GWCT forgot the…?

Complaint to Charity Commission

I am writing to you in connection with the Game and Wildlife Conservation Trust (GWCT – charity number 1112023). There are several significant issues about the charity that concern me, and given their volume, I thought it best to make a complaint.

I was recently considering making a donation to the Game and Wildlife Conservation Trust, using their website, and I was concerned when I was unable to discover what percentage of my donation would be spent on the cause.

When I managed to track down a copy of their report and accounts, I was shocked to see that the charity spends £2.7m on raising funds, but only generates £7.1m, which seems a very low proportion. Perhaps this is why they are so reluctant to make a solicitation statement on their website. I feel these are two issues that the Charity Commission should look into.

When I found a link on the GWCT website that appeared to lead to their accounts the sum total of the information provided was: “In 2013 the Trust had a total income of £7.09 million, representing a 5.6% increase compared with 2012, and the Trust spends £4 million of its total expenditure on its charitable activities. Expenditure on research again exceeeded (sic) £3.5 million.”

I suppose it is for the charity to decide how to spend their funds, but if more than £3.5m is spent on research, that appears to leave less than £0.5m for all their other charitable objects: is education of the public, the conservation of biological diversity, the provision of natural habitats and the maintenance of species really so much cheaper/less important than research? Maybe GWCT have forgotten something. This is my third area of complaint.

It is concerning that the charity’s report and accounts are not published on their website. I believe that accountability and transparency are hallmarks of an effective charity so this particular omission is a significant cause of concern to me, as I am sure it will be to you (Issue 4).

The charity also does not appear to have a complaints process – not one I could find on their website at least: another black mark for me when it comes to accountability. Again, I feel this should be investigated (Issue five).

As you will no doubt have gathered, this has made me think twice about giving them my financial support. Perhaps they don’t need it though: when I looked at the accounts it seemed from my basic understanding that their financial reserves were significantly higher than their target figure, but I can’t seem to find out why – should the Commission look into this too, perhaps (Issue six)?

Maybe they are awash with money? I cannot find out from their website roughly how much they pay their Chief Executive – I thought that remuneration information was supposed to be available within three clicks of the charity’s homepage (Issue seven).

In fact, the more I looked at the available information, the more concerned I was. For example, although GWCT’s charitable objects include research into game and other wildlife, I couldn’t work out what proportion of their resources is expended on non-game activities – although, to me, it didn’t look very high (Issue eight).

Much of their research appears to be privately funded, but I couldn’t work out what their procedures were for avoiding conflicts of interest, and for declaring related party transactions, and this doesn’t feel right to me as a potential donor (Issues nine and ten).

With this in mind, I was more than a little disturbed when I considered how their activities could really be for the public benefit, and merit the trust that the public puts in them (not to mention the financial benefits derived from charitable status)(Issue eleven).

Thinking in more detail about public benefit, I was taken aback to see in their Annual Review 2013 that:
‘Over the decades, our scientists have developed beetle banks, conservation headlands, medicated grit and new types of traps and snares’. Is it really in the public interest to cover our countryside with Flubendazole and Fenbendazole? What I read here  certainly made me concerned about this. Given that the dangers of lead shot to wildlife and people have been known, through careful research, for many years I was surprised that this issue receives scant treatment on the GWCT website despite being the subject of a government sponsored working group on which GWCT have been represented.  Is the GWCT research really for the public good or is it for the benefit of the British shooting industry(Issue twelve)?

You will see from Twitter that I sometimes get into debates with one of the Directors of GWCT, for example here.  What worries me, though, is that someone so closely identified with GWCT, and in fact in charge of much of their public facing activity, does seem from time to time to be using highly emotive, potentially provocative language, without a supporting factual framework, whereas I thought that charities were required to take special care in this area, and that the Commission had said so in guidance back in 2008 (Issue thirteen).

Since I held back from making a donation, I don’t know what their supporter marketing material might say, but this lack of awareness of your regulation and guidance worries me (Issue fourteen).

I realise that with such a lot of issues, it may be some time before you are able fully to investigate them all, but I do hope, as a matter of public interest, it will be possible to get to the bottom of it all.


The Charity Commission can be contacted with extreme difficulty, because the GOV.UK website is so awful, and acts as a barrier to communication between citizens and government bodies.  You could phone the Helpline and say that you support this complaint if you do 0300 066 9197.

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13 Replies to “GWCT forgot the…?”

  1. Fantastic. Looks like raptorpersecutionscotland are firing on both barrels too - their latest post about the "natural" food campaign and SNH's involvement (29/06).

  2. Sorry Mark, I'm sure you have a point (or fourteen) but this feels rather like stooping to Botham's level and I'm not sure it is helpful. What is the goal here exactly? Does this move us closer to having hen harriers back above ecologically managed, biodiverse uplands, or further away?

    1. Hugh - let's see what the Charity Commission says. They need the public to point them in the direction of charities who are not sticking to the standards.

      1. Well the Grouse shoot managers get away with their abuse of nature because people turn a blind eye to their practices. We should be discussing every aspect of their destructive, unsustainable hobby. If food is marketed for human consumption it should conform to standard practice.... which of course game does not. Riddled with toxic lead shot and un-monitored diseases, retrieved in a dogs mouth, stacked on the ground and thrown into the back of a landrover allowing cross contamination between carcasses..... the list of basic food handling infringements goes on....
        If they have just lost their rates exemption because it could not be justified, their exemption from basic food hygiene is probably next target.
        Mark is right to expose the PR smokescreen that these people use to hide their activities...... and "charities" like GWCT are little more than PR smokescreens.

        1. "contamination between carcasses"

          When preparing meat of all kinds I always remove the hair or feathers and then cook it. Seems to work. I have only ever had food poisoning from a doner kebab (Cambridge), a sausage roll (Waterloo Station), mussels (Lostwithiel). There is a frisson of excitement to be had in anticipation of botulism from unwashed lettuces

    2. Certainly not further away. It serves to highlight the fact that the likes of Botham and Gilruth do not play with a straight bat.

  3. I do agree the Government website is appalling. One can only assume its purpose is to obstruct the public in its enquiries. Thank you so much for providing such a comprehensive template for missives to the Charity Commissioners as there are some pressing matters I have to take up with them.

  4. As you note, the last accounts made available for public scrutiny were year ended 31 December 2013. As you also suggest, the 28 pages make interesting reading

    Their SIR return also, see in which beneficiaries are listed in rank order (?) public, policy makers and practitioners.

    The annual report mentions advocacy work undertaken - wasn't that something the Government were seeking to stiffle charities undertaking, so another area to consider perhaps? This is particularly interesting when they claim policy makers are beneficiaries, vested interest in promoting something they seem to suggest the principle beneficiaries are the public? How does the CC / Government reconcile these?

    What likelihood of the Charity Commission investigating? It has been said that they are understaffed and only look at financial issues?

    60,000 supporters of which 22,000 are members .... the costs of supporting that seem rather high perhaps?

    Intrigued as to what their new (2013) Shoot Biodiversity Assessment Service is - perhaps it assesses the lead content in the game?

  5. Its interesting that just about every conservation body going has been push the petition to save the EU directives that protect nature, but not a word from GWCT. Almost as if wildlife isnt a priority for them


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