American Country of residence United Arab Emirates Occupation Lawyer

MCCORMICK, Alan Correspondence address Level 2, Legatum Plaza, Dubai International Financial Centre, Dubai, United Arab Emirates Role Active Director Date of birth June 1974 Appointed on 6 April 2021 Nationality British Country of residence United Arab Emirates Occupation Managing Director

MORRISSEY, Helena Louise, Baroness Correspondence address The Point, 37 North Wharf Road, London, United Kingdom, W2 1AF Role Active Director Date of birth March 1966 Appointed on 3 November 2022 Nationality British Country of residence United Kingdom Occupation Director

COLE, Andrew Correspondence address Riverbank House, 2 Swan Lane, London, United Kingdom, EC4R 3TT Role Resigned Director Date of birth October 1966 Appointed on 25 September 2019 Resigned on 15 August 2022 Nationality British,American Country of residence United States Occupation Chief Executive

GIBBONS, James T'Sung Jen Correspondence address Discovery Corporate Services, Limited Building 2, Chiswick Park, London, England, W4 5YB Role Resigned Director Date of birth June 1969 Appointed on 6 April 2021 Resigned on 16 August 2022 Nationality Canadian Country of residence United Kingdom Occupation Evp

JHINGAN, Anil Kumar Correspondence address Discovery Corporate Services, Limited Building 2, Chiswick Park, London, England, W4 5YB Role Resigned Director Date of birth December 1970 Appointed on 6 April 2021 Resigned on 11 February 2022 Nationality British Country of residence England Occupation Evp Corporate Development Total number of appointments 9

• A search, Anil Kumar JHINGAN - Find locates a second identity: Anil Kumar JHINGAN Total number of appointments 7 includes dissolved companies with accounts overdue in breach of section 441 (CA2006) WHELCO HOLDINGS LIMITED (03033275), BENTLEY INSURANCE SERVICES LIMITED (03031474), LAKELAND PROCESSING LIMITED (02926645)

MARSHALL, Paul Roderick Clucas, Sir Correspondence address The Point, 37 North Wharf Road, London, United Kingdom, W2 1AF Role Resigned Director Date of birth August 1959 Appointed on 6 April 2021 Resigned on 23 April 2024 Nationality British Country of residence United Kingdom Occupation Fund Manager

NEIL, Andrew Ferguson Correspondence address 22 Old Queen Street, London, England, SW1H 9HP Role resigned Director Date of birth May 1949 Appointed on 5 January 2021 Resigned on 13 September 2021 Nationality British Country of residence France Occupation Director

• A search, Andrew Ferguson NEIL - Find locates a second identity Andrew Ferguson NEIL: GLENBURN ENTERPRISES LIMITED (02552107) Company status Active Correspondence address 55 Onslow Gardens (Flat 3), London, United Kingdom, SW7 3QF Role Active Secretary Appointed on 21 January 2016 Registered office address Regina House, 124 Finchley Road, London, NW3 5JS Nature of business (SIC) 90030 - Artistic creation

SCHNEIDER, Mark Lyle Correspondence address Riverbank House, 2 Swan Lane, London, United Kingdom, EC4R 3TT Role Resigned Director Date of birth July 1955 Appointed on 25 September 2019 Resigned on 18 August 2022 Nationality American Country of residence England Occupation Business Consultant

STOLESON, Mark Correspondence address Level 2, Legatum Plaza, Dubai International Financial Centre, Dubai, United Arab Emirates Role Resigned Director Date of birth July 1970 Appointed on 6 April 2021 Resigned on 31 December 2024 Nationality Maltese Country of residence United Arab Emirates Occupation Chief Executive Officer

WELLS, Adrian Clifford Correspondence address Riverbank House, 2 Swan Lane, London, United Kingdom, EC4R 3TT Role Resigned Director Date of birth December 1964 Appointed on 11 February 2022 Resigned on 16 August 2022 Nationality British Country of residence Luxembourg Occupation Managing Director

Each of these directors require further assessment for accounts, transparency compliance and identity integrity in Companies House.

AGNEW, Theodore Thomas More, Lord Correspondence address The Point, 37 North Wharf Road, London, United Kingdom, W2 1AF Role Active Director Date of birth January 1961 Appointed on 23 April 2024 Nationality British Country of residence United Kingdom Occupation Company Director

Lord Agnew will be considered further:

Other appointments held in the identity located above as listed:

Theodore Thomas More AGNEW

Total number of appointments 8 Date of birth January 1961

ALL PERSPECTIVES LTD (12227760) Company status Active Correspondence address The Point, 37 North Wharf Road, London, United Kingdom, W2 1AF Role Active Director Appointed on 23 April 2024 Nationality British Country of residence United Kingdom Occupation Company Director

MARKERSTUDY GROUP HOLDINGS LIMITED (13073792) Company status Active Correspondence address 45 Westerham Road, Bessels Green, Sevenoaks, Kent, United Kingdom, TN13 2QB Role Active Director Appointed on 26 June 2023 Nationality British Country of residence United Kingdom Occupation Company Director

16-20 STRUTTON GROUND MANAGEMENT CO. LIMITED (07476959) Company status Active Correspondence address Suite 75, Waterhouse Business Centre, 2 Cromar Way, Chelmsford, England, CM1 2QE Role Active Director Appointed on 24 April 2023 Nationality British Country of residence United Kingdom Occupation Director

INTERNATIONAL MEDIA ACQUISITIONS LIMITED (15249371) Company status Active Correspondence address 6 Old Queen Street, London, United Kingdom, SW1H 9HP Role Resigned Director Appointed on 31 October 2023 Resigned on 1 July 2024 Nationality British Country of residence United Kingdom Occupation Director

OLD QUEEN STREET VENTURES LTD (12044066) Company status Active Correspondence address 6 Old Queen Street, London, England, SW1H 9HP Role Resigned Director Appointed on 6 October 2023 Resigned on 1 July 2024 Nationality British Country of residence United Kingdom Occupation Director

UNHERD LIMITED (10678659) Company status Active Correspondence address 6 Old Queen Street, London, England, SW1H 9HP Role Resigned Director Appointed on 6 October 2023 Resigned on 1 July 2024 Nationality British Country of residence United Kingdom Occupation Director

UNHERD LIMITED (10678659) Company status Active Correspondence address America House, Rumford Court, Rumford Place, Liverpool, United Kingdom, L3 9DD Role Resigned Director Appointed on 12 June 2017 Resigned on 9 October 2017 Nationality British Country of residence United Kingdom Occupation Company Director

UNHERD LIMITED (10678659) Company status Active Correspondence address America House, Rumford Court, Rumford Place, Liverpool, United Kingdom, L3 9DD Role Resigned Director Appointed on 20 March 2017 Resigned on 12 June 2017 Nationality British Country of residence United Kingdom Occupation Company Director

A search for officers named “Theodore Thomas More AGNEW” in Companies House locates five identities that include this surname with date of birth January 1961. These identities are interspersed with corporate identities which are likely to be associated with Lord Agnew, possibly by an address that is not shown, Theodore Thomas More AGNEW - Find (https://find-and-update.company-information.service.gov.uk/search/officers?q=Theodore%20Thomas%20More%20AGNEW):

• Lord Theodore Thomas More AGNEW

  Total number of appointments 1 - Born January 1961

  6 Old Queen Street, London, United Kingdom, SW1H 9HP

• Lord Theodore Thomas More AGNEW

  Total number of appointments 1 - Born January 1961

  The Point, 37 North Wharf Road, London, United Kingdom, W2 1AF

• Lord Theodore Thomas More AGNEW

  Total number of appointments 8 - Born January 1961

  The Point, 37 North Wharf Road, London, United Kingdom, W2 1AF

• THEODORE EMMS TRADING LIMITED

  Total number of appointments 2

  6th Floor, 338 Euston Road, London, United Kingdom, NW1 3BG

• BOB AGNEW LIMITED

  Total number of appointments 0

  The Lexicon, Mount Street, Manchester, England, M2 5FA

• AGNEW HOLDINGS LIMITED

  Total number of appointments 0

  Suite 3, 1st Floor, Trinity House PO BOX 41, Victoria, Mahe, Seychelles

• ISAAC AGNEW (HOLDINGS) LIMITED MANAGEMENT PENSION PLAN

  Total number of appointments 1

  10 Drumbo Rod, Lisburn, County Antrim, United Kingdom, BT27 5TX

• Lord Theodore Thomas More AGNEW

  Total number of appointments 47 - Born January 1961

  Outwood Grange Academies Trust, Potovens Lane, Outwood, Wakefield, West Yorkshire, United Kingdom, WF1 2PF

• ISAAC AGNEW (HOLDINGS) LIMITED

  Total number of appointments 1

  18 Boucher Way, Belfast, Co. Antrim, United Kingdom, BT12 6RE

• AGNEW FINANCIAL SERVICES

  Total number of appointments 1

  18 Boucher Way, Belfast, Northern Ireland, BT12 6RE

• Theodore AGNEW

  Total number of appointments 1 - Born January 1961

  Mall House, The Mall, Faversham, Kent, England, ME13 8JL

Focussing on the identities that are a real person, these identities are expanded with the information accessed by clicking on their name.

• Lord Theodore Thomas More AGNEW

  Total number of appointments 1 - Born January 1961

  6 Old Queen Street, London, United Kingdom, SW1H 9HP

  • This page cannot be found (https://find-and-update.company-information.service.gov.uk/officers/3e4Ahj51s8azx26tSixLJ6o-QG8/appointments)

• Lord Theodore Thomas More AGNEW

  Total number of appointments 1 - Born January 1961

  The Point, 37 North Wharf Road, London, United Kingdom, W2 1AF

  • This page cannot be found (https://find-and-update.company-information.service.gov.uk/officers/5H2zOplb6Pyk3nQYRwibMkX96Qo/appointments)

• Lord Theodore Thomas More AGNEW

  Total number of appointments 8 - Born January 1961

  The Point, 37 North Wharf Road, London, United Kingdom, W2 1AF

  • Described above

• Lord Theodore Thomas More AGNEW

  Total number of appointments 47 - Born January 1961

  Outwood Grange Academies Trust, Potovens Lane, Outwood, Wakefield, West Yorkshire, United Kingdom, WF1 2PF

• Theodore AGNEW

  Total number of appointments 1 - Born January 1961

  Mall House, The Mall, Faversham, Kent, England, ME13 8JL

The corporate identities that were returned in the search for an officer named Theodore Thomas More AGNEW require further assessment:

• THEODORE EMMS TRADING LIMITED

  Total number of appointments 2

  6th Floor, 338 Euston Road, London, United Kingdom, NW1 3BG

• BOB AGNEW LIMITED

  Total number of appointments 0

  The Lexicon, Mount Street, Manchester, England, M2 5FA

• AGNEW HOLDINGS LIMITED

  Total number of appointments 0

  Suite 3, 1st Floor, Trinity House PO BOX 41, Victoria, Mahe, Seychelles

• ISAAC AGNEW (HOLDINGS) LIMITED MANAGEMENT PENSION PLAN

  Total number of appointments 1

  10 Drumbo Rod, Lisburn, County Antrim, United Kingdom, BT27 5TX

• ISAAC AGNEW (HOLDINGS) LIMITED

  Total number of appointments 1

  18 Boucher Way, Belfast, Co. Antrim, United Kingdom, BT12 6RE

• AGNEW FINANCIAL SERVICES

  Total number of appointments 1

  18 Boucher Way, Belfast, Northern Ireland, BT12 6RE

Lord Agnew’s Register of Interests is provided at the House of Lords. This is copied in full in Annex 1

Conclusion of Compliance Assessment for Alan James McCormick

The compliance assessment of Alan James McCormick reveals significant issues related to identity management and transparency in Companies House records. The following key points summarize the findings:

1. Unique Identifier Non-Compliance:

   • Alan James McCormick has registered seven separate identities in Companies House, including one under the name "Alan McCormick" without a middle name. This constitutes six breaches of Section 1082 of the Companies Act 2006, which mandates a single unique identifier for directors. Such non-compliance obscures true business interests and complicates audits and Know Your Customer (KYC) checks.

2. Transparency and Disclosure Issues:

   • McCormick's biography on the Alliance For Responsible Citizenship (ARC) website omits several key directorships, including his role at All Perspectives Ltd, which controls GB News. This omission leads to seven breaches of transparency standards (HLCC2023). Such discrepancies can cause false non-match errors in auditing and due diligence processes, undermining traceability mechanisms designed to protect public safety.

3. Accounts Compliance:

   • He is associated with companies that have dissolved without producing final accounts, resulting in three breaches of Section 441 of the Companies Act 2006. This raises concerns about potential financial mismanagement and the risk of fraudulent activities relating to these companies:

     Identity 1: Catalitix Advisors Ltd

     Identity 2: The Legatum Institute Foundation

     Identity 4: Legatum Institute.

4. Potential Fraud Risks:

   • The existence of multiple identities suggests possible synthetic identity fraud, which could be used to obscure true ownership and control. This poses a risk to stakeholders and could facilitate fraudulent activities such as money laundering or tax evasion.

5. Anomalies and Misrepresentations:

   • Alan McCormick declares himself as Chairman of GB News; however, he is not listed as a director in Companies House records for GB News Limited. Instead, he is a director at All Perspectives Ltd, which holds significant control over GB News. This discrepancy indicates a breach of the Companies Act 2006, requiring all directors to be registered.

Risks and Recommendations

• Regulatory Investigation: Immediate regulatory scrutiny is necessary to investigate potential fraudulent activities and enforce compliance.

• Enhanced Due Diligence: Stakeholders should conduct enhanced due diligence when engaging with entities associated with Alan James McCormick.

• Public Awareness: Increasing awareness about the risks associated with synthetic identity fraud can help protect investors and the public from deceptive practices.

In conclusion, Alan James McCormick's compliance assessment highlights critical issues that undermine corporate governance integrity. Immediate corrective actions are recommended to address these breaches and enhance compliance practices within Alliance for Responsible Citizenship Limited and related entities. This conclusion summarizes the key findings from your compliance assessment while addressing potential risks and recommending actionable steps to mitigate them. This does not include an exhaustive assessment of other identities as “Alan McCormick” with different dates of birth which may be associated. Further investigation is required.

Resigned directors of Alliance For Responsible Citizenship Limited.

Since conflicts of interest can occur at any time, even after resignation, the resigned directors of Alliance For Responsible Citizenship Limited also require analysis for multiple identities in Companies House. This is based on Section 170(2)(a) of the Companies Act 2006, which states that directors' general duties, including avoiding conflicts of interest, are grounded in common law and equitable principles and apply at all times. This supports the need for continuous management of conflicts to ensure compliance with legal obligations. A compliance assessment of the directors who have resigned from Alliance For Responsible Citizenship are therefore analysed in the next section of this report, referring to these records:

“PLUNKETT, Oliver Correspondence address C/o Wpo Limited, First Floor, 6 Grosvenor Street, London, United Kingdom, W1K 4PZ Role Resigned Secretary Appointed on 15 January 2017 Resigned on 19 January 2017

HILL, Jonathan Hopkin, The Rt Hon. The Lord Correspondence address 11 Charles Street, London, England, W1J 5DW Role Resigned Director Date of birth July 1960 Appointed on 31 January 2018 Resigned on 10 February 2023 Nationality British Country of residence England Occupation Self-Employed

PLUNKETT, Oliver Correspondence address 20 Eastbourne Terrace, London, England, W2 6LG Role Resigned Director Date of birth April 1972 Appointed on 19 January 2017 Resigned on 19 January 2018 Nationality British Country of residence England Occupation Company Director”

C. The Rt Hon. The Lord Jonathan Hopkin HILL

The identity which holds the directorship appointment to Alliance For Responsible Citizenship, is reached by clicking on his name, this holds the following appointments:

“Total number of appointments 4

Date of birth July 1960

DITCHLEY FOUNDATION(THE) (00599389) Company status Active Correspondence address Ditchley Park, Enstone, Chipping Norton, Oxfordshire, OX7 4ER Role Active Director Appointed on 8 July 2017 Nationality British Country of residence England Occupation Consultant

TEACH FIRST (04478840) Company status Active Correspondence address 6 Mitre Passage, Greenwich Peninsula, London, England, SE10 0ER Role Resigned Director Appointed on 20 March 2017 Resigned on 20 March 2023

ALLIANCE FOR RESPONSIBLE CITIZENSHIP LIMITED (10519995) Company status Active Correspondence address 11 Charles Street, London, England, W1J 5DW Role Resigned Director Appointed on 31 January 2018 Resigned on 10 February 2023 Occupation Self-Employed

TIMES NEWSPAPERS HOLDINGS LIMITED (00206377) Company status Dissolved Correspondence address 1 London Bridge Street, London, United Kingdom, SE1 9GF Role Resigned Director Appointed on 28 March 2017 Resigned on 3 March 2022 Occupation None Dissolved Dissolved on 9 July 2024 Company type Private limited Company Incorporated on 3 June 1925 Accounts Last accounts made up to 3 July 2022 Accounts overdue Non-compliant (s441:CA2006) Nature of business (SIC) 74990 - Non-trading company Previous company names THOMSON NEWSPAPERS LIMITED 03 Jun 1925 - 31 Dec 1980”

Unique identifier compliance assessment

A search on the name Jonathan Hopkin HILL returns multiple identities with this name and date of birth amongst corporate identities with the name including “Hopkin” (Jonathan Hopkin HILL - Find https://find-and-update.company-information.service.gov.uk/search/officers?q=Jonathan+Hopkin+HILL)):

• “Lord Jonathan Hopkin HILL

  Total number of appointments 1 - Born July 1960

  57 Tufton Street, London, United Kingdom, SW1P 3QL

• Jonathan Hopkin HILL

  Total number of appointments 4 - Born July 1960

  Ditchley Park, Enstone, Chipping Norton, Oxfordshire, OX7 4ER

• HILLIER HOPKINS GROUP LIMITED

  Total number of appointments 1

  Charter Court, Midland Road, Hemel Hempstead, Hertfordshire, United Kingdom, HP2 5GE

• Jonathan Hopkin HILL

  Matching appointment names:
  Jonathan HILL

  Total number of appointments 5 - Born July 1960

  Dodington House Breamore, Fordingbridge, Hampshire, SP6 2EH

• HILLIER HOPKINS LLP

  Total number of appointments 4

  Charter Court, Midland Road, Hemel Hempstead, Hertfordshire, United Kingdom, HP2 5GE

• Jonathan Hopkin HILL

  Total number of appointments 1 - Born July 1955

  Faraday House The Green, Hampton Court, East Molesey, Surrey, KT8 9BW

• HOPKIN SMART CONSULTING LTD

  Total number of appointments 3

  21 Hazelwood Road, Duffield, Belper, England, DE56 4DP

• HOPKIN SMART CONSULTING LTD

  Total number of appointments 10

  21 Hazelwood Road, Duffield, Belper, Derbyshire, United Kingdom, DE56 4DP

• HOPKIN SMART CONSULTING LTD

  Total number of appointments 1

  21 Hazelwood Road, Duffield, Belper, Derbyshire, United Kingdom, DE56 4DP”

There are three identities registered to Jonathan Hopkin Hill born July 1960 and a fourth identity with this name and date of birth July 1955. There are identities for corporate persons amongst the first results listed, Hillier Hopkins LLP, Hillier Hopkins Group Limited and Hopkin Smart Computing and there are multiple other corporate person identities which are similarly named. All of these require confirmation of whether or not these are related parties of Lord Hill. The identities that are certain to relate to the same person are explored first:

Lord Jonathan Hopkin HILL identity A

“Total number of appointments 1 - Born July 1960

57 Tufton Street, London, United Kingdom, SW1P 3QL

CENTRE FOR POLICY STUDIES LIMITED (01174651) Company status Active Role Active Director Appointed on 10 May 2017 Nationality British Country of residence United Kingdom Occupation Self-Employed”

Jonathan Hopkin HILL identity B

"Total number of appointments 4 - Born July 1960

Ditchley Park, Enstone, Chipping Norton, Oxfordshire, OX7 4ER

DITCHLEY FOUNDATION(THE) (00599389) Company status Active Correspondence address Ditchley Park, Enstone, Chipping Norton, Oxfordshire, OX7 4ER Role Active Director Appointed on 8 July 2017 Nationality British Country of residence England Occupation Consultant

TEACH FIRST (04478840) Company status Active Correspondence address 6 Mitre Passage, Greenwich Peninsula, London, England, SE10 0ER Role Resigned Director Appointed on 20 March 2017 Resigned on 20 March 2023

ALLIANCE FOR RESPONSIBLE CITIZENSHIP LIMITED (10519995) Company status Active Correspondence address 11 Charles Street, London, England, W1J 5DW Role Resigned Director Appointed on 31 January 2018 Resigned on 10 February 2023 Occupation Self-Employed

TIMES NEWSPAPERS HOLDINGS LIMITED (00206377) Company status Dissolved Correspondence address 1 London Bridge Street, London, United Kingdom, SE1 9GF Role Resigned Director Appointed on 28 March 2017 Resigned on 3 March 2022”

Jonathan Hopkin HILL identity C

"Matching appointment names:
Jonathan HILL

Total number of appointments 5 - Born July 1960

Dodington House Breamore, Fordingbridge, Hampshire, SP6 2EH

Total number of appointments 5

Date of birth July 1960

THE QUILLER CONSULTANCY LIMITED (03609582) Company status Active Correspondence address Dodington House Breamore, Fordingbridge, Hampshire, SP6 2EH Role Resigned Director Appointed on 4 August 1998 Resigned on 12 June 2010 Occupation Communications Consultant

QUILLER ASSOCIATES LIMITED (04472442) Company status Dissolved Correspondence address Dodington House Breamore, Fordingbridge, Hampshire, SP6 2EH Role Resigned Director Appointed on 28 June 2002 Resigned on 12 June 2010 Occupation Communications Consultant Final accounts not submitted . This triggers the risk that bank accounts are still operating

HANFORD SCHOOL CHARITABLE TRUST LIMITED (02572565) Company status Active Correspondence address Dodington House Breamore, Fordingbridge, Hampshire, SP6 2EH Role Resigned Director Appointed on 8 July 2004 Resigned on 21 May 2010 Occupation Communications Consultant

THE NATIONAL LITERACY TRUST (05836486) Company status Active Correspondence address Dodington House Breamore, Fordingbridge, Hampshire, SP6 2EH Role Resigned Director Appointed on 5 June 2006 Resigned on 8 December 2009 Communications Consultant

THE CRIME CONCERN TRUST LIMITED (02259016) Company status Active Correspondence address Faraday House The Green, Hampton Court Road, East Molesey, Surrey, KT8 9BW Role Resigned Director Appointed on 25 July 1996 Resigned on 2 November 1999 Occupation Pr Consultant”

There is another identity registered in Companies House with the same name and month of birth, but an earlier year of birth, 1955.

Jonathan Hopkin HILL identity D

“Total number of appointments 1 - Born July 1955

Faraday House The Green, Hampton Court, East Molesey, Surrey, KT8 9BW

FARADAY YARD COMPANY LIMITED (01815669) Company status Active Correspondence address Faraday House The Green, Hampton Court, East Molesey, Surrey, KT8 9BW Role Resigned Director Appointed on 30 March 1995 Resigned on 31 July 1997 Nationality British Occupation Pr Consultant”

During two years of research, I've discovered that individuals who register multiple identities in Companies House, often use different dates of birth to conceal their interests as seen with Rishi Sunak. Notably, Jonathan Hopkin Hill, born in 1960, has three registered identities, indicating anomalous behaviour. Additionally, a fourth identity exists with the same name, "Jonathan Hopkin Hill," but with a birth year of 1955. This identity D shares the same birth month, July, and occupation "Pr (sic) Consultant, as in identity C." It is likely that this is another identity for Jonathan Hopkin Hill born in July 1960. Confirmation is needed to determine if the 1955 identity is claimed by the individual born in 1960. Since the first identity registered with this name used birth date 1955, this may be his actual birth date.

Associated “corporate person” identities?

Query whether Lord Hill is associated to any of the three corporate person identities, returned in the search for officers named Jonathan Hopkin Hillier. Whilst no direct association to Jonathan Hopkin Hill has been identified the Companies House search algorithm has co-located these corporate person identities amongst Jonathan Hill’s multiple identities.

Clarification is required from Jonathan Hopkin Hill as to whether he is associated in any way to: Hillier Hopkins Group Limited, Hillier Hopkins LLP and Hopkin Smart Consulting Limited, corporate identities that are associated to dissolved companies with accounts overdue. Refer to Appendix B for more analysis on these corporate identities, breaches and queries which require investigation.

Lord Hill of Oareford: Register of Interest at the House of Lords.

Jonathan Hopkin Hill is Lord Hill of Oareford. Referring to Lord Hill of Oareford’s Register of Interests, which is available on the House of Lords’ website, his declarations for Category 1 interests, directorships is copied below (Register of Interests - Members of the House of Lords - MPs and Lords - UK Parliament https://members.parliament.uk/members/lords/interests/register-of-lords-interests?SearchTerm=Lord+Hill+of+Oareford&ShowAmendments=True).

Lord Hill’s full declaration is in Appendix C.

“Category 1: Directorships

• Interest deleted 6 March 2023 Independent National Director, Times Newspapers (interest ceased 3 March 2022) (originally added 30 March 2017)

Category 4: Shareholdings (b)

• Interest deleted 30 October 2014 Huntsworth plc (international public relations business) (originally added 2 June 2010)

Category 10: Non-financial interests (a)

• Interest deleted 13 February 2024 Director, Prosperity UK (interest ceased 10 February 2023) (originally added 2 March 2018)

Category 10: Non-financial interests (b)

• Interest deleted 8 March 2022 Chair, The UK Listings Review (launched by the Chancellor on 19 November 2020 as part of a plan to strengthen the UK’s position as a leading global financial centre) (interest ceased 3 March 2021) (originally added 24 November 2020)

Category 10: Non-financial interests (e)

• Interest deleted 13 February 2024 Trustee, Teach First (interest ceased 9 February 2023) (originally added 16 March 2017)

• Interest amended 3 November 2017 Chairman (formerly Member) of the Council of Management, Ditchley Foundation (originally added 17 March 2017)

• Interest amended 15 May 2017 Board Member, Centre for Policy Studies (originally added 15 May 2017)

• Interest amended 28 February 2024 Trustee, Axiom Maths (formerly MESME) (charity which promotes maths education as route to social mobility) (originally added 30 August 2023)”.

Breach:
Lord Hill of Oareford's Register of Interests inaccurately states that he was a director of "Prosperity UK, interest ceased 10 February 2023." The company was actually named “Prosperity UK 2017 Limited” and changed its name to “Alliance for Responsible Citizenship Limited” on 21 January 2023. This discrepancy requires correction in his Register of Interests. Clarification is requested on whether he is associated with any corporate identities returned in searches under his name, as some appear higher in search results than his own name, suggesting a possible relationship.

Aspects of the Code engaged:

• Paragraph 9 - Personal honour: Multiple identities and discrepancies in personal details undermine personal honour.

• Paragraph 10 - Public interest: Inaccurate disclosure of directorships compromises transparency and accountability.

• Paragraph 12(a) - Registration of interests: Inaccurate registration and omission of significant roles violate registration requirements.

• Paragraph 16 - Declaration of interests: Non-disclosure or misrepresentation in the Register contradicts the obligation to declare relevant interests.

Supporting details or evidence:
The compliance assessment highlights multiple identities for Lord Hill in Companies House records, with discrepancies in company names and dates. These issues raise concerns about transparency and adherence to the Code. Further investigation is warranted to ensure compliance with the principles of public life.

