Webb & Company ACCOUNTANTS AND BUSINESS ADVISERS
Financial Statements
REGISTERED COMPANY NUMBER: 12123483 (England and Wales) REGISTERED CHARITY NUMBER.. 1185872 Spotlight on Corruptlon Ltd Report of the Trustges and Unaudited FlnanGial Statements for the Year Ended 30 September 2025 Webb & Co Ltd A¢counlanls and Business Advisols One New Street Wells Sornersel BA5 2LA
Spotlight on Corruption Ltd Contents of tho Flnan¢lal Statsments for the year ended 30 September 2025 Page Chalmian's R8POrt Report of the Trustees Indgpondont Examiner's Report io Statement of Flnanclal Activities Balance Sheet 12 10 13 Notes to thg Flnanclal Statements 14 10 18 Detsilad Statement of Financial Activitias 19
Spotlight on Corruption Lld Chalrman's Report for thè year ended 30 Septembér 2025 Spotllght on Corruption Annual Report 2024125 The trustees, who are also the directors for the purposes of company law, present their report and the unaudited financial slalemenls of the charity for the year ended 30 September 2025. Introductlon by the Chalr and Executive Director Spollighl on Corruption provides a unique focus on how the UK enfoTces rts anli-corruption laws. Vve work to ensure the laws in pl8ce are fil for purpose, that they are proaclwely enforced, and that they are complemented wlh robust adminislralive and regulalory systems acr()ss govemmenl. OurAchlèvem8nts This last year has been another busy year as we have sought lo maximise key opportunities for refoTm lo ensure that the UK is a global leader on tackling corruption and dirty money. Given the global and domestic political context, we have made good progress. This is despite strong global he8dwinds against the anli-corruplion agenda - from geopolitical pressures. lo the rise of populist politics, and a new focus on deregulation. Despite these headwinds we were particularly pleased with Spollighvs contribution towards.. - The announcennI of 8 dirty mon8y Summit organised by the Foreign. Commonwealth and Development Offic& for 2026", - The developrnenl of a new Anti-corruplion Strategy published at the end of 2025, overseen by the anli-coriuplion Champion., Uplrfts in resourcing for anli-corruplion units in the poli as well as the inlroduclion in legislation of costs protection for law enforcement bodies when recovering assets of wealthy criminals., Thè announcemènt of a major overhaul of how the legal and aecountancy sectors will be regulated for anli-money laundering., The launch of a new Ethics and Integrity Commission - a proposal that we developed as a response to ongoing crises in trust in politicians- and the introduction of a new slalulory misconduct in public olfi¢e offence- something w8 Campaigned for., Govèrnment commilmènls lo strengthen political finance rules and in particular introduce Know Your Donor rules for political parties, Organisational dèvglopm&nt DLFring the year we developed a new Ihree-year strategy for 202&2028, which included refreshed theories of change, mission, vision and values. We also added additional capacity lo oijr team of staff, increasing research capacity for ou¥ Ending Impunity work and launching a new Legal Fellowship. Our staff survey results show high salislaclion with working al Spollighl on CDrrupliDn, and we Continue lo priorilise retaining key talent, including through offering professional development and training, and a nine-day lortnighl working pallern. We also Continue lo develop our organis8tional policies lo provide a safe working enviionmenl, and sel clear expectatnS of. staff. Page 1
Spotlight on Corruption Ltd Chairman's Report for the yèar ended 30 September 2025 Looklng forward The coming year will see the implemenlalK)n of the government's new Anti-corruplton Strategy and the development of a new Anti-money Laundering and Ass&1 Recovery Strategy. 11 will also see increased UK global leadership on corruption as the governrnenl prepares lo host an Illicit Finance Summit in London. These are Crucial opportunities lo ensure that the UK develops robust anli-corruplion measures at home. and lakus a global leadership role in fighting coriuplion and defending deMracY. Organisalionally, a new fundraiser will start this year lo help us expand our funding base and ensure sustainable growth. We will also continue lo develop best practice with our policies. and find ways lo ensure that staff are able lo havè a rewarding career as wèll as a wort(-life balance. Lloydette Bal-marrow Chalr Susan Hawley ExeculSve Dlrector 2410312026 191a812026 Page 2
