Decision

Charity inquiry: Al-Manar Centre Trust

Published 11 July 2025

Applies to England and Wales

The Charity

Al-Manar Centre Trust (the ‘charity’) was established by a declaration of trust dated 21 May 2009. The charity was entered onto the Register of Charities on 18 June 2009.

The objects of the charity are:

• to advance and support the Islamic education of all Muslims, providing facilities for regular prayer meetings for Sunni Muslims
• to foster community relationships and religious harmony in Cardiff and the surrounding area
• to advance the education of the public in the Islamic faith through the study of the Qur’an and the Arabic language
• the relief of unemployment amongst Muslims for the benefit of the public in such ways as may be thought fit, including assistance to find employment
• to help young people, especially but not exclusively through leisure time activities, so as to develop their capabilities that they may grow to full maturity as individuals and members of society
• to relieve poverty, sickness and distress arising therefrom of individuals of the Islamic faith

As part of its activities, the charity operates a mosque in Cardiff. The charity’s entry can be found on the Register of Charities.

Background and issues under investigation

On 22 January 2024, the Charity Commission for England and Wales (the ‘Commission’) became aware of a video (the ‘Video’) posted on the charity’s Facebook page on 2 November 2023.

The Video, in Arabic, featured footage of Hamas’ military wing, the Izz ad-Din al-Qassam Brigades, a proscribed organisation since 2001 under the Terrorism Act 2000 (with the entirety of Hamas proscribed since 2021). Upon consideration, the Commission took the view that the footage could be interpreted as extremist content, as it presented a positive image of Hamas, attempted to downplay and/ or justify its terrorist attack against Israel on 7 October 2023, and/ or was supportive of or glorified terrorism. In particular:

• the Video shows the release of two female Israeli hostages following Hamas’ terrorist attack on Israel on 7 October 2023, during which the narrator of the Video says (emphasis added by the Commission):

“A war that confuses the perpetrator and the victim and between this and all of that, those being attacked free two of their prisoners without any condition and the only reason is compassion towards their health condition. Only for us to see one of them goes to greet one of her jailers saying goodbye before leaving in a view that has never been expected by the ones stating the rules of imprisonment nor has our modern world seen something like it and this was for an enemy known for killing the prisoners and the mutilation of the innocent civilians. So that these Muslim fighters show us that the image the world has distorted which is that the ethics of the wars and imprisonment in Islam compares to anything of the violators and war criminals. This is not  strange from the fighters whose justice is their slogan and who they learnt from the work of their Lord, “And fight for Allah those who fight you and do not commit aggression for Allah does not love aggressors”…”;

• the Video shows armed members of Hamas’ military wing taking part in what appears to be military exercises and parading with firearms
• the Video ends with a generated image of a person paragliding above a religious building resembling the Al-Aqsa Mosque in Jerusalem. With the image of the paraglider visible, the narrator concludes with the following:

“He is Allah, the owner and the creator of the Earth and the one who gives to whom he wills from his good servants to conquer in his precious name. Maybe the Crusaders forgot about this just like their counterparts tend to forget. Those that algorithms do not like us when we bad mouth them but Hattin hid the traces of their ancestors after 90 years in the dust of history. Their Hattin so not that far from us with Allah willing.”

(The Battle of Hattin took place in 1187 in Northern Palestine, marking the defeat of the Christian Crusader armies and capture of Jerusalem by Muslim forces.)

On learning about the Video, the Commission opened a regulatory compliance case and obtained an independent translation of the Video. The Video is no longer available on YouTube (or the Charity’s Facebook page which posted the YouTube video). However, it remains available online, via the organisation that published it, on X (formally known as Twitter).

On 23 January 2024, the Commission wrote to the trustees requiring them to answer questions and provide relevant documents in relation to the Video.

On 30 January 2024, the trustees informed the Commission that the charity had suspended all publication of content on its social media platforms and that the Video had been removed. The trustees also informed the Commission that an “internal review” had been initiated, which was expected to take two weeks.

