Friday 29 September 2023

Islington Council passes key motion on the Anti-Boycott Bill claiming the Bill poses a threat to local democracy, freedom of expression and civil society campaigns

 I wrote about concerns over the Government's Anti-Boycott Bill some time ago LINK so I was pleased to see that Islington Council last night approved a motion opposing the Bill and pointing out its difficulties. The initial motion was moved by two Green councillors, and amended by Labour. The final motion (below) was passed unanimously:

This Council notes:

  •   The “Economic Activity of Public Bodies (Overseas Matters) Bill”, otherwise known as the "anti-boycott bill", is slowly making its way through Parliament, and passed its second reading in July.

  •   The government’s planned anti-boycott bill poses a threat to local democracy, freedom of expression and civil society campaigns. It will shield states involved in practices that many people in this country find abhorrent, including genocide and occupation.

  •   If approved, the bill will restrict the ability of public bodies such as local authorities, universities, and some pension funds to make ethical decisions about investment and procurement. It will violate the rights of individual pension holders to invest their pensions in line with their values.

  •   The Labour Party tabled an amendment to the bill which sought to allow public bodies to make their own investment and procurement decisions and remove the threat of fines, ensuring that that such decisions are in accordance with an ethical investment framework that is applied equally across the board. This amendment was defeated in the House of Commons

  •   A broad coalition of over seventy organisations including charities, trade unions, human rights and faith organisations are working publicly to stop the bill, alongside the Scottish government.

  •   Sacha Deshmukh, Amnesty International UK's Chief Executive, called the bill “pernicious” and said “it will close off a key means to hold companies to account and once again show that this Government thinks little of the plight of persecuted communities around the world.”

  •   Lisa Nandy, MP for Wigan, revealed that the Labour Party has taken legal advice over the bill, calling it “bad law” and stating that lawyers had raised concerns that the bill could lead the way for endless litigation in the courts over the practice of Boycott, Divestment and Sanctions (BDS).

    This Council further notes:

  •   Procurement of goods and services is an important part of councils’ expenditure with third party revenue expenditure totalling around £60 billion a year across local government. This council spends £650million with almost 6,000 providers.

  •   In our progressive procurement strategy – adopted in 2020 – we seek to encourage and amplify the award of work, supply and service contracts to companies and professionals that perform public contracts with a business model based on ethical behaviour, and to promote democratic participation and drive social innovation.

  •   The framework incorporates a series of mandatory ethical requirements that we expect of ourselves and from those who want to do business with the council. By ethical behaviour, we define this as decent wages, fair employment practices, safeguards against modern slavery and environmental sustainability.

  •   In 2018, Islington became the first council nationally to sign the Charter Against Modern Slavery

  •   Over 80 local authorities across the UK have now signed the Charter, which Islington Council helped draft. Addressing modern slavery is a key priority for the council, with work on it overseen by the Safer Islington Partnership. We have an ongoing training programme to assist staff and partners to identify the signs of modern slavery.

  •   We use our leverage as a major commissioner to encourage suppliers to support and endorse accreditations and charters such as ethical procuring and supply chain visibility.

  •   Trade Unions have an important role to play in the fight against modern slavery and exploitation by supporting and championing workers’ rights. Workers and providers are frequently not aware of their rights and responsibilities. It is for that reason that the Council has taken a stand against blacklisting of trade union members and emphasise this requirement as mandatory.

  •   BDS has a centuries-long tradition as a successful method of peaceful protest and local government has played its part in following this democratic political practice.

  •   BDS campaigns have been used by social movements to change the course of history for the better.

  •   Concerned members of the public and local authorities have championed BDS tactics in prominent campaigns such as the 1963 Bristol bus boycott, the rejection of sugar produced on slave plantations, led by nineteenth century British citizens, and divestment from fossil fuel companies. The best-known boycott was the campaign to end apartheid in South Africa.

  •   During the campaign to end South African apartheid, similar limitations were introduced. Nonetheless, millions of people, including local councils, continued their support for the movement.

  •   In 2016, a UK High Court ruled that the boycotts of Israeli settlement goods by local authorities in Leicester and Wales were not anti-Semitic, nor did they contravene laws on equality.

  •   Restricting the ability of local councils to engage in BDS in wrong. In a world where Uyghur’s, undergoing ethnic cleansing, are forced to produce garments and commodities, where local government pension funds are invested in arms companies known to be complicit in violations of Palestinian human rights, and where Saudi Arabia, accused of crimes against humanity, is the world’s largest oil exporter, we need these tactics to hold those complicit to account.