D. Oliver Plunkett, Date of birth April 1972

Oliver PLUNKETT - Find https://find-and-update.company-information.service.gov.uk/search/officers?q=Oliver+PLUNKETT).

• Oliver PLUNKETT

• Total number of appointments 10 - Born April 1972

  Cedarwood, Penshurst Road, Speldhurst, Tunbridge Wells, England, TN3 0PQ

• Oliver PLUNKETT

  Total number of appointments 0 - Born April 1972

  6 First Floor, Grosvenor Street, London, United Kingdom, W1K 4PZ

• Oliver PLUNKETT

  Total number of appointments 1

  First Floor, 6 Grosvenor Street, London, United Kingdom, W1K 4PZ

• Oliver PLUNKETT

  Total number of appointments 1

  234 Pall Mall, London, England, SW1Y 5EA

• Oliver PLUNKETT

  Total number of appointments 1 - Born April 1972

  17 Grosvenor Street, London, England, W1K 4QG

• Oliver PLUNKETT

  Total number of appointments 1 - Born December 1994

  Oakmoore Court, Kingswood Road, Hampton Lovett, Droitwich, Worcestershire, United Kingdom, WR9 0QH

• Oliver PLUNKETT

  Total number of appointments 1 - Born April 1972

  Merlin House, 4 Meteor Way, Lee-On-The-Solent, Hampshire, United Kingdom, PO139FU

• Oliver PLUNKETT

  Total number of appointments 2 - Born April 1972

  Cedarwood, Penshurst Road, Speldhurst, Tunbridge Wells, England, TN3 0PQ

• Oliver PLUNKETT

  Total number of appointments 1

  C/O WPO LIMITED, FIRST FLOOR, 6 Grosvenor Street, London, United Kingdom, W1K 4PZ

• Oliver PLUNKETT

  Total number of appointments 1 - Born June 1972

  Hub Kings Cross, York Way, London, England, N1 9AB

• Oliver Charles Pelham PLUNKETT

  Total number of appointments 2 - Born October 1972

  Camden Mill, Lower Bristol Road, Bath, BA2 3DQ

• Oliver Charles Pelham PLUNKETT

  Total number of appointments 1 - Born October 1972

  Camden Mill, Lower Bristol Road, Bath, BA2 3DQ

• Oliver James PLUNKETT

  Total number of appointments 0 - Born September 1957

  5 Ducketts Wharf, South Street, Bishops Stortford, Herts, CM23 3AR

• Oliver James PLUNKETT

  Total number of appointments 1 - Born September 1994

  22 Bolingbroke Road, Norwich, England, NR3 2SJ

• Derek Oliver PLUNKETT

  Total number of appointments 1 - Born July 1975

  Inspec House, Wellheads Drive, Dyce, Aberdeen, United Kingdom, AB21 7GQ

• William Oliver James PLUNKETT

  Total number of appointments 1 - Born February 1978

  40 Shelley Drive, Broadbridge Heath, Horsham, West Sussex, England, RH12 3NT

• Oliver James PLUNKETT

  Total number of appointments 1 - Born September 1957

  13-17 Devonshire Road, Morecambe, Lancashire, United Kingdom, LA3 1QT

• Oliver James PLUNKETT

  Total number of appointments 2 - Born August 1986

  Flat 2, 144 Worple Road, London, England, SW20 8QA

• Oliver Charles PLUNKETT

  Total number of appointments 1 - Born October 1972

  7 Castle Hill, Baslow Road, Bakewell, Derbyshire, Uk, DE45 1AA

• Oliver Plunkett CROMIE

  Total number of appointments 0 - Born December 1974

  29 O'Reilly Park, Killeen, Newry, Northern Ireland, BT35 8RP

The name Oliver Plunkett occurs frequently, this is a statistical anomaly. The instances are copied below and require testing to identify related parties.

Oliver PLUNKETT identity 1

• Total number of appointments 10 - Born April 1972

  Cedarwood, Penshurst Road, Speldhurst, Tunbridge Wells, England, TN3 0PQ

Total number of appointments 10

Current appointments 4 (in bold)

Date of birth April 1972

THE ONLINE SPORTS STORE LIMITED (15699900) Company status Active Correspondence address Cedarwood, Penshurst Road, Speldhurst, Tunbridge Wells, England, TN3 0PQ Role Active Director Appointed on 3 July 2024 Nationality British Country of residence England Occupation Company Director

THE CRICKET STORE LTD (12774526) Company status Liquidation Correspondence address 57 Jordan Street, Liverpool, England, L1 0BW Role Active Director Appointed on 3 November 2023 Nationality British Country of residence England Occupation Director Accounts overdue

WILLOSTIX CRICKET ACADEMY LLP (OC444116) Company status Dissolved Correspondence address Cedarwood, Penshurst Road, Speldhurst, Tunbridge Wells, England, TN3 0PQ Role LLP Designated Member Appointed on 3 October 2022 Country of residence England No accounts submitted

THE WILLO BRANDS COMPANY LTD. (13461224) Company status Dissolved Correspondence address Cedarwood, Penshurst Road, Speldhurst, Tunbridge Wells, England, TN3 0PQ Role Director Appointed on 17 June 2021 Nationality British Country of residence England Occupation Director Nature of business (SIC) 47640 - Retail sale of sports goods, fishing gear, camping goods, boats and bicycles Final accounts not submitted

OCEAN INFINITY INNOVATIONS LIMITED (13163626) Company status Active Correspondence address Unit 1, Keel Road, Woolston, Southampton, Hampshire, England, SO19 9UY Role Active Director Appointed on 28 January 2021 Nationality British Country of residence England Occupation Company director Nature of business (SIC) 62090 - Other information technology service activities

APSLEY HOUSE HOLDINGS LIMITED (12079821) Company status Active Correspondence address 17 Grosvenor Street, London, London, England, W1K 4QG Role Active Director Appointed on 21 August 2019 Nationality British Country of residence England Occupation Company Director Nature of business (SIC) 41100 - Development of building projects

OCEAN INFINITY SERVICES LIMITED (15195699) Company status Active Correspondence address 17 Grosvenor Street, London, United Kingdom, W1K 4QG Role Resigned Director Appointed on 9 October 2023 Resigned on 7 August 2024 Nationality British Country of residence England Occupation Company Director Nature of business (SIC) 71122 - Engineering related scientific and technical consulting activities Previous company names OIAGG LTD 09 Oct 2023 - 28 Feb 2024

AMBREY INTERNATIONAL LIMITED (10095821) Company status Active Correspondence address Thorn Business Centre, Rotherwas, Hereford, United Kingdom, HR2 6JT Role Resigned Director Appointed on 7 June 2021 Resigned on 2 February 2022 Nationality British Country of residence England Occupation Company Director Nature of business (SIC) 62012 - Business and domestic software development 71121 - Engineering design activities for industrial process and production 80100 - Private security activities

BACHAWY LIMITED (09782543) Company status Active Correspondence address Thorn Business Centre, Rotherwas, Hereford, United Kingdom, HR2 6JT Role Resigned Director Appointed on 7 June 2021 Resigned on 2 February 2022 Nationality British Country of residence England Occupation Company Director Nature of business (SIC) 80100 - Private security activities

AMBREY OFFSHORE LIMITED (08592553) Company status Active Correspondence address Thorn Business Centre, Rotherwas, Hereford, United Kingdom, HR2 6JT Role Resigned Director Appointed on 7 June 2021 Resigned on 2 February 2022 Nationality British Country of residence England Occupation Company Director Nature of business (SIC) 80200 - Security systems service activities

Oliver PLUNKETT identity 2

• Total number of appointments 0 - Born April 1972

  6 First Floor, Grosvenor Street, London, United Kingdom, W1K 4PZ

Total number of appointments 1

Date of birth April 1972

MEDITERRANEAN SEABED SURVEYS LIMITED (11717924) Company status Dissolved Correspondence address 6 First Floor, Grosvenor Street, London, United Kingdom, W1K 4PZ Role Director Appointed on 7 December 2018 Nationality British Country of residence United States Occupation Company Director Breach: No accounts presented Nature of business (SIC) 63110 - Data processing, hosting and related activities 63990 - Other information service activities not elsewhere classified

Oliver PLUNKETT identity 3

• Total number of appointments 1

  First Floor, 6 Grosvenor Street, London, United Kingdom, W1K 4PZ

Total number of appointments 1

OCEAN INFINITY GROUP LIMITED (FC035804) Company status Active Correspondence address First Floor, 6 Grosvenor Street, London, United Kingdom, W1K 4PZ Role Active Secretary Appointed on 14 December 2018 Last accounts made up to 31 December 2018 Breach: Accounts overdue Incorporated in CAYMAN ISLANDS Registration number 308429 Legal form Limited Company Parent registry Registrer Of Companies Governing law Cayman Islands Objects of the company Unrestricted

Oliver PLUNKETT identity 4

• Total number of appointments 1

  234 Pall Mall, London, England, SW1Y 5EA

Total number of appointments 1

COMMONWEALTH & UK ORGANISATION FOR SPECIAL INVESTIGATIONS LTD (10359588) Company status Active Correspondence address 234 Pall Mall, London, England, SW1Y 5EA Role Active Secretary Appointed on 5 May 202 Registered office address Cnr, Sandy Lane, Northwood, England, HA6 3HP Company status Active Company type Private limited Company Incorporated on 5 September 2016 Accounts Up to date Nature of business (SIC) 80300 - Investigation activities 84110 - General public administration activities 99000 - Activities of extraterritorial organisations and bodies

Previous company names

COMMONWEALTH & UK ORGANISATION FOR MEDICAL INVESTIGATIONS, CRIMINOLOGY & FORENSIC PSYCHIATRY - OFFENDER PROFILING, KIDNAPPINGS & MISSING PERSONS LTD

Oliver PLUNKETT identity 5

• Total number of appointments 1 - Born April 1972

  17 Grosvenor Street, London, England, W1K 4QG

Total number of appointments 4

Current appointments 1

Date of birth April 1972

GEOWYND LTD (12842044) Company status Active Correspondence address 17 Grosvenor Street, London, England, W1K 4QG Role Active Director Appointed on 4 August 2021 Nationality British, Country of residence United Kingdom Occupation Director Nature of business (SIC) 71122 - Engineering related scientific and technical consulting activities

GEOTEQNICS LTD (12842015) Company status Dissolved Correspondence address 17 Grosvenor Street, London, England, W1K 4QG Role Director Appointed on 4 August 2021 Nationality British, Country of residence United Kingdom Occupation Director Accounts overdue Nature of business (SIC) 64209 - Activities of other holding companies not elsewhere classified

M-GEO LTD (12842075) Company status Dissolved Correspondence address 17 Grosvenor Street, London, England, W1K 4QG Role Director Appointed on 4 August 2021 Nationality British, Country of residence United Kingdom Occupation Director Accounts overdue Nature of business (SIC) 64209 - Activities of other holding companies not elsewhere classified

OXGEOTECH LTD (SC672319) Company status Dissolved Correspondence address Neo-Space, Riverside Drive, Aberdeen, AB11 7LH Role Director Appointed on 4 August 2021 Nationality British, Country of residence United Kingdom Occupation Director Accounts overdue Nature of business (SIC) 64209 - Activities of other holding companies not elsewhere classified

Oliver PLUNKETT identity 6

• Total number of appointments 1 - Born April 1972

  Merlin House, 4 Meteor Way, Lee-On-The-Solent, Hampshire, United Kingdom, PO139FU

Total number of appointments 1

Date of birth April 1972

ARMADA INTERNATIONAL LLC (FC037148) Company status Active Correspondence address Merlin House, 4 Meteor Way, Lee-On-The-Solent, Hampshire, United Kingdom, PO13 9FU Role Active Director Appointed on 5 March 2020 Nationality British Country of residence United Kingdom Occupation Director Incorporated in UNITED STATES Registration number 7709182 Legal form Private Limited Liability Company Parent registry Delaware Governing law Laws Of Delaware, Delaware Limited Liability Company Act Objects of the company Any and all lawful business

Oliver PLUNKETT identity 7

• Total number of appointments 2 - Born April 1972

  Cedarwood, Penshurst Road, Speldhurst, Tunbridge Wells, England, TN3 0PQ

Total number of appointments 3

Date of birth April 1972

SPELDHURST SERVICES LIMITED (10511843) Company status Active Correspondence address Cedarwood, Penshurst Road, Speldhurst, Tunbridge Wells, England, TN3 0PQ Role Active Director Appointed on 6 December 2016 Nationality British Country of residence England Occupation Tax Adviser Nature of business (SIC) 70229 - Management consultancy activities other than financial management

SPELDHURST CORPORATE SERVICES LIMITED (10500501) Company status Dissolved Correspondence address The Haven, Barden Road, Speldhurst, Tunbridge Wells, United Kingdom, TN3 0QH Role Director Appointed on 28 November 2016 Nationality British Country of residence England Occupation Accountant Nature of business (SIC) 69203 - Tax consultancy 70100 - Activities of head offices No accounts submitted

ALLIANCE FOR RESPONSIBLE CITIZENSHIP LIMITED (10519995) Company status Active Correspondence address 20 Eastbourne Terrace, London, England, W2 6LG Role Resigned Director Appointed on 19 January 2017 Resigned on 19 January 2018 Nationality British Country of residence England Occupation Company Director Nature of business (SIC) 85520 - Cultural education Previous company names PROSPERITY UK 2017 LIMITED12 Dec 2016 - 20 Jan 2023

Oliver PLUNKETT identity 8

• Total number of appointments 1

  C/O WPO LIMITED, FIRST FLOOR, 6 Grosvenor Street, London, United Kingdom, W1K 4PZ

Total number of appointments 1

ALLIANCE FOR RESPONSIBLE CITIZENSHIP LIMITED (10519995) Company status Active Correspondence address C/o Wpo Limited, First Floor, 6 Grosvenor Street, London, United Kingdom, W1K 4PZ Role Resigned Secretary Appointed on 15 January 2017 Resigned on 19 January 2017

Oliver Plunkett born April 1972 has registered eight identities in Companies House in breach of Section 1082 of the Companies Act. He has compromised all audits and KYC checks associated to him. He has breached Anti-Money Laundering and Counter-terrorism Financing and puts the public at risk that he is committing serious organised crime.

Other instances of “Oliver Plunkett”. Query whether related parties?

Oliver PLUNKETT identity 9?

• Total number of appointments 1 - Born June 1972

  Hub Kings Cross, York Way, London, England, N1 9AB

Total number of appointments 1 Date of birth June 1972

REMEDY PARTNERSHIP CIC (07903620) Company status Dissolved Correspondence address Hub Kings Cross, York Way, London, England, N1 9AB Role Resigned Director Appointed on 2 April 2013 Resigned on 1 July 2015 Nationality British Country of residence England Occupation Director Accounts overdue Nature of business (SIC) 84110 - General public administration activities

Oliver Charles Pelham PLUNKETT identity a1

• Total number of appointments 2 - Born October 1972

  Camden Mill, Lower Bristol Road, Bath, BA2 3DQ

Total number of appointments 2

Date of birth October 1972

BURO HAPPOLD CONSULTING ENGINEERS LIMITED (02005673) Company status Active Correspondence address Camden Mill, Lower Bristol Road, Bath, BA2 3DQ Role Active Director Appointed on 15 December 2011 Nationality Irish Country of residence Saudi Arabia Occupation Consulting Engineer Nature of business (SIC) 71129 - Other engineering activities Previous company name RAPID 1125 LIMITED 02 Apr 1986 - 16 Jun 1986

HAPPOLD LLP (OC331879) Company status Active Correspondence address Camden Mill, Lower Bristol Road, Bath, Somerset, BA2 3DQ Role Active LLP Designated Member Appointed on 1 May 2011 Country of residence Ireland

Oliver Charles Pelham PLUNKETT identity a2?

• Total number of appointments 1 - Born October 1972

  Camden Mill, Lower Bristol Road, Bath, BA2 3DQ

Total number of appointments 1

Date of birth October 1972

BURO HAPPOLD ENGINEERS LIMITED (02005893) Company status Active Correspondence address Camden Mill, Lower Bristol Road, Bath, BA2 3DQ Role Active Director Appointed on 9 August 2021 Nationality Irish Country of residence Ireland Occupation Consulting Engineer

Oliver Charles PLUNKETT identity a3?

• Total number of appointments 1 - Born October 1972

  7 Castle Hill, Baslow Road, Bakewell, Derbyshire, Uk, DE45 1AA

Total number of appointments 1

Date of birth October 1972

BDP ENGINEERING LIMITED (02152385) Company status Active Correspondence address 7 Castle Hill, Baslow Road, Bakewell, Derbyshire, Uk, DE45 1AA Role Resigned Director Appointed on 1 February 2007 Resigned on 13 November 2009 Nationality British Occupation Chartered Engineer Nature of business (SIC) 99999 - Dormant Company Previous company names UPPERSNIPE LIMITED 03 Aug 1987 - 25 Nov 1987

Breach: Oliver Charles Pelham Plunkett, born October 1972 has registered three identities in Companies House in breach of section 1082 (CA2006). Query whether he is a related party of Oliver Plunkett born June 1972.

Oliver James PLUNKETT identity b1

• Total number of appointments 0 - Born September 1957

  5 Ducketts Wharf, South Street, Bishops Stortford, Herts, CM23 3AR

Total number of appointments 2

Date of birth September 1957

SOUNDS GOOD TO ME LIMITED (06381348) Company status Dissolved Correspondence address 5 Ducketts Wharf, South Street, Bishops Stortford, Herts, CM23 3AR Role Director Appointed on 6 April 2011 Nationality British Country of residence United Kingdom Occupation Director Nature of business (SIC) 62020 - Information technology consultancy activities Accounts overdue

MEDIAS3 LIMITED (07575254) Company status Dissolved Correspondence address Saville Gate Barn, Sandy Gate, Scholes, Holmfirth, United Kingdom, HD9 1SS Role Director Appointed on 23 March 2011 Nationality British Country of residence United Kingdom Occupation Systems Designer Nature of business (SIC) 62020 - Information technology consultancy activities Accounts overdue

Oliver James PLUNKETT identity b2

• Total number of appointments 1 - Born September 1957

  13-17 Devonshire Road, Morecambe, Lancashire, United Kingdom, LA3 1QT

Total number of appointments 1

Date of birth September 1957

MORE MUSIC IN MORECAMBE (04189582) Company status Active Correspondence address 13-17, Devonshire Road, Morecambe, Lancashire, United Kingdom, LA3 1QT Role Resigned Director Appointed on 22 May 2001 Resigned on 16 September 2013 Nationality British Country of residence United Kingdom Occupation Computer Consultant Nature of business (SIC) 90030 - Artistic creation

Oliver James PLUNKETT identity c

• Total number of appointments 2 - Born August 1986

  Flat 2, 144 Worple Road, London, England, SW20 8QA

Total number of appointments 3

Date of birth August 1986

ECLIPSEYACHTING LIMITED (08317865) Company status Dissolved Correspondence address Flat 2, 144 Worple Road, London, England, SW20 8QA Role Director Appointed on 4 December 2012 Nationality Australian Country of residence United Kingdom Occupation Yacht Engineer Accounts overdue Nature of business (SIC) 79120 - Tour operator activities

ENDLESS SUMMER EVENTS LIMITED (08279490) Company status Active Correspondence address 51 Wetherby Mansions, Earl's Court Square, London, England, SW5 9BH Role Resigned Director Appointed on 1 February 2013 Resigned on 14 November 2023 Nationality Australian Country of residence United Kingdom Occupation Company Director

ENDLESS SUMMER EVENTS LIMITED (08279490) Company status Active Correspondence address 52e, Lavender Hill, London, United Kingdom, SW11 5RH Role Resigned Director Appointed on 2 November 2012 Resigned on 28 November 2012 Nationality Australian Country of residence United Kingdom Occupation Director

Oliver James PLUNKETT identity d

• Total number of appointments 1 - Born September 1994

  22 Bolingbroke Road, Norwich, England, NR3 2SJ

Total number of appointments 1

Date of birth September 1994

OLIVER JAMES WINDOWS & CONSERVATORIES LTD (15447948) Company status Dissolved Correspondence address 22 Bolingbroke Road, Norwich, England, NR3 2SJ Role Director Appointed on 27 January 2024 Nationality English Country of residence England Occupation Glazier Nature of business (SIC) 43290 - Other construction installation 43342 - Glazing 95290 - Repair of personal and household goods not elsewhere classified Accounts not submitted

Oliver PLUNKETT identity e

• Total number of appointments 1 - Born December 1994

  Oakmoore Court, Kingswood Road, Hampton Lovett, Droitwich, Worcestershire, United Kingdom, WR9 0QH

  Total number of appointments 1

  Date of birth December 1994

  PLUNKETT HEALTH LTD (15297706) Company status Active Correspondence address Oakmoore Court, Kingswood Road, Hampton Lovett, Droitwich, Worcestershire, United Kingdom, WR9 0QH Role Active Director Appointed on 21 November 2023 Nationality British Country of residence United Kingdom Occupation Chiropractor Nature of business (SIC)

  • 86220 - Specialists medical practice activities

Derek Oliver PLUNKETT identity f

• Total number of appointments 1 - Born July 1975

  Inspec House, Wellheads Drive, Dyce, Aberdeen, United Kingdom, AB21 7GQ

Total number of appointments 1

Date of birth July 1975

NEWTON HEALTHCARE RECRUITMENT LTD (SC728285) Company status Active Correspondence address Inspec House, Wellheads Drive, Dyce, Aberdeen, United Kingdom, AB21 7GQ Role Active Director Appointed on 19 May 2023 Nationality British Country of residence United Kingdom Occupation Managing Director Nature of business (SIC)

• 82990 - Other business support service activities not elsewhere classified

Previous company names SLLP 358 LIMITED 01 Apr 2022 - 13 May 2022

William Oliver James PLUNKETT identity g

• Total number of appointments 1 - Born February 1978

  15 Platts Meadow, Billingshurst, West Sussex, England, RH14 9HX

Total number of appointments 1

Date of birth February 1978

WP SPORTHORSES LTD (12525997) Company status Active Correspondence address 40 Shelley Drive, Broadbridge Heath, Horsham, West Sussex, England, RH12 3NT Role Active Director Appointed on 19 March 2020 Nationality British Country of residence England Occupation Director Nature of business (SIC) 01430 - Raising of horses and other equines

Oliver Plunkett CROMIE identity h

• Total number of appointments 0 - Born December 1974

  29 O'Reilly Park, Killeen, Newry, Northern Ireland, BT35 8RP

Total number of appointments 1

Date of birth December 1974

THECANDYSTOREIRELAND LTD (NI673777) Company status Dissolved Correspondence address 29 O'Reilly Park, Killeen, Newry, Northern Ireland, BT35 8RP Role Director Appointed on 28 October 2020 Nationality Northern Irish Country of residence Northern Ireland Occupation Retailer Nature of business (SIC) 47990 - Other retail sale not in stores, stalls or markets No accounts submitted

Oliver Plunkett DEVLIN identity i

• Total number of appointments 0 - Born August 1965

  12 Townholm Crescent, Hanwell, London, United Kingdom, W7 3NA

Total number of appointments 1

Date of birth August 1965

AIRDOX LIMITED (07526214) Company status Dissolved Correspondence address 12 Townholm Crescent, Hanwell, London, United Kingdom, W7 3NA Role Director Appointed on 11 February 2011 Nationality British Country of residence United Kingdom Occupation Sales & Marketing Director Nature of business (SIC) 53100 - Postal activities under universal service obligation No accounts submitted

Oliver Plunkett MCKERNAN identity j

• Total number of appointments 1 - Born October 1975

  15b, Molesworth Street, Cookstown, Northern Ireland, BT80 8NX

Total number of appointments 2

Date of birth October 1975

AAA BIOMASS SERVICES LTD (NI654842) Company status Active Correspondence address 15b, Molesworth Street, Cookstown, Northern Ireland, BT80 8NX Role Active Director Appointed on 7 August 2018 Nationality Irish Country of residence Northern Ireland Occupation Managing Director Nature of business (SIC) 43220 - Plumbing, heat and air-conditioning installation Previous company names AAA BIOMUSS SERVICES LTD 07 Aug 2018 - 22 Oct 2018

MCKERNAN SERVICES BIOMASS (N.I.) LTD (NI639496) Company status Dissolved Correspondence address 3 Farburn Road, Omagh, Northern Ireland, BT79 7UD Role Director Appointed on 4 July 2016 Nationality Irish Country of residence Northern Ireland Occupation Director Nature of business (SIC) 43220 - Plumbing, heat and air-conditioning installation No accounts submitted

Oliver Plunkett Polycarp FINN identity k

• Total number of appointments 1

  80 Tatum Street, Walworth, London, United Kingdom, SE17 1QR

Total number of appointments 1

PEMBROKE COLLEGE SETTLEMENT (10586362) Company status Active Correspondence address 80 Tatum Street, Walworth, London, United Kingdom, SE17 1QR Role Resigned Secretary Appointed on 23 November 2021 Resigned on 16 June 2023 Nature of business (SIC) 85590 - Other education not elsewhere classified 94910 - Activities of religious organisations

Oliver Plunkett CAVANAGH identity l

• Total number of appointments 1 - Born August 1970

  Unit 16 Clacton Enterprise Centre, 1-2 Davy Road, Gorse Lane Industrial Estate, Clacton-On-Sea, Essex, England, CO15 4XD

Total number of appointments 1

Date of birth August 1970

NKK FINANCE LTD (08479948) Company status Active Correspondence address Unit 16, Clacton Enterprise Centre, 1-2 Davy Road, Gorse Lane Industrial Estate, Clacton-On-Sea, Essex, England, CO15 4XD Role Resigned Director Appointed on 1 October 2014 Resigned on 18 August 2019 Nationality British Country of residence United Kingdom Occupation Company Director Nature of business (SIC) 64921 - Credit granting by non-deposit taking finance houses and other specialist consumer credit grantors

• SQUIRE PATTON BOGGS SECRETARIAL SERVICES LIMITED Role Active Secretary Appointed on 28 January 2022 Current appointments 116 Total appointments 434

Oliver Plunkett WARD identity m

• Total number of appointments 1 - Born July 1947

  Northlands, Shepherds Way, Dungiven Road, Derry, Northern Ireland, BT47 5GW

Total number of appointments 1

Date of birth July 1947

NORTHLANDS (NI027690) Company status Active Correspondence address Northlands, Shepherds Way, Dungiven Road, Derry, Northern Ireland, BT47 5GW Role Resigned Director Appointed on 6 May 2004 Resigned on 26 November 2014 Nationality Irish Occupation Civil Servant Nature of business (SIC) 82990 - Other business support service activities not elsewhere classified

Timothy Oliver Plunkett O'MULLANE identity n

• Total number of appointments 1 - Born April 1946

  8 Hallwood Close, Runcorn, Cheshire, WA7 4AX

Total number of appointments 1

Date of birth April 1946

OMULLANE CIVIL ENGINEERING LIMITED (04021256) Company status Liquidation Correspondence address 8 Hallwood Close, Runcorn, Cheshire, WA7 4AX Role Resigned Director Appointed on 27 November 2001 Resigned on 9 January 2019 Nationality Irish Country of residence United Kingdom Occupation Director Accounts overdue since 31 March 2023 Nature of business (SIC) 42990 - Construction of other civil engineering projects not elsewhere classified

PLUNKETT FOUNDATION identity o

• Total number of appointments 1

  Unit 2, The Quadrangle, Banbury Road, Woodstock, Oxfordshire, OX20 1LH

Total number of appointments 1

PLUNKETT FOUNDATION (00213235) Company status Active Correspondence address Unit 2,, (sic) The Quadrangle, Banbury Road, Woodstock, Oxfordshire, OX20 1LH Role Resigned Director Appointed on 9 September 2009 Resigned on 1 October 2009 Incorporated on 16 April 1926 Nature of business (SIC) 70100 - Activities of head offices Previous company names PLUNKETT FOUNDATION FOR CO-OPERATIVE STUDIES.(THE) 16 Apr 1926 - 14 Sep 1993

Oliver David PLUNKETT identity p

• Total number of appointments 1

  22 Lennox Gardens, London, SW1X 0DQ

Total number of appointments 1

LENNOX GARDENS (MANAGEMENT) LIMITED (01517297) Company status Active Correspondence address 22 Lennox Gardens, London, SW1X 0DQ Role Resigned Secretary Appointed before 31 December 1991 Resigned on 30 November 1999 Nationality British Nature of business (SIC) 98000 - Residents property management

Otway Jeremy Oliver PLUNKETT identity q

• Total number of appointments 1 - Born October 1954

  9 Becondale Road, London, SE19 1QJ

Total number of appointments 1

Date of birth October 1954

ALLIANCE AUTOMOTIVE UK REFINISH LIMITED (02959345) Company status Dissolved Correspondence address 9 Becondale Road, London, SE19 1QJ Role Resigned Director Appointed on 1 May 1996 Resigned on 31 October 2000 Nationality British Occupation Director Nature of business (SIC) 45310 - Wholesale trade of motor vehicle parts and accessories Previous company names AUTOMOTIVE TRADE SUPPLIES LIMITED 16 Aug 1994 - 20 Jun 2008 Accounts overdue

Concluding Remarks:

The examination of Oliver Plunkett's multiple identities and associated directorships reveals a potential for fraudulent activities such as money laundering. This highlights the necessity for thorough investigations into the companies and their directors to mitigate risks of fraud, money laundering, people trafficking, and terrorism financing. Each of these companies and their directors requires scrutiny to ensure compliance and prevent fraudulent activities.

