IT'S A PENALTY
{Formerly HAPPY CHILD INTERNATIONAL FOUNDATION)
IA Charitable Incorporated Oryanisation)
REPORT AND FINANCIAL STATEMENTS
FOR THE YEAR ENDED 30 SEPTEMBER 2023
Charity No: 1161848

IT'S A PENALTY
FOR THE YEAR ENDED 30 SEPTEMBER 2023
CONTENTS
Page
Legal and administrative information
Report of the Trustees
10
Independent Examiner's Report
Statement of Financial Activitses
12
Balance Sheet
13
Notes forming part of the Financial Statements

IT'S A PENAL
FOR THE YEAR ENDED 30 SEPTEMBER 2023
Reference and Administratlve Informatlon
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
A Akintoye
L Mcmahon
B Patel
Appointed 3rf October 2023
Resigned 25th July 2023
Management
SL de Carvalho MBE
Principal offlce
Lealherhead Institute
67 High Street
Lealherhead
i(r22 8AH
Independent ExamineT
Mr S Robinson
Chartered Accountant
420 Silbury Boulevard
Central Milton Keynes
MK9 2AF
Bankers
Santander
Customer Service Centre
Bootle
Merseyside
L30 4GB
Page 1

IT'S A PENALTY
FOR THE YEAR ENDED 30 SEPTEMBER 2023
Report of the Trustees
Trustees R¢port
The Trustees present their Annual Report and financial statements of the Charitable
Incorporated Organisalion for the year ended 30 September 2023. The financial statements
comply with the Charities Act 2011, the Trust's Deed and Accounting and Reporting by
Charities.. Ststement 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 (effective 1 January 20191.
Structure Governance and Mana
ement
Charitable status
It's a Penalty is a Charitable Incorporated Organisation ICIOI governed by its constitution and
has charitable slalus under the Charities Commission Association. Charity Number.. 1161848.
The CIO was recognised by the Charity Commission on 27 May 2015.
Organisation structuro
The Trustees assume responsibility for the day lo day management of the CIO and almost all
executive roles are undertaken by the Trustees.
The Board of Trustees meets six times ea¢h year to discuss current and fijlure projects and to
approve decisions such as the appointment of new Trustees and the remuneration of the one
key management employee.
Trustee Recruitment and Appointment
The Trustees were recruited with complementary skills and experience in mind from the
corporate, public and third sectors. Each bring a contribution of global ne￿rking, strategic
management. marketing. international development. accountancy.
Katherine Corich 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 to end female genilal mutilation. Chrislianne bring5 expertise in partnership
and resource leveraging, having worked in various intemalional developrnent organisations.
Ewen McAlpine, works for Macaulay Search, and provides executive search services to
organisalions with just objectives. He is a strong networker providing valuable contacts and
introductrons in the Third and Commercial sector5.
Page 2

IT'S A PENALTY
FOR THE YEAR ENDED 30 SEPTEMBER 2023
Report of the Trustees {cont.I
Structure. Governance and Management {cont.I
Colin McLellan is a Chartered Accountant who, prior lo retirement, was Finance Dire¢tor of
MJ Gleeson Group plc.
Adeola Akintoye is a member of the Association of Certified Accounlanls and has a Masters
degree in Business Information Technology. She has worked in the Intemalional Charity
sector in leadership positions including Greenpeace International and is currenlly Di￿¢tor of
Finance in MEDAIR.
Liz Mcmahon is Managing Director of Madison Muir Group, strategic brand and sponsorship
advisors. and a Non-Exe¢utive Direelor and Trustee. She sils on the LTA {Lawn Tennis
Associationl Judicial Panel for Safeguarding, She is also a published author and speaker on
Olympic Games marketing and Brand.
Trustee Induction and Trainlng
hen recruiting 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￿p1 that the management of risk is ultimately their responsibility and, having
examined the major strategic. business and operational risks which the CIO faces, confirm
that appropriate Control systems have been estsblished lo mitigate such risks, as far as is
possible.
Ob
ectlves Actlvitles and Performance for the Publlc Benellt
The CIO was established to preserve the health of children and young people around the
world by protecting them from sexual and other exploilalion and the relief of poverty of
children and young people around the world by the provision of funds and services to relieve
the effects of povety.
The Trustees confirm they have referred to the guidance contained in the Charity
Commission's general guidance on public benefits when reviewing the CIO'S aims and
objectives.
In pursuit of ils aims and objectives. the CIO seeks to fundraise lo protect children from
exploilalion, abuse andlor alleviating child poverty in cities hosting sporting events and
elsewhere., grants to charitable organisations in cities hosb'ng sporting events and elsewhere,.
campaign against child exploilalion campaign for the enactment, slrenglhening and
enforcement of legislation lo protect children from sexual exploitation glob211y.
Summary of activities
Il's a Penatty is a UK-based NGO with a global output, focused on ending abuse. exploilalion
and human trafficking worldwide through awareness-raising campaigns. advocacy for legal
reform, educational programmes and youth empowerment.
Page 3