On 14 February 2024, the trustees provided the Commission with the findings and recommendations of the internal review, which was carried out by a third party organisation (the ‘Third Party Report’). The Third Party Report recorded that the review took place between 30 January 2024 and 12 February 2024. The review found that:

• the charity’s chair trustee, who was responsible for inspecting audio and video proposed for publication across the charity’s social media platforms, was the person responsible for posting the Video on the charity’s Facebook page. The charity’s other trustees were unaware that the Video had been shared by the chair trustee
• the Video “contained images linked to proscribed organisations” and “could be misconstrued as endorsing violence although the message of the entire video was shedding light on the history of the Holy Land”
• the “various imagery used in the video was established as being problematic, thus causing reputational damage to the charity as well as a failure to meet its objectives”
• The Video “shouldn’t have been shared and was removed immediately when this was brought to the charity’s attention” by the Commission
• the content of the Video “had not been inspected properly” and only the audio was vetted due to “circumstantial reasons”. Those reasons were said to be that the chair trustee was “overwhelmed with duties and resorted to listening to the clip while driving home after a busy day”. Accordingly, “a proper, full vetting of the video did not take place”
• the chair trustee deemed that the audio of the Video aligned with the charity’s objectives and aims but acknowledged that “had the due process [been] followed, the video in question would not have been posted on the charity’s social media platforms…due to the reputational risks it poses to the charity as well as the possible inference for support for violence”
• the chair trustee “expressed his regret for the oversight and accepted full responsibility”

The Third Party Report concluded that segments of the Video could be misconstrued as endorsing violence and promoting a proscribed organisation. It noted that inadequate inspection and vetting led to this oversight and subsequent publication of the Video.

The Third Party Report went on to recommend that the charity implement a more comprehensive social media policy to replace the then existing one.  

In response to questions raised by the Commission, on 14 February 2024, the trustees explained that the Video’s intent was to highlight topics like the history of the Holy Lands and the Islamic principles governing moral conduct in warfare. The trustees further explained that the Video covered the history of the Children of Israel, as referenced in the Qur’an, and the Crusades.  

The trustees added that, when the Video was shared, the Cardiff community and congregation were profoundly impacted by the tragedies in the Occupied Palestinian Territories, and the Video was meant as a source of solace in alignment with Islamic teachings. However, as soon as the Commission brought the trustees’ attention to how the Video could be interpreted, the Video was immediately removed.

The trustees set out to the Commission that they unequivocally condemn any exploitation of the events in the Middle East to foster hatred and division, and are committed to fostering unity, compassion, and understanding across all communities, regardless of faith or background.

While the Commission recognised that part of the Video referred to historical matters, such as the Crusades, it did not negate the fact that parts of the Video could be interpreted as justifying or downplaying a terrorist attack in Israel, resulting in mass casualties. This interpretation was strengthened by the absence of any condemnation of Hamas’ actions.

While the Commission recognised the trustees’ responsive actions once alerted, serious regulatory concerns remained. These concerns included, in light of the failure to properly vet the Video, the possible existence of other inappropriate material on the charity’s social media platforms and the adequacy of controls in place for use of social media.

In consequence of the above, on 28 February 2024, the Commission took the decision to open a statutory inquiry (the ‘inquiry’) into the charity under section 46 of the Charities Act 2011 (the ‘Act’). The charity’s trustees were notified of the inquiry on 29 February 2024 and it was publicly announced on 7 March 2024.

The scope of the inquiry considered the trustees’ administration, management, and governance of the charity, with particular regard to the charity’s social media and website controls, and the circumstances surrounding the Video’s posting.

The inquiry’s role was not to decide questions of criminal liability or illegality, that is a matter for the police and/ or other authorities. The Commission’s role as charity regulator is to oversee charity trustees’ compliance with charity law duties and responsibilities.

On 29 February 2024, the inquiry issued a direction under section 47 of the Act, compelling the charity’s trustees to provide information and documents related to the posting of the Video.

