IT'S A PENALTY
{Fomierty HAPPY CHILD INTERNATIONAL FOUNDATION)
(A Charitable Incorporated Organisation}
REPORT AND FINANCIAL STATEMENTS
FOR THE YEAR ENDED 30 SEPTEMBER 2022
Charity No: 1161848

'S A PENALTY
FOR THE YEAR ENDED 30 SEPTEMBER 2022
CONTENTS
Page
Legal and adminislralive information
Report of the TTuslees
13
Independent Examinerfs Report
14
Statement of Financial Activities
15
Balance Sheet
16
Notes forming part of the Financial Statements

ITS A PENALTY
FOR THE YEAR ENDED 30 SEPTEMBER 2022
Reference and Administratlve Infomiatlon
Registered Charity Number
1161848
Trustees
The Trustees serving during the year and since the year end were as follows..
C Williamson
K Corich
E McAlpine
C McLellan
B Patel
A Akintoye
Appointed 9 November 2021
Management
SL de CaTvalho MBE
Principal office
Leatherhead Institute
67 High Street
Lealherhead
r22 8AH
Independent Examiner
Mr S Robinson
Chartered Accountant
420 Silbury Boulevard
Central Milton Keynes
MK9 2AF
Bankers
Santander
Customer Service Centre
Boolle
Merseyside
L30 4GB
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ITS A PENALTY
FOR THE YEAR ENDED 30 SEPTEMBER 2022
Report of the Trustees
Trustees Report
The Trustees present their Annual Report and financial statements of the Charitable
Incorporated Organisation for the year ended 30 September 2022. The financial slalements
cornply with the Charities Act 2011, the Trust's Deed and Accounting and Reporting by
Charities.. Statement of Recommended Practice applicable lo charities preparing their accounts
in accordance with the Financial Reporting Standard applicable in the UK and Republic of
Ireland IFRS 1021 leffeclive 1 January 20191.
Structure Governance and Mana
ement
Charitable status
It's a Penalty is a Charitable In¢orpoRted Organisation ICIOI governed by its constitution and
has charitable status under the Charities Commission Association, Charity Number," 1161848.
The CIO was recognised by the Charty Commission on 27 May 2015.
Organisation stmcture
The Trustees assume responsibility for the day to day management of the CIO and almost all
executive roles are undertaken by the Trustees.
The Board of Trustees meets six b.mes each year to discuss current and future projects and to
approve decisions such as the appointment of new Trustees and the remuneration of the one
key management employee.
Trustee Recrultment and Appointment
The Trustees were recruited with complementary skills and experien￿ in mind from the
corporate, public and third sectors. Each bring a Contrribulion of global ne￿orkIng, strategic
management, marketing, international development, accountancy.
Katherine Conch is our Chair. She is founder and Global CEO of Sysdoc. Voted UK New
Zealander in 2015, Katherine is a global ne￿Orker and engages her staff in the work of the
campaign. Sysdoc is one of the campaign's partners.
Christianne Williamson is a strategic communications expert currently leading a global DFID-
funded campaign lo end female genilal mutilation. Christianne brings expertise in partnership
and resourTr leveraging, having worked in various international development organisations.
Ewen McAlpine, works for Macaulay Search, and provides executive search services to
organisations with just objectives. He is a strong ne￿Orker providing valuable ¢ontscts and
introductions in the Third and Commer¢ial sectors.
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Report of the Trustees Icont.)
Structure. Governance and Management Icont.)
Colin McLellan is a charter￿ Accountant who, prior to retirement. was Finance Director of MJ
Gleeson Group plc.
Bharti Patel is an accomplished and dedicated Human Rights and Social Justice campaigner
focusing on every child's right to quality education and to be free from abuse and exploitation
in all ils forms. Previous roles include CEO of ECPAT UK - Every Child Protected Against
Trafficking, Director of SVARAJ Society for voluntary action Revilalisation and Justice and
Director of Low Pay Unil.
Adeola Akinloye is a member of the Association of Certified Accounlanls and has a Masters
degree in Business Information Technology. She has worked in the International Charity sector
in leadership positions over the last 24 years and is currently Finance Director of MEDAIR
Trustee Induction and Training
Vvhen recruTting new Trustees, the Board ensures that such candidates fully understand the
Charity's purposes and aims and possess the necessary skills to carry out their responsibilities.
Risk Management
The Trustees ac￿pt that the man8gement of risk is ultimately their responsibilty and, having
examined the major strategic, business and operational risks which the CIO faces, confirm that
appropriate Control systems have been established to mitigate such risks, as far as is possible.
Summary of Activities
It's a Penalty is a UK-based NGO with a global output, focused on ending abuse, exploitation
and human Irafticking worldwide through awareness-raising campaigns, advocacy for legal
refom, edu¢8tional programmes and youth empowerment.
In 2021122, It's ? Penalty had a phenomenal impact with I￿0 further campaigns around major
sporting events (Super Bowl LVI Campaign lJanuary-February 20221- Los Angeles. USA.,
Commonwealth Games lJune-Augusl 20221- Birmingham, UK. In addition lo our c3mpaigns,
we also greatly expanded the impact of It's a Penalty by continuing work on the additional
programmati¢ areas which contribute lo our goal of ending abuse, exploitation and human
trafficking on a global scale.. CommonProtect. student Ambassadors Ne￿Ork and Safe lo
Compete.
Objectives, Activltles and Perforniance for the Public Benefit:
It's a Penalty strives for a worfd where no human being suffers abuse, exploitation or trafficking.
To achieve this goal, our work consists on 4 key strategic programmes..
