2024-09-30-accounts

REGISTERED COMPANY NUMBER.. 12123483 {England and Wales) REGISTERED CHARITY NUMBER: 1185872 Spotlight on Corruptlon Ltd Report of the Trustees and Unaudited Flnancial Statements for the Year Ended 30 Septembor 2024 Webb & Co Ltd Accountants and Busilless Advisers One New Street W611s Somerset BA5 2LA

Spotlight on Corruption Lid Contents of the Financial Statements for the year ended 30 September 2024 Pag8 Chalrman's Report Report of the Trustees Independent Examinerfs Report 10 Stat8m8nt of Flnancial Actlvltles Balance Sheet 12 to 13 Notes to the Flnanclal Statements 14 10 18 Detailed Statement of Financlal Actlvltles 19

Spotlight on Corruptlon Ltd Chairman's Report for the year ended 30 September 2024 Spotllght on Corruption Annual Report 2023124 The Iwslees, who are also the dlrectors for the Purposes of company law, present their report and tha unaudited financial statements of the charity for the year ended 30 Sept8mb8r 2024. Introductlon by thè Chalr and Executive Director Spotlight on Corruption provides a unique focus on how th8 UK enforces ils anti-cornjplion laws. We work to ensure the laws in place are lit for purpose. that they are proaclFvely enfor￿d, and Ihal they are complem8nled with robust adminislralive and regulatory systems across governmenl. OurAchlevements Spotlighvs financial year started with major pleces of legls121ion Coming onlo Ihg slatule books which contained provisions we had long advocated. The Economic Crime and Corporate Transparency Act 2023 fundamentally reshapes the UK'S corporate liability laws while the Procurement Act 2023 introduces a new debarment regime lo keep corrupt and fraudulent actors out of public procur&menl. We were dolighled lo See thes8 new tools introduced into the UK lo enhance enforcement against corruption and other economic crimes. The highlights of our work over the course of the year Include.. maklng enforcement a key government priorlty We researched and published 8 series of fouT reports on UK anli-corruption enforcement over th8 course of 2024, three of which were published in this financial year. These included a report on how the LIK could improve the enforcement of ils sanctions r8gim8, a r8POrt on aid-funded law enforcement to tackle ov8rseas corruption, a report on how to tackle the recruitment and retention crisis al the National Crime Agency which was covered on the front page of the Times, and a report on reinvesting more assals into law enforcement across the board. As th8 year came lo an end, the gov&Tnmenl announced significant new funding for Ihe UK'S aid-lunded enforcement unil. and has repsaledly sta16d that improving enforcernenl including for sancltons is a major priority. - some significant successes our legal work Our inlorvention in a Court of Appeal case brought by the World Uyghur Congress IWUCI againsl the Naliofjal Crime Agency for falling lo invesllgale alleged priKeeds of slave labour playe6 a significant role in the success of the case. We intervened because of the implications of the case for tha UK'S money laundering regime and the Court's ruling has s8t soma significant legal precedents lor how professionals should handle proce8ds of alleg6d crim8. and for when law enforcement are empowered to op8ri invesligalions. Our pioneering work on open justice in the courts maanwhile. including on challenging anonymlty orders granted lo those conneeled lo major corruption scandals. has also been particularly fruitful. We coordinated a suc￿Ssful challenge with media partners lo lift anonymity of former suspects and implicated individuals in a major bribery case, setting a groundbreaking pre￿dent. Just as the year came lo an end we had a very significant open justice win when a ￿vrt ruled that Spotitghl can publish Iranscripls and evidence from another major foreign brib8ry court case The case was significant becaus8 of allegations about government GompliGily in Ihe bribery. Medla and governmental Impact Spollighl has continued to be a go-to commentator on ￿rruptIOn and enforcement issues in Ihe UK. We were quoted or mentioned in over 200 media articles, and had three opinion pieces in national level newspapers over thè year. In parliament. our research was cited in 23 parliamentary debates and we submitted evidence lo 8 different Select or Bill Commillees, with this evidence cited in five committee reports, lellers or debates. Page 1