Spotllght on Corruption Ltd Report of the Trustee5 for the yoar ended 30 September 2025 The trustees who are also directors of the charity for the purposes of the Companies Act 2006. present their report with the financial slalemenls of the charity for the year ended 30 September 2025. The Iruslees have adopted the provisions of Accounting and Reporting by Charities.. Slalemenl of Recommended Pr2clice applicable lo charities preparing their accounts in accordance with the Financial Reporting Standard applicable in the UK and Republic of Ireland IFRS 1021 leff6¢tive 1 January 20191. VISION, MISSION, OBJECTIVES ANDACTIVITIES OUR MISSION: Spollighl on Corruption shines a light on the UK'S role in Cofruplion al home and abroad. OUR VISION: We wanl lo see a society with strong, Iransparenl and accounlablo inslitullons which ensure coNuplion is not lol@ral8d and democracy flourishes both in the UK and globally. HOW WE DO THIS.. We highlight the harms of corruption and campaign for ambS1ious, evidence-based refoms to ensure the UK has strong laws and systems of accounlabilily that are robustly enforced. OUR VALUES: Curious, rigorous, collaborative, courageous Our Charitabl8 objects Spotlight on Corruption's objects for the public benefrf( are.. To prevent and relieve poverty in any part of Ihe world Caused directly or indirectly by corruption., To foster Complian with the law and the production ol ethica5 COLles of conduct by governmental, industrial, commeTcial, voluntary sector and commercial bodies., To promote the sound adminislralion of the law in the field of anli-corruplion. Including Iwilhoul limilalionl by.. The promotion and understanding of measures lo ieduce and eliminate corruption.. The giving lo legislative and public bodies and olheTS, information and advice and assistan in relation lo the reduction and 81iminalton of corruption and eff@cliv8 means lo achieve this.. The promotion, undertaking or commissioning of research ¢on¢¢rning offecliv8 means to achieve compliance with Ihe18w lo promote ethical standards of conduct by governmental. industrial, commercial, voluntary sector and professional bodies. Our work Our work seeks lo address the rol& corruption plays as a root cause in driving global povety. impeding development, and undermining democracy, institutions and good governance. Our work involves.. Tracking the implemenlalion and enfor¢gmenl of the UK'S 8nli-corruplion laws to ensure that they are deleiring and preventing coiruplion.. Undertaking detailed, evidence-based and impactful research on the implemenlalion and enforcement of the UK'S anli-corruplion laws snd policy, looking for way8 in which they can be improved., Exploring the role that slralègic litigation can play in improving anti-corruplion enforcement oijlcomes. Page 3
Spotlight on Corruptlon Ltd Report ofthe Trustees for thè year ènded 30 September 2025 Over the past year, Spollighl on Corruplion organised 118 work under three campaigns, each with particular goals. 11 undertook the following acliviliES toward these goals. CAMPAIGN ONE.. POLITICAL INTEGRITY Goal 1.. The overnmenl c(Immils lo measures lo influence ?nd to more Irans aren in lobb in rotecl rts d&cision-makin from une ua This year we focused on transparency and fairn8ss in lobbying government deeision-makers. We produced lobbying Iransp8ren¢y scorecard for the govemmenl in December 2024. to highlight ongoing d8ficienci&s. And we published a major report in March 2025, Levelling the Playing Field, launched in Parliament and covered in the Guardiar), about unfair access lo decision-makers on economic policy maklng. Goal 2.. Si nificanl sle s ar? taken lo u rade the re ulalo and criminal framewoiks for u holdin slandards This year the government announced its Ethics and Inlegrily Commission. Vvhile we were delighted lo see this proposal come lo fruition, the final terms of reference remained far weaker than we had recommended when we first proposed the creation of such a commission. We have raised our concerns about this by briefing parfiarnenlarians and producing public commentary. Vve were also pleased Its see an announcement that the govemmenl will reform the UICS ouldaled common law Misconduct in Public Office offence and has since brought foward legislatlon lo dD so. However, the sugg&sl8rl legis181ion again falls short of what we recommended and we have flagged our analysis, produced with legal experts, with parliamentarians and government officials. Government lakes meanin ful sle lo tackle dirt mone and undue influence. s towards closln s in eleclNal flnance laws and enforcement This year, the government produced ils strategy for electoral reform which commilled lo introducing Know Your Donor rules for politic81 parties 8 proposal which we campaigned for. Wè have sought lo increase ambition by the government lo use a foTthcoming Elections Bill lo tackle oth@r loopholes in the regulation and enfoicemenl of political finance rules. This included producing expert briefings and 8 report on the independence of the Electoral Commission. We have produced several briefings on crypto don£lions including giving evidence to Parliament. And we have worked with lawyers lo develop proposals lo tackle gaps in the criminal offences rel81ing lo political finance Ihal we have put forward lo the government and the Commission Goal 4.. Commitments are mad8 lor stron in rocuremenl. 8r Conflict of inleresl and exclusion ruies for revenlin This year we used the Opportunity of the Covid Inquiry module into PPE procurement and the appointment gf the Covid Anti-Fraud Commissioner lo raise various proposals for reform to prevent procurement malpractice in the future. This included producing expert analysis on conflicts of inl8r8sl, and improving the debaimenl regime. CAIVIPAIGN TWO: TACKLING ENABLERS OF DIRTY MONEY Goal 1., s&rvices nmenl commits lo realer consolidation and more èffecllve AML su ervision of rofessional Over Ihe last year we have worked closely with civil society colleagues to coordinate and sustain pressure on the new governm8nl lo adopt ambitious reform lo the UK'S Anli-money Laund&ring {AMLI regime. This included producing expert analysis, including a report in March 2025, Broken Record, which looked al the patchy progress in the legal sector on tackling non<omplian¢e with anli-money 18undeiing rLFles. 11 also included monitoring and providing expert analysis on major anli-money laundering cases involving law firms. We were delighted that IhÈ government has now gnnounced that il will undertake major reform, Page4
