2022-03-31-accounts

Company number: 02368562 Charity Number: 1003342

Report and financial statements For the year ended 31 March 2022

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Public Law Project annual report

Reference and administrative information

For the year ended 31 March 2022

Reference and administrative information ........................................................................................................... 3 Director and Chair’s reports .................................................................................................................................. 4 Trustees’ annual report ......................................................................................................................................... 7 Independent auditor’s report .............................................................................................................................. 30 Statement of financial activities (incorporating an income and expenditure account) ...................................... 34 Balance sheet ....................................................................................................................................................... 35 Statement of cash flows ....................................................................................................................................... 36 Notes to the financial statements ....................................................................................................................... 37

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Public Law Project annual report

Reference and administrative information

For the year ended 31 March 2022

Company number 02368562 Charity number 1003342 Registered office The Design Works, 93-99 Goswell Road and operational London address EC1V 7EY Country of incorporation United Kingdom Country of registration England & Wales Trustees Trustees, who are also directors under company law, who served during the year and up to the date of this report were as follows: Sarah Jane Burton Renata Czinkotai Pavan Dhaliwal Andrew Hood Company Secretary Rosanna McKearney (Resigned 28 September 2022) Qalid Mohamed (Resigned 29 June 2022) Bryan Nott Elizabeth Prochaska Chair Richard James Savill Treasurer Mark Wood Director Jo Hickman Bankers Unity Trust Bank PLC Nine Brindleyplace BIRMINGHAM B1 2HB Auditor Sayer Vincent LLP Chartered Accountants and Statutory Auditor Invicta House, 108-114 Golden Lane LONDON, EC1Y 0TL

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Public Law Project annual report

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Director’s report

PLP made meaningful progress despite significant and often intensifying challenges across our focus areas, and for the people with whom we work. I’m immensely proud of the focus and dedication of the PLP team.

One significant win was the Government’s agreement to remove a clause from the Judicial Review and Courts Bill that would have significantly weakened the remedies available to people using the law to hold the state accountable. This was achieved through determined collaboration across the sector, and reflected a new workstream for PLP, focusing more intently on constitutional reform.

This focus, and the addition of new influencing and research resources, allowed us to have a bigger impact across a range of legislative and policy areas, including on human rights, Government use of algorithmic and automated decision-making, immigration reform, the Nationality and Borders Bill, legal aid, welfare and benefits, and treaties. We published articles and we are quoted with increasing regularity and prominence across national and sector media and in academic journals. The reach of our work grows ever wider, as we can see in the number of times PLP briefings and research from all our focus areas have been positively cited and referenced in Parliamentary debate, committee and by independent reviews.

We were also able to support our clients to achieve important wins. Following a judicial review claim the Department of Work and Pensions agreed to waive hardship payment debt accrued by a Universal Credit claimant who had been incorrectly sanctioned. The Department then revised guidance to decision-makers to clarify where it has discretion to waive such debt. We helped a group of ex-sex workers and their supporters use the Equality Act and the Human Rights Act to challenge an order by the Hull City Council that left them at greater risk of danger, and our longstanding work with the NGO APPEAL recently resulted in the BBC agreeing to undertake a gender equality review in 2022.

Meanwhile our work in Wales is progressing well. Our new Wales-based lawyer has worked closely with organisations supporting asylum seekers to get safe accommodation and supported public law challenges including: a failure to assess the needs of a disabled wheelchair user; a failure to provide accommodation to a disabled child near to essential medical treatment; and a delay in deciding a financial support to a mother of two relying on foodbanks.

Inside PLP

We continued work to acknowledge and address the effects of the Covid-19 pandemic on PLP as an organisation and on its individuals. Being well positioned in terms of our infrastructure and remote working policies allowed us to work effectively and promote team connectivity during this period, and we saw growth of capacity and resources across our teams. We spent time and resources developing wellbeing initiatives and creating regular opportunities for connectivity. Staff feedback from the wider team showed an overwhelming sense of belonging and commitment to the organisation and its goals.

In Autumn 2021 we said goodbye to Research Director Dr Joe Tomlinson and Legal Director Alison Pickup who stepped down from their roles. Alison joined Asylum Aid as Director and Joe turned to focus on his academic roles, although he remained an Associate Fellow with PLP.

We took this opportunity to recruit a Legal Director to lead both casework and research teams and we were delighted to appoint Ariane Adam, a barrister with experience in leading strategic litigation,

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Public Law Project annual report

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policy and charity research initiatives. Ariane started at PLP in January 2022. This change has allowed us to make even better use of the synergy between these two teams that is unique to PLP’s approach.

We also created two new roles: a Policy and Parliamentary Officer and a Communications Officer, both reporting into the Communications Director as part of a reconfigured Communications and Events Division. The addition of both positions has been transformative. The Policy and Parliamentary Officer played a key role in our successful work on the Judicial Review and Courts Bill, and our Communications Officer has helped to increase the impact of our work across the board.

Looking forwards

As 2022 marked a new strategic period we spent much of 2021 exploring and developing a new threeyear strategy to build on achievements and refocus to maximise our impact. The 2022-2025 strategy has now been finalised and will mark an exciting new phase for PLP.

In particular, we put significant time and resource into reflecting on our anti-discrimination objectives and our approach to equality and diversity. Although equality has long been one of our core values, it was time to take a fresh look at our approach. Our new strategy acknowledges that institutional discrimination permeates society, the legal system, and the charity sector within which we work, and that despite our best intentions, it is reflected in our own structures.

We have explicitly acknowledged PLP’s privilege, status and platform in the public law sphere and committed to making an active and conscious effort to understand and address the effects of discrimination in all our work, both externally and internally.

This includes improving the way we work with user-led groups and movements and our understanding of lived experience. PLP will continue to do more to connect with and learn from individuals, groups, communities affected by unlawful state decision-making - and organisations representing their interests - throughout the design and delivery of our work.

And finally

This will be my last Director’s Report. As we announced in Summer 2022, I will be stepping down as Director of PLP at the end of 2022. I have been at PLP for 13 years, including a stint as the Head of Casework and seven years as the organisational Director and it feels like the right time for a change.

I’m so grateful for my time at PLP. It has been a privilege to have had the opportunity to work with and to learn from so many brilliant people – colleagues, clients, partners and friends across the social justice space.

It’s always hard to leave an organisation and people that you love. However I know I am leaving PLP in great shape, and with an extraordinarily talented team of staff and trustees. Their ideas, energy and commitment are truly inspirational and I have no doubt PLP will continue to go from strength to strength.

Jo Hickman

Director Public Law Project

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Chair’s report

PLP strives for a world where the state acts fairly and lawfully. This may sound simple, but amidst escalating attacks on basic democratic standards, this goal feels more important - and ambitious - than ever.

An emerging threat that PLP identified in the previous year was the effort by Government to re-shape the relationship between the executive, legislature, and judiciary in fundamental and problematic ways. This year, if anything, that effort has intensified. At the end of the 2022 reporting period, the Government looked set to press ahead with reform - if not wholescale repeal - of the Human Rights Act; Brexit legislation is in train to place unprecedented law-making powers in the hands of ministers; and more and more decisions that impact people’s freedoms and access to state services are being made by automated systems and algorithm. Meanwhile, benefit sanctions reached record highs, eligibility for legal aid continued to restrict access to justice, and new immigration reforms place even more lives at risk.

As our casework team sees first-hand and know all too well, the people who suffer the impact of all this are the single mothers and victims of domestic violence who cannot access legal aid, disabled people who are wrongly denied benefits, victims of trafficking who are improperly harassed by local authorities, and migrants who are unlawfully removed to violent regimes.

It is a credit to PLP’s agility that we have been able to shift our focus to where it is needed and adapt how we work where necessary. We created new roles and recruited outstanding people that allowed us to better understand these threats and how to tackle them. The team has done a brilliant job, from helping get important amendments to flagship government Bills and addressing Parliamentary committees, through to publishing thought leading articles, media briefings, conferences and roundtables.

I joined PLP as Chair three years ago because I was passionate about its work protecting rights and the rule of law. I’m continually impressed by the drive and determination of the team and the quality and breadth of their work. Our people act in vital legal challenges big and small; we publish cutting edge research, deliver stellar public law training and events, and perform outstanding advocacy and influencing. Our unique approach of combining this expertise puts us at the heart of addressing the strong tide of regressive change, against which all wins are hard fought. The work that PLP has undertaken this year, externally and internally, including the development of our new strategy for 2022-25, means we are well positioned to play an active role in ensuring the state acts fairly and lawfully.

Finally, I would like to extend, on behalf of the board, our huge thanks to PLP’s Director, Jo Hickman who is standing down at the end of 2022. Jo has given PLP outstanding leadership and has truly transformed the organisation. We are all hugely grateful, not least for building such an exceptional team, and for putting the organisation in such strong shape to carry on our mission.

Elizabeth Prochaska

Chair Public Law Project

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Trustees’ annual report

The trustees present their report and the audited financial statements for the year ended 31 March 2022. Reference and administrative information set out on page 1 forms part of this report. The financial statements comply with current statutory requirements, the memorandum and articles of association and the Statement of Recommended Practice - Accounting and Reporting by Charities: SORP applicable to charities preparing their accounts in accordance with FRS 102.

Objectives and activities

Role of trustees

The trustees review the aims, objectives and activities of the charity each year. This report looks at what the charity has achieved and the outcomes of its work in the reporting period. The trustees report the success of each key activity and the benefits the charity has brought to those groups of people that it is set up to help. The review also helps the trustees to ensure that the charity's aims, objectives and activities remained focused on its stated purposes.

The trustees have referred to the guidance contained in the Charity Commission's general guidance on public benefit when reviewing the charity's aims and objectives and in planning its future activities. In particular, the trustees consider how planned activities will contribute to the aims and objectives that have been set.

Purpose and aims

The decisions of public bodies have a significant impact on the lives of marginalised and disadvantaged people. Such decisions may include whether health care will be provided to an older person, whether benefits will be awarded to a destitute family, or whether a migrant fleeing torture will be detained or removed from the country. Those with the most to lose from unlawful or unfair decisions are often the most vulnerable.

The purpose and aims of the charity are, therefore:

• To improve access to public law remedies for those whose access to justice is restricted by poverty or some other form of disadvantage

• To promote and undertake research into the practice of public law, and

• To increase understanding, expertise, and knowledge of public law and how it can be applied

In fulfilling this mission, PLP carries out work in the following areas:

• Research and policy work to influence and inform policy

• Training and events to enhance capacity and expertise in the use of public law

• Advice and support to frontline charities and civil society organisations, and

• Casework to represent individuals or NGOs with standing, to act as an intervener, and in exceptional circumstances, to act as a litigant in its own right.

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Strategic Report

During the reporting period, PLP reviewed and updated the five-year strategic plan 2017-22 to reflect emerging themes.

PLP’s central organising goals for 2021-22 were:

• Goal 1: Identify and contribute to the prevention of regressive constitutional reform

• Goal 2: Use resources effectively to challenge unlawfulness significantly impacting on disadvantaged groups and support others to do so, and

• Goal 3: Prioritise development of PLP as a resilient, connected organisation

We continued to approach our work through the prism of focus areas identified and adopted in 2017:

• Access to Judicial Review

• Access to Legal Aid

• Public Law and Technology

• Benefit Sanctions

• • Brexit

The trend towards regressive constitutional reform gathered significant pace and momentum, with restrictions to judicial review and human rights a major focus of the Government. In addition to the substance of the reforms, the procedural approach often showed little concern for transparency or scrutiny.

The reporting year began just after the Government launched a consultation on reform of judicial review, in March 2021. Even though the Independent Review of Administrative Law (IRAL) panel had reported to Government in January of that year, publication of its report was delayed until the launch of the consultation. It soon became clear that plans for legislation went much further than the IRAL had recommended, and that ministers had not accurately represented some of the panel’s key findings. Further, the Government refused to publish the submissions that its departments had made to the IRAL, despite repeated Freedom of Information Act requests and a legal challenge brought by PLP. The effect was that once the Judicial Review and Courts Bill was before Parliament, MPs and Peers were unable to review evidence that would have enabled more effective scrutiny.

As noted above, PLP and partner organisations were successful in securing an important amendment to the Bill. Unfortunately, it passed with a clause that abolished ‘Cart’ judicial reviews which are used – among other things - to protect vulnerable migrants from being deported to dangerous regimes. Despite PLP having repeatedly pointed out that the statistics used by the Government to justify the change were not right – a criticism that was supported by the Office for Statistics regulation – the Government maintained its claim and pushed the provision through.

