Decision

Charity inquiry: Education for Gondar, and formerly registered charities Education in Sidama, Education for Nyanza and Education in Western Province

Published 23 April 2025

Applies to England and Wales

The charities

The charities included in the class inquiry were all charitable incorporated organisations (‘CIOs’), governed by constitutions.

Education for Gondar

Registered with the Commission on 27 June 2018.  The charity’s objects are:

For the public benefit to promote the education of people under the age of 18 years living in the Gondar region of Ethiopia in such ways as the charity trustees think fit, including by:

• awarding to such persons scholarships, maintenance allowances or grants connected with the attendance of any school, university, college or institution or further or higher education
• providing their education, undertaking travel in furtherance of that education or preparing them for entry to any occupation, trade or profession on leaving any educational establishment
• supporting schools in the region, including building or maintaining schools, providing teachers at such schools and supporting teacher training for schools in the region
• Recruiting UK based volunteers to travel to the region to act as teachers, mentors and in any other roles supportive of these objects as the trustees deem fit.

Education for Gondar is in the process of being dissolved, and once this process has been completed the charity will be removed from the Commission’s register of charities.

The charity’s entry can be found on the Commission’s register of charities.

Education in Sidama

Registered with the Commission on 5 March 2021. The charity’s objects were:

For the public benefit to promote the education of people under the age of 18 years old living in the Sidama region of Ethiopia in such ways as the trustees think fit, including by:

Awarding to such persons scholarships, maintenance allowances or grants connected with the attendance of any school, college or other institution of education in the Sidama region;
Supporting existing schools, colleges or other institutions of education in the Sidama region by providing funds to help with the running of such institutions, including but not limited to funding the provision of teachers, buildings, educational materials and general running costs.

Education for Sidama was dissolved on 6 December 2024 and is recorded as a removed charity on Commission’s register of charities.

Education in Western Province, Kenya

Registered with the Commission on 21 June 2021. The charity’s objects were:

For the public benefit to promote the education of people under the age of 18 years old living in the Western Province of Kenya in such ways as the trustees think fit, including by awarding to such persons scholarships, maintenance allowances or grants connected with the attendance of any school, college or other institution of education in the Western Province of Kenya.

Education in Western Province, Kenya was dissolved on 6 December 2024 and is recorded as a removed charity on the Commission’s register of charities.

Education for Nyanza

Registered with the Commission on 6 July 2021. The charity’s objects were:

For the public benefit to promote the education of people under the age of 18 years old living in the Nyanza province of Kenya in such ways as the trustees think fit, including by:-

awarding to such persons scholarships, maintenance allowances or grants connected with the attendance of any school, college or other institution of education in the Nyanza province; Supporting existing schools, colleges or other institutions of education in the Nyanza province by providing funds to help with the running of such institutions, including but not limited to funding the provision of teachers, buildings, educational materials and general running costs.

Education for Nyanza was dissolved on 6 January 2025 and is recorded as a removed charity on the Commission’s register of charities.

Background

In August 2023 the Commission received nine charity registration applications which were linked to a company called MWA Management Advisory Services Ltd (company number 12251805). The sole director and member of MWA Management Advisory Services Ltd is Richard Gary Lorrison (‘Mr Lorrison’).

The Commission then identified four registered charities (Education for Gondar, Education for Nyanza, Education in Western Province, Kenya, and Education in Sidama) which also appeared to be connected to Mr Lorrison and MWA Management Advisory Services Ltd.

On 25 August 2023 the Commission selected Education for Gondar for proactive engagement to determine whether there were any regulatory concerns. Following this, the Commission opened compliance cases into the three other charities.

The Commission found that the four charities showed similarities in the pattern of trustee appointments as well as common linked addresses. The Commission identified that all the accounts for all four of the charities had been signed off by Mr Lorrison. Mr Lorrison was also a trustee and the Chair for Education for Gondar.

All charities must maintain accounting records and prepare accounts. A charity’s accounting information must be submitted to the Commission within 10 months of the end of the financial year to which they refer. All the charities were in default with their accounting requirements as the trustees had failed to submit their accounts for financial year ending (‘FYE’) 31 January 2023 within the required time.

The Commission identified that the four charities’ previous accounts were not compliant with the Statement of Recommended Practice (‘SORP’). For example, in the case for Education for Gondar, the information provided in the accounts for FYE 31 January 2022 does not match that in the Annual Return for the corresponding year, which shows income of £195,125.00 (compared to an income of £244,730 declared in its accounts for the same year).