Spotllght on Gorruptlon Ltd Rèport of thÉ Trustees for the year ended 30 September 2025 Goal 2.. There is increased a ainsl AML f ilure LAP elile b overnmenl re al sec ulalors and law enfoicemenl lo18ke robust action blin We worked closely with 8cademics lo produco a report as part of a Governance & Integrity Anti-corruplion Evidence (GI ACE) research project on the contested role of lawyers as enablers ol kleptocracy that was launched in Pailiamenl in March 2025. We have also engaged closely with initiatives by the legal sector itself lo raise ethical standards. including the Instilul& of Business Ethics TaskfoiGe on Legal Ethics which produced a report in Aprfl 2025 which we fed inlts and the Legal Services Board's consullallDn on legal èthics. We have also been working closely with civil $IetY ¢olleagu&s lo promote accounlabilily of18wyers who bling Strategic Liligalion Against Public Participation cases {SLAPPsl by supporting journalists as they seek regulatory action, monitoring early SLAPP cases Teferred lo the Solicitors Disciplinary Tribunal. and increasing pressure for gre81er transp8nCY in SLAPP cases. CAMPAIGN THREE: SCALING UP ANTI-CORRUPTION ENFORCEMENT Goal 1.. Sle s are taken b the overnmenl towards ensurin hat law enforcement is ro resourced In November 2024, we published a major report on boosting resourcing for law enforcèment Ihrtsugh relnvesling recovered assets and economic crirlle fines. launched in Parliament. We convelled key law enfOement and government officials lo discuss the findings lo build consensus for reform and briefed parliamenlari8ns who are seeking a governm8nl review of how lo reinvest more assets into law enforcement during the passage of the Crime and Policing Bill a Bill which also introduces Cost protection fOrmS in civil recovery cases that we campaigned for. Our pressure on resourcing for law enforcement made a strong contribution toward croaling the political pressure that led lo some increasos in funding for key agencies including the SFO and the NCA'S International Corruption Unil. In April 2025 we used a public webinar lo launch our Anli-CDrruplton Enforcement Tracker which has been used hLSndreds of limes a¢ross 60 countries including by members of perliamenl lo support their scrutiny of the government, and has received positive feedback from experts. Goal 2.. Sle s taken towards ensurin realer effectweness and accounlabilil of law enforcement In Dember 2024, we published an expert briefing by & former chief pioseculor on the prosecution of economic crime and submitted evidence lo the Leveson Inqijiry and Fisher review on the same topic. We have maintained close and ongoing engagement with key stakeholders in law enforcement, government and parliament about 8nhancing enforment and have cor)linued lo monitor major SFO and NCA rrvplion-relaled cases, publishing commentary lo inform both public debate and the dev&lopment of our own policy recommen¢Jalions. Throughout the year, we also pushed for open justice by making submissions opposing anonymity and seeking the publication of k8y evid8nce- and w8 have been having increasing success in these applicalions, Goal 3.. Global south Voices are am reen corru lion. lifieLI in the context of sancltons victim com ensalion asset return and We pushed for greater use of the Global Anti-corruplion IGACI sanctions regime during the course of the year. working with civil society colleagues to highlight key opportunities and follow key developments in sanclions-relaled cases. Wè also convened experts lo discuss victim compensation lor communities from affocted countries In corruptn Cases, and built on this work lo submit evidence and recommendations lo the Home Office and FCDO. We were part 01 an FCDO-funded proiecl assessing asset returns lo Nigeria. and worf(8d with Malawian civil society groups lo urge law enforcement to priorilise compensation. Page 5