This Council resolves to:

  •   Write to the Prime Minister to share, and ask him to consider, the legal opinion published by the Labour Party on the rights of councils to boycott oppressive regimes and illegal practices, emphasising the need for councils to make their own decisions on procurement and investment matters.

  •   Continue to ensure that our own ethical procurement strategy doesn’t include procuring goods and services produced by oppressive regimes,

GLA Call for Evidence: Preventing Violence and Protecting Young People


The weekend's stabbings in Wembley Park and Neasden, as well as the death in Croydon, were very much on our minds last night at the Brent and Harrow hustings for the Green Party candidate for the GLA constituency.

The London Assembly Police and Crime Committee chaired by Green Assembly Member Caroline Russell, has launched an investigation into preventing violence and protecting young people. It will consider the root causes of violence affecting young people in London and what the Mayor and Metropolitan Police are doing to prevent violence in communities.

You can submit your own evidence to the investigation.  Details from  the GLA below.


How to respond 


The deadline for submission is Friday 13 October 2023.


The Committee would like to invite anyone with knowledge or experience of violence affecting young people to submit views and information to the investigation, including those working to protect young people and prevent violence, giving you the opportunity to inform the Committee’s work and influence its recommendations. Therefore, this call for evidence is open to all who would like to respond.


1.    What are the root causes of violence affecting young people in London?

2.    What role do non-policing solutions, including projects run by youth services, community organisations and charities, play in preventing violence and protecting young people in London? How do these projects help to reduce violence affecting young people?

3.    What more should schools and education providers be doing to protect children and young people at risk of violence in London?

4.    What impact has London’s Violence Reduction Unit had on reducing and preventing violence since it was established in 2019?

5.    How well does the Met work with partner organisations to prevent and reduce violence affecting young people? What more should it be doing?

6.    What actions should the Mayor be taking to build trust and confidence among young people and protect communities that are most impacted by violence?

7.    What action should be taken to engage young Londoners in initiatives to protect and support young people affected by violence?


Please send evidence by email to:


What we will do with your responses

The responses to this Call for Evidence will be used to inform the Committee’s discussion with invited stakeholders at its meetings in September and October 2023 and any subsequent recommendations. These are open meetings which will be held in City Hall, and anyone is welcome to attend as an audience member to watch the discussions. They will also be broadcast online.

Following the investigation, the Committee may produce an output in the form of a published letter or report. Information and/or quotations from submissions to this call for evidence may be used in this output, and we will ensure we cite you. We generally inform those who have submitted evidence about the outcome of the investigation in the form of link to a report or output when it is published.


Brent Council writes to tenants on implications of the Building Safety Act ahead of Saturday's deadline

Wembley Matters has written about the implications of the Building Safety Act on a number of occasions as well as putting questions to the Brent Cabinet lead member for housing.

Now Brent Council has written to tenants and leaseholders of all the blocks owned by the Council affected by the Act with the actions they and tenants have to take to comply.  I have embedded the letter below in order to keep the QR codes intact.

As usual click on bottom right to enlarge the image. 


These are the Brent Council blocks affected. In addition blocks owned by private companies and housing associations will come under the Act if they meet the criteria.

 Asked by Wembley Matters to comment on the Brent Council letter a local tenant said:

I wonder if any of those receiving a letter are aware of all the other statutory obligations that the council has to send to the building regulator by Saturday.

1) Registration ---Completed

2) KBI's (Key Building information)

3) Following Registration the council have to publish their Resident Engagement Strategy, along with a Complaints Policy in order to apply for a Building Safety Certificate for each building.

4) Publish a safety case for each building, including Resident Profiles.

However the Regulator will only wish to see a safety case if there has been a recent incident, so that means the council have to send a safety case for Kilburn Square which shows the regulator what fire safety measures were in situ at the time of the fire.

All the above have to be with the regulator by Saturday the 30th September 2023.

In the letters, the council  only refers to Safety Case Reports which are summaries of safety cases but they are not the same.

Safety Case Reports are not needed to be sent to the Regulator until the deadline which is the 6th April 2024.

Thursday 28 September 2023

Ballymore to submit hybrid application for Kensal Canalside development at the end of the month - write a complaint letter

 From Keep Kensal Green



On September 14th we learnt that Ballymore would be submitting a "Hybrid" Planning Application to RBKC at the end of September. 

