Select Committee on Public Accounts Minutes of Evidence


Copy of a letter and a memorandum submitted by The Association for Charities


  Thank you for your letter of 25 October indicating the Committee's willingness to receive submissions on matters under consideration. I now enclose the Association's submission for the Committee's meeting on 28 November 2001, and should be grateful if you would circulate it to the Committee Members.

  Whilst our submission concentrates chiefly on the NAO report findings on the Commission's performance in the area of investigations (Report, Part 2), it also relates these to Association evidence from some 20 charities with direct experience of the Commission's investigatory performance since 1994. Given the need for a brief submission, however, the back-up evidence for Association statements does not accompany the submission: the dossier of such evidence can, however, be made available to the Committee, or any Member, on request. Our submission also refers to an August 2001 report from the Independent Complaints Reviewer, which is also available, upon request. This report was copied to the writer by a complainant (who is not an Association member) with permission to release it to any interested party.

Association for Charities: A National Association for the Support and Protection of Charity Beneficiaries, Trustees, Volunteers and Donors



  A welcome for the NAO Report HC 234 and its consideration by the Public Accounts Committee.

  1.1  Given the importance to our national life and economy of this major, but generally under-regarded sector, the Association for Charities (AfC) welcomes the National Audit Office (NAO) report on the regulatory role of the Charity Commission (the Commission); and the Public Accounts Committee's (PAC) early consideration of it. The Association also welcomes the opportunity to present this submission to the Committee.

  1.2  The Association hopes that the PAC's report, together with that from the Cabinet Office's Performance and Innovation Unit (PIU) expected early next year, will lead the Government and Parliament to undertake the fundamental and much-needed review of the sector; and, in particular, a review of the legal and regulatory framework, and the regulatory role of the Commission.

The Association for Charities

  1.3  The PAC may recall that trustees of certain charities made submissions on the last occasion the Committee reported on the NAO's Report, Charity Commission: Regulation and Support of Charities (HC2, Session 1997-98). These submissions raised concerns stemming from trustees' experiences of the Commission's exercise of its regulatory powers. One such case was raised at the Committee by a Member, in the private session, as reported in the Committee's Twenty eighth Report of April 1998. That case led to an application for judicial review in the High Court; another led to trustee appeals against Commission Orders which resulted in a landmark judgement and other developments outlined in Section 2 of this submission, and to the formation, in 1999, of the Association for Charities.

  1.4  The Association's area of concern, operation and activity is the regulatory framework for the charity and voluntary sector, with particular reference to the regulatory role of the Commission, and the manner in which the Commission has exercised the unparalleled regulatory and judicial powers conferred by the Charities Act 1993.

  1.5  The Association is not attached to any political party or any other organisation or body. It is wholly independent, although it seeks to co-operate with other bodies which share its objects and concerns; and it supports the attempts of the present Chief Commissioner to change the culture and improve the performance of the Commission in its regulatory role. It is almost entirely financed by its core membership, who, in the best traditions of the voluntary sector, give generously of their time, expertise and other resources without charge.

  1.6  The AfC has, since 1999, received and collated information and evidence from trustees and supporters of some 20 charities. This evidence demonstrates the improper, and on occasion unlawful, exercise of the Commissioners' regulatory powers by Commission officers. Such conduct has led to unnecessary and extensive damage to beneficiaries (both human and animal); to charities; and to trustees who had served with integrity, competence and whole-hearted commitment. [Note: The Association's first video "With Charity for All?" refers to some of the effects of the exercise of the Commission's regulatory powers on four charities.

Layout of the Submission

  1.7  Following this brief introduction, the submission is divided into three further sections. Section 2 outlines important developments relating to the Commission's accountability to the Courts; Section 3 deals with the NAO Report's findings (particularly in relation to Part 2 of the NAO Report which is the area of the Association's focus) and relates these to the evidence obtained by the Association from 20 charities; and Section 4 draws the Committee's attention to the lessons the AfC believes may be drawn from the matters outlined in Sections 2 and 3 of the Submission.


  2.1  As the NAO Report notes, the Commission is a non-ministerial Government department accountable to the Courts for its decisions (Report 1.4). In truth, the Commission's regulatory powers "are in their nature judicial powers: they are the sort of powers the Court exercises" [Ref: The Law and Practice relating to the Charities—Hubert Picarda QC, 1999]. No Minister, Government, nor even Parliament can at present review the Commission's regulatory decisions: only the High Court (and the Court of Appeal/House of Lords) could do so if they so determine. The Courts provide the only (theoretical) safeguard against any abuse of the Commissioners' regulatory powers.

