Sir Stephen Bubb

Sir Stephen Bubb

Wednesday, 20 August 2014

Reds under charity beds....

So, it’s the silly season and you can expect fluffy stories, one of which appeared in the Sunday Telegraph this weekend. I had bought a copy after early morning Communion and it had me chortling on my croissant. Apparently charities are being taken over by former advisors to Gordon Brown. A lurid headline “former brown aides fighting coalition as charity chiefs" failed to provide any evidence to back this up.

It would appear that on the ST logic you are unable to perform a professional job for a charity if you previously worked for a labour politician. So they castigate Justin Forsyth who is doing a tremendous job at Save the Children in incredibly taxing times simply for his former role with our last Prime Minister. No evidence is provided that somehow their work has been subverted by improper political influence.

The reality is that many former advisors to Blair and Brown are in jobs across the public, private and third sectors. That is because they are talented and professional people who have significant experience to bring to the job. Should the fact that Simon Stevens was a Blair advisor and former Labour Lambeth Councillor rule him out of the top job in running our NHS?  Of course not and everyone recognises the huge skill and talent which led the Government to appoint him.

The fact that people take jobs working in Government for Ministers of whatever persuasion should not rule them out for running anything. They should be appointed on merit and ability and they are. Its the outcomes and delivery that matters in a top job not the colour of the tie you wear . The ST failed to provide any evidence that there has been political bias in the work they do; and that's because there isn't any.

It is always disappointing when senior politicians revert to character assassination rather than tackling an argument on its merits or demerits. A classic example of this was Chris Grayling's article to accompany the ST piece. His attack on Frances Crook who leads the Howard League for Penal Reform was particularly regrettable. A distinguished and ardent campaigner; I have known her for years as an ACEVO member. She has been as fierce in attacking Blair and brown as in attacking plans by this government depending on what she feels to be right. According to Mr Grayling she is "one of the most prominent labour supporting pressure group leaders". And the reason for this attack? I reckon it is because The Howard League have criticised the introduction of fixed bedtimes for teenagers. For the world's oldest and most respected penal reform charity not to campaign on such issues would be a dereliction of their charity duty and indeed I know Frances would have been as vehement about this whether it was a coalition or labour policy. It is entirely respectable to criticise such policies. Indeed a healthy democracy respects and encourages such debate. I recommend Frances's excellent Blog on this subject. (

And I rather liked her pithy response to the ST story ". We would be shirking our duty if we did not (campaign). Sometimes it is unpalatable to politicians and this is just tough". Amen to that.

Friday, 15 August 2014

Council woes

I first came across the “graph of doom" in Exeter when I was meeting the CEO, Phil Norrey, of Devon County Council. This set out the stark reality of local government finances; that on the current trajectory the only services councils will be able to deliver are basically the statutory services for the old and refuse collection. But when I was with the CEO of Nottinghamshire County Council Mick Burrows recently he was talking about a graph of opportunity. In other words, thinking of how to deliver differently.

Whatever way you cut it local councils have one heck of a task on their hands. They have faced massive reductions in budgets and face similar huge cuts to come. They have by and large faced the challenge well, though we know that many third sector bodies have faced unprecedented cuts and in some cases had to close down.

The bald facts of the finances make it clear that councils need to look afresh at their delivery role and look at how the third sector can be part of the answer to budget cuts. We can do more with less; we always have.

It’s against this background that ACEVO has been developing its work in consortia building across our sector in order to build capacity to bid for council services. Yesterday my local government director John Gillespie and I were in Warwick to see Jim Graham, the CEO of Warwickshire County Council to discuss how we can work with them to support capacity building there. A good meeting; Jim sees a strong role for our sector in meeting gaps they will have over the coming years as they deliver services in tightened times. And good to meet the Leader of the Council too.

Warwick is a stunning place. I was a good boy (taking Simon Gillespie's advice) and walked from the station. And as I was early I got a chance to see the Collegiate Church of St Mary’s, one of the finest of Britain's Parish Churches. It has a particularly famous memorial chapel built by Richard Beauchamp, Earl of Warwick to house his grand tomb.

 His son in law was Richard Neville, Earl of Warwick and known as Neville the King Maker for his role in the ascension of Edward III before he switched sides to support Henry VI. A distant relative - 18th cousin I think- so pleased to see his figure on the side of the grand tomb, along with his wife Anne Neville.