Spotlight on Corruption Ltd Chainnan's Report for the year ended 30 September 2024 Our reports have been widely read by policy-makers in government, with the minister responsible for the NCA being briefed directly on our report on Ihe agency's recruitment and retention crisis, and our Know Your Donor policy for political parties being particularly influenti21 in light of po18ntial 818cloral financ8 r8form. Looklng fonmard Thare are many opportunities in the coming y8ar to make good progress on our goals. The Government's ngw Anti-corruplion Champion is leading the developmenl of a new Anli-corruplion Strategy, due to be published in 2025. There is increased political will lo lackle corruption, with the Foreign Secretary 8nnouncÉng that tackling dirty money is a personal campaign priority, and enhanced coordination between three different government departments. This year will see a real focus on integrity in procurement, with the devek)pment of a new procurement stralegy, the delayed implementation of the Procurement Act and the COVID-19 inquiry. These will all provide major opportunili&s lo increase anti•corruplion and integrity checks in UK procur8m8nl. They will also provide an opportunity to highlight the importanc8 of tackling domestic corruption in the UK. and partScularly the need for changes ID the UK'S current laws on corruption in public officè. Meanwhile, there is growing momentum for how the UK tackles prof&ssionals who willingly or unwillingly help corrupt actors 18under funds. With the government starting lo prepare for a visit from the global anli-money laundering walchdog, FATF. in 2027. and a major intervention due on legal ethics in early 2025 from a legal ethics taskforce, there is real scope for a much more ambitious approach to the UK'S regime for money laundering supervision. Driving forward gre8ler ambition will be particularly crucial as the government prepares lo announce reforms to the AML supervisory regime. There is also potential for more focus on how senior exècutives are held lo account for money laundering and whether stronger rule8 and leglslalion is needed to slop professionals from handling kleptocratic assets. In keeping with our strong collaborative alhos, we will continue lo work in coordination with our civil soci8ty partners, and engage exlen5ively with a wide range of stakeholders, to drive fO￿ard ambitious action lo end the UK'S role as a hub for dirty money and to ensure we get our own house in order. Oryanisalionally. we will need to continue our focus on expanding our funding bas@ and ensuring sustainable growth. We will also continue to develop best practic& with our policies, particularly in relation to diverslly, equity and inclusion. Finally, it will be critical over the next year to ensure Ihal our staff are able to vnanage what remains a very busy workload and lo carry on le81ing fully valued and rewarded. Lloydette 8al-Marrow Chair Susan Hawley Executive Director Page 2

Spotllght on Corruptlon Ltd Report of the Trustees for the year ended 30 September 2024 The Irustees who are also directors of Ihe charily for the purposes of the Companies Act 2006, pres8nl their report with the finanGlal statements of the Gharily for the year ended 30 September 2024. The trustees have adopted the provisions of Accounting and Reportlng by Charities.. Statement of Recommended Practice applicable lo charilies preparing their accounts in accordance with the Financial Reporling Standard appllcable In the UK and Republic of Ireland {FRS 1021 leffeclive 1 January 2019). VISION, MISSION. OBJECTIVES AND ACTIVITIES Our ￿5[on We want lo see 8 society with slrong, Iransparenl and a¢Gounlable Institutions which ensura corruption is not loleraled and democracy flourishes bolh in the UK and globally. To achieve this we highlight corruption and the harm il causes, and campaign lo improve the UK'S legal systems and enforcetnenl of the law. Our mission Spollighl on Corruption shines a light on the UK'S rol& in corruption at home and abroad. Our Charltable objects Spotlight on Corrupllon's objects for the public banefil are- To prevent and relleve poverty in arby part of the wortd caused directly or indirectly by corruption., To foster wmpliance with the law and the production of ethical code5 of conduct by governmental. industrial, commercial, voluntary sector and commercial bodies- To promot8 the sound administration of the law in the f181d of anli-corruplion. Including IwÉlhout limitation) by: The promotion and understanding of measures lo reduce and eliminate corruption., The giving to legislative and public bodies and others. information and advice and assi81ance in relation lo the reduction and elimination of corrupllon and effective means lo achieve this,. The promotion, undertaking or commissioning of research concerning effective means lo achieve compliance with the law to promote ethical standards of condycl by governmental. industrial, commercial, voluntary sgclor and professional bodies. Ourwork Our work seeks to address the role corruption plays a8 a root cause in driving glob81 poverty, impeding development, and undermlning democracy, institutions and good governance. work involves- Tracking the implemenlalion and enforG8menl of the UK'S anli-corruplion laws lo ensure that they are deterring and preventing corruption. Urbdertaklng detailed, evidenca-based and impactful research on the imp18mentalion and enforcement of the UK'S anti-corruplion laws and policy, looking for ways in which they can be improved,. Exploring the role that strategic litigation can play in improving anti-corwption enforcement outcomes. Over the past year, Spotlight on Corruplian has und&rtaken the following activilles towards our long-term goals. Page 3