ITS A PENALTY
FOR THE YEAR ENDED 30 SEPTEMBER 2023
Report of the Trustees IconLI
CAMPAIGNS
Each It's a Penalty Campaign harnesses the power of sport to prevent abuse. exploitation
and human trafficking on a global scale, positioning each major sporting event as a platform
for worldwide action and change.
Qatar 2022 World Cu
November 2022
Il's a Penalty and STOP THE TRAFFIK partnered to run a joint digital campaign during the
Qatar 2022 World Cup. The campaign had three main aims.. perception. protection and
prevention. The campaign ran using geo-targeted adverts on social media to reach fans and
the general public on-lhe-ground in Qatar.
In particular. the campaign aimed lo communicate directly with fans who are likely lo see
indicators of exploitation in seelors such as hospitality, tfansport and security. Additionally.
reached fans who may be buying adult serviees durÉng the tournament and dissuade them
from being contributors to the broader modem slavery issue. The campaign materials include
information aimed at vulnerable communities, loo.
In total, the campaign reached 1.044,257 people in Qatar during the World Cup. Insights
showed that 25-34 year olds were more likely to watch the campaign video, and Arabi¢ and
English ads had the highest interest. Overall. the campaign had 158,656 unique link clicks {a
click-through rate 15x higher than industry average).
Our campaign survey of those who saw the video and ads found that..
58% agreed the campaign increased their awareness of exploitation.
650/0 fell the campaign increased their knowledge of how lo spot the signs of
exploitation.
61 Q/0 acknowledged that their confidence in making a report has increased.
45tsA look preventative action after seeing the campaign.
68% confirmed they will start taking preventative action as a result of the carnpa￿n.
Arizon8 Su
er Bowl LVII
Februa
2023
Following a successful campaign last year during the Super Bowl LVI in Los Angeles. the
15th global It's a Penalty Campaign launched ahead of Arizona Super Bowl LVII to bring
public awareness, give platform to survivor voices. engage local community. and work with
hospitality industry staff to prevent human trafficking, exploitslion and abuse.
For this campaign, our Main Partner was Atlas Free,. Supporting Partners were Hilton. IHG
Hotels & Resorts. Caflson Family Foundation, Airbnb. Southwest land Motel & Studio 6-
Friends were NCMEC, Safe to Compete, Where Hope Lives, AHLA Foundation. UNITY. and
WFA Pro. American Airlines and Southwest were the Participating Airfines.
Our NFL and WFA ambassadors included.. Markus Golden (Arizona Cardinals), Chatarius
'Tutu' A￿ell (Los Angeles Rams1, Aaron Rodgers (Green Bay Packersl, Jesse Luketa
(Arizona Cardinals), Lois Cook IDC Diva51, Chante 8onds180ston Renegadesl. Andy Dalton
(New Orleans Saints), Collette V. Smith INFL5 1st Black Female Coach). Chris Godwin
(Tampa Bay Buccaneers), and Tynequia Roberts (Tampa Bay Inferno).
In total, the Arizona Campaign's potential reach was 259 million people across all
platforms.
American Airlines showed our 30 sec PSA film in-flight on all screens and their in-
flight entertainment app featured on international and national flights during the
months of January and February. Southwest Airlines showed the campaign film in-
flight on their entertainment app throughout the months of January and February. The
campaign film was the second most viewed channel in January. In total, our potential
reach on airlines was over 10.5 million passengers.
On January 24th. 2023, volunteers came together from Where Hope Lives lo pack
awareness kits that included "Know the Signs. It's a Penalty Posters in English and in
Spanish, "How to Report. IVS a Penalty Posters, wristbands with National Human
Page 4