The Government adopted a similar approach with the Human Rights Act by publishing the report of the Independent Human Rights Act Review (IHRAR) at the same time as launching its own consultation in December 2021. As with the IRAL, the Government’s consultation proposals did not reflect the analysis of its own independent review, and went further, despite a lack of evidential foundation. The subsequent draft legislation was supported by a troubling lack of evidence, notwithstanding that its effect will be to restrict how people can enforce their human rights domestically, in the UK, and will increase the likelihood they will need to take their claims to the Strasbourg court to get justice.

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The third major piece of legislation PLP engaged with was the Nationality and Borders Bill. Published on 6 July, the Bill emerged just 8 weeks after the close of the ‘New Plan for Immigration’ consultation. The consultation itself was deeply flawed. It allowed inadequate time for responses, the questions it asked were underpinned by problematic and unevidenced assumptions, and the case studies it referenced were unbalanced.

The legislation that passed in April 2022, just after the reporting period, represented a profoundly regressive shift in immigration policy, including by penalising refugees who arrive at the UK by irregular means, such as across the channel. PLP’s work focused on the access to justice elements, including: the weakening of appeal rights despite high levels of wrong initial decisions by the Home Office; requiring judges and Home Office caseworkers to give “minimal weight” to some evidence provided by legitimate asylum seekers; and increasing arbitrary powers of the Home Secretary, such as the authority to require certain cases to be heard artificially quickly, aggravating the risk of rushed and illegal outcomes.

Beyond these high-profile pieces of primary legislation, significant themes emerged across our focus areas.

The development of legal frameworks to manage government use of algorithms and automation in state decision-making has not reflected a commitment to transparency and accountability, and yet such decisions can be life-changing for those they affect and are made this way with ever-greater frequency. A-level results, investigations into sham marriages, and fraud checks on disabled benefits claimants are all examples of decisions that have been decided—at least initially—by systems with algorithms at their heart. As part of the new plan for immigration, the Home Office planned to use an algorithm to “identify and block the entry of those who present a threat to the UK.” In all these instances, the risk of discrimination is high. It does not, for example, require a leap of imagination to foresee a hike in racial profiling at our borders.

It is therefore vital that transparency and human oversight, as well as a legal framework to ensure that people can effectively challenge decisions made in these ways, are put into law, policy and practice if the new era of automated decision-making is to be fair for everyone.

Unfortunately, in November 2021 the Government’s consultation ‘Data a new direction’ signalled a worrying erosion of oversight for automated decisions that affect people’s lives. The consultation also proposed removing a requirement for organisations to undertake Data Protection Impact Assessments and limiting people’s ability to find out how their data is being used.

Around the same time, the Cabinet Office piloted an Algorithmic Transparency Standard (ATS) to encourage greater transparency around government use of such systems. Although positive at first glance, the initiative had many shortcomings. Firstly, participation by Government has not been compulsory, and second the standard does not ask for sufficient detail that would allow those affected by automated systems to understand how they work. Algorithms are highly complex, and a higher degree of transparency about how they operate is essential if people are going to be able challenge and hold the state accountable for decisions that turn out to be unlawful.

Symptomatic of this approach to transparency is that the DWP refused PLP’s Freedom of Information Act request for impact assessments of automated tools used to identify fraudulent Universal Credit claims. Again, despite the obvious risk of discrimination and harm, much about automated systems and how Government uses them remains hidden from public view.

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Whilst benefit sanctions figures at the start of the reporting year were relatively low, they increased sharply by the summer of 2021 and rose to an all-time high by the end of the reporting period. This represented a 160% increase in sanctions compared to the pre-pandemic peak in July 2019. This rise occurred despite increasing acceptance that benefit sanctions have a negative impact on mental health and contribute to debt and financial hardship. There is also very little evidence that they achieve their stated objectives.

Having been extensively criticised for the absence of such evidence, this reporting year it was revealed that the DWP had in fact produced a report into the effectiveness of sanctions, and refused to publish it. The department claimed the report did not present a complete picture and that it “includes details of a sensitive nature whose publication would be likely to inhibit candour and be likely to prejudice the effective conduct of public affairs”.

In the same week that the DWP reiterated its refusal to publish its report, on 27 January the department launched the ‘Way to Work’ initiative as part of a drive to get half a million people into work by the end of June 2022. This required Universal Credit claimants to search more widely for available jobs earlier on or risk being sanctioned if they do not. Ultimately the plan amounted to little more than increasing the threat of sanctions.

With the UK having formally left the European Union in January 2020, PLP’s Brexit work this year focused on the European Union Settlement Scheme, for which the application deadline passed in July 2021. Through working with frontline organisations such NGOs, advice organisations, charities, and law centres who assist vulnerable individuals with EUSS issues, we identified a need for legal advice to support complex cases raising a wide range of issues. These issues included, for example, delays in issuing certificates to applicants in the EUSS, and delays in processing immigration applications that were causing undue hardship for individuals.

Despite multiple warnings from civil society organisations, the Government pressed ahead with the policy of requiring people to prove their immigration status through a ‘digital only’ process. Immigration status is essential for accessing accommodation and work, and the digital process has been difficult to navigate for lots of groups including those who are homeless, those with cognitive disabilities, the elderly and certain ethnic groups. The Home Office’s support system also had significant limitations, with over half of calls made to it in 2021 being abandoned and over two thirds of calls in its first month being unresolved. A digital only process increased the threat that even those who successfully obtain status under the EUSS may face unfair and unnecessary barriers to proving they have status. This risk was exacerbated towards the end of the reporting period in March 2022 when the Government made law by statutory instrument – a process which eludes meaningful parliamentary scrutiny – to invalidate biometric residence or permit cards as proof of lawful status to rent or work.

In September 2021, the Government launched two inquiries into retained EU Law; that is law which was transferred wholesale into UK statute as part of the process of withdrawal. This was part of a series of developments leading to the announcement of a Brexit Freedoms Bill in the Queen’s Speech of April 2022. As anticipated, the proposals centred around giving Ministers the power to change retained EU law by statutory instrument. This will allow Ministers to re-write laws affecting areas such as employment rights, consumer protection, and health and safety, without effective scrutiny by Parliament.

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On legal aid, there is a positive consensus among key influencers about the importance of reform. For example, the Justice Select Committee’s report published in July 2021 called for an overhaul of the current system and for it to be designed around the needs of those who use it. The report also recognised the need for improvements to the Exceptional Case Funding scheme and a greater number of providers to allow consistent access to legal aid lawyers.

Additionally, a comprehensive commission on legal aid set up by the All Party Parliamentary Group on Legal Aid, which took evidence from a wide range of stakeholders including PLP, made an impressive set of recommendations, including for the reinstatement of areas of social welfare law and access to early help.

Despite these positive voices, there has been no significant change in policy to reverse the effect of the cuts made by LASPO years ago. The Government’s long-awaited means test review to look at the financial eligibility thresholds for legal aid did not launch until the end of the reporting period in March 2022.

Meanwhile, there were continued problems with the Detained Duty Advice Scheme, the system by which people in Immigration Removal Centres can access a lawyer, and about the Legal Aid Agency’s failure to monitor the scheme and widespread complaints about inadequate representation.

These problems are set to be intensified by the Nationality and Borders Bill which failed to address the need for access to proper legal advice and at the same time weakened appeal rights and introduced a host of provisions that were harmful to access to justice for those in the immigration system.

In light of this context, for this reporting period and in line with our 2017-2022 strategy, PLP’s five interlinked areas of focus remained: access to judicial review, access to legal aid, benefit sanctions, public law and technology, and Brexit. As explained in the Director’s Report, this year we developed our new strategy for 2022-25 which maintains our focus on core issues whilst recognising the continued and specific risks arising in the context of constitutional reform and immigration.

Access to Judicial Review

As a suite of flagship Government Bills made their way through Parliament throughout 2021-22, PLP maintained focus on resisting regressive constitutional reform, our goal being to support the protection and enjoyment of fundamental rights and the rule of law. As much of our work on constitutional reform relates to judicial review and access to the courts, that work is reported in this section.

PLP engaged robustly with the Judicial Review and Courts Bill, the New Plan for Immigration and the Nationality & Borders Bill, the Environment Bill, and the Independent Human Rights Act Review, which was a precursor to the introduction of the Bill of Rights.

Throughout the year, Public Law Project played a central role in these constitutional debates. Our engagement included detailed empirical research, provision of written and oral evidence to parliamentary committees, the production of articles and media commentary; leadership and collaboration with other NGOs; training and thought leadership events; and deployment of a parliamentary influencing strategy.

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Our impact included:

Supporting legislative scrutiny :

• PLP’s briefings were demonstrably influential; they were widely cited in Parliament during the passage of the Judicial Review and Courts Bill and Nationality and Borders Bill and referenced with approval by other leading organisations, including the Bingham Centre for the Rule of Law.

• Two PLP colleagues gave oral evidence to the Justice Committee on judicial review reform.

• Rt Hon David Davis MP cited PLP’s briefing in his opinion piece in The Guardian opposing Government reforms to judicial review.

• Labour’s Lord Ponsonby referred to analysis published by PLP during the Lords’ second reading of the Nationality and Borders Bill.

• Efforts by Lord Anderson to amend Clause 1 of the Judicial Review and Courts Bill (supported by PLP) were ultimately successful. The Government agreed to Lord Anderson’s amendment and in doing so removed a presumption requiring judges to grant a weakened form of redress in successful judicial reviews. This was a major victory for the rule of law, effective redress and Judicial independence.

Media communications :

PLP played a key role in informing key influencers and stakeholders. This included:

• Articles and commentary on a range of constitutional issues were published in The Law Society Gazette, Legal Action Group, the Constitution Society, and the UK Constitutional Law Association.

• A comment piece by a PLP research fellow was referenced by Sir Peter Gross, the chair of IHRAR, in a UCL speech on the Government’s proposals.

• Our Research Fellow in Constitutional Reform, Lee Marsons, was interviewed by the Financial Times on plans to reform human rights laws. Researcher Mia Lesley was published by the BIHR.

• PLP drew attention to the use of inaccurate figures used to justify restrictions on judicial reviews in cases where vulnerable migrants have faced unlawful removal to countries where they would be at risk of torture and death. Our concerns were supported by the Office for Statistics Regulation.

• Our Director Jo Hickman was quoted in the legal media highlighting the Government’s refusal to publish all the available review information gathered by the Independent Review of Administrative Law.

• PLP’s analysis of the Nationality and Borders Bill was cited in Freemovement and the Law SocietyGazette.

Human Rights policy engagement :

• We produced a detailed response to the Independent Human Rights Act Review, which included original research on the number of successful challenges to statutory instruments on human rights grounds and the number of times those instruments were quashed. This research been widely disseminated and relied upon, including by IHRAR in its official report and recommendations to the Government.

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• The IHRAR concurred with PLP’s warning against developing legislation to weaken the powers of judges to invalidate statutory instruments. PLP shared its research with other civil society organisations in advance of the deadline to assist their own responses. This was particularly helpful to migrant non-legal organisations in engaging with the Government’s questions on article 8 (the right to family and private life) and its application to deportation decisions.

Supporting civil society :

• PLP worked to ‘join up the dots’ to highlight that constitutional reform has been undertaken by the Government through a range of piecemeal and incremental Government actions. This work has primarily been through the launch of the UK Constitutional Reform Tracker, a website developed with civil society partners which plots and categorises constitutionally significant events ranging from Acts of Parliament and statutory instruments to cases and ministerial speeches.

• Between its launch in October 2021 and March 2022, the website received around 4,000 views and has received praise from leading researchers, academics and practitioners. The site continues to attract over 150 hits per week.

Treaties :

• PLP was invited to give oral evidence to the Public Accounts and Constitutional Affairs Committee as part of its call for inquiry into international agreements. In evidence and in later articles, PLP’s Head of Research Arabella Lang called for greater scrutiny and accountability in international agreements to ensure Parliamentary sovereignty and the support the interests of marginalised groups.

Legal Aid

Improving the legal aid scheme

We continued to work to improve the legal aid scheme. Most recently we established through litigation that legal aid can and should be available to people on low incomes who do not have meaningful capital assets. We embarked upon a range of activities to ensure that these litigation successes were understood and utilised by practitioners, advisors and the general public. Our work was repeatedly cited by the Justice Select Committee's October 2021 report 'The Future of Legal Aid'.

We were involved in influencing work with a coalition of NGOs engaging with the Legal Aid Agency (LAA) (through meetings and correspondence) in order to improve the operation and monitoring of the Detained Duty Advice Scheme in Immigration Removal Centres. This was in response to concerns about the LAA’s failure to monitor the scheme and widespread complaints about inadequate representation.