Spotlight on Corruption Ltd Report of the Trustees for the year ended 30 September2024 Long-lerm 9￿1 #1.. The UK has a robust legislatlvo and regulatory framework for prosecutlng and sanctioning corruptlon and financial crlme Senior exaculiv6 accaunlabili In January 2024, we published an in-depth report on senior executive accountability for economic crime irb the UK, which was launched al a well attended event in Parliament with the Inslilule of Directors and Lord Tyrie. The report was covered by City AM and a wide range of legal comm8nlalDrs. and we also had a comment piece in the FT about our findings. Professional enablers The role of professional enablers of economic crfme and kleptocracy has b6come a particular policy focus over the past year. We fed into the govarnmenl's new cross-syslem professional 8nablers strategy, launched in early 2024, and engaged with the Legal Services Board consullalion on the new statutory objective for legal sector regulators lo prevent economic crime. Having referred several dossiers on lawyers and law fimis lo legal sector regulators, we also closely monitored enforcement by legal seclor regulators, and published detailed analysis on these c3S8S. Working closely with civil society colleagues, we developed a coordinated approach to s8ek ambilloLJS reform lo the UK'S Anli-money Laundering regime. We also work6d with investigative joumalisls from Al Jazeera looking al the professional enablers involved in handling suspiciou8 funds from Bangladesh, and coordinated work to encourage the UK government to act swiflly lo identify, selze and return assets slolon from the peop12 of Bangladesh, and urge UK regulators lo investigate those engaged in facilitating suspect funds arriving in the UK. Thls year our Executive Director was a member of a high-protile taskforce considering the ethics of UK firms providlng civil legal seNices to kleplocrals and oligarchs. We also encouragsd political parties to adopt ambitious proposals on tackling dirty money and money laundering in light of the general eleGlion, producing background briefings and policy input to shape their policies in this area. Long-term g031 #2.. The UK has more proactive, properly resourced, transparent and effective enforcèment of its anti-corruptlon laws Enforcement During 2024, we published a series of major reports on the slate of enforcement, consolidating our strong reputation for specialist expertise in Ihls area. These included reports with a focus on enforcement in relation lo sanctions and inlemallonal corruption, and detailed report8 on issues impeding enforcement al the National Crime Agency, and rllaking the case for more reinveslmenl of assets back into enforcement bodies. Major cases that we have monitored and provided analysis of over the past year include a long-running bribery trial involving a UK-Saudi am)s deal, tha first-ever UK prosecution of a foreign politically exposed person for soliciting a bribe, the corruption trial re12ting lo Mozambiqua's 'luna bond, scandal, and the UK'S first forfeiture of sanctioned RussSan funds. We also fed into major policy debates about how lo improve enforcement outcomes, from the Independenl review of the disclosure regime lo a consullalion on cost protections for law enforcement. Page 4

Spotllght on Corruptlon Ltd Report of the Trustees for the year ended 30 September 2024 en Jijstice We have been an open justice pioneer through our court monitoring programme, setting up a calendar of court dales, challenging anonymity orders, and maintaining pressur8 for greater access lo court information. This included a submission to a judicial consullalion on public access to court documents and our coordination of a leller to the Lady Chief Justic8 raising COn￿mS about the government's new open justice guidance, as well as our ongoing advoc2cy as a founding member of tha Courts and Tribunals ObseNers Network. We have also highlighted Ihe grave risks of corruplion c8S8s being withheld from public scrutiny through cFosed arbilralion proceedlngs. Victims of corru tion And we continued lo highlight the need for victim compensation for communities and co¢JnlNes affected by co￿uption in a number of high-profile cases, collaboraling with global South partners on joint advocacy and calling for reform5 to ensure ViGlims are properly compensated and assets are returned. This included working with Parliamentarian5 to highlight Iha noed for reform in the context of the Victims Bill, and an op-ed in CityAM coinciding with Global Anll-corruplion Day. Long-term goal #3: The UK governments puts in place stronger anti*orruptlon systams to tackl8 corruptlon at home and abroad Political inle We encouraged political partie5 to adopt ambitious proposals to strengthen political integrity over the year, particularly in light of the general election. This included encouraging proactive use of the new debam)ent regime lo protect public spending, and commitments lo significanlly upgrade how standards in public life are regulated. W& published a series of papers about the need to improve r8gulalion of public standards irb the UK to inform public and political debate. This included joint bri8fings with civil society partners, as well as Spollighl papers and commentary on progress made on reforms recommended by ind8pendenl bodies, and how lo improve regulation in this area. We also started a major new body of work around lobbying, policy capture and unequal access lo economic decision-makers. Spollighl and a coalition of other experts were accepted as a Cora Participant for the procurement module of the Covid-19 Inquiry, where we are raising key weaknesses in the UK'S regime for tsckling conflicts of ir>lerest, and in domestic legislative provisions for tackling corruption. And we undertook exlerbsive work on the need for political finance reform, including producing and coordinating briefings Iwrillen and through a roundlablel for policy rnakers and the public on the need for major reforms and the risks of dirty money in political finance. We also submllled evidence lo inquiries, and 8ngaged in corresponden¢8 with tha National Crime Agency about enforcement gaps. Our work on risks of dirty money in political fin8nc8 helped lo secure two 'molions of regret, in the House of Lords - relating lo tha independence of the Elector81 Commission and increased dirty money risks. Sanctions We closely monitored key sanclions-relaled cases in the courts, induding sanctions evasion cases, and the first legal challenges lo sanctions imposed after Russia's Invaslon of Ukraine. We submilt8d evidence to several parliamentary inquiries, where our 8n8lysis was clled, and co-hosted a roundlable discussion with the APPG on Anli-corruption and Responsible Tax on sanctions enforcement with key govemmenl offlcials. parliamentarians, private sector figures and civil society- Our advocacy during this lime to Impose a duty on sanctioned individuals to disclose Ihelr UK-bas8d assets lad lo a change in legislation to this effect. We also provided policy briefings for parllamenlarians. and policy makers about how lo improve enforcement for sanctions alongside a detailed report that we produced during the year outlining the UK'S record on sanctions enforcemerJl. Page 5

