If you’ve already read the introductory article then you’ll be aware that the starting point for this entire investigation is a series of articles published by the Daily Telegraph in February 2014 which stemmed from an undercover investigation into the “counselling” practices of a self-styled “Crisis Pregnancy Centre” operating from premises in Central London – an investigation that was fine as far as it went but which, nevertheless, left behind a considerable number of unanswered questions, not least that of the identity of the people and organisation(s) responsible for running this centre.
In this article, I’m going to begin to answer some of those questions but I will warn you that this is going to be the most complicated article in this series to follow because it necessarily requires to pick our way through a paper trail that is often far from transparent and, at times, appears to be subject to a certain amount of deliberate obfuscation.
To begin with, then, all we have to work with, from the Telegraph’s investigation, is the name of the centre itself – at the time was the “Central London Women’s Centre”, although it has since changed its name (again) and calls itself simply “The Women’s Centre” and a website  that is noticeably light on traceable information. There are couple of contact telephone numbers, including a 0800 Freephone number, and an “online booking form” for appointments but no address. On its “Find us” page visitors to the site are told only that the closest tube station to the centre is Edgware Road and that directions will be given after they’ve contacted the centre and made an appointment.
Fortunately, those telephone numbers, together with information from a couple of online business directories and a couple of other sources, is more than sufficient to trace the location of the centre back to premises located 73-75 Bell Street NW1.
These are the offices of “The Women’s Centre”, which was previously the “Central London Women’s Centre” and has also operated in the past as the “Albany Women’s Centre” and the “Adams Women’s Centre”. The Centre actually occupies just the ground floor and basement – records held by the Land Registry also show that there are also six residential properties (flats) at this particular address but these are not associated with the centre itself.
Having located the premises, a search of Westminster City Council’s planning system quickly turned up a retrospective planning application filed in April 2006  which identified the occupier of these premises as a registered charity called “The Guild of Our Lady of Counsel” giving a named contact – Clare McCullough – and a contact address in NW9, which also serves as the main contact address for the charity held by the Charity Commission. The planning application also shows that the charity moved into the premises in Bell Street in April 2004 and that it had been operating what it describes as “Women’s Centre” from that site for two years prior to the application without it either applying for a change of use on the premises, which had previously been a bicycle shop, or for planning permission for the installation of roller shutters that the charity had installed to secure the premises and other records held by Westminster’s planning department  indicate that the charity only submitted this planning application after the council had started its own enforcement enquiry.
Okay, so that gives us something to concrete to work with. We now have a registered charity number and with that it’s a relatively simple matter to obtain the organisation’s Trustees’ reports and accounts for the five years from 2008/9 to 2012/13, giving us six years of financial data, and – via FOI – a copy of charity’s governing document, a Declaration of Trust  that was adopted and registered with the Charity Commission in 2003. This in turn, tells that the name on the planning application – Clare McCullough – is that of one of the charity’s three founding trustees and one of two individuals to have remained a trustee of the charity right the way through from the date on which it was founded to the present day. The other ever-present trustee is named in the trust deed as Marguerita Carroll and McCullough and Carroll are, respectively, the Chair and Treasurer of the charity and they appear have held those positions for the last eleven years.
Working from the charity’s accounts we see that it has managed to increase both its income and expenditure of the six year period, not always in exact step with each other but close enough not to create any serious financial problems.
It’s also clear from the accounts is that charity owns the leasehold on the premises at Bell Street as this appears in the accounts as a fixed asset that was valued at a little over £333,500 in 2008/9, the last year for which it can be identified as a separate line item and we can also see that this lease was purchased, at least in part, with a mortgage on which the outstanding balance (also in 2008/9) was just over £162,000 with annual repayments on the mortgage of £14-16,000 a year. However, in 2009/10 the charity received a substantial bequest – a residential property in North Kensington – which it valued in the accounts at £938,800 and within 12 months of receiving this bequest the charity flipped that property for a larger but less expensive property in Dollis Hill in a deal that, amongst other things, enabled them to pay off the mortgage on Bell Street.
The full story of this deal and the Dollis Hill property that the charity purchased in 2010 will be the focus of a later article.