Campaigns - raising awareness about human trafficking, exploitation and abuse during
major sporting events.,
CommonProlecl
advocating for legal reform to improve protection from sexual
exploitation and abuse for children throughout the Commonwealth.,
Student Ambassadors Nelmork - educating and oising up UK university students lo
prevent human trafficking and exploitstion-,
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Report of the Trustees IconLI
Safe to Compete training sports coaches and parents of children in Little Leagues
lage S-12 years) in the USA to prevent abuse and exploitation.
As a member of the UN Global Compact. our work contributes towards the achievement of the
UN Sustsinable Development Goals.. 5.2 - Eliminate all forms of violence against all women
and girls in the public and private spheres, including trafficking and sexual and other types of
exp50itslion", 8.7 Take immediate and effective measures to emdicate forced labour, end
modern slavery and human trafficking and secure the prohibition and elimingtion of the worst
forms of child labour, including recruitment and use of child soldiers, and by 2025 end child
labour in all its forms,. 16.2- End abuse, exploitation, trafficking and all forms of violence against
and torture of children.
1. CAMPAIGNS
Harnessing the power of sport lo prevent abuse, exploitation and human trafficking, It's
Penalty campaigns around major sporting events to ￿lse awareness on a global scale, educate
about the si9ns to look out for and equip people with ways lo report
Since 2014, we have launched 14 global campaigns headed by high-profile athletes and actors,
primarily positioning major sporting events as platforms for worldwide action and change. Each
campaign is bespoke and conlextualised to each major sporting event and the need in the host
country, determined by working in partnership with sporting governing bodies and local NGOS.
Educational messages about what human trafficking is. the penalties for offenders, and how lo
identify and report it reach a global audience through strategi¢ distribution channels including..
airlines, in-flight entertainment, hotels and accommodation, airports, local transport, cinemas,
and social media.
Every campaign reaches an average of 180 million people across the world through
our strategic channels.
During each campaign. we have encouraged people to report abuse, exploitation
andlor human trafficking, resulting in an average increase of calls to hotlines of 210'/o.
To date, our campaigns have protected 17.000 potential survivors abuse, exploitab.on
and hum2n tmfficking globally, and prevented thousands more from being victimised.
Iys a Penalty believes that prevention and awareness-raising campaigns are an effective way
to curtail offences committed, and reduce demand while encouraging individuals, including
victims to come fomard and make a report.
To prevent abuse, exploitation and human trafficking. in 2021122 we..
EDUCATED- about the global issues of abuse, exploitation and human trafficking, the
penalties for offenders, and the signs of human tmfficking - #knowthesigns.,
EQUIPPED - sporting fans, tourists and the general public with mechanisms to ￿POrt
these crime5, both whilst at home and abroad.,
ENCOURAGED- people and potential victims of human trafficking lo make a report.
Super Bowl LVI Campaign lJanuary-February 20221- Los Angeles, USA
In Januaryl February 2022, It's a Penalty made an impact globally, and locally in Los Angeles
California. reaching a potential 737.5 million people worldwide.
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Report of the Trustees {cont.I
In ¢ollaboralion with our founding partner A21, on the 26th of January we launched the
Campaign, hosted by our Headline Partner IHG Hotels & Resorts, al Hotel Indigo in Downtown
Los Angeles, in collaboration with our other HeadSine Partners the NFL and Super Bowl Host
Committee and Friends at AHLA (American Hotel & Lodging Association), HALA (Hotel
Association of Los Angelesl and CHLA (California Hotels & Lodging Association). The Launch
event started with welcome remarks by IHG Hotels & Resorts Americas CEO Elle Maalouf and
our guest speaker Kathryn S. Schloessman, President & CEO LASEC, host ofSUPER BOVVL
LVI. Followed by messages from California elected officials - U.S. Representative Karen Bass
and Attorney General Rob Bonta. On this day 427 hoteliers listened to panel discussions on
Hotels Tackling Trafficking and Super Bowl Anti-Trafficking measures. Panel speakers
represented our partners such as Motel 6, Hilton, Los Angeles International Airport, the US
Institute of Human Trafficking, AHLA and our guest Marriott hotels. To conclude, our founding
partner A21 hosted a hotel specific Human Trafficking training with closing remarks from Nick
Caine, CEO, A21.
It's a Penalty also held a press conference, hosted by LAX Airport, attended by Dignitaries
including Los Angeles Attorney General Rob Bonta, President of LA City Council Nury Martinez,
VP Board of Airport Commissioners Val Velasco and LAX CEO Justin Erbacci at Los Angeles
International Airport. We also had representatives from our partners Uber, Airbnb, American
Airlines and Kevin Malone CEOI U.S Institute Against Human Trafficking (The HT Alliance). It's
a Penalty Campaign digital and printed signage was unveiled in LAX terminals, security
checkpoints and public restrooms to educate passengers. The press ¢onferen¢e generated 175
pieces of TV coverage and 363 online articles for a potential reach of over 277 million people.
This year we also provided a special QR code that allowed people to ￿ port suspected cases
of Human Trafficking or Child Sexual Exploitation from anywhere in the world.
Vve work with a talented PR agency called The Brand Amp, based in the US, who help us to
prepare a press release, prepare for interviews and ensure maximum coverage. Our press
release was picked up by 363 online postings, representing a total of 213.2 million potential
audience impressions. In total, our potential media reach was over 490 million people.
LAX is ranked as the 3rd busiest airport both in the U.S. and the world. Ifs 8 Penalty's digital
signage featuring Chris Godwin and Johnny Hekker has been displayed since January 1 st
throughout the airport with the hotline number. LAX has reported that a total of 4 million
passengers travelled through LAX during the month of January with another 4 million travellers
in Febmary for a total potential reach of 8 million + passengers as the signs are still being
displayed at LAX until further notice. The LAX airport also put Il's A Penalty's Mirror clings in
bathrooms throughout the terminals that included QR codes to make reports of Human
Trafficking and Sexual Exploi(ation anywhere in the world via our intemal ￿ porting tool found
on It's a Penalty website.