Spotlight on Corruptlon Ltd Report of the Trustees for the yearended 30 September 2024 PUBLIC BENEFIT The b8nefici8ries of our work are the victims of corruption in the UK and overseas and all those who will benefit from hlgher ethical standards of conduct in govemmenl and compliance with th6 law by the private sector. 11 includes ordinary citizens and voters, who are disadvantaged by governments mi5allocaling public money as a resLJII of corruption and who will benefi't from the improved functioning of democracy that results from strong anli-corruplion systems and robust instilulions. 11 also inciudes businesses who are d8nied a level playing field by unf8lr praelices that result from corruption. Stronger enforcement of UK anti-corruplion laws and higher anli-corruption standards in UK loreign policy and export support benefits victims of corruption and the public of countries affacted by corwplion by leading to.. greater transparency about Ihe idenlily of corrupt actors and the nature of their corruption to enable greater accounlabilily., Increased confiscation of corrupt assets which can ba returned lo affected countries through development projects., potential compensation throLrgh the courts in the 8v8nt of conviction which can likewise be returned lo affected countries., and strong social condemnation of and stronger procedures lo prevent bribery and corruption. Our work benefits the wider public in the UK by providing expert and insighfful analysis about how anti-corruption laws are being enforced and anli-corruption standards maintained, including through our website, Twiller account and media engagement. Our work on improving integrity and anli-corruplion measur8s in procurem8nl benefits the public in the UK through providing solulians for how lo improve public trust in government and in public contracting and ensure greater value for mon8y in government spending. Our board has taken into account the Commission's guidance on public benefit guidance when making relevant decisions. MONITORING AND EVALUATION During this year, Spollighl continued to ulilise our irblern81 monllorlng tool to assess our impact. We log on a weekly basis our achievements and significant oulpulg, and are beginning lo conduct more regular deep-dive reviews evalualir¢g which sorts of Inlervenlions have the most impact, and why. In particular we have started lo track more closely how we keep on track with our commitments under the Annual Plan and other grant commllmenls. Durlng 2023-24, we did change some of the action points we had erkvisaged in our Annual Plan, as the external context changed, or as new evidence emerged whlch led us lo reassess what would be the most valuable avenue for research and impact. For instance. rather than doing a raport providing a 'lwo years on, Ovgrview of enf0￿ment funding gaps we decided to focus on the NCA as a key agency for delivering anli-corruplion and illicit finance enforcement, as well as on aid funded enforcement. Similady, instead of doing a report on the licencing regim8 in relation lo sanctions, we did a report on sanctions enforcement instead. Some action points we were not able to deliver due lo capacity constralnls, largely arising from the shtfting context brought about by an election year. In other areas we made gignificanl progress on winning the argument with a large mnge of stskeholders on board for a partiCLJlar reform, but no formal government decision was taken due policy upheaval in an eleclion year. We are commilled lo being a learning organisalion, and looking at new ways lo ensure we have a continuous process of evaluation as part of how we develop strategy and deliver our work plans. Wllh a new finance and operations manager on board we have beeTI able to vastly improve our organisalional systems lo help us keep track of commilmenls, evaluate our work, and overall be more efficient and productive. During the delivery of our Annual Plan w8 have 18arn8d that well-evidenced research produced at the rfghl tim8, and maximising political opportunities for r8form are crucial lo enhancing impact. Page 6