The upshot of all this is that although, at the end of 2012/13, the charity had a net book value on paper of just over £1.12 million, although the vast bulk of this is tied up in fixed assets – i.e. the properties in Bell Street and Dollis Hill – with the charity holding liquid assets (i.e. cash) of just over £40,000 and no significant reserves.
It’s also clear from the charity’s accounts that it not only does owns a long-term lease on the premised at Bell Street but also and also that it meets a substantial portion, if not all, the overhead associated with operating a “Women’s Centre” from that location as direct expenditure from the charity’s funds. Even before it acquired the residential property in 2009/10, the charity’s accounts were showing “Building Expenses” in the region of £22-28,000 a year together with “Support Costs” which show an expenditure of around £4,000 a year on telephone calls/services and anything from £6,000-16,000 a year on printing, postage and stationary.
However, it is this point that we run into what looks a very significant anomaly in the accounts relating to the figures given for salary payments to employees.
So, since 2007, the charity claims to have to employed between 1 and 3 people a year at a cost that in most years is too low for there to have been more than one full-time employee, even at minimum wage, and yet, in a letter submitted to planning department at the City of Westminster (dated 27 July 2006), the charity provides the following information about the opening hours and staffing levels at the Bell Street centre:
3. You requested that we “provide details of how the service is used and run including the hours and number of staff.”
The service, – which is completely free, – is accessed via distribution of leaflets, adverts, and through adverts in other types of advice centres. Our “clients” are mainly women needing confirmation of pregnancy and information about pregnancy and/or help with accommodation, financial help, maternity clothes and baby goods.
Our opening hours are 10.30-6pm Monday to Friday and 9am-2pm Saturday. Wherever possible evening appointments are available on request.
Number of staff currently employed: 1 full-time and 6 part-time staff. We also have several volunteers.
So the charity has between 1 and 3 employees during the entire period for which we have accounts but the centre, only 12 month prior to the first year for which we have financial data for the charity, had 7 employees, one of whom was full-time.
There doesn’t add up at all. Despite owning the premises at Bell Street and meeting most, if not all, of its overheads the charity – on the figures given for employees/salaries in its accounts – does not appear to have employed sufficient people to run the centre and offer the range and level of services that it declared in its letter to the City of Westminster planning department.
So where are these missing employees and salaries?
The answer to that question appears to lie in a couple of line items booked into the charity’s accounts as grants to what are, ostensibly, other independent organisations.
Grants to “GCN London” and other GCN branches, when taken together, make up the single biggest line item of expenditure in the charity’s accounts over the six years from 2007 to 2013 and account for 43.5% (£631,303) of its total expenditure over that period, with the vast bulk of that money – at least £445,987 having gone to what appears to be the London branch of this organisation.
This is before we take into account that rather obvious accounting anomaly in 2009/10 in which the London branch is shown not have received a grant at all while the funding allocated to other branches shot up from just £3,260 in 2008/9 to £151,983 in 2009/10. This seems such an unlikely development that – given the figures for other years – the most plausible explanation here is that, for reasons known only to the charity and for that one year only, it chose to incorporate the grant to London branch into the total given for other branches, even though the bulk of that figure of £151,983 still went to “GCN London”.
So, the obvious question here is who are “GCN London” and what is their actual relationship to this particular registered charity?
This is where things start to become a little complex and difficult to follow – so bear with me – because the “GCN London” which appears in the charity’s accounts is an organisation calling itself the “Good Counsel Network”, a name that’s been cropping up in the press of late in relation to the running of so-called “prayer vigils” outside abortion clinics in the Greater London Area.
We’ll get to the question of who the Good Counsel Network are shortly but to start with I want to look at its relationship to the charity and the extent to which the public face of this relationship differs markedly from the relationship that’s revealed by the charity’s own accounts.
To get an idea of the relationship that the public is meant to see we can look at how this is described on these organisation’s respective websites. On the charity’s website , it describes its activities in the following terms:
We aim to assist Mothers-to-be and New Mothers with advice, information, friendship, baby goods, financial help, moral support and accommodation as appropriate to their needs and according to the resources we have available. Our main outreach is through funding groups which provide these services, though the Guild does make grants to individuals where appropriate.