Our work included representing Detention Action in litigation against the Lord Chancellor. Whilst Detention Action was refused judicial review, the challenge nonetheless led to important

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improvements, including: the removal of firms providing inadequate representation from scheme; ensuring providers on the scheme can undertake judicial review work; increased contract management activity by the LAA; and the acknowledgement that firms that do not hold a DDA contract can act for detained clients.

Director Jo Hickman was one of a chorus of expert legal voices referenced in a piece by Jon Robins in The Justice Gap exploring how the legal aid sector is in ‘desperate need of investment’, following a commission set up by the All Party Parliamentary Group on Legal Aid.

Exceptional Case Funding

Our work around understanding Exceptional Case Funding (ECF) and making it more accessible continued. Researcher Emma Marshall’s work held particular focus in this area. Her article ‘Improving Access To Justice Through Legal Aid: Exploring The Possibilities Of ‘Exceptional Case Funding’ Clinics In University Law Schools’ was published in April’s International Journal of Legal Education, to an audience of over 10,000 law teachers and 500 subscribers.

Emma also published a detailed report in the same month on the flawed proposals within the Government’s ‘New Plan for Immigration’: the decision to remove immigration from legal aid scope; and why the Exceptional Case Funding scheme is a barrier to legal aid and is counter-productive to its aims.

In March, PLP’s client, a ‘looked after’ child with disabilities, was granted permission to challenge the Legal Aid Agency’s refusal to grant her ECF. Combined with assisting the client, PLP lawyers hoped a positive outcome in the case would help define the landscape of legal aid accessibility for this small but vulnerable group. The case was ongoing as of March 2022.

‘Trapped capital’

PLP’s work around ‘trapped capital’ and access to legal aid also progressed. We began work on a research project investigating whether legal aid had become more accessible following a November 2020 case which found that PLP’s client should be eligible for legal aid after having been denied it on the basis of owning a home.

We ran a survey with legal aid practitioners, advice and support charities in August – one year on from the judgment – to gauge how the situation had changed. Initial findings were shared in an article for Legal Action Magazine, and formed the basis for a longer piece of research that was completed in April 2022.

Public Law and Technology

PLP’s public law and technology work continued to explore, document and challenge the opacity of Government’s use of algorithms. We gave evidence to consultations on government use of data and automated decision making (ADM), and on monitoring and evaluation of the online courts and digital justice.

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The issue of opacity

Much of PLP’s work in this area includes continuous calls for ADM to be transparent so that potentially life changing decisions can be challengeable in court and barriers to justice removed.

Research Fellow Jack Maxwell and former Legal Director Joe Tomlinson explored this issue in the quarterly Judicial Review journal, setting out how the courts are increasingly requiring Government to disclose the mathematical and technical models it uses to make decisions.

A Prospect article by PLP staff warned that the Government’s proposed Algorithmic Transparency Standard undermines procedural fairness and does not require sufficient guidelines for ensuring ADM operates fairly and without discrimination.

One example of where opaque algorithms was leading to potentially discriminatory decisions was the Home Office’s sham marriage algorithm where certain nationalities seem to be targeted more than others. PLP’s early research into this issue was referenced in the Bureau of Investigative Journalism on the potentially discriminatory nature of the sham marriage algorithm.

In July the Home Office denied PLP’s request for aspects of the algorithmic criteria to be disclosed. Tatiana Kazim unpacked the main issues in an article for Free Movement.

PLP hosted the launch of Jack Maxwell and Joe Tomlinson’s Experiments in Automating Immigration Systems , with a panel of public law and technology experts chaired by Charlotte Kilroy QC of Blackstone Chambers. Key points from the discussion were then summarised in a short report.

Governance and human oversight of automated decision making

Two further strands of PLP’s work in this area were the role of human oversight in ADM and the governance of ADM. We analysed potential problems with proposals to scrap mandatory removing human oversight in a piece for Prospect magazine and advocated for a new legal framework for ADM in a guest blog for Legal Futures.

Evidence submissions

Many of the concerns outlined above were shared with key decision makers in Government and Parliament: the Department for Culture, Media and Sport (DCMS), and Justice and Home Affairs Committee (JHAC).

PLP’s response to the JHAC’s call for evidence on new technologies and the application of the law advocated for why the criteria behind the sham marriage and prisoner categorisation algorithms should be more transparent and suggested regulations by which a new legal framework could operate fairly and lawfully. The resulting report by the JHAC included many of PLP’s recommendations.

PLP also responded to DCMS’ ‘Data: a new direction’ consultation to raise concerns over the proposed overhaul of data protection law and its potentially detrimental impact on ADM and discrimination.

Online courts and digital exclusion

Research Fellow Jo Hynes’ investigations of online courts and digital exclusion continued with reports on ensuring digital exclusion does not obstruct justice.

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‘Digital support for HMCTS reformed services: what we know and what we need to know’ tracked the progress of the Digital Support programme designed to assist individuals navigating the online court system.

We then hosted a private roundtable with seventeen external parties, to explore the next phase of Digital Support, chaired by The Right Hon Sir Ernest Ryder. A ’Rapporteur’s Briefing’ was published to outline the discussion, and a blog by Jo Hynes published by The UK Administrative Justice Institute summarised the issues raised in the discussion and subsequent briefing.

Benefit Sanctions

This has been a busy area of work for PLP, with two particularly significant wins standing out.

DWP change their practice

The first related to the Department of Work and Pensions (DWP) agreement to change their guidance on Recoverable Hardship Payments (RHP) following a judicial review.

PLP’s client was a Universal Credit claimant who was forced to claim hardship payments to cover essential needs after she was unfairly sanctioned for over a year and a half. The DWP agreed to waive her debt as a result of the challenge and formally updated its guidance to confirm it has discretion to waive RHPs regardless of whether the claimant meets the requisite earnings threshold. Following the case there was a marked increase in the number of waivers granted in these circumstances.

PLP lawyer Emma Vincent Miller explored the impact of the debt on the client and the wider problems with benefit sanctions in an article for Legal Action Magazine.

The second was a case in which the DWP agreed to stop cold-calling disabled people and pressuring them into accepting lower benefit offers. PLP’s client in this case was a disabled woman who spent more than a year trying to persuade the DWP to change their unlawful practice. In response to a judicial review eventually brought by the client, the DWP agreed to re-write their policies and update training to DWP officials.

The result was covered in specialist and general media, including Disability News Service, The Sun, The Law Society Gazette, The Mirror, The Guardian, The Independent, and The Canary.

Benefit sanctions and barriers to challenge

PLP Researcher Caroline Selman undertook extensive research around the barriers welfare benefit claimants face when challenging benefit sanctions and the noticeably low number challenged in the first place. This research enabled PLP to ensure that our work in this area is properly informed by people’s lived experience. We produced a number of articles, policy responses, and evidence submissions, alongside collating evidence to use in a final research report.

Evidence was submitted to the Welsh Affairs Committee inquiry into benefits systems in Wales and the Work and Pensions committee inquiry on health-related benefits. Recommendations emphasised the need to improve the fairness and due process of sanctioning decisions.

Caroline analysed the rise in benefit sanctions in a blog in December, calling for a renewed focus on how sanctions are applied in practice as their numbers increase.

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We also shared further criticism of the effectiveness of benefit sanctions in a blog responding to the DWP’s new Way to Work Policy, which included plans to expand their use.

Brexit

After the end of the transition period in December 2020, the majority of our Brexit work focused on the EU Settlement Scheme, with a view to ensuring procedural fairness to those likely to be most affected by the Brexit process.

In July 2021, PLP published its final briefing on EU citizens’ rights after the Brexit transition period. Here, we set out the latest information on the law applicable to EU nationals residing in the UK, or who arrive in the UK, after the end of the Brexit transition period, which we shared with partner organisations supporting EU citizens living in the UK.

During the reporting year, PLP set up the EU Settlement Scheme (EUSS) Hub. The purpose of the Hub was to provide legal advice to support complex cases raising a wide range of issues, for example: delays in issuing certificates of application to applicants in the EUSS; delays in processing immigration applications that were causing undue hardship for individuals.

“Just before Christmas, I assisted a client (referred to PLP by a partner organisation) whose EUSS application had been rejected unlawfully, without any right of appeal. My client instructed me to send a pre-action letter making the Home Office aware that he would bring proceedings against them if they did not take action to remedy their improper decisionmaking. After a seven month wait (and within two weeks of sending the pre-action letter), my client was finally granted the immigration status he was entitled to, without having to issue his claim.

“The success of cases like this shows the importance of working with frontline organisations to recognise challenges that individuals are facing. With their help, we are able to make a positive difference to people’s lives by identifying and better understanding issues in the EUSS that are causing real unfairness and hardship for often the most marginalised groups, and which might be challengeable by judicial review.”

• Aoife O’Reilly, EUSS Hub Co-ordinator

Through the EUSS Hub, PLP represented three NGO partners that were concerned about discriminatory or otherwise unfair aspects of the EU Settled Status scheme; the Joint Council for the Welfare of Immigrants, Migrants Organise, and the3million. Despite these claims being unsuccessful in court (on the basis of prematurity), they resulted in positive developments to the EUSS system, in particular to Home Office policy and guidance. They also strengthened our collaborative working relationships, including with organisations representing discriminated and/or vulnerable groups.

Towards the end of the reporting year in Spring 2022, PLP tackled the challenges posed by the muchtrailed ‘Brexit Freedoms Bill’ whose objective was to set out the process for amending retained EU law.

At this time, PLP prepared and drafted written evidence (submitted after the reporting period) to the European Scrutiny Committee as part of its inquiry into retained EU law, in which we set out why

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it would be constitutionally inappropriate for a Bill to give the Government a broad general power to amend all categories of retained EU law by Statutory Instrument.

This type of power is unprecedented in the UK’s legal system and would constitute a significant and concerning transfer of legislative competence from Parliament to the Executive.

In our briefing - which formed the basis of our approach to the Brexit Freedoms Bill – we set out five headline points relevant to ensuring any potential fast-track procedure to amend retained EU law would be fair and lawful.

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Events and Training

This year’s programme enabled us to build consensus, drive forward new thinking and share learning on some of the most pressing challenges across our focus areas. Highlights included:

• An event to support NGOs in responding to the Government’s Human Rights Act consultation

• Rise of the Robots, an event to equip public lawyers with the practical knowledge and skills required to challenge automated government decisions

• The return of #PublicDisco, PLP’s flagship discrimination event, to improve understanding and application of discrimination law, and

• Our annual conference: Accountability and the Constitution, which attracted some of the most high-profile thinkers and actors in constitutional reform and which was addressed by the Attorney General, the Rt Hon Suella Braverman QC MP.

Having successfully moved our events on-line during the pandemic, this year the legal restrictions lifted; at first gradually and then completely.

Whilst at one level this was good news, it also presented a challenge. The partner organisations on whom we rely for physical venue space were understandably cautious about hosting in-person events. At the same time, it was widely – if anecdotally - acknowledged by peer organisations that ‘Zoom fatigue’ was setting in.

Our team responded brilliantly to the challenge. By innovating and adapting our offer we kept up the momentum of online events and took a total of 1,852 bookings, and with increased confidence and experience in producing online events, we tried new approaches and ultimately produced a greater number and range of events than in the previous year.

For the first time we introduced split ticket sales which allowed people to attend specific days and sessions, rather than the whole programme. This was a huge success. It improved accessibility by allowing delegates to pay a lower price, and it meant PLP could produce more specialist seminars aimed at specific groups. For example, our Costs and Funding training event was made up of 14 seminars across the week and covered topics including ECF in SEND, family law, welfare benefits, and immigration. This approach also saw retention rates for some sessions hit 98%.

We made some major updates to our Learning Management System (LMS) which now makes available a range of free and paid content. Delegates can now view seminars after the event and our content is made available to delegates within one or two working days after each event.

Some key highlights of the year included:

• 100% of delegates throughout the year said that they would attend another PLP event

• Our Online Judicial Review Academies remained popular with events in June and November 2021 hitting 84% and 87% knowledge increase levels

• We improved accessibility by offering Speech to Text Reporting to our delegates

• 2021 saw the return of our in person Royal Parks Half Marathon fundraising event. With just over £12,000 fundraised for PLP, this event signified the beginning of PLP’s successful return to in person events

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Overall, the events team continued to play a vital role for PLP in building networks and deepening relationships with existing partners from across the legal sector, academia, civil society, and the political sphere. PLP is looking forward to moving into in person and hybrid conferences and training events in the coming year.

Volunteers

PLP is greatly strengthened by its volunteers. In the last year we were supported by Alastair Wallace who assisted the casework team with file reviews, mentoring and recruitment on a voluntary basis and Musta Iqbal who joined PLP as a Bonavero Intern to assist with our Constitutional Reform work and then joined the PLP staff team as a paid member of the research team.