At the time the inquiry was opened, the charity had four trustees, all of whom were in office when the Video was posted.^{[footnote 1]} A fifth individual was appointed as a trustee in September 2024, after both the posting of the Video and the opening of the inquiry. Accordingly, the findings and conclusions of this inquiry do not relate to the fifth trustee.

Findings

On 15 April 2024, the inquiry conducted interviews with the charity’s trustees, including a separate interview with the charity’s chair trustee, who had posted the Video.

The inquiry’s findings are based on these interviews, together with written correspondence and documentation provided by the trustees, and other relevant material obtained during the course of the inquiry.

The Video

The inquiry established that the Video was not produced by or for the charity, but by an organisation with which the charity had no relationship with.

The Video was shared via the charity’s Facebook page by the chair trustee, who held sole responsibility for posting content via the charity’s social media platforms. This function was carried out without any oversight from the charity’s other trustees. At the time, the charity’s social media policy – adopted in September 2023 – consisted solely of a flowchart. Further details concerning the charity’s social media controls are set out below under the heading, ‘the charity’s social media policy’.

The inquiry sought to understand how the chair trustee first encountered the Video. When asked about this at interview, alongside other certain questions pertaining to the Video, the solicitor acting for the charity advised the chair trustee not to respond to those questions, and the chair accordingly declined to answer. The solicitor also advised the other trustees to refrain from answering certain questions about the Video. However, those trustees did engage with the inquiry and answered the inquiry’s questions in full. The trustees acknowledged that it had been a mistake to share the Video and confirmed it had been removed as soon as the Commission raised concerns.

Following the inquiry’s interviews of the trustees, the chair had further opportunities to offer their account to the inquiry as to how they first encountered the Video. Despite these opportunities, no details have been forthcoming. The inquiry was therefore unable to establish the circumstances under which the Video came to the chair’s attention.

How the Video came to be shared has been set out above in the ‘background’ section. In summary, and for ease of reference, the chair listened to the audio of the Video only and deemed the Video appropriate to share.

The inquiry found that the chair failed to adequately review the Video prior to sharing it on the charity’s Facebook page. As the proposed content was a video, a review of the audio alone was wholly insufficient. Further, and in the inquiry’s view, even reviewing just the audio, the chair should have recognised from the excerpts set out in this report that its content could be interpreted as supporting Hamas’ actions. The inquiry heard that the chair trustee was “overwhelmed” at the time of the incident, which was a contributing factor in the Video failing to be properly scrutinised.

The charity’s other trustees only learned of the Video when informed by the Commission two months after it was shared.

In their initial correspondence to the Commission, the trustees described the Video as an educational one, with the purpose of explaining “various features of Islam and Islamic history as it responds to current societal trends” and the charity merely shared it.

The Commission acknowledges that charities can engage in activity that is controversial, which includes viewpoints that may shock or offend (and that charities have freedom of expression). However, in this case, the narration of the Video portrayed a proscribed terrorist organisation in a positive light; it is not in question that the Video featured footage of the military wing of Hamas. In the inquiry’s view, the Video contains content which presents a positive image of Hamas and its terrorist attack against Israel on 7 October 2023, and attempts to downplay and/ or justify Hamas’ terrorist attack. Further, it is the inquiry’s view that the Video was likely to lead an ordinary member of the public to infer that the charity was supportive of and/ or glorified terrorism.

The Video could therefore be understood as demonstrating support, on the part of the charity, for Hamas, and thus put the charity’s reputation at risk which is a resource of the charity.

Further, the inquiry considered that the Video did not further the charity’s objects (which are related to religion, the relief of poverty and helping young people) and was not for the public benefit.

At the time the Video was shared by the chair trustee, it was done so without oversight by the other trustees or proper controls in place and there can be no excuse for a failure to properly inspect content to be shared by the charity. Trustees of a charity are expected to further its objects, act in its best interests and protect its reputation. They are also expected to have familiarised themselves with the Commission’s guidance on social media, and protecting charities from abuse for extremist purposes. In this matter, the inquiry was not satisfied that, at the time the Video was shared, the charity’s trustees were sufficiently aware of their duties in this regard.