We particularly support groups which strive to reach out to expectant Mothers in crisis who fell under any kind of pressure during their pregnancy. Once they are in touch with Mothers they continue their friendship with them for the long haul.
So the charity clearly states that it does is main outreach work by funding groups which provide the services it describes in the first sentence, which is what you’d expect from an organisation operating as a charitable trust because that’s generally what charitable trusts do – they raise money from the public and distribute that money via grants to other organisations that actually do the work on the ground.
Immediately following that statement is a hyperlink which reads “Pregnant and worried? Get help by clicking here.” and that link – of course – leads to the website of the Good Counsel Network  on which there are pages and a number of recent newsletters describing a wide range of activities carried out by that organisation. There are, for example, several mentions on the site of a centre run by the Good Counsel Network – although not the name or location of that centre – plus other activities carried out publicly under the organisation’s name; such as “prayer vigils” outside abortion clinics in Central London, Ealing and Twickenham and an intern programme and other volunteering opportunities at the group’s centre, which the group has been advertising in its most recent (July 2014) newsletter  along with a couple of paid positions:
Volunteer & Job Opportunities
All applicants should be committed to our pro-life ethos.
Our Intern Programme continues to be very blessed. Interns are Volunteers who come to learn the skills needed to run Prayer Vigils and to Counsel. The programme is full-time and Interns receive a stipend, travel and accommodation in London. There are spaces available on the Programme now.
Needed for 4 weeks: Temporary Assistant to the Mothers Help Co-ordinator. This is a flexible paid position for 25 hours plus. Applicants must be able to handle a heavy workload, people friendly and willing to learn.
Church Collections Person
Paid position, working 12 Weekends a year (or more if you wish), you need to be people friendly, willing and able to speak clearly, passionate about our work, punctual, reliable and a driver.
And there’s also a link on the site’s homepage to a blog – “Maria Stops Abortion” on which an article published on 4 November 2011 shows them looking for pregnant women to volunteer to assist them in training their own volunteers to use a recently purchased foetal ultrasound scanner located at what the article describes as “Good Counsel’s Pregnancy Centre” .
Now London based women who are between 5 and 13 weeks of pregnancy can help to save lives by having a dating scan at Good Counsel’s Pregnancy Centre to help us train our Ultrasonographers. We urgently need women at this stage of pregnancy to act as scan “models” for our trainees.
Ultrasound Scans are one of those mixed blessings. Routinely used to detect and exterminate those whom society deems “imperfect”, the flipside of ultrasound is that crisis pregnancy centres report that as many as 90% of abortion-minded women change their mind after seeing a scan of their baby.
The Good Counsel Network is seeking to redress the balance here in London – where scan technology is so often used against life – by offering a scan to all abortion-minded women we see. In order to get this service up and running, we are training some volunteers to do the scans.
And to that particular article we can also add a fundraising letter dating to September 2011  in which the Good Counsel Network – that is at least as far as the heading on the letter is concerned – is announcing that it has “London’s first pro-woman, pro-life ultrasound scanning service” but that they still needed to raise an additional £5,500 to cover the full cost of the system:
After a lot of consultation with a number of pro-life doctors and other Health professionals, we have bought a machine best suited for our needs. The machine and equipment costs £24,000, but I’m not asking you, our supporters, for that much, as we have already raised £18,500 towards the cost. We do currently need to raise £5,500.
So far as the Good Counsel Network’s relationship with the charity – The Guild of Our Lady of Good Counsel – goes, this is described very simply on the donations page on its website, and in a brief donations form in its newsletter, in the following terms:
The Guild of Our Lady of Good Counsel is a Registered Charity number: 1096617, supporting the work of the Good Counsel Network
All in all, you could easily take that, like the description that the charity gives on its website of its own activities, as indicating that these two organisations are separate entities – or you could if you didn’t take the time to read through the charity’s accounts.