Spotlight on Corruption Ltd Report of the Trustees for the year ended 30 September 2024 FACTORS AFFECTING ACHIEVEMENT OF OBJECTIVES As a small team with growing external domands on our lime, managing urgent response lo events and media driven opportunities alongside delivering long-lerm priorities is always a challenge. An uncertain funding environment has also meant considerable time investment by staff lo fundraising, given Spotlight's lack of dedicated fundraising capacity, 2nd also to delivering on short-tem) grant commitments. Political will is a critical factor in achieving our objeclives. While there has been exceptionally strong F)olilical will in certain areas (particularly tackling dirty money as it relates lo Russia and hostile stal8sl, in olhar areas, such as integrity in public life il has be8n much more difficult lo make progress. FUTURE PLANS- THE YEAR FROM OCTOBER 2024 As we deliver our Annual Plan for 24125, we are seeking lo streamline our work into thr8e campaign areas to give greater el8rily about our work, and help lo prioritise our workload. Our overall goals remain the same as they reflect our three year strategy. Over the course of th8 year we will be developing a new 3-5 year strategy, and conducting external stakeholder and inlemal strategic processes to have this in place for the next financial year. Al an organisational level, w6 will build on improvements made this year lo systems and processes, and further develop how we can work m051 efficiently and productively as a team. We will continue lo actively promote and encourage professional development and training. We will embed our diversity. equity and inclusion policy across all our woik, and w8 will continue work on enhancing Spollighl's financial suslainabilily, seeking out new opportuni118s for grants and donations. FINANCIAL REVIEW This has been a year of financial stability and sustainable growth at Spotlight. Overall income this year lotalled £583,927 and we brought forward £353.851 from gran15 awarded in previous years. Sums brought forwar(i included £252.129 from a Ihre8-year grant awarded by Open Society Foundations IOSFI in FY 2021-22 and generolfsly provided in full al tha outset of the grant perFod. The majority of our income this year came in the farm of grant funding, and we also received £10,988 in donations from individuals. As In previous years, in FY 2D23-24 Spollighl had good cash flow and financial security, with growth in expenditure of 28/0 to £489,851. This r8ne¢led the addition to the team of a new Senior Grants and Operations Manager, and a new Legal Researcher who joined on a one year contract. We also continued our use of consultants contributing lo research and business support and increased our expenditure on communications, advocacy and fundraiging. Overall, the Charity ended the year with funds of £447,927, of which £99,308 represents the balance of the OSF fundlng whlch covered three years. A further £163,186 represents Iwo new OSF grants awarded during this year and generously provided in full al the outsel. of which £62,344 will be sub.granled to the International Lawyerfs Project for work on sanctions that we are conductlng in partnership with them. We continue lo be mindful that in order to sustain the achievements of this year, we sh211 need lo continue lo secure subslanlial new funding in fu1U￿ years. Page 7

Spotlight on Corruption Ltd Report of the Trustees for the year ended 30 September 2024 We ar8 exlremgly grateful lo our funders during this period.. The David and Elaine Potter Foundation The Joffe Charitable Trust John Ellerman Foundation The Foreign Policy Centre Isub-grant on behalf of the Joffe Charitable Trust) The Frlends Provlilent Charitable Foundation The Joseph Rowntrae Charitablè Trust (JRCT) JRSST Charltable Trust IJRSST-CTI Luminate Foundation Open Society Foundatlons IOSFI REDRESS Isub-grant on behalf of Open Society Foundatlonsl Transparency Intemational SeGretariat ($ub.grant on behalf of the Global Anti-corruptlon Consortium) Further delalls of the grants are provided In Note 12. RESERVES POLICY The Charity has revlewed ils requirements for reserves from unreslricled income lo be primarily for the following reasons.. delays in funding or urbforeseen lerminalions,- cash flow variations. As a result of the review. Spotlight'5 policy Is to hold reserves equating lo at least three months of operating costs. Vvilh unrestrlcted funds of £262,266 carried fo￿ard, Ihis requiromenl was m8t. RISK MANAGEMENT The Trustees have conducted a review of the major risks lo which the charity is exposed and has a regularly pdaled risk register. The risk register is reviewed al each Board meeting. Where appropiiate. systems ar procedures have been identified to mitigate the risks that the charity faces. SMALL COMPANY PROVISIONS This report has been prepared in accordance with the provisions applicable lo companies enlllled to the sm811 companies exemption. STRUCTURE, GOVERNANCE AND MANAGEMENT In earty 2024, after advertising th6 roles and conducting an interview process. Spolllghl was delighted lo recruit Nvo new Trustaes. Spollighl is now oov6med by seven Trustees. with Lloydelle Mai-Barrow as Chair and Angus Brown as Treasurer. Th& Board is supportad by a Finance and Operallons Commlllee which oversees the flnances of the organisalion. drawing upon trustees with very significant expertise and experiernce in finanoial managemenl alld govemance. Board meetings take pla￿ three times a year, with Finance and Operations Commillee meolings taklng place ahead ol the Board meetings. The Board approves Spollighl's Annual Plan in Seplember ahead of each year, monilors ils implementation in February, and receives a final repori on aGlivilies and progress on objectives in the summer. In 2024, as part of an ongoing commitment lo strong governance, the Board approved a number of new policies including Social Media. Cyber Security, Donations Due Diligence, Carer's Leave and Dependanls Leave, as well as Gonlinuing lo review existing policies. The Execulwe Direclor is supported by a Senior Management Team, and an Advisory Board of widely respected pmfessionals from the sector. In the previou5 financial year, we und8rtook a racruitment for a new Senior Grants and Operations Manager, who started work in October 2023 and has enabled us lo ramp up our finance and operations work, bringing greater efficiency and suslainabilily lo the organisalion. Page 8