A Hybrid application means that Ballymore will only submit a detailed plan for the new Sainsburys build.

Plans for the rest of the housing development  will only be submitted in outline with updated plans for different parcels of land (or plots)  submitted as and when Ballymore are ready.

This type of planning application is not unusual for large scale developments, but given the long list of concerns raised by residents about scale and density of the build, loss of light, traffic congestion, impact on the Cemetery, drain on local infrastructure and crucially the issue of site contamination and how this will be dealt with on a "plot by plot" basis -- its vital that we register our complaint NOW before the application goes in. 

We have been advised by a lawyer that residents should have been made aware from DAY 1 of the consultation process that this was a HYBRID planning application. RBKC's failure to do so is deemed "misleading" and unacceptable.

We have also been advised we have grounds to mount a challenge and ask RBKC to start a new consultation process that this time, includes information about the proposed Hybrid application.

If you would like to register your concern please click on the link to download a TEMPLATE Letter of Complaint which you can adapt and edit as you like.

Wednesday 27 September 2023

'Not ANOTHER winter with damp and mould' - Brent Renters negotiate with Brent Council on Saturday 30th September 10.30pm to 1pm

 The Brent branch of the London Renters Union are meeting with Muhammed Butt, leader Brent Council, and Cllr Promise Knight, the Cabinet lead on housing on Saturday.

The aim is to negotiate action on the pressing problem of mould, damp and other health issues in private housing,

The group have produced a powerful video that shows how renters are suffering at present. LINK

The campaign is pushing for Brent Council to take much stronger enforcement action against landlords who are breaking the law. They don't think renters should be paying upwards of £2,000 a month to get asthma and other chronic health conditions.

Brent Renters urge the public to sign their petition HERE that states:

BRENT COUNCIL: Not another winter with damp and mould

 More than 10,000 private rented homes in Brent have a serious health hazard. Damp and mould are making us sick, leading to asthma, respiratory issues, skin conditions, and  mould poisoning. 

Our children’s health is in crisis because landlords are being allowed to get away with not keeping our homes safe. Damp and mould mean people can’t use some rooms, and are overcrowded in the others. This meant that Church End had the highest Covid death rate in the country. 

Brent council has a legal duty to make sure our homes are safe but their current plan isn’t good enough. In the areas of Brent where housing is most dangerous, they’re only promising to deal with 10% of the most serious problems this year. What about the other 90% of renters left with unsafe homes?

It doesn’t have to be like this. Members of the London Renters Union in Brent have come together to create an action plan for how the council can hold landlords accountable and keep us safe. Add your name to our campaign. Together we can win safer homes for everyone. 

If you are part of an organisation, please ask them to support the campaign by sharing this petition, and by signing the open letter here.

For background info, see our factsheet here




Wembley Park road closure from 8.30am on Sunday for NFL game

From Brent Council

Jacksonville Jaguars vs Atlanta Falcons 

Wembley Stadium will be hosting a National Football League (NFL) game between the Jacksonville Jaguars vs Atlanta Falcons this Sunday 1 October. Please read below to see how this might affect you.


Doors will open from 11:30am and road closures will be in place from 8:30am.

We expect the area around Wembley Stadium to be very busy before and after the event so please avoid the area if you can unless you have a ticket.

The sad story of Wembley Hill Lodge and the current view from the upper deck of the 297 bus

After a passing bus passenger said that she had seen the landmark Wembley Hill Lodge being demolished there was a flurry of activity on social media. The Victorian Society tweeted concern as it is a listed building.   In fact back in January 2023 Brent Council planning officers had approved partial demolition and rebuild of the listed but fire damaged Lodge as well as permission for a two storey house to be built in the grounds.

The Victorian Society does not appear to have been consulted despite the cottage's listed status. LINK


The site today


I took a photograph of the current state of the site from the 297 bus this lunchtime and it is indeed a sad sight. Foundations for the new house were being prepared before restoration work has begun. The architect, Alex Nacu used an archaic form of the word 'restoration' in their planning statement. There was no reference to the new house in that statement so I had to go to the plans. Wembley Hill Lodge was not listed on their 'Projects' links.

The restored Lodge and the new 2 storey building

Work is in progress but it is worth referring back to the documentation of the January 2023 decision to see what is being envisaged, recommendations and in particular the Conditions appended to the approval. Are they being adhered to?  Work appears to have begun on the footings for the 'New House' before restoration of the cottage. The cottage was left open to the elements and resulting damage, which made it less likely to survive.