For FYE 31 January 2022, the Commission also identified that there were similarities in the wording of the trustees’ annual report (‘TAR’) for all four charities, all of which were signed by Mr Lorrison. The ‘Public Benefit’ paragraph in the TAR for each of the four charities was identical, including the same grammatical error. The ‘Achievements and Performance’ paragraph in the TAR for each charity was also very similar and, in some places, identical.

As a result of these regulatory concerns all four compliance cases were escalated to a statutory class inquiry (‘class inquiry’) opened under section 46 of the Charities Act 2011 (‘the Act’). When the Commission opens inquiries into a group of charities these are known as ‘class’ inquiries.

The class inquiry was opened on 01 February 2024.

Issues under investigation

The scope of the class inquiry was to examine:

The extent to which the charities’ trustees complied with their legal duties in respect of the administration, governance and management of their charities, with particular regard to:

• the management of their charities’ finance
• accurately accounting for their charities’ funds and assets in accordance with legal requirements
• unauthorised payments to trustees or connected persons
• ensuring their charities’ objects are being met and the charities were operating for the public benefit

The class inquiry closed with the publication of this report.

Findings

Unauthorised payments to trustees or connected parties

The class inquiry found that £ 270,717.69 had been transferred from the bank accounts of Education for Gondar and Education in Sidama to the personal bank account of Mr Lorrison.

The class inquiry found from the analysis of the bank statements for Education for Gondar that between 11 September 2018 and 4 July 2022 the only funds deposited into the account were HMRC Gift Aid payments totalling £187,828.75. Immediately upon receipt of each payment (the same or next day), the Gift Aid payments were transferred into a private current account in the name of Mr Richard Gary Lorrison.

The class inquiry analysed the bank statements for Education in Sidama and found a similar pattern. Through 15 separate payments between 28 July 2021 and 10 June 2022, a total of £82,888.94 was paid by HMRC in Gift Aid into Education in Sidama’s bank account. The value of these payments, or an amount within £20.00, was then immediately transferred (the same or next day) into the personal bank account of Mr Lorrison.

The class inquiry found that the bank statements for Education for Gondar and Education in Sidama’s bank accounts did not evidence either of them having received any donated funds or grants.  The information in the bank statements for both charities therefore provided no evidence that they received any donations for which a Gift Aid claim could have been made.

Furthermore, none of the trustees were able to explain or evidence to the class inquiry the donations on which the Gift Aid claims were based.

Throughout the course of the investigation the class inquiry sought to contact Mr Lorrison and the other trustees in order to gather information as to why these payments were made to Mr Lorrison. Mr Lorrison never responded to the class inquiry’s contact attempts and failed to comply with orders and directions of the Commission. Failure to comply with orders and directions of the Commission is misconduct and/or mismanagement in the administration of the charities.

The class inquiry found that the trustees of each of the four charities were unable to provide any evidence of charitable expenditure and in relation to Education for Gondar and Education in Sidama, were unable to explain why these payments had been made into Mr Lorrison’s personal bank account.  Consequently, there is no evidence that these payments were made in furtherance of a charitable purpose, and the class inquiry therefore considers that the Gift Aid payments were misappropriated by Mr Lorrison. This is misconduct and/or mismanagement in the administration of the charities by the trustees and Mr Lorrison.

Governance

Throughout the course of the investigation the class inquiry sought to engage with Mr Lorrison and the other trustees in order to gather information in relation to the regulatory concerns.  Whilst Mr Lorrison failed to co-operate, the other trustees engaged with the investigation.

The class inquiry found that across the four charities, Mr Lorrison had advertised the role of trustee (and in some cases offered small payments) on job recruitment sites. He then interviewed prospective candidates, who were then appointed as trustees. Mr Lorrison then stated he would be in touch. Mr Lorrison then ceased all contact with the trustees. All the trustees Mr Lorrison recruited across the four charities had no involvement with the charities and were completely unaware of the concerns raised by the investigation until the class inquiry engaged with them.

The class inquiry found that the trustees had no knowledge of the payments to Mr Lorrison, the charity administration or even the identity or contact details for one another. The class inquiry found that Mr Lorrison had sole control over all the charities as well as their bank accounts. The trustees were effectively trustees in name only. This is a failure of the trustees to fulfil their legal duties and responsibilities as trustees and is misconduct and/or mismanagement in the administration of the charities. It is, however, clear that Mr Lorrison used these individuals without their knowledge or involvement to give the impression that the charities had the appropriate governance and oversight.

Accounts

As detailed above, all the charities’ accounts were in default with the submission of their accounting information for FYE 31 January 2023. These accounts were never submitted to the class inquiry despite the trustees being directed to provide them. A failure to submit accounts and/or an annual return to the Commission within the required timeframe is a criminal offence and constitutes misconduct and/or mismanagement in the administration of the charities.