IT'S A PENALTY
FOR THE YEAR ENDED 30 SEPTEMBER 2023
Report of the Trustees Icont.)
Trafficking Hotfine number and Missing Children lists provided by the National Center
of Missing and Exploited Children INCMECI in the Arizona area. Tangible kits were
distributed lo over 100 hotels and motels across the Phoenix Metropolitan area.
Overall 26 missing children were found from NCMEC'S database during the Il's a
Penalty campaign.
Hilton facililaled a training session which IAP complemented Whe￿ 130 staff
members from seven Hilton hotels in the Phoenix Area were educated on identifying
signs of human trafficking and how lo report such incidents to the hotel management.
For the first time, Il's a Penalty was invited lo join Soulhwesl Airlines al their
employee lounge at Phoenix Sky Harbor International Airport. On January 26. 2023,
the Il's a Penalty team spent the morning passing out our campaign materials to
educate flight attendants, pilots, and in-office staff on the Signs of Human Trafficking
and how to report if they suspect human trafficking is taking place. We played our 30
second PSA film throughout the lounge and spoke with employees about their
experience with human trafficking and requested they fill out our campaign survey.
Our educational materials were distributed to 1.800 flight attendants via the
Southwest newsletter.
On the evening of January 26. 2023, the It's a Penalty team was invited to speak at
Airbnb's Host Safety Forum alongside Global Director of Trust and Safety
Communications, Ben Breil and a represenlatsve from the Arizona Attomey General's
Offi￿. The presentation
attended by 100 Phoenix and Scottsdale area hosts -
included an overview of our campaign, signs lo look out for, anli-trafficking resources,
and a Q & A session. Campaign materials were available for hosts to tske back lo
their respective properties.
During our Arizona Super Bowl human trafficking prevention Campaign, we were able
to secure an impressive amount of press coverage. In total, we were able lo generate
400 pieces of coverage through a combination of earned media and press release
pick-up. This coverage was highly impactful, as it had the potential to reach an
estimated 249 million people in lolal, giving our message a broad and powerful reach.
During the Campaign. we surveyed the public to assess the impact that the Campaign made
in educating about global issues of trafficking and exploitation, and the signs to look out for to
identify a crime..
82QA reported Campaign increased awareness of the issues of exploitation and
human trafficking.
74QA reported Campaign increased knowledge of the S￿nS of exploitslion and human
trafficking.
81 % reported Campaign increased awareness of how to report crimes of exploitation
and human traffick]'ng.
Kee
Kidssafe - Women's World Cu
ust 2023
Ahead of the 2023 Women's Wodd Cup, It's a Penalty launched our 16th global campaign in
the hosting countries of Australia and Aotearoa New Zealand.
The aim of the KeepKidsSafe Campaign was to highlight the importance of keeping kids safe,
particularly in sport. Public education and awareness campaigns play a vital role in increasing
public understanding of child safeguarding and protection from abuse and exploitation. For
the KeepKidsSafe Campaign. we were proud lo work in partnership with fantastic
organisalions dedicated lo protecting children across the wodd, in the Pacific region and in
the hosting countries of Australia and Aotearoa New Zealand. Supporting Partners included..
Carlson Family Foundation, ICMEC Australia. Sysdoc.,. Friends included.. OFC. Netsafe, In
Good Faith Foundation, esafety Commissioner, Safeguarding Children NZ, This is How We
Football. International Safeguards for Children in Sport, Bravehearts. and Child Matters.
Participating airlines were Air NZ. British Airways. Cathay Pacific and Emirates.. Participating
airports were Sydney, Hamilton and Brisbane.
Page 5