The training and events team was supported by volunteers throughout the year. Virtually all our speakers across training events and conferences are academics, barristers, solicitors, advisers or other experts who volunteer their time and their expertise. PLP was also supported by individuals who raised money for us by running the Royal Parks Half Marathon.

Beneficiaries of our services

PLP recognises that public authority decision-making and unequal structures have a disproportionate impact at the intersection of protected characteristics and that many people experience multiple marginalisation.

Specifically, we understand that individuals and groups experience or are at risk of discrimination because of race, sex, gender, gender identity, sexual orientation, disability, or other protected status.

PLP lawyers act for individuals who cannot afford private representation, particularly those who face such discrimination risk and for those who experience multiple barriers related to poverty, language, literacy, mental health conditions, or ill health. PLP also acts for organisations that represent the interests of such marginalised groups.

PLP makes a difference not just to the individual clients for whom its lawyers act but to wider society by identifying and mitigating barriers which prevent individuals from achieving justice and improving the quality of public decision-making, and by influencing and informing Government and public authority policies.

PLP’s success rate is high, and our Annual Complaints and Feedback Review indicate that clients expressed very high levels of client satisfaction.

Fundraising

PLP’s approach to fundraising has traditionally focussed on foundations and grant giving trusts both for core and project funds. This means that fundraising from individual donors is usually modest in comparison to income from other sources. PLP undertakes individual donor fundraising activities including entering teams in the Royal Parks Half Marathon and fundraising dinners and receive donations (both regular and one off) from individuals. We made the decision during the reporting period not to hold any major fundraising events such as a dinner.

PLP receive direct, unsolicited donations via a Charities Aid Foundation account, which also takes unsolicited donations through our website. Routes for individuals to donate to PLP are listed on its

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website and include information on legacy giving and for those not wishing to use an online donation portal. PLP continues to use its general mailing list to offer the opportunity to make donations.

Due to the limited nature of this activity, we have not sought to register with the fundraising regulator. Staff involved in organising fundraising regularly update themselves with relevant legislation and codes of practice (including all those overlapping with GDPR) and practice concerning finance, such as VAT and fundraising events, through courses and seminars and reading guides. PLP received no complaints regarding its fundraising in 2021/22. We do not directly involve vulnerable people in our fundraising activities. Where an individual has been identified as a benefactor of PLP’s work, for instance in a case study of PLP’s activities, their permission must be explicitly sought. PLP does not ask any third parties to undertake any fundraising activities on its behalf.

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Financial Review

PLP has been keenly aware of our privileged financial position in emerging from the pandemic financially secure – we end the year at the top of our reserves policy with 6.5 months (£1,195,436) of freely available unrestricted reserves (2021: 6.5 months or £1,001,527). We are committed to using this position to benefit the many people who have been affected by unfair public decisions through the pandemic and this period of constitutional upheaval. This commitment can be seen in the rapid growth of the charity with our total expenditure nearing £2m (2022: £1,959,326, 2021: £1,390,618) and the average number of employees rising to 35 people (2022: 34.6, 2021: 25.6). The sustained generosity of our funders has provided the platform for this growth at a time when the need for those making decisions on behalf of the public to be accountable is particularly vivid.

This review comes at the conclusion of the April 2017 to March 2022 strategic period. It also comes shortly after Jo Hickman, PLP’s director for that period and a key part of the PLP team for many years prior, has decided to step down at the end of 2022. This review will consider both the last financial year and its place in the longer-term context of the charity. Our outlook for the coming year reflects that 2021/22 included some income expected for 2022/23 and we anticipate reducing our reserves as we continue to grow our expenditure.

Growth in charitable activities

This year PLP spent more than £1m directly on charitable activities for the first time in its 30-year history. In response to the growing need for our work, and possible thanks to the growing recognition of that need, spend on our charitable activities grew by 147% just in 2021/22 (2022: £1,288,379, 2021: £878,976).

Since the start of the strategic plan 2017-2022 PLP has trebled its expenditure on its charitable activities (2022: £1,288,379, 2017: £413,187). Departments which did not exist at the outset of the strategic plan are now able to use nearly as much resource advancing our charitable aims as our largest team could back in 2017 (research - 2022: £325,593, casework – 2017: £350,640).

This growth is reflected in the growth of the number of staff, including time spent working directly on our charitable activities 23.5 full time equivalent (FTE) worked on charitable activities this year compared to 17.9 FTE last year (2021).

Spend on charitable activities trebles over 5 years

Budgeted expenditure expected to reduce reserves next year

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Growth in support for our work

Despite considerable financial uncertainty at the very outset of the pandemic PLP was able not only to stabilise but to grow to respond to new demands and challenges. As the pandemic exposed and exacerbated the societal inequities that discriminatory and unfair public decision-making also contributes to, PLP was able to demonstrate a critical need for its work. Income from grants and donations has increased by nearly £200,000 on the prior year (2022: £1,410,042, 2021: £1,218,552). Income from grants is now over than £1m higher than at the outset of this strategic plan.

We are grateful for the continuing support of established funders and for the new funding relationships we have developed this year.

As ever PLP is especially appreciative of long-term funding of our core work which mitigates the changes in income from other sources including both unrestricted grants from the Oak Foundation and Sigrid Rausing Trust and restricted grants such as from Esmée Fairbairn Foundation and AB Charitable Trust. We have also received unrestricted funding this year from AB Charitable Trust, Allen & Overy Foundation, Bromley Trust,

Garden Court, London Legal Support Trust and Paul Hamlyn Foundation – whose flexibility and support we are particularly grateful for.

PLP is also delighted to receive restricted funding enabling the delivery of projects within our strategic priorities including from AB Charitable Trust, Barings Foundation, Crisis, The Joseph Rowntree Foundation, Lankelly Chase Foundation, The Law Society, The Legal Education Foundation, Trust for London and Unbound Philanthropy. The Legal Education Foundation in particular have funded a wide range of projects with PLP over many years and have this year provided major new funding (£393,000 over three years) to ensure Fairer Systems for the exercise of executive power amid the post Brexit context and the rise of automated decision-making.

Note 15 provides further details on the restricted funds which many of our funders support. Note 2 provides a full list of our funders, to all of whom we are exceedingly grateful.

Self-generated income

PLP has sought to supplement the growth in our support from grants with increased income from self-generated revenue to avoid over-dependence on one revenue source. We have succeeded in generating stable levels of income from our casework and events programmes. Over the next strategic period we plan to making our income-generating activities more efficient through systems investments and expect to invest in at least one dedicated member of fundraising staff. We are also conscious that our relatively high levels of reserves and long-term grant funding enable a less cautious risk appetite in respect of our self-generated income. Our relative stability means we can take more deserving cases on ‘conditional fee agreements’ (CFA or ‘no-win, no fee’) where legal aid is not available, and that we can innovate in the delivery of our events to target an increasingly diverse group of delegates. This year our self-generated income was in line with our internal targets (and therefore a little higher than our budgeted expectations).

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PLP’s casework income is unpredictable year to year due to the relatively low volume of cases and the disproportionate impact that winning any particular case has on the level of income PLP will achieve. This is particularly the case for cases PLP take on a ‘conditional fee agreement’ (CFA or ‘nowin, no-fee’) basis as such cases are valued as nil in these accounts but may be worth full ‘commercial’ rates if the case is won the following year. The below set of graphs shows how, with the growth our grant income, this uncertainty in casework income has less effect on PLP’s total income than it did at the outset (and prior to) our last strategy – for example in 2020 and 2022 PLP was able to grow total income despite casework income being less than the prior year.

These changes are reflected in changes to our reserves policy which took effect this year and allow PLP to operate with proportionately less reserves than in prior years (see reserves section below).

PLP funds

PLP’s total funds have risen following a small surplus in the year (Net income - 2022: £77,605, 2021: £554,511. Total funds - 2022: £2,370,599, 2021: £2,292,994) despite having planned and budgeted for a deficit year in part due to savings against expected spend on staffing with several positions, including our legal director, being vacant for some of the year. Cash at bank and in hand remains relatively high for a charity of PLP’s size at £1,963,258 (2021: £1,121,955.

A large proportion of our funds remain restricted (£273,868) and designated (£841,912). Each year PLP sets aside an amount to build a designated fund able to cover relocation costs in order that we can move offices if required at the end of our lease (2022: £55,975). Our casework work in progress (WIP) designated fund (£588,937) reflects income we have recognised but is an illiquid asset which cannot be relied upon as part of our reserves policy. Many firms will have WIP with a high turnover, however much of PLP’s WIP relates to cases which are two years old or more – therefore PLP cannot be confident that it would be able to convert recent casework income into cash should the need arise during any short-medium period of time. As casework is a major source of unrestricted income we show our WIP as a designated fund in order to avoid misleading funders that these funds are available to invest in our charitable activities. In 2022, thanks to the hard work of our billings co-ordinator and the casework team, PLP was able to bring in a significant amount of old casework debts leading to casework fees received in cash (2022: £809,878, 2021: £362,691) this reduced the amount of designated funds held as WIP (2022: £588,937, 2021: £884,309). Much of this cash was received unexpectedly at the end of the 2022 financial year.

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The trustees have used this opportunity to designate funds towards planned improvements in our internal systems to ensure they are optimised for hybrid working and online collaboration and to support transition within our senior leadership with our long term Director Jo Hickman departing PLP at the end of 2022.This along with substantial recruitment to our charitable activities approved from our unrestricted funds in our 2022/23 budget will ensure PLP reduces general funds in line with its reserves policy.

In 2022 The remainder of our unrestricted funds (£1,254,819) are available as general funds and form the basis of calculating our reserves.

PLP funds and reserves
Total unrestricted funds	£2,096,731
Less designated funds of	£841,912
Less assets and longterm debtors of	£58,367
Freelyavailable,unrestricted reserves	£1,254,819

Reserves policy

PLP’s reserves are held to deal with the following contingencies:

• Problems with cash flow, for instance when waiting for casework receipts;

• Staffing shortages such as those due to sickness, maternity/paternity leave;

• Reductions in or withdrawal of funding;

• In the event of closure, the costs to wind up the organisation and pay redundancies and leasehold liabilities.

PLP’s board of trustees consider PLP’s free reserves to include all unrestricted funds excluding designated funds and the value of fixed assets (2022: £17,282) and long term debtors (2022: £41,085). Work in progress (our largest designated fund) is not freely available as explained above.

Our unrestricted freely available reserves at 2022 are £1,196,452 (2021: £1,004,155) representing six and a half months of running costs as budgeted for the coming year.

PLP’s reserves policy during the year ending 31 March 2022 is to retain between 4.5 and 6.5 months of running costs (4.5: £827,609, 6.5: £1,195,436). PLP’s trustees consider a relatively high minimum reserves policy is required, given the high level of PLP’s fixed costs (largely permanent staff and lease on premises) and the unpredictability of its unrestricted income (particularly casework income as noted above).

This reserves policy is reviewed annually when the board of trustees set the budget for the following financial year.

During the review process for the 2021/22 budget, the trustees noted that PLP’s income has become increasingly secure and predictable in recent years. A greater proportion of PLP income is from grants with several of our major funders have committed to PLP over the longer term making PLP less dependent on uncertain casework income sources (as noted above). As such the trustees agreed that PLP could prudently reduce the level of reserves from between six and eight months to the current

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policy. The trustees considered whether a further reduction in reserves was prudent this year and decided to retain the new policy, particularly in light of rising inflation, however this will be kept under annual review and reduced further if it would be prudent to do so.

Principal risks and uncertainties

The urgent need to respond to the Government’s political reform agenda has widened from the post-Brexit context described above [page 17] to encompass wider threats to constitutional norms and rights. The breadth and pace of the government’s proposed reforms present a risk that PLP lacks the capacity to monitor, evaluate and respond on all the avenues that are being pursued. In mitigation PLP’s new strategy in this area has been well supported and PLP has been able to recruit new team members to resource our work. At the time of writing, the Rt Hon Elizabeth Truss MP has recently taken office as the Prime Minister, and PLP will take available opportunities to continue to work with Government and parliamentarians on all sides to ensure constitutional reforms respect the rule of law and access to justice, and promote accountability of government.

After 13 years at the Public Law Project, including a stint as the Head of Casework and seven years as the organisational Director, Jo Hickman will be stepping down at the end of 2022. Our chair noted the ‘outstanding leadership’ Jo has displayed evident in “the difference she has made to the communities we serve, and the transformational impact she has had on PLP as an organisation.” The board of trustees aim to appoint PLP’s next Director/CEO by the end of the year. As with any change of key personnel there is a degree of uncertainty amongst our staff and supporters about the changes a new appointment will bring. PLP’s trustees, senior leadership team and recruitment partners are working hard to ensure a smooth transition and focus on the opportunities that also come with new leadership.