As you might have already guessed, the Good Counsel Network’s “Pregnancy Centre” is – of course – the same centre in Bell Street NW1 that has also gone by the names “Albany Women’s Centre”, “Central London Women’s Centre” and, most recently just “The Women’s Centre”, not that any of these names appear to acknowledged anywhere by either the charity or the Good Counsel Network in any of their paperwork. You might also have already noticed that the charity and the Good Counsel Network have one very obvious thing in common; the both use the same 0207 Central London telephone number, which is the main contact number for Bell Street, but not – interestingly – the number that the centre itself uses to advertise its services on its website, that’s a 0208 Outer London number the actual location of which will be revealed later in this series of articles.
That in itself is interesting because, as we’ve already established, the lease on the centre is owned by the charity which also, based on the figures in its accounts, covers most if not all of the centre’s overheads and core running costs and for a charity that claims that, for the most part, it funds other groups to do its outreach work, its annual expenditure on postage, stationary and telephone calls looks suspiciously high.
Then there are the “prayer vigils” which are organised by and run solely under the name of the Good Counsel Network but which, in 2012-13, were funded by the charity to the under £1,789 over the course of the year, again as direct expenditure by the charity and not as part of the £128,535 that went to the Good Counsel Network by way of a block grant .
And what about the Good Counsel Network’s intern programme? Well in 2012-13 that was also directly funded by the charity outside of its block grant to “GCN London”, at a cost of £19,473, but more than that the charity also had to say in the Trustees’ Report that forms part of its annual accounts .
Our Internship (Voluntary Worker) Programme is now up and running and has so far been very successful in recruiting a wide range of applicants of all ages and backgrounds to learn about our work and to receive training which we hope will encourage them to become involved in similar work in the future.
Sorry, whose internship programme? There’s certainly no mention in either the Trustee’s Report or accounts of the involvement of the Good Counsel Network in running this programme, which the charity is clearly claiming as its own direct charitable work and not as something it funds another group to deliver.
We’ve also already seen that an ultrasound scanning service was set up by the Good Counsel Network in 2011 and that it was that group which raised funds, in its own name, to cover at least part of the purchase cost of scanning equipment – but guess who actually owns the equipment?
Yes, in its 2011-2012 accounts , the charity added a new piece of equipment valued at £22,208 to its fixed assets – that’s the scanner – while noting in the Trustees’ Report that:
We now provide a free Ultrasound Scanning service to pregnant women particularly those experiencing emotional and financial difficulties in their pregnancy, and those with no access to free medical care in the UK.
Surely they mean the Good Counsel Network, the organisation that the charity funded to the tune of £106,697 that year in addition to giving it the use of premises owned by the charity on which the charity pays most, if not all, of the overheads.
And it’s not just in the charity’s accounts that we find a considerable of confusion over who, exactly, is doing what in this rather odd and incestuous looking relationship.
In the Good Counsel Network’s most recent newsletter  you’ll find the organisation making the following appeal.
Wanted, A New Home for Mothers: Due to the success of our work, we are selling our existing Mother and Baby Home which we have outgrown and are looking to buy a new home for expectant mums and new mums and babies, ideally able to hold up to 20 mums/expectant mums. Must be close to London, preferably within zone 5. North West London would be most suitable but all London areas considered. If you know of somewhere suitable, or of a convent or hostel etc. that is on the market please get in touch: email@example.com or call 02077231740 and ask for Stuart or Clare
The full story of this “Mother and Baby Home” and why it was actually put on the market at the beginning of 2014 is one I’ll be covering in detail in a later article – let’s just say for now that the group is being extremely economical with the truth here and has been so not only with the people who read its newsletter but also with the Charity Commission – but for the purposes of this article what you need to know about this ‘home’ is that it is, of course, owned by the charity and not by the Good Counsel Network and, again, it has been the charity that’s been picking up the running costs of the property, including staff costs – independently of the funding that it’s been giving to the Good Counsel Network.
So, again, who exactly is this “we” that the Good Counsel Network is referring to?
Well, with that I think it’s time for a very quick history lesson which will explain exactly who this “we” are and it begins with references in several places, including this blog post by Joseph Shaw, the chairman of the Latin Mass Society, to the founding of the Good Counsel Network .
