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Because the formal audit looked solely at the council’s procedures, it is what
is not reported that is equally important:
- Common Purpose selected the applicants for training, and even then on
the basis on their value to Common Purpose, not the ratepayer who was
funding the alleged training.
- There were no prior declarations of interest among the local authority
officers who dealt with both the training arrangements and the FoI
requests, and who were also ‘graduates’ of Common Purpose.
- Both Common Purpose and graduates of Common Purpose who were
local authority officers worked together in a futile attempt to unlawfully
frustrate the FoIA, and also in doing so embarked upon a national
campaign of defamation, slander and libel against requesters, and in
doing so unlawfully releasing their personal details nationally, for which
Common Purpose has been rebuked by the Information Commissioner
- Decisions were being made that had financial impact upon the ratepayer
using mechanisms that bypassed the local democratic processes, the
statutory requirements, and mandatory scrutiny.
There is much more that could be said not only with this case, but also about
Common Purpose exercising power beyond legal authority within other local
authorities, institutions, Eurofunding organizations, Quangos and
Government Departments. Even the press is tainted by Common Purpose.
Whilst the example below is but one example, the association of Common
Purpose with ongoing fraud and corruption is actually ubiquitous throughout
the country, throughout local authorities, across sectors, geographic borders,
and in the EU.
Sheffield, for a long time accurately labeled the corruption capital of Europe,
is riddled with the influence of Common Purpose. Regular readers have seen
how the council regularly and unlawfully shows contempt for the law
whenever Common Purpose is involved. Frequently, it has been determined
that when fraud and corruption were exposed, those involved were
associated with Common Purpose. Readers have also seen what happens to
those who raise questions about Common Purpose, or council corruption, or
who simply expose this criminality. They are destroyed, publicly humiliated,
lied to, lied about, harassed and abused, ruthlessly and relentlessly.
It has already been shown how, especially where control and power
mechanisms are concerned, Common Purpose is to be found, i.e. with
decision-making about money, who gets what, what for, and the blatant and
illegal lack of monitoring. Elected members of Sheffield City Council have
already received a list, at Full Council, of the council-associated
organizations that are Common Purpose influenced, and work in partnership
with council Common Purpose graduates. Despite this, elected members are
being denied their right to know who these people are. The ratepayers are
also being denied their rights to information.
There have to be questions to ask about how it has come about that this
corruption and Common Purpose activity has not been brought to the
attention of the authorities with purview. ( Targeting of children ! )
As seen in the example below, the unacceptable behavior ( note that the
audit findings would have been even harsher had the auditors been given the
minutes of Common Purpose meetings – but these are supposed to be
secret, as meetings are held under ‘Chatham House’ rules ) has been
ongoing for years, yet not one of these incidents has ever been reported
upon by the Audit Commission. The same applies not only to Sheffield, but
nationally. The question must be, Why NOT? Perhaps the answer can only
be surmised, but a quick look at the Common Purpose graduate member list
among Audit Commission personnel, the expenditure of the Audit
Commission on Common Purpose, the status of the most senior Audit
Commission personnel within Common Purpose, and the defiance to publish
who their graduates are, all add up to a definitive and undeniable conclusion.
Again, we must ask, why have the police NOT acted, and the Crown
Prosecution Service NOT prosecuted, when Eurofraud, corruption, and other
criminal acts are reported to them, accompanied by objective evidence. As
above, the answer is simple, all the institutions, such as South Yorkshire
Police ( and other Constabularies ) and the CPS are themselves active
supporters and sponsors of Common Purpose. It is highly unlikely therefore
that they will embark upon any course of action against their corrupt
Common Purpose colleagues within, for example, council departments, the
European Secretariat, local devolution mechanisms, or regional partnerships.
This non-action is in turn supported by one of the most lucrative supporters
of Common Purpose, the Ministry of Justice ( sic ). In their turn, those who
have acted corruptly, and / or viciously towards citizens, are amply rewarded
with jobs, status, Honours, and of course, vast amounts of money.