  2.2  Under present arrangements, trustees seeking to appeal against Commission Orders require the Commission's permission to bring appeals; cannot, as trustees, obtain legal aid whatever their circumstances; and the Commission need not appear as a defendant to seek to support or justify their Orders. Any trustee seeking to complain to an MP, Minister, or the Parliamentary Ombudsman about the use of the Commission's judicial powers is informed that these are matters for the High Court alone.

Why in practice the only safeguard against Commission abuse of powers may no longer operate

  2.3  In landmark charity law appeals (1999 to 2001) trustees appealed against Commission Orders appointing a Receiver and Manager to make and execute a substantial financial settlement from charity funds which professional advisers to the charity had advised the trustees it would be a breach of their duty of care to do on the available evidence. At a hearing of these appeals, a High Court Judge ruled (on grounds of time and cost) that "it would not be right to spend time investigating what the Charity Commissioners did and what the Charity Commissioners thought and what the Charity Commissioners said." Consequently, the Court determined, "considering what factors influenced the Charity Commissioners, what discussions took place within the Charity Commission, whether the Charity Commissioners were fair, whether they were reasonable, whether they might have done things differently from the way they did could all be avoided". [Note: The appellant trustees, legally advised, and financed by one of their number in their Court appeals designed to protect the charity's assets, had alleged bias and misconduct on the part of Commission officers in the making of such Orders—but Counsel for HM Attorney-General, as defendant, argued that the Court should accept "prima facie expect the Commission not to be wrong"]. Prior to the Court's ruling, the then Head of the Home Civil Service had asserted that he would be unable to consider any allegations of misconduct by Commission officers: only the High Court could do so.

  2.4  The Association's evidence is that Commission officers, exercising the Commissioner's powers, have acted carelessly, incompetently, with bias and, on occasion, unlawfully. Powers of this nature are not generally available to other UK regulatory bodies without prior reference to the Courts: they were not available to the Commission until the implementation of the Charities Act 1993.

  2.5  The Association believes that the landmark Court ruling related above—now case law precedent—may serve to relieve the Commission of the likelihood that any future decision of theirs will be the subject of Court review. In reality this Court ruling, the AfC and leading charity lawyers believe, leaves the Commission effectively unaccountable in the exercise of its regulatory powers. The AfC claims that such a situation is inimical to the public interest; and could well be the subject of concern and possible action by Parliament. The AfC believes that Lord Acton's dictum (1887) "power tends to corrupt and absolute power corrupts absolutely" should serve as an appropriate warning in this situation.


  3.1  NAO reports by their nature and language do not appear in dramatic form: they record, in measured form and language, the objects of a review, the study methodology, and progress and failings in specific areas. A reader of this report may too readily conclude that there is no cause for particular concern, as did the editor of a leading charity news magazine, who recently commented as follows in her editorial "The Charity Commissioners must be breathing a sigh of relief. The National Audit Office's Report that came out last week has given the Commission a clean bill of health". The AfC suggests that such a reading of the report fails to appreciate the serious defects and deficiencies referred to below.

  3.2  The Commission has a multiplicity of roles under present arrangements: registry, supportive, administrative, and investigatory, followed by the exercise, where chosen, of judicial regulatory powers. The AfC welcomes the Commission's progress recorded in three areas by the NAO Report (Report Summary, 1.5).

  3.3  Whether a prospective charity achieves Commission registration which will affect its taxation status or whether or not a charity is helpfully and effectively supported by the Commission advice or guidance, is unlikely to cause the degree and kind of damage to beneficiaries which can, and has occurred through the exercise of the Commission's judicial powers. Such damage can include, and has included, possible loss of life and livelihood, deterioration of health and a lack of safety. In the area of the AfC's particular concern—investigations work—there is considerable evidence that serious weaknesses remain.