Spotllght on Corruptlon Ltd Report of the Trustees for the year ended 30 September 2025 Spotlight has also conven8d civil society in the UK and overseas {especially in the Global South) on themes that will be addressed by the governmenl Illicit Finance Summit- in parti¢LJlar on gold and asset recovery. We are Working closely with Ghanaian civil society lo make recommendations on tsckling illicf( financial flows through gold. This year we also started to develop work and consulted a wide range of partners on how anli-corruplion efforts can support 8 just transition and tackle environmental harms, with a view lo developing a manifesto for 8ction. PUBLIC BENEFIT Th8 b8neticiarres of our work are the victims of corruption in the UK and oversea8 and all those who will benefit fTom higher elhical standar(Ss of conduct in government and compliance with the law by the private sector. It includes ordinary citizens and voters, who are dis8dvan18ged by govèrnments misallocaling public money as a result of corruption and who will benefit from the improved functioning of democracy that results ffom strong anli-corruption systems and robust inslilLJlions.11 also includes businesses who are denied a level playing field by unfair practices that result from coiruplion. Stronger enfor¢emenl of UK anli-corruption laws and higher anli-corruplion standards in UK foreign policy and export support benefits victims of corruption and the public of countries affected by wrruplion by leading lo.. greater transparency 8boul the identity of corrupt actors and the nature of their corruption lo enable gre?ler a¢counlabilily', increased confiscation of corrupt assets which can be rèturned lo aff8cl6d countries through development projects., polenlial compensation through the court8 in the event of conviction which can likewise be returned to affected counlrie8", and strong soci81 condemnation of and slronuer procedures lo prevent bribery and corruption. Our work benefits the wider public in the UK by providing expert and insightful analysis aboLs1 how anli-corruplion laws are being enforced and anti-corfuplion $18nd8rds maintained, including through our website, Twiller account and media engagement. Our wotk on improving integrity and anli-corruplion measuffts in procurement benefits the public in the UK Ihiough providing solution5 for how lo improve public trust in government and in public contracting and ènsure greater value for money in government spending. Our board has t8k8n into account the Commission's guidan on public benefit guidance when making relevant decision8. MONITORING AND EVALUATION Spollighl 18 commilled to b8ing a r&flecliv@, learning organisalion. We regularly assess our work and impact according lo the following criteria.. whether our work contributed lo and enhanced public debate on fighting ¢orruplion.' whether il informed deci8ion-making and thinking by decision-makers., and whether il contributed to better oulcomes. We have an inteTnal IpaCI tracker which we update and discuss weekly, and which we have recently refined lo make il more conducive lo a deeper rèflection on our impact. In addition, w6 tak6 regular opportunili8s lo do déep dives into the learnin9 from particular pieces of work. adapting our approach lo maximise impact and deliver our objectives. We also explore how we could improve and whal lessons can be learned through regular staff reviews,. and we rllainlain a dynamic risk register, which looks al the impact that external events, and internal factors, could have on our ability lo achieve success. As part of our three year strategic planning process we commissioned an external consultant lo conduct stakeholder interviews, covering our profile, effectiveness, niche, impact and opportunities. The findings from this rese8rch were presented lo staff and the Board. 8nd inlegraled into our strategy process. Page 6
Spotlight on Corruptlon Ltd Report of the Trustees for the year 8nded 30 September 2025 FACTORS AFFECTING ACHIEVEMENT OF OBJECTIVES A8 a small team with growing external d8mands on our lime, managing our workload, including responding lo urgent opportunities created by events and media requests alongside delivering long-lerm priorities, is always a challenge. Our agility as an organisalion is crucial lo our impact, bul ensuring that il does not pose an undue burden on staff remains an ongoing issue that we monitor closely. The political and economic environment. including stale ol public finances. has a significant impact on the levels of ambition lo tackle corruption. Making corruption salient amongst a range of competing highly important other issues politically can b& challenging. The global geopolitical environment meanwhile has resulted in anli-corruplion norms facing serious backsliding across the world. However, there is signilicanl political will al the moment for the UK lo play a leadership role in t4ckling corruption which creales welcome opportunities for our work. FUTURE PLANS - THE YEAR FROM OCTOBER 2025 As we d81iver our next three year strategy, and Annual Plen for 2025126 under that strategy, wo have moved our work into two pillars.. Defending Democracy and Ending Impunity. We have refined our goals and objectives 8S Part of this slral&gy, and d&veloped detailed internal reporting mechanisms on the outcomes we achieve towards Ih&8e. Al an olganisalional level, we will have a new Head of Finance and Operations and a Senior Philanthropy and Partnership Manager starting this year, who will both play a crucial role in building Spollighl's financial and operational systems and ensuiing our financial sustsinabilily. We will continue lo actively promote and encourage professional development and training and we will embed new policies, including on