Through our airline partners, we had a potential reach of 10.5 million people. American Airfines
showed our 30 sec PSA film in-flight on all international and national flights during the months
of January and February, and Southwest Airlines showed the campaign film in-ffighl throughout
the months of January and February. Additionally, Southwest shared the film on all digital signs
system wide and their internal and external blogs which has a reach of 55,000 employees and
a potential reach of over 200,000+ people.
As part of our awareness Campaign, we ¢reated edu¢ational anti-trafficking kits contsining
materials with signs to look out for and the National Human Trafficking Hotline number. In total,
1.5k tangible and digital kits were distributed to hotels and motels for staff and management
and the general public. 2,500 hang lags were distributed to Uber drivers in Los Angeles,
Califomia. Hang tags displayed the hotline number lo call if a driver OT passenger suspeeled 8
criminal actwity involving Human Trafficking or Child Sexual Exploitation.
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427 hoteliers participated in a training at Hotel Indigo in DTLA sponsored by our Headline
Partner IHG Hotel & Resorts. During this training, hotel staff listened lo panel discussions by
industry leaders on human trafficking prevention methods in the hotel industry. Attendees heard
from local NGOS and Dignitaries locally in Los Angeles. Our founding partner A21 finished the
event by providing more intense and detailed training on Human Trafficking and Signs to look
out for with real life examples. Every person in attendance received a tangible 11 s a Penalty
anli-trafficking kit.
The It's a Penalty team was invited to contribute to the Hilton staff anli-trafficking training,
alongside the Global Director of Intelligence, Gabriel Warren. The presentation. attended by
staff across the board - from housekeeping lo chefs, lo security and front of house staff
included an overview of our campaign and the signs to look out for. 70 attendees at the Hilton
training sessions also received tsngible It's a Penalty anli-trafficking kits with posters in English
and Spanish, hand sanitizers and a missing children's list provided by NCMEC to take back to
their respective hotels. We asso partnered with Airbnb lo raise awareness. Los Angeles Airbnb
hosts received digital kits containing posters in English and Spanish.
On January 20, 2022, volunteers joined ZOE International, a Los Angeles organisation whose
mission is to reach every person and rescue every child, led by Michael & Carol Hart.
Volunteers packed awareness kits that included 11,500 It's a Penalty posters in English and in
Spanish, 8,500 hand sanitizers and 1,500 Missing Children lists provided by the National Cenler
of Missing 2nd Exploited Children in the Los Angeles area. Campaign materials were distribute
to over 450 hote5s and motels across the Los Angeles area. It's a Penalty and its Founding
Partner A21 partnered with Zoe International to coordinate the outreach.
For the first time, It's a Penalty as part of The Allian￿ Against Human Trafficking and
Exploitation IA21, USIAHT, Inner City Visions, Knot Today, Ifs a Penalty) had a booth al the
Super Bowl Experience. This was an interactive botsth with activities for the kids with squishy
mini footballs and over 12,500 flyers with human trafficking awareness infomation from each
of these NGO'S was distributed. All organisations collaborated to produce a PSA video that was
shown to a potential 80,000 people that attended the Los Angeles Super Bowl NFL Experience.
Volunteers from It's a Penalty partners Zoe Intemational and A21 were train￿ to run the booth.
In addrtion lo the above. our direct local impact for the LA Campaign includes..
14 missing children identified in Los Angeles.
20010 increase in reports to the US Human Trafficking Hotline- in the run-up super bowl
compared ID the same time period the previous year.
8 minors who were being sexually exploited in Los Angeles were rescued.
494 traffickers and sex buyers were arrested throughout California during the
campaign.
A potential reach of 3 million people followed, shared and viewed the campaign on
social media.
During the Super Bowl LVI in Los Angeles, we asked people to answer a short survey on our
website Iwww.itsapenalty.orgl lo help us understand and assess the differen￿ that the Il's a
Penalty carnpaign made in EDUCATING about global issues of tracking and exploitation, and
the signs to look out for to identify a ¢rime.
A primary goal of the campaign is to EQUIP the public to report these ¢rimes and ENCOURAGE
them to be confident in making that report. Overall, 960/0 of respondents felt It's a Penalty
improved their awareness of the issues of human trafficking and exploitation., 93Q/o of
respondents said their knowledge of the signs of these crimes had increased because of It's a
Penalty., 93010 of respondents felt more equipped to report crimes of traffickin9 and exploitation
after being exposed to the LA Campaign,. 100 /0 of respondents felt that It's a Penalty LA
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Campaign increased their confidence or likeliness to report suspected cases of exploitation and
trafficking.
2022 Commonwealth Games lJuly-August 20221- Birmingham, UK
In 2022, the Birmingham Commonwealth Games presented a fant2Stic opportunity to raise
awareness locally in Birmingham, across the UK and worfdwide, and P￿vent people from
becoming victims of human trafficking and exploitation. This was the second It's a Penalty
Campaign lo run al a Commonwealth Games Ilhe previous being 2018 at Gold Coasll, and we
aimed to maximise our impact at the Games even further in Birmingham.
The Birmingham Campaign mobilised during the Commonwealth Games in Birmingham to
encourage millions of people to help prevent modem slavery and protect survivors throughout
the West Mid18nds, the UK and W0￿dwIde.