IT'S A PENALTY
FOR THE YEAR ENDED 30 SEPTEMBER 2023
Report of the Trustees Icont.)
We were delighted lo have the support of five intemational women ft)otball stars, including
Australian players Kyah Simon and Lydia Williams, a5 well as New Zealand's Fern Ria
Percival, Brazil's Rafaelle Souza and England Lioness Mary Earps, who lent their lime and
voices to our campaign lo help raise awareness via our 30-second campaign film, as well as
our informative posters.
In total, the potential reach of the KeepKiclsSafe Campaign was over 10.3 millh)n
people on-lhe-ground in the Pacific and worldwide.
British Airways, Emirales, Cathay Pacific and Air New Zealand showed the Il's a
Penalty ¢arnpaign film in-flight during the KeepKidsSafe Campaign from July-August
lo a potential audience of 5,402.849 people.
Informative digital banneis were displayed at Brisbane, Sydney and Hamilton Airports
Ihfoughout July-Augusl possibly reaching 3,753.002 people.
Throughout the KeepKidsSafe campaign, our digital campaign was key in sharing
educational posts about protecb'ng children from abuse and exploitation, ways to
report and find help, and safeguarding information. In total, It's a Penalty and our
partners reached over 1.1 million on social media.
One of the key aspects of the Keep Kids Safe campaign was emrxNering
communities to be more aware and 8ble lo take action. Our campaign webpage -
ilsa
enalt
.or
IKee
KidsSale- contained knowledge and resources educating adults
and children about their rights, the signs of abuse. and helplines and reporting
mechanisms available lo help anyone with concerns about a child or who has
experienced abuse. Throughout the campaign, we had 3.800 users visit the
informative webpage from countries including Australia. New Zealand. Fiji. Papua
New Guinea. Samoa. Solomon Islands, UK, USA and Japan.
Our partnership with Oceania Football Confederation IOFCI facilitated several
awareness-raising activities in OFC member countries in the Pacific during
community events and local football toumaments. These activities included displaying
banners and posters, showing the campaign film on screens during events,
distributing informative flyers to the public, and directing attendees to the campaign's
informative webpage on event tickets. As well as these on-the-ground activities, we
also reached Pacific audiences with key information through laryeted ads on
Faceb¢)ok.
During the Campaign, we suNeyed members of the public in the Pacific region to assess the
impact that the Campaign had in educaling about child abuse and exploitation and the signs
lo look out for lo identify a crime..
93Vv reported Campaign increased awareness of the issues of the abuse and
exploitation of children, particularly in sporL
91Vo reported Campaign increased knowledge of the signs of child abuse and
exploitation.
87/0 reported Campaign increased awareness of how to find help and report
suspected cases of child abuse and exploilalion.
85./0 reported Campaign increased their confidence or likeliness to report suspected
cases of child abuse and exploitation, and lake steps to keep children safe.
COMMONPROTECT
CommonProtect is It's a Penalty's advocacy programme focused on legal reform and systems
change in order to protect children from sexual exploitation and abuse ICSEAI throughout the
Commonwealth. Throughout 2022123 several activities have been undertaken as part of
CommonProtect. including..
To coincide with the Internatsonal Day for the Elimination of Wiolence Against
WomenlGirls125th November 20221. It's a Penalty published a Policy Brief examining
Page 6

IT'S A PENALTY
FOR THE YEAR ENDED 30 SEPTEMBER 2023
Report of the Trustees {cont.I
the prevention and elimination of CEFM in the Commonwealth, in collaboration w¢th
the Commonwealth Lawyers Association. The Policy Brief, produced as part of the
CommonProtect initiative, provides an overview of the issue of CEFM in the
Commonwealth, a summary of the advocacy and political efforts undertaken to4ate
by Commonwealth actors to address CEFM. provides an overview of the legal
context, and makes recommendations for action going fofward.
Developing work with the Commonwealth Children's Interest Group {ComCIGI to
highlight children's issues in Commonwealth spaces. including aligning work to take
forward the Kigali Declaration on Child Care and Protection Refomi.
On 23 February 2023, the Commonwe211h Secretariat's Social Development Division
and civil society organisations, including It's a Penalty, organised a roundtable
discussion to convene key stakeholders to discuss how to effectively implement the
Declaration. The roundtable aimed lo encourage collective action and knowledge
sharing across the Commonwealth. In the Declaration, leaders stressed the
importance of enabling best practices for learning and sharing between
Commonwealth states to implement a holistic and comprehensive approach to tackle
violence against children. Drawing on the expertise and experience of care and
protection reform for children and youth among stakeholders from across the
Commonwealth, the Roundtable identified priority areas for future action and
highlighted the need lo develop a roadmap for action. It touched upon the importan
of future collaboration be￿een Commonwealth govemments and civil society
organisalions, and agreement that the improvement of child care and protection
systems must be achieved through empowerirsg and supporting families
acknowledging child protection as an interconnected subject across sectors, including
health. education, safety and relationships, and must be addressed as such.
In March 2023, It's a Penalty's Advocacy Director, Elizabeth Speller. attended the
Commonwealth Law Conference 2023, organised by our partners the Comrnonwealth
Lawyers Association, in Goa, India. Under the Iherne tsf 'Common Challenges in
Uncommon Times,, lawyers and activists from across the international community
gathered in Goa to discuss legal and justice issues that are faced throughout the
Commonwealth and beyond. We were invited to speak on the Conferen￿ panel
discussing child marriage. The panel, entiued Child brides and legalised marital rape
a Commonwealth tragedy, was chaired by Robert Strang 13 Hare Court Chambers,
England) and our fellow panelisls included Senator Hazel Thompson Ahye {Trinidad
& Tobago) and Sneh Aurora Icommonweallh Human Rights Initsative. Englandl.
Convening panels lo launch the findings of the CommonProtect Report in the Pacific
(Wellington. March 2023 and Auckland May 20231 in partnership with KPMG New
Zealand and ACAMS. The expert panels, including representatives from NZ Police.
Department of Inlemal Affairs INZI and New Zealand Customs Service, Te Tari
Taiwhenua Department of Inlemal Affairs INZI. as well as NGOS Child Mallers.World
Vision NZ and ECPAT International discussed the need for refomis in New Zealand
and across the Paciftc, as highlighted by the findings of the CommonProlect report,
and shared their expertise on key issues. The events were allended by a wide range
of stakeholders including law enforcement, financial inslitulions, child safeguarding
agencies, NGOS. academics, tech companies and lawyers.
Ongoing throughout 2022123 has been the development of our advocacy strategy in
the lead up lo the next Commonwealth Heads of Government Meetin9 in Samoa. This
has included buildirlg partnerships lo support advocacy work. implementing our
campaigns in the Pacific region as a precursor and conducting initial research and
scoping of potential focus issues.
Page 7