Stuart McCullough is a blogger himself, with the Ecumenical Diablog; the Good Counsel Network, for whom he is a fundraiser and counselor, has another blog, Maria Stops Abortion.
It was Stuart’s wife, Clare McCullough, who founded the Good Counsel Network in London in 1997, inspired by the work of the Chicago Women’s Centre in the USA.
That’s one version of the origins of the Good Counsel Network although there is a second version, one that will (again) feature very prominently in a later article. For now, however, it’s enough to note that the article names Clare McCullough, one of the Founding Trustees of charity, The Guild of Our Lady of Good Counsel, and the charity’s chairperson, seemingly from its inception in 2003, as being the founder of the Good Counsel Network.
Now, this was all before her marriage to Stuart McCullough in 2001, so back in 1997 Clare McCullough would have been known to the world by her original family name of McCarrick and it just so happens that in 1998, Clare McCarrick – who public records show to be an Irish national – registered a limited company called the “Good Counsel Network Ltd” and the records this which show that although she was the sole director of the company she also had a partner in the new venture, another Irish national named Marguerita Carroll, who took on the role of Company Secretary.
Yes, that the other Founding Trustee of the charity who has been with it since the very beginning and who appears to have served throughout as the it’s treasurer.
Now, for reasons known only to the McCarrick sisters – sorry, did I forget to mention that Marguerita Carroll’s family name, prior to her own marriage, was also McCarrick – the Good Counsel Network Ltd didn’t trade at all between 1998 and 2010, when it was formally dissolved and ceased to exist as a legal entity but it nevertheless provides clear documentary evidence that links Marguerita Carroll back to the Good Counsel Network to go with her role in the management of the charity that has funded the Good Counsel Network’s activities to the tune of close to £600,000 over the last six years, on top of the all the in-kind support like the seemingly free use of the premises in the Bell Street and picking up the tab for the intern programme, the “vigil” expenses, etc.
And it gets even better because the earliest media reference to the Good Counsel Network I’ve managed to track down to date, an article in the archives of the Catholic Herald dating back to 2000  adds a third McCarrick to the overall picture; a Rita McCarrick whom the article identified as the Good Counsel Network’s secretary but who would have been – and still is – much better known to Clare and Marguerita as ‘Mum’.
Sadly, since starting work on this investigation, the Catholic Herald has decided to put its archives behind a paywall, so you’ll have to make do with just the text of the article:
A LONDON-BASED Catholic pro-life counselling group has made an urgent appeal for funds following mounting debts of over £18,000, which could threaten the future of the organisation.
Rita McCarrick, secretary to The Good Counsel Network (GCN), which offers support and counselling to pregnant women, said: “We have branches spread around the country but each is autonomous.
“We have one office in central London and we really need to hang on to it.
“Because these women are actively seeking abortions and not support or counselling, we advertise in the same places as abortion clinics and so our advertising costs are quite large.
“Sometimes women are also looking for accommodation and work and so we try and offer that.
“If we don’t get financial help, we simply won’t be able to operate on the same level we do now.”
This particular article is interesting for several reasons beyond the appearance of a third member of McCarrick family with an active role in the early days of the Good Counsel Network.
For one thing – and this genuinely could be no more than a coincidence – the primary reason given for this appeal was that, at the time, the group claimed to have debts of over £18,000 and, somewhat curiously, in the charity’s accounts from 2007/8 right through to 2012/13 there is a record of a loan of exactly £18,000 on which the charity has neither incurred any interest nor has it made any payments despite it, on at least two occasions, having generated surpluses on the year that would have enabled it to clear that outstanding debt in full. That’s a little odd but may well amount to nothing more than a curiousity.
There’s also quite a frank admission that the organisation was, at least at the time, advertising in the exact same places as genuine abortion service providers which, in practice, meant more or less passing itself off as an abortion clinic in the hope of intercepting women who were looking in business directories for a genuine provider, which is a pretty telling example of the misleading manner in which this and similar organisations generally operate.
And finally, although not shown in that extract, the contact address for the Good Counsel Network given at the end of the Herald’s article turned out – when I checked it – to be that of a flat in Wembley that was occupied at the time by Marguerita Carroll and her family.