Spotllght on Corruptlon Ltd Report of the Trustefrs for the year ended 30 September 2024 STRUCTURE. GOVERNANCE AND MANAGEMENT REFERENCE AND ADMINISTRATIVE DETAILS Registered Company number 12123483 (England and Wales) Reglstered Charlty number 1185872 Reglstered offSce 82 Tanner Streel London SE13GN Trustees Ms L Bai-marrow {Chairl Mr A Brown (Treasurer) Mr J Dale Mr S Eastwood Ms C Stewart MS M M Davles (appointed 713120241 hAr S P Holland (appolnted 713120241 Independent Examiner Webb & Co Ltd Accounlanls and Business Advisers One New Streel Wells Somersel BA5 2LA Banks Triodos Bank Deanery Road Bristol BS1 SAS CCLA Investment Management 1 Angel Lane London EC4R 3AB Senlor Management Team Dr Susan Hawley Mr George Havenhand Dr Helen Taylor Ms Kathryn Busby (Executive Diroclor) (Senior Legal Rese8rcherl (Senior Legal Researcher) (Senior Finance and Operations M8nagerl Approvad by ord8r of the board of trustees on 5 February 2025 and signed on its behalf by.. s L Bai-Marrow- Trustee Page g

Independent Examlner'5 Report to the Trust88s of Spotlighl on Corruption Ltd Independent examlnevs report to the trustees of Spotlight on Corruption Ltd I'the Company.) report lo the charity trustees on my examination of the accounts of the Company for the year ended 30 September 2024. Responslbllltles and basis of report As the charity's trustees of the Company land also ils directors for the purposes of comp8ny18wI you are responsible for the preparalior¢ or the accounts in accordance with the requirements of the Companies Act 2006 ('Ihe 2006 Acl'l. Having satisfied myself that the accounts of th8 Company are not required lo be audited under Part 16 of the 2006 Act and are eligible for independent examination, I report in respect of my examinalior¢ of your charit￿5 accounts as carried out under Section 145 of the Charities Act 2011 {'Ihe 2011 Acl'l. In carrying out my examination I have follow8d the Directions given by the Charity Commission under Section 14515) Ib) of the 2011 Act. Independent examiner's statement Since your charity's gross income exceeded £250.000 your examiner must be a member of a listed body. I Can confirm that l am qualified to undertake the examination becaus8 18m a member of the Inslilule of Chartered Accounlanls in England and Wales, which is one of the listed bodies. I have completed my examination. I corbfirm that no ma119rs have come to my attention in connection with the 6xaminalion givlng me cause to believe: accounting records were not kept in respect of the Company as required by Section 386 of the 2006 Act., or the accounts do nol accord with those records,. or the accounts do not comply with the 8ccounling requirements of Section 396 01 the 2006 Act other than any requirement that the accounts give a true and fair view which is not a maller Gonsidered as part of an independent examination,. or the accounts have not been prepared in accordance with the methods and principles of the Stal8m8nt of Recommended Practice for accounting and reporting by charities (applicable lo charities preparing their accounts in accordance with the Financial Reportlng Standard applicable in the UK and Republic of Ireland IFRS 1021). I have no COn￿rnS and have come across no other mallers in connection with the examination lo which allenlion should be drawn in this report in ordeT to enable a proper understanding of the accounts to be reached. Barry Davidson Webb & Co Ltd Accounlanls and Business Advisers One New Str881 Wells Somerset BA5 2LA Dale.. Page 10

Spotlight on Corruption Ltd Statement of Financial Activltigs for the year ended 30 September 2024 2024 Total funds 2023 Total funds Unrestrlcted Restrlcted fund fund Notes INCOME AND ENDOWMENTS FROM Grant income 266.814 303.847 570,661 288,794 Investment income Other Income 12,787 479 12,787 479 5,294 335 Total 280,080 303,847 583,927 294,423 EXPENDITURE ON Charitable activities Direct charitable activities and support costs 252,751 237,100 489,851 381.382 NET INCOMEIIEXPENDITUREI 27,329 66.747 94.076 186.959) RECONCILIATION OF FUNDS Total funds brought forward 234,937 118,914 353,851 440,810 TOTAL FUNDS CARRIED FORWARD 262,266 185,661 447.927 353,851 The notes form part of these financial statements Page 11