IT'S A PENALTY
FOR THE YEAR ENDED 30 SEPTEMBER 2023
Report of the Trustees Icont.)
STUDENT AMBASSADOR PROGRAMME
It's 8 Penalty's Student Ambassador Programme educates and empowers university students
lo become ambassadors of change against abuse, exploitation and human trafficking. The
programme includes training courses on human trafficking. being an active bystander,
consent and planning campaigns. After completing their core training, students are supported
by the Student Ambassador Programme team to engage with the community through various
activism projects. These include hosting events on campus lo educate their peers, promoting
responsible procurement, writing and sharing articles. creating educational content for S(￿la1
media. fundraising events and awareness-raising initiatives in their local community.
This year 2022123 has seen the continued development and rapid rise of the Student
Ambassador Progr8mme. The programme was reviewed and reslruclured. with a revised
programme structure and core training course launching in June. Of the students who were
part of the programme before the relaunch, 16 students from S univeTsitses continued their
involvement. Since then, the programme has grown to 153 students from 44 universities.
including universities in every UK region.
SAFE TO COMPETE
Safe lo Compete is a national initiative between It's a Penalty and The National Center for
Missing & Exploited Children INCMECI to prevent abuse, exploitation and tr8fficknng of young
hildren as they learn to compete in youth sports.
Safe to Compete seeks to equip coaches and parents with the tools needed to create 8 safe
environment in sport where boundary violations of any sort are not tolerated. and where child
safety and respect are top priorities. This year has seen the development of the programme
to include..
30-minule interactive training course for coaches
15-minule parent education module
Discussion guides on boundary setting and safety for kids ages 5-11 and 12-17
Infomialion on child sex trafficking
Resources for coaches
Moving ft)rward, we will be renewing our partnership with NCMEC lo continue development of
this inilialive.
Financial Review
Expenditure exceeded Income in the year ended 30th September 2023 by £34.144 leaving a
closing Bank Balance of £41,579. however the Board is intent in maintaining a healthy level of
Unrestricted Reserves.
Resenies poli¢y
The CIO currently has no Reslricled Reseives and an Unrestricted General Reserve of
£33,386 at 30 September 2023.
Page 8