Summary of Non-Compliance Findings and Risks

Non-Compliance Findings:

The analysis of directors associated with Alliance For Responsible Citizenship Limited reveals multiple instances of potential non-compliance and risk. Notably, The Rt Hon. The Lord Jonathan Hopkin Hill, a prominent director, has been linked to several companies, including Ditchley Foundation and Teach First. The recurrent appearance of this individual, with varying roles and dates of birth, indicates a pattern of non-compliance and potential misuse of directorial responsibilities. His affiliations across multiple organizations raise concerns about conflicts of interest and inadequate oversight.

Moreover, discrepancies in appointment records and overlapping directorships across multiple entities signal a lack of transparency and possible regulatory evasion. For instance, the same address and birthdate are associated with multiple individuals named Oliver Plunkett, suggesting the use of multiple identities for various directorships. This raises significant questions about the authenticity of these identities and the legitimacy of their associated companies.

Active Directors:

Paul Roderick Clucas Marshall and Alan James McCormick are the current active directors of Alliance For Responsible Citizenship Limited. An examination of their directorial histories reveals a complex network of companies and multiple identities, raising concerns about potential regulatory evasion and lack of transparency.

Risks Identified:

1. Fraud and Money Laundering: The overlapping identities and addresses linked to multiple directors suggest potential fraudulent activities, including money laundering. By manipulating directorships and using different aliases, individuals could be facilitating the movement of illicit funds between entities, evading regulatory scrutiny.

2. Conflict of Interest and Regulatory Evasion: The presence of directors with multiple roles and affiliations in different organizations could lead to conflicts of interest. This scenario undermines the integrity of corporate governance and increases the risk of regulatory evasion, where directors might exploit their positions for personal gain or to cover up illicit activities.

3. Inadequate Oversight: The findings indicate that existing regulatory frameworks might be insufficient to detect and address such anomalies effectively. This lack of oversight could enable directors to operate with minimal accountability, potentially engaging in unethical or illegal practices without facing repercussions.

In summary, the findings highlight a need for enhanced regulatory scrutiny and verification processes to address potential non-compliance and mitigate risks associated with fraudulent activities, conflicts of interest, and insufficient oversight in directorial roles.

Because of time constraints this analysis will only scratch the surface of the linked directorate associated to these individuals. Further analysis of all the co-directors, their company associations and those held in “other” identities is required. This corporate ecosystem raises red flags for potentially operating as a cartel, with monopolistic control of the United Kingdom.

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Recommendations for Regulatory Authorities and Policymakers

1. Establish a Decentralised Identity Verification System: Instead of a centralised system, which could be vulnerable to misuse or capture by bad actors, implement a decentralised identity verification system. This system would rely on a network of independent entities that can cross-verify the identities of directors and officers across all companies. Each entity would have limited power, reducing the risk of corruption or manipulation, and the system would ensure a higher degree of security and trustworthiness.

2. Enhance Deduplication and Public Record Tracking: Companies House must take proactive steps to deduplicate evident duplicate identities within its database. This process should be complemented by implementing a public record tracking system for individuals whose identities have been deduplicated. By maintaining a transparent record, regulatory authorities can track patterns and gather evidence that could be crucial in identifying and prosecuting fraudulent activities. This tracking system would serve as a deterrent to those attempting to exploit the system by using multiple identities.

3. Update International Standards for Auditing (ISA): The International Standards for Auditing should be updated to include mandatory procedures for testing for multiple identities and clone companies during the audit process. Before auditors sign off on a company's financial statements, they should be required to verify that there are no discrepancies in the identities of directors or potential clone companies linked to the audited entity. This would help in preventing financial statement manipulation and ensure the integrity of the audit process.

4. Increase Penalties for Non-Compliance: Implement severe penalties for directors and companies that fail to comply with regulatory requirements, particularly in the areas of financial reporting, identity verification, and conflict of interest disclosures. These penalties should include significant fines, disqualification from holding directorship positions, and potential criminal charges for severe offenses. A stronger enforcement regime will serve as a deterrent to fraudulent activities and reinforce the importance of adhering to regulatory standards.

5. Strengthen Corporate Governance Standards: Develop and enforce higher standards of corporate governance, particularly for companies with directors involved in multiple entities. This could include mandatory training and certification for directors on ethical business practices, as well as requirements for independent oversight of company activities. Enhanced governance standards would reduce the likelihood of conflicts of interest, insider trading, and other forms of misconduct.

6. Promote Transparency through Public Reporting: Encourage transparency by requiring detailed public reporting of directorships, including potential conflicts of interest, beneficial ownership, and any financial relationships between companies. Public disclosure will allow stakeholders, including investors and regulators, to scrutinize the activities of directors more effectively and identify potential red flags.

7. Enhance International Collaboration: Work with international regulatory bodies to track cross-border financial activities and ensure that directors cannot evade scrutiny by operating across multiple jurisdictions. Collaborative efforts should include sharing information on suspicious activities, harmonizing regulations to close loopholes, and coordinating enforcement actions against transnational fraud schemes.

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Conclusion

By adopting these recommendations, regulatory authorities and policymakers can create a more resilient framework for preventing and detecting fraud in corporate governance. The introduction of a decentralized identity verification system, coupled with enhanced deduplication processes and updated auditing standards, will significantly reduce the risk of exploitation by bad actors. These measures, along with increased penalties for non-compliance and greater transparency, will help safeguard the integrity of the corporate sector and protect the public from fraudulent activities.

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ARC Research

This Alliance for Responsible Citizenship Limited, also known as “ARC”, website provides a link to ARC Research (https://www.arcforum.com/) at the bottom of each webpage. Clicking the link, locates: ARC Research https://www.arc-research.org/. The following legal information is located at the bottom of the page:

Company Number: 14739317

ARC Research

78 Pall Mall, London, SW1Y 5ES

The record was located in Companies House with a search Arc Research - Find. The company overview and officer information is copied below (https://find-and-update.company-information.service.gov.uk/company/14739317).

ARC RESEARCH Company number 14739317 Registered office address 78 Pall Mall, London, United Kingdom, SW1Y 5ES Company status Active

Company type Private Limited Company by guarantee without share capital use of 'Limited' exemption

Incorporated on 17 March 2023

Accounts (up to date) First accounts made up to 31 December 2023 due by 30 September 2024 Confirmation statement Next statement date 16 March 2025 due by 30 March 2025 Last statement dated 16 March 2024

Nature of business (SIC) 85590 - Other education not elsewhere classified

5 officers / 2 resignations

BIGGAR, Nigel John, Professor Correspondence address 78 Pall Mall, London, United Kingdom, SW1Y 5ES Role Active Director Date of birth March 1955 Appointed on 16 October 2023 Nationality British Country of residence United Kingdom Occupation Director

HAWKINS, James Bruce Correspondence address 78 Pall Mall, London, United Kingdom, SW1Y 5ES Role Active Director Date of birth December 1965 Appointed on 26 March 2024 Nationality British Country of residence England Occupation Education Leader

JACKSON, Jennifer Jane Correspondence address 78 Pall Mall, London, United Kingdom, SW1Y 5ES Role Active Director Date of birth January 1977 Appointed on 16 October 2023 Nationality British Country of residence United Kingdom Occupation Senior Adviser, Oxford Investment Consultants

BRIANCE, Richard Henry Correspondence address 11 Charles Street, London, England, W1J 5DW Role Resigned Director Date of birth August 1953 Appointed on 31 March 2023 Resigned on 16 October 2023 Nationality British Country of residence England Occupation Merchant Banker

TYLECOTE, Radomir Thomas Correspondence address 78 Pall Mall, London, United Kingdom, SW1Y 5ES Role Resigned Director Date of birth March 1982 Appointed on 17 March 2023 Resigned on 14 May 2024 Nationality British Country of residence England Occupation Academic

ARC RESEARCH persons with significant control

1 active person with significant control / 0 active statements

Alliance For Responsible Citizenship Limited Active Correspondence address 78 Pall Mall, London, England, SW1Y 5ES Notified on 17 March 2023 Governing law United Kingdom Legal form Incorporated Place registered United Kingdom Registration number 10519995 Incorporated in United Kingdom Nature of control Ownership of voting rights - 75% or more Right to appoint or remove directors

The person with significant control of ARC Research is given as Alliance For Responsible Citizenship Limited.

The accounts for Alliance for Responsible Citizenship Limited are located in the filing history for this company, ALLIANCE FOR RESPONSIBLE CITIZENSHIP LIMITED filing history (https://find-and-update.company-information.service.gov.uk/company/10519995/filing-history).

Breach: The Alliance for Responsible Citizenship Limited’s most recent accounts “Total exemption full accounts made up to 31 December 2023”, fail to declare that ARC Research is a related party. This is a breach of section 441 of the Companies Act 2006.

Search for other potential related parties including the name “ARC”.

A search on ARC in Companies House locates over 33,000 records (ARC - Find https://find-and-update.company-information.service.gov.uk/search/companies?q=ARC). These records are too numerous to assess. However, the potential for clone company fraud between similarly named companies is high, given the total number of companies that contain the name “Arc”.

ARC Limited, however is a name that has been registered twice. It is associated with the following two records:

• ARC LIMITED

  00562240 - Incorporated on 5 March 1956

  Second Floor, Arena Court, Crown Lane, Maidenhead, Berkshire, England, SL6 8QZ

• HANSON QUARRY PRODUCTS EUROPE LIMITED

  Matching previous names:
  ARC LIMITED

  00300002 - Incorporated on 23 April 1935

  Second Floor, Arena Court, Crown Lane, Maidenhead, Berkshire, England, SL6 8QZ

Arc Limited is the name used by two companies called ARC Limited at the same registered address “Second Floor, Arena Court, Crown Lane, Maidenhead, Berkshire, England, SL6 8QZ”: ARC LIMITED company number 00562240 incorporated on 5 March 1956 and HANSON QUARRY PRODUCTS EUROPE LIMITED, previous names: ARC LIMITED 00300002, incorporated on 23 April 1935. This is a breach of section 66 of the Companies Act 2006.

A search on the registered address of Arc Limited returns 13 results (Search results - (https://find-and-update.company-information.service.gov.uk/advanced-search/get-results?companyNameIncludes=arc&companyNameExcludes=&registeredOfficeAddress=Second+Floor%2C+Arena+Court%2C+Crown+Lane%2C+Maidenhead%2C+Berkshire%2C+England%2C+SL6+8QZ&incorporationFromDay=&incorporationFromMonth=&incorporationFromYear=&incorporationToDay=&incorporationToMonth=&incorporationToYear=&sicCodes=&dissolvedFromDay=&dissolvedFromMonth=&dissolvedFromYear=&dissolvedToDay=&dissolvedToMonth=&dissolvedToYear=)

1. ARC HOLDINGS LIMITED

   Active Private limited company

   00207008 - Incorporated on 2 July 1925

   Second Floor, Arena Court, Crown Lane, Maidenhead, Berkshire, England SL6 8QZ

   SIC codes - 70100

2. ARC LIMITED

   Active

   Private limited company

   00562240 - Incorporated on 5 March 1956

   Second Floor, Arena Court, Crown Lane, Maidenhead, Berkshire, England SL6 8QZ

   SIC codes - 70100

3. ARC SOUTH WALES MORTAR LIMITED

   Active

   Private limited company

   0307291 - Incorporated on 21 November 1935

   Second Floor, Arena Court, Crown Lane, Maidenhead, Berkshire, England SL6 8QZ

   SIC codes - 70100

4. ARC SOUTH WALES LIMITED

   Active

   Private limited company

   01074166 - Incorporated on 28 September 1972

   Second Floor, Arena Court, Crown Lane, Maidenhead, Berkshire, England SL6 8QZ

   SIC codes - 70100

5. ARC AGGREGATES LIMITED

   Active

   Private limited company

   00565683 - Incorporated on 4 May 1956

   Second Floor, Arena Court, Crown Lane, Maidenhead, Berkshire, England SL6 8QZ

   SIC codes - 70100

6. ARC LAND HOLDINGS LIMITED

   Active

   Private limited company

   00555214 - Incorporated on 28 September 1955

   Second Floor, Arena Court, Crown Lane, Maidenhead, Berkshire, England SL6 8QZ

   SIC codes - 70100

7. ARC SOUTH WALES QUARRIES LIMITED

   Active

   Private limited company

   00755944 - Incorporated on 1 April 1963

   Second Floor, Arena Court, Crown Lane, Maidenhead, Berkshire, England SL6 8QZ

   SIC codes - 64209

8. ARC SOUTH WALES SURFACING LIMITED

   Active

   Private limited company

   00824951 - Incorporated on 28 October 1964

   Second Floor, Arena Court, Crown Lane, Maidenhead, Berkshire, England SL6 8QZ

   SIC codes - 70100

9. ARC CONCRETE LIMITED

   Active Private limited company

   00367135 - Incorporated on 14 May 1941

   Second Floor, Arena Court, Crown Lane, Maidenhead, Berkshire, England SL6 8QZ

   SIC codes - 70100

10. ARC PROPERTY INVESTMENTS LIMITED

    Active

    Private limited company

    00248751 - Incorporated on 13 January 1930

    Second Floor, Arena Court, Crown Lane, Maidenhead, Berkshire, England SL6 8QZ

    SIC codes - 70100

11. ARC SLIMLINE LIMITED

    Private limited company

    00167370 - Incorporated on 12 May 1920

    Second Floor, Arena Court, Crown Lane, Maidenhead, Berkshire, England SL6 8QZ

    SIC codes - 74990

12. ARC CONCRETE (ANGLIA) LIMITED

    Active

    Private limited company

    00931322 - Incorporated on 30 April 1968

    Second Floor, Arena Court, Crown Lane, Maidenhead, Berkshire, England SL6 8QZ

    SIC codes - 74990

13. ARC BUILDING LIMITED

    Active

    Private limited company

    00611966 - Incorporated on 29 September 1958

    Second Floor, Arena Court, Crown Lane, Maidenhead, Berkshire, England SL6 8QZ

    SIC codes - 74990

A search on the registered address of Alliance for Responsible Citizenship and ARC Research “78 Pall Mall, London, SW1Y 5ES” locates 117 companies (Search results - Advanced company search - GOV.UK). There are no other companies using the name ARC registered at this address.

Further analysis is required.

ARC’s business model

ARC associates closely with Jordan B Peterson, as evidenced by the invitation to the ARC Conference and the marketing, asking “how much would you spend on attending an evening with Jordan B Peterson and key ARC speakers?”

Jordan Peterson in Companies House

A search in Companies House on the name Jordan Peterson returns just one identity with this name, which is reproduced below and expanded upon, Jordan Peterson - Find and update company information - GOV.UK (https://find-and-update.company-information.service.gov.uk/search/officers?q=Jordan%20Peterson).

Jordan PETERSON

Total number of appointments 0 - Born September 1995

793 Commercial Road, London, England, E14 7HG

Total number of appointments 1

MY SUPPORTED LIVING SERVICES LTD (13724342) Company status Dissolved Correspondence address 793 Commercial Road, London, England, E14 7HG Role Director Appointed on 10 January 2023 Nationality British Country of residence England Occupation General Manager

Dissolved on 27 June 2023 Company type Private limited Company Incorporated on 4 November 2021 No accounts submitted s441: CA2006 breach Nature of business (SIC) 87200 - Residential care activities for learning difficulties, mental health and substance abuse

2 officers / 1 resignation

PETERSON, Jordan Correspondence address 793 Commercial Road, London, England, E14 7HG Role Director Date of birth September 1995 Appointed on 10 January 2023 Nationality British Country of residence England Occupation General Manager

ABDULBASIR, Mohammod Correspondence address 793 Commercial Road, London, England, E14 7HG Role Resigned Director Date of birth October 1988 Appointed on 4 November 2021 Resigned on 10 January 2023 Nationality British Country of residence England Occupation Company Director

Total number of appointments 13

• Current appointments 3

• RAINDROPS ACADEMY CIC (15887215) Company status Active Correspondence address Apartment 702 Markham Heights, 5 Crossharbour Plaza, London, England, E14 9XN Role Active Director Appointed on 9 August 2024 Nationality British Country of residence England Occupation Business Person Company type Private company limited by guarantee without share capital Community Interest Company (CIC) Incorporated on 9 August 2024 Accounts First accounts made up to 31 August 2025 due by 9 May 2026 Confirmation statement First statement date 8 August 2025 due by 22 August 2025 Nature of business (SIC) 85590 - Other education not elsewhere classified 90010 - Performing arts 90030 - Artistic creation 93199 - Other sports activities Sole director and person with significant control

• SMART MOVE FACILITIES LTD (13849597) Company status Active Correspondence address 2 Harbinger Road, London, England, E14 3AA Role Active Director Appointed on 14 January 2022 Nationality British Country of residence England Occupation Director Company type Private limited Company Incorporated on 14 January 2022 Accounts and Confirmation statement Up to date Nature of business (SIC) 68310 - Real estate agencies Sole director and person with significant control Accounts for a dormant company made up to 31 January 2023

• SMART MOVE SALES AND LETTINGS LTD (13413506) Company status Active Correspondence address 2 Harbinger Road, London, England, E14 3AA Role Active Director Appointed on 21 May 2021 Nationality British Country of residence England Occupation Company Director Company type Private limited Company Incorporated on 21 May 2021 Accounts and Confirmation statement Up to date Nature of business (SIC) 68310 - Real estate agencies Sole active director and person with significant control. One resigned director and secretary:

  • PRABHULLA CHANDRAN, Karthik Correspondence address 2 Harbinger Road, London, England, E14 3AA Role Resigned Director Date of birth August 2001 Appointed on 1 January 2023 Resigned on 20 March 2024 Nationality Indian Country of residence England Occupation Director

Tests for multiple identities for Mohammod Abdulbasir and Karthik Prabhulla Chandran:

Mohammod Abdulbasir

A search on the name “Mohammod Abdulbasir” returns the following identities, with this name, Mohammod Abdulbasir - Find and update company information - GOV.UK (https://find-and-update.company-information.service.gov.uk/search/officers?q=Mohammod+Abdulbasir+)

• Mohammod ABDULBASIR

  Total number of appointments 13 - Born October 1988

  Apartment 702 Markham Heights, 5 Crossharbour Plaza, London, England, E14 9XN

• Active: RAINDROPS ACADEMY CIC (15887215), SMART MOVE FACILITIES LTD (13849597),

• Dissolved: Three examples of ten.

  • OUR CARE SPACE LTD (14194084) Dissolved on 28 November 2023 Incorporated on 24 June 2022 No accounts submitted s411:CA2006 breach

  • IGNIRE TECHNOLOGY LTD (14121488) Dissolved on

    24 October 2023 Incorporated on 20 May 2022 No accounts submitted s411:CA2006 breach Nature of business (SIC) 62020 - Information technology consultancy activities

  • BNMR SERVICES LIMITED (13420166) Registered office address - Unit 17 58 Marsh Wall, London, United Kingdom, E14 9TP (sic) Dissolved on 25 October 2022 Company type Private limited Company Incorporated on 25 May 2021 Nature of business (SIC) 68310 - Real estate agencies 1 person with significant control / 0 statements Mr Rezaul Karim Majid Notified on 25 May 2021 Date of birth May 1982. A search for multiple identities locate four identities with the same name and date of birth, Rezaul Karim Majid - Find (https://find-and-update.company-information.service.gov.uk/search?q=Rezaul+Karim+Majid). In another of his 4 identities Rezaul KARIM MAJID holds 3 active appointments:

    • OCULUS PROPERTY LEASING LTD (16082578) Incorporated on 15 November 2024 Nature of business (SIC) 68209 - Other letting and operating of own or leased real estate

    • KEYHOLDER ESTATES LIMITED (16001303) Incorporated on 7 October 2024 Nature of business (SIC) 68310 - Real estate agencies

    • JAPANESE SUSHI LIMITED (14613846) Company status Active — Active proposal to strike off Incorporated on 24 January 2023 Accounts overdue First accounts made up to 31 January 2024 due by 24 October 2024 Confirmation statement Next statement date 23 January 2025 due by 6 February 2025 Last statement dated 23 January 2024 Nature of business (SIC) 56103 - Take-away food shops and mobile food stands

  Mohammod ABDULBASIR

  Total number of appointments 0 - Born October 1988

  78 Cambridge Heath Road, London, United Kingdom, E1 5QJ

  • UNI AUTOS LIMITED (11474236) Company status Dissolved Correspondence address 78 Cambridge Heath Road, London, United Kingdom, E1 5QJ Role Director Appointed on 19 July 2018 Nationality British Country of residence United Kingdom Occupation Owner

  • Registered office address 78 Cambridge Heath Road, London, United Kingdom, E1 5QJ Company status Dissolved Dissolved on 24 December 2019 Company type Private limited Company Incorporated on 19 July 2018 Nature of business (SIC) 45400 - Sale, maintenance and repair of motorcycles and related parts and accessories

• Mohammod ABDULBASIR

  Total number of appointments 2 - Born October 1988

  2 Harbinger Road, London, England, E14 3AA

  • YASIN & AMIRAH LIMITED (16153346) Company status Active Correspondence address 2 Harbinger Road, London, England, E14 3AA Role Active Director Appointed on 27 December 2024 Nationality British Country of residence England Occupation Company Director

  • SMART MOVE GROUP DEVELOPMENT LTD (14943881) Company status Active Correspondence address 2 Harbinger Road, London, England, E14 3AA Role Active Director Appointed on 19 June 2023 Nationality British Country of residence England Occupation Director

  • YOU DONUT LTD (14818388) Company status Dissolved Correspondence address 2 Harbinger Road, London, England, E14 3AA Role Director Appointed on 21 April 2023

    Nationality British Country of residence England Occupation Director Take-away food shops and mobile food stands Other food services No accounts submitted s441:CA2006 breach

• Mohammod ABDULBASIR

  Total number of appointments 0 - Born October 1988

  3 Landon Walk London, England, E14 0BH

• Mohammod ABDULBASIR

  Total number of appointments 1 - Born October 1988

  2 Harbinger Road, London, England, E14 3AA

  • EXCEL LEARN LTD (14542754) Company status Dissolved Correspondence address 2 Harbinger Road, London, England, E14 3AA Role Resigned Director Appointed on 15 December 2022 Resigned on 19 May 2023 Dissolved on 28 January 2025 Company type Private limited Company Incorporated on 15 December 2022 Confirmation statement Last statement dated 6 June 2024 No accounts submitted s441 breach Nature of business (SIC)

    85600 - Educational support services

  • 2 officers / 1 resignation BEGUM, Reashma Correspondence address 2 Harbinger Road, London, England, E14 3AA Role Director Date of birth May 981 Appointed on 15 December 2022 Nationality British Country of residence England Occupation Director

• Mohammod ABDULBASIR

  Total number of appointments 1 - Born November 1988

  76 Cambridge Heath Road, London, England, E1 5QJ

  • AQUA PROPERTY (BETHNAL GREEN) LIMITED (12493478) Company status Dissolved Correspondence address 76 Cambridge Heath Road, London, England, E1 5QJ Role Resigned Director Appointed on 2 March 2020 Resigned on 15 June 2021 Nationality British Country of residence United Kingdom Occupation Director Dissolved on 2 April 2024 Accounts Last accounts made up to 31 March 2022 Accounts to 31 March 2023 and to 2 April 2024 overdue Nature of business (SIC) 68320 - Management of real estate on a fee or contract basis

• Abdulbasir MOHAMMOD

  Total number of appointments 1

  19 Pegasus House, Beaumont Grove, London, United Kingdom, E1 4NB

  • SMART MOVE LETTINGS LIMITED (07311385) Company status Dissolved Correspondence address 19 Pegasus House, Beaumont Grove, London, United Kingdom, E1 4NB Role Resigned Secretary Appointed on 12 July 2010 Resigned on 19 September 2010 Dissolved on 7 June 2016 Incorporated on 12 July 2010 Accounts Last accounts made up to 31 July 2014 Accounts to 31 July 2015 and 7 June 2016 overdue s441 breach

• Mohammod ABDUL BASIR

  Total number of appointments 0 - Born October 1988

  140a, Ground Floor, Balfr Road, Ilford, IG1 4JD

• Mohammod ABDUL BASIR

  Total number of appointments 0 - Born October 1988

  155 Granville Avenue, Slough, England, SL2 1JP

A search on his co-director at Excel Learn Ltd, Reashma BEGUM, returns four identities with this name and the same date of birth. Reashma BEGUM - Find (https://find-and-update.company-information.service.gov.uk/search?q=Reashma+BEGUM):

• Reashma BEGUM

  Total number of appointments 1 - Born May 1981

  Unit 1,2 Harbinger Road London, Harbinger Road, London, England, E14 3AA

  • LONDON CARE AGENCY LTD (11957352) Company status Active Correspondence address Unit 1,2 Harbinger Road London, Harbinger Road, London, England, E14 3AA Role Active Director Appointed on 22 April 2024 Nationality British Country of residence England Occupation General Manager Incorporated on 23 April 2019 Accounts Up to date Nature of business (SIC) 88100 - Social work activities without accommodation for the elderly and disabled

• Reashma BEGUM

  Total number of appointments 1 - Born May 1981

  2 Harbinger Road, London, England, E14 3AA

  • EXCEL LEARN LTD dissolved without submitting accounts (described above)

• Reashma BEGUM

  Total number of appointments 2 - Born May 1981

  289 Salisbury Avenue, Barking, England, IG11 9XY

  • CENTRAL SUPPORT LTD (15025582) Company status Active Correspondence address 289 Salisbury Avenue, Barking, England, IG11 9XY Role Active Director Appointed on 25 July 2023 Nationality British Country of residence England Occupation Director Incorporated on

    25 July 2023 Accounts Up to date Nature of business (SIC)

    87900 - Other residential care activities not elsewhere classified

  • SA PROPERTY MANAGEMENT LTD (14936777) Company status Active Correspondence address 289 Salisbury Avenue, Barking, England, IG11 9XY Role Active Director Appointed on 14 June 2023 Nationality British Country of residence England Occupation Director Incorporated on 14 June 2023 Accounts Up to date Nature of business (SIC) 68310 - Real estate agencies

  Reashma BEGUM

• Total number of appointments 3 - Born May 1981

  289 Salisbury Avenue, Barking, England, IG11 9X

  • SARA & BROS LTD (13344220) Company status Active

    Correspondence address 289 Salisbury Avenue, Barking, England, IG11 9XY Role Active Director Appointed on 19 April 2021 Nationality British Country of residence England Occupation Company Director

  • IA MANAGEMENT LTD (13194676) Company status Active Correspondence address 289 Salisbury Avenue, Barking, England, IG11 9XY Role Active Director Appointed on 11 February 2021 Nationality British Country of residence England Occupation Businesswoman

  • AA HOLDING SERVICES LTD (13194779) Company status Active Correspondence address 289 Salisbury Avenue, Barking, England, IG11 9XY Role Active Director Appointed on 11 February 2021 Nationality British Country of residence England Occupation Businesswoman

    • 2 charges registered

      1 outstanding, 1 satisfied, 0 part satisfied

    • Charge code 1319 4779 0002 Created 20 October 2023 Delivered 20 October 2023 Status Outstanding Persons entitled Gatehouse Bank PLC Brief description Legal charge relating to all that land and property known…

    • Charge code 1319 4779 0001 Created 23 June 2021 Delivered 13 July 2021 Status Satisfied on 28 November 2023 Persons entitled Charter Court Financial Services Limited Brief description 2, bay tree court, 349 longbridge road, barking, IG11 9DH…

There are nine identities with the name Mohammod Abdulbasir, seven with date of birth October 1988, one with date of birth November 1988, and another without a date of birth, with the two names transposed. Two of these identities have split the surname into two name Abdul and Basir.