Historic England’s Position


This application reflects the results of our pre-application discussions and therefore Historic England is pleased to support these proposals as presented. In our view the accurate restoration / reconstruction of the lodge would deliver clear heritage related public benefits, securing the building's long term future and returning it to its optimum viable use. The proposals would also likely lead to the building's removal from the Heritage at Risk Register.


The restoration of the lodge is of the highest priority and therefore should your council be minded to approve the application, it’s essential in our view that the proposed new building to the rear of 114 Wembley Hill Road is clearly linked to the repair and delivery of the listed building, secured through conditions and/or legal agreement. We would consider the phased repair and restoration of the listed building prior to the delivery and/or occupation of the new building would comprise a significant public

benefit that should be taken into account when weighing the application in the planning balance.


We would further recommend the following safeguards are secured through discussions with the applicant to ensure the repair is executed in a scholarly and faithful manner.


*Detailed building recording is carried out prior to any demolition to inform the reconstruction of the listed cottage.


 *Method statements concerning the dismantling of the existing structure and repairs to the remaining historic fabric using approved conservation techniques, ensuring adequate protection throughout.





Officers’ Report


The NPPF (2021) recognises that heritage assets are an irreplaceable resource and seeks to conserve them in a manner appropriate to their significance. It further states that when considering the impact of the development on the significance of a designated heritage asset, great weight should be given to the assets conservation (and the more important the asset, the greater the weight should be). This is irrespective of whether any potential harm amounts to substantial harm, total loss or less than substantial harm to its significance. Policy BH1 of the London Plan states that where heritage assets have been identified as being 'At Risk', boroughs should identify specific opportunities for them to contribute to regeneration and place-making, and they should set out strategies for their repair and re-use.


A Structural Survey/ Inspection Report has been submitted as part of this application, detailing the site conditions at the time of submission of this application in which no works have been undertaken to protect or preserve the site since the fire in 2013. The report notes that the building is in extreme poor structural condition as it remained unprotected from weather conditions with only the footprint, chimney and external walls remaining -the surviving windows and doors exposed to moisture and fungal attack, the load bearing walls are unstable, external cracks are also evident on some of the building's walls with shrubs propogating through the cracks in several locations which indicates that the building is experiencing cracking and movements. The building is dangerous and at the risk of collapsing.


The Heritage Statement submitted with this application, sets out the need to demolish and reconstruct the surviving portion of the lodge that burnt down and to build a new addition of the footprint of the 1930s extension and a New House on-site. The design approach follows the conservation philosophy of reconstruction and addition to historic structure. As per the Listed Building Consent (21/2009) granted in 2021, the design approach towards the Listed Building remains unchanged -with the only difference for this Listed Building Consent application is the removal of the proposed basements in the 'Lodge' and 'New House' that was granted full planning permission. The Council's Heritage Conservation officer notes that the plans submitted with this Listed Building Consent application does not provide a basement level, and that the 'Lodge' never had an original basement to begin with so the removal of the proposed basement would not harm the significance of the building.The Heritage Conservation Officer is overall satisfied with the proposed works which would preserve the character and setting of the Listed building as a building of special architectural or historical interest.


Notwithstanding this, conditions would be issued with any consent to ensure that the restoration and reconstruction works to the 'Lodge' is completed before works before works for the 'New House' can commence. This would ensure that the restoration of the lodge is prioritized within the proposed development.


On balance, and considering the existing 'At Risk' state of the building and the restoration/ proposed works to restore the building, the proposal is considered acceptable in principle




4. No development shall take place before detailed building recording (internally and externally) is carried out prior to any demolition to inform the reconstruction of the listed Lodge. This should be submitted and agreed in writing by the Local Planning Authority.

Reason: To safeguard the architectural or historic interest, necessary repair work and significance of the Listed Building.


5 No development shall take place before a method statement has been provided concerning the dismantling of the existing structure and repairs to the remaining historic fabric of the listed lodge using approved conservation techniques. This should also illustrate adequate protection of the surviving fabric.


The report(s) should be submitted with a phased schedule of works for the whole site and agreed in writing by the Local Planning Authority.


Reason: To safeguard the architectural or historic interest, necessary repair work and significance of the Listed Building.


6 No development shall take place before specialist contractors in restoration and repair works have been agreed by the Local Planning Authority.