All charitable organisations will have recognised a heightened strain on staff capacity and wellbeing in the last few years. Maintaining a positive outlook in recent times this is particularly acute for our staff who spend their work life fighting some of the worst examples of unfairness and hardship in our society. We believe that a positivity is both a product of and a catalyst for a healthy and productive work. To promote a positive culture PLP will be focused on fostering the sense of community with new hybrid working models; developing the support we provide to current and aspiring managers; improving the holistic support we offer for staff wellbeing; and ensuring we have the capacity necessary to deliver our strategy.

The trustees have assessed PLP to be going concern with no material uncertainties. In so assessing they have considered the impact of the above and other risks and uncertainties that impact on solvency and liquidity alongside prepared budgets, forecasts and sensitivity analysis.

Governance & Management

The Board are PLP’s charitable trustees who accept ultimate responsibility for directing the affairs of PLP and ensuring that it is solvent, well-run, and delivering the charitable outcomes for the benefit of the public for which it has been set up. The trustees are volunteers who receive no remuneration for their time beyond reasonable out of pocket expenses (2022: £ 97).

The trustees elect a Chair, Secretary and Treasurer to whom the Board may delegate any of its powers. In practise, the Chair carries out the function of line-managing the Director/CEO and leading the Board

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and managing Board meetings. The Treasurer is expected to provide general financial oversight of PLP among other duties relating to the financial management and control of the charity. The Secretary has overall responsibility for meeting reporting requirements and board administration as required by PLP’s regulators and its Articles. The board may create sub-committees and working groups of its members to focus on particular areas of governance such as personnel and risk.

The Chair ensures new trustees receive an appropriate induction. New trustees receive copies of PLP’s Articles, Detailed Governance Procedures, Strategic Plan, PLP policies, papers and minutes of recent board meeting and access to other information relevant to the role.

The Board is responsible for appointing PLP’s Director/CEO and is involved in the appointment of other members of the Senior Leadership Team (SLT). The Board delegates authority for the day-to-day operation of PLP to the Director/CEO who may further delegate to the SLT or other staff as they consider appropriate. Some decisions are reserved to the Board including expenditure over set amounts, escalated staff grievances, relocating PLP’s office, acting in ‘own-name’ litigation and the recruitment, contracts and pay of the SLT.

The SLT are the ‘key management personnel’ of the organisation and in addition to the Director/CEO include the Legal Director, Finance and Operations Director and Communications Director. The Chair and Personnel sub-committee are involved in setting pay and remuneration of the SLT. Trustees consider relevant and available information on comparable roles when setting pay. Current SLT and staff pay is informed by a benchmarking exercise carried out Total Reward Group in 2021.

Since the last annual report PLP has welcomed Ariane Adams as our new Legal Director. Ariane joins PLP from the Equal Rights Trust where she was Deputy Director and is an experienced public law practitioner with a focus on discrimination and human rights, having developed her practice at 1MCB Chambers. Her role at PLP includes the senior leadership of the casework and research departments.

Alison Pickup, PLP’s former Legal Director has taken on the role of Director at Asylum Aid where we are delighted to continue to have opportunities to work with her in partnership. Dr Joe Tomlinson, PLP’s former Research Director now works as Professor in Public Law the University of York, a member of the Academic Panel at Blackstone Chambers whilst continuing to work with PLP as an Associate Fellow.

PLP thanks Qalid Mohamed for his years of service on our board of trustees ending in June 2022 to focus on his work and studies. PLP benefitted enormously from Qalid’s lived experience of discrimination and immigration issues that we seek to address, as well as his time and expertise in financial and business management. At the September 2022 Rosanna McKearney steps down to focus on her new family. Rosie’s perspectives, expertise in campaigns and fundraising and thoughtfulness will be sorely missed by the board. The staff team were particularly grateful to Rosie for sharing her personal and professional experiences of managing wellbeing during the Covid pandemic and we wish her and her family the very best for the future.

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Related parties and relationships with other organisations

None of our trustees receive remuneration or other benefit from their work with the charity. Any connection between a trustee or employee and anyone involved in the charity’s business must be disclosed to the board of trustees in the same way as any other contractual relationship with a related party. In the current year, no such related party transactions were reported.

Statement of responsibilities of the trustees

The trustees (who are also directors of PLP for the purposes of company law) are responsible for preparing the trustees’ annual report and the financial statements in accordance with applicable law and United Kingdom Accounting Standards (United Kingdom Generally Accepted Accounting Practice).

Company law requires the trustees to prepare financial statements for each financial year which give a true and fair view of the state of affairs of the charitable company and of the incoming resources and application of resources, including the income and expenditure, of the charitable company for that period. In preparing these financial statements, the trustees are required to:

• Select suitable accounting policies and then apply them consistently

• Observe the methods and principles in the charities SORP

• Make judgements and estimates that are reasonable and prudent

• State whether applicable UK accounting standards and statements of recommended practice have been followed, subject to any material departures disclosed and explained in the financial statements

• Prepare the financial statements on the going concern basis unless it is inappropriate to presume that the charity will continue in operation

The trustees are responsible for keeping adequate accounting records that disclose with reasonable accuracy at any time the financial position of the charitable company and enable them to ensure that the financial statements comply with the Companies Act 2006. They are also responsible for safeguarding the assets of the charitable company and hence for taking reasonable steps for the prevention and detection of fraud and other irregularities.

In so far as the trustees are aware:

• There is no relevant audit information of which the charitable company’s auditor is unaware

• The trustees have taken all steps that they ought to have taken to make themselves aware of any relevant audit information and to establish that the auditor is aware of that information

The trustees are responsible for the maintenance and integrity of the corporate and financial information included on the charitable company's website. Legislation in the United Kingdom governing the preparation and dissemination of financial statements may differ from legislation in other jurisdictions.

Members of the charity guarantee to contribute an amount not exceeding £1 to the assets of the charity in the event of winding up. The total number of such guarantees at 31 March 2022 was 10. The trustees are members of the charity but this entitles them only to voting rights. The trustees have no beneficial interest in the charity.

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Auditor

Sayer Vincent LLP was re-appointed as the charitable company's auditor during the year and has expressed its willingness to continue in that capacity.

The trustees’ annual report has been approved by the trustees on 28 September 2022 and signed on their behalf by

Elizabeth Prochaska Chair of the Board of Trustees

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Opinion

We have audited the financial statements of Public Law Project (the ‘charitable company’) for the year ended 31 March 2022 which comprise the statement of financial activities, balance sheet, statement of cash flows and notes to the financial statements, including a summary of significant accounting policies. The financial reporting framework that has been applied in their preparation is applicable law and United Kingdom Accounting Standards, including Financial Reporting Standard 102 The Financial Reporting Standard applicable in the UK and Republic of Ireland (United Kingdom Generally Accepted Accounting Practice).

In our opinion, the financial statements:

• Give a true and fair view of the state of the charitable company’s affairs as at 31 March 2022 and of its incoming resources and application of resources, including its income and expenditure, for the year then ended

• Have been properly prepared in accordance with United Kingdom Generally Accepted Accounting Practice

• Have been prepared in accordance with the requirements of the Companies Act 2006

Basis for opinion

We conducted our audit in accordance with International Standards on Auditing (UK) (ISAs (UK)) and applicable law. Our responsibilities under those standards are further described in the Auditor’s responsibilities for the audit of the financial statements section of our report. We are independent of the charitable company in accordance with the ethical requirements that are relevant to our audit of the financial statements in the UK, including the FRC’s Ethical Standard and we have fulfilled our other ethical responsibilities in accordance with these requirements. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion.

Conclusions relating to going concern

We have nothing to report in respect of the following matters in relation to which the ISAs (UK) require us to report to you where:

• The trustees’ use of the going concern basis of accounting in the preparation of the financial statements is not appropriate; or

• The trustees have not disclosed in the financial statements any identified material uncertainties that may cast significant doubt about the charitable company’s ability to continue to adopt the going concern basis of accounting for a period of at least twelve months from the date when the financial statements are authorised for issue.

Other information

The other information comprises the information included in the trustees’ annual report, including the strategic report and the director’s and chair’s reports, other than the financial statements and our auditor’s report thereon. The trustees are responsible for the other information. Our opinion on the financial statements does not cover the other information and, except to the extent otherwise explicitly stated in our report, we do not express any form of assurance conclusion thereon. In

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connection with our audit of the financial statements, our responsibility is to read the other information and, in doing so, consider whether the other information is materially inconsistent with the financial statements or our knowledge obtained in the audit or otherwise appears to be materially misstated. If we identify such material inconsistencies or apparent material misstatements, we are required to determine whether there is a material misstatement in the financial statements or a material misstatement of the other information. If, based on the work we have performed, we conclude that there is a material misstatement of this other information, we are required to report that fact.

We have nothing to report in this regard.

Opinions on other matters prescribed by the Companies Act 2006

In our opinion, based on the work undertaken in the course of the audit:

• The information given in the trustees’ annual report, including the strategic report and the director’s and chair’s reports for the financial year for which the financial statements are prepared is consistent with the financial statements

• The trustees’ annual report, including the strategic report and director’s and chair’s reports, has been prepared in accordance with applicable legal requirements

Matters on which we are required to report by exception

In the light of the knowledge and understanding of the charitable company and its environment obtained in the course of the audit, we have not identified material misstatements in the trustees’ annual report including the strategic report and director’s and chair’s reports.

We have nothing to report in respect of the following matters in relation to which the Companies Act 2006 requires us to report to you if, in our opinion:

• Adequate accounting records have not been kept, or returns adequate for our audit have not been received from branches not visited by us; or

• The financial statements are not in agreement with the accounting records and returns; or

• Certain disclosures of trustees’ remuneration specified by law are not made; or

• We have not received all the information and explanations we require for our audit.

Responsibilities of trustees

As explained more fully in the statement of responsibilities of the trustees set out in the trustees’ annual report, the trustees (who are also the directors of the charitable company for the purposes of company law) are responsible for the preparation of the financial statements and for being satisfied that they give a true and fair view, and for such internal control as the trustees determine is necessary to enable the preparation of financial statements that are free from material misstatement, whether due to fraud or error.

In preparing the financial statements, the trustees are responsible for assessing the charitable company’s ability to continue as a going concern, disclosing, as applicable, matters related to going

31

Public Law Project annual report

For the year ended 31 March 2022

concern and using the going concern basis of accounting unless the trustees either intend to liquidate the charitable company or to cease operations, or have no realistic alternative but to do so.

Auditor’s responsibilities for the audit of the financial statements

Our objectives are to obtain reasonable assurance about whether the financial statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditor’s report that includes our opinion. Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in accordance with ISAs (UK) will always detect a material misstatement when it exists. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected to influence the economic decisions of users taken on the basis of these financial statements.

As part of an audit in accordance with ISAs (UK), we exercise professional judgment and maintain professional scepticism throughout the audit. We also:

• Identify and assess the risks of material misstatement of the financial statements, whether due to fraud or error, design and perform audit procedures responsive to those risks, and obtain audit evidence that is sufficient and appropriate to provide a basis for our opinion. The risk of not detecting a material misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control.

• Obtain an understanding of internal control relevant to the audit in order to design audit procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the entity’s internal control.

• Evaluate the appropriateness of accounting policies used and the reasonableness of accounting estimates and related disclosures made by the trustees.

• Conclude on the appropriateness of the trustees’ use of the going concern basis of accounting and, based on the audit evidence obtained, whether a material uncertainty exists related to events or conditions that may cast significant doubt on the entity’s ability to continue as a going concern. If we conclude that a material uncertainty exists, we are required to draw attention in our auditor’s report to the related disclosures in the financial statements or, if such disclosures are inadequate, to modify our opinion. Our conclusions are based on the audit evidence obtained up to the date of our auditor’s report. However, future events or conditions may cause the entity to cease to continue as a going concern.

• Evaluate the overall presentation, structure and content of the financial statements, including the disclosures, and whether the financial statements represent the underlying transactions and events in a manner that achieves fair presentation.

We communicate with those charged with governance regarding, among other matters, the planned scope and timing of the audit and significant audit findings, including any significant deficiencies in internal control that we identify during our audit.

32

Public Law Project annual report

For the year ended 31 March 2022

Use of our report

This report is made solely to the charitable company's members as a body, in accordance with Chapter 3 of Part 16 of the Companies Act 2006. Our audit work has been undertaken so that we might state to the charitable company's members those matters we are required to state to them in an auditor’s report and for no other purpose. To the fullest extent permitted by law, we do not accept or assume responsibility to anyone other than the charitable company and the charitable company's members as a body, for our audit work, for this report, or for the opinions we have formed.