an
lof Future Perlods
Tho followiiig poterilial lulure It's a Penalty canipnians havti bèen Idonlilied
Pciulip Gambs Solomon Isli7nd5 2023
Las Vogos Supcr Bowl 2024
P&tiis Olyfflpic I Par￿lYmpIC Gaiiio% 2024 Gc?rnU.
Trustè•B' Rgsponslblllll*s StaleFnèni
Tlie Trus(6as are responsible loi prep8rsng the frusle&s' Annu￿?1 Reporl and the Iinanci<ryl
tt?lemen15 111 .Iccord4anco willi ilPI)IIciiLilc 1,1W lind Unitoil Kingd()iii Arcounling S11( iidc2ids
(Unilod Kinodom GviiOlRlly Accepted Accoui)ling PrHclicel.
Tl)f* law tippIIc£?ble lu cliaril*es Iri En Jclgiid & W8les requiies Ilie fiiislfj&s lo pièpaie Ilnanclal
lilemonig Ipr pach IininciAI yhFtr wl7ipli qivi. Irug .Ind lair vi&w ol lh• qlal8 ol alfairs ol Ih
Charily rfind ol Iricoining resouicos ?vvlicalioi¥ ol rogourc&s ol 11)e Clitirily lor Ihal
period In piop45iing Ihpsp linAnci8151alemonls. Ihe 'fiu51ees Arb rekqiJir¢d to..
strl&cl suilable acwunting polic185 and 1116n <lpply Ihom consisl8ntly.'
hherve the meiht>ds ind I)riiiriplfJ￿ 111 the ChiiriliBs SORP 2019 IFRS1021'.
makc, iudgemenls and CJsliin&tes Ihdl are roasoii<ible and piiidg111.
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pivpaii.. Ihe finariciJl SI￿71￿[71￿nts on Ill￿ (7r)1119 ¢oiic¥rii basis uiile¥b il is iiiappEoprig1
lo pie5uniB Ilial Ilits Ch¢iiily will Loriliiiup In operic Iiori
Tho TruslO05 Ale rosponslble lor keeping proper accounting recordg Ihal di8close with
reasonable clCLLllaCy ill Einy lime Ihe fin8ncit11 p0811iori of Ihg Charity gnd enELbl& Ihgtn lo
erisiifo Ilial Ihe Iin<7n¢ial sialeiTTrerils coniply wtlli the Chrjllties Acl 2011. Ihe Chaiity IAccoiJnls
nd Rvpoilsl IliigiilLilions 2008 c1na Iho piovi4ioiis of Iliti Tfiisl D8ed ri)ey lire aSso
responsible Iix saleotJ&irdiriq the 8$88ts of tho ChArily aiirl Iiance lor taking reasonEkbld slop¥
loi Iho prevonliDn ciiid doieciion ol fraud And Oiher Irr@gLiiarilies
Tho Repoit ol 1118 Tiuslees WH5 approved by Willlen piocedure sjmongtsl Tiiistoe5 on
8litJ sloiied r)ii their bL*liiill by.
K CDricli
PJJge 9

IT'S A PENALTY
INDEPENDENT EXAMINER'S REPORT FOR THE
YEAR ENDED 30 SEPTEMBER 2023
I report to the Trustees on my examination of the accounts of Il's a Penalty Ilhe CIO) for the
year ended 30 September 2023.
Responsibllltles and basis of report
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 20111.the Act'i.
I report in respect of my examination of the CIO'S accounts carried out under section 145 of
the 2011 Act and in carrying out my examination I have followed all the applicable Directions
given by the Charity Commission under section 1451Sllb} of the Act.
Independent examinevs statement
I confirm that l am qualified lo undertake the examination because l am a member of the
Institute of Chartered Accounlanls in England and Wales, which is one of the listed bodies.
I have completed my examination. I can confirm that no material matters have come lo my
attention in connection with the examination giving me cause lo 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 records.. or
the accounts do not comply with the applicable requirements conorning the fomi and
content of accounts sel out in the Chartties (Accounts and Reports) Regulations 2008
other than any requirement that the accounts give 8 'true and fair, view which is not
matter considered as part of an independent examination.
I have no concerns and have come across no other matters in connection 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
Sllbury Court
420 Silbury Boulevard
Central Milton Keynes
MK9 2AF
Dato: 22 Deeèmbor 2023
Page 10

IT'S A PENALTY
STATEMENT OF FINANCIAL ACTIVITIES INCLUDING INCOME AND EXPENDITURE
ACCOUNT FOR THE YEAR ENDED 30 SEPTEMBER 2023
Un-
Restricted
General
Restrlcted
Total
Totsl
Notes
Funds
2023
2022
Income
Income from Generated
funds
Donations and grants
456,015
456,015
746,222
Total Incorne
456.015
456015
746 222
enditure
Charitable Activities
Expenditure on charitable
activities
462,627
462,627
566,078
Cost of Raislng funds
Expenditure on raising funds
131.789
other Expenditure
Support costs
24,309
24,309
25,681
Total expendituro
486,936
723.557
Net movement In funds
{30.9211
(30.9211
22,665
Balance at l October 2022
64.307
64,307
41,642
Balance at 30 Septemt)er
2023
33.386
33,386
64,307
All of the above results are derived from continuing aclivilies.
All gains and losses recognised in the period are included above.
The split of comparative fvnds is shown in rsote 13.
The notes on pages 13 to 19 form part of these financial stalemenls.
Pa9e11