Reason: To safeguard the architectural or historic interest, necessary repair work and significance of the Listed Building.


7 No development shall take place before sample panels of brickwork for the listed Lodge and the new build demonstrating the colour, texture, bond and pointing of the brickwork have been provided onsite for inspection and approved in writing by the Local Planning Authority. The details shall include the colour, texture, bond and pointing of the brickwork and the development shall be carried out in accordance with the approved details.

Reason: To ensure a high quality design and to protect the character of the listed buildings the visual amenity of the area.


8 No development to the listed Lodge shall take place before the following has been provided and agreed in writing by the Local Planning Authority.

· A window and door schedule including sections at scale 1:10.

Reason: To safeguard the architectural or historic interest, character, appearance and significance of the Listed Building


Philip Grant wrote a guest post in 2021 regarding the first planning submission for the site and thought that though not perfect, it offered a reasonable solution to  the problem of what to do with the house and site. LINK


Tuesday 26 September 2023

New Petition: Save Barham Park from commercial development


A new petition has been launched on the petition site LINK

 The Petition

Barham Park in Wembley/Sudbury (Brent) was donated to the 'public' for their recreation by Titus Barham the owner of Express Dairies in 1937.

The original buildings, some dating back to 1780, are currently rented out to local groups including Barham Community Library run by volunteers. The Leadership of Brent Council wants to get rid off all of the existing community groups and redevelop the buildings for commercial uses such as hotel rooms, supermarket, shops and commercial office space.

Local people oppose these plans and want to see them scrapped.

Barham Park used to be the home and gardens of the Barham family. We want the Titus Barham gift & legacy to be preserved for the enjoyment of the public.

Support our campaigning and help us send a message to Brent Council - HANDS OFF OUR PARK


Barham Park Trust accounts rubber stamped despite detailed anaylsis revealing many problems with them

 Paul Lorber was refused permission to present this paper on the Barham Park Trust accounts at today's meeting. The meeting lasted less than 10 minutes. Officers said that representations had been dealt with in previous correspondence and the accounts were fine. Cabinet members in the guise of trustees asked no questions and then rubber stamped them.




The revised accounts for the year 2022/23 are fundamentally wrong and should not be approved. They are inconsistent with previous years, do not reflect the correct income due to the Charity, overstate the Charity expenses and do not provide information in an understandable and clear way that makes review and scrutiny of those accounts easy.


I deal with some of the key issue in detail below and summarise the other issues in need of investigation.


Rental Income presentation problem (the income is not confidential and can be easily ascertained from past public reports)


Excluding the £11,300 rental income from the Children centre, £6,500 from Virgin Media, casual rentals and income from the funfair the Rental Income due from the four tenants occupying the Barham Park buildings is as follows:

ACAVA                                    £43,000

Friends of Barham Library         £7,000

Barham Veterans Club                £3,000

Tamu Samaj                                 £1,500

TOTAL                                       £54,500


This income has remained unchanged for some years. According the Officers the Accounts are presented on a Cash “received” basis rather than on the more usual” arrears” basis.


This income is shown in the accounts on the line described as “Rental Income – other”

The amounts shown are:

17/18               £50,373

18/19               £52,500

19/20               £51,500

20/21               £51,500

21/22               £50,009

22/23                 £1,625


None of the years 17/18 to 21/22 agree with the expected income suggesting that some rents were not collected. The officers may want to explain which tenant did not pay and why or what the discrepancy with the expected £54,500 p.a. is for each of the years.


The amount for the year 2022/23 looks very odd compared to all the previous years. The officers claim that the Accounts for the Trust are prepared on a cash basis (i.e. they show income in terms of cash received and payments in terms of cash paid rather than on the traditional accruals basis of showing the income expected to be received in the year with any amount not received shown in debtors.)


This explanation does not stand up to scrutiny when you look at the extracts from the minutes dealing with the 2020/21 accounts. Minute 3.5 clearly states “the majority of the rental income for 2020/21 is still outstanding”. If this is so why is the supposedly “cash received” figure for the year showing £51,500 when most of the rental income “has not yet been paid”.


The rental income for 2019/20 of £51,500 too is clearly also NOT the “cash received” as note 3.6 below states that at 31 March 2021 …..£76k of the rental income has not yet been received. As ACAVA’s annual rent is £43,000 this means that £33,000 (£76,000 less £43,000) of the amount outstanding as unpaid must relate to 2019/20 – which in turn means that the £51,500 clearly cannot possibly represent the “cash received” in respect of rent in that year.