The inquiry concluded that the sharing of the Video constituted misconduct and/ or mismanagement in the administration of the charity. While the chair trustee was responsible for sharing the Video, the trustees are collectively responsible for the management and administration of the charity. Therefore, the failing here is a collective one, including on the part of the charity’s trustees regarding adequate diligence and monitoring of online content posted by the charity. Furthermore, the failure here is aggravated as the Commission has previously given regulatory advice and guidance to the charity concerning social media use. Further information about this is set out below under the heading, ‘the charity’s social media policy’.

The inquiry acknowledges that the trustees engaged constructively with the Commission after the issue of the Video was raised. They promptly removed the Video, commissioned a review by a third party, and took steps to strengthen internal controls. Furthermore, the chair trustee expressed his regret and accepted full responsibility for sharing the Video. While these actions are noted, they do not absolve the trustees of their responsibility and culpability for what occurred. The corrective steps taken were reactive, prompted by the Commission’s intervention, rather than a result of the trustees identifying the issue themselves.  

The inquiry sought to understand whether any disciplinary action would be taken against the chair, by the charity’s other trustees, in light of the Video being posted. In response, the trustees confirmed that this had been carefully considered. After reflecting on a range of factors, they reached a collective view that formal disciplinary action would not be proportionate in the circumstances.

The trustees also explained that they are committed to continuous improvement and, to this end, had taken steps to strengthen the charity’s internal procedures. The trustees, including the chair, have (post the opening of the inquiry) also attended and participated in Commission training on the use of social media by charities, and the duties of trustees in the context of faith-based charities.

The charity’s social media policy

The inquiry found that, at the time the Video was shared, the trustees had failed to ensure that adequate controls and procedures were in place governing the use of social media.

The charity’s social media policy in place at the time – adopted in September 2023 – consisted solely of a flowchart. This document lacked sufficient detail, failed to provide clear guidance, and did not include provisions for risk assessment, oversight, or record-keeping.  

The flowchart first required the decision-maker to determine whether the proposed publication had “value”. If so, the second question required the decision-maker to ask whether the proposed post aligned with the charity’s objectives. If the answer to that question was negative, the decision-maker was required not to post the publication; otherwise, the decision-maker was required to consider a series of further questions relating to the proposed format, availability of visual assets and timing of the publication.

The inquiry found that the charity’s social media policy failed, in a number of respects, to meet the requirements expected by the Commission of a social media policy. The trustees acknowledged that the policy was inadequate in preventing the Video from being posted.

An aggravating factor in this case was the Commission’s prior engagement with the charity in 2014, during which the charity was provided statutory regulatory advice and guidance, under section 15(2) of the Act, on protecting charities from abuse for extremist purposes. That guidance explained that trustees must ensure their charity’s activities do not promote violence, racial or religious hatred, or encourage or glorify terrorism, or incite criminal acts or public order offences. The guidance also set out that trustees must not engage in conduct or activities which would lead a reasonable member of the public to conclude that the charity or its trustees were associated with a proscribed organisation or promoting or supporting terrorism.

Although social media was not the primary focus of the 2014 engagement, the trustees informed the Commission at that time that the charity undertook limited monitoring of third-party content on its social media platforms and generally did not publish material. The Commission advised the charity that maintaining an online presences without effective monitoring  left the charity vulnerable to reputational risk, particularly if third parties posted inappropriate material. The Commission recommended the following:

“The trustees must take all reasonable steps to protect the assets of the Charity including its reputation. The trustees should develop written policies and procedures to control what material is added to the Charity’s website and social media and how this is regularly reviewed. This should include checking that any media associated with the Charity furthers its charitable purposes for the public benefit and is appropriate.

The trustees should ensure their decision making is fully documented, following the principles of good trustee decision making. Any inappropriate material that is identified during the review should be removed or amended.”