And also discovered nearby was the tomb of Robert Dudley, the first Earl of Leicester and supposed lover of Elizabeth I. Dudley died in Charlbury, at Cornbury Park in 1588, just one year after my cottage in Charlbury was built from where I now Blog!

Thursday, 14 August 2014

It’s a Dog’s life....

I hate those fascist like signs that are increasingly seen in our parks and public spaces “No Dogs". The sort of signs that call for civil disobedience from us dog lovers. They’re stupid too, when we should be encouraging more dog walking as we all understand better the dangers of obesity. I'd have dog walking on the NHS for diabetics!

Anyway this is just a lead in to say farewell to the wonderful Clarissa Baldwin who is stepping down as CEO of the Dogs Trust after 28 years. An inspirational and much loved leader. I well remember my visit out to see her at their HQ. She is perhaps best known as the author of the slogan “A dog is for life not just for Christmas". And the Dogs Trust is in safe hands as they have appointed Adrian Burder who has been working at the Trust for some time and knows the ropes. Good luck in leading them. I should mention that both my Chair and I are Dogs Trust members! And Clarissa was a longstanding member of ACEVO.

And finally, another huge irritation to us dog lovers are the problems in finding places to stay that aren't sniffy and irritating about dogs. Help is at hand with a blog written by a dog!  Phileasdogg...

See this video snip...

Now I'm off to Warwick to talk to the CEO, Jim Graham, of Warwickshire County Council about how to maximise the use of the third sector in delivering better citizen focused services and ensuring the council hears the voice of their local communities. A not un-agreeable place to spend the day though I doubt I’ll make the castle... The Hound is off in Battersea Park.

Wednesday, 13 August 2014

Brixton Boys and the death of political discourse

What a treat to listen to John Major on Radio 4 this morning! He was born just down the road from me on Coldharbour Lane and talked about his Brixton days. He, like me , was a Lambeth Councillor – though not quite in the same era!

What I found reassuring was his welcoming attitude to immigration. He was pointing to his own experience of hard working and ambitious immigrants in Brixton. Such a change of dialogue from the nasty, divisive speeches we get these days from many politicians who want to pitch to base instincts and spread scare stories about scroungers and welfare cheats . This discourse is corrosive to social cohesion and builds on people’s prejudices, without so much as a shred of proper evidence, as opposed to pub room chatter and anecdote. Or should we call this ‘policy making by the Daily Mail’?

But political discourse is pretty dismal all round. A classic example today was the announcement of unemployment figures. For the government this is evidence of ‘the long term economic plan’ working , while for the opposition it’s further fuel to the ‘cost of living crisis’ fire. These trite clich├ęs will be trotted out ad nauseam up to the election, and most of us will find it is off-putting to proper democratic debate.  Spin as opposed to proper evidence-based (or even deeply principle-based) policy offers.

Where are the parties’ narratives on society and on the role of civil society? How about social cohesion and community? I have yet to hear an election-focused speech from either Cameron or Miliband on these issues, let alone Clegg.

And whatever happened to the ‘Big Society’ – and what is Labour's alternative?

We need better. It’s no wonder so many people find that the political parties are not the place to find the answers to many of society’s problems and challenges. It’s why so many people now find outlets for their campaigning and advocacy work through charities, and why our memberships have soared whilst the parties have atrophied. Plenty of civil society groups – like the RSPB and National Trust, to name two of the biggest – have memberships in the millions, many times the size of all the political parties put together.

You can however be sure that ACEVO will be battling away on these issues, and challenging the parties to spell out their attitudes to society and community and the role of civil society. Isn't it sad that instead of spending proper time on all this we are having to battle away at the iniquities of the Gagging Act and the vague guidance on it from the Electoral Commission.

I suspect it will be down to charities to spell out the truths about immigration and climate change in the lead-up to the election, and to inform the debate on the environment and international development and build community and radicalism in public service reform. And you can be sure ACEVO won’t allow the Gagging Act to stop us pursuing our mission or on working with our CEOs to ensure we all continue to speak truth to power, whatever politicians might think about that. When the political parties fail to debate key issues then civil society must.