our diversity, equity and inclusion, across 811 our work. FINANCIAL REVIEW This has been 8 y@ar of financial stability and consolidation al Spollighl. Overall income this year lotalled £630,280 and we b¥oughl forward £447,927 from grants awarded in previous years and generously provided in lull al the start of the grant perK)d. The Inajorily of our income this year came in the form of grant funding, and we also received £2,708 in dgnations from ir)dividuals. As in previous years, in FY 2024-25 Spollighl had good cash ftow and financial Senty, with overall growth in oxpendilure of 25'A lo £614,643. This included sub-granls of £118,447 made lo thè Inlern81ional L8wyers Project1£67.3331 and Foreign Policy Centre {£51,1141 for WOTk on joint projects whère Spotlight was the main gr?nl-holder. Our expenditure not including the sub-granls was very slablo, increasing by just 1 tsA compared with last year. lo £496,196. Overall. the Charity ended th8 yfrar with funds of £463,564, of which £216,024 Tepresenls the balance of year one funding from the Joffe Trust. awarded in July 2025 and paid in advance. Due lo this and other funding secured, we were able lo increase our staff team from six lo sevon people in August 2025. end then lo eight in October 2025. The team will grow again to nine staff members in March 2026 and in order lo sustain the achievements of this year. w8 shall need lo continue secuTing subslanlial new funding in future yeaTS. With this in mind, the staff member joining in March 2026 will be our first fundraiser, a Senior Philanthropy and Partnership Manager. Page 7
Spotlight on Corruption Ltd Report of the Trustees for the year ended 30 Sopt&mbgr 2025 We are extremely grateful lo our funders during this period.. The Davld and Elalng Potter Foundation The Joffe Charitable Trust John Ellerman Foundation The Forelgn Pollcy Centre (Subrant on bghalf of thg Joffo Charitable Trustl The Friends Provident Charitable Foundation The Josèph Rowntree Charitable Trust IJRCT} JRSST Charitable Trust IJRSST.CTI Open Soclety Foundatlons IOSF Gower Street Network for Social Change Charltsble Trust Afrlca Network for Environmental and Economlc Justlce IANEEJ) Governance & Intagrity Anti-corruption Evidence {GI ACEI programme. funded by the FCDO Transparency International Secretariat Isub-grant on behalf of the Global Anti-corruption Consortium) Further details of the giants are prov¢ded in Note 12. RESERVES POUCY The Charity has revièwed its requir?menls for reserves from unrestricted income to be primarily for the following reasons., delays in funding or unforeseen lerminalions,. cash flow variations. As a result of the review, Spollighl's policy 15 to hold ieserves equating lo at least three months of operating costs. With unrestrted funds of £177,579 carried forward, this requirement was mel. RISK MANAGEMENT The TrLsslee8 have conducted a review of the major risks to which the charity is exposed and has a regularly updated risk regisler. The risk register is reviewed at each Board meeting. Vvhere appropriate, systems or proceduies have been identified lo miligale the risks that the Charity faces. SMALL CONiPANY PROVISIONS This report has been prepared in accordance with the provisions applicable lo compani8s enlilled lo th8 small ¢ompanies exemption. STRUCTURE. GOVERNANCE AND MANAGEMENT Spollighl is governed by seven Trustees, with Lloydette Bai-M8rrow as Chair and Angus Brown as Treasurer. The Board is supported by a Finan and Operations Cornmillee which overs6&s the finances of the organi5alion, drawing upon Iruslees with very significant expertise and experience in financial management and governance. Board meetings lake plac8 four limes a year, with Finance and Operations Committe8 meolings taking place ahead of the Board m&elings, and also holds strategy days with the team usually on an annual basis. The Board approves Spotlight's Annual Plan in Seplèmb8r ahead of each year, monitors ils implemenlalion in February, and receives a final report on activities and progress on objectives in the summer. In 2025, the Board also approved a new Ihree-year strategy for spo1ght, having partiBip3led in an extensive sliategic planning process with staff, In th¢ past year, as part of an ongoing commitment to strong governance. the Board approved a number ol new and revised policies including Anli-Bribery, Anli.Bultying and Harassrnenl, Malernily. Paternity & Shared Parental Leave, and Compassionate Leave. as well as continuing lo review existing policies. The Execulivo Director is supported by a Senior Management Te8m, and an Advisory Board of widely respected professionals from the sector. Pag8 8