The inquiry considers that the incident involving the Video could have been prevented had the charity implemented and followed the regulatory advice and guidance provided by the Commission in 2014, concerning the charity’s use of social media. At the time the Video was posted in November 2023, three of the charity’s trustees, including the chair who posted the Video, were also in post when the Commission issued its regulatory advice and guidance in 2014. As such, they should have been familiar with the Commission’s expectations regarding the responsible use of social media and taken steps to ensure those standards were upheld.

The inquiry therefore found that there were failings on the part of the trustees in relation to the charity’s social media policy and associated controls. The trustees  failed to act in the charity’s best interests and did not manage its resources responsibly, exposing the charity’s reputation to unnecessary risk. These failings, including the then trustees failing to follow previous regulatory advice and guidance, constituted misconduct and/ or mismanagement in the administration of the charity.

Following the Commission’s intervention, the trustees have since implemented significantly improved procedures governing the charity’s use of social media. If properly followed, they will provide an appropriate level of protection. However, this does not detract from the charity’s then existing policy and controls being insufficient such as to result in the Video being posted on the charity’s social media.

On 1 October 2024, the inquiry made an Order under its statutory powers directing the trustees to take specified actions in relation to the charity’s historic and ongoing use of social media. Further details are provided below under the section, ‘regulatory action taken’.

Conclusions

Trustees are publicly accountable and have a responsibility and duty of care to their charity which includes taking the necessary steps to safeguard the charity and its beneficiaries from harm of all kinds, including damage to its reputation. Trustees must therefore not engage in conduct or activities which would lead a reasonable member of the public to conclude that the charity or its trustees are associated with, or support, a proscribed terrorist organisation or terrorism. This is because links between a charity and terrorist activity corrode public trust and confidence in the integrity of the charity and of the sector generally.

The Commission concluded that the sharing of the Video was wholly inappropriate for the reasons set out above and risked causing significant damage to the charity’s reputation, and that the conduct of the charity’s trustees – in particular that of the chair trustee – fell below the standard it expects of those which hold this position. In particular, the Commission considers that the trustees should have been more alive to the risks when posting on social media given the Commission’s previous involvement with the charity, and guidance given to it (which also included guidance in relation to social media), in 2014.

The Commission was therefore satisfied that there was misconduct and/ or mismanagement in the administration of the charity by its trustees.

Regulatory action taken

Information gathering powers

The inquiry exercised the Commission’s information gathering powers under section 47 of the Act on multiple occasions both to obtain documents and answers to questions.

During the inquiry, the Commission exchanged information with the police in relation to the Video under sections 54 and 56 of the Act.

The Commission’s power to direct specified action to be taken

On 1 October 2024, the inquiry exercised the Commission’s power under section 84 of the Act and made an Order directing the trustees to take specified actions in relation to the charity’s use of social media.  

The Order was made on the basis that the inquiry was satisfied that, at the time, there had been misconduct or mismanagement in the administration of the charity.

The Order required the trustees to:

• adhere to the procedures set out in the charity’s newly adopted social media policy for all posts and content on the charity’s website and social media platforms
• immediately report to the Commission any unauthorised content(referred to in the policy) on the charity’s website and social media platforms and take steps to remedy this
• review all existing content on the charity’s website and its social media platforms, and provide written confirmation to the Commission that they were satisfied all such content is consistent with the charity’s objects and complies with its social media policy
• submit to the Commission an overview of the role being carried out by each of the trustees, and an explanation of how they intend to act and make decisions collectively

On 17 December 2024, the trustees informed the inquiry of the actions taken in response to the Order. Following a review of the information provided, the inquiry was satisfied that the trustees had fully complied with the requirements of the Order.

Official Warning

Also on 1 October 2024, the inquiry gave formal notice, as is required under the Act, of the Commission’s intention to issue the charity with an Official Warning under section 75A(1)(b) of the Act.

The Official Warning was proposed in respect of the charity sharing the Video and due to a lack of an adequate social media policy.

On 27 October 2024, the trustees made representations and sought an internal review of the proposal to issue the charity with an Official Warning.