Our approach for the campaign was to educate people coming into and travelling around
Birmingham during the Games on how lo spot abuse, exploitation and human trafficking, make
them aw8re of the issue and SUPPDrt available for survivors, and the helpline lo call if they
suspect themselves or someone they know are being exploited. Due to Birmingham's
promotion as a tourist destination in the lead-up-to the Games, working with the travel and
tourism industry was essential in order to reach as many people as possible with the key
campaign messages. To give the campaign a Commonwealth vol￿, we worked with sporting
ambassadors from across the Commonwealth, including Usain Bolt (Jamaical, Ellie Simmonds
{UK) and Cathy Freeman (Australia).
To ensure that our campaign fil the locsl need in Birmingham and came alongside existing anti-
human trafficking efforts in the region, we partnered with local fronlline NGOS the West
Midlands Anti Slavery NeI￿ork, West Midlands Violence Reduction Partnership and Faith
Alliance, and UK-wide charity Missing People. We also worked with the endorsement of United
by Birmingham 2022. Wth the help of our expert partners, we were able to distribute our
ampaign materials across the West Midlands and beyond, including in-flight on international
airlines (British Airways and Emiratesl, motorway service stations, Birmingham airport. train
stations, trams, hotels and in hospitality venues. In total, the potential reach of the Birmingham
Campaign was a phenomenal 57,746,897 people on-the￿r0und in the UK and worldwide.
During the Birmingham Campaign, for the first time ever. It's a Penalty displayed huge signs
outside of Molo motorway services. This was a brand new form of reaching people with our
campaign messaging, and proved very successful. We were able to do this due lo Moto
generously donating their advertising space to the campaign, which was very encouraging for
us. Motorway service stations have been identified in previous news oullels as a key Spa￿ in
which lorries that illegally move human trafficking survivors in dangerous conditions have been
found. For this reason, we felt il hugely important lo show our campaign materi815 to the public
at service stations. In total, a potential 1,463,823 people were reached throughout the UK as a
result of this collaboration with Moto.
Engaging the local community, empowering survivors and reaching those at risk of abuse.
exploitation and trafficking was of Critical importan¢e. Thanks to our partnership with community
organisations such as the West Midlands Violence Reduction Partnership's Faith Alliance.
NebNorkFour and Pitsstop, over 2500 It's a Penalty campaign posters and business cards were
distributed to and displayed at 370 events and venues. including pubs, bars and restaurants,
hotels, pla￿S of worship and information centres across Birmingham city centre and
surmunding areas.
Throughout the Birmingham Campaign, Il's a Penalty and our partners shared impactful social
media content about the campaign aclivilies, human trafficking and exploitation in Birmingham,
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the Wesl Mid5ands, and the Commonwealth, the signs to look out for and reporting helpline
information. Digital toolkits contsining the campaign film, list of missing people in the Wesl
Midlands, posters and social media campaigns were also shared wrth partners, friends and
supporters.
Working with our partners AiTbnb, It's a Penalty delivered in-person training on human
trafficking awareness, the signs to look out for, and reporting information to 45 Airbnb hosts
from across Birmingharn ahead of the Commonwealth Games. Airbnb also distributed It's a
Penalty's informative campaign materials to 115 more hosts online. Il's a Penalty also assisted
our global partner Hilton, who addrfcionally hosted the campaign launch event in Bimingham,
with training on human trafficking, the signs to look out for and how to make a report to hotel
managers in the run-up to the start of the Commonwealth Games. In total, 396 Hilton staff were
trained, including teams trom Front Desk, Housekeeping, Maintenance, Security, Food and
Beverage, and ConferenTr and Events. During the campaign, as a result of this collaboration,
Il's a Penalty posters and informative business cards were also displayed in 6 Hilton hotels
throughout the Wesl Midlands reaching members of staff, back-of-house teams and guests.
During the Bimiingham Campaign, 998 potential victims of modern slavery in the UK indicated
to Unseen's Modern Slavery and Exploitation Helpline. In the West Midlands, 23 potential
victims of modern slavery were identified by the Helpline in the Wesl Midlands.
As an additional campaign activity. It's a Penalty was honoured lo partner with Missing People
during our Birmingham Campaign to raise awareness of people who have gone missing in the
West Midlands and may be at risk of exploitation. Our joint campaign posters containing a QR
code linking lo our infom8tive custorn webpage were displayed on 36 large screens throughout
train stations for 17 days spanning over July and August. The posters were displayed in 5
stations throughout Birmingham.. Birmingham New St. Leamington Spa, Birmingham Moor St,
Birmingham Snow Hill, and the University reaching a potential 7,154,495 people. 22 people
that Missing People appealed for were found safe and well during the Campaign period.
Additionally, 191 posters of missing people appeals were downloaded from the Missing People
website - widening the reach and publicity of their Work.
Following the conclusion ofthe Birmingham 2022 Commonwealth Games Campaign, we asked
people to answer a short survey on our website Iwww.itsapena5ty.orgl to help us understand
and assess the difference that the Il's a Penalty campaign made in educating about global
issues of abuse. exploitation and human trafficking. the signs to look out for to identify a crime,
reporting helpline information, and increasing their confidence in making a report. 93D/o of
respondents fell Il's a Penalty improved their awareness of the issues of abuse, exploitation
and human trafficking., 860/0 of respondents said their knowledge of the signs of these crimes
had increased because of It's a Penalty., 88g/o of respondents felt more equipped to report
crime5 of abuse, exploitation and human trafficking after being exposed lo the Birmingham
Campaign,. and 81 % of respondents felt that It's a Penalty Bimingham Campaign increased
their confidence or likeliness to report suspected cases of exploitation and trafficking.
As part of our survey we asked for people to submit comments about the camp?ign and how it
benefited them. Here are some of their comments. Each lime I read over the signs of human
trafficking, they become more embedded into my thought process, l am ￿mInded to be more
aware of my surroundings and those l am crtsssing paths with when I read if you see something
say something."; "This helps to know how to report suspected cases with every little bit of
wisdom & knowledge that helps along the way."