Noelia Serrano (Partner)

20 October 2022

for and on behalf of Sayer Vincent LLP, Statutory Auditor Invicta House, 108-114 Golden Lane, LONDON, EC1Y 0TL

33

Public Law Project

Statement of financial activities (incorporating an income and expenditure account)

For the year ended 31 March 2022

Note Income from: 2 3 3 4 4 4 4 5 Reconciliation of funds: Donations and grants Charitable activities Casework and legal advice Raising funds Net income / (expenditure) for the year and net movement in funds Total expenditure Charitable activities Influencing(Policy, Information, Training) Influencing(Policy, Information, Training) Casework and legal advice Research Investments Total income Expenditure on: Other trading activities - fundraising event Transfers between funds Miscellaneous income Total funds brought forward Total funds carried forward	Unrestricted £ 522,241 536,745 79,982 - 2,987 7,175	Restricted £ 887,801 - - - - -	2022 Total £ 1,410,042 536,745 79,982 - 2,987 7,175	Unrestricted £ 347,193 620,861 103,804 1,556 356 -	Restricted £ 871,359 - - - - -	2021 Total £ 1,218,552 620,861 103,804 1,556 356 -
	1,149,130	887,801	2,036,931	1,073,770	871,359	1,945,129
	64,050 497,983 178,905 311,954	- 571,640 301,920 32,874	64,050 1,069,623 480,825 344,828	50,314 118,217 134,436 231,760	- 673,721 173,095 9,075	50,314 791,938 307,531 240,835
	1,052,892	906,434	1,959,326	534,727	855,891	1,390,618
	- 96,238	- (18,633)	- 77,605	8,370 547,413	(8,370) 7,098	- 554,511
	2,000,493	292,501	2,292,994	1,453,080	285,403	1,738,483
	2,096,731	273,868	2,370,599	2,000,493	292,501	2,292,994

All of the above results are derived from continuing activities. There were no other recognised gains or losses other than those stated above. Movements in funds are disclosed in Note 15 to the financial statements.

34

Public Law Project

Balance sheet

Balance sheet
For the year ended 31 March 2022			Company no. 2368562
Note Fixed assets: 10 11a Current assets: 11b Liabilities: 12 14 Total unrestricted funds 15 Cash at bank and in hand Tangible assets Amounts recoverable on casework Debtors Non current debtors Cash Deposits (longer than 3 months) Restricted income funds Unrestricted income funds: Designated funds General funds Total charity funds The funds of the charity: Creditors: amounts falling due within one year Net current assets Total net assets	£ 588,937 128,787 85,000 1,963,258	2022 £ 17,282 41,085	£ 884,309 207,997 505,925 1,121,955	2021 £ 20,896 41,085
		58,367 2,312,232		61,981 2,231,013
	2,765,982 (453,750)		2,720,186 (489,173)
	841,912 1,254,819		934,357 1,066,136
		2,370,599		2,292,994
		273,868 2,096,731		292,501 2,000,493
		2,370,599		2,292,994

Approved by the trustees on 28 September 2022 and signed on their behalf by

Elizabeth Prochaska Chair

35

Public Law Project

Statement of cash flows

For the year ended 31 March 2022

Reconciliation of net income to net cash flow from operating activities

(as per the statement of financial activities) Depreciation charges Investment income Decrease / (increase) in debtors and WIP (Decrease) / increase in creditors Net cash provided by operating activities Cash and cash equivalents at the beginning of the year Cash and cash equivalents at the end of the year Change in cash and cash equivalents in the year Investment income Cash flows from operating activities Net cash used in by investing activities Net cash provided by operating activities Cash flows from investing activities: Purchase of fixed assets Net income for the reporting period	£ £ 427,777 2,987 (10,386) (7,399) 420,378 1,627,880 2,048,258 2022	£ £ 427,777 2,987 (10,386) (7,399) 420,378 1,627,880 2,048,258 2022	2022 £ 77,605 14,000 (2,987) 374,582 (35,423)	2021 £ 554,511 14,147 (356) (236,503) 386,555
			427,777	718,354
			£ £ 718,354 356 (10,108) (9,752) 708,603 919,277 1,627,880 2021
		420,378 1,627,880		708,603 919,277
		2,048,258		1,627,880

36

Public Law Project

Notes to the financial statements

For the year ended 31 March 2022

1 Accounting policies

a) Statutory information

Public Law Project is a charitable company limited by guarantee and is incorporated in the United Kingdom.

The registered office address is The Design Works, 93–99 Goswell Road, London, EC1V 7EY.

b) Basis of preparation

The financial statements have been prepared in accordance with 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 and Republic of Ireland (FRS 102) - (Charities SORP FRS 102), The Financial Reporting Standard applicable in the UK and Republic of Ireland (FRS 102) and the Companies Act 2006.

Assets and liabilities are initially recognised at historical cost or transaction value unless otherwise stated in the relevant accounting policy or note.

In applying the financial reporting framework, the trustees have made a number of subjective judgements, for example in respect of significant accounting estimates. Estimates and judgements are continually evaluated and are based on historical experience and other factors, including expectations of future events that are believed to be reasonable under the circumstances. The nature of the estimation means the actual outcomes could differ from those estimates. Any significant estimates and judgements affecting these financial statements are detailed within the relevant accounting policy below.

c) Public benefit entity

The charitable company meets the definition of a public benefit entity under FRS 102.

d) Going concern

• The trustees consider that there are no material uncertainties about the charitable company's ability to continue as a going concern.

The trustees do not consider that there are any sources of estimation uncertainty at the reporting date that have a significant risk of causing a material adjustment to the carrying amounts of assets and liabilities within the next reporting period.

e) Income

Income is recognised when the charity has entitlement to the funds, any performance conditions attached to the income have been met, it is probable that the income will be received and that the amount can be measured reliably.

Income from government and other grants, whether ‘capital’ grants or ‘revenue’ grants, is recognised when the charity has entitlement to the funds, any performance conditions attached to the grants have been met, it is probable that the income will be received and the amount can be measured reliably and is not deferred.

Income received in advance of the provision of a specified service is deferred until the criteria for income recognition are met.

Work under conditional fee agreements is valued at nil until the case is won, at which point the charity has entitlement to the funds.

f) Donations of gifts and services

Donated professional services and donated facilities are recognised as income when the charity has control over the item or received the service, any conditions associated with the donation have been met, the receipt of economic benefit from the use by the charity of the item is probable and that economic benefit can be measured reliably. In accordance with the Charities SORP (FRS 102), volunteer time is not recognised so refer to the trustees’ annual report for more information about their contribution.

On receipt, donated gifts, professional services and donated facilities are recognised on the basis of the value of the gift to the charity which is the amount the charity would have been willing to pay to obtain services or facilities of equivalent economic benefit on the open market; a corresponding amount is then recognised in expenditure in the period of receipt. There were no gifts in kind for 2021/22 (in previous years these principally relate to the provision at no cost of venue space or catering for PLP Events. Most PLP events continued to be held online during 2021/22.)

37

Public Law Project

Notes to the financial statements

For the year ended 31 March 2022

• 1 Accounting policies (continued)

g) Interest receivable

Interest on funds held on deposit is included when receivable and the amount can be measured reliably by the charity; this is normally upon notification of the interest paid or payable by the bank.

h) Fund accounting

Restricted funds are to be used for specific purposes as laid down by the donor. Expenditure which meets these criteria is charged to the fund.

Unrestricted funds are donations and other incoming resources received or generated for the charitable purposes.

Designated funds are unrestricted funds earmarked by the trustees for particular purposes.

i) Expenditure and irrecoverable VAT

Expenditure is recognised once there is a legal or constructive obligation to make a payment to a third party, it is probable that settlement will be required and the amount of the obligation can be measured reliably. Expenditure is classified under the following activity headings:

• Costs of raising funds relate to the costs incurred by the charitable company in inducing third parties to make voluntary contributions to it, as well as the cost of any activities with a fundraising purpose.

• Expenditure on charitable activities includes the costs of delivering legal services, education and training events and conducting research undertaken to further the purposes of the charity and their associated support costs.

Irrecoverable VAT is charged as a cost against the activity for which the expenditure was incurred.

j) Allocation of support costs

Resources expended are allocated to the particular activity where the cost relates directly to that activity. Support and governance costs are re-allocated to each of the activities on the following basis which is an estimate, based on staff time, of the amount attributable to each activity.

	Support	Governance
	Costs	costs
Cost of raising funds	3%	4%
Casework and legal advice	51%	54%
Research	24%	25%
Influencing (Policy, Information, Training)	17%	18%
Governance	4%

Governance costs are the costs associated with the governance arrangements of the charity. These costs are associated with constitutional and statutory requirements and include any costs associated with the strategic management of the charity’s activities.

k) Operating leases

Rental charges are charged on a straight line basis over the term of the lease.

l) Tangible fixed assets

Items of equipment are capitalised where the purchase price exceeds £1,000. Depreciation costs are allocated to activities on the basis of the use of the related assets in those activities. Assets are reviewed for impairment if circumstances indicate their carrying value may exceed their net realisable value and value in use.

Depreciation is provided at rates calculated to write down the cost of each asset to its estimated residual value over its expected useful life. The depreciation rates in use are as follows:

• Fixtures and fittings

33.00% Straight line

38

Public Law Project

Notes to the financial statements

For the year ended 31 March 2022

1 Accounting policies (continued)

m) Amount receivable on casework (WIP)

Income is recognised on casework earned and due ("work in progress" or "WIP") according to the time booked on the matter multiplied by the relevant legal aid or interpartes rate. Appropriate provision is made for irrecoverable WIP. While some WIP will be recoverable within 12 months and some over 12 months, it is not possible to calculate this split with accuracy. The charity accounts for WIP as a current asset as it aims to recover WIP within the shortest possible timeframe; however, WIP is excluded from the free reserves of the charity.

n) Debtors

Trade and other debtors are recognised at the settlement amount due after any trade discount offered. Prepayments are valued at the amount prepaid net of any trade discounts due.

o) Cash at bank and in hand

Cash at bank and cash in hand includes cash and short term highly liquid investments with a short maturity of three months or less from the date of acquisition or opening of the deposit or similar account.

p) Creditors and provisions

Creditors and provisions are recognised where the charity has a present obligation resulting from a past event that will probably result in the transfer of funds to a third party and the amount due to settle the obligation can be measured or estimated reliably. Creditors and provisions are normally recognised at their settlement amount after allowing for any trade discounts due.

q) Financial instruments

The charity only has financial assets and financial liabilities of a kind that qualify as basic financial instruments. Basic financial instruments are initially recognised at transaction value and subsequently measured at their settlement value.

r) Pensions

The charitable company operates a defined contribution pension scheme. The assets of the scheme are held separately from those of the charitable company in an independently administered fund. The charitable company has no liability under the scheme other than for the payment of those contributions.

s) Client monies

Client monies are excluded from the financial statements. The balance on the client bank account of these client monies at 31 March 2022 was nil (2021:nil).

39

Public Law Project

Notes to the financial statements

For the year ended 31 March 2022

• 2 Income from donations and grants

Grants and donations included in income were received from the following:

Coronavirus Job Retention Scheme Lloyds Bank Foundation Sam and Bella Sebba Charitable Trust Sigrid Rausing New Philanthropy Therium UK Paul Hamlyn Foundation The Legal Education Foundation London Legal Support Trust Oak Foundation Other Donations <£5,000 Trust for London (Strategic Legal Fund) Unbound Philanthropy AB Charitable Trust Garden Court (CAF) Esmée Fairbairn Foundation Allen & Overy Foundation Baring Foundation Bromley Trust Lankelly Chase Foundation Community Justice Fund Joseph Rowntree Foundation Crisis UK The Law Society	Unrestricted £ 3,750 10,000 - 15,000 - - - 4,000 - - - - 10,000 250,000 - 60,000 - 150,000 - - - 666 18,826	Restricted £ 60,000 - 70,120 - - 50,000 53,928 - 40,124 30,000 150,099 269,599 61,000 - - - - 27,931 - - 37,500 37,500 - -	2022 Total £ 63,750 10,000 70,120 15,000 - 50,000 53,928 4,000 40,124 30,000 150,099 269,599 61,000 10,000 250,000 - 60,000 27,931 150,000 - 37,500 37,500 666 18,826	Unrestricted £ - 5,000 - 15,000 - - 25,665 4,000 - - - - - 10,000 - - 70,000 - 150,000 30,000 - - 24,173 13,355	Restricted £ 60,000 - 55,000 - 100,000 50,000 52,613 - 30,090 30,000 437 151,423 - - 145,046 24,250 - - - - 75,000 97,500 - -	2021 Total £ 60,000 5,000 55,000 15,000 100,000 50,000 78,278 4,000 30,090 30,000 437 151,423 - 10,000 145,046 24,250 70,000 - 150,000 30,000 75,000 97,500 24,173 13,355
	522,241	887,801	1,410,042	347,193	871,359	1,218,552

• 3 Income from charitable activities

Unrestricted £ (5,019) 814,897 22,239 (295,372)	Restricted £ - - - -	2022 Total £ (5,019) 814,897 22,239 (295,372)	Unrestricted £ 61,614 301,077 23,856 234,314	Restricted £ - - - -	2021 Total £ 61,614 301,077 23,856 234,314
	- - -	536,745 4,300 75,682	620,861 5,250 98,554	- - -	620,861 5,250 98,554
	-	79,982	103,804	-	103,804
616,727	-	616,727	724,665

Since the year-end, Public Law Project has received no income under Conditional Fee Agreements (2021: £nil).