Spotllght on Corruptlon Ltd Report of the Trustees for the year ended 30 September 2025 STRUCTURE, GOVERNANCE AND 14iANAGEMENT REFERENCE AND ADMINISTRATIVE DETAILS Registered Company number 12123483 (England and Wales) Registered Charity number 1185872 Reglst&red offlce 82 Tanner Street London SE13GN Trustees Ms L Bai-marrow Ichairl Mr A Brown (Treasurerl Mr J Date Mr S Eastwood Ms C J Stewart liesigned 2214120251 Ms M M Davies Mr S P Holland Indepèndent ExamSner Webb & Co Ltd Accounlanls and Business Advisers One New Street Wells Somersel BA5 2LA Banks Triodos Bank Deanery Road Bristol BS15AS CCLA Investment Management 1 Angel Lane London EC4R 3AB Senior Management Team Dr Susan Hawley Dr Helèn Taylor Ms Kathryn Busby Ms Abigail Orr Mr George Havenhand Ms Kamila Kingslone (Executive Director) IDÉpuly Direclorl (Senior Finance and Operations Manager}. until 2910112D26 (Head of Finance and Operalionsl, from 0510112026 (Senior Legal Resear¢herl, until 1610412025 (Defending Democracy programm8 lead), from 0511112026 2410312026 Approved by lxder of the board of Iruslees on and signed on ils bèhalf by.. Ms L Bai-Marrow- Trustee Page 9
Independent Examln8V8 Report to the Trustees of Spotllght on Corruption Ltd Independent examlner's r6port to the trustees of Spotlight on Corruption Ltd {*hè Company'l I report lo the charity trustees on my ex8minalion of the accounts of the Company for the year ended 30 September 2025. Responsibilities and basls of report As the charily's Iruslees of the Company land also its directors for the purposes of company lawl you are responsible for the preparation of the accounts in accordance wilh the requirements of the Companies Act 20061.lhe 2006 Acl'l. Having Satisfied mysoK that the accounts of the Company are not reqLFired lo be audited under Part 16 of the 2006 Act and are eligible lor independent examination. I report in respect of my examination of your charity's accounts as carried out under Section 145 of the Chaiilies Act 2011 I'lhe 2011 Acl'l. In carrying out my examination I have followed the DirecliDns given by the Charity Commission under Section 145151 Ib} of the 2011 Act. Independent examlner's statement Since your charity's gross incorlle exceeded £250,000 your examiner musl be a member of a listed body. I can 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 confirm that no mallers have come lo my allenlion in connection with the examination giving me caus8 lo beli&ve'. accounting records were not kept in respecl of the Company as required by Strction 386 of the 2006 Act., or the accounts do not accord with those records., or the accounts do not comply with the accounting requirements of Section 396 of the 2006 Act other than any requirement that th& accounts give a true and fair view which is not a maller considered as part of an indepèndent examination., or the accounts have not been prepaied in accordance with the methods and principles of the Slalement of Recommended Practice for ?c¢ounling and reporting by charities lapplicablè lo charities preparing their accounts in accordance with th8 Financial Reporting Standard applicable in the UK and Republic of Ireland IFRS 1021}. I hav& no concerns and have come across no other mallers in conneclioll with the examination lo which allenlion should be drawn in this ieport in order to enable a proper understanding of the accounts lo be r8ach8d. Barry Davidson Webb & Co Ltd Accountants Business Aisvisers One New Street Wells Somersel BA5 2LA 24 March 2026 Page 10
Spotlight on Corruptlon Ltd Statement of Financial Activities for the year ended 30 September 2025 202S Total funds 2024 Total funds Unrestrlcted Restrictpd fund fund Notes INCOME AND ENDOWMENTS FROM Grant income 129,070 491,876 620,946 570.661 Investment income Other income 8,496 838 8,496 838 12,787 479 Total 138,404 491.876 630,280 583.927 EXPENDITURE ON Charitable activitS8s Direct charitabla activities and support cosls 223,091 391,552 614,643 489,851 NET INCOMEI(EXPENDITUREI 184.6871 100,324 15,637 94,076 RECONCILIATION OF FUNDS Total funds brought foNard 262,266 185.661 447,927 353,851 TOTAL FUNDS CARRIED FORWARD 177,579 285,985 463,564 447,927 The notes fom part of these ftnancial slalemenls Page11
Spotllght on Corruption Ltd Balance Sh&et 30 September 2025 2025 Total funds 2024 Total funds Unrestrl¢ted Restricted fund fund Notes CURRENT ASSETS Debtors Cash al bank 48,337 150,304 46,337 436,289 1,346 456,985 285.985 196,641 285.985 482,626 458,331 CREDITORS Amounts falling within one year 119,052 119.IK21 110,4041 NET CURRENT ASSETS 177,579 285,985 463.564 447,927 TOTAL ASSETS LESS CURRENT LIABILITIES 177,579 285.985 463,564 447,927 NET ASSETS 177,579 285,985 463,564 447,927 FUNDS UnTeslricted funds Restricted funds 10 177.579 285,985 262.266 185,661 TOTAL FUNDS 463.$64 447,927 The charitable company is enlilled to exemption from audit under Section 477 of the Compani8s Act 2006 for the year ended 30 September 2025. The members have not required the company lo obtain an audit of ils flnancial slalements for the year ended 30 September 2025 in accordan with Section 476 of the Companies Act 2006. The trustees acknowledge their r8sponsibililies for la) ensuring that the charitable company keeps accounting records that comply wllh Sections 386 and 387 of the Companies Act 2006 and Ib) preparing finanGial slalemenls which give a true and lair view of the slate of affairs ol the charitsble company as al the end of each financial year and of ils surplus or d6li¢il for each 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 lo financial slatsmenls, so far as applicable to the charitable company. The notes form part of these financial statements Page 12 continued...