The class inquiry found that across all four charities, that none of their previously submitted accounts were compliant with the SORP. Charity trustees are responsible for ensuring their charity complies with the law and is accountable. This failure to comply with the SORP is misconduct and/or mismanagement in the administration of the charities.

Operating for the public benefit

The class inquiry found that none of the four charities were or had ever operated for the public benefit. No evidence was provided to the class inquiry to show how the charities met their objectives despite evidence being requested. This is misconduct and/or mismanagement in the administration of the charities.

The trustees all confirmed that the charities were not operating and therefore the class inquiry sought to dissolve the charities.

Conclusions

The Commission concluded that there was serious misconduct and/or mismanagement in the administration of the charities due to the poor financial management and governance.

The Commission concluded that the trustees failed to manage their charities or discharge their duties as trustees by failing to act to ensure sufficient oversight of the activities of the charities. This failure to act constitutes a breach of their trustee duties and is misconduct and/or mismanagement in the administration of the charities.

The Commission concluded that Mr Lorrison set up and used the charities in order to personally benefit from them and as a result was removed as a trustee under section 79(4) of the Act meaning that he has been disqualified from acting as a trustee in any charity.

Regulatory Action Taken

On 26 February 2024 the inquiry made two orders not to part with charitable property, under section 76(3)(d) of the Act, the impact of which was to freeze the bank accounts for Education for Nyanza and Education in Western Province, Kenya. The Commission attempted to make similar orders in relation to Education for Gondar and Education in Sidama, but these accounts were closed prior to the class inquiry being opened.

The inquiry exercised its powers under section 47(2)(a) and (b) of the Act on several occasions to obtain information and documentation from the trustees and a range of third parties.

On 30 May 2024 the class inquiry exercised its powers under section 76(3)(a) of the Act to suspend Mr Lorrison from the exercise of his trusteeship of Education for Gondar.

On 30 May 2024 the inquiry exercised its powers under section 79(4) of the Act to remove Mr Lorrison from the position of trustee. This order came into effect on 2 July 2024. Consequently, Mr Lorrison is disqualified from acting as a trustee in any charity.

On 31 July 2024 the inquiry exercised its powers under regulation 16 of the CIO (Insolvency and Dissolution) Regulations 2012/2013 to issue its notice of intention to dissolve Education for Gondar and Education in Western Province, Kenya. Education in Western Province, Kenya was dissolved on 6 December 2024 and removed from the register of charities.

On 13 August 2024 the inquiry exercised its powers under regulation 16 of the CIO (Insolvency and Dissolution) Regulations 2012/2013 to issue its notice of intention to dissolve Education in Sidama. The Charity was dissolved on 6 December 2024 and removed from the register of charities.

On 13 September 2024 the inquiry exercised its powers under regulation 16 of the CIO (Insolvency and Dissolution) Regulations 2012/2013 to issue its notice of intention to dissolve Education for Nyanza. The charity was dissolved on 6 January 2025 and removed from the register of charities.

On 3 February 2025 comprehensive regulatory advice and guidance under section 15(2) of the Act was issued to each of the trustees.

Issues for the wider sector

The abuse of charities for unlawful purposes is absolutely unacceptable. In instances where the Commission uncovers or has evidence to suggest that a civil or criminal offence may have been committed, we will share this information, through our statutory gateway, with the police and other relevant agencies.

Charities can be attractive to criminals to disguise unlawful activities. The Commission will seek and support prosecution where they believe that criminal activity relating to maladministration or fraud occurs in respect of a charity.

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.

Trustees must:

• act within their powers
• act in good faith and only in the interests of the charity
• make sure they are sufficiently informed
• take account of all relevant factors
• ignore any irrelevant factors
• manage conflicts of interest
• make decisions that are within the range of decisions that a reasonable trustee body could make

It is important that charity trustees apply these 7 principles when making significant or strategic decisions, such as those affecting the charity’s beneficiaries, assets or future direction. Further guidance and advice on trustee duties can be found on GOV.UK.

Charity accounting requirements become increasingly rigorous the larger a charity is. There are legal requirements for charities relating to the preparation of charity accounts and annual reports, the audit or independent examination of accounts and the submission of these to the Commission. Trustees must familiarise themselves with the appropriate requirements.

Registered charities are required by law to provide annual returns and accounts to the Commission. The type of scrutiny required depends on the income and assets of the charity. Broadly speaking, an independent examination is needed if gross income is between £25,000 and £1 million and an audit is needed where the gross income exceeds £1 million. An audit will also be needed if total assets (before liabilities) exceed £3.26 million, and the charity’s gross income is more than £250,000. Further guidance and advice on accounting requirements can be found on GOV.UK.