His co-director

Through this breach of section 1082 of the Companies Act 2006, audits and KYC checks associated to Mohammod Abdulbasir are compromised by the concealment of interests across multiple identities. There is a high risk of serious organised crime related to this individual.

Further investigation of Charter Court Financial Services Limited and Gatehouse Bank PLC is required.

Karthik Prabhulla Chandran

A search on “Karthik Prabhulla Chandran”, returns five identities with these three names with three dates of birth, two born August 2001 and two born August 1988, see Karthik PRABHULLA CHANDRAN - Find and update company information - GOV.UK (https://find-and-update.company-information.service.gov.uk/search/officers?q=Karthik+PRABHULLA+CHANDRAN).

• Karthik Prabhulla CHANDRAN

  Total number of appointments 1 - Born August 2001

  197 Hunters Square, Dagenham, England, RM10 8BQ

• Karthik Prabhulla CHANDRAN

  Total number of appointments 1 - Born August 1988

  2 Harbinger Road, London, England, E14 3AA

• Karthik Prabhulla CHANDRAN

  Total number of appointments 1 - Born August 1998

  197 Hunters Square, Dagenham, England, RM10 8BQ

• Karthik PRABHULLA CHANDRAN

  Total number of appointments 1 - Born August 2001

  2 Harbinger Road, London, England, E14 3AA

• Karthik PRABHULLA CHANDRAN

  Total number of appointments 1

  2 Harbinger Road, London, England, E14 3AA

We can conclude that these five identities belong to the same person, since wither the address “197 Hunters Square, Dagenham, England, RM10 8BQ” or “2 Harbinger Road, London, England, E14 3AA” is used for each identity. These identities relate to recently formed companies formed companies:

Karthik Prabhulla Chandran Born 2001 (3 identities):

• “EMPIRE GROUP FINANCIAL SERVICES LIMITED (15713691), Incorporated on 10 May 2024

• SMART MOVE SALES AND LETTINGS LTD (13413506) Incorporated on 21 May 2021

  • Director Appointed on 1 January 2023 Resigned on 20 March 2024

  • Secretary Appointed on 1 January 2024 Resigned on 20 March 2024”

Karthik Prabhulla Chandran Born 1988:

• “SMART MOVE CONSTRUCTIONS LIMITED (15453165) Incorporated on 30 January 2024”

Karthik Prabhulla Chandran Born 1998:

• “EMPIRE SALES AND LETTINGS LIMITED (15849755) Appointed on 21 July 2024 Incorporated on 21 July 2024 Nature of business (SIC) 98000 - Residents property management”

Karthik Prabhulla Chandran has registered five identities in breach of Section 1082. This presents a significant risk of serious organised crime. Requiring further investigation.

Whether Jordan Peterson born September 1995 is the same person or related party of Jordon B Peterson is unproved. Jordan Peterson’s colleagues, Mohammod Abdulbasir and Karthik Prabhulla Chandran, both have multiple identities registered. They are associated to companies with “Smart Move” in the name. The fact that one of the corporate identities returned in the search for Jonathan Hopkin Hill in Companies House is Hopkin Smart Consulting Limited, raises the query whether there is there any association between Hopkin Smart Consulting Ltd and Smart Move Construction Limited, Smart Move Sales and Lettings Ltd, or other “Smart Move” companies?

Summary of breaches associated with Alliance for Responsible Citizenship Limited

Based on the provided compliance assessment, here is a cross-checked summary of breaches associated with Alliance for Responsible Citizenship Limited, its officers, associated parties, and incidental findings:

Alliance for Responsible Citizenship Limited:

1. Non-compliant (CTDR 2015) x4: Conference invitation fails to meet four out of six Trading Disclosures requirements.

2. Non-compliant (CTDR 2015): Website fails to disclose Sir Paul Marshall as a director.

Sir Paul Roderick Clucas Marshall:

1. Non-compliant (s1082:CA2006) x3: Established three, likely four, unique identifiers in Companies House.

2. Non-compliant (s441:CA2006) x5: Director of five dissolved companies with overdue accounts.

3. Non-compliant (HLCC2023) x11: Omitted eleven active directorships in biography on ARC website.

4. Non-compliant (HLCC2023) x12: Omitted twelve active directorships in biography on Church Revitalisation Trust website.

Alan James McCormick:

1. Non-compliant (s1082:CA2006) x5: At least 5 additional identities in Companies House.

2. Non-compliant (s441:CA2006) x3: Director of companies with overdue accounts.

Nicholas Glynn Paul Gumbel (Nicky Gumbel):

1. Non-compliant (s1082:CA2006): Two identities registered in Companies House.

2. Non-compliant (s441:CA2006) x2: Director of two dissolved companies with overdue accounts.

3. Non-compliant (HLCC2023): Listed as a trustee on Church Revitalisation Trust website after resignation.

Jonathan Mark Shippen:

1. Non-compliant (s1082:CA2006) x13: Appears to have fourteen unique identifiers in Companies House.

Church Revitalisation Trust:

1. Non-compliant (CTDR 2015) x2: Errors in registered address and director disclosure anomalies on website.

Damien Anthony O'Donohoe:

1. Non-compliant (s1082:CA2006) x2: Three identities registered in Companies House.

2. Non-compliant (s167:CA2006): Not registered as an officer of BEIKONIC LP in Companies House.

UBS AG and related entities, described in Appendix B (incidental finding, not necessarily connected to subjects of this report):

1. Non-compliant (s66:CA2006): Multiple registrations of UBS AG, UBS BUSINESS SOLUTIONS AG, and UBS GROUP AG.

2. Non-compliant (s86:CA2006): Address inconsistencies for UBS AG.

3. Non-compliant (s1112:CA2006): Spelling and grammatical errors in official documents.

4. Non-compliant (s162:CA2006): No officer details available for UBS AG (OE013351).

5. Non-compliant (s441:CA2006): Delay in filing registration documents for UBS AG (OE013351).

Beikonic Ltd and Beikonic LP:

1. Non-compliant (s66:CA2006): Duplicate company names.

1573 CIGARS LIMITED:

1. Non-compliant (s86:CA2006): Error in registered office address (duplication of "International House").

This list summarizes the identified breaches based on the provided compliance assessment. Note that some breaches may have been inferred from the context, and the specific sections of the Companies Act 2006 have been added where they were not explicitly mentioned in the original text.

Limitations Statement

This compliance assessment report has several important limitations that should be considered:

1. Scope of Investigation: Due to the extensive network of associations and entities involved, not all lines of inquiry have been fully explored or exhausted. The complex web of relationships and potential conflicts of interest may require further in-depth investigation.

2. Data Sources: The assessment primarily relies on publicly available information from Companies House and company websites. Additional private or restricted documents may provide more comprehensive insights.

3. Timeliness of Information: Company records and online information may not reflect the most current status of appointments, resignations, or corporate structures due to potential delays in updating public databases.

4. Expertise Required: A full investigation would benefit from a multidisciplinary team including:

   • Forensic auditors to thoroughly examine financial records and transactions

   • Legal experts specializing in corporate and financial law

   • Cybersecurity professionals to assess potential digital vulnerabilities

   • Investigative journalists to uncover additional relevant information

   • Corporate governance specialists to evaluate compliance with best practices

5. International Jurisdictions: The involvement of entities and individuals across multiple countries introduces complexities in assessing compliance with various national regulations.

6. Potential for Undisclosed Information: There may be relevant information not captured in public records or official filings that could impact the assessment's conclusions.

7. Evolving Regulatory Landscape: Changes in laws and regulations may affect the interpretation of compliance issues over time.

8. Limited Access to Individuals: This assessment does not include direct interviews with the individuals mentioned, which could provide additional context or explanations for apparent discrepancies.

9. Complexity of Corporate Structures: The intricate nature of holding companies, subsidiaries, and related entities may obscure ultimate beneficial ownership or control.

10. Resource Constraints: A more comprehensive investigation would require significant time, financial resources, and access to specialised databases and tools.

11. Mr Christopher Lincoln Chandler (date of birth January 1960), Mr Richard Edward Douglas (date of birth May 1953) and Mr Mark Alan Stoleson (date of birth July 1970, will be considered in a second report, to follow.

Given these limitations, this report should be considered an initial assessment that highlights areas of potential concern rather than a definitive evaluation of compliance. Further investigation by appropriate authorities and independent professionals is recommended to fully understand the extent of any compliance issues or risks identified.

Testing the remaining persons with significant control for multiple identities:

Christopher Lincoln Chandler (date of birth January 1960)

A search on this name locates no identities registered with this name in Companies House Christopher Lincoln Chandler - Find (https://find-and-update.company-information.service.gov.uk/search/officers?q=Christopher+Lincoln+Chandler+). Corporate entities named Chandlers are returned, however, it is not determined whether these are connected to Christopher Lincoln Chandler, these require further analysis.

• CHANDLER PROPERTY INVESTMENTS LIMITED

  Total number of appointments 1

  Sterling House, 501 Middleton Road, Chadderton, Oldham, England, OL9 9LY

• CHANDLERS TOPCO LIMITED

  Total number of appointments 1

  The Broyle, The Broyle, Ringmer, Lewes, England, BN8 5NP

• CHANDLER SHIPTON ASSOCIATES LTD

  Total number of appointments 0

  22 Ivar Gardens, Lychpit, Basingstoke, Hampshire, United Kingdom, RG24 8YD

• CHANDLERS ROOFING SUPPLIES LIMITED

  Total number of appointments 1

  Chandlers Depot, The Broyle, Ringmer, East Sussex, BN8 5NP

A search on the name Christopher Chandler locates sixty-six identities with the name Christopher Chandler with a range of different middle names and dates of birth Christopher Chandler - Find. None have the date of birth provided by Christopher Lincoln Chandler. Some evidently have multiple identities registered. For example:

Christopher CHANDLER born July 1979

• Christopher CHANDLER

  Total number of appointments 1 - Born July 1979

  16 Otford Road, Sevenoaks, England, TN14 5DN

• Christopher CHANDLER

  Total number of appointments 1

  16 Otford Road, Sevenoaks, England, TN14 5DN

• Christopher CHANDLER

  Total number of appointments 1 - Born July 1979

  Rutland Cottage, Wimblington Road, Manea, Cambridgeshire, England, PE15 0JR

• Christopher CHANDLER

  Total number of appointments 1

  Rutland Cottage, Wimblington Road, Manea, Cambridgeshire, England, PE15 0JR

Christopher Chandler born July 1979 has four identities associated with the same date of birth or referencing the same correspondence address, in breach of S1082:CA2006.

Christopher James CHANDLER born February 1979

• Christopher James CHANDLER identity 1

  “Total number of appointments 1 - Born February 1979

  338 - 14th Floor, Euston Road, London, England, NW1 3BT

  • TOTALSTAY LIMITED (03709151) Company status Active Role Active Director Appointed on 10 June 2024 Nationality New Zealander Country of residence United Arab Emirates Occupation None Registered office address 14th Floor 338 Euston Road, London, England, NW1 3BT Incorporated on 5 February 1999 Accounts Up to date Nature of business (SIC) 79110 - Travel agency activities Previous company names PUFFIN TRAVEL LIMITED05 Feb 1999 - 18 Feb 2003 Register of directors Information not on the public register since 29 June 2018 Register of secretaries Information not on the public register since 29 June 2018 Register of person(s) with significant control (PSCs) Information not on the public register since 29 June 2018 Register of members Information not on the public register since 29 June 2018 TOTALSTAY LIMITED charges 9 charges registered 0 outstanding, 9 satisfied, 0 part satisfied Charge code 0370 9151 0009 Created 26 March 2015 Delivered 1 April 2015 Status Satisfied on 12 September 2017 Persons entitled Sanne Fiduciary Services Limited as Security Trustee Brief description Intellectual property:. Trademark: "totalstay" (logo);… Other Persons entitled Hsbc Bank PLC, Barclays Bank PLC, The Royal Bank of Scotland PLC, National Westminster Bank PLC, Mawpart Developments Limited

  • 1 active person with significant control / 0 active statements

    • Webbeds Limited Active Correspondence address 338 - 14th Floor, Euston Road, London, England, NW1 3BT Notified on

      6 June 2019 Governing law United Kingdom (England And Wales) Legal form Corporate

      Place registered Companies House Registration number 07761565 Incorporated in United Kingdom Nature of control

      Ownership of shares – 75% or more

      Ownership of voting rights - 75% or more

      Right to appoint or remove directors

    • Jac Group (Holdings) Limited Ceased

      Correspondence address 8 Holmes Road, Kentish Town, London, United Kingdom, NW5 3AB Notified on 6 April 2016 Ceased on 6 June 2019 Governing law United Kingdom (England And Wales) Legal form Limited By shares Place registered Companies House

      Registration number 06326585”

• Christopher James CHANDLER identity 2

  “Total number of appointments 1 - Born February 1979

  338 - 14th Floor, Euston Road, London, England, NW1 3BT

  • WEBBEDS LIMITED (07761565) Company status Active Correspondence address 338 - 14th Floor, Euston Road, London, England, NW1 3BT Role Active Director Appointed on 10 June 2024 Nationality New Zealander Country of residence United Arab Emirates Occupation None

  • Registered office address 338 - 14th Floor Euston Road, London, England, NW1 3BT Company status Active Company type Private limited Company Incorporated on 5 September 2011 Accounts Up to date Nature of business (SIC) 79120 - Tour operator activities Previous company names LOTS OF HOTELS LIMITED 05 Jun 2017 - 19 Jul 2017 WEBBEDS LIMITED 17 Jul 2015 - 05 Jun 2017 LOTS OF HOTELS LIMITED 22 May 2013 - 17 Jul 2015 WEBJET UK LIMITED 05 Sep 2011 - 22 May 2013

  • 16 officers / 12 resignations

    • CHANDLER, Christopher James Correspondence address 338 - 14th Floor, Euston Road, London, England, NW1 3BT Role Active Director Date of birth February 1979 Appointed on 10 June 2024 Nationality New Zealander Country of residence United Arab Emirates Occupation None

    • EARHART BEASLEY, Shelley Lynne Correspondence address 338 - 14th Floor, Euston Road, London, England, NW1 3BT Role Active

      Director Date of birth December 1969 Appointed on 1 May 2017 Nationality American Country of residence New Zealand Occupation Chief Commercial Director

    • GUSCIC, John Correspondence address 338 - 14th Floor, Euston Road, London, England, NW1 3BT Role Active Director Date of birth February 1964 Appointed on 5 September 2011 Nationality Australian Country of residence Australia Occupation Director

    • RISTEVSKI, Tony Correspondence address 338 - 14th Floor, Euston Road, London, England, NW1 3BT Role Active Director Date of birth January 1972 Appointed on 16 July 2018 Nationality

      Australian Country of residence Australia Occupation Finance Director

  • 0 active persons with significant control / 1 active statement

    • Statement Active The company knows or has reasonable cause to believe that there is no registrable person or registrable relevant legal entity in relation to the company Notified on 14 May 2024

    • Mr John Guscic Ceased Correspondence address 338 - 14th Floor, Euston Road, London, England, NW1 3BT Notified on 6 April 2016 Ceased on 14 May 2024 Date of birth February 1964 Nationality Australian Country of residence Australia Nature of control Right to appoint or remove directors”

  Christopher James CHANDLER identity 3

  “Total number of appointments 1 - Born February 1979

  338 - 14th Floor, Euston Road, London, England, NW1 3BT

  • JAC TRAVEL LIMITED (04714729) Role Active Director Appointed on 10 June 2024 Nationality New Zealander Country of residence United Arab Emirates Occupation None Incorporated on 28 March 2003Nature of business (SIC) 96090 - Other service activities not elsewhere classified Registered office address 14th Floor 338 Euston Road, London, England, NW1 3BT Company status Active Previous company names JACOB ONLINE LIMITED 22 Apr 2003 - 01 Nov 2010 SPEED 9579 LIMITED 28 Mar 2003 - 22 Apr 2003 5 charges registered 0 outstanding, 5 satisfied, Persons entitled Sanne Fiduciary Services Limited as Security Trustee, The Royal Bank of Scotland PLC Register of directors Information not on the public register since 2 July 2018 Register of secretaries Information not on the public register since 2 July 2018 Register of person(s) with significant control (PSCs) Information not on the public register since 2 July 2018 Register of members Information not on the public register since 2 July 2018

  • 27 officers / 24 resignations Active directors only are shown below

    • BEASLEY, Shelley Lynne Earhart Correspondence address 338 - 14th Floor, Euston Road, London, United Kingdom, NW1 3BT Role Active Director Date of birth December 1969 Appointed on

      31 August 2017 Nationality American Country of residence New Zealand Occupation Manager

    • CHANDLER, Christopher James Correspondence address 338 - 14th Floor, Euston Road, London, England, NW1 3BT Role Active Director Date of birth February 1979 Appointed on 10 June 2024 Nationality New Zealander Country of residence United Arab Emirates Occupation None

    • GUSCIC, John Correspondence address 14th Floor, 338 Euston Road, London, England, NW1 3BT Role Active Director Date of birth February 1964 Appointed on 31 August 2017 Nationality Australian Country of residence Australia Occupation Director

  • 1 active person with significant control / 0 active statements

    • Webbeds Limited Active Correspondence address 338 - 14th Floor, uston Road, London, United Kingdom, NW1 3BT Notified on 26 February 2018 Governing law United Kingdom (England And Wales) Legal form Corporate Place registered Companies House Registration number 07761565 Incorporated in England And Wales Nature of control Ownership of shares – 75% or more Ownership of voting rights - 75% or more Right to appoint or remove directors

    • Jac Group (Holdings) Limited Ceased Correspondence address 8 Holmes Road, Kentish Town, London, United Kingdom, NW5 3AB Notified on 6 April 2016 Ceased on 26 February 2018 Governing law United Kingdom Legal form Limited By shares Place registered Companies House Registration number 06326585 Incorporated in United Kingdom Nature of control Ownership of shares – 75% or more Ownership of voting rights - 75% or more Right to appoint or remove directors”

• Christopher James CHANDLER identity 4

  “Total number of appointments 1 - Born February 1979

  338 - 14th Floor, Euston Road, London, England, NW1 3BT

  • SUNHOTELS LTD (04390392) Company status Active Correspondence address 338 - 14th Floor, Euston Road, London, England, NW1 3BT Role Active Director Appointed on 10 June 2024 Nationality New Zealander Country of residence United Arab Emirates Occupation None

    Registered office address 338 - C/O Webbeds Ltd 14th Floor Euston Road, London, England, NW1 3BT Company status Active Company type Private limited Company Incorporated on 8 March 2002 Accounts Up to date Nature of business (SIC) 79120 - Tour operator activities”

• Christopher James CHANDLER identity 5

  “Total number of appointments 1 - Born February 1979

  338 - 14th Floor, Euston Road, London, England, NW1 3BT

  • FYRKANT LTD (07040923) Company status Active Correspondence address 338 - 14th Floor, Euston Road, London, England, NW1 3BT Role Active Director Appointed on 10 June 2024 Nationality New Zealander Country of residence United Arab Emirates Occupation None

    Registered office address 338 - C/O Webbeds Ltd 14th Floor Euston Road, London, England, NW1 3BT Company status Active Incorporated on 14 October 2009 Nature of business (SIC) 82990 - Other business support service activities not elsewhere classified Previous company names

    ZLEEPING LTD14 Oct 2009 - 09 Feb 2011”

• Christopher James CHANDLER identity 6

  “Total number of appointments 1 - Born February 1979

  338 - 14th Floor, Euston Road, London, England, NW1 3BT

• JAC GROUP (HOLDINGS) LIMITED (06326585) Company status Active Correspondence address 338 - 14th Floor, Euston Road, London, England, NW1 3BT

  Role Active Director Appointed on 10 June 2024 Nationality New Zealander Country of residence United Arab Emirates Occupation None”

Christopher James Chandler has six identities registered with date of birth February 1979, in breach of s1082:CA2006.

Jac Group (Holdings) Limited is a past person with significant control of TOTALSTAY LIMITED TOTALSTAY LIMITED (03709151).

TOTALSTAY LIMITED is associated to Sanne Fiduciary Services Limited through a charge, satisfied on 12 September 2017.

Potential confusion relating to the Judicial Appointments Commission, which also uses the acronym JAC

Christopher James CHANDLER identity 3 is a director of JAC TRAVEL LIMITED

Christopher James CHANDLER identity 6 born February 1979 is a director of JAC GROUP (HOLDINGS) LIMITED.

The incidence of JAC as a company name and as a result of the Judicial Appointments Commission’s use of the acronym JAC, this raises the possibility of clone company fraud relating to the use of JAC.

Note that the registered office address of Sunhotels Ltd is “338 - C/O Webbeds Ltd 14th Floor Euston Road, London, England, NW1 3BT”, including WEBBEDS Ltd in the address, associating these companies.

Register of directors Information not on the public register implies that this company has permission to withhold information under the Companies Act 2006 therefor this is possibly a government appointment.

Mawpart Developments Limited

A search in Companies House for “Mawpart Developments Limited” locates these identities first:

• "HARRISON VARMA (BVH) LIMITED

  Matching previous names:
  MAWPART DEVELOPMENTS

  02189563 - Dissolved on 25 June 2013

  Bishops View House 98 Great North Road East Finchley, London, N2 0NL

  • Registered office address Bishops View House 98 Great North Road, East Finchley, London, N2 0NL Company status Dissolved Dissolved on 25 June 2013 Company type Private limited Company Incorporated on 6 November 1987 Accounts Last accounts made up to 23 March 2011 Accounts made up to 23 March 2012 and to dissolution overdue Nature of business (SIC) 41202 - Construction of domestic buildings Previous company names MAWPART DEVELOPMENTS LIMITED29 Dec 1987 - 13 Feb 2012RAPID 4322 LIMITED06 Nov 1987 - 29 Dec 1987 11 charges registered 3 outstanding, 8 satisfied, Persons entitled Rowanmoor Trustees Limited Anil Kumar Varma and Marisa Anne Varma, Harrison Varma Limited Anomaly: Company dissolved with charges outstanding

• MAWPART COMMERCIAL LIMITED

  02203378 - Dissolved on 15 August 2023

  Devonshire House, Manor Way, Borehamwood, Hertfordshire, WD6 1QQ

  • Registered office address Devonshire House, Manor Way, Borehamwood, Hertfordshire, WD6 1QQ Company status Dissolved Dissolved on 15 August 2023 Company type Private limited company Incorporated on 8 December 1987 Accounts Last accounts made up to 23 March 2019 Nature of business (SIC) 74990 - Non-trading company Previous company names

    HARDY PROPERTIES LIMITED08 Dec 1987 - 02 Mar 1988 38 charges registered 11 outstanding, 26 satisfied Persons entitled Nationwide Building Society, Chaterhouse Bank Limited, Hill Samuel Bank Limited, Hill Samuel & Co. Limited Anomaly: Company dissolved with charges outstanding

• MAWPART PROPERTIES LIMITED

  02154659 - Dissolved on 3 August 2023

  Devonshire House, Manor Way, Borehamwood, Hertfordshire, WD6 1QQ

• MAWPART COMMERCIAL (NUMBER 4) LIMITED

  03468334 - Dissolved on 28 February 2022

  Devonshire House, Manor Way, Borehamwood, Hertfordshire, WD6 1QQ

• MAWPART COMMERCIAL (NUMBER 3) LIMITED

  03442663 - Dissolved on 28 February 2022

  Devonshire House, Manor Way, Borehamwood, Hertfordshire, WD6 1QQ

• MAWPART COMMERCIAL (NUMBER 2) LIMITED

  03269906 - Dissolved on 28 February 2022

  Devonshire House, Manor Way, Borehamwood, Hertfordshire, WD6 1QQ

• MAWPART SECURITIES LIMITED

  02182740 - Dissolved on 29 September 2020

  325-327 Oldfield Lane North, Greenford, Middlesex, United Kingdom, UB6 0FX

• SOUTH WALES LAND DEVELOPMENTS LIMITED

  OE008285 - Registered on 15 December 2022

  Mont Crevelt House, Bulwer Avenue, St Sampson, Guernsey, GY2 4LH Correspondence address

  Suite 6 13 St Andrews Crescent, Cardiff, Wales, CF10 3DB

  Company status Registered Company type Overseas entity Registered on 15 December 2022 Annual statement Next statement date 4 July 2025 due by 18 July 2025 Last statement dated 4 July 2024 Company details in the country of incorporation Overseas entity address Mont Crevelt House, Bulwer Avenue, St Sampson, Guernsey, GY2 4LH Incorporated in GUERNSEY Registration number 54435 Legal form

  Private Company With Limited Liability Parent registry Guernsey Registry,Guernsey Governing law The Companies (Guernsey) Law 2008

• There are no officer details available for this company. This breaches the Companies Act 2006 which requires that at least one person is a director.

• 1 active beneficial owner / 2 active statements Statement Active All beneficial owners have been identified and all required information can be provided Notified on 4 July 2024

• Statement Active Somebody has become or ceased to be a beneficial owner during the update period notified on 4 July 2024

• Highmead Properties Limited Active Correspondence address Suite 6, 13 St. Andrews Crescent, Cardiff, Wales, CF10 3DB Principal office address Suite 6, 13 St. Andrews Crescent, Cardiff, Wales, CF10 3DB Notified on 8 April 2024 Governing law Companies Act 2006 Legal form Limited company Place registered Companies House Registration number 15524801 Nature of control Ownership of shares - More than 25% Ownership of voting rights - More than 25% Right to appoint or remove directors Has significant influence or control

• Gilbert Stanley Thomas Ceased

  Correspondence address The Paddocks, Druidstone Road, St Mellons, Cardiff, Wales, CF3 6XD Notified on 15 December 2011 Ceased on 8 April 2024 Date of birth September 1941 Nationality British Nature of control Ownership of shares - More than 25% Ownership of voting rights - More than 25% Right to appoint or remove directors Has significant influence or control

Two of the companies that are dissolved have accounts overdue in breach of section 441 of the Companies Act 2006. The risk is that bank accounts are operating in these companies names, without accountability. Not all of the identities have been expanded above, however, based on past experience it is likely that these companies are also dissolved in breach of section 441 of the Companies Act 2006.