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2. COMMONPROTECT
The sexual exploitation and abuse of children, including online, is reaching epidemic levels. No
country is immune. Current gaps in laws mean that millions of children throughout the
Commonwealth are legally unprotected from abuse by nationals and travelling offenders.
Working in collaboration with governments, civil society organisalions, child rights champions
and Commonwealth institutions, CommonProtect is the Commonwealth-wide movement to end
impunity for child sexual exploitation and abuse ICSEAI, improve access tojuslice for survivors
and ensure better child protedion. Our ultimate goal is for there lo be a comprehensive legal
framework in pla¢e in each Commonwealth country which criminalises CSEA in every form, no
matter where the offender is from or where in the world the offenTr takes place.
In March 2022, we held an online panel to mark Commonwealth week, build a Commonwealth
¢all lo action ahead of the Commonwealth Heads of Government Meeting ICHOGMI in June.
and announce the upcoming CommonProlecl report. The theme of the panel was the Tole of
the Commonwealth in protecting children from sexual exploitation and abuse. Panel
participants in¢luded representatives from. the Commonwealth Secretariat. Commonwealth
Lawyers Association, Commonwealth Parliamentary Association, Commonwealth Org8nisation
for Social Work and the Commonwealth Human Rights Initiative
In May 2022, launched the CommonProtect report with an online event featuring several
partners and an expert panel, planned over a series of months prior to the publication date. The
CommonProlecl report analyses the laws and systems in pla￿ in 21 Commonwealth countries
to protect children from sexual exploitation and abuse, and make recommendations for
govemments and other stakeholders to lake action in order to improve the prosecution,
p￿ventIon and protection from these forms of violence. The report wa5 prodU￿d over a two-
year period in partnership with Trust Law, the Commonwealth Lawyers Association, Sysdoc,
CMS and Clayton Utz, as well as 21 lawyers and researchers in the focus countries. Spotlight
piece contributors to the report included.. ICMEC, ECPAT, WeProtect, IFRC, Commonwealth
Lawyers Association, Dr. Michael Salter, Human Dignity Trust, Commonwealth Human Rights
Initiative & Walk F￿e Foundation, UNICEF, Commtsnwealth Organisation of Social Work and
the Council of Europe's Lanzarote Committee.
The report found there is still a long way to go towards ensuring that every child in the
Commonwealth is safe from exploitation and abuse.. Millions of children do not currently have
the full protection of the law against all forms of sexual exploilalion and abuse., Children's
access lo justice is hampered by law enforcement and prosecution rates, societal stigma,
under-reporting, and the limited capacity of protective services,. Not only must legal change be
brought about lo better protect childon from CSEA, the improvement of enforcement, reporting,
prosecution, protection and p￿ventIon are also key.
The report and executive summary establishes the evidence base for the CommonProtect
programme ?nd will be used as a key advocacy material moving forward. In July 2022. our
partners Clayton Utz hosted a AuslraSia-based launch event to promote the report and its
findings, involving ￿gIonal experts on CSEA and representatives from leading child protection
organisalions, law enforcement and legal experts.
Following the publication of the report, a key priority was implementing a strategy in order to
Influen￿ the agenda al the Commonwealth Heads of Government Meeting in June 2022 to
include the protection of children from sexual exploitation and abuse. As a result of our efforts
and those of other stakeholders and partners, we were able to succeed in including the issue
into two key statements from the meeting. As a result of the outcomes of CHOGM 2022, we
have been developing and implementing our high-level advocacy strategy, with the support of
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Report of the Trustees Icont.)
our partner Atlas Free, to continue spollighling child protection to be on the agenda for
discussion and aotion in Commonwealth spaces.
The year 202112022 has also involved building a social media presence and voice on child
protection issues for CommonProtect, nebworking with other organisations and establishing It's
a Penalty as a leading authority on protecting children from CSEA, as well as maintaining and
developing relationships and partnership5 Wlth key organisations.
3. STUDENT AMBASSADORS NETWORK
It's a Penalty's Student Ambassador Ne￿tsrk is a programme to raise a community of student
activists in the UK. This programme is designed to provide future change-makers with a spa
to embraTr creativity, enhance employability and champion a social justice initiative to
complement academic learning and skills. The Programme combines conventional
campaigning techniques - from building support on their campuses and in their communities to
influencing people in authority. On joining the Student Ambassador Network, they be¢ome part
of a national ne￿Ork of young changemakers to bring about the social transformation we all
want to see locally and globally.
The Student Ambassador NebNork ISANI programme empowers university students with the
knowledge, confidence, networks and skills to become ambassadors of change against abuse,
exploitation and human trafficking. The programme includes four core courses ¢overing'.
Human trafficking training, Bysl8nder training 8nd Consent training developed by Marshall
elearning and Coventry University and Campaign planning developed by Campaign Bootcamp.
In lolal, the training lakes approx. 6 hours and students don't have to complete it all in one go.
Following the training, the students engage with the community through various activism
projects. The majority of Students undertaking the programme host campus events, promote
discussion and empower participants to know the signs of human abuse, exploitation and
human trafficking and how to report it,. promote responsible procurement., become a
conscientious consumer, write and share articles and educational content on social media.
Students also undertake fundraising events as part of the programme. Throughout the process,
students are mentored and supported by the Student Ambassador Ne￿Ork team.
The year 2021122 has seen the ¢ontinued development of the SAN programme, including
expanding the number of universities the prtsgramme is implemented at and building new
complementary projects. In total, 151 students have signed up to the programme in the last
academic year, and a series of lectures and seminars were delivered in the academic year lo
220 students who were exposed to training and awareness of modem slavery. To date, the
Student Ambassador Ne￿ork has been run in Birmingham City University, Cardiff Met
University. Edinburgh Unive￿Ity, Goldsmiths University, Hull University, Portsmouth University,
St Mary's University Surrey University and Sussex University.