1. INTRODUCTION
1.1 Common Purpose is a registered charity providing training and
networking events for leaders of the future. XXXXXXXX Council has used
Common Purpose on a number of occasions to provide external training to
select applicants. A number of Freedom of Information (FOI) requests have
been made around the procurement of Common Purpose services and a
potential conflict of interests.
1.2 A review of XXXXXXXX Council’s relationship with Common Purpose was
made at the request of the Head of Audit & Risk Assurance and the Head of
Legal and was undertaken following agreement of the Terms of Reference
included at Appendix A. This report sets out the findings and
recommendations of the review.
2. WORK UNDERTAKEN
2.1 The review sought to ensure that:
- Any interests were declared in line with the Code of Conduct for staff.
- The need for a leadership programme was formally identified prior to
entering into a commitment with Common Purpose.
- All potential providers were approached to demonstrate Value for Money.
- Applicants for training were identified as part of the personal development
programme through Step Ahead appraisals.
- Training evaluation was completed following attendance to ensure training
objectives were met.
- The authority met its obligations when responding to subsequent FOI and
Data Protection requests.
3. BACKGROUND
3.1 Common Purpose have been used on four separate occasions by
XXXXXXXX Council.
The table below summarises the expenditure.
3.2 The Navigator training course was arranged by the Democratic Service
Lead Manager following discussions as part of the annual appraisal and
continuing personal development (CPD) process. A search of potential
training courses by the Democratic Service Lead Manager had identified the
Navigator course as the most suitable.
PO Number Value Date Description
45_93581 £6,050.00 03.09.07 Navigator Course 2-5 Nov
45_144511 £293.75 12.08.08 Leading Beyond Authority Masterclass
45_156428 £41,000.00 14.11.08 InsideOUT Leadership Development
Programme Commenced 6 Nov
45_183616 £4,500.00 12.05.09 Meridian Programme commenced 17 June
3.3 Training with Common Purpose was arranged for the Head of
XXXXXXXX Highways following development needs recognised through the
appraisal process and discussions with the Interim Head of Human Resource
(HR) and Interim Strategic Director for Highways and Transportation. The
Common Purpose Meridian programme was recommended as the most
appropriate. The 2009/10 Procurement Standing Orders require purchases
over the value of £5,000 to request three quotes, consequently there was no
need to approach alternative providers for the Meridian programme.
3.4 This review has focused on the payment of £41k for the InsideOUT
programme.
4. MANAGEMENT SUMMARY
4.1 The review found that the services of Common Purpose were procured
without a formally documented assessment of need or appraisal of alternative
suppliers. Common Purpose operate leadership development networks and
programmes across geographical areas and sought to establish such a
network for the XXXXXXXX geographical area. In August 2008 a commitment
was made by XXXXXXXX Council to provide £41k to subsidise such a
programme in XXXXXXXX.
4.2 Without the formal identification of the need for the leadership training and
a comprehensive explanation of the limited market in which Common
Purpose operate, and the unique nature of the programme, it is difficult for the
authority to demonstrate value for money on the spend of £41k.
4.3 Expressions of interest from XXXXXXXX Council staff were canvassed
internally in October 2008 prior to a purchase order being raised and prior to
PRG approval being requested in November 2008. When PRG refused
approval pending further information a request to approve the Contract
Standing Order waiver without further delay was made by Senior Officers and
granted by Procurement.
4.4 The failure to follow Procurement Standing Orders and ensure
transparency throughout the procurement process has exposed the authority
to allegations of cronyism, however misguided. The review uncovered no
evidence to suggest that any XXXXXXXX officer made personal gain from the
relationship with Common Purpose nor that any officer was involved in the
business operation of Common Purpose.
4.5 It is the opinion of internal audit that controls were inadequate to
demonstrate value for money and procurement officers did not provide
sufficient challenge to the direction of senior members of staff within the
Council.
The request did not appear on the agenda sent out prior to the meeting as the
request was submitted at short notice. This was not untypical. The request
was submitted by HR and presented by the HR Practice Manager, as the
expenditure would be charged to the central HR training budget. PRG did not
give approval to the request and required further information to be provided
that could support the request for CSO waiver.