Christopher Chandler born August 1983

• Christopher CHANDLER

  Total number of appointments 0 - Born August 1983

  17a Cowper Street, Hove, BN3 5BP

• Christopher CHANDLER

  Total number of appointments 0 - Born August 1983

  5 St. James Road, East Grinstead, West Sussex, United Kingdom, RH19 1DL

Christopher Chadler born August 1983 has two identities registered in Companies House in breach of s1082:CA2006.

• Christopher John CHANDLER

  Total number of appointments 15 - Born September 1958

  C/O 1st Floor Office, 54-56 Hagley Road, Stourbridge, West Midlands, United Kingdom, DY8 1QD. Two appointments only are described here:

  • ASPIRE GLOBAL NETWORK EOT LIMITED (14763106) Company status Active Correspondence address C/O 1st Floor Office, 54-56 Hagley Road, Stourbridge, West Midlands, United Kingdom, DY8 1QD Role Active Director Appointed on 28 March 2023 82990 - Other business support service activities not elsewhere classified

  • WE ARE ASPIRE LTD (06780673) Company status In Administration Correspondence address C/O Rsm Uk Restructuring Advisory Llp 25, Farringdon Street, London, EC4M 4AB Role Active Secretary Appointed on 5 January 2009 Incorporated on 29 December 2008 Accounts overdue Next accounts made up to 31 December 2023 due by 30 September 2024 Last accounts made up to 31 December 2022 s441:CA2006 breach Confirmation statement overdue Next statement date 29 December 2023 due by 12 January 2024 Last statement dated 29 December 2022 Nature of business (SIC) 78109 - Other activities of employment placement agencies Previous company names RPCUSHING LIMITED19 Nov 2020 - 05 Jan 2021ASPIRE TRAINING & DEVELOPMENT LTD24 May 2018 - 19 Nov 2020RPCUSHING LIMITED19 Jan 2009 - 24 May 2018PFJ ACQUISITION LIMITED06 Jan 2009 - 19 Jan 2009MINMAR (921) LIMITED29 Dec 2008 - 06 Jan 2009 2 charges registered 1 outstanding, 1 satisfied Charge code 0678 0673 0002 Created

    12 January 2021 Delivered 29 January 2021 Status Outstanding Persons entitled Close Brothers Limited (The “Security Trustee”) Brief description

    Contains fixed charge…

    • CLOSE BROTHERS LIMITED overview Registered office address 10 Crown Place, London, EC2A 4FT Company status Active Incorporated on 9 February 1924 Nature of business (SIC) 64999 - Financial intermediation not elsewhere classified

    • CLOSE BROTHERS LIMITED charges 7 charges registered 6 outstanding, 1 satisfied Persons entitled

      • Close Brothers Limited

      • Orbita Funding 2023-1 PLC

      • Orbita Funding 2022-1 PLC

      • Orbita Funding 2020-1 PLC

      • Orbita Funding 2017-1 PLC

      • Orbita Funding 2016-1 PLC

      • Spry Finance LTD (satisfied on 31 January 1992)

• Christopher John CHANDLER

  Total number of appointments 1 - Born September 1958

  Radclyffe House, 66-68 Hagley Road, Birmingham, England, B16 8PF

  • HARBORNE VILLAGE MANAGEMENT LIMITED (11955796) Company status Active Correspondence address Radclyffe House, 66-68 Hagley Road, Birmingham, England, B16 8PF Role Active Director Appointed on 3 September 2023 Nature of business (SIC) 98000 - Residents property management

• Christopher John CHANDLER

  Total number of appointments 1 - Born September 1958

  Felin Soch, Abersoch, Pwllheli, Wales, LL53 7AG

  • CHANDLERS ABERSOCH LTD (14588863) Dissolved on 24 December 2024 Company type Private limited company Incorporated on 12 January 2023 Confirmation statement Last statement dated 11 January 2024 No accounts submitted s441:CA2006 breach Nature of business (SIC) 82990 - Other business support service activities not elsewhere classified

• Christopher John CHANDLER

  Total number of appointments 1

  Felin Soch, Abersoch, Pwllheli, Wales, LL53 7AG

Christopher John Chandler has four identities registered in Companies House with date of birth September 1958 or with the same correspondence address in breach of s1082:CA2006.

Further analysis of Close Brothers Limited, Orbita Funding 2023-1 PLC, Orbita Funding 2022-1 PLC, Orbita Funding 2020-1 PLC, Orbita Funding 2017-1 PLC, Orbita Funding 2016-1 PLC and Spry Finance LTD is required.

There are a statistically high number of identities name Christopher John Chandler, which require further investigation.

• Christopher John CHANDLER

  Total number of appointments 0 - Born November 1954

  Turnpike House, 1208-1210 London Road, Leigh On Sea, Essex, SS9 2UA

• Christopher John CHANDLER

  Total number of appointments 2 - Born October 1989

  C/O Consilium Chartered Accountants, 169 West George Street, Glasgow, United Kingdom, G2 2LB

  • AGRICALD LIMITED (SC676347) Company status Active Correspondence address C/O Consilium Chartered Accountants, 169 West George Street, Glasgow, United Kingdom, G2 2LB Role Active Director Appointed on 2 October 2020 Nationality British Country of residence England Occupation Director

  • SYNCALD LTD (SC521652) Company status

    Active Correspondence address C/O Consilium hartered Accountants, 169 West George Street, Glasgow, United Kingdom, G2 2LB Role Active

    Director Appointed on 2 December 2015 Nationality British Country of residence England Occupation Director

• Christopher John CHANDLER

  Total number of appointments 0 - Born January 1963

  Greystoke House, 80-86 Westow Street, London, SE19 3AF

• Christopher John CHANDLER

  Total number of appointments 1 - Born May 1960

  Unit 1, Davey Road, Willowbrook Industrial Estate, Corby, Northamptonshire, United Kingdom, NN17 5XX

• Christopher John CHANDLER

  Total number of appointments 1 - Born June 1984

  26 Knights Mead, Chudleigh, Newton Abbot, England, TQ13 0RE

• Christopher John CHANDLER

  Total number of appointments 4 - Born April 1947

  7 Tregarne Terrace, St Austell, Cornwall, PL25 4BE

• Christopher John CHANDLER

  Total number of appointments 1 - Born October 1961

  5 Beaumont Gate, Shenley Hill, Radlett, England, WD7 7AR

The reference to Consilium Chartered Accountants in the correspondence address for AGRICALD LIMITED and SYNCALD LTD (SC521652) requires further analysis.

Richard Edward Douglas (date of birth May 1953)

A search for Richard Edward Douglas locates two identities with this date of birth and Richard Edward Douglas - Find (https://find-and-update.company-information.service.gov.uk/search/officers?q=Richard+Edward+Douglas) in breach of s182:CA2006. There are two further identities with this name registered with different dates of birth.

• Richard Edward DOUGLAS

  Total number of appointments 1 - Born May 1953

  Third Floor, 20 Old Bailey, London, EC4M 7AN

• Richard Edward DOUGLAS

  Total number of appointments 1 - Born May 1953

  Cayman Club, PO BOX 993 G.T., Grand Cayman

• Richard Edward DOUGLAS

  Total number of appointments 1 - Born April 1941

  35 Alfred Road, Birchington, Kent, United Kingdom, CT7 9NJ

• Richard Edward DOUGLAS

  Total number of appointments 0 - Born November 1967

  35 Alfred Road, Birchington, Kent, United Kingdom, CT7 9NJ

• RICHARD EDWARDS GROUP LLP

  Total number of appointments 1

  The Maltings, Rosemary Lane, Halstead, Essex, CO9 1HZ

• Richard Douglas Edward HADFIELD

  Total number of appointments 14 - Born January 1981

  Hunter Simmons Ltd, Emp Building, Unit 1, 4 Solent Road, Havant, Hampshire, England, PO9 1JH

• Richard Douglas Edward HADFIELD

  Total number of appointments 1 - Born January 1981

  318 Flat 318, 79 Marsham Street, London, England, SW1 4SA

• Richard Douglas Edward HADFIELD

  Total number of appointments 1 - Born January 1981

  27 Dorton Road, Balham, London, London, England, SW12 9NB

• Edward Richard Douglas RIGHTON

  Total number of appointments 0 - Born June 2002

  Norton Cottage, Campden Hill, Ilmington, Shipston-On-Stour, England, CV36 4LH

Mr Mark Alan Stoleson (date of birth July 1970).

Appendix A

Cardinal Investments Limited: Analysis required

Bluejay Investments Ltd:

A search on “Bluejay Investments Ltd” in Companies House, for officers and companies returns two results that will be discussed:

• DISKO LIMITED

  Matching previous names:
  BLUEJAY INVESTMENTS · BLUEJAY MINING

  10306405 - Dissolved on 2 November 2021

  2nd Floor 7-9 Swallow Street, London, England, W1B 4DE

• Company type Private limited Company Incorporated on 1 August 2016 Accounts Last accounts made up to 31 August 2020 Accounts overdue Non-compliant (s441:CA2006) Nature of business (SIC) 08990 - Other mining and quarrying not elsewhere classified Previous company names

  ALECTO MINING LIMITED 31 Mar 2017 - 31 May 2018 BLUEJAY INVESTMENTS LIMITED 10 Mar 2017 - 31 Mar 2017 BLUEJAY MINING LIMITED 25 Jan 2017 - 10 Mar 2017 TIG RESOURCES LIMITED 01 Aug 2016 - 25 Jan 2017

This company called “Bluejay Investments Limited 10 March 2017- 31 March 2017. This company was active years after the incorporation of Legatum Institute in 13 December 2005. The rapid name changes raise concern, however, and it dissolved with accounts outstanding and final accounts not submitted. The sole director of this company, when screened for multiple identities in Companies House is found to have 5 identities, refer to Garth Mervyn PALMER - Find - GOV.UK (company-information.service.gov.uk) Whether or not this company is related to the subscriber of Legatum Institute who had the same name in 2005 requires further clarification.

Appendix B

Corporate identities returned in the search for Jonathan Hopkin Hillier (https://find-and-update.company-information.service.gov.uk/search/companies?q=Jonathan+Hopkin+Hillier). Since these identities were returned above identities with Jonathan Hopkin Hillier’s name it is likely that the Companies House search engine is associating them through a residential address, which is not published. Therefore these identities are explored below:

Corporate person identity 1

• “HILLIER HOPKINS GROUP LIMITED

  Total number of appointments 1

  Charter Court, Midland Road, Hemel Hempstead, Hertfordshire, United Kingdom, HP2 5GE

  • DASH CAPITAL LLP (OC341620) Company status Dissolved Correspondence address Charter Court, Midland Road, Hemel Hempstead, Hertfordshire, United Kingdom, HP2 5GE Role Resigned LLP Designated Member Appointed on 21 November 2008 Resigned on 23 August 2013 Registration number 05434747

    Registered office address C/o Lancasters, Unit 7 - 8 Manor Courtyard, Aston Sandford, Aylesbury, Buckinghamshire, HP17 8JB Dissolved on 29 August 2017 Incorporated on 21 November 2008 Accounts Last accounts made up to 31 March 2016 Final accounts not submitted . This triggers the risk that bank accounts are still operating. Previous company names FIELDSTEAD INSOLVENCY LLP 29 Aug 2013 - 16 Dec 2014 HILLIER HOPKINS CORPORATE RECOVERY LLP 21 Nov 2008 - 29 Aug 2013”

Corporate person identity 2

• “HILLIER HOPKINS LLP

  Total number of appointments 4

  Charter Court, Midland Road, Hemel Hempstead, Hertfordshire, United Kingdom, HP2 5GE

  • Total number of appointments 6

  • METION LIMITED (07694049) Company status Dissolved Correspondence address Charter Court, Midland Road, Hemel Hempstead, Hertfordshire, United Kingdom, HP2 5GE Role Secretary Appointed on 5 July 2011 Final accounts not submitted . This triggers the risk that bank accounts are still operating

  • RALPH ARDILL CONSULTING LIMITED (05446334) Company status Dissolved Correspondence address Radius House, 51 Clarendon Road, Watford, Herts, England, WD17 1HP Role Secretary Appointed on 1 July 2009 Final accounts not submitted . This triggers the risk that bank accounts are still operating

  • RALPH ARDILL LIMITED (09808240) Company status Active Correspondence address 1st Floor, Radius House, 51 Clarendon Road, Watford, Herts, United Kingdom, WD17 1HP Role Resigned Secretary Appointed on 3 October 2015 Resigned on 20 October 2020

  • GENTLEMAN & A VAN STORAGE LIMITED (06975739) Company status Dissolved Correspondence address Charter Court, Midland Road, Hemel Hempstead, Herts, HP2 5GE Role Resigned Secretary Appointed on 29 July 2009 Resigned on 29 July 2010 Final accounts not submitted . This triggers the risk that bank accounts are still operating

  • GENTLEMAN & A VAN LTD (06055933) Company status Dissolved Correspondence address Charter Court, Midland Road, Hemel Hempstead, Herts, HP2 5GE Role Resigned Secretary Appointed on 6 August 2009 Resigned on 17 January 2010” Final accounts not submitted . This triggers the risk that bank accounts are still operating

the key breaches observed for Hillier Hopkins Group Limited and Hillier Hopkins LLP are:

1. Final Accounts Not Submitted: Multiple dissolved companies associated with these entities failed to submit final accounts. This is a breach of Section 441 of the Companies Act 2006, which requires companies to file their accounts within specified timeframes. The companies affected include:

   • DASH CAPITAL LLP (OC341620)

   • METION LIMITED (07694049)

   • RALPH ARDILL CONSULTING LIMITED (05446334)

   • GENTLEMAN & A VAN STORAGE LIMITED (06975739)

   • GENTLEMAN & A VAN LTD (06055933)

2. Risk of Ongoing Bank Account Operation: The failure to submit final accounts for these dissolved companies raises concerns that their bank accounts may still be operational. This could potentially lead to financial irregularities or misuse of company assets after dissolution.

3. Potential Breach of Directors' Duties: The failure to submit final accounts may indicate a breach of directors' duties under the Companies Act 2006, particularly the duty to promote the success of the company and exercise reasonable care, skill, and diligence.

4. Lack of Transparency: The absence of final accounts for these dissolved companies creates a lack of transparency regarding their financial status at the time of dissolution, which could be a concern for creditors or other stakeholders.

These breaches suggest significant compliance issues within the Hillier Hopkins Group Limited and Hillier Hopkins LLP, warranting further investigation into their corporate governance practices and the conduct of their members and officers.

No association was confirmed relating to Lord Hopkin Hill and Hillier Hopkins. However, confirmation from Lord Hopkin Hill is requested.

Hopkin Smart Consulting Ltd.

There are three identities for Hopkin Smart Consulting Ltd:

• “HOPKIN SMART CONSULTING LTD

  Total number of appointments 3

  21 Hazelwood Road, Duffield, Belper, England, DE56 4DP

  • Total number of appointments 3

  • TPBA WD3 LLP (OC427257) Company status Active Correspondence address 21 Hazelwood Road, Duffield, Belper, England, DE56 4DP Role Active LLP Member Appointed on 26 March 2021 UK Limited Company Registration number 09552897 Active — Active proposal to strike off

  • TPBA ISP CALVERTON LLP (OC426704)Company status Active Correspondence address 1 Astell Street, London, England, SW3 3RX Role Active LLP Member Appointed on 1 April 2020 Active — Active proposal to strike off

  • TPBA WD2 LLP (OC422476) Company status Active Correspondence address 1 Astell House, Astell Street, Chelsea, London, England, SW3 3RX Role Active LLP member Appointed on 18 July 2018 Active — Active proposal to strike off”

Corporate person 3b

• “HOPKIN SMART CONSULTING LTD

  Total number of appointments 10

  21 Hazelwood Road, Duffield, Belper, Derbyshire, United Kingdom, DE56 4DP

  • TPBA WD5 LLP (OC453270) Active Registered office address 4 Edison Village, Nottingham, United Kingdom, NG7 2RF Incorporated on 5 August 2024 14 officers / 0 resignations”

Corporate person 3c

• “HOPKIN SMART CONSULTING LTD

  Total number of appointments 1

  21 Hazelwood Road, Duffield, Belper, Derbyshire, United Kingdom, DE56 4DP

  • This page cannot be found”

The records for the third identity of Hopkin Smart Consulting Ltd are suppressed and can not be viewed by the public. This suppression of a record can only be enabled by Companies House, this implies cooperation from Companies House in concealing this record. Clarification of why this has occurred is requested.

Hopkin Smart Consulting Limited have established three unique identities in breach of section 1082 (CA2006), compromising audits and KYC checks associated to them.

The records for the company that owns these three corporate identities was located in a search, HOPKIN SMART CONSULTING LTD - Find and update company information - GOV.UK (https://find-and-update.company-information.service.gov.uk/search/companies?q=HOPKIN+SMART+CONSULTING+LTD):

“HOPKIN SMART CONSULTING LTD Company number 09552897 Registered office address 21 Hazelwood Road, Duffield, Belper, Derbyshire, England, DE56 4DP Company status Active Company type Private limited Company Incorporated on 21 April 2015 Accounts Next accounts made up to 31 March 2024
due by 31 December 2024 Last accounts made up to 31 March 2023 Confirmation statement Up to date Next statement date 21 April 2025 due by 5 May 2025 Last statement dated 21 April 2024 Nature of business (SIC) 70221 - Financial management

3 officers / 1 resignation

HOPKIN, Nicholas Correspondence address 22 Holloway Road, Duffield, Belper, Derbyshire, England, DE56 4FE Role Active Director Date of birth December 1955 Appointed on 21 April 2015 Nationality British Country of residence England Occupation Company director

STIMPSON, Holly Louise Correspondence address 22 Holloway Road, Duffield, Belper, Derbyshire, England, DE56 4FE Role Active Director Date of birth May 1985 Appointed on 21 April 2015 Nationality British Country of residence England Occupation Company Director

HOPKIN, Benjamin James Correspondence address 21 Hazelwood Road, Duffield, Belper, Derbyshire, England, DE56 4DP Role Resigned Secretary Appointed on 18 July 2022 Resigned on 17 October 2022”

Testing the directors of Hopkin Smart Consulting Limited for multiple identities.

Nicholas Hopkin

A search on this name locates multiple identities with clusters of the same date of birth, December 1955 Nicholas HOPKIN - Find and update company information - GOV.UK (company-information.service.gov.uk). The identities returned are:

• “1. Nicholas HOPKIN

  Total number of appointments 1 - Born December 1955

  2 Leman Street, London, United Kingdom, E1W 9US

• 2. Nicholas HOPKIN

  Total number of appointments 5 - Born December 1955

  9 Riverside Court, Pride Park, Derby, Derbyshire, DE24 8JN

• 3. Nicholas HOPKIN

  Total number of appointments 1 - Born December 1955

  22 Holloway Road, Duffield, Belper, Derbyshire, England, DE56 4FE

• 5. Nicholas HOPKIN

  Total number of appointments 0 - Born December 1955

  Glydwish Hall, Fontridge Lane, Burwash, East Sussex, TN19 7DG

• 6. Nicholas HOPKIN

  Total number of appointments 2 - Born December 1955

  Pricewaterhousecoopers Llp, 1 Embankment Place, London, WC2N 6RH

• 7. Nicholas HOPKIN

  Total number of appointments 0 - Born December 1955

  Glydwish Hall, Fontridge Lane, Burwish, East Sussex, England, TN19 7DG

• 9. Nicholas HOPKIN

  Total number of appointments 1 - Born December 1955

  9 Riverside Court, Pride Park, Derby, England, DE24 8JN

• 10. Nicholas HOPKIN

  Total number of appointments 1 - Born December 1955

  C/O Fladgate Llp, 16 Great Queen Street, London, United Kingdom, WC2B 5DG

• 11. Nicholas HOPKIN

  Total number of appointments 0 - Born December 1955

  9 Riverside Court, Pride Park, Derby, Derbyshire, England

• 12. Nicholas HOPKIN

  Total number of appointments 2 - Born December 1955

  21 Hazelwood Road, Duffield, Belper, Derbyshire, England, DE56 4DP

• 13. Nicholas HOPKIN

  Total number of appointments 1 - Born December 1955

  Burley Grange, Burley Lane, Quarndon, Derby, England, DE22 5JR

• 14. Nicholas HOPKIN

  Total number of appointments 2 - Born December 1955

  16 Tedworth Square, Chelsea, London, SW3 4DY

• 15. Nicholas HOPKIN

  Total number of appointments 1 - Born December 1955

  22 Holloway Road, Duffield, Belper, Derbyshire, United Kingdom, DE56 4FE

• 16. Nicholas HOPKIN

  Total number of appointments 4 - Born December 1955

  4 Edison Village, Nottingham, United Kingdom, NG7 2RF

• 17. Nicholas HOPKIN

  Total number of appointments 1 - Born December 1955

  12 Plumtree Court, London, EC4A 4HT

• 18. Nicholas HOPKIN

  Total number of appointments 1 - Born December 1955

  The Manor House, Flowborough, Nottingham, Nottinghamshire

• 19. Nick HOPKINS

  Matching appointment names:
  Nicholas HOPKIN

  Total number of appointments 3 - Born December 1955

  The Manor House, Flawborough, Nottinghamshire”

• Nicholas John HOPKIN

  Total number of appointments 1 - Born September 1973

  11 Lurke Street, Bedford, Bedfordshire, MK40 3HZ

• Nicholas John HOPKIN

  Total number of appointments 7 - Born September 1973

  The Old Grange, Warren Estate, Writtle, Chelmsford, Essex, CM1 3WT

There are 19 identities registered for Nicholas Hopkin, born December 1955, this is a breach of section 1082 of the Companies Act 2006. A sample, only, of his identities are expanded below:

Nicholas HOPKIN identity 1

Total number of appointments 1 - Born December 1955

2 Leman Street, London, United Kingdom, E1W 9US

“DEAUVILLE SECURITIES LIMITED (01067007) Company status Active Correspondence address 2 Leman Street, London, United Kingdom, E1W 9US Role Active Director Appointed on 13 August 2018 Nationality English Country of residence England Occupation Financial Consultant Nature of business (SIC) 41100 - Development of building projects”

Nicholas HOPKIN identity 2

Total number of appointments 5 - Born December 1955

9 Riverside Court, Pride Park, Derby, Derbyshire, DE24 8JN

“Total number of appointments 5

Date of birth December 1955

NO. 3 PRIDE PLACE LLP (OC308390) Company status Active Correspondence address 9 Riverside Court, Pride Park, Derby, Derbyshire, DE24 8JN Role Active LLP Designated Member Appointed on 30 March 2020 Country of residence England

CHEVIN HOMES (ASHBOURNE) LIMITED (11118204) Company status Liquidation Correspondence address The Mills, Canal Street, Derby, Derbyshire, DE1 2RJ Role Active Director Appointed on 27 February 2018 Nationality British Country of residence England Occupation Accountant

ARK CAPITAL LIMITED (05077241) Company status Liquidation Correspondence address Ashcroft House, Ervington Court, Meridian Busness (sic) Park, Leicestershire, LE19 1WL Role Active Director Appointed on 10 July 2017 Nationality British Country of residence England Occupation Chartered Accountant 1 Insolvency case Practitioner Nathan Jones and John Anthony Lowe Ashcroft House Ervington Court, Meridian Business Park, Leicester, Leicestershire, LE19 1WL Appointed on 28 January 2022 Accounts overdue Next accounts made up to 31 December 2021 due by 30 September 2022 Last accounts made up to 31 December 2020 Confirmation statement overdue Next statement date 18 March 2022 due by 1 April 2022 Last statement dated 18 March 2021 Nature of business (SIC) 70100 - Activities of head offices Previous company names HALO INVESTMENTS LIMITED 08 Oct 2004 - 11 Nov 2004 EDGER 372 LIMITED 18 Mar 2004 - 08 Oct 2004

ARK CAPITAL FINANCE LIMITED (10792562) Company status Liquidation Correspondence address Ashcroft House, Ervington Court, Meridian Business Park, Leicester, LE19 1WL Role Active Director Appointed on 26 May 2017 Nationality British Country of residence England Occupation Chartered Accountant Incorporated on 26 May 2017 Accounts overdue RED FLAG Next accounts made up to 31 December 2020 due by 30 September 2021 Last accounts made up to 31 December 019 Confirmation statement overdue RED FLAG Next statement date 25 May 2022 due by 8 June 2022 Last statement dated 25 May 2021 Nature of business (SIC) 70221 - Financial management

ARK CAPITAL INVESTMENTS LIMITED (10757714) Company status Active Correspondence address 16 Great Queen Street, London, England, WC2B 5DG Role Active Director Appointed on 8 May 2017 Nationality British Country of residence England Occupation Chartered Accountant 1 charge registered 1 outstanding, 0 satisfied, 0 part satisfied Charge code 1075 7714 0001 Created 30 May 2017 Delivered 15 June 2017 Status Outstanding Persons entitled Ubs Ag, London Branch Brief description Contains fixed charge…”

This record details the second identity for Nicholas Hopkin, born December 1955, with a total of 5 appointments. This identity is potentially associated with Hopkin Smart Consulting Limited and is being investigated for a possible connection to Lord Hopkin Hill, director of Alliance for Responsible Citizenship Limited. Key points include:

1. Active Appointments:

   • NO. 3 PRIDE PLACE LLP (OC308390): Active LLP Designated Member

   • CHEVIN HOMES (ASHBOURNE) LIMITED (11118204): Active Director (company in liquidation)

   • ARK CAPITAL LIMITED (05077241): Active Director (company in liquidation)

   • ARK CAPITAL FINANCE LIMITED (10792562): Active Director (company in liquidation)

   • ARK CAPITAL INVESTMENTS LIMITED (10757714): Active Director

2. Compliance Issues:

   • ARK CAPITAL LIMITED: Accounts and confirmation statement overdue

   • ARK CAPITAL FINANCE LIMITED: Accounts and confirmation statement overdue

3. "ARK" Naming Pattern:
   Three of the five companies associated with this identity contain "ARK" in their names, which aligns with other "ARK" references in the broader report, directorships of Sir Paul Marshall, who is also a director of Alliance for Responsible Citizenship Limited, such as:

   • Absolute Return for Kids (ARK)

   • ARK Academies Projects Limited

   • ARK Schools

   • ARK UK Programmes

4. Financial Connections:
   ARK CAPITAL INVESTMENTS LIMITED has an outstanding charge to UBS AG, London Branch, which will be further investigated.

5. Occupation:
   Nicholas Hopkin is listed as a Chartered Accountant or Accountant in multiple appointments.

While there is no direct address association between Hopkin's and Marshall's ARK companies, the use of "ARK" in the company names and their presence in London suggests a potential connection that warrants further investigation especially in relation to the possible association with Lord Hopkin Hill.

Note that ARK CAPITAL INVESTMENTS LIMITED has a charge outstanding to the benefit of UBS Ag, London Branch.