Extract from 2020/21 Accounts

3.4 During 2020/21 the Trust incurred expenditure of £96,283 on maintenance of the building complex and the park. This is made up of £60,383 of unrestricted funds expenditure and £35,900 of restricted funds. The Trust generated £81,300 receipts from rental income and interest earned.

3.5 This includes rental income that is due but has not yet been paid. The majority of rental income for 2020/21 is still outstanding. The cumulative rental income due but not paid as at 31 March 2021 was £76,291.

3.6 This means that as at 31 March 2021, the Trust had assets of: (i) £58k unrestricted funds cash (ii) £353k restricted funds cash (iii) £76k rental income due but not yet received (unrestricted funds) (iv) £939k valuation of Barham Park Building Complex

3.7 This means that if the rental income arrears are not received, the Trust would have only £58k of unrestricted cash. If the arrears continue building up, the £58k would be enough to cover around 12 months of maintenance and wardens costs.




The Accounts for all years to 2021/22 have been produced on an accruals basis (they show the rent due and not the cash income received).


The revised 2022/23 Accounts presented to you on Tuesday 25 September 2023 are wrong as they are being presented on an inconsistent and a totally incomprehensible basis.


The 2022/23 figures are attempting to show some form of ‘cash basis’ whereas the comparative figures for 2021/22 are clearly on the correct accruals basis.


Even if officers were correct to present the 2022/23 on a cash received basis to make the accounts consistent and for them to make sense they would have to revise the 2021/22 comparatives to a cash basis too.




In terms of the size of its transactions the Barham Park Charity should prepare its accounts on an accruals basis as in relation to rental income the accounts would show the rents due in the year and any amounts uncollected/owing would be shown as a debtor and any rents paid in advance/prepaid would be shown as a creditor.


This makes it straight forward to make comparisons between the years in respect of both income and expenditure figures making it easy for Trustees and 3rd party observer to see the trends between years and ask questions if unusual variations arise.




Various reports claim that the Council provides the Barham Park Charity with a subsidy. This cannot be substantiated because none of this is reflected in the Barham Park Trust Accounts.


Charity Commission Guidance covers this issue:




Accounting and Reporting by Charities: Statement of Recommended Practice applicable to charities preparing their accounts in accordance with the Financial Reporting Standard applicable in the UK


Accounting for donated facilities and services, including volunteers

6.13. If a charity is given facilities and services for its own use which it would otherwise have purchased, these must be included in the charity’s accounts when received, provided the value of the gift can be measured reliably.

6.14. Measuring donated services using fair value would not be practical as such services cannot be resold and the use of fair value may result in an overstatement of the value of the donation to the charity. Donated facilities and services are therefore measured and included in accounts on the basis of the value of the gift to the charity.

 6.15. Value to the charity is the amount that the charity would pay in the open market for an alternative item that would provide a benefit to the charity equivalent to the donated item. Value to the charity may be lower than, but cannot exceed, the price the charity would pay in the open market for the item. Accounting and Reporting by Charities Page 62

6.16. Donated facilities and services that are consumed immediately must be recognised as income, with an equivalent amount recognised as an expense under the appropriate heading in the statement of financial activities (SoFA).

6.17. Facilities such as office accommodation or services supplied by an individual or an entity as part of their trade or profession can usually be reasonably quantified and must be included in a charity’s accounts.

6.18. Charities often rely on the contribution of unpaid general volunteers in carrying out their activities. However, placing a monetary value on their contribution presents significant difficulties. For example, charities might not employ additional staff were volunteers not available, or volunteers might complement the work of paid staff rather than replace them. These factors, together with the lack of a market comparator price for general volunteers, make it impractical for their contribution to be measured reliably for accounting purposes. Given the absence of a reliable measurement basis, the contribution of general volunteers must not be included as income in charity accounts.

6.19. However, it is important that the user of the accounts understands the nature and scale of the role played by general volunteers. Charities must include a description of the role played by general volunteers and provide an indication of the nature of their contribution in a note to the accounts




If substantial – and the Council implies this by always refering to providing the Barham Park Charity with a subsidy – the services provided by the Council to the Charity must be valued and shown both as Donated Income on one side and ‘deemed’ expense on the other.


While the net impact is £0 any reader of the accounts become aware of the true cost of managing the Charity.