There’s nothing quite like keeping it in the family, eh?
Since that earliest media reference to the Good Counsel Network both Rita McCarrick and Marguerita Carroll have slipped very much into the background – that article is the only I could find that indicates that Rita McCarrick ever took an active role in the organisation – while the three names that now tend to crop up most prominently in conjunction with that of the Good Counsel Network, when you cast around the Internet for information, are those of Clare and Stuart McCullough and – during the period from 2009 to 2012/13 – that of a Conor Carroll who – to no one’s great surprise I’m sure – turns out to be the son of Marguerita Carroll.
This is all, to say the least, a little odd not to mention markedly lacking in transparency because unlike the charity, which is accountable to the Charity Commission and required by law to publish a Trustees’ Report and annual accounts every year giving reasonably detailed information about its income, expenditure and activities, the Good Counsel Network is accountable to no one other than – in this case – the charity from which it receives its funding, a charity that, on the face of it, is controlled by pretty much the same people that set up and run the Good Counsel Network.
In short, we have close to £600,000 of expenditure by the charity over the last six years which the charity hasn’t fully and transparently accounted for in the accounts that it’s filed with the Charity Commission because that money has been disbursed as block grants to an organisation that, at the very least, appears to be controlled by the same people who control the charity and which may even, in practice, be the same organisation as the charity. And this is all on top of the charity’s remaining direct expenditure, a large proportion of which also goes toward supporting work carried out by, or at least under the name of, the Good Counsel Network. Yes, it’s apparent from some of the earlier sets of the accounts that there were at one time at least some other branches of the Good Counsel Network operating outside London and that these did receive small amounts of funding from the charity but the sums involved were always very small – £3000-6,000 in total – and those payments ceased after the 2010-2011 financial year.
Something is missing from this overall picture and it was only when I went through the charity’s accounts in detail, cross-referencing its direct expenditure with the various activities carried out under the Good Counsel Network name as revealed by its website, newsletter and, in some case, blog posts that it became apparent that just about the only thing that the charity hasn’t been directly funding from its own coffers are salaries for any of the staff working in the Bell Street centre. Everything else, from the day-to-day overheads of running the centre to specific activities like the intern programme, the vigils and the ultrasound service right the way through to the money that was spent on renovating its “home” for pregnant women after that was purchased towards the end of 2009 and the staff it employed to run that “home” was all being paid for by the charity as direct charitable expenditure. The only thing that the “grant” to the Good Counsel Network appeared likely to be covering was staff costs – i.e. salaries, etc. – and of course we already know that just to run the centre, back in 2006, the charity told Westminster City Council that it had one full-time and six part-time employees.
Now that raises a very interesting question. Why, out of everything the charity spends its resources on – and these are not small sums of money by any means as over the six years, from 2007 to 2013, the charity’s total expenditure was a touch over £1.4 million – does it appear that it has only been the salaries for staff working in the centre and, at least notionally, for the Good Counsel Network that haven’t been recorded openly and transparently in the charity’s accounts?
That will ultimately be a question that the Charity Commission will be invited to investigate but while I was working through the transcript of a “counselling” session at the Bell Street centre that was recorded by an undercover researcher during the latter part of 2013, I ran across a couple of off-the-cuff remarks made by the male “counsellor” who took the session, one which appears to shed a considerable amount of light on that question and which may very well go on to for the charity and the people who control it.
The “counsellor” that the researcher saw on this occasion has been positively identified as Stuart McCullough who is, of course, the husband of Clare McCullough, the founder – according to one version of its history – of the Good Counsel Network and the Chairperson and a Founding Trustee of the charity that funds its activities.
About halfway through the transcript, during a brief discussion about the possible reaction of the researcher’s parents to her pregnancy, McCullough – who, so far as I can tell, does not have any actual counselling qualifications and certainly isn’t a profession member of any of the UK main counselling organisations – throws in the follow remarks:
It’s very common for people worry about their parents, but then we [CWLC] will speak to parents. I’ve been in this job for 12 years and no grandparents have ever seen it the way their daughter does. Obviously the daughter does not want to be a burden but the grandparents don’t see their grandchild as a burden.