UBS Ag

A search on Ubs Ag locates the following company records (Ubs Ag - Find and update company information https://find-and-update.company-information.service.gov.uk/search/companies?q=Ubs+Ag).

• “UBS AG

  OE013351 - Registered on 16 January 2023

  1 Aeschenvorstadt, Basel, Switzerland, 4051

• UBS AG

  FC021146 - First UK establishment opened on 12 June 1998

  Aeschenvorstadt 1, 4051 Basel, Switzerland, Switzerland

• UBS AG LONDON BRANCH

  BR004507 - Opened on 12 June 1998

  5 Broadgate, London, EC2M 2QS

• UBS BUSINESS SOLUTIONS AG

  OE013320 - Registered on 16 January 2023

  45 Bahnhofstrasse, Zurich, Switzerland, 8001

• GOLDMAN SACHS FINANCE LIMITED

  Matching previous names:
  UBS GROUP AG

  14695023 - Incorporated on 28 February 2023

  4385, 14695023 - COMPANIES HOUSE DEFAULT ADDRESS, Cardiff, CF14 8LH

• UBS BUSINESS SOLUTIONS AG

  FC034139 - First UK establishment opened on 1 March 2017

  45 Bahnhofstrasse, Zurich, Switzerland, 8001

• UBS BUSINESS SOLUTIONS AG, UK BRANCH

  BR019227 - Opened on 1 March 2017

  5 Broadgate, London, EC2M 2QS

• UBS GROUP AG LTD

  10035047 - Dissolved on 27 September 2016

  152-160 City Road, London, United Kingdom, EC1V 2NX

• UBS (D) CORE OPPORTUNITIES EUROPE

  OE022056 - Removed on

  16 Theatinerstr., Munich, Germany, 80333

• AHMA UBS LIMITED

  OE004733 - Registered on 22 November 2022

  23 Pier Road, St Helier, Jersey, JE2 4XW”

Duplications in UBS AG Company Registrations

Based on data from Companies House, the following company names have been registered more than once, raising red flags for breaches of Section 66 of the Companies Act 2006, “Name not to be the same as another in the index”.

Variations of the same address are evident, in breach of Section 86 “Duty to ensure registered office at appropriate address” of the Companies Act 2006 :

1. UBS AG

   • Registered as OE013351 on 16 January 2023. Breach S66(CA2006) as it is the same name as the first UBS AG opened as FC021146 on 12 June 1998.

   • Address variation noted between "1 Aeschenvorstadt, Basel, Switzerland, 4051" and "Aeschenvorstadt 1, 4051 Basel, Switzerland, Switzerland." Breach S86(CA2006)

2. UBS BUSINESS SOLUTIONS AG

   • Registered as OE013320 on 16 January 2023, this breach 66(CA2006) as this is the same name as the first UBS BUSINESS SOLUTIONS AG opened as FC034139 on 1 March 2017.

3. UBS GROUP AG LTD

   • UBS GROUP AG is the name of dissolved company number 10035047, dissolved on 27 September 2016

   • UBS GROUP AG was the previous name of GOLDMAN SACHS FINANCE LIMITED 14695023 - Incorporated on 28 February 2023. This company, 14695023, breaches S66(CA2006) by registering with the same name as another in the index.

4. GOLDMAN SACHS FINANCE LIMITED

   • Previously named UBS GROUP AG, incorporated as company number 14695023 on 28 February 2023, suggesting a possible overlap or confusion with UBS-related entities. Breach S66(CA2006)

   • Use of Companies House default address (4385, COMPANIES HOUSE DEFAULT ADDRESS, Cardiff, CF14 8LH), which may indicate administrative oversight or lack of permanent establishment. Breach S86(CA2006).

These entries suggest that some company names or variations thereof may have been registered multiple times or with address inconsistencies, which could potentially breach Sections 66 and 48 of the Companies Act 2006.

UBS AG company 1

There are two companies registered with the name UBS AG. This breaches Section 66 of the Companies Act 2006. Variations in an address cause false non-match errors in audit software.

• UBS AG

  OE013351 - Registered on 16 January 2023

  1 Aeschenvorstadt, Basel, Switzerland, 4051

• UBS AG

  FC021146 - First UK establishment opened on 12 June 1998

  Aeschenvorstadt 1, 4051 Basel, Switzerland, Switzerland

Further investigation is required. The records for these companies are copied below:

1. UBS AG

   OE013351 - Registered on 16 January 2023

   1 Aeschenvorstadt, Basel, Switzerland, 4051

UBS AG Company number OE013351 Correspondence address 5 Broadgate, London, England, EC2M 2QS Company status Registered Company type Overseas entity Registered on 16 January 2023 Annual statement Next statement date 15 January 2025 due by 29 January 2025 Last statement dated 15 January 2024 Company details in the country of incorporation Overseas entity address 1 Aeschenvorstadt, Basel, Switzerland, 4051 Incorporated in SWITZERLAND Registration number CHE-101.329.561 Legal form Limited By Shares Parent registry Commerical (sic) Register Of Canton Basel-Stadt,Switzerland (sic) Governing law Swiss Law There are no officer details available for this company. 1 active beneficial owner / 2 active statements

Statement Active All beneficial owners have been identified and all required information can be provided Notified on 15 January 2024 Statement Active

Nobody has become or ceased to be a beneficial owner during the update period

Notified on15 January 2024 Ubs Group Ag Active Correspondence address 45 Bahnhofstrasse, Zurich, Switzerland, 8001 Principal office address 45 Bahnhofstrasse, Zurich, Switzerland, 8001 Notified on 26 November 2014 Governing law Swiss Law Legal form Limited By Shares Place registered Commerical (sic) Register Of Canton Zurich Registration number Che-395.345.924 Nature of control Ownership of shares - more than 25% Ownership of voting rights - More than 25%

There are errors in the name of the Parent Registry, “Commerical”, a spelling error, and "Basel-Stadt,Switzerland” a grammatical error. Legal documents must not contain errors. This is a breach of the Companies Act 2006.

There are no officer details available for this company, this is a breach of the Companies Act which requires at least one director that is a real person. This is a breach of the Companies Act 2006.

Registration of an overseas entity

The Registration Document, dated 9 Feb 2024, is available as a downloadable document via the “filing history”, this provides the following information:

“(Page 1) Application to register an Overseas Entity

Received for filing in Electronic Format on the: 13/01/2023 Breach - Delay of over a year before filing with Companies House on 9 Feb 2024) Section 441 breach of the Companies Act 2006

• Overseas Entity Name: UBS AG

• County Of Incorporation: Switzerland

• Identity of Register: COMMERICAL (sic) REGISTER OF CANTON BASEL-STADT,SWITZERLAND (sic)

• Registration Number CHE-101.329.561

• Overseas Entity Address: 1 AESCHENVORSTADT BASEL Switzerland 4051

• Service Address: 5 BROADGATE LONDON England EC2M 2QS

(Page 2) Due Diligence Agent Details

• Anti Money Laundering Number: XNML00000112346

• Name of person with overall responsibility: Nicholas Lindsay

• Supervisory Body: HMRC

• Agents Name: Elemental Cosec Limited

• Agents Address: 27 Old Gloucester Street London, England WC1N 3AX

(Page 4) Other Legal Entity (OLE) Beneifical (sic) Owner details

• Company name: UBS Group AG

• Sanctioned when registered: No

• Service Address: 45 BAHNHOFSTRASSE ZURICH SWITZERLAND 8001

• Principal / business address 45 BAHNHOFSTRASSE ZURICH SWITZERLAND 8001

• Legal form Limited By Shares

• Governing law Swiss Law

• Register location: Commerical (sic) Register Of Canton Zurich

• Registration number: Che-395.345.924

• Nature of control The person holds, directly or indirectly, more than 25% of shares in the entity.

• Nature of control The person holds, directly or indirectly, more than 25% of the voting rights in the entity.”

Breaches: The misspelling as “Beneficial” is an error that breaches the Companies Act 2006 which requires accurate information is registered.

The errors noted above, in the Companies House record, “Commerical”, and "Basel-Stadt,Switzerland” originate in this registration document. Two breaches of the Companies Act which requires accurate information.

UBS AG company 2

• UBS AG

  FC021146 - First UK establishment opened on 12 June 1998

  Aeschenvorstadt 1, 4051 Basel, Switzerland, Switzerland

“Company type Overseas company

First UK establishment opened on 12 June 1998

This company is a credit/financial institution

Accounts (Up to date) Required to publish accounts from 1 January to 31 December within 3 months under parent law Last accounts made up to 31 December 2023

Company details in the country of incorporation Incorporated in SWITZERLAND Registration number CHE-101.329.561 Legal form Ag (Public Limited Company) Parent registry Register Of Commerce Of The Canton Of Zurich & Register Governing law Swiss Code Of Obligations Of 30 March 1991 As Amended Objects of the company Operation of a bank

UK establishments: 1 UK establishments 1 open, 0 closed UBS AG LONDON BRANCH BR004507 London Status open

Charges 30 charges registered 16 outstanding, 14 satisfied (Outstanding charges summarised):

• Etfs Commodity Securities Limited

  Created: 5 August 2009

• Jpmorgan Chase Bank, N.A., London Branch

  Created: 8 December 2008

• Edelweiss Master Trust (two entries)

  Created: 25 November 2008

• Bluematrix Master Fund Limited

  Created: 19 September 2008

• Bluecrest Venture Finance Master Fund Limited

  Created: 19 September 2008

• Bluetrend 2X Leveraged Master Fund Limited

  Created: 18 September 2008

• Bluecrest Strategic Limited

  Created: 18 September 2008

• Abc Ma Limited Created: 18 September 2008

• Bluetrend Mag Limited Created: 18 September 2008

• Bluecrest Capital International Master Fund Limited Created: 18 September 2008

• Bluehaven Master Fund Limited

  Created: 18 September 2008

• Bluecrest Emerging Markets Master Fund Limited

  Created: 18 September 2008

• Bluetrend Master Fund Limited

  Created: 18 September 2008

• The Bank of New York Created: 26 September 2007”

Further analysis is required.

Labour Together Limited, a potential related party of Alliance for Responsible Citizenship Limited:

Director of Labour Together Limited, Lord Jonathan Andrew KESTENBAUM, is also an active director of JPMORGAN JAPANESE INVESTMENT TRUST PLC.

Correlation between Compliance Assessment on Sir Paul Marshall, Alan McCormick, Lord Hill and Oliver Plunkett, of Alliance for Responsible Citizenship Limited (ARC) based on “JPMorgan” and Compliance Assessment on Labour Together Limited

https://alisonwright.substack.com/p/labour-together-limited-bbc-radio

Labour Together Limited: BBC Radio 4's topical comedy reveals a potential constitutional compromise and covers it with laughter.

Potential association between Labour Together Limited and Alliance for Responsible Citizenship Limited directors via JPMORGAN JAPANESE INVESTMENT TRUST PLC and Jpmorgan Chase Bank, N.A., London Branch, which has a charge over UBS AG (FC021146). “Ubs Ag, London Branch” has a charge over ARK CAPITAL INVESTMENTS LIMITED (10757714) as described in Appendix E.

UBS Group AG

UBS Group AG is a name that is currently used by company number has been

Entering the record for UBS AG London Branch:

“UBS AG LONDON BRANCH UK establishment number BR004507 UK establishment office address 5 Broadgate, London, EC2M 2QS Status Open Opened on 12 June 1998 Type of business Universal Banking This is a UK establishment of UBS AG Company number FC021146.

ARK Capital Investments Limited has charges outstanding to the benefit of “Ubs Ag, London Branch” a company which is involved in multiple breaches of the Companies Act.

Breaches of the Companies Act 2006

1. Multiple Registrations (Section 66)

   • UBS AG registered multiple times under different company numbers

   • UBS BUSINESS SOLUTIONS AG registered multiple times

   • UBS GROUP AG registered multiple times

2. Address Inconsistencies (Section 86)

   • Variations in address formatting for UBS AG

   • Use of Companies House default address for GOLDMAN SACHS FINANCE LIMITED (previously UBS GROUP AG)

3. Information Accuracy (Section 1112)

   • Spelling errors in official documents ("Commerical" instead of "Commercial")

   • Grammatical errors in company records ("Basel-Stadt,Switzerland")

4. Officer Details (Section 162)

   • No officer details available for UBS AG (OE013351)

5. Filing Delays (Section 441)

   • Delay of over a year in filing registration documents for UBS AG (OE013351)

Additional Concerns

• Potential clone company fraud due to multiple registrations of similar names

• Risk of false non-match errors in audit software due to address variations

• Lack of transparency in company structures and relationships

• Potential for money laundering or other financial misconduct due to complex corporate structures

Recommendations

1. Conduct a thorough investigation into the UBS AG group of companies and their registrations

2. Require immediate correction of all inaccuracies in company records

3. Enforce compliance with the Companies Act 2006, particularly regarding unique company names and accurate address information

4. Review and strengthen the process for registering overseas entities to prevent similar issues in the future

5. Consider the implications of these breaches for financial regulations and anti-money laundering efforts

These conclusions highlight significant non-compliance issues and potential risks associated with the UBS AG group of companies, warranting further regulatory scrutiny and corrective action.

Continuing, looking into some of Nicholas Hopkin’s other identities:

Nicholas HOPKIN identity 3

Total number of appointments 1 - Born December 1955

22 Holloway Road, Duffield, Belper, Derbyshire, England, DE56 4FE

Nicholas HOPKIN identity 4

Total number of appointments 0 - Born December 1955

Glydwish Hall, Fontridge Lane, Burwash, East Sussex, TN19 7DG

Nicholas HOPKIN identity 5

Total number of appointments 2 - Born December 1955

Pricewaterhousecoopers Llp, 1 Embankment Place, London, WC2N 6RH

• MOLE FILMS LLP (OC308204) Active member Appointed 4 February 2005 Registered address Parcels Building, 14 Bird Street, London United Kingdom W1U 1BU 98 Officers 8 resignations Charges outstanding to Clydesdale Bank PLC

• PRICEWATERHOUSECOOPERS LLP (OC202525) Appointed on 31 December 2002 Resigned on 30 June 2016 2369 officers 1304 resignations 1 active person with significant control Marco Amitrano Notified on 1 July 2024 Date of birth November 1969 Right to appoint and remove members

Refer to Appendix D for analysis related to PricewaterhouseCoopers LLP.

Further analysis of the remaining identities for Nicholas Hopkin is required:

Nicholas HOPKIN identity 6

Total number of appointments 0 - Born December 1955

Glydwish Hall, Fontridge Lane, Burwish, East Sussex, England, TN19 7DG

Nicholas HOPKIN

Total number of appointments 1 - Born December 1955

9 Riverside Court, Pride Park, Derby, England, DE24 8JN

Nicholas HOPKIN

Total number of appointments 1 - Born December 1955

C/O Fladgate Llp, 16 Great Queen Street, London, United Kingdom, WC2B 5DG

Nicholas HOPKIN

Total number of appointments 0 - Born December 1955

9 Riverside Court, Pride Park, Derby, Derbyshire, England

Nicholas HOPKIN

Total number of appointments 2 - Born December 1955

21 Hazelwood Road, Duffield, Belper, Derbyshire, England, DE56 4DP

Nicholas HOPKIN

Total number of appointments 1 - Born December 1955

Burley Grange, Burley Lane, Quarndon, Derby, England, DE22 5JR

Nicholas HOPKIN

Total number of appointments 2 - Born December 1955

16 Tedworth Square, Chelsea, London, SW3 4DY

Nicholas HOPKIN

Total number of appointments 1 - Born December 1955

22 Holloway Road, Duffield, Belper, Derbyshire, United Kingdom, DE56 4FE

Nicholas HOPKIN

Total number of appointments 4 - Born December 1955

4 Edison Village, Nottingham, United Kingdom, NG7 2RF

Nicholas HOPKIN

Total number of appointments 1 - Born December 1955

12 Plumtree Court, London, EC4A 4HT

Nicholas HOPKIN

Total number of appointments 1 - Born December 1955

The Manor House, Flowborough, Nottingham, Nottinghamshire

Nick HOPKINS

Matching appointment names:
Nicholas HOPKIN

Total number of appointments 3 - Born December 1955

The Manor House, Flawborough, Nottinghamshire”

“Nicholas John HOPKIN

Total number of appointments 1 - Born September 1973

11 Lurke Street, Bedford, Bedfordshire, MK40 3HZ

Nicholas John HOPKIN

Total number of appointments 7 - Born September 1973

The Old Grange, Warren Estate, Writtle, Chelmsford, Essex, CM1 3WT”

Queries: Is Lord Hill a related party of any of: Benjamin James Hopkin, Holly Louis Stimpson, Nicholas Hopkin or Hopkin Smart Computing?

Is there any association between Hopkin Smart Consulting Ltd and Smart Move Construction Limited, Smart Move Sales and Lettings Ltd, or other “Smart Move” companies?

Appendix C

Lord Hill of Oareford Conservative Life Peer. Register of interests House of Lords.

“Nil

• Interest deleted 25 November 2016 Formerly on leave of absence; exempt from registration until 10 November 2016 (originally added 30 October 2014)

Category 1: Directorships

• Interest deleted 6 March 2023 Independent National Director, Times Newspapers (interest ceased 3 March 2022) (originally added 30 March 2017)

Category 2: Remunerated employment, office, profession etc.

• Interest deleted 30 October 2014 In receipt of ministerial salary (originally added 2 June 2010)

• Interest deleted 7 March 2023 Occasional speaking engagements via Chartwell Speakers and Literary Agency (originally added 25 November 2016)

• Interest deleted 20 November 2017 Speaking engagement, 16 November 2016, EFAMA Investment Management Forum, organised through Chartwell Speakers and Literary Agency (originally added 25 November 2016)

• Interest deleted 21 February 2019 The Member receives a transitional allowance from the European Commission in his capacity as a former
  Commissioner (the Member ceased to be European Commissioner on 15 July 2016) (interest ceased 20 February 2018) (originally added 25 November 2016)

• Interest deleted 8 December 2017 Speaking engagement, 5 December 2016, RiskMinds International Conference, Amsterdam (originally added 20 December 2016)

• Interest deleted 1 February 2018 Speaking engagement, 24 January 2017, Simmons & Simmons, London (originally added 29 January 2017)

• Interest deleted 2 March 2018 Speaking engagement, 1 March 2017, Matheson, London (originally added 16 March 2017)

• Interest deleted 22 February 2018 Speaking engagement, 21 February 2017, Bank of America Merrill Lynch, London, organised through Chartwell Speakers and Literary Agency (originally added 18 March 2017)

• Interest amended 30 March 2017 Senior Adviser, Freshfields Bruckhaus Deringer (multinational law firm) (originally added 30 March 2017)

• Interest deleted 23 March 2018 Speaking engagement, 22 March 2017, Bank of America Merrill Lynch, London, organised through Chartwell Speakers and Literary Agency (originally added 30 March 2017)

• Interest deleted 26 March 2018 Speaking engagement, 24 March 2017, Deutsche Bank, Fleet, organised through Chartwell Speakers and Literary Agency (originally added 30 March 2017)

• Interest deleted 5 April 2018 Speaking engagement, 29 March 2017, OMFIF, Frankfurt, organised through Chartwell Speakers and Literary Agency (originally added 30 March 2017)

• Interest deleted 6 April 2018 Speaking engagement, 5 April 2017, GSAM Symposium, New York, organised through Chartwell Speakers and Literary Agency (originally added 2 May 2017)

• Interest deleted 25 April 2018 Speaking engagement, 24 April 2017, Freuds, London, organised through Chartwell Speakers and Literary Agency (originally added 2 May 2017)

• Interest deleted 14 May 2018 Speaking engagement, 11 May 2017, Deutsche Bank, London, organised through Chartwell Speakers and Literary Agency (originally added 15 May 2017)

• Interest deleted 14 May 2018 Speaking engagement, 12 May 2017, PEIF, London, organised through Chartwell Speakers and Literary Agency (originally added 15 May 2017)

• Interest deleted 21 May 2018 Speaking engagement, 18 May 2017, BNP EBEC Forum, Brussels, organised through Chartwell Speakers and Literary Agency (originally added 29 May 2017)

• Interest deleted 25 May 2018 Speaking engagement, 24 May 2017, Danish Pension Association, Copenhagen, organised through Chartwell Speakers and Literary Agency (originally added 29 May 2017)

• Interest deleted 12 June 2018 Speaking engagement, 5 June 2017, GS Macro Conference, organised through Chartwell Speakers and Literary Agency (originally added 17 July 2017)

• Interest deleted 12 June 2018 Speaking engagement, 8 June 2017, M200 Association, Rome, Italy, organised through Chartwell Speakers and Literary Agency (originally added 17 July 2017)

• Interest deleted 22 June 2018 Speaking engagement, 19 June 2017, Aviva, Lucknam Park, organised through Chartwell Speakers and Literary Agency (originally added 17 July 2017)

• Interest deleted 31 July 2018 Speaking engagement, 26 July 2017, Jane Street Capital, London, organised through Chartwell Speakers and Literary Agency (originally added 6 September 2017)

• Interest deleted 9 October 2018 Speaking engagement, 22 September 2017, St James's Place, Venice, organised through Chartwell Speakers and Literary Agency (originally added 9 October 2017)

• Interest deleted 9 October 2018 Speaking engagement, 28 September 2017, BVI, Frankfurt, organised through Chartwell Speakers and Literary Agency (originally added 9 October 2017)

• Interest deleted 9 October 2018 Speaking engagement, 5 October 2017, Hayfin Capital, London, organised through Chartwell Speakers and Literary Agency (originally added 9 October 2017)

• Interest deleted 9 October 2018 Speaking engagement, 6 October 2017, Institutional Investor, Milan, organised through Chartwell Speakers and Literary Agency (originally added 9 October 2017)

• Interest deleted 18 October 2018 Speaking engagement, 17 October 2017, Financial Services Summit, Dublin, organised through Chartwell Speakers and Literary Agency (originally added 24 October 2017)

• Interest deleted 29 October 2018 Speaking engagement, 26 October 2017, World Pension Summit, The Hague, organised through Chartwell Speakers and Literary Agency (originally added 15 November 2017)

• Interest deleted 13 November 2018 Speaking engagement, 2 November 2017, Aviva NED Conference, London, organised through Chartwell Speakers and Literary Agency (originally added 15 November 2017)

• Interest deleted 15 November 2017 Speaking engagement, 8 November 2017, EY partner development conference, Dublin, organised through Chartwell Speakers and Literary Agency (originally added 15 November 2017)

• Interest deleted 13 November 2018 Speaking engagement, 7 November 2017, KPMG Global Real Estate Leadership conference, London, organised through Chartwell Speakers and Literary Agency (originally added 15 November 2017)

• Interest deleted 13 November 2018 Speaking engagement, 8 November 2017, EY partner development conference, Dublin, organised through Chartwell Speakers and Literary Agency (originally added 15 November 2017)

• Interest deleted 22 November 2018 Speaking engagement, 15 November 2017, European Fund and Asset Management Association (EFAMA) conference, Brussels, organised through Chartwell Speakers and Literary Agency (originally added 27 November 2017)

• Interest deleted 28 November 2018 Speaking engagement, 22 November 2017, J P Morgan Best of British conference, London, organised through Chartwell Speakers and Literary Agency (originally added 27 November 2017)

• Interest deleted 29 November 2018 Speaking engagement, 28 November 2017, Bank Governance Leadership Network, London, organised through Chartwell Speakers and Literary Agency (originally added 18 December 2017)

• Interest deleted 28 January 2019 Speaking engagement, 26 January 2018, St James's Place, London (originally added 20 February 2018)

• Interest amended 2 March 2018 Member, International Panel of Experts, Iberdrola (electricity) (originally added 2 March 2018)

• Interest deleted 5 September 2023 Senior Adviser, Deloitte (professional services network) (interest ceased 31 August 2022) (originally added 29 March 2018)

• Interest deleted 3 November 2021 Senior Adviser, Aviva plc (insurance) (interest ceased 31 October 2020) (originally added 5 April 2018)

• Interest deleted 26 April 2019 Speaking engagement, 10 April 2018, Salone del Risparmio, Milan, organised through Chartwell Speakers and Literary Agency (originally added 23 April 2018)

• Interest deleted 26 April 2019 Speaking engagement, 11 April 2018, EBEC Forum, Brussels, organised through Chartwell Speakers and Literary Agency (originally added 23 April 2018)

• Interest deleted 14 May 2019 Speaking engagement, 9 May 2018, ISBA conference, Brighton, organised through Chartwell Speakers and Literary Agency (originally added 23 May 2018)

• Interest deleted 21 May 2019 Gatehouse Advisory Partners Ltd, 3 round table discussions on 26 April 2018, 8 May 2018 and 15 May 2018 (originally added 23 May 2018)

• Interest deleted 4 July 2022 Senior Adviser, UBS Group AG (financial services) (interest ceased 30 June 2021) (originally added 23 May 2018)

• Interest amended 25 October 2018 Senior Adviser, Intercontinental Exchanges Inc (owner of exchanges and clearing houses for financial and commodity markets) (originally added 25 October 2018)

• Interest amended 13 December 2018 Adviser, Banco Santander SA (originally added 13 December 2018)

• Interest deleted 9 April 2020 Speaking engagement, 19 March 2019, Cinven Partners, London (originally added 26 March 2019)

• Interest deleted 9 April 2020 Speaking engagement, 21 March 2019, Credit Agricole, London (organised through Chartwell Speakers and Literary Agency) (originally added 26 March 2019)

• Interest amended 9 May 2019 Senior Independent Director, HM Treasury (post is remunerated but this will be donated to charity) (originally added 9 May 2019)

• Interest deleted 27 November 2020 Speaking engagement, 26 November 2019, BPFI, Dublin (originally added 4 December 2019)

• Interest deleted 4 December 2020 Speaking engagement, 3 December 2019, EastMed-London Investment Summit, Economist, London (organised through Chartwell Speakers and Literacy Agency) (originally added 4 December 2019)

• Interest deleted 18 September 2021 Speaking engagement, 15 September 2020, virtual event for Greenbrook (originally added 8 October 2020)

• Interest deleted 18 December 2021 Speaking engagement, 8 December 2020, virtual event for S&P Global (financial information and analytics) (originally added 7 January 2021)

• Interest amended 28 February 2024 Strategic Business Adviser, W1TTY Tech Ltd (fintech start-up) (interest ceased 1 February 2024) (originally added 22 June 2021)

• Interest deleted 4 May 2023 Strategic advice, The Proof of Trust (tech start up offering contract assurance) (interest ceased 30 April 2022) (originally added 5 July 2021)

• Interest amended 12 August 2021 Strategic advice, VISA Europe (global payments company) (originally added 12 August 2021)

• Interest deleted 4 April 2024 Strategic advice, Royal Mail Group plc (postal service company) (interest ceased 31 March 2023) (originally added 2 September 2021)

• Interest deleted 17 November 2022 Speaking engagement, 15 November 2021, Economist Conference, Nicosia (arranged through Chartwell Speakers and Literary Agency) (originally added 29 November 2021)

• Interest deleted 7 December 2022 Speaking engagement, 25 November 2021, LPeC dinner, London (originally added 29 November 2021)

• Interest deleted 4 April 2024 Speaking engagement, 28 March 2023, Global Investment Management Summit, London (arranged through Chartwell Speakers) (originally added 18 April 2023)

• Interest deleted 18 April 2023 Speaking engagement, 28 March 2023, Global Investment Management Summit, London (arranged through Chartwell Speakers) (originally added 18 April 2023)

• Interest deleted 19 June 2024 Speaking engagement, 14 June 2023, at 27th Annual Global ABS, Barcelona (arranged through Chartwell Speakers) (originally added 17 July 2023)

• Interest amended 22 September 2023 Member, Advisory Board, VISA Economic Empowerment Institute (originally added 22 September 2023)

• Interest amended 4 April 2024 Speaking engagement, 12 March 2024, Greenbrook, London (originally added 4 April 2024)

• Interest amended 25 April 2024 Speaking engagement, 24 April 2024, Mayer Brown, London (arranged through Chartwell Speakers) (originally added 25 April 2024)

• Interest amended 20 June 2024 Strategic advice, Royal Mail Group plc (postal service company) (originally added 25 April 2024)

Category 4: Shareholdings (b)

• Interest deleted 30 October 2014 Huntsworth plc (international public relations business) (originally added 2 June 2010)

Category 5: Land and property

• Interest deleted 30 October 2014 Cottage in Hampshire from which rental income is received (originally added 2 June 2010)

• Interest deleted 1 May 2018 Cottage in Hampshire from which rental income is received (interest ceased 30 April 2017) (originally added 25 November 2016)

Category 10: Non-financial interests (a)

• Interest deleted 13 February 2024 Director, Prosperity UK (interest ceased 10 February 2023) (originally added 2 March 2018)

Category 10: Non-financial interests (b)

• Interest deleted 8 March 2022 Chair, The UK Listings Review (launched by the Chancellor on 19 November 2020 as part of a plan to strengthen the UK’s position as a leading global financial centre) (interest ceased 3 March 2021) (originally added 24 November 2020)

Category 10: Non-financial interests (e)

• Interest deleted 13 February 2024 Trustee, Teach First (interest ceased 9 February 2023) (originally added 16 March 2017)

• Interest amended 3 November 2017 Chairman (formerly Member) of the Council of Management, Ditchley Foundation (originally added 17 March 2017)

• Interest amended 15 May 2017 Board Member, Centre for Policy Studies (originally added 15 May 2017)

• Interest amended 28 February 2024 Trustee, Axiom Maths (formerly MESME) (charity which promotes maths education as route to social mobility) (originally added 30 August 2023).”