Spotlight on Corruption Ltd Balanca Sheet 30 September 2024 2024 Total funds 2023 Total funds Unrestricted Restrlcted fund fund Notes CURRENT ASSETS Debtors Cash at bank 1,346 271,324 1,346 456,985 1,488 363.522 185,661 272,670 185,661 458.331 365.010 CREDITORS Amounts falling dLte within ona year (10,404) (10,404 (11,159) NET CURRENT ASSETS 262,266 185,661 447,927 353,851 TOTAL ASSETS LESS CURRENT LIABILITIES 262,266 185,661 447,927 353.851 NET ASSETS 262,266 185,661 447,927 353.851 FUNDS Unrestricted funds Restricted funds 10 262,266 185,661 234,937 118,914 TOTAL FUNDS 447,927 353,851 The charitable company is enlilled lo exemption from audit under Sectlon 477 of the Companies Act 2006 for the yaar ended 30 Seplernber 2024. The membeTS have not required the company lo obtain an audit of its financial slalements for the year ended 30 September 2024 in accordance with Section 476 of the Companies Act 2006. The IrLFsle@S 3cknow18dge their responsibilities for (al ensuring that the oharilable company keeps accounting record5 that Gomply wilh Sections 386 and 387 of the Companies Act 2006 and Ib) preparing financial slalemenls which give a true and fair view of the slate of affairs ol the charitable company as al the end of each financial year and of its surplus or deficit for 6ach financial year in accordance with the requirements of Sections 394 and 395 and which otherwise comply with the requirements of the Companies Act 2006 relating to financial slalemenls. so far as applicable lo the charitable company. The notes form part of Ihese financial statements Page 12 continued.

Spotlight on Corruption Ltd Balance Sheet . contlnued 30 September 2024 These financial statements have been prepared in accordanTr with the provisions applicable lo charitable companies subject lo the small companies regime. The financial statements were approved by the Board of Trustees and authorised for issue on 5 February 2025 and wtsre signed on its behalf by.. Mr A Brown - Trustee Ms L B8i-Marrow- Trustee The notes fomi part of these financial slalemenls Page 13

Spotllght on Corruption Ltd Notes to the Flnancial Statement5 for the year ended 30 Sèptember 2024 ACCOUNTING POLICIES Bas1$ of preparing the financlal statements The financial slalements of the charitable company. which is a public benefit enlily under FRS 102, have been prepared in accordance with the Charities SORP IFRS 1021 'Accounllng and Reporting by Charities.. Slalemenl of Recommended Practice applicable to charities preparing their accounts in accordance with the Financlal Reporting Standard applicable in the UK and Republic of Ireland IFRS 1021 leffeclive 1 January 20191,, Financial Reporting Standard 102 'The Financial Reporting Standard applicable in the UK and Republic of Ireland. and the Companies Act 2006. The financial statements have been prepared under the historical cost convention. Flnanclal reportlng standard 102 - reduced disclosure exemptions The charitable company has taken advantage of the following disclosure exemption in preparing these financial slalemenls, as permilled by FRS 102 'The Financial Reporting Standard applicable in the UK and Republi¢ of Ireland,: the requiremtsnls of Section 7 Slalemenl of Cash Flows. Income All income is recognised in the Statement of Finanual Activities once the charily has enlillemenl to tha funds, il is probable that the income will be re￿iVed and the amount can be measured reliably. Expendlture Liabilities are recognised as expenditure as soon as there is a legal or conslruclive obligatio commilling the charity lo that expenditure, it is probable that a transfer of economic benefi15 will be required in selllemenl and the amount of th6 obligation can be measured reliably. Expenditure is accounted for on an accDJals basi5 and ha5 been classified under headings that aggregate all cost relaled lo the category. Where costs cannot be directly atlribuled to particular headings they have been allocated to activities on a basis consistent with the use of resources. Taxation The charity is exempl from corporation lax on its charitable activities. Fund accounting Unrestricted funds can be used in accordance with the charitable objectives at the discretion of the Iruslees. Restricted funds can only be used for particular reslricled purposes within the objects of the ¢har¢ly. Reslriclions arise when specified by the donor or when funds are raised for particular reslricled purposes. Further explanation of tho nature and purpose of each fund is included in the notes lo the financlal st8temenls. Penslon costs ahd other post-retirement benefits The charitable company operates a defined contribution pension scheme. Contributions payable lo the charitable company's pension scheme are charged lo the Stslement of Financial AclFvilies in the period lo which they relate. Page 14 continued...