I’m not going to comment on McCullough’s counselling technique, or lack thereof, because the real point of interest here is the statement to which I’ve added my own emphasis in which he states that he has “been in this JOB for 12 years”.
Factually speaking that is entirely consistent with what I’ve been able to uncover about McCullough’s background. He married his wife, Clare, in 2001 and this transcript dates to 2013, so his comment indicates that he started working for the Good Counsel Network at around the time that he married its founder. I guess you could say that on marrying into the family, he joined the family business. What that statement also very strongly implies, of course, is that McCullough not only works for the Good Counsel Network but that he is actually remunerated for doing so. What he does is a “job” and a reasonable person would generally understand that to mean paid employment and not just a voluntary position, particularly as he’s been doing it, by his own admission, for twelve years.
Now, if McCullough is, in fact, paid a salary for his work for the Good Counsel Network, as seems highly likely given that statement, then we really do have a problem here because one of the key characteristics of a registered charity in UK law – and let’s not forget that although the Good Counsel Network is not, itself, a registered charity, in practical terms it is more or less indistinguishable from the registered charity that funds its activities – is “voluntary management”.
In law, charities are run by trustees and trustees are, on the whole, not permitted to benefit financially from holding a position as a charity trustee. This is not an absolute prohibition but there are very strict rules covering payments to trustees, whether as expenses or as remuneration for specific services or activities undertaken on behalf of a charity, which both trustees and charities are required to comply with in the interests of transparency and accountability and to prevent situations arising in which the charity operate, or is perceived to be operating, under a conflict of interest. The Charity Commission, of course, publishes detailed guidance on the subject of payments to trustees  which I’d suggest you at least skim read to get a general picture of the rule but for our purposes the key section of the guidance we need to look at is Section G, and particularly Section G7, which deals with the employment of spouses and other persons who are financially interdependent with a serving trustee and which I’ve reproduced below:
G7. What is the position where a trustee’s spouse or partner or other ‘connected persons’ become paid employees of the charity?
The short answer
Our approval must be obtained if there is financial interdependence between the parties and there is no other authority for the transaction.
In more detail
Contracted employment: If a trustee’s spouse or partner becomes a paid employee on a full or part-time contract, then if they are financially interdependent, the trustee could profit from the employment. In law, this can be a trustee benefit, requiring express authority. This also applies to businesses owned by a trustee, or in which the trustee is a partner, a managing director, or has any financial interest. It can also apply to employment with a subsidiary owned by the charity.
Need for openness: Trustee boards should be aware of the possible need for authority, and ensure no improper influence has been brought to bear in the charity’s decision to employ a firm or individual. Any arrangement with a connected person should be open and transparent, so that it can be seen to be made in the charity’s interests. The trustee board should ensure any potential conflict of interest is declared and recorded in its minutes, and that the trustee concerned does not take any part in the board’s discussions and decisions concerning the terms and conditions of the connected person’s employment.
Seeking our approval: Authority is only required where there is a potential financial dependency between a trustee and a connected person who is employed. If no such link exists, then no approval is needed – though any potential conflict of interest still needs to be managed. If trustee boards are in doubt about the need for authority, we recommend they take advice.
So, although it is possible for a charity to employ the spouse or partner of a serving trustee but to do so requires the express approval of the Charity Commission and the charity has to demonstrate that such an appointment is fully justified and that there had no improper influence over the decision.
Needless to say, when I contacted the Charity Commission to obtain the trust deed of The Guild of the Lady of Good Counsel, which doesn’t itself contain any express power to employ any of its trustees on a regular basis, I also asked whether or not the charity had even applied for permission to employ either a trustee or the spouse of a trustee and the answer I got back was ‘No’. The Charity Commission has not have any record of such an application from The Guild of Our Lady of Good Counsel.