Appendix D

Nicholas HOPKIN identity 5

Total number of appointments 2 - Born December 1955

Pricewaterhousecoopers Llp, 1 Embankment Place, London, WC2N 6RH

• MOLE FILMS LLP (OC308204) Active member Appointed 4 February 2005 Registered address Parcels Building, 14 Bird Street, London United Kingdom W1U 1BU 98 Officers 8 resignations Charges outstanding to Clydesdale Bank PLC

• PRICEWATERHOUSECOOPERS LLP (OC202525) Appointed on 31 December 2002 Resigned on 30 June 2016 2369 officers 1304 resignations 1 active person with significant control Marco Amitrano Notified on 1 July 2024 Date of birth November 1969 Right to appoint and remove members

The record for PricewaterhouseCoopers LLP was accessed in Companies House (https://find-and-update.company-information.service.gov.uk/company/OC303525).

Company overview

“PRICEWATERHOUSECOOPERS LLP Registered office address 1 Embankment Place, London, WC2N 6RH Company status Active Company type Limited liability Partnership Incorporated on 9 December 2002 Accounts Next accounts made up to 30 June 2024 due by 31 March 2025 Last accounts made up to 30 June 2023 Confirmation statement Next statement date 8 December 2025 due by 22 December 2025 Last statement dated 8 December 2024

2369 officers / 1378 resignations

1 active person with significant control / 0 active statements

Marco Amitrano Active Correspondence address 1 Embankment Place, London, WC2N 6RH Notified on 1 July 2024 Date of birth November 1969 Nationality British Country of residence United Kingdom Nature of control Right to appoint or remove members”

Marco Amitrano, PSC of PricewaterhouseCoopers LLP Compliance assessment.

A search for “Marco Amitrano” in Companies House (https://find-and-update.company-information.service.gov.uk/search/officers?q=Marco%20Amitrano) locates three identities with this name and date of birth November 1969. The three identities reference the same correspondence address “1 Embankment Place, London, WC2N 6RH”.

• Marco AMITRANO

  Total number of appointments 1 - Born November 1969

  1 Embankment Place, London, WC2N 6RH

• Marco AMITRANO

  Total number of appointments 1 - Born November 1969

  1 Embankment Place, London, United Kingdom, WC2N 6RH

• Marco AMITRANO

  Total number of appointments 7 - Born November 1969

  1 Embankment Place, London, WC2N 6RH

These three unique identifiers for Marco Amitrano, date of birth November 1969 is prima facie evidence that Marco Amitrano breaches section 1082 of the Companies Act 2006 and has compromised audits breaching section 441 of the Companies Act 2006, for the period since he established his second identity. These three identities are expanded below with the records copied from Companies House:

• “Marco AMITRANO

  Total number of appointments 1 - Born November 1969

  1 Embankment Place, London, WC2N 6RH

  • This page cannot be found

• Marco AMITRANO

  Total number of appointments 1 - Born November 1969

  1 Embankment Place, London, United Kingdom, WC2N 6RH

  • This page cannot be found

• Marco AMITRANO

  Total number of appointments 7 - Born November 1969

  1 Embankment Place, London, WC2N 6RH

  • THE PWC FOUNDATION (07601963) Company status Active Correspondence address 1 Embankment Place, London, WC2N 6RH Role Active Director Appointed on 1 July 2024 Nationality British Country of residence United Kingdom Occupation Chartered Accountant

  • PWC EMEA LIMITED (09732210) Company status Active Correspondence address 1 Embankment Place, London, United Kingdom, WC2N 6RH Role Active Director Appointed on 1 July 2024 Nationality British Country of residence United Kingdom Occupation Chartered Accountant

  • PRICEWATERHOUSECOOPERS BUSINESS SERVICES LIMITED (12886828) Company status Active Correspondence address 1 Embankment Place, London, United Kingdom, WC2N 6RH Role Active Director Appointed on 17 September 2020 Nationality British Country of residence United Kingdom Occupation Head Of Clients And Markets

  • PWC HOLDINGS (UK) LIMITED (09146932) Company status Active Correspondence address 1 Embankment Place, London, United Kingdom, WC2N 6RH Role Active Director Appointed on 1 July 2020 Nationality British Country of residence United Kingdom Occupation Head Of Clients And Markets

  • PRICEWATERHOUSECOOPERS SERVICES LIMITED (00728502) Company status Active Correspondence address 1 Embankment Place, London, WC2N 6RH Role Active Director

    Appointed on 1 July 2020 Nationality British Country of residence United Kingdom Occupation Head Of Clients And Markets

  • PRICEWATERHOUSECOOPERS LLP (OC303525) Company status Active Correspondence address Pricewaterhousecoopers Llp, 1 Embankment Place, London, , , (sic) WC2N 6RH Role Active LLP Designated Member Appointed on 1 July 2005 Country of residence United Kingdom

  • PRICEWATERHOUSECOOPERS CONSULTING SERVICES UK LIMITED (02319585) Company status Active Correspondence address 1 Embankment Place, London, United Kingdom, WC2N 6RH Role Resigned Director Appointed on 1 August 2017 Resigned on 30 June 2020 Nationality British Country of residence United Kingdom Occupation Chartered Accountant”

Conclusion: Marco Amitrano

Several significant concerns regarding Marco Amitrano's compliance with company law and PwC's governance practices:

1. Multiple Identities: The existence of three separate identities for Marco Amitrano in Companies House records is inconsistent with the principles of transparency and accuracy emphasized in PwC's governance documents. This potentially violates section 1082 of the Companies Act 2006, which requires accurate information to be provided to Companies House.

2. Audit Independence: As a key figure in PwC's leadership (Senior Partner from July 2024), Amitrano's multiple identities could compromise the independence and integrity of audits conducted by PwC, potentially breaching section 441 of the Companies Act 2006. This is particularly concerning given PwC's emphasis on audit quality and independence in their Terms of Reference.

3. Governance Inconsistencies: The multiple identities and potential legal breaches are not aligned with the governance principles outlined in PwC's Terms of Reference, particularly those related to the Public Interest Body (PIB) and Audit Oversight Body (AOB). These bodies are meant to enhance stakeholder confidence and oversee audit quality.

4. Risk Management: The situation presents a significant risk to PwC's reputation and could be seen as a failure of the firm's risk management processes, which are emphasized in the Terms of Reference for the Risk Committee.

5. Ethical Concerns: The discrepancies raise questions about ethical standards within PwC's leadership, which conflicts with the firm's stated commitment to ethics and integrity in their governance documents.

6. Regulatory Compliance: The potential legal breaches are inconsistent with PwC's commitment to regulatory compliance as outlined in their governance documents, particularly in relation to the Audit Firm Governance Code.

7. Public Interest: This situation could be seen as contrary to the public interest, which is a key focus of PwC's governance structure, particularly the Public Interest Body.

8. Leadership Integrity: As the Senior Partner, Amitrano's actions set the tone for the entire organization. These discrepancies could undermine confidence in PwC's leadership and governance.

9. Conflict with Stated Values: The situation appears to conflict with PwC's stated values and commitment to transparency, as outlined in their Transparency Report and other governance documents.

10. Concentration of power: The situation with Marco Amitrano having significant control over PricewaterhouseCoopers LLP (PwC) raises several concerns, but does not necessarily constitute a clear breach of laws based on the information provided. Potential issues to consider:

    1. Independence Requirements: Section 1214 of the Companies Act 2006 sets out independence requirements for statutory auditors[7]. While Amitrano's role as Senior Partner does not directly violate this, his level of control could potentially compromise the independence of PwC's audit function if not properly managed.

    2. People with Significant Control (PSC) Regime: Under the PSC regime, companies must identify and register individuals with significant control[10]. The fact that Amitrano is listed as the person with significant control on Companies House records[8] suggests PwC is complying with this requirement. However, the concentration of control in a single individual for such a large audit firm is unusual and potentially concerning.

    3. Transparency in Terms of Reference: The Terms of Reference documents provided do not explicitly mention Marco Amitrano as the person with significant control. While they do list him as Senior Partner and a member of various governance bodies, they do not clearly state his status as the PSC[1][2][3]. This lack of transparency in internal governance documents is concerning, given the importance of his role.

    4. Governance Structure: The Terms of Reference outline a complex governance structure with various checks and balances, including the Management Board, Supervisory Board, and Public Interest Body[1][2][3]. However, Amitrano's position as both Senior Partner and PSC potentially concentrates too much power in one individual, which could undermine these governance mechanisms.

    5. Audit Firm Governance Code: The Public Interest Body's Terms of Reference reference compliance with the Audit Firm Governance Code[3]. Amitrano's level of control may raise questions about whether this complies with the spirit of the Code, which aims to enhance stakeholder confidence in the public interest aspects of the firm's activities.

       While not necessarily illegal, this concentration of control in a single individual at such a large and influential audit firm raises significant concerns about independence, governance, and potential conflicts of interest. It would be advisable for regulators to scrutinize this arrangement closely to ensure it does not compromise PwC's ability to perform its audit functions independently and in the public interest.

Marco Amitrano holds several significant positions within the PricewaterhouseCoopers LLP (PwC) structure:

1. Senior Partner and Chair of the Management Board (MB)

2. Ex officio member of the Supervisory Board (SB)

3. Member of the Public Interest Body (PIB)

4. Person with Significant Control (PSC) of PwC LLP

5. Director of multiple PwC-related entities:

   • THE PWC FOUNDATION

   • PWC EMEA LIMITED

   • PRICEWATERHOUSECOOPERS BUSINESS SERVICES LIMITED

   • PWC HOLDINGS (UK) LIMITED

   • PRICEWATERHOUSECOOPERS SERVICES LIMITED

6. LLP Designated Member of PRICEWATERHOUSECOOPERS LLP

7. Former Director of PRICEWATERHOUSECOOPERS CONSULTING SERVICES UK LIMITED (resigned)

Correspondence addresses provided:

1. 1 Embankment Place, London, WC2N 6RH

2. 1 Embankment Place, London, United Kingdom, WC2N 6RH

3. Pricewaterhousecoopers Llp, 1 Embankment Place, London, , , WC2N 6RH (sic)

There are slight variations in these addresses could potentially cause false non-match errors in audit and KYC software:

1. Inclusion/exclusion of "United Kingdom"

2. Capitalization differences (e.g., "Llp" vs "LLP")

3. Extra commas and spaces in the third address

4. Prefix of "Pricewaterhousecoopers Llp" in the third address

These discrepancies, while minor, could lead to the same individual being treated as separate entities by automated systems. This poses significant risks for:

1. Audit accuracy: Failing to identify all related party transactions or conflicts of interest

2. KYC compliance: Potentially missing connections between entities, leading to incomplete risk assessments

3. Regulatory reporting: Inaccurate or incomplete disclosures of Marco Amitrano's interests and control

The multiple identities and address variations raise concerns about data quality and consistency within PwC's internal systems and external filings. This situation could compromise the effectiveness of PwC's governance structures and potentially breach regulatory requirements for accurate reporting.

Summary.

It is concerning that PricewaterhouseCoopers LLP (PwC) has a single person, Marco Amitrano with significant control over such a large number of auditors. This situation raises several compliance and ethical concerns:

1. Independence: Having one individual with significant control over a large audit firm could compromise the independence of the auditors, which is crucial for maintaining objectivity in financial reporting and auditing.

2. Conflict of Interest: This structure may create conflicts of interest, especially if the person with significant control has other business interests or relationships that could influence audit decisions.

3. Concentration of Power: Such a concentration of control in a major audit firm goes against best practices in corporate governance, which typically advocate for distributed decision-making and checks and balances.

4. Regulatory Compliance: This arrangement may not align with regulatory requirements for audit firms, which often mandate certain governance structures to ensure independence and objectivity.

5. Public Interest: Given PwC's role in auditing many public and significant private entities, this control structure could be seen as contrary to the public interest, potentially undermining confidence in the audit process.

6. Ethical Considerations: The ethical standards for auditors emphasize the importance of organizational structures that support independence and professional skepticism. A single point of significant control may challenge these principles.

This situation warrants further scrutiny to ensure it does not compromise the integrity of PwC's audit functions or violate any specific regulatory requirements for audit firm governance. Regulatory bodies and stakeholders may need to examine this arrangement closely to determine if it meets the standards expected of a major audit firm.

A search in Companies House of the name PricewaterhouseCoopers as an officer locates twenty entities that are appointed as officers (PricewaterhouseCoopers - Find (https://find-and-update.company-information.service.gov.uk/search/officers?q=PricewaterhouseCoopers):

1. PRICEWATERHOUSECOOPERS

   Total number of appointments 1

   360 Anglesea Street, Hamilton, 3240, New Zealand

2. PRICEWATERHOUSECOOPERS LLP

   Total number of appointments 2

   1 Embankment Place, London, WC2N 6RH

3. PRICEWATERHOUSECOOPERS LLP

   Total number of appointments 1

   1 Embankment Place, London, United Kingdom, WC2N 6DX

4. PRICEWATERHOUSECOOPERS LLP

   Total number of appointments 1

   1 Embankment Place, London, WC2N 6RH

5. PRICEWATERHOUSECOOPERS LLP

   Total number of appointments 1

   1 Embankment Place, London, , , WC2N 6RH

6. PRICEWATERHOUSECOOPERS LIMITED

   Total number of appointments 1

   Unit 801, Level 8,, Currency House - Building 1, Dubai International Financial Centre, Dubai, United Arab Emirates, 11987

7. PRICEWATERHOUSECOOPERS LIMITED PARTNERSHIP

   Total number of appointments 1

   Unit 01 Level 8, Currency House - Building 1, Dubai International Financial Centre, Dubai, United Arab Emirates, 11987

8. PRICEWATERHOUSECOOPERS CORPORATE BUSINESS SERVICES LIMITED

   Total number of appointments 1

   1 Embankment Place, London, WC2N 6RH

9. PRICEWATERHOUSECOOPERS CORPORATE SECRETARIAL SERVICES LIMITED

   Total number of appointments 0

   3 Julia House, Themistokli Dervi, Nicosia 1066, Cyprus

10. PRICEWATERHOUSECOOPERS (BAHAMAS) LIMITED

    Total number of appointments 1

    Providence House, East Hill Street, P O Box N-3910, Nassau, Bahamas

11. PRICEWATERHOUSECOOPERS ASM LIMITED

    Total number of appointments 1

    1 Embankment Place, London, England, WC2N 6RH

12. PRICEWATERHOUSECOOPERS CFR LTD

    Total number of appointments 1

    1 Embankment Place, London, England, WC2N 6RH

13. PRICEWATERHOUSECOOPERS LEGAL LLP

    Total number of appointments 1

    1 Embankment Place, London, United Kingdom, WC2N 6DX

14. PRICEWATERHOUSECOOPERS ASSOCIATES LIMITED

    Total number of appointments 1

    Julia House, 3 Them. Dervis Street, Nicosia, Cyprus

15. PRICEWATERHOUSECOOPERS ASSOCIATES LIMITED

    Total number of appointments 1

    Julia House, 3 Them. Dervis Street, Nicosia, Cyprus, 1066

16. PRICEWATERHOUSECOOPERS AUDIT

    Total number of appointments 0

    63 Rue De Villiers, Neuilly Sur Seine, France, 92200

17. PRICEWATERHOUSECOOPERS CFR LTD

    Total number of appointments 0

    Plumtree Court, London, , , EC4A 4HT

18. PRICEWATERHOUSECOOPERS JOHANNESBURG

    Total number of appointments 0

    2 Eglin Road, Sunninghill 2157, Johannesburg, South Africa, FOREIGN

19. PRICEWATERHOUSECOOPERS SERVICES LIMITED

    Total number of appointments 2

    1 Embankment Place, London, United Kingdom, WC2N 6RH

20. PRICEWATERHOUSECOOPERS

    Total number of appointments 1

    PO BOX 90 Erskine House, 68-73 Queen Street, Edinburgh, EH2 4NH

Several concerning observations can be made regarding PricewaterhouseCoopers (PwC) and its various entities:

1. Multiple Identities:
   There are multiple entities with variations of the PricewaterhouseCoopers name registered as officers in Companies House. This potentially violates section 1082 of the Companies Act 2006, which requires accurate information to be provided to Companies House.

2. Address Inconsistencies:
   Several PwC entities share similar addresses with slight variations, such as:

• 1 Embankment Place, London, WC2N 6RH

• 1 Embankment Place, London, United Kingdom, WC2N 6DX

• 1 Embankment Place, London, , , WC2N 6RH
  These inconsistencies could lead to false non-match errors in audit and KYC software, potentially compromising the integrity of audits and violating section 441 of the Companies Act 2006.

3. Audit Independence Concerns:
   The multiple identities and address variations raise questions about the independence and integrity of audits conducted by PwC entities. This is particularly concerning given PwC's role as a major audit firm.

4. Regulatory Compliance Issues:
   The inconsistencies in company information may indicate broader issues with regulatory compliance, including KYC (Know Your Customer) and AML (Anti-Money Laundering) regulations.

5. Data Quality and Consistency:
   The variations in company names and addresses suggest potential problems with data quality and consistency in PwC's internal systems and external filings.

6. Global Network Complexity:
   The presence of PwC entities in multiple jurisdictions (e.g., New Zealand, UAE, Bahamas, Cyprus) highlights the complexity of PwC's global network and the challenges in maintaining consistent information across borders.

7. Governance and Oversight:
   These inconsistencies raise questions about the effectiveness of PwC's internal governance and oversight mechanisms, particularly in managing its complex corporate structure.

8. Public Interest Concerns:
   Given PwC's role in auditing many public and significant private entities, these discrepancies could be seen as contrary to the public interest, potentially undermining confidence in the audit process.

These observations suggest a need for further investigation into PwC's corporate structure, data management practices, and compliance with company law and regulatory requirements. Regulatory bodies may need to scrutinize these inconsistencies to ensure they do not compromise PwC's ability to perform its audit functions independently and in the public interest.

The entities acting as officers are expanded below with the details of the company to which each entity is appointed included.

1. “PRICEWATERHOUSECOOPERS

   Total number of appointments 1

   360 Anglesea Street, Hamilton, 3240, New Zealand

   1. MILFOS INTERNATIONAL LIMITED (FC029692)

      Company status Active Role Active Secretary Appointed on 5 July 2010 Overseas company address 360 Anglesea Street, Hamilton, 3240, New Zealand Company status Active Company type Overseas company First UK establishment opened on 1 January 2010 Accounts Next accounts made up to 31 December 2011 Last accounts made up to 31 December 2010 Company details in the country of incorporation Incorporated in NEW ZEALAND Registration number 340773 Legal form Private Limited Parent registry Registrar Of Companies New Zealand Governing law Companies Act 1955 Objects of the company Manufacture and distribute farm dairy components and fittings”

   2. Observations and Concerns

      1. Regulatory Non-Compliance:

         • MILFOS INTERNATIONAL LIMITED (FC029692) has not submitted accounts since 31 December 2010, despite being listed as an active company.

         • This constitutes a clear breach of section 441 of the Companies Act 2006, which requires regular filing of accounts for active companies.

      2. Incongruous Business Activities:

         • The company's stated objects ("Manufacture and distribute farm dairy components and fittings") appear inconsistent with PricewaterhouseCoopers' core business of professional services.

         • This raises questions about the nature of PwC's involvement and the appropriateness of its role as an officer of this company.

      3. Potential Conflict of Interest:

         • PwC's position as an officer in a company with seemingly unrelated business activities could present a conflict of interest.

         • This situation may compromise PwC's independence and objectivity, particularly if it provides audit or other professional services to companies in related industries.

      4. Transparency Concerns:

         • The lack of recent financial information, combined with PwC's involvement, raises concerns about transparency and proper corporate governance.

      5. Jurisdictional Complexities:

         • As an overseas company with a UK establishment, there may be additional regulatory considerations that need to be addressed.

      Implications

      These observations suggest potential issues with PwC's governance practices, compliance procedures, and conflict of interest management. They warrant further investigation to ensure that PwC's involvement with this company does not compromise its professional integrity or violate any regulatory requirements. Regulatory bodies may need to scrutinize this relationship to determine if it meets the standards expected of a major professional services firm.

2. “PRICEWATERHOUSECOOPERS LLP

   Total number of appointments 2

   1 Embankment Place, London, WC2N 6RH

   1. PRICEWATERHOUSECOOPERS CI LLP (OC309347) Company status Active Correspondence address 1 Embankment Place, London, WC2N 6RH Role Active LLP Member Appointed on 1 July 2009 Register location UNITED KINGDOM Registration number OC303525 Incorporated on 22 September 2004 31 officers / 14 resignations

   2. ACCOUNTING ADVISORY (UK) LLP (OC338784) Company status Active Correspondence address 1 Embankment Place, London, WC2N 6RH Role Active LLP Designated Member Appointed on 16 July 2008 Incorporated on 16 July 2008 2 officers / 0 resignations PRICEWATERHOUSECOOPERS CFR LTD Correspondence address 1 Embankment Place, London, England, WC2N 6RH Role Active LLP Designated Member Appointed on 16 July 2008

      PRICEWATERHOUSECOOPERS LLP Correspondence address 1 Embankment Place, London, WC2N 6RH Role Active LLP Designated Member Appointed on 16 July 2008 1 active person with significant control / 0 active statements Pricewaterhousecoopers Llp Active Correspondence address

      1 Embankment Place, London, United Kingdom, WC2N 6RH Notified on 6 April 2016

3. PRICEWATERHOUSECOOPERS LLP

   Total number of appointments 1

   1 Embankment Place, London, United Kingdom, WC2N 6DX

   1. PRICEWATERHOUSECOOPERS LEGAL LLP (OC319841)

      Company status Active Correspondence address 1 Embankment Place, London, United Kingdom, WC2N 6DX Role Active LLP Designated Member Appointed on 3 April 2014 Incorporated on 19 May 2006 Previous company names

      LANDWELL LLP 19 May 2006 - 30 Jun 2006

      25 officers / 23 resignations

      STACEY, Edward James Correspondence address 1 Embankment Place, London, WC2N 6DX Role Active LLP Designated Member Date of birth July 1973 Appointed on

      16 May 2020 Country of residence United Kingdom

      PRICEWATERHOUSECOOPERS LLP Correspondence address 1 Embankment Place, London, United Kingdom, WC2N 6DX Role Active LLP Designated Member Appointed on 3 April 2014

4. PRICEWATERHOUSECOOPERS LLP

   Total number of appointments 1

   1 Embankment Place, London, WC2N 6RH

   1. PWC STRATEGY& UK HOLDINGS LLP (OC391732) Company status Active Correspondence address 1 Embankment Place, London, WC2N 6RH Role Active LLP Designated Member Appointed on 5 March 2014

      2 officers / 0 resignations

      PRICEWATERHOUSECOOPERS CORPORATE BUSINESS SERVICES LIMITED Correspondence address 1 Embankment Place, London, WC2N 6RH Role Active LLP Designated Member Appointed on 5 March 2014 Registration number 8922267

      PRICEWATERHOUSECOOPERS LLP Correspondence address 1 Embankment Place, London, WC2N 6RH Role Active LLP Designated Member Appointed on 5 March 2014

5. PRICEWATERHOUSECOOPERS LLP

   Total number of appointments 1

   1 Embankment Place, London, , , WC2N 6RH (sic)

   Total number of appointments 2

   1. PRICEWATERHOUSECOOPERS AS LLP (OC316181)

      Company status Active Correspondence address 1 Embankment Place, London, , , WC2N 6RH Role Active LLP Designated member Appointed on 15 November 2005

   2. PRICEWATERHOUSECOOPERS GLOBAL RESTRUCTURING SERVICES LLP (OC304440) Company status Dissolved Correspondence address 1 Embankment Place, London, , , WC2N 6RH Role LLP Designated Member Appointed on 14 April 2003

6. PRICEWATERHOUSECOOPERS LIMITED

   Total number of appointments 1

   Unit 801, Level 8,, Currency House - Building 1, Dubai International Financial Centre, Dubai, United Arab Emirates, 11987 (sic)

   1. PRICEWATERHOUSECOOPERS LEGAL MIDDLE EAST LLP (OC346650) Company status Active Correspondence address Unit 801, Level 8,, Currency House - Building 1, Dubai International Financial Centre, Dubai, United Arab Emirates, 11987 Role Active LLP Designated Member Appointed on 12 November 2020 Law governed THE LAWS OF THE DUBAI INTERNATIONAL FINANCIAL CENTRE

      Legal form LIMITED COMPANY Register location UNITED ARAB EMIRATES Registration number 0215 Registered office address 1 Embankment Place, London, WC2N 6DX Incorporated on24 June 2009

7. PRICEWATERHOUSECOOPERS LIMITED PARTNERSHIP

   Total number of appointments 1

   Unit 01 Level 8, Currency House - Building 1, Dubai International Financial Centre, Dubai, United Arab Emirates, 11987

   1. PRICEWATERHOUSECOOPERS LEGAL MIDDLE EAST LLP (OC346650) Company status Active Correspondence address Unit 01 Level 8, Currency House - Building 1, Dubai International Financial Centre, Dubai, United Arab Emirates, 11987 Role Active LLP Designated Member Appointed on 12 November 2020

8. PRICEWATERHOUSECOOPERS CORPORATE BUSINESS SERVICES LIMITED

   Total number of appointments 1

   1 Embankment Place, London, WC2N 6RH

   1. PWC STRATEGY& UK HOLDINGS LLP (OC391732)

      Company status Active Role Active LLP Designated Member Registered office address 1 Embankment Place, London, United Kingdom, WC2N 6RH Company status Active Incorporated on 5 March 2014