While I blog, it’s worth mentioning there is a good BBC Radio 4 programme on this topic tomorrow evening. Worth listening to – even the bits of me that they will use!

Opposition across the sector to Charity Commission strategy

This week the Charity Commission closed their latest consultation on their Annual Return for 2015. As one of the main regulatory tools, which makes up the Commission's Register, it is important to ask the right questions. We took a strong line at ACEVO (see our website here) in opposition to the Commission's proposals – which received third sector press coverage here, here and here. Here's our submission in full:

Association of Chief Executives of Voluntary Organisations (ACEVO)
Consultation response: Charity Commission Annual Return 2015
August 2014

General comments

ACEVO welcomes the opportunity to comment on the Charity Commission’s consultation on the Annual Return for 2015. We have discussed our initial concerns with Caroline Cooke, Head of Policy Engagement and Foresight at the Commission, and would welcome the opportunity of further discussion with the Commission if this is necessary. We also have discussed our response with ACEVO’s membership of 1500 charity and social enterprise leaders, through two calls to action online and through our regional engagement work right across the UK.

We are sympathetic to the imperfect options open to the Commission for increasing the data collected about charities – and we are aware of the constraints imposed by IT resources in the short term.

We also believe, however, that some of the Commission’s proposals for the Annual Return 2015, especially the proposed burdens placed upon charities’ historic right to campaign – are disproportionate and illogical.  We have grave reservations over their potential inclusion in any future Annual Return. We explain why in our submission below.
Q1 Do you agree with the proposal to introduce a question into the annual return to ask how much of a charity’s total expenditure has been on campaigning activities?

ACEVO is clear: this is a corrosive proposal for the reasons set out below.

Illogicality and irresponsibility

Charities exist for the furtherance of public benefit: to ‘do good.’ Charities do good both by providing services that help people, and also by recognising that no one charity can eliminate the harm entirely. That is why charities speak out, make connections with other charities and attempt to influence donors and statutory bodies to change the system in which the charity operates.

A charity’s service and its advocacy about the service are completely indivisible. It is illogical to suggest otherwise. Indeed, it would be a dereliction of duty for a charity seeking to alleviate harm to not speak about that harm or its experiences of alleviating harm so as to compel others to join in the struggle.

ACEVO’s Chief Executive Sir Stephen Bubb explained on BBC Radio 4’s World at One on 27 June 2014 that “charities’ work in delivering services is inextricably linked with our campaigning and advocacy roles”. To attempt to separate different parts of charities’ work towards their public benefit mission is deeply irresponsible. It risks creating the false impression that their campaigning work is somehow separable from, or an optional addition to, service delivery to beneficiaries.


On a practical level, accounting for a charity’s total spend ‘on campaigning activities’ is difficult when the Charity Commission has not precisely defined the scope of the term. In the words of one ACEVO member, “it would be hugely time consuming and difficult to define the difference between awareness raising and political lobbying”.

It is important to consider this proposal in the context of a range of pressures on charities’ ability to speak out in public on their beneficiaries’ behalf. These include limits placed on charities’ ability to speak out in an election year through the Government’s Transparency of Lobbying Act and limits on charities’ ability to criticise bad practice on the part of government by way of ‘gagging clauses’ in public service delivery contracts. These pressures – both of perception and practicality - are considerable. As such, we are strongly opposed to any regulatory measure that would increase the actual or implied pressure on charities that speak out. We trust that the Commission will agree with this analysis as the commitment expressed in its guidance document CC9, Speaking Out, is clear:

“Campaigning and political activity can be legitimate and valuable activities for charities to undertake.”

CC9 also makes clear that:

“Charities can campaign for a change in the law, policy or decisions where such change would support the charity’s purposes.”

ACEVO recommends in the strongest terms that the Charity Commission do not introduce a question on campaign spending into the Annual Return and that they resist any future pressure to do so.

Infantilisation of the public debate

We believe that the UK deserves a world class charity sector and that this requires a strategically focussed, innovative regulator. Across the world, forward thinking philanthropists are recognising the indivisibility of a non-profit organisation’s service and its voice. Mark Kramer’s article ‘Catalytic Philanthropy’, for example, refers to catalytic, next generation philanthropy as a synthesis of delivery and advocacy, or taking innovative social ideas and ‘mainstreaming’ them.[1] It is a matter of regret that on this matter the UK’s debate, which often is world leading on the subject of philanthropy, actually appears to be regressing. The Charity Commission must work harder to lead this debate, not follow it.