These representations were considered by an independent reviewer (the ‘Reviewer’) as part of the Commission’s decision review procedure. On 9 April 2025, the Reviewer concluded that the Commission’s intention to issue the charity with an Official Warning was reasonable, proportionate, and lawful – as such, the Reviewer determined that the Commission proceeds to issuing it. This decision represented the final decision of the Commission.

On 9 April 2025, the Official Warning was issued to the charity.

Issues for the wider sector

The purpose of this section is to highlight the broader issues arising from the Commission’s assessment of the issues raised publicly that may have relevance for other charities. It is not intended as further comment on the charity in addition to the findings and conclusions set out in the earlier sections of this report but is included because of their wider applicability and interest to the charity sector.

Governance

Trustees are representatives of the charity they govern or the charitable funds they are responsible for, in the charity sector. Trustees must be aware of and act in accordance with their legal duties. The conduct of trustees can be a key driver of public trust and confidence in the charity sector. When the conduct of trustees falls below the standards expected there can be damage to the reputation of individual trustees, the charity and possibly the wider charity sector.

All charities should have appropriately tailored internal policy documents which address the specific risks associated with the kind of activities that are undertaken. A failure to implement internal policies (and follow them) can put assets, beneficiaries, and a charity’s reputation at risk.

Terrorism

Trustees must be vigilant to ensure that a charity’s premises, assets, staff, volunteers and other resources cannot be used for activities that may, or appear to, support terrorist activities.

Where a charity’s activities may, or appear to support, condone or encourage terrorist activity and terrorist ideology, trustees should take immediate steps to make clear it does not support terrorist or violent activities and views, these are not the charity’s views and that it does not condone or support them. If there is a close association between the activities and a terrorist group, the charity is likely to have to stop those activities.

Social media

Social media can be a powerful communication tool for charities, to raise awareness and funds and to better engage beneficiaries. It can help charities reach a much wider audience, much more quickly, than traditional methods of communication. But it can introduce risks.

The duties of trustees to act in their charity’s best interests and to protect its property – which includes its reputation – apply equally to a charity’s use of online and social media platform as it does to other areas of its work. If trustees decide to utilise social media and a website in the charity’s name, they need to ensure that it is regularly monitored and its content reviewed, and take action to deal with inappropriate or illegal content that is posted. This applies equally to content posted by the charity itself as well as comments or responses made by third parties. Responsibility for monitoring can be delegated, but must be overseen by the trustees who jointly retain ultimate responsibility.

If trustees decide to use websites and social media but cannot devote sufficient resource or implement effective controls to monitor online content and posts, they should question whether and how it is in their charity’s best interests to utilise these platforms. As with all of a charity’s activities, information posted or published online must directly relate to and further the charity’s objects as set out in its governing document. Charities must operate for the public benefit which includes ensuring that a charity’s activities do not cause undue harm or detriment to other people – this could include publishing or promoting comments or views which are disparaging or disrespectful towards those who fall within the protected characteristics set out in the Equality Act 2010. Any material posted on a charity’s website or social media platforms which crosses a criminal threshold and is in breach of UK law is a matter for the police and/or other authorities, but would also constitute evidence of mismanagement and/ or misconduct within a charity’s administration and a clear breach of a trustees’ duty to comply with the law.

If your charity uses social media, the trustees are responsible for:

• agreeing and putting in place a social media policy so that you have internal controls that are appropriate and proportionate for your charity’s needs and which are clear to everyone at the charity using social media
• ensuring your social media policy is regularly reviewed to check it is working effectively and fits your charity’s needs
• ensuring your charity’s social media helps you achieve your charity’s purpose (what your charity was set up to do) and in a way that is in your charity’s best interests
• complying with relevant laws
• ensuring any campaigning or political activity that your charity does on social media complies with the rules on political activity and campaigning
• ensuring your processes help you keep people safe online including any extra considerations when dealing with vulnerable users

1. One of these trustees resigned from their position in December 2024. ↩