Spotllght on Corruption Ltd Notes to the Financlal Statements - continued for the year ended 30 September 2024 GRANT INCOME 2024 2023 Donations Grants receivable Fund for Policy Reform - Contract funding OSI - Contract funding 10,988 559,673 276,494 8,400 3,900 570,661 288.794 INVESTMENT INCOME 2024 2023 Deposil ac￿￿nt inl8resl 12,787 5,294 CHARITABLE ACTIVITIES COSTS Support costs (see note 51 Dlrect Costs Total8 Direct charitable aclivilles and support costs 487,563 2,288 489,851 SUPPORT COSTS Goveman¢e Costs 2024 2023 Independent examiners fees Finance charges 2,450 10 1,973 2,460 1,982 TRUSTEES. REMUNERATION AND BENEFITS There were no trustees, remuneralionlother benefits for th8 year ended 30 September 2024 nor for the year ended 30 September 2023. Trustees. expense5 During the year ended 30 September 2024 a total of £129.20 was reimbursed to one trustee for travel cost5. Page 15 eonlinued...

Spotlight on Corruption Ltd Notss to the Financial Statements - continued for the year ended 30 September 2024 STAFF COSTS 2024 2023 Wages and salarles Social security costs Olh6r pension costs 319,589 30,340 7,819 222,402 19,372 5.529 357,748 247,303 The average monthly number of empk)yees during the year was as follows.. 2024 2023 Staff The number of employees whose empkjyee benefits (excludlng employer pension costs) exceeded £60,000 was.. 2024 2023 £60,001- £70,000 DEBTORS: AMOUNTS FALLING DUE WITHIN ONE YEAR 2024 2023 Accrued income 1,346 1,488 CREDITORS: AMOUNTS FALLING DUE WITHIN ONE YEAR 2024 2023 Social s8curily and oth6r taxes Accrued expenses 3,534 6,870 2,133 9,026 10,404 11,159 10. MOVEMENT IN FUNDS Net movement In funds At 1110123 At 3019124 Unrestricted funds General fund 234,937 27,329 262,266 Restrlcted tunds Reslricled Fund 118,914 66.747 185,661 TOTAL FUNDS 353,851 94,076 447,927 Page 16 continued...

Spotllght on Corruption Ltd Notes to the Financial Statements - continued for the year ended 30 September 2024 10. MOVEMENT IN FUNDS- contlnued Nel movement in funds, included in tho above are as follows.. Incomlng resources Resources Movement expended n funds Unrestrlcted funds General fund 280,080 (252,751) 27,329 Restrlcted funds Reslricled Fund 303,847 (237,1001 66,747 TOTAL FUNDS 583,927 (489,8511 94.076 Comparatives for movemant in funds Net movement in funds At 1110122 At 3019123 Unrestricted funds General fund 175,505 59,432 234,937 Restricted funds Restricted Fund 265,305 1146,3911 118,914 TOTAL FUNDS 440,810 186.9591 353,851 Comparative nel movemenl in funds, included in the above are as follows.. Incomlng resources Resources Movement expended In funds Unrestrlcted funds Genaral fund 242,465 {183,033) 59.432 Restrlcted funds Restricted Fund 51,958 1198,3491 1146,391) TOTAL FUNDS 294,423 1381,3821 186,959) Page 17 continued...

Spotlight on Corruptlon Ltd Notes to the Flnancial Statements - continued for the year ended 30 September 2024 11. RELATED PARTY DISCLOSURES There were no related party transactiOFFS for the year ended 30 September 2024. 12. ANALYSIS OF CHARITABLE FUNDS Blhvd Income Expendlture l￿d Joseph Rownlree Charitable Trust Joffa Charitable Trust David and Elaine Poller Foundation John Ellerman Foundation OSF via REDRESS JRSST Charitable Trust OSF UK AML Campaign Luminale Foundation OSF Sanctions Friends Provident Charllable Foundation Joffe Charitable Trust via Foruign Policy Centre Global Anli-corruplion Consortlum via Transparency Inlernalional Secretariat OSF UK AML Campaig Isupplemenlal grant) Gen8ral Income 55,000 107,295 31,000 155,0001 145,0001 126,667) (20,0001 (39,2051 118,917) 1152.821 J {56,4951 (1,2361 18,750 22,667 20,000 319 1,417 252,129 32,940 81,045 27,000 38.886 17,500 99,308 38,976 109,992 62,531 111,228 23,478 (15,241) 8,237 2.500 11141 2,386 29,491 {27,3851 2,106 80,764 24,254 (27,570) {4,200) 53,194 25,683 5,629 Total 353,851 583.927 (489,8511 447.927 Page 18