McCullough, if he is indeed employed by the Good Counsel Network, is not directly employed by the charity but it is nevertheless still abundantly clear that the organisation that he does work for is wholly dependent for its funding on the charity of which his wife is a Founding Trustee and long-term Chairperson, while his Sister-in-Law is also a Founding Trustee of the same charity and it’s treasurer; and as we’ve already seen the financial and operational relationship between the charity and the Good Counsel Network is some considerable way short of being open, transparent and fully accountable. In fact, let’s be brutally honest here, the rather odd arrangement that exists between the two, in which the charity appears to be directly financing everything except the salaries paid to employees of the Good Counsel Network, which are funded through an annual block grant in a manner that ensures that neither the number of employees nor the amount paid to them in salaries is recorded in the charity’s accounts looks a hell of a lot like a set-up designed to take an end-run around the Charity Commission’s regulations on trustee benefits.
We can’t be 100% sure here because unlike the charity, the Good Counsel Network doesn’t openly publish its accounts or indeed account for any of the expenditure from its block grant to anyone other than the charity but there are nevertheless more than enough areas of concern once you start digging into the close, and some would say extremely incestuous, relationship between these two organisations – if there are, in fact, two organisations here – to warrant asking the Charity Commission to undertake an inquiry into the running of the charity; and that’s all before we get to the little matter of the unlicensed ultrasound scanning service that ran for two years, from 2011 to 2013, and the unlicensed and unregulated home/hostel that the charity used to run in Dollis Hill.
But those are both stories that will feature in upcoming articles in this series – next time around which should be within the next couple of days, we’ll be looking in more detail at some of the “counselling” and advertising practices of the Good Counsel Network/Guild of Our Lady of Good Counsel and efforts that these organisations have made, over the years, to keep their links to the Bell Street centre, and the adverse publicity that has generated on several occasion, firmly out of the public eye.
 Central London Women’s Centre, “Homepage,” [Online]. Available: http://www.abortionchoices.org/. [Accessed June 2014].
 City of Westminster, “Planning Application – 73-75 Bell Street, NW1,” 24 4 2006. [Online]. Available: http://idoxpa.westminster.gov.uk/online-applications/files/078429D6C8132A636F3408ED215F49D5/pdf/06_03185_FULL–1116303.pdf. [Accessed June 2014].
 City of Westminster, “Property History – 73-75 Bell Street, NW1,” 2006. [Online]. Available: http://idoxpa.westminster.gov.uk/online-applications/propertyDetails.do?activeTab=relatedCases&keyVal=003LQORPLI000. [Accessed June 2014].
 The Guild of Our Lady of Good Counsel, “Home Page,” [Online]. Available: http://www.guildofourladyofgoodcounsel.co.uk/. [Accessed July 2014].
 Good Counsel Network, “Home Page,” [Online]. Available: http://www.goodcounselnet.co.uk. [Accessed July 2014].
 Good Counsel Network, “Good Counsel News,” July 2014. [Online]. Available: http://www.goodcounselnet.co.uk/upload/Newsletter%20Summer%202014.pdf. [Accessed September 2014].
 Good Counsel Network, “Having Your Baby Scanned Can Help Us Save Lives,” 4 November 2011. [Online]. Available: http://mariastopsabortion.blogspot.co.uk/2011/11/having-your-baby-scanned-can-help-us.html. [Accessed July 2014].
 Good Counsel Network, “Ultrasound Scanner Appeal” September 2011. [Online].
 The Guild of Our Lady of Good Counsel, “Trustees’ Report and Financial Statements for the Year ended 31 March 2013” 29 January 2014. [Online]. [Accessed July 2014].
 The Guild of Our Lady of Good Counsel, “Trustees’ Report and Financial Statement for the Year ended 31 March 2012” 31 January 2013. [Online]. [Accessed June 2014].
 J. Shaw, “Trustees’ Report and Financial Statement for the Year ended 31 March 2012” 12 June 2012. [Online]. [Accessed 12 2014].
 Catholic Herald, “Good Counsel Network appeals for help,” 18 August 2000. [Paywall]. Available: http://archive.catholicherald.co.uk/article/18th-august-2000/3/good-counsel-network-appeals-for-help. [Accessed June 2014].
 Charity Commission, “Trustee expenses and payments (CC11),” [Online]. Available: http://apps.charitycommission.gov.uk/publications/cc11. [Accessed October 2014].
 The Guild of Our Lady of Good Counsel, “Declaration of Trust” 15 January 2003.