Serious weaknesses in investigations work

  3.4  The Association notes that Part 2 of the NAO Report lists a catalogue of substantial defects in the Investigation Division's performance. Eight years after the Commissioners were granted probably the most substantial judicial powers granted to any regulatory agency in the United Kingdom, and four years after trenchant criticisms of the Commission's investigatory performance were made by the PAC, the Commission's performance in this area appears to be inadequate. [Note: the NAO Report records that the only two Treasury Minute responses in which the Commission is recorded as not accepting the PAC's conclusions were a lack of management grip, and the allocation of resources to investigations work (Report, Appendix 2, pages 17-18). If the Commission could not accept that such strictures were justified in those areas, it is perhaps not surprising that serious weaknesses remain.]

  3.5  The Commission appears to be completing investigations more quickly (Report, paragraph 2.6), but this may be because, as the Association's evidence demonstrates, they are failing to investigate cases as thoroughly and professionally as they should—possibly in their drive to achieve target completions. The same remarks may be relevant to the reported progress in tackling the backlog of cases (paragraph 2.7). The Association believes that, as the NAO recommends, it could be helpful and good management practice for individual cases to be carefully and properly monitored (paragraph 2.8)—provided such monitoring did not concentrate exclusively on the need to meet target investigation completion dates regardless of the quality of the case officer's performance of the complexity of the case.

  3.6  The Commission's failure to consult trustees about important decisions (Report, page 17, final sentence of Commentary) is common to the great majority of the cases known to the Association. Again the AfC notes that the Commission does not review the cumulative time taken to resolve cases, nor their cumulative costs (paragraph 2.9); nor does it systematically review the scope of inquiries before launching an inquiry (paragraph 2.10). Few inquiries include systems checks within charities or detailed financial examinations (paragraph 2.12).

  3.7  The Association notes, with some surprise (albeit welcome surprise) that certain other regulatory bodies appear to consider their liaison arrangements with the Commission are working well. The Association's experience is that, in certain cases, the Commission failed to inform the Police and the Inland Revenue, even when requested and reminded by trustees to do so.

  3.8  It is clear from the NAO Report (paragraphs 2.16 and 2.17) that the Commission does not always check that charities have successfully carried out agreed actions aimed at remedying weaknesses; nor was it possible always to identify clearly from files what actions a charity was expected to carry out to rectify weaknesses.

The dangers of purely quantitative targets to complete investigations

  3.9  The Association draws attention to Appendix 3 of the NAO Report in which the Commission reports performance in 2000-01 against targets they set in relation to three objectives. Leaving aside the question of whether the particular targets set by the Commission under objective 3 were sufficiently taxing, the Association notes that each of the targets on the investigative side are expressed purely in quantitative terms—with no reference whatsoever to quality of performance. The Association claims there is considerable danger that measurements expressed purely in quantitative terms—particularly in the area of investigations completed within certain dates—will be likely, if not virtually certain, to encourage careless, incompetent and inadequate investigations in order to reach or exceed a target of investigations completed. In seeking to meet such quantitative targets, investigations staff are likely to be encouraged to "cut corners" and bring investigations to an end without taking full and careful account of the true needs of beneficiaries and the interests of the charities the Commission should be there to protect. It is the Association's experience, confirmed also by the findings in Part 2 of the NAO Report, and an Independent Complaints Reviewer's recent report (see paragraphs 3.20-3.22 below) that the Investigation Divisions perform very poorly in the critical area of investigation work.

Complaints and Compliments: inadequate measures to determine performance or effectiveness

  3.10  The Association notes that no proper complaints procedures (either internal or external) were available to complainants until January 2000—a possibly unique deficit in any governmental regulatory body. The AfC believes that it was no coincidence that, following the landmark charity case outlined earlier in this Submission and the Association's formation, the Commission detected a need for pilot internal and external complaints procedures. The AfC immediately welcomed the introduction of these pilot procedures by the present Chief Commissioner, and has made certain proposals to the Commission Board for improvements which the Chief Commissioner has indicated will be taken into account when the Board reviews the pilot schemes before the end of this year.

  3.11  From a meeting with the Independent Complaints Reviewer earlier this year, the AfC was surprised to learn that the Commission—of its own volition—has a policy of only keeping certain files on a case for a period of three months. Apparently, in certain cases where the Commission decides (do they have a crystal ball?) that a case may become the subject of complaints, they may keep the files for a longer period. The AfC believes that such a Commission policy is, frankly, unacceptable—as well as being out of line with other Government Departments and Agencies.