Q2 Do you agree with the proposal to introduce a question to the annual return to ask how much of a charity’s income was received from:
• public service delivery
• private donations?
Q3 If we did introduce the questions set out above is it feasible for charities to provide this information?

We are not against the idea in principle, but we oppose this proposal.

Submitting income from only these two sources would not give a clear picture of charities’ income. Grant funding from statutory sources, for example, would not be covered by either of these two headings.

The SORP Committee observed that this reporting was neither in the public interest nor was it proportionate. It would certainly place an unnecessary bureaucratic burden on charities that we cannot sanction unless further persuasive argument is given.

There is no doubt that the Commission are sincere in their desire to give effect to the PASC report. Only asking for these two items, however, adumbrates a further infantilisation of the important debate around charity and public service that is regrettable.

Q4 Do you agree with the proposal to ask whether a charity has a written policy on remuneration of executive staff?

ACEVO’s Good Pay Guide for Charities and Social Enterprises, published in December 2013 is the sector leading publication on executive pay. In it we made clear our organisation’s commitment to five principles of transparency and proportionality over staff pay and the principle that sits primus inter pares: value for money.[2] There is strong consensus across the charity sector on the need for transparency about pay – at all levels, not just in senior management. Charities are working towards this end irrespective of any pressure from the regulator.

At ACEVO we have been heartened by the positive response to these proposals and the extent to which charity remains among the most trusted of all the professions.

As such it is unclear whether a tick box of the kind proposed will make any tangible difference. The regulator should have a strategic vision for charities to follow, not simply ‘regulate’ for the sake of it. ACEVO believes it is unnecessary for the Charity Commission to ask about a ‘written policy’ on executive pay in the Annual Return. It will merely duplicate an initiative which is already widespread and self-enforced across the sector, and asking a simple yes/no question collects so little information that it will not substantively increase transparency about pay in the sector.

We do not agree with the proposal as written here. We may be amenable to a revised proposal that aligns explicitly with the SORP. Substantively, these requirements should not be extended to smaller charities; and if the question is to be included, it should explicitly be stated that answering is optional as good practice rather than as a regulatory requirement.

Q5 Do you agree with the proposal to introduce a question into the annual return for 2015 to ask if a charity has carried out a review of its financial controls during the reporting year?

We support good quality financial management in the charity sector. We have concerns, however, around whether this question is the correct way to go about getting them.

Given the diversity in the size of UK charities – by turnover and staff numbers – we do not think that it would be advantageous to ask all charities whether they have reviewed their financial controls. This would risk creating an expectation that charities should review their financial controls every year. In small charities which may not have paid staff it is hard to imagine that creating such an expectation would be advantageous to the sector’s smooth operation or to the public’s trust in it.

Furthermore, the question may not actually yield appropriate information. Charity Commission guidance CC8 contains the checklist that many charities would use. Whether capacity exists to fully instantiate those controls within the smaller charities on an annual basis is unclear. We are concerned that the annual requirement would create a perverse incentive and many smaller charities might simply wave through the ‘checks.’ This is not quality financial management but regulation by box ticking, and would not substantively deal with the problem. As such we cannot agree with this proposal.

Q6 Do you agree with the proposal to ask charities with incomes of between £10,000 and £500,000 to provide some key financial information through the annual return?

We understand that the regulator is keen to collect data about the smaller end of the charity market, but it must remember that its most basic aim must be to do no harm.

Small charities are particularly vulnerable to excessive bureaucratic burdens. ACEVO believes this proposal would, if implemented, need to be optional. We want the charity sector to be being as transparent as reasonably possible, but making this requirement mandatory could add unnecessary pressure on smaller organisations, especially those without paid staff. In the case of organisations with incomes as low as £10,000, we strongly feel that being compelled to submit this information is particularly contrary to the public interest. The only justification we can see is that it would be convenient for the regulator, which we do not feel would be sufficient.

[1] Mark Kramer, ‘Catalytic Philanthropy’, Stanford Social Innovation Review ((2009).
[2] ACEVO, The Good Pay Guide for Charities and Social Enterprises (December 2013).