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..
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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
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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
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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
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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.
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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.
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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
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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)
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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
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