As part of the SAN programme, in 2022, we produced a Modern Slavery.. County Lines
awareness film in partnership with West Sussex poliTr. The film was promoted across oursocial
media and used as a key awareness-raising piece about country lines exploitation and how to
prevent it.
As a result of working collaboratively during the Birmingham Campaign, the West Midlands
Anti-slavery NebNork and It's a Penalty have teamed up to create a West Midlands Slavery
Free Campus Alliance to promote slavery-free university campuses across the region. The
Alliance will analyse university structures and make key recommendations for universities to
Page 10

IT'S A PENALTY
FOR THE YEAR ENDED 30 SEPTEMBER 2022
Report of the Trustees IconLI
tackle modem slavery, promote evidents-based targeted prevention and intervention
techniques to educate students and staff on exploitation, build students, confidence and
knowledge of their rights in the work environment, and address the risk of modern slavery
across university activities and pro￿sses.
4. SAFE TO COMPETE
Safe lo Compete is a national initiative based in the US launched by IVS a Penalty and The
National Center for Missing & Exploited Children INCMECI lo prevent abuse, exploitation and
trafficking of young children as they learn lo compete in youth sports. With Safe to Compete,
It'5 a Penalty aims to foster an environment in youth sports wheo children are safe from these
forms of violence.
Youth sports present a great platform through which to raise awareness and protect children.
High profile Cases of young athletes being abused whilst competing have drawn attention to the
issue of child protection in sports all over the world. Safe to Compete's focus is to address gaps
in knowledge, skills and action amongst parents, caregivers and coaches in order lo improve
every child's protection from these forms of violence.
In partnership with NCMEC, in the year 2021122, we continued work to promote and develop
the programme across the US. The microsile for Safe lo Compete was launched in Sprring 2022,
which includes key information on the abuse, exploitation and trafficking of children, training
courses for parents, caregivers and coaches, and ways lo make a report. In addition, we filmed
and launched 3 Public Setvice Announcements IPSAS) featuring Safe to Compete
ambassadors Hunter Dozier Imajor League Baseball Player for Kansas City Royals), Evan
Kravetz (Major League Baseball Player for Cincinnati Redsl and Chris Godwin (Wide Receiver
with Tampa Bey Buccaneers and Super Bowl Champion}-
Financial Review
It's a Penalty enjoyed another good year in terms of financial support- particularly for Super
Bowl LVI in Los Angeles and the recently created Student Ambassador Network. Further Pro
Bono work of £428,164 was also received. A surplus of £22,665 was achieved in the year and
Unrestricted Reserves of £64,307 are carried forward into the year to 30th September 2023.
Reserves policy
The CIO currently has no Restricted Reserves and an Unrestricted General Reserve of £64,307
at 30 September 2022 a figure that exceeds three months core" costs. Fundraising efforts will
continue lo ensure that this level of Reserves is maintained.
Plans for Future Periods
The prTncipal campaigns with which It's a Penalty will be involveos in are the Arizona Super
Bowl, the FIFA Women's World Cup in Australia and New Zealand and the F1 Las Vegas
Grand Prix.
Page11

IT'S A PENALTY
FOR THE YEAR ENDED 30 SEPTEMBER 2022
Report of the Trustees {cont.I
Trustees, Responsibilities Statement
The Trustees are responsible for preparing the Trustees, Annual Report and the financial
stslements in accordance with applicable law and United Kingdom Accounting Standards
Iuniled Kingdom Generally Accepted Accounting Practice).
The law applicable to charities in England & Wales requires the Tnjstees to prepare ffnancial
statements for ea¢h financial year which give a true and fair view of the state of affairs of the
Charity and ofthe ineoming resources and application of reSoUr￿S of the Charity forthat period.
In preparing these financial stslements, the Trustees are required to..
select suitable accounting policies and then apply them consistently.,
observe the methods and principles in the Charities SORP 2019 IFRS1021',
make judgements and estimates that are reasonable and prudent.,
stale whether applicable accounting standards have been followed, subject to any
rnaterial departures disclosed and explained in the financial stalemenls.,
prepare the financial statements on the going concern basis unless it is inappropriate
to presume that the Charity will continue in operation.
The Tm5tees are responsible for keeping proper accounting records that disclose with
reasonable accuracy at any tirne the financial position of the Charity and enable them to ensure
that the financial statements comply with the Charities Act 2011, the Charity (Accounts and
Reports) Regulations 2008 and the provisions of the Trust Deed. They are also responsible for
safeguarding the assets of the Charity and hence for taking reasonable steps for the prevention
and detection of fraud and other irregularities.
The Report of the Trustees was approved by written procedure amongst Trustees on 2I-ia ￿12
and signed on their beha5f by..
E McAlpine

IT'S A PENALTY
INDEPENDENT EXAMINER'S REPORT FOR THE
YEAR ENDED 30 SEPTEMBER 2022
I report to the Trustees on my examination of the accounts of Il's a Penalty (the CIO) for the
year ended 30 September 2022.
Responsibilities and basis of Trport
As the Charity Trustees of the CIO you are responsible for the preparation of the accounts in
accordance with the requirements of the Charities Act 2011 I'the Act'i.
I report in respect of my examination of the CIO'S accounts carried out under se¢lion 145 of the
2011 Aet and in carrying out ry examination I have followed all the applicable Directions given
by the Charity Commission under section 14515llbl of the AGt.