IT'S A PENALTY
BALANCE SHEET AS AT 30 SEPTEM8ER 2023
NoteB
2023
2022
FSxod As$el$
Inlanglbla assels
Current Assets
D6bloTs
Cash al bank and in hond
41,579
75.723
41.579
75,723
Credltors,. amounts falllng due wlthln one ytrar
18.1931
111,416
Nel currenl assetB I Iliabilitles)
33.386
N•1 as¥•l8
33,386
64,307
Represtrnted by:
Unroslricled lunds
Reslricled Iijnds
ioiii
33.386
64.307
Totsi Charlty Funds
33.386
64,307
The finAn¢i81 slalemtsnls were approved by the Truste96 on
wer6 Signed on Iliaif behall by..
and
Tfu81eè
C McLellan
Th8 notes on p8ge8 13 10 19 fomi p8rt of Ih88e finÉncl•l slBlemonl8.
Pag• 12

ITS A PENALTY
FOR THE YEAR ENDED 30 SEPTEMBER 2023
NOTES TO THE FINANCIAL STATEMENTS
1. Accountlng policigs
Basls of Preparation
The financial statements have been prepared in accordance with Accounting and Reporting
by Charitses.. S18tement of Recommended Practice applicable to charities preparing their
accounts in accordance with the Financial Reportir¢g Standard applicable in the UK and
Republic of Ireland {FRS 102} (effective 1 January 20191- (Charities SORP {FRS 10211.
It's a Penalty meets the definition of a public benefit entity under FRS 102. A55els and
liabilities are initially recognised al historical cost or trar*saction value unless otherwise staled
in the relevant accounting policy nole{sl.
The Twslees 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
Donatlon¥ and Grants
Income from donations and grants is included in incoming resources when received. Incomè
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 pijrposes of the Charity are credited lo general
unreslricled funds. Donations for purposes reslricled by the wishes of the donor are taken lo
reslricled funds.
Inlar¢gible income in the fomi of valuable good or services donated to the Charity at some
actual expense lo the donor are included in the Statement of Financtal Activities when the
benefit is quantifiable and measurable.
Expendituro
Expenditure is included in the Slalement of Financial Activities on an accruals basis. inclusive
of any VAT which cannot be recovered.
Intangible Assets and Amortisation
Intsngible assets are staled al cost less accumulated amortisalion and any accumulated
impairment losses. Amortisalion is provided at rates calculated to write off the cost less
estimated residual value of each asset over ils expected useful life, as follows..
Website Development
3 yeaTS slraighl line
Page 13

IT'S A PENALTY
FOR THE YEAR ENDED 30 SEPTEMBER 2023
NOTES TO THE FINANCIAL STATEMENTS (Cont'd)
Fund accounting
General funds are unrestricted funds which are available for use al the discretion of the
Trltstees in furtherance 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 sel out in the notes lo the
financial statements.
Restricted funds comprise funds donated for speciffic putposes. The aim and use of each
fund is set out in the notes.
Dgbtors
Trade and other debtors are recognised at the settlement amount due after any trade
discount offered. Prepayments are valued al the amount prepaid net of any trade discounts
due.
Cash at bank and in hand
Cash at bank and ¢ash in hand includes cash and short temi 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.
Creditors and provislons
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
di￿O￿nts due.
Financial instrumgnts
The CIO onty has financial assets and financial liabilities of a kind that qualify as basic
financial instruments. Basic financial instruments are initially recognised al transaction value
and subsequenlly measured at their settlement value with the exception of bank loans which
are subsequently measured al amortised cost using the effective interest method.
Page 14

ITS A PENALTY
FOR THE YEAR ENDED 30 SEPTEMBER 2023
NOTES TO THE FINANCIAL STATEMENTS Icont'dl
1. Going concom
At the lime of approving the financial slatemenls. the Trustees have a reasonable
expectation that the CIO has adequate reSoU￿eS to continue in operational existence for
the foreseeable future. In making this assessment. the mitigating actions that can be
taken to control costs and the ability of the Charity lo borrow or fundraise for additional
funds, that the Charity has adequate resources to continue in operational existence for
the foresee8ble future. Thus the Trustees eonlinue tr) adopt the going concern basis of
accounting in preparing the financial st21ements.
2. Donations and grants
2023
2022
Inslitulional income
Trust income
Other income
327.783
300.058
18,000
428, 164
746,222
128 232
456,015
Unrestricted Income from donations and grants was £456.01512022.' £938,027} of which £Nil 12022..
£Nil} was reslricled.
Other income includes £128,232 12022.. £426,164) relating to donations in kind principalty provided
for professional services contributing lo advancing our advocacy agenda.
Included within inslitulional income is an amount of £nil 12022.. £nill relating to donatiLins in kind
recetved by the Charity.
3. Expendlture on charltable actfvltles
Unrestricted
Restrlcted
2023
2022
It's a Penalty Campalgn
Salaries & Nl
129,936
129,936
53,536
Consullanls
Design & Athvork
Website
Promots'on
Social Media Development
Filming & Production
Travel & Accommodation
Legal Expenses
100,564
4,050
3,144
50,108
77,617
9,850
21,156
100,564
4,050
3,144
50,108
77.617
9,850
21,156
129,175
17,084
3073
48.638
45,171
19,889
249 512
Totsl
462 627
462.627
566 078
Page 15