40

Public Law Project

Notes to the financial statements

For the year ended 31 March 2022

4a Analysis of expenditure (current year)

Staff costs (Note 6) Audit Bank Charges Legal Fees Professional Indemnity Insurance Personnel Premises and Equipment Depreciation Office overheads Casework Costs Courses, seminars, conferences Research Costs Other grant expenditure Support costs Governance costs Total expenditure 2022 Total expenditure 2021	Cost of raising funds £ 40,829 - - - - - - - - - 268 - -	Charitable activities	Charitable activities	Charitable activities	Governance costs £ 47,342 9,660 - - - - - - - - - - -	Support costs £ 218,059 - 944 6,220 18,351 55,394 146,678 14,000 113,202 - - - -	2022 Total £ 1,385,771 9,660 944 6,220 18,351 55,394 146,678 14,000 113,202 130,312 29,326 6,346 43,122	2021 Total £ 1,006,957 9,600 848 - 18,330 30,790 114,394 14,147 78,547 49,862 12,426 1,341 53,376
		Casework and Legal Advice £ 601,282 - - - - - - - - 130,312 - - -	Research £ 276,125 - - - - - - - - - - 6,346 43,122	Influencing (Policy, Information, Training) £ 202,134 - - - - - - - - - 29,058 - -
	41,097 20,029 2,924	731,594 294,973 43,056	325,593 135,459 19,773	231,192 99,162 14,474	57,002 23,225 (80,227)	572,848 (572,848) -	1,959,326 - -	1,390,618 - -
	64,050	1,069,623	480,825	344,828	-	-	1,959,326	-
	50,314	791,938	307,531	240,835	-	-	-	1,390,618

41

Public Law Project

Notes to the financial statements

For the year ended 31 March 2022

4b Analysis of expenditure (prior year)

Charitable activities

Staff costs (Note 6) Audit Bank Charges Legal Fees Professional Indemnity Insurance Personnel Premises and Equipment Depreciation Office overheads Casework Costs Courses, seminars, conferences Research Costs Other grant expenditure Support costs Governance costs Total expenditure 2021	Cost of raising funds £ 30,662 - - - - - - - - - 1,115 - -	Casework and Legal Advice £ 462,481 - - - - - - - - 49,862 - - -	Research and Policy £ 157,560 - - - - - - - - - - 1,341 53,376	Education, Information and Training £ 143,045 - - - - - - - - - 11,311 - -	Governance costs £ 52,148 9,600 - - - - - - - - - - -	Support costs 2021 Total £ £ 161,061 1,006,957 - 9,600 848 848 - - 18,330 18,330 30,790 30,790 114,394 114,394 14,147 14,147 78,547 78,547 - 49,862 - 12,426 - 1,341 - 53,376 418,117 1,390,618 (418,117) - - - - 1,390,618
	31,777 15,156 3,381	512,343 228,599 50,996	212,277 77,880 17,374	154,356 70,706 15,773	61,748 25,776 (87,524)
	50,314	791,938	307,531	240,835	-

42

Public Law Project

Notes to the financial statements

For the year ended 31 March 2022

• 5 Net income for the year

This is stated after charging:

This is stated after charging:
	2022	2021
	£	£
Depreciation	14,000	14,147
Operating lease rentals:
Property	80,650	80,650
Auditor's remuneration (excluding VAT) - for audit:	8,775	8,350
Auditor's remuneration (excluding VAT) - for SRA audit:	-	1,250

• 6 Analysis of staff costs, trustee remuneration and expenses, and the cost of key management personnel

Staff costs were as follows:

Staff costs were as follows:
Salaries and wages Social security costs Employer’s contribution to defined contribution pension schemes	2022 £ 1,194,786 112,888 78,097	2021 £ 859,754 82,214 64,989
	1,385,771	1,006,957

Redundancy and termination costs in the year were £34,200 (2021: nil)

One employee earned more than £60,000 during the year (2021: nil). No employees earned between £60,000 and £70,000 during the year (2021: nil). One employee earned between £70,000 and £80,000 during the year (2021: nil)

The total employee benefits including pension contributions and employer's national insurance of the key management personnel were £279,837 (2021: £376,864). During 2022 these are the Director, the Legal Director, the Finance and Operations Director, the Communications Director and the Research Director. In 2021 these also included the Deputy Legal Director and Events and Resources Manager. The cost of key management personnel excluding the Deputy Legal Director and Events and Resources Manager in 2021 was £276,501.

The charity trustees were not paid or received any other benefits from employment with the charity in the year (2021: £nil). No charity trustee received payment for professional or other services supplied to the charity (2021: £nil).

Trustees' expenses representing the payment or reimbursement of travel costs of £96.90 were paid to one trustee (2021: £nil).

7 Staff numbers

The average number of employees (head count based on number of staff employed) during the year was as follows:

Casework and legal advice Influencing (Policy, Information, Training) Governance Raising funds Support Research	2022 No. 0.8 12.6 9.8 5.0 5.8 0.7	2021 No. 0.6 10.2 6.1 3.2 4.5 1.0
	34.6	25.6

The average number of employees (based on full-time equivalent) during the year was as follows:

Casework and legal advice Raising funds Support Governance Research Influencing (Policy, Information, Training)	2022 No. 0.7 12.3 6.8 4.5 4.5 0.6	2021 No. 0.5 9.8 5.0 3.0 3.7 0.8
	29.3	22.9

43

Public Law Project

Notes to the financial statements

For the year ended 31 March 2022

8 Related party transactions

The following related party transactions occurred in 2022:

Key management personnel were reimbursed £1,932.69 for expenses incurred for team away days held during the year The director was reimbursed £2,250 for a training course paid for out of pocket.

Key management personnel were reimbursed £102.78 for sundry expenses during the year Trustees were reimbursed £96.90 expenses for attending board meetings These totaled £4,382.37

PLP also received free access to meeting rooms at FieldFisher and 11KBW for the purpose of board meetings via trustee's

The following related party transactions occurred in 2021:

A small thank you gift to the value of £25 was paid to each trustee during the year, which totalled: £280

Three trustees received small gifts relating to significant events to the value of less than £100 . These totalled £189.02

9 Taxation

The charitable company is exempt from corporation tax as all its income is charitable and is applied for charitable purposes.

10 Tangible fixed assets

Tangible fixed assets
At the end of the year At the start of the year Additions in year Cost Disposals in the year Disposals in the year At the end of the year At the end of the year At the start of the year At the start of the year Net book value All of the above assets are used for charitable purposes. Depreciation Charge for the year	Fixtures and fittings £ 71,521 10,386 (6,953)	Total £ 71,521 10,386 (6,953)
	74,954	74,954
	50,625 14,000 (6,953)	50,625 14,000 (6,953)
	57,672	57,672
	17,282	17,282
	20,896	20,896

11a Non current debtors

Non current debtors
Current debtors Prepayments Other debtors Lease deposit Accrued income Trade debtors	2022 £ 41,085	2021 £ 41,085
	41,085	41,085
	2022 £ 2,483 26,246 74,958 25,100	2021 £ 14,387 33,318 42,792 117,501
	128,787	207,997

11b Current debtors

44

Public Law Project

Notes to the financial statements

For the year ended 31 March 2022

• 12 Creditors: amounts falling due within one year

Creditors: amounts falling due within one year
Accruals Deferred income Taxation and social security Trade creditors Other creditors	2022 £ 158,502 153,579 74,389 66,590 690	2021 £ 141,687 33,962 39,409 24,115 250,000
	453,750	489,173

All deferred income brought forward was released in the year

13 Pension scheme

The charitable company operates a defined contribution pension scheme administered by B&CE. The assets of the scheme are held separately from those of the charitable company in an independently administered fund. The charitable company has no liability under the scheme other than for the payment of those contributions. At 31 March 2022 PLP had 32 (2021: 25) employees in the scheme. The amount owed to the pension scheme at Year End was £4,632 (2021: £nil).

14a Analysis of net assets between funds (current year)

Cash at bank and in hand Net assets at 31 March 2022 Debtors Amounts recoverable on casework Liabilities Fixed assets	General unrestricted £ 58,367 128,787 - 1,521,415 (453,750)	Designated £ - - 588,937 252,975 -	Restricted £ - - - 273,868 -	Total funds £ 58,367 128,787 588,937 2,048,258 (453,750)
	1,254,819	841,912	273,868	2,370,599

14b Analysis of net assets between funds (prior year )

Fixed assets Amounts recoverable on casework Net assets at 31 March 2021 Liabilities Cash at bank and in hand Debtors	General unrestricted £ 61,981 207,997 - 1,285,331 (489,173)	Designated £ - - 884,309 50,048 -	Restricted £ - - - 292,501 -	Total funds £ 61,981 207,997 884,309 1,627,880 (489,173)
	1,066,136	934,357	292,501	2,292,994

45

Public Law Project

Notes to the financial statements

For the year ended 31 March 2022

15a Movements in funds (current year)

	At 1 April	Income and	Expenditure		At 31 March
	2021	gains	and losses	Transfers	2022
	£	£	£	£	£
Restricted funds:
Casework and legal advice
Access to Judicial Review in Wales - Barings Foundation	32,470	50,120	(48,581)	-	34,009
Access to Justice - Oak Foundation	303	-	(303)		-
Access to Public Law Remedies - Esmée Fairbairn Foundation
	4,275	53,928	(54,688)	-	3,515
Best Practice Innovation - Crisis	50,000	50,000	(70,000)		30,000
Covid-19, Response Fund - Barings	30,000	-	(30,000)	-	-
Justice First Fellowships - TLEF	5,722	53,519	(49,392)	-	9,849
Justice Together Initiaitve	-	39,780	(19,890)		19,890
Legal Aid (21/22) - The Law Society	7,500	30,000	(30,000)	-	7,500
Rule of Law - AB Charitable trust	30,000	30,000	(30,000)	-	30,000
Rule of Law - Unbound Philanthropy	84,997	37,500	(74,143)	-	48,354
Strategic Partnership project - Lankelly Chase Foundation
	(9,523)	149,099	(111,927)	-	27,649
Welfare & Immigration Rights Post Brexit - Trust for London	15,216	37,500	(52,716)	-	-
Research
Brexit Public Law Policy - TLEF	7,121	49,350	(56,471)	-	-
Constitutional Reform - AB Charitable Trust	14,097	30,000	(32,000)	-	12,097
Constitutional Reform - Barings Foundation	9,398	20,000	(20,000)	-	9,398
Constitutional Reform - Joseph Rowntree Charitable Trust	-	40,124	(40,124)	-	-
Fairer Systems - TLEF	-	126,950	(117,951)	-	8,999
Welfare Barriers - Lloyds Bank	-	61,000	(35,374)	-	25,626
Influencing (Policy, Information, Training)
Policy and Influencing - Sam and Bella Sebba Charitable Trust	-	27,931	(20,949)	-	6,982
Wellbeing - Lankelly Chase Foundation	-	1,000	(1,000)	-	-
Law and Technology - TLEF	10,925	-	(10,925)	-	-
Total restricted funds	292,501	887,801	(906,434)	-	273,868
Unrestricted funds:
Designated funds:
Amounts recoverable on casework (work in progress)	884,309	-	-	(295,372)	588,937
Office relocation fund	50,048	-	-	5,927	55,975
Systems change and transition fund	-	-	-	197,000	197,000
Total designated funds	934,357	-	-	(92,445)	841,912
General funds	1,066,136	1,149,130	(1,052,892)	92,445	1,254,819
Total unrestricted funds	2,000,493	1,149,130	(1,052,892)	-	2,096,731
Total funds	2,292,994	2,036,931	(1,959,326)	-	2,370,599