  3.12  The AfC believes that, for a variety of reasons, the level of complaints and compliments received by the Commission cannot properly be used to measure the efficiency or effectiveness of the manner in which it performs, particularly in its investigatory role. Firstly, as any senior manager or chief executive of a public sector organisation appreciates, many people (possibly the majority?) will not trouble to compliment or complain to a public sector organisation; they may consider it will not make any difference—except to lead to exchanges of correspondence if they were to complain; while others may wish to avoid jeopardising any future contacts with the organisation by complaining.

  3.13  Finally, so far as the Commission is concerned, several of those who felt most strongly about the poor performance of the Commission and the damage done to their charities or themselves by Commission actions, have sought to complain. Their complaints, however, have not been recognised or dealt with on a number of grounds—not least that their complaints are out of time. The Commission has written to members of the Association who sought to complain about Commission conduct or performance, saying that "the files are closed" and that no further reply from them will be forthcoming.

  3.14  From paragraph 3.19 of the NAO Report, we learn that 22 per cent of the 121 complaints to the Commission in 2000 were upheld: a statistic which may either be considered as an acknowledgement that about a quarter of the complaints were justified, indicating a relatively poor initial performance, or that the Commission's internal complaints procedure is working satisfactorily, or both. Although the NAO do not seek to relate the number of complaints or compliments to the Commission's overall performance, the Association is aware that the Commission themselves have in the past sought to do so. During the same period, paragraph 3.20 of the NAO Report indicates that the Independent Complaints Reviewer received 43 complaints, partially upholding one of the eight formally investigated with two of the eight being outside the Reviewer's terms of reference. The answer to a recent Parliamentary Question seeking information on the numbers of complainants and complaints to the Commission and the Independent Reviewer, with results, from January 2000 to the present, should be available in the House of Commons Library by the date of the Committee's meeting.

The Use of the Commission's Statutory Powers

  3.15  The NAO Report notes that the Commission's use of statutory powers has continued to decline (paragraphs 2.14 to 2.15 and Figure 10) despite the Committee's concerns expressed in 1998. The Association has consistently supported the proper and speedy use of statutory powers by the Commission, once the need for such has been established by thorough and professionally executed investigations. The Association suspects that the proven cases of maladministration or abuse amongst registered charities are likely to under-represent the true position, given:

    —  the difficulty of obtaining evidence in this area;

    —  the relative ease with which fraud and abuse may occur in relation to the size, monetary value and fragmentation of the sector;

    —  the management of such bodies by trustees and governors, who may in many cases lack the necessary time, skill and management expertise required; and

    —  the opportunities for malfeasance and fraud in this sector allied to the relatively low rates of detection.

  Such conditions might reasonably be expected to attract those who might seek to take advantage of such opportunities. The AfC shares the PAC's expressed concerns in their last report relating to the Commission's "failure to show more drive in exploiting the opportunities for greater effectiveness which the 1993 legislation provides" (Report, Appendix 2).

  3.16  At the same time, the Association has extensive evidence of the Commission's misuse of statutory powers, particularly in relation to small and medium-sized charities, where the Commission has been too ready to impose its control by statutory means, rather than investigate and remedy the defects reported to them by concerned trustees.

  3.17  The AfC notes that a seeming paradox emerges from their review of several of their case files. On the one hand, the Commission, in these cases, failed to investigate, either at all or properly, the evidence of maladministration drawn to their attention, with consequent costs and losses to the charity in certain cases: on the other hand "whistle-blower" trustees have experienced the full penalties of the apparently arbitrary exercise of Commission judicial powers, without any effective means of appeal or redress.

  3.18  A classic case of the Commission's misuse of statutory powers (one of several) relates to a charity where trustees obtained an injunction to prevent a Receiver and Manager making a financial settlement from charity funds which he had been instructed by Commission Order to execute. The Commission, having additionally appointed new trustees to take on the management of the charity from the trustees appealing against their Order, were later faced with a situation in which the trustees they had appointed, in time also came to oppose the financial settlement the Commission had instructed the Receiver to execute. The result was that the Commission, belatedly, was obliged to support the new trustees in their opposition to the financial settlement; and dismiss the Receiver whom they had appointed, at charity expense, to execute the settlement they sought.

  3.19  As a final irony, in the case mentioned above, the claimant of charity funds, whose claims the Commission had sought to meet by the appointment of the Receiver, made use of the Commission's new internal and external complaints procedures to complain about several aspects of the Commission's conduct. After securing certain apologies from the Chief Commissioner who had reviewed his complaints, reference was made to the Independent Complaints Reviewer. Of the 12 complaints the Independent Reviewer considered, she partially or fully upheld six.