Independent examinees staternent
I confimi that l arn qualified lo undertake the examination because l am a member of the
Institute of Chartered Accounlanls in England and Wales, whi¢h is one of the listed bodies.
I have completed my examination. I can confirm that no material matters have come lo ry
attention in connection with the examination giving me cause to believe that in any material
respect..
Accounting records were not kept in respect of the CIO as required by section 130 of the
Act., or
The accounts do not accord with those record5', or
The accounts do not comply with the applicable requirements concerning the form and
eontent of accounts set out in the Charities (Accounts and Reports) Regulations 2008
other than any requirement that the accounts give a 'true and fair, view which is not a
matter considered as part of an independent examination.
I have no contsrns and have come across no other matters in ¢onne¢lion with the examination
to which attention should be drawn in this report in order to enable a proper understanding of
the accounts lo be reached.
Steve Robinson FCA
Chartered Accountant
Silbury Court
420 Silbury Boulevard
Central Milton Keynes
MK9 2AF
Date:22 De¢embèr 2022
Page 13

IT'S A PENALTY
STATEMENT OF FINANCIAL ACTIVITIES INCLUDING INCOME AND EXPENDITURE
ACCOUNT FOR THE YEAR ENDED 30 SEPTEMBER 2022
Un-
Restricted
General
Notes
Restricted
Total
Total
Funds
2022
2021
Income
Incorne from Generated
funds
Donations and grants
746,222
746,222
938,027
Total Income
746,222
746,222
938,027
Ex
enditure
Charitable Activities
Expenditure on charitable
activities
566.078
566,078
839,578
Cost of Raising funds
Expenditure on raising funds
131,798
131,798
50,492
Other Expenditure
Support costs
25,681
25,681
20,317
Total expendtture
723.557
723,557
910,387
Transfer be￿een Funds
Net movement in funds
22,665
22,665
27,640
Balance at l October 2021
41,642
41,642
14,002
Balance at 30 September
2022
64,307
64,307
41,642
All of the above results are derived from continuing activities_
All gains and losses recognised in the period are included above.
The split of comparative funds is shown in note 13.
The notes on pages 16 to 22 form part of these financial statements.
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rrs A PENALTY
BALANCE SHEET AS AT 30 SEPTEklBER 2022
Notes
2022
2021
Fjxed Assets
Intsngible assets
Current Assets
Debtors
Cash al bank and in har
75.723
75.990
75,723
Creditors: amounts falling due within one year
{11,4T61
(34.348)
Net current assets
64.307
41,642
Net assets
64.307
41.642
Represented by:
Unreslnc*ed fvnds
Restnrted fvnds
IOIII
64.307
41.642
Totsl Charity Funds
84.307
41,642
The fin2nckil statèments wère appr4 ved ty Tnjstees c
were signed on th6ir beHI ty.
and
TNslee
C McLellan
The notes on pages 16 10 22 fom part of these fin211ts¥1 *alements.
Page1S

IT'S A PENALTY
FOR THE YEAR ENDED 30 SEPTEMBER 2022
NOTES TO THE FINANCIAL STATEMENTS
1. Accounting policies
Basis of Preparation
The financial ststements 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 IFRS 1021 leffeclwe 1 January 20191 (Charities SORP IFRS 10211.
It's a Penalty meets the definition of a public benefit entity under FRS 102. Assets and liabilities
are initially recognised at historical cost or transaction value unless otherwise ststed in the
relevant accounting policy notelsl.
The Trustees have taken advantage of the exemption in Charities SORP IFRS1021 from
including a cashflow statement in the financial statements on the grounds that the organisation
is small.
Income
Donations and Grants
Income from donations and grants is included in incoming resources when received. Income
is then deferred when a condition which is placed upon the Charity's entitlement to it has not
yet been completed.
Donations receivable for the general purposes of the Charity a￿ credited to general
unrestricted funds. Donations for purposes ￿$tricted by the wishes of the donor are taken to
restricted funds.
Int2ngible income in the form of valuable good or seNiTrs donated to the Charity at some
a&ual expense to the donor are included in the Statement of Financial Activities when the
benefit IS quantifiable and measurable.
Expenditure
Expenditure is included in the Statement of Financial Activities on an accruals basis, inclusive
of any VAT which cannot be recovered.
Intangible Assets and Amortisation
Intangible assets are slated at cost less accumulated amortisation and any accumulated
impairment losses. Amortisalion is provided al rates calculated to write off the cost less
estimated residual value of each asset over ils expected useful life, as follows..
Website Development
3 year5 Straight line
Page 16

tT'S A PENALTY
FOR THE YEAR ENDED 30 SEPTEMBER 2022
NOTES TO THE FINANCIAL STATEMENTS (Cont'dl
Fund accounting
General funds are unrestricted funds which are available for use at the discretion of the
Trustees in further8nce of the general objectives of the Charity and which have not been
designated for other purposes.
Designated funds comprise unrestricted funds that have been set aside by the Trustees for
particular purposes. The aim and use of each designated fund is set out in the notes to the
financial ststements.
Restricted funds comprise funds donated for specffic purposes. The aim and use of each fund
is set out in the notes.
Debtors
Trade and other debtors are wognised at the settlement amount due after any trade discount
offered. Prepayments are valued al the amount prepaid nel of any trade discounts due.
Cash at bank and in hand
Cash at bank and cash in hand includes ¢ash and short term highly liquid investments with a
short rnalurity of three months or less from the date of acquisition or opening of the deposit or
similar aceount
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 lo a third paty and the amount
due to settle the obligation can be measured or estimated reliably. Creditors and provisions are
normally recognised al their settlement amount after allowing for any trade discounts due.
Flnanclal Instruments
The CIO 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 al their settlemènt value with the exception of bank loans which are
subsequently measured at amortised cost using the effective interest method.