46

Public Law Project

Notes to the financial statements

For the year ended 31 March 2022

15b Movements in funds (prior year)

Influencing (Policy, Information, Training) Total restricted funds Total designated funds General funds Rule of Law - AB Charitable trust Research Settled Status Hub - NPC Transition Advice Fund (and TAF Rule of Law - Unbound Philanthropy 1 & 2 Strategic Legal Fund for Vulnerable Young Migrants: No notice Welfare & Immigration Rights Post Brexit - Trust for London Brexit Public Law Policy - TLEF Access to Public Law Remedies - Esmée Fairbairn Foundation Total funds Unrestricted funds: Designated funds: Amounts recoverable on casework (work in progress) Total unrestricted funds Constitutional Reform - AB Charitable Trust Constitutional Reform - Barings Foundation Fairer Systems - TLEF LASP Exceptional Case Funding (ECF) Clinics Toolkit - Best Practice Innovation - Crisis Strategic Partnership project - Lankelly Chase Foundation Covid-19, Operational Impacts - Barings Community Justice Fund - Access to Justice Foundation Office relocation fund Constitutional Reform - Joseph Rowntree Charitable Trust Law and Technology - TLEF Access to Justice - Oak Foundation Legal Aid (21/22) - The Law Society Casework and legal advice Restricted funds: Covid-19, Response Fund - Barings Justice First Fellowships - TLEF Access to Judicial Review in Wales - Barings Foundation	At 1 April 2020 £ 46,113 5,708 4,277 - - - - 3,502 - 30,000 42,497 14,193 3,434 119,527 5,071 9,671 - - - - 1,410 -	Income and gains £ - 145,046 52,613 50,000 100,000 5,000 30,000 17,473 30,000 30,000 97,500 24,250 - 437 75,000 82,250 30,000 20,000 30,090 31,700 - 20,000	Expenditure and losses £ (13,643) (150,451) (52,615) - (91,630) (5,000) - (15,253) (22,500) (30,000) (55,000) (38,443) (3,434) (129,487) (64,855) (84,800) (15,903) (10,602) (30,090) (31,700) (1,410) (9,075)	Transfers £ - - - (8,370) - - - - - - - - - - - - - - -	At 31 March 2021 £ 32,470 303 4,275 50,000 - - 30,000 5,722 7,500 30,000 84,997 - - (9,523) 15,216 7,121 14,097 9,398 - - - 10,925
	285,403	871,359	(855,891)	(8,370)	292,501
	649,995 21,575	234,314 -	- -	- 28,473	884,309 50,048
	671,570	234,314	-	28,473	934,357
	781,510	839,456	(534,727)	(20,103)	1,066,136
	1,453,080	1,073,770	(534,727)	8,370	2,000,493
	1,738,483	1,945,129	(1,390,618)	-	2,292,994

47

Public Law Project

Notes to the financial statements

For the year ended 31 March 2022

• 15 Movements in funds (continued)

Purposes of restricted funds

Casework and legal advice

Access to Judicial Review in Wales - Barings Foundation

The Barings Foundation has awarded PLP £150,000 over three years to meet the costs of employing a public law specialist based in Wales. The project aims to improve access to judicial review and legal aid in Wales by providing casework and by building networks with organisations who may have capacity to use public law. The project commenced with the appointment of PLP lawyer Matthew Court to the role in January 2021, who has since relocated to be based within a local firm in Cardiff.

Access to Justice - Oak Foundation

The Oak Foundation awarded PLP £613,566 over four years, starting March 2017, to improve access to justice, increase the accountability of public decision-makers and enhance the quality of public decision-making. PLP achieved this by developing a stakeholder network to systemically improve its lobbying and advocacy efforts, delivery of a bespoke training and outreach programme to raise awareness and generate referrals for PLP's casework and taking on 'test cases' to bring about strategic changes. A small final balance from this restricted grant was b/f from the prior year. We are pleased that The Oak Foundation has continued to fund PLP through a new unrestricted grant of £1,000,000 over four years which started in April 2021.

Access to Public Law Remedies - Esmée Fairbairn Foundation

Esmée Fairbairn Foundation has granted PLP £263,223 over five years towards core costs to improve access to public law remedies for those affected by poverty or disadvantage.

Best Practice Innovation - Crisis

Crisis provided PLP for two years to a total value of £100,000 through their Best Practice Grant Innovation Programme. PLP worked with Law Centres and Skylight centres and other frontline advice organisations to provide specialist support hubs addressing systemic unfairness that causes homelessness. PLP expanded its EU Settlement Scheme (EUSS) hub to include support for welfare benefits (particularly benefit sanctions). PLP delivered specialist training to over 150 people to improve their expertise in public law, welfare rights and the EUSS and aid their work supporting vulnerable people.

Covid-19, Operational Impacts 2 - Barings

The Barings Foundation Covid-19 Response Fund is for organisations experiencing an increase in demand for expert legal advice. PLP was awarded a grant of £30,000 over one year to support its work to address increased demand and complexity in requests for advice from civil society organisations.

Justice First Fellowship- TLEF (The Legal Education Foundation)

Under the Justice First Fellowship scheme, the Legal Education Foundation provided funding to enable PLP to host a trainee solicitor, who we are pleased to report recently qualified and will start their work as a solicitor covering PLP's hub work.

Justice Together - Justice Collaborations

Justice Collaborations has awarded a grant of £250,347 over 36 months for work on the Justice Together Initiative which seeks a fair, timely and accessible immigration. This funding has enabled PLP to resource the leadership of a team providing specialist public law support to the network of organisations and individuals working challenging unfairness and systemic racism in the immigration system.

Legal Aid (21/22) - The Law Society

The ‘Legal Aid Support Project’ started in 2013 seeking to mitigate the effect of the reforms to legal aid contained within the Legal Aid

48

Public Law Project

Notes to the financial statements

For the year ended 31 March 2022

Purposes of restricted funds (continued)

Rule of Law - AB Charitable trust

AB Charitable Trust have provided long term 'anchor' of general support funding (£30,000 per year for five years) to assist PLP in its work to limit and challenge the inappropriate exercise of executive power and support effective regulatory systems at a time of great constitutional change in the UK.

Rule of Law - Unbound Philanthropy

Unbound Philanthropy have provided general support funding to assist PLP work to limit and challenge the inappropriate exercise of executive

Strategic Partnership Project - Lankelly Chase Foundation

The Lankelly Chase Foundation has provided funding to explore how strategic litigation and other legal tools can be used to effect systemic change for people facing severe and multiple disadvantage. The work involves working with a Learning Partner and work with organisations who work with people facing severe and multiple disadvantage to build their understanding and skills relating to legal redress for the people they work with.

Welfare & Immigration Rights Post Brexit - Trust for London

Trust for London have provided a £150,000 grant over two years towards assisting Londoners facing immigration and welfare rights issues in the context of post Brexit and the rise of auto-mated decision-making. The funding meets both the costs of specialist lawyers conducting strategic casework on immigration and welfare rights issues, as well as an academic lawyer to gather robust, empirical evidence on the operation of the EU Settlement Scheme.

Research

Brexit Public Law Policy - The Legal Education Foundation (TLEF)

PLP is engaged with Brexit given the Rule of Law and access to justice issues arising from what is the biggest legislative project in UK history. TLEF have provided £164,999 over 30 months to fund PLP's work to progress towards fair and effective systems for the exercise and control of executive power amid Brexit and the rise of automated decision-making. PLP's legal and policy experts monitor these systems, identify systemic problems, and work with others to challenge them in public debate and in the courts where they undermine the rights of marginalised people.

Constitutional Reform - AB Charitable Trust

AB Charitable Trust have awarded PLP a restricted grant of £30,000 per year for two years which, alongside funding from the Barings Foundation, meets the employment costs of a Research and Policy Fellow and supports our work to promote and evidence-led approach to constitutional reform, particularly in relation to the government's proposed reforms of judicial review. This post ensures that PLP has the capacity to conduct pro-active research and gather evidence that supports evidence-based reform of judicial review, and to react effectively as the details of proposals emerge.

Constitutional Reform - Barings Foundation

The Barings Foundation have awarded PLP a restricted grant of £40,000 over two years which, alongside funding from AB Charitable Trust, meets the employment costs of a Research and Policy Fellow and supports our work to promote and evidence-led approach to constitutional reform, particularly in relation to the government's proposed reforms of judicial review. This post ensures that PLP has the capacity to conduct pro-active research and gather evidence that supports evidence-based reform of judicial review, and to react effectively as the details of proposals emerge.

Constitutional Reform - Joseph Rowntree Charitable Trust

The Joseph Rowntree Charitable Trust awarded PLP of £80,246 over 2 years towards the costs of providing strategic leadership promoting an evidence-led approach to constitutional reform, particularly in relation to the government's proposed reforms of judicial review. The work requires significant input from members of PLP's Senior Leadership Team, particularly the Communications Director who is leading on developing its communications strategy; the Research Director who will oversee and supervise the collation of research to support its strategy; and the Director and Legal Director who will provide legal and strategic input into the communications strategy and engage in advocacy with Parliamentarians and others.

Fairer Systems - TLEF

TLEF have agreed to provide PLP funding of £393,000 over 3 years to ensure that the UK’s systems for the exercise and control of executive power are fair and effective, amid Brexit and the rise of automated decision-making. PLP's legal and policy experts will monitor these systems, identify systemic problems, and work with others to challenge them in public debate and in the courts.

Welfare Barriers - Lloyds Bank Foundation

Lloyds Bank Foundation awarded a grant to assist PLP in identifying the barriers that welfare benefits claimants face in appealing unfair sanctions decisions, and to inform a strategy for tackling those barriers through policy, litigation and/or casework. The work involves collecting up-to-date evidence around sanctions as the basis for an informed debate with government. The research recognises the disproportionate sanctioning that minoritised communities face and we ensure diversity across research participants. Lloyd's has extended its support to enable PLP to develop a longer term research, litigation and casework strategy aimed at ensuring benefit deductions operate in a

49

Public Law Project

Notes to the financial statements

For the year ended 31 March 2022

Influencing (Policy, Training, Events)

Law and Technology - TLEF

The Legal Education Foundation (TLEF) have awarded PLP £20,000 to train public lawyers on how to challenge automated government decisionmaking. This work will prepare and deliver a training program which covers an introduction to automated systems in government, the laws governing automated government decision-making, and how to challenge automated decisions in practice.

Policy and Influencing - The Sam & Bella Sebba Charitable Foundation

The Sebba Foundation have supported PLP with a grant of £27,931 for one year towards your project: to support the establishment of a new policy and influencing post. The new post is designed to develop our policy positions drawing from expertise held across our research, casework and training teams and engage collaboratively with government, Parliamentarians and the media .

Wellbeing grant - Lankelly Chase Foundation

In hearing from the charities they fund about the pressure on that keeping things going during 2020 and 2021, and caring for others, has placed on staff and volunteers alike Lankelly Chase offered their grant partners a £1,000 to support wellbeing. PLP has used this to support wellbeing initiatives among its staff team including providing away days to encourage teams to support each other after long periods of remote working where forging connections is that much more challenging.

Purposes of designated funds

Designated funds have been set aside by the trustees for a certain purpose. The trustees have set aside two funds as follows:

Amounts recoverable on casework (Work in Progress)

Purpose: To clearly identify Work in Progress assets in the balance sheet of PLP’s audited accounts so as to distinguish them from PLP’s freely available, unrestricted funds.

Office relocation fund

Funds set aside over 5 years to meet other costs required to facilitate a move to new premises towards the end of PLP's lease at Goswell Road.

Systems change and transition fund

PLP's Strategy for 2022-2025 and Financial Strategy identifies the need to further invest in our internal systems in order to keep overheads efficient as we grow and to ensure they are optimised for hybrid working and online collaboration. This requires substantial investment to introduce new core systems - a cloud-based server and document management system; financial accounting system and case management system. We have also identified a need to support transition within our senior leadership with our long term Director Jo Hickman departing PLP at the end of 2022. The trustees have designated funds from unrestricted funds that PLP unexpectedly received in 2021/22 as ringfenced for properly resourcing these changes in 2022/23.

16 Operating lease commitments

The charity's total future minimum lease payments under non-cancellable operating leases is as follows for each of the following periods

Less than one year One to Five Years	2022 2021 £ £ 45,650 80,650 - 40,325 Property	2022 2021 £ £ 45,650 80,650 - 40,325 Property
	45,650	120,975

17 Legal status of the charity

The charity is a company limited by guarantee and has no share capital. The liability of each member in the event of winding up is limited to £1.

50