5.3.2 Following the PRG meeting the Procurement and Commercial Manager
was challenged by the former Acting Head of PAPA to explain why approval
had not been granted. It was reasoned that the programme had the support
of the Chief Executive and that Common Purpose were a unique provider in
this field. The urgency of the request was also emphasised. Following the
discussion approval was given outside of formal PRG discussion by the
Procurement and Commercial Manager and sign off was sought from
Finance and Legal by email. Approval was granted by the Financial
Accounting & Analysis Manager and Contracts and Property Group Manager
on the 7 November without further discussions.
5.3.3 This route was not untypical and was seen as an ‘emergency
procedure’ for PRG approval. However, the decision to conduct discussion
outside of a formal forum and the failure to formally record the reasons for
PRG approval has unnecessarily protracted FOI correspondence.
5.3.4 One of the reasons cited for the delay in seeking PRG approval was the
difficulty in arranging a meeting between the former Chief Executive and the
former Leader of the Council. As a result it was not possible to present the
waiver request to PRG before approval had been sought.
5.3.5 When interviewed the former Leader of the Council could not recall any
briefing on the topic and expressed the view that it would be unusual for him
to be consulted by the Chief Executive for a relatively small amount of
expenditure.
5.4 PO Timescale
Finding
5.4.1 It is unclear why the request for CSO waiver was made in such
expedient circumstances. The funding of the programme had been agreed
with Common Purpose in August 2008 (as evidenced in email
correspondence between the former Acting Head of PAPA and
Common Purpose) and dates for the programme were circulated in October
to CPT two weeks before formal procurement approval was sought in
November.
Procurement Standing Orders require that all purchasing must be:
“…financially approved according to the Council’s Financial
Regulations prior to issue to the supplier.
Verbal Commitments or Retrospective Purchase Orders are not
permitted in any circumstance.”
5.4.2 It is evident from the above that the procurement of the services of
Common Purpose in the above instance did not comply with Procurement
Standing Orders.
5.9 Recommendations
5.9.1 The process for submitting late requests to PRG should only occur in
exceptional circumstances with good reason. Requests should be recorded in
full with supporting documentation where required. Discussion and decisions
for granting or refusing PRG approval should be documented to ensure
transparency can be demonstrated if challenged at a later date.
5.9.2 Training spend should be linked to the Council's objectives / values /
priorities and individuals’ development plans.
5.9.3 An official statement should be released clarifying XXXXXXXX Council’s
relationship with Common Purpose and the status of the leadership network
within XXXXXXXX.
6. ACKNOWLEDGEMENT
6.1 The assistance and co-operation of all the staff involved was greatly
appreciated.
APPENDIX A
TERMS OF REFERENCE
Common Purpose 2010
BACKGROUND
Common Purpose is a registered charity providing training and networking
events for leaders of the future. XXXXXXXX Council has used Common
Purpose on a number of occasions to provide external training to select
applicants. A number of Freedom of Information (FOI) requests have been
made around the procurement of Common Purpose services and a potential
conflict of interests.
PURPOSE OF THE AUDIT
The audit will review compliance with the arrangements, as defined within the
Council’s Procurement Standing Orders, and draw conclusions and
recommendations based on the findings.
WORK TO BE UNDERTAKEN
The review will seek to ensure that:
• Any interests were declared in line with the Code of Conduct for staff.
• The need for a leadership programme was formally identified prior to
entering into a commitment with Common Purpose.
• All potential providers were approached to demonstrate Value for Money.
• Applicants for training were identified as part of the personal development
programme through Step Ahead appraisals.
• Training evaluation was completed following attendance to ensure training
objectives were met.
• The authority met its obligations when responding to subsequent FOI and
Data Protection requests.