Spotllght on Corruptlon Ltd Balance Sh8et- continued 30 September 2025 These flnancial slalemenls have been preparod in accordance with the provisions appIlble lo charitable companies subject to the small companies regime. The financial statem&nls were approved by the Board of Trustees and aulhorised for issue on 2410312026................................. and were signed on ils behaLI by.. MrA Brown- Trustee Ms L Bai-Marrow- Trustee The notes form part ol these financial slalemenls Page13
SpotlSght on Corruption Ltd Notes to the Flnanclal Statements for the year ended 30 September 2025 ACCOUNTING POLICIES Basls of prgparing the financial ststements The financial statements of the charitable company, which is a public ben¥f¢t entily under FRS 102, have been prepared in accordance wilh the Charities SORP IFRS 1021 'Accounling and Reporting by Charities.. Slalemenl of Recommended Practice applicabla lo charities pieparing their accoLEnls in accordance with the Financial Reporting Standard applicable in tho UK and Republic of Ireland IFRS 1021 leffeclive 1 Janusry 20191,. Financial Reporting Standard 102 'The Financial Reporting Stsndard applicable in the UK and Republic of Ireland, and the Companies A¢1 2006. The fi'nancial slatemenls have been prepared under the historical cost Convention. Flnancial reporting standard 102- reduced disclosure exemptions The charitable company has taken advantag8 of the following disclosu exemption in preparing these financial slalemenls, as pemiilled by FRS 102 'The Financial Reporting Standard applicable in the UK and Republic of Ireland,: the requirements of Section 7 Slalemenl of Cash Flows. Incomè All income is recogrbised in the Statemènt of Financial Activities once the charity has enlillemenl to the funds, it is prob3ble that the income will be received and the amount can be measured reliably. Expenditure Liabilrties are recognised as expenditure as soon 05 there is a legal or conslruclive obligation commilling the charity to that expenditure, il is probable that a transfer of economic benefits will be required in settlement and the amount of the obligation can be measured reliably. Expenditure is accounted for on an accruals basis and has been classifi'ed under headings that aggr6gate all cost related lo the category. Where costs cannol be directly allribuled to particular headings they hav been 8llocaled lo activities on a basis consislenl with the use of resources. Taxatlon The charity is exempl from corporation tax on its ch8rilabl& 8¢tivili&s. Fund accountlng Unreslricled funds can be used in accordance with the charitable objectives al the discretion of the Iruslees. Restricted funds can On be used for particular restricted purposes wlhin the objects of the ¢harily. R8Strictions arise when specified by the donor or when funds are raised for particular reslricled purposes. Further explanation ol the nature and purpose of 8ach fijnd is included In the notes to the financial slalemenls. Penslon costs and other po$t-retirem&nt nefItS The charitable company operates a defined conliibulion pension scheme. Contributions payab5e lo the charilable company's ptrnsion scheme are charged lo the Statement of Financial Activities in the peri1 lo which they relate. Page 14 Gontinued...
Spotllght on Corruptlon Ltd Notes to the Flnan¢lal Statements - continued for the year ended 30 September 2025 GRANT INCOME 2025 2024 Donations Grants receivable 2,708 618.238 10,988 559.673 620,946 570,661 INVESTMENT INCOME 2025 2024 Deposil account interest 8,4 12,787 CHARITABLE ACTIVITIES COSTS Support costs Isee note 51 Dlr&ct Costs Totals Direct charitable activities and support costs 611.686 2,957 614,643 SUPPORT COSTS Governance costs 2025 2024 Independent examiners fees 2.957 2,288 TRUSTEES. REMUNERATION AND BENEFITS There were no Iruslees. remuneraliDn/other benefits for the year ended 30 September 2025 nor for the year ended 30 S8pl&mber 2024. Truste&s' expenses During the year ended 3D September 2025 a 10181 of £60.4012024 - £129.20) was reirnbursed lo one Iruslee lor travel costs STAFF COSTS 2025 2024 Wages and salaries Soci81 security costs Other pension costs 301,008 26,601 7,197 319,589 30,340 7,819 334,808 357,748 The average monthly number of employefjs during the ye?r was as follows.. 2025 2024 Stsff Page 1S continued...