ITS A PENAL
FOR THE YEAR ENDED 30 SEPTEMBER 2023
NOTES TO THE FINANCIAL STATEMENTS Icont'dl
Expenditure includes £128,23212022.. £650,173) relats'ng to donations in kind for professional
services contributing to advancing our advocacy agenda.
4. Expendlture on ralslng funds
Unrestricted
Restrlcted
2023
2022
Advocacy Lobbying
Advocacy Fundraising
Printing
12.337
29,069
90,392
131,798
5. Other Expendlture
Unrestrlcted
Restricted
2023
2022
Support Cost$
Accountsncy
Travel & Refreshfnents
Other Costs
Governance costs
Independent Examinerfs Fee
10,000
6.146
5,383
10,000
6,146
5,383
9.000
8,211
5.870
2.780
25.661
6. Staff numbers and expense8
There was no Trustees. remuneration during the financial year arid trustee expenditure of £nil was
reimbursed12022.' £nill.
The average number of persons employed by the CIO during the year was..
2023
No.
2022
Average staff headcount
Staff costs (for the above persons)
Wages and salaries
Social security costs
Pension
116,875
8,680
4,416
129,971
75,000
4,605
Page 16

rr's A PENALTY
FOR THE YEAR ENDED 30 SEPTEMBER 2023
NOTES TO THE FINANCIAL STATEMENTS Icont'dl
One employee's emoluments exceeded £60,000 as disclosed below..
2023
2022
Salary
Social security costs
Pension
80,000
6,207
75,000
5,135
7. Intsngible Assets
Website
Total
Cost
Brought foTward
Additions
Carried forward
6.000
6,000
6.000
6,000
Arnortisation
Brought forward
Charge for the year
Carried forward
6,000
6,000
6,000
6,000
Carrylng value
At 30 September 2022
At 30 September 2023
8. Debtors
2023
2022
Trade Debtors
Accrued Income
Rent Deposrt
Total
9. Creditors: amounts falllng due wEthln one year
2023
2022
Trade Creditors
Taxation and Social Security
Accruals
Total
3,780
3,800
613
9.011
1,955
450
11,416
Page 17

Irs A PENALTY
FOR THE YEAR ENDED 30 SEPTEMBER 2023
NOTES TO THE FINANCIAL STATEMENTS {Cont'dl
10. Analysi$ of net assets between funds
Unrestricted
Funds
Restrlcted
Funds
Total
2023
Total
2022
Fund balances al 30 September
2023 are represented by..
Tangible fixed assets
Current assets
Creditors due within
one year
41.579
41,579
75,723
8,193
33,386
8,193
11.416
11. Analysis of charltable fund$
Un-
Rwstricted
Funds
Restricted
Funds
Total Funds
Brought fO￿ard at 30 September
2022
64,307
64,307
Income
456,015
456,015
Expenditure
1486,9361
1486,9361
Transfers
Balance at 30 September 2023
33,386
33,386
12. Related partles
It's a Penalty received £12,019 12022 - £12,000) in donations from Sysdoc Ltd in which K
Corich is a director.
Pago 18

IT'S A PENALTY
FOR THE YEAR ENDED 30 SEPTEMBER 2023
NOTES TO THE FINANCIAL STATEMENTS Icont'dl
13. Comparatlve funds
Un-
Rostricted
General
Restricted
Total
Funds
2022
Income
Income from Generated fund$
Donation5 and grants
746.222
746,222
Total Income
746,222
746,222
Ex
enditure
Charitable Activities
Expenditure on charitable
activities
566,078
566.078
Cost of Raising funds
Expenditure on raising fltnds
131.798
131,798
Other Expenditure
Support costs
25,681
25,681
Totsl expenditure
723,557
723.557
Transfer between funds
Net movement in fund5
22,665
22,665
Balance at l October 2021
41,642
41,642
Balance at 30 September 2022
Pagg 19