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 announcen￿nI 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 expectat￿nS 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 deM￿racY.
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 transp8￿nCY 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
enfO￿ement 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 De￿mber 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 enfor￿ment 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
corrupt￿n 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 I￿paCI 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 Se￿nty, 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 (Sub￿rant 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
unrestr￿ted 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 spo￿1ght, 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 appIl￿ble 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 peri￿1
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