Do the trustees know or understand what the figure described as cash advance” of £27,092 represents?


According to the report the £27,092 is actually a net figure made up of the remaining balance of rent owed by one of the tenants of £39k offset by an unpaid consultancy fees of £12k due to the Architects for their recent work on the ‘hypothetical’ project.


It is described this way in the Report:

3.11 As at 31 March 2023, the Trust had a rental debtor of £39,625 and a £12,533 payment that was due but not yet paid. These have been recognised as debtors and creditors on the Council’s side and the Council gave a net £27,092 cash advance to the Trust in order to aid the Trust’s cashflow position and avoid a detrimental effect of outstanding debt on the Trust’s financial position. In 2022/23 the cash advance has been reported on a separate line in the income section to aid transparency. The Council has also paid interest to the Trust on the cash advance. The Trust continues liaising with tenants and expects all arrears to be cleared by March 2024.


In my view the netting off of these two figures and their presentation is wrong. Income should be shown in the Income section and the Expense in the Expense section. More importantly it hides the fact that £12,533 of consultancy costs on top of the £8,711 already shown in the accounts (Total £21,244) – and there may be more paid and charged in 2023/24 to the Barham Park Charity when they should NOT be.


The treatment of the estimated costs of £25,000 for the architects working on the recent Barham Park vision study was agreed and confirmed at the Trust Meeting of 27 January 2022. This is what the minutes say:

Having authorised officers (in September 21) to prepare a financial strategy in respect of the Trust, approval was now being sought to the appointment of an architect in order to lead development of a more holistic options appraisal relating to the feasibility of improvements to the buildings comprising the Estate and impact on current occupation uses and tenancies.  The cost identified for the architectural services required had been £25,000 which it was proposed to fund from the Council’s Capital Programme rather than directly by the Trust, given the existing commitments on its available restricted and unrestricted funds.




If it was agreed to charge the Architects cost to the “Council’s Capital Programme” why are £21,244 of the costs charged to the Barham Park Charity in its 2022/23 accounts.


The Charity’s surplus for the year and its unrestricted funds are clearly being reduced by this substantial amount.


The 2022/23 Accounts are therefore materially wrong on this point alone and need to be corrected.




I will just list a few issues here that need investigation, should concern the Trustees and should lead to more questions.

1.      The Barham Park Charity has been deprived of correct Interest Income. The amount paid to it by Brent Council for the use of over £500,000 of cash balances does not represent a fair arms length price. I estimate that in the current year The Charity has been deprived of at least £5,000 of extra income and the amount will be at least double that if this is allowed to continue.


2.     The so called ‘arms length’ rent paid by the Council to the Charity for the use of the former Children Centre has not changed for years. As the sub lease has expired a true market rent should be charged each year. The Council has failed to follow correct procedures in ensuring that an ‘arms length rent’ is paid.


3.      It is also not clear why the Children Centre is not paying service charges for services such as refuse collection, water etc that it receives. There is no reason why the Charity should be paying for this.


4.     There has been a failure to implement rent reviews due some years ago. The cumulative cost of this failure runs into tens of thousands of pounds in lost rental income to the Charity.


5.      The Charity has had a benefit of NCIL Grants to upgrade the QE II Silver Jubilee Gardens and the Pond in the Park. The value of these Grant is well in excess of £100,000. The accounts for the current and previous years for failing to reflect both the Grant Income received and the expenditure on which the Grant was spent on.


6.     The Accounts fail to show enough detail in relation to the expenditure line of “maintenance and wardens”. This heading includes some expenditures which have nothing to do with maintenance and include items which should be included in the lines – including utilities, waste disposal etc. Without this information the Trustees and others cannot be certain if some of these costs should not have been recharged.


Why is the Charity incurring an insurance charge of £2,500 – should not some or all of this have been recharged?




I have tried to engage with Council officers to highlight these issues. My views and concerns have been ignored. As a result the revised Accounts as presented are fundamentally wrong.


1.     They are prepared on the wrong and inconsistent basis.


2.     They do not comply with acceptable accounting policies as advised by the Charity commission.


3.     The figures are wrong.


4.     They understate the Charity’s Income


5.     They overstate the Charity’s expenses


6.     As a result of 4 & 5 above they understate the net worth of the charity (its net assets).


These accounts should NOT be approved or submitted to the Charity Commission in their current state.


Councillor Paul Lorber

25 September 2023