  3.20  In her August 2001 report on that case, the Independent Reviewer reached the following conclusion:

    "At the end of the review, I am led to conclude that overall this case was very poorly handled. It has been characterised by changes in approach and direction and the Commission has tried almost every possible intervention in order to achieve a solution to the problems that were being faced. Its active intervention has lasted literally for years and the issue of the loans has still not been resolved. It is difficult to see how this can be a reasonable use of public money."

  In the Association's view, such a finding could apply to other cases on its files.

  3.21  At the conclusion of the same report, the Independent Reviewer made seven recommendations, the first two of which were recommendations that the Commission offered the complainant an apology for the shortcomings identified in that report which were not the subject of an earlier apology following the Chief Commissioner's review; and a recommendation that the Commission offer a consolatory payment to the complainant, or if they preferred, the recommended sum could be paid directly to a charity of the complainant's choice. The remaining five recommendations related to failures in the Commission's handling of the case, with the final recommendation that the Commission use the lessons of that report to inform future practice and procedure.

The need for swift and decisive Commission action to deal effectively with the serious continuing weaknesses in investigations work which have led to the misuse of judicial powers

  3.22  The AfC believes that it is now clear from the considerable evidence of the NAO Reports, the Independent Reviewer's Report from which a quotation appears in paragraph 3.21 above, and from the AfC's dossier of some 20 cases, the time has now come for swift and decisive Commission action—and before any further unnecessary damage occurs to beneficiaries, charities and trustees. The AfC believes that such management action will need to be taken in relation to the two related areas of inadequate investigatory performance, and the resultant misuse of the Commission's judicial powers. The extra million pounds noted in the NAO Report to be allocated to investigations work may otherwise be wasted; and used to perpetuate a failing (and failed) area of activity.

  3.23  With regard to the continuing investigatory work failures, the AfC considers that a root-and-branch reform will be required. It would be inexcusable were the next NAO report to have to point to investigation failures again—while in the meantime more beneficiaries, charities and trustees were being failed.

  3.24  Firstly, it is the AfC's considered view that the Heads of Investigations in the three Commission offices should be stood down, and replaced by Investigative Service Managers of proven competence, who are used to demanding, and obtaining the highest standards of investigatory performance. Such managers, the AfC believes could be recruited, either on a temporary or permanent basis from established regulatory agencies with a record of investigative competence, including the NAO, the Audit Commission and the Police Service. Such appointments could be expected to secure the requisite improvements in staff training, mentoring, procedural improvements and effective monitoring, to gain full value from the additional £1 million (a 31 per cent increase) proposed for investigatory work.

  3.25  Secondly, given the damage to the lives, livelihood, heath and safety of those affected by the exercise of such powers, the AfC considers that in every case where the use of such powers is under consideration, the Commission Board should, upon a report, determine what exercise, if any, of its judicial powers would be requisite. By this means, the AfC believes, confidence in the integrity of charity, and of the Commission's exercise of its judicial powers will be increased; and the Court's assumptions that it was the Commissioners (and not the Commission officers) who were so acting, would be validated. [Note: the 1993 Act grants judicial powers to the Commissioners.]

  3.26  The Association believes that the action proposed to secure investigations of the requisite quality, together with the accountability resulting from the Commission Board's consideration of every proposed use of judicial powers, should serve to protect beneficiaries; encourage the greater and proper use of the Commissioners' statutory powers; and make the most effective, efficient and economical use of the public funds allocated to this function.


  4.1  The NAO Report reviewed issues relating to the economy, efficiency and effectiveness of how the Commission has performed in its present regulatory role. It did not set out to address the more fundamental and wider-ranging issue of what changes might be appropriate to "enable the existing and new not-for-profit organisations to thrive and grow; to encourage the development of new types of organisation; and to ensure public confidence in the sector"—so as to "help to secure a strong, independent and diverse sector, capable both of challenging Government and working with it where appropriate". These are the stated aims of the current PIU review.

  4.2  The AfC, together with many other organisations with an interest in the health and development of this sector, will be making a submission to the PIU. It will be neither appropriate nor necessary, in this submission to the PAC, to attempt to cover the same ground as will be covered in the PIU submission.