OUTCOMES
The following outcomes will result:
• Verbal summary of findings at the end of fieldwork for discussion with key
officers;
• Draft report of the findings and recommendations for factual accuracy, to
include an opinion on the adequacy of controls in operation and whether
value for money is being achieved;
• Final report with a Management Action Plan (MAP) of recommendations for
the service to respond to and implement within agreed timescales.
REPORTING ARRANGEMENTS
Auditor: XXXXXXXX, Lead Auditor
Supervisor: XXXXXXXX, Internal Audit and Inspection Manager
Reporting to: XXXXXXXX, Chief Executive
Audit Ref: XXXXXXXX / XXXXXXXX
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Comment
Even with the very narrow remit of the audit, and the absence of
consideration of external documents, the conclusions are damning.
Please note that even The Law Society has been infiltrated. Corruption within
the Solicitors Regulation Authority has already been demonstrated by this
citizen in a previous publication, and there is a further SRA corruption report
to be published in the next few days.
But one of the most disturbing features is the selection of potential future
leaders, by Common Purpose, from among our children. As has been seen in
Sheffield, young people are targeted for Common Purpose training and
activities, either through the council or via a Housing Association or other
third party ( ‘YourTurn’ ) , with absolutely no evidence whatsoever of there
having been any of the statutory CRB checks by the local police upon those
in contact with the children at these Common Purpose events.
Is there still anyone left in the country that doubts whether Sheffield City
Council is absolutely corrupt?
It was mentioned before the audit report that Common Purpose had been
rebuked by the Information Commissioner.
Here are a few examples, as indicated to the complainant. Please note that
these are only a few examples from a single citizen, there are literally dozens
of similar instances, from over 150 citizens, where the same is happening
throughout the country, as part of a national campaign by Common Purpose
to not only destroy those who ask legitimate questions of local authorities and
institutions about their involvement with Common Purpose, but to criminally
show contempt for the law, in this case the FoIA and DPA. Note that the false
allegation of vexatiousness also occurs in local, unlawful refusal notices.
· Assessment letter for your complaint against the Ministry of Justice
(Reference: RFA0225283);
“"Appropriate technical and organisational measures shall be taken
against unauthorised or unlawful processing of personal data and
against accidental loss or destruction of, or damage to, personal data."
From the information you have provided it appears likely that the MoJ has
failed to comply with the seventh principle in this case. This is because steps
were not taken to ensure that your personal data was held securely and not
passed to Common Purpose.”
· Assessment letter for your complaint against London Councils
(Reference: RFA0225285);
"Appropriate technical and organisational measures shall be taken
against unauthorised or unlawful processing of personal data and
against accidental loss or destruction of, or damage to, personal data."
From the information you have provided it appears likely that London
Councils has failed to comply with the seventh principle in this case. This is
because London Councils did not take steps to ensure that your personal
data was withheld from Common Purpose when they were approached about
your FOIA request.
In light of this it is my assessment that it is unlikely that London Councils has
complied with the DPA in this case.”
This information has been complied into a list which contains details of the
request and also personal data such as names and addresses of the
requester. This list has then been provided to other public authorities as a
way for Common Purpose to demonstrate their view that the requests are
vexatious. The first principle states:
"Personal data shall be processed fairly and lawfully."
From the information you have provided it appears likely that Common
Purpose has failed to comply with the first principle in this case. This is
because an individual would not reasonably expect Common Purpose to use
information which was provided to one public authority in order to deal with a
specific request to be passed onto multiple other public authorities. The
processing was not therefore fair.
In light of this it is my assessment that it is unlikely that Common Purpose has
complied with the DPA in this case.”
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Thank you to all those who have worked so hard in providing material for this
publication. Throughout the country, fraud and corruption continues to be
exposed, and those involved with this corruption are definitely seeking a way
out of their predicament. Such is futile. With the death of nulabor, nobody
shall be able to avoid being held to account. Given that the Charity
Commission has proved itself to be an institutionally corrupt nulabor
sycophant ( not least about how it encouraged the use of another local
corrupt fake charity, Lowedges Forum, to not only operate without legitimacy,
but to launder fraudulently acquired Eurofunds ), Common Purpose has no
future.