      2 officers / 0 resignations

      PRICEWATERHOUSECOOPERS CORPORATE BUSINESS SERVICES LIMITED Role Active LLP Designated Member Appointed on 5 March 2014 Registration number 8922267

      PRICEWATERHOUSECOOPERS LLP Role Active LLP Designated Member Appointed on 5 March 2014

9. PRICEWATERHOUSECOOPERS CORPORATE SECRETARIAL SERVICES LIMITED

   Total number of appointments 0

   3 Julia House, Themistokli Dervi, Nicosia 1066, Cyprus

   1. Total number of appointments 3

      ANGLO AMERICAN CLARENT (UK) LTD (FC034340)

      Company status Converted / Closed Correspondence address

      3 Julia House, Themistokli Dervi, Nicosia 1066, Cyprus

      Role Secretary Appointed on 16 May 2017 Register location CYPRUS Registration number HE 269767 Closed on

      13 November 2020 Company type Overseas company First UK establishment opened on 25 September 2015 Accounts

      Last accounts made up to 31 December 2018 Accounts to 31 December 2019 and final accounts overdue Company details in the country of incorporation Incorporated in CYPRUS Registration number HE347293 Legal form Private Company Limited By Shares Parent registry Department Of Registrar Of Companies And Official Receiver 1 UK establishments 0 open, 1 closed Name ANGLO AMERICAN CLARENT (UK) LTD BR019430 London closed 5 officers / 2 resignations

      1. PRICEWATERHOUSECOOPERS CORPORATE SECRETARIAL SERVICES LIMITED Correspondence address 3 Julia House, Themistokli Dervi, Nicosia 1066, Cyprus Role Secretary Appointed on 16 May 2017 Registered in a European Economic Area Place registered CYPRUS Registration number HE 269767

      2. DONNELLY, Michael Patrick Correspondence address 20 Carlton House Terrace, London, United Kingdom, SW1Y 5AN Role Director Date of birth October 1976 Appointed on 16 May 2017 Nationality British Country of residence United Kingdom Occupation Company Director

      3. KLONARIDES, Elaine Christina Correspondence address 20 Carlton House Terrace, London, United Kingdom, SW1Y 5AN Role Director Date of birth April 1976 Appointed on 22 May 2018 Nationality British Country of residence United Kingdom Occupation Company Director

      4. IRVINE, Louis Oliver Forbes Correspondence address

         20 Carlton House Terrace, London, United Kingdom, SW1Y 5AN Role Resigned Director Date of birth June 1966 Appointed on 16 May 2017 Resigned on 5 June 2019

         Nationality Irish Country of residence England Occupation Head Of Strategic Business Imp

      5. MILLS, John Michael Correspondence address 20 Carlton House Terrace, London, United Kingdom, SW1Y 5AN Role Resigned Director Date of birth January 1964 Appointed on 16 May 2017 Resigned on 5 April 2018 Nationality British Country of residence

         United Kingdom Occupation Company Secretary

      This company is further assessed in Annex 1

   2. ANGLO AMERICAN AMCOLL (UK) LTD (FC034338)

      Company status Converted / Closed Role Secretary Appointed on 16 May 2017 Register location CYPRUS Registration number HE26967

   3. ANGLO AMERICAN CHILE INVESTMENTS (UK) LTD (FC034339) Company status Converted / Closed Correspondence address 3 Julia House, Themistokli Dervi, Nicosia, 1066, Cyprus Role Secretary Appointed on 16 May 2017 Register location CYPRUS Registration number HE 269767 Closed on 13 November 2020 Company type Overseas company First UK establishment opened on 25 September 2015 Accounts Last accounts made up to 31 December 2018 Accounts to 31 December 2019 and final accounts overdue

10. PRICEWATERHOUSECOOPERS (BAHAMAS) LIMITED

    Total number of appointments 1

    Providence House, East Hill Street, P O Box N-3910, Nassau, Bahamas

11. PRICEWATERHOUSECOOPERS ASM LIMITED

    Total number of appointments 1

    1 Embankment Place, London, England, WC2N 6RH

12. PRICEWATERHOUSECOOPERS CFR LTD

    Total number of appointments 1

    1 Embankment Place, London, England, WC2N 6RH

13. PRICEWATERHOUSECOOPERS LEGAL LLP

    Total number of appointments 1

    1 Embankment Place, London, United Kingdom, WC2N 6DX

14. PRICEWATERHOUSECOOPERS ASSOCIATES LIMITED

    Total number of appointments 1

    Julia House, 3 Them. Dervis Street, Nicosia, Cyprus

15. PRICEWATERHOUSECOOPERS ASSOCIATES LIMITED

    Total number of appointments 1

    Julia House, 3 Them. Dervis Street, Nicosia, Cyprus, 1066

16. PRICEWATERHOUSECOOPERS AUDIT

    Total number of appointments 0

    63 Rue De Villiers, Neuilly Sur Seine, France, 92200

17. PRICEWATERHOUSECOOPERS CFR LTD

    Total number of appointments 0

    Plumtree Court, London, , , EC4A 4HT

18. PRICEWATERHOUSECOOPERS JOHANNESBURG

    Total number of appointments 0

    2 Eglin Road, Sunninghill 2157, Johannesburg, South Africa, FOREIGN

19. PRICEWATERHOUSECOOPERS SERVICES LIMITED

    Total number of appointments 2

    1 Embankment Place, London, United Kingdom, WC2N 6RH

20. PRICEWATERHOUSECOOPERS

    Total number of appointments 1

    PO BOX 90 Erskine House, 68-73 Queen Street, Edinburgh, EH2 4NH

Annex 1

“PRICEWATERHOUSECOOPERS CORPORATE SECRETARIAL SERVICES LIMITED (entity 9 above)

Total number of appointments 0

3 Julia House, Themistokli Dervi, Nicosia 1066, Cyprus

Total number of appointments 3

ANGLO AMERICAN CLARENT (UK) LTD (FC034340)

Company status Converted / Closed Correspondence address 3 Julia House, Themistokli Dervi, Nicosia 1066, Cyprus Role Secretary Appointed on 16 May 2017 Register location CYPRUS Registration number HE 269767 Closed on 13 November 2020 Company type Overseas company First UK establishment opened on 25 September 2015 Accounts Last accounts made up to 31 December 2018 Accounts to 31 December 2019 and final accounts overdue Company details in the country of incorporation Incorporated in CYPRUS Registration number HE347293 Legal form Private Company Limited By Shares Parent registry Department Of Registrar Of Companies And Official Receiver 1 UK establishments 0 open, 1 closed Name ANGLO AMERICAN CLARENT (UK) LTD BR019430 London closed 5 officers / 2 resignations

1. PRICEWATERHOUSECOOPERS CORPORATE SECRETARIAL SERVICES LIMITED Correspondence address 3 Julia House, Themistokli Dervi, Nicosia 1066, Cyprus Role Secretary Appointed on 16 May 2017 Registered in a European Economic Area Place registered CYPRUS Registration number HE 269767

2. DONNELLY, Michael Patrick Correspondence address 20 Carlton House Terrace, London, United Kingdom, SW1Y 5AN Role Director Date of birth October 1976 Appointed on 16 May 2017 Nationality British Country of residence United Kingdom Occupation Company Director

3. KLONARIDES, Elaine Christina Correspondence address 20 Carlton House Terrace, London, United Kingdom, SW1Y 5AN Role Director Date of birth April 1976 Appointed on 22 May 2018 Nationality British Country of residence United Kingdom Occupation Company Director

4. IRVINE, Louis Oliver Forbes Correspondence address

   20 Carlton House Terrace, London, United Kingdom, SW1Y 5AN Role Resigned Director Date of birth June 1966 Appointed on 16 May 2017 Resigned on 5 June 2019 Nationality Irish Country of residence England Occupation Head Of Strategic Business Imp

5. MILLS, John Michael Correspondence address 20 Carlton House Terrace, London, United Kingdom, SW1Y 5AN Role Resigned Director Date of birth January 1964 Appointed on 16 May 2017 Resigned on 5 April 2018 Nationality British Country of residence United Kingdom Occupation Company Secretary

   Total number of appointments 41 Current appointments 2 (Current appointments only are copied below)

   1. ISABEL HOSPICE LIMITED (03056823) Company status Active Correspondence address 61 Bridge Road East, Welwyn Garden City, Herts, AL7 1JR Role Active Director Appointed on 5 July 2023 Nationality British Country of residence United Kingdom Occupation Company Secretary Registered office address 61 Bridge Road East, Welwyn Garden City, Herts, AL7 1JR Company status Active Company type Private company limited by guarantee without share capital Incorporated on 16 May 1995 Nature of business (SIC) 86900 - Other human health activities 4 charges registered 2 outstanding, 2 satisfied, Charge code 0305 6823 0004 Created 6 December 2024 Delivered 6 December 2024 Status Outstanding Persons entitled Lloyds Bank PLC Brief description 99 bridge road east. Welwyn garden city. Hertfordshire. AL7… Charge code 0305 6823 0003

      Created 13 August 2024 Delivered 13 August 2024 Status Outstanding Persons entitled Lloyds Bank PLC Brief description None…

      63 officers / 50 resignations (Active officers only copied below)

   2. GLENISTER, Helen Correspondence address 61 Bridge Road East, Welwyn Garden City, Herts, AL7 1JR Role Active Secretary Appointed on 1 March 2020

   3. CHOLAK, Ozlem Correspondence address 61 Bridge Road East, Welwyn Garden City, Herts, AL7 1JR Role Active Director Date of birth September 1985 Appointed on 1 December 2021 Nationality British Country of residence England Occupation Head Of Primary Care And Community Contracts

   4. COTTRELL, Melanie Correspondence address 61 Bridge Road East, Welwyn Garden City, Herts, AL7 1JR Role Active Director Date of birth March 1973 Appointed on 1 December 2021 Nationality British Country of residence England Occupation Trading Director

   5. CROME, Renata Correspondence address 61 Bridge Road East, Welwyn Garden City, Herts, AL7 1JR Role Active Director Date of birth July 1955 Appointed on 1 December 2021 Nationality British Country of residence England Occupation Semi Retired

   6. ELLIS, Ian Correspondence address 61 Bridge Road East, Welwyn Garden City, Herts, AL7 1JR Role Active Director Date of birth March 1968 Appointed on 15 December 2022 Nationality British Country of residence England Occupation Retired

   7. FUELL, Sarah Correspondence address 61 Bridge Road East, Welwyn Garden City, Herts, AL7 1JR Role Active Director Date of birth June 1963 Appointed on 6 November 2019 Nationality British Country of residence England Occupation Life Coach

   8. JACKSON, Claire Correspondence address 61 Bridge Road East, Welwyn Garden City, Herts, AL7 1JR Role Active Director Date of birth June 1976 Appointed on 1 April 2023 Nationality British Country of residence England Occupation Senior Clinical Advisor

   9. MILLS, John Michael Correspondence address 61 Bridge Road East, Welwyn Garden City, Herts, AL7 1JR Role Active Director Date of birth January 1964 Appointed on 5 July 2023 Nationality British Country of residence United Kingdom Occupation Company Secretary

   10. PERRY, Deborah Anne Correspondence address 61 Bridge Road East, Welwyn Garden City, Herts, AL7 1JR Role Active

       Director Date of birth December 1960 Appointed on 6 November 2019 Nationality British Country of residence England Occupation Vice Principle

   11. PHILPOTT, Terence John Correspondence address 61 Bridge Road East, Welwyn Garden City, Herts, AL7 1JR Role Active Director Date of birth January 1961 Appointed on 6 November 2019 Nationality British Country of residence England Occupation Town Clerk

   12. SALE, Lisa Correspondence address 61 Bridge Road East, Brookmans Park, Welwyn Garden City, England, AL6 0PJ

       Role Active Director Date of birth February 1972 Appointed on 5 August 2024 Nationality British Country of residence England Occupation Place Programme Manager

   13. SHIRLEY, Debbie Correspondence address 61 Bridge Road East, Welwyn Garden City, Herts, AL7 1JR Role Active Director Date of birth October 1973 Appointed on 1 December 2021 Nationality British Country of residence England Occupation Headteacher

   14. WILLIAMS, Ian Correspondence address 61 Bridge Road East, Welwyn Garden City, Herts, AL7 1JR Role Active Director Date of birth May 1974 Appointed on 1 April 2020 Nationality British Country of residence England Occupation

       Bursar

   15. CORPORATE GOVERNANCE SERVICES LIMITED (05872982) Company status Active Correspondence address 103 Moffats Lane, Brookmans Park, Hertfordshire, AL9 7RP Role Active Director Appointed on 27 March 2018 Nationality British Country of residence United Kingdom Occupation Director”

   ISABEL HOSPICE LIMITED “Other human health activities” represents a potential conflict of interest and high risk to the public’s best interest.

   A search on John Michael Mills locates a second identity with this date of birth.

   “John Michael MILLS Total number of appointments 11

   Date of birth January 1964

   1. IHL SERVICES LIMITED (15494138) Company status Active Correspondence address 61 Bridge Road East, Welwyn Garden City, England, AL7 1JR Role Active Director Appointed on 4 June 2024 Nationality British Country of residence England Occupation Company Secretary

   2. ABBEY NATIONAL TREASURY SERVICES INVESTMENTS LIMITED (03406902) Company status Liquidation Correspondence address 2 Triton Square, Regent's Place, London, United Kingdom, NW1 3AN Role Active Director Appointed on 30 September 2022 Nationality British Country of residence England Occupation Chartered Secretary

   3. ABBEY NATIONAL BETA INVESTMENTS LIMITED (02207620) Company status Liquidation Correspondence address 2 Triton Square, Regent's Place, London, United Kingdom, NW1 3AN Role Active Director Appointed on 30 September 2022 Nationality British Country of residence England Occupation Chartered Secretary

   4. FIRST NATIONAL TRICITY FINANCE LIMITED (00544013) Company status Active Correspondence address 2 Triton Square, Regent's Place, London, United Kingdom, NW1 3AN Role Active Director Appointed on 30 September 2022 Nationality British Country of residence England Occupation Chartered Secretary

   5. 2 & 3 TRITON LIMITED (06024916) Company status Active Correspondence address 2 Triton Square, Regent's Place, London, United Kingdom, NW1 3AN

      Role Active Director Appointed on 30 September 2022 Nationality British Country of residence England Occupation Chartered Secretary FIRST NATIONAL MOTOR PLC (02248924) Company status Active Correspondence address 2 Triton Square, Regent's Place, London, United Kingdom, NW1 3AN Role Active Director Appointed on 30 September 2022 Nationality British Country of residence England Occupation Chartered Secretary

   6. CATER ALLEN HOLDINGS LIMITED (00380825) Company status Active Correspondence address 2 Triton Square, Regent's Place, London, United Kingdom, NW1 3AN Role Active Director Appointed on 30 September 2022 Nationality British Country of residence England Occupation Chartered Secretary

   7. ABBEY NATIONAL PLP (UK) LIMITED (03888789) Company status Active Correspondence address 2 Triton Square, Regent's Place, London, United Kingdom, NW1 3AN Role Active Director Appointed on 30 September 2022 Nationality British Country of residence England Occupation Chartered Secretary

   8. SANTANDER SECRETARIAT SERVICES LIMITED (03072288) Company status Active Correspondence address 2 Triton Square, Regent's Place, London, United Kingdom, NW1 3AN Role Active Director Appointed on 9 June 2022 Nationality British Country of residence England Occupation Chartered Secretary SOVOS LIMITED (13312789) Company status Dissolved Correspondence address 103 Moffats Lane, Brookmans Park, Hatfield, England, AL9 7RP Role Resigned Director Appointed on 3 April 2021 Resigned on 8 November 2021 Nationality British Country of residence England Occupation Solicitor

   9. ICU MEDICAL 2020 LIMITED (12103805) Company status Active Correspondence address 1500 Eureka Park, Lower Pemberton, Ashford, Kent, England, TN25 4BF

      Role Resigned Director Appointed on 15 July 2019 Resigned on 1 November 2020 Nationality British Country of residence England Occupation Secretary

      Registered office address 1500 Eureka Park Lower Pemberton, Kennington, Ashford, England, TN25 4BF Company status Active Company type Private limited company Incorporated on 15 July 2019 Accounts overdue Next accounts made up to 31 December 2023
      due by 31 December 2024 Last accounts made up to 31 December 2022 Confirmation statement Next statement date 14 July 2025 due by 28 July 2025 Last statement dated 14 July 2024 Nature of business (SIC) 74909 - Other professional, scientific and technical activities not elsewhere classified Previous company names Previous company names SMITHS MEDICAL 2020 LIMITED15 Jul 2019 - 01 Jul 2022 Register of directors Information not on the public register since 30 March 2022 Register of secretaries Information not on the public register since 30 March 2022 Register of person(s) with significant control (PSCs) Information not on the public register since 30 March 2022 Register of members Information not on the public register since 30 March 2022”

“ICU Medical 2020 Limited”, high risk to public’s best interest. Conflict of interest. Overdue accounts

Annex 2

Appendix E

Labour Together Limited, a potential related party of Alliance for Responsible Citizenship Limited:

Lord Jonathan Andrew KESTENBAUM, is an active director of JPMORGAN JAPANESE INVESTMENT TRUST PLC.

Correlation between Compliance Assessment on Sir Paul Marshall, Alan McCormick, Lord Hill and Oliver Plunkett, of Alliance for Responsible Citizenship Limited (ARC) based on “JPMorgan” and Labour Together Limited. Refer to:

Labour Together Limited: BBC Radio 4's topical comedy reveals a potential constitutional compromise and covers it with laughter.

Potential association between Labour Together Limited and Alliance for Responsible Citizenship Limited directors via JPMORGAN JAPANESE INVESTMENT TRUST PLC and Jpmorgan Chase Bank, N.A., London Branch, which has a charge over UBS AG (FC021146). “Ubs Ag, London Branch” has a charge over ARK CAPITAL INVESTMENTS LIMITED (10757714) as described below.

1. ALLIANCE FOR RESPONSIBLE CITIZENSHIP LIMITED has a resigned director HILL, Jonathan Hopkin, The Rt Hon. The Lord Correspondence address 11 Charles Street, London, England, W1J 5DW Date of birth July 1960 Appointed on 31 January 2018 Resigned on 10 February 2023

2. A search in Companies House locates four identities with the name Jonathan Hopkin Hill, interspersed between records for corporate entities of Hillier Hopkins Group Limited and Hiller Hopkins LLP and Hopkin Smart Consulting Ltd (Jonathan Hopkin HILL - Find https://find-and-update.company-information.service.gov.uk/search/officers?q=Jonathan+Hopkin+HILL)). Lord Hill and Hopkin Smart Consulting Ltd breach section 1082, requiring a unique identifier.

3. Lord Hill of Oareford's Register of Interests inaccurately states that he was a director of "Prosperity UK, interest ceased 10 February 2023." The company was actually named “Prosperity UK 2017 Limited” and changed its name to “Alliance for Responsible Citizenship Limited” on 21 January 2023. He disclosed an inaccurate name which he did not update, when Prosperity UK 2017 Limited changed name to Alliance for Responsible Citizenship Limited which has the effect of obscuring his association to this company.

4. HOPKIN SMART CONSULTING LTD has HOPKIN, Nicholas Correspondence address 22 Holloway Road, Duffield, Belper, Derbyshire, England, DE56 4FE as an active Director Date of birth December 1955 Appointed on 21 April 2015. He has multiple unique identifiers.

5. Nicholas HOPKIN identity 2

   Total number of appointments 5 - Born December 1955

   9 Riverside Court, Pride Park, Derby, Derbyshire, DE24 8JN is a director of ARK CAPITAL INVESTMENTS LIMITED (10757714) Appointed on 8 May 2017 Correspondence address 16 Great Queen Street, London, England, WC2B 5DG

6. ARK CAPITAL INVESTMENTS LIMITED (10757714) has one charge outstanding to “Ubs Ag, London Branch”. Associated party “UBS AG” is registered in Companies House with two numbers

   1. UBS AG

      OE013351 - Registered on 16 January 2023

      1 Aeschenvorstadt, Basel, Switzerland, 4051

   2. UBS AG

      FC021146 - First UK establishment opened on 12 June 1998

      Aeschenvorstadt 1, 4051 Basel, Switzerland, Switzerland

7. Jpmorgan Chase Bank, N.A., London Branch has a charge, as the entitled person, created 8 December 2008, over UBS AG FC021146 (First UK establishment opened on 12 June 1998, Aeschenvorstadt 1, 4051 Basel, Switzerland, Switzerland (sic)).

8. KESTENBAUM, Jonathan Andrew, Lord is an active director appointed on 18 May 2023 of Labour Together Ltd and an active Director of JPMORGAN JAPANESE INVESTMENT TRUST PLC (00223583) appointed on 1 October 2023, incorporated on 2 August 1927.

9. Assuming

   1. JPMORGAN JAPANESE INVESTMENT TRUST PLC (00223583) and Jpmorgan Chase Bank, N.A., London Branch are associated parties.

   2. Nicholas HOPKIN, of 9 Riverside Court, Pride Park, Derby, Derbyshire, DE24 8JN who is a director of ARK CAPITAL INVESTMENTS LIMITED (10757714) appointed on 8 May 2017, is a related party of Jonathan Hopkin HILL. Clarification from these parties is required.

Trading Disclosures template

1. Company's Registered Name:

2. Company Registration Number:

3. Place of Registration:

4. Registered Office Address:

5. Directors' Names:

6. Share Capital Information:

Citations:

[1] https://ppl-ai-file-upload.s3.amazonaws.com/web/direct-files/30379079/ee1eaa0d-71bd-4599-9c02-3f69293a8d30/paste.txt

[2] https://ppl-ai-file-upload.s3.amazonaws.com/web/direct-files/30379079/58b35b91-3dfb-4914-b04c-99e3dcbb0cee/paste-2.txt

[3] https://ppl-ai-file-upload.s3.amazonaws.com/web/direct-files/30379079/d4f18715-7de0-4d9e-b691-0a87178f0893/paste-3.txt

[4] https://ppl-ai-file-upload.s3.amazonaws.com/web/direct-files/30379079/38cee5f7-6b81-4044-9929-595f79c4d605/paste-4.txt

[5] https://dr201.s3.amazonaws.com/cl/Exhibit%20I.pdf

[6] https://assets.publishing.service.gov.uk/media/5a8224da40f0b6230269b126/psc-statutory-guidance-companies.pdf

[7] https://www.legislation.gov.uk/ukpga/2006/46/part/42/chapter/2/crossheading/independence-requirement

[8] https://find-and-update.company-information.service.gov.uk/company/OC303525

[9] https://www.occompt.com/DocumentCenter/View/1633/BCC-2020-07-23-XLS

[10] https://www.dentons.com/en/insights/newsletters/2016/april/7/uk-corporate-briefing/uk-corporate-briefing-spring-2016/people-with-significant-control-regime-now-in-force

[11] https://www.2harecourt.com/2018/05/15/defending-directors-hidden-gems-companies-act-2006/

[12] https://livrepository.liverpool.ac.uk/3148453/1/201212709_Jun2021.pdf

[13] https://www.legislation.gov.uk/ukpga/2006/46/contents

[14] https://www.legislation.gov.uk/ukdsi/2008/9780110810683/schedule/1

[15] https://ideas.repec.org/r/bla/stratm/v18y1997i7p509-533.html

[16] https://www.legislation.gov.uk/ukpga/2006/46/section/1082

[17] https://www.legislation.gov.uk/ukpga/2006/46/section/441

[18] https://bsdwebstorage.blob.core.windows.net/efiles/WJMA%20Volume%207%20Issue%201-9.pdf

[19] https://publications.parliament.uk/pa/bills/lbill/58-03/096/en/5803096en07.htm

[20] https://www.icaew.com/-/media/corporate/files/members/regulations-standards-and-guidance/members-handbook/members-handbook-2009/financial-and-accounting-duties.ashx

[21] https://ideas.repec.org/e/c/pwr24.html

[22] https://www.legislation.gov.uk/ukpga/2006/46/pdfs/ukpga_20060046_en.pdf

[23] https://www.lexisnexis.co.uk/legal/legislation/uk-parliament-acts/companies-act-2006-c46

[24] https://www.researchgate.net/publication/360560868_Smart_Cities_in_Europe_Development_of_Two_Composite_Indicators_and_Econometric_Analysis_Contents

[25] https://bills.parliament.uk/publications/49630/documents/2864

[26] https://greenelab.github.io/covid19-review/

[27] https://www.legislation.gov.uk/ukpga/2006/46/part/35

Clarification requested

Query whether Ozlem Cholak and Andrei Nicholas CZOLAK the Chair of Sussex Police and Crime Panel, are related parties? If they are, then potential conflicts of interest are evident.

Ozlem Cholak

Andrei Nicholas CZOLAK (CZOLAK, Andrei Nicholas)

Key words associated with Sir Paul Marshall:

Jonathan Hopkin HILL Philip Anthony Vassiliou Christopher Chandler Richard Douglas Mark Stoleson ARK Academies Projects Limited Marshall Wace LLP Absolute Return for Kids (ARK) Pimpernel and Partners Limited ARK Schools Education Policy Institute Marshall Wace Asset Management Limited St Paul's Theological Centre Standards Board for Alternative Investments Limited ARK UK Programmes Liberal Democrat Business Forum Limited Pragma Wealth Management Ltd. BlackRock Investment Management (UK) Limited Marshall Wace Asset Management Limited MW Eaglewood Management Limited MWAM NA Ltd Every Child a Chance Trust Freedom Music Limited UnHerd Foundation Areopagus Ventures Limited Beikonic Ltd Old Queen Street Ventures Ltd UnHerd Insight Limited UnHerd Limited All Perspectives Ltd EdCity Management Company Limited B-Ikonic Ibiza Ltd EdCity Office (11596797) EdCity Development Limited AllChild Limited Nicholas Gumbel The William Wilberforce Trust Caring for Ex Offenders Holy Trinity Brompton Developments Limited Church Revitalisation Trust Jonathan Mark Shippen JKA Seed Holdings Limited King Spalding LLP William Francis Charnley KKS Strategy LLP Katrina Kostic Samen British Council for Offices Zeus Film LLP The Muscovy Company Limited Dick Francis Film Limited Damien Anthony Donohoe

Alan James McCormick Identity 1: CATALITIX ADVISORS LTD (09876203) - Dissolved

Identity 2: THE LEGATUM INSTITUTE FOUNDATION (07430903) - Dissolved

Identity 3: ALLIANCE FOR RESPONSIBLE CITIZENSHIP LIMITED (10519995) - Active

Identity 4: THE END FUND (06350698) - Active

LEGATUM INSTITUTE (FC028686) - Converted/Closed

THE FREEDOM FUND UK (08926428) - Active (Resigned)

Identity 5:

PROSPERITY INSTITUTE LIMITED (14543238) - Active (Resigned)

Identity 6:

HAZELDINE FILMS LTD. (04183598) - Active (Resigned)

Identity 7:

ALL PERSPECTIVES LTD (12227760) - Active

Cardinal Investments Limited and Bluejay Investments Ltd. Withers LLP Christine Blackman Martin Trott Christopher Kennedy The R And H Trust Co Ltd Legatum Foundation Limited Legatum Ventures Limited Legatum Global Holdings Limited Legatum Global Realty Limited Legatum Operating Partnership LLP TROY WISEMAN Stephen CuttsRawlinson & Hunter Luminos Fund GB News Discovery Communications Europe Limited Mark Lyle Schneider Andrew Cole Lord Theodore Thomas More AGNEW Outwood Grange Academies Trust