  4.3  At the same time, the AfC welcomes the PIU's recognition that "there are growing public demands for greater openness and accountability". [PIU statement Modernising the Legal and Regulatory Framework for Charities and the Voluntary Sector—the Case for Further Reform]. One of the three key objectives of the Commission is "to improve the governance, accountability, efficiency and effectiveness of charities" (NAO Report 1.5). The AfC believes that "Physician heal thyself" (St Luke 4, 23) has a particular force for the Commission. How can the Commission be expected to improve the governance, accountability, efficiency and effectiveness of charities until it puts its "own house" in order by performing effectively and with integrity in its investigatory role and the exercise of its judicial powers?

  4.4  The Commission's effective lack of accountability for its decisions—particularly give the decision of the Courts that they would not review Commission conduct or decisions in appeals against Commission Orders—makes it difficult to envisage the likelihood of further trustee appeals, or of the chances of success were any such appeals to be made to the Courts. Given the already formidable obstacles facing any trustee attempting to challenge Commission Orders, the AfC claims that the necessity for appeals to go before the High Court needs to be subject to review and alteration.

  4.5  The AfC draws attention to arrangements in force in other fields of regulation: even where regulatory agencies do not have the substantial judicial powers of the Commissioners—and where appellants are not faced with the virtually insuperable obstacles in bringing appeals. The Association questions why it should be necessary for appeals against Commission conduct, decisions and Orders to be dealt with by the High Court alone, when elsewhere appellants can appear before independent tribunals, or seek alternative dispute resolution without reference to the Courts.

  4.6  Appeals to an independent tribunal could remove the virtually insuperable obstacles facing an appellant; and achieve an outcome in a greater reduced timeframe, and with greatly reduced costs to all parties. [Note: The present "High Court only" appeals can result, and have resulted in costs of over £200,000 and extend over a period of some four years. While such appeals provide substantial fees for the lawyers representing the parties, it is difficult to see what benefits they provide for charities and trustees.]

  4.7  In summary, the AfC believes that the present appeals arrangements are characterised by the following defects. They are:

    —  unparalleled: the Commission possesses relatively greater powers, without recourse to the Courts, than the Police. In no other area of activity known to the Association is it possible for decisions, involving those relating to the life, health and safety of people and animals (in respect of charity beneficiaries), to be made by a small and poorly-performing public service organisation (in the field of investigations). The Commission also acts as prosecutor, judge, jury and executioner in relation to the removal of charity trustees without there being any viable means of appeal against such decisions;

    —  unaccountable: Commission officers and the Commissioners appear to be unaccountable for their decisions—except to the High Court—which has declined to consider either their conduct or the circumstances in which they reached such decisions;

    —  unsatisfactory: the present arrangements fail to provide any effective safeguard to ensure that the Commission exercises its regulatory powers competently, fairly and in the interests of the charities it regulates;

    —  unsuited: the present arrangements appear unsuited to the proper requirements of a regulatory system; or to the needs of charities, trustees, beneficiaries, volunteers, charity workers and supporters to be served;

    —  unlawful (possibly): under the European Human Rights legislation and the Human Rights Act 1998, it is highly doubtful if a trustee, removed by Commission Order, could obtain a fair and proper hearing from the Commission acting as prosecutor, judge, jury and executioner;

    —  uneconomic: High Court and Court of Appeal hearings against Commission Orders are extremely costly:

      —  to the public purse: through the preparation for Court appeals by the Commission, Treasury Solicitor and Attorney-General, with the possibility that certain adverse Court costs may be borne by the public purse;

      —  to trustees: if their appeals against Commission Orders fail and they have all costs awarded against them;

      —  to charities: if no Receiver is in post and charity funds are used for the appeals; or if Court costs are awarded against the charity;

    —  unnecessary: the present regulatory arrangements are unnecessary because there are other well-established and well-tried methods of regulation and appeal which are far less complicated, less time-consuming and less costly to all concerned.

  4.8  The AfC believes that it is possible, desirable and indeed, essential for the present legal and regulatory framework for charities and the voluntary sector to be reviewed; and for a framework to be designed from first principles to avoid the defects and deficiencies of the current arrangements. The AfC trusts that the PIU, the Government and Parliament, with the support of the Committee, will address this issue.

Mr John Weth


The Association for Charities

November 2001

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