Spotlight on Corruptlon Ltd Note$ to the Flnanclal Statements - contlnued for the year ended 30 September 2025 STAFF COSTS- contlnued The number of employees whose employee benefits lexcludlng employer pension costs) exceeded £60,000 was.. 2025 2024 £60,001- £70,0 DEBTORS.. AMOUNTS FALLING DUE WITHIN ONE YEAR 2025 2024 AccnJed income 46,337 1,346 CREDITORS: AMOUNTS FALLING DUE WITHIN ONE YEAR 2025 2024 Trade creclilors Social security and oth@r laxÈs Pension liability Accrued expenses 4,863 e,8L 1,722 5.671 3,534 6.870 19,062 10,404 10. MOVEMENT IN FUNDS Net movement In funds At 1110124 At 3019125 Unrestrlcted funds General fund 282,266 184,687) 177.579 RgStrl¢ted funds Reslricled Fund 185,661 100,324 285,985 TOTAL FUNDS 447,927 15,637 463,564 Nel movement funds, included in the above are as follows.. Incomlng re$our¢es Resources Movement expended In funds Unrestrlcted funds General fund 138,404 1223,0911 {84,687) Rgstricted funds Reslricled Fund 491.876 (391,5521 100,324 TOTAL FUNDS 630,280 1614,6431 1 S,637 Page 16 continued...
Spotlight on Corruption Ltd Notes to the Financial Statements - continued for the year ended 30 September 2025 10. MOVEMENT IN FUNDS-contlnued Comparatlves for movement In funds Net movement In funds At 1110123 At 3019124 Unrestrlcted funds General fund 234,937 27,329 262,266 Restricted tunds Reslricled Fund 118.914 S6.747 185,661 TOTAL FUNDS 353,851 94.076 447,927 Comparative nel movement in funds, included in the above are a5 follow5-. Incoming resources Resources èxpended Movement In funds Unrestricted funds General fund 280.080 {252,7511 27,329 Restricted funds Reslri¢led Fund 303.847 1237,1001 66.747 TOTAL FUNDS 583,927 {489,8511 94,076 11. RELATED PARTY DISCLOSURES There were no relaled party transactions for the year ended 30 September 2025. Page17 continued...
Spotlight on Corruptlon Ltd Notes to the Flnan¢lal Statements - contlnued for tho year ended 30 Septgmber 2025 12. ANALYSIS OF CHARITABLE FUNDS Blfwd Income Expenditure Clfivd J08eph Rownlree Charitable Trust Joffe Charitable Trust David and Elaine Potter Foundation Joffe Charitable Trust OSF JRSST Charitable Trust OSF UK AML Campaign OSF SLAPPS OSF Sanctions Friends Provident Charitable Foundation Joffe Charitable Trust via Foreign Policy Centre Global Anli-corruplion Consortium via Transparency International Secretarial Gower Str8el Network for Social Change Charitable Trust GI ACE programme, funded by FCDO Africa Network for Environmental and Economic Justice OSF UKAML Campaign (supplemental grant) General Incomo 41,600 45.000 3,000 270,000 36,762 34.896 134,5531 166,9741 130,0001 153,9761 7,047 59,071 81,045 27,000 216,024 36,762 1,127 133,769) 199,3081 163,6601 1109,9921 99,308 98.227 34,567 109,S92 8,237 36,629 {32.9481 11,918 2,386 (2.3861 2.106 2,238 2L),000 14.3441 17,6181 12.382 17.935 9,50D 17,9711 19,5001 9,964 2,450 12,450} 53,194 64,659 153,194) {2,0001 12,043 74.702 Total 447.927 630,280 1614,6431 463,564 Page18
Spotllght on Corruptlon Ltd Detailed Statement of Financial Activitie8 for the year ended 30 September 2025 2025 2024 INCOME AND ENDOWMENTS Grant inGome Donations Grants receivable 2,708 618,238 10,988 559,873 820.946 570,661 Investment income Deposit account interest 8,496 12,787 Other Income Other income 838 479 Total incoming resources 630,280 583,927 EXPENDITURE Charltablg a¢tivltlgS Wages Social secuiity Pensions Insurance Other office costs Travel costs Communications Legal and profession81 fees Consultancy fees Stsff training and dèvelopment Bank Charges Fundraising costs Sub Grants 301,008 26.601 7.197 8.756 17,154 5,184 28,570 9,650 76.579 8.044 150 4,346 118,447 319,589 30.340 7,819 6,812 9,758 5,316 17,672 11,986 72.453 1,530 68 4,220 611,886 487,583 Support costs Governancg Costs Indep8ndenl examiners fees 2,957 2,288 Total resources expended 614,643 489,851 Net income 15,637 94,076 This page does not form part of the slatulory financial slalemenls Page 19