Page 17

IT'S A PENALTY
FOR THE YEAR ENDED 30 SEPTEMBER 2022
NOTES TO THE FINANCIAL STATEMENTS (Cont'dl
1. Golng concem
At the time of approving the financial statements, the Trustees have a reasonable
expectation that the CIO has adequate resources to continue in operational existence for
the foreseeable future. The charity has adequate resources lo continue in operational
existence for the foreseeable future. Thus the Trustees continue to adopt the going concem
basis of accounting in preparing the fsnancial statements.
2. Donatlons and grants
2022
2021
Institutional income
Trust income
other income
300,058
18,000
428,164
746,222
277.854
10,000
650,173
938,027
Unrestricted Income from donations and grants was £746,22212021.. £938,027> of which £Nil12021..
£Nill was reslricled.
Other income includes £428.16412021.' £650.1731 relating to donations in kind principally provided for
professional serVI￿S contributing to advancing our advocacy agenda.
Included within institutional income is an amount of £nil 12021.. £nill relating to donations in kind
received by the Charity.
3. Expenditure on charitable acttvities
Unrestricted
Restricted
2022
2021
It's a Penalty Campaign
Salaries & Nl
Consullanls
Design & Athork
Website
Promotion
Social Media Development
Filming & Production
Travel & Accommodation
Legal Expenses
Total
53,536
129,175
17,084
3,073
53,536
129,175
17,084
3,073
54,081
91,265
16,806
1,312
48,638
45,171
19,889
249,512
566,078
48,638
45,171
19,889
249,512
566,078
33,942
6.300
635,872
839,578
Page 18

IT'S A PENALTY
FOR THE YEAR ENDED 30 SEPTEMBER 2022
NOTES TO THE FINANCIAL STATEMENTS {Cont'dl
Expenditure includes £428,164 {2021.. £650,173) relating lo donab.ons in kind for profession81
servI￿S contributing to advancing OLJr advocacy agenda.
4. Expenditure on raising funds
Unrestrlcted
Restrfcted
2022
2021
Advocacy Lobbying
Advocacy Fundraising
Printing
12,337
29,069
90,392
131,798
12,337
29,069
90,392
131,798
21,378
29,114
50,492
5. Other Expenditure
Unrestricted
Restricted
2022
2021
Support Costs
Office Rent
2,474
Accountancy
Travel & Refreshment5
Other Costs
Governance costs
Independent Examiner's Fee
9,000
8,211
S,870
9,000
8,211
5,870
8,000
4,275
4,068
2,600
25,681
2,600
25,681
1,500
20,317
6. Staff numbets and expenses
There was no Trustees, remuneration during the financial year and trustee expenditure of £nil was
reimbursed12021.' £nill.
The average number of persons employed by the CIO during the year was:
2022
No.
2021
No.
Average stsff head count
Staff costs (for the above persons)
Wages and salaries
Social security costs
Pension
75.000
4.605
3,000
75,000
5,134
3,000
82,605
83,134
One employee received emoluments of MO￿ than £60,000 per annum as disclosed above.
Page 19

IT'S A PENALTY
FOR THE YEAR ENDED 30 SEPTEMBER 2022
NOTES TO THE FINANCIAL STATEMENTS {Confdl
7. Intangible Assets
Website
Total
Cost
Brought forward
Additions
Carried forward
6,000
5,000
6,000
6,000
Amortisation
Brought forward
Charye for the year
Carried forward
6.000
6,000
6,000
6.000
Carrying valuè
AI 30 September 2021
AI 30 September2022
8. Debtors
2022
2021
Trade Debtors
Accrued Income
Total
9. c￿ditors. arnounts falling due within one year
2022
2021
Trade Creditors
Taxation and Social Security
Accruals
Total
9,011
1.955
450
11,416
7,111
2,465
24,772
34,348
Page 20

tT'S A PENAL
FOR THE YEAR ENDED 30 SEPTEMBER 2022
NOTES TO THE FINANCIAL STATEMENTS {Cont'dl
10. Analysis of net assets between funds
Unrestricted
Funds
Restricted
Funds
Total
2022
Total
2021
Fund balances at 30 September
2022 are represented by..
Tangible fixed assets
Current assets
Creditors due within
one year
75,723
75,723
75.990
11,416
64,307
11,416
64,307
34,348
41,642
11. Analysis of charitable funds
Un-
Restricted
Funds
Restricted
Funds
Total Funds
Brought forward al 30 September
2021
41,642
41,642
Income
746,222
746,222
Expenditure
1723,5571
1723.5571
Balance at 30 September 2022
64.307
64.307
Page 21

Irs A PENALTY
FOR THE YEAR ENDED 30 SEPTEMBER 2022
NOTES TO THE FINANCIAL STATEMENTS Icont'dl
12. Related parties
During the year It's 8 Penalty paid a share of rent and telephone costs of £Nil12021.' £3,684)
for a shared office space, to Ils sister Charity Happy Child International.
Irs a Penalty received £12,000 {2021- £11,000) in donations from Sysdoc Ltd in which K Corich
1$ 8 director.
13. Comparative Statement of Financial Activities
Un-
Restricted
General
Restricted
Total
Funds
2021
Income
Income from Generated funds
Donations and grants
938,027
938,027
Total Income
938,027
938,027
Ex
enditure
Charitable Activities
Expenditure on charitable
activities
839,578
839,578
Cost of Raising funds
Expenditure on raising funds
50,492
50,492
Other Expenditure
Support costs
20,317
20,317
Total expenditure
910,387
910,387
Transfer be￿een funds
Net movement In funds
27,640
27,640
Balance at l October 2020
14.002
14.002
Balance at 30September 2021
41,642
41.642
Page 22