Monday 4 March 2024

Does the home of the UCCF Director break Charity Commission rules?

I have some new discoveries about UCCF and The Areopagus Trust.

Let's start with the question of whether UCCF's director, Richard Cunningham, lived in the building of The Areopagus Trust. And then I have surprising news to share about the owner of that building.

Cunningham was a governor of Kingham Hill School. It's no ordinary school: it's a school founded by a Christian philanthropist, and the governing charity also oversees Oak Hill Theological College

The school helpfully provides a biography of their governors. And it's from the 2013 version of that page that we learn about Cunningham's career:
"Rev Richard Cunningham - lives close by the school in [redacted] that Kingham Hill owned [redacted]. Studied at London University- trained and worked as a teacher, followed by a stint on the staff of St Helen’s Church, Bishopsgate. Trained for ordination in Oxford and after clergy roles locally and in Oxford works as the Director of UCCF: The Christian Unions."

I've redacted some details because I don't want to give away what may be Cunningham's home address. I'll refer to it as the 'Churchill Building' from this point forward.

Do you notice the connection to St Helen's Bishopsgate? It won't be the last time you hear that name.

Actually, the bio above seems to be missing one role. In an interview for Pantheos Cunningham talks about an earlier stint at UCCF in the 90s:

"Following a stint on staff as Evangelism trainer in the 90s I remained hugely interested in the ministry of UCCF and continued leading student missions. But I never imagined I would ever go back to work for UCCF- so was as surprised as anyone when I was made Director in 2004."

So, his career has gone something like this:

  • Teacher
  • Staff at St Helen's Bishopsgate
  • UCCF
  • Ordination training
  • Curacy? (normally part of ordination training)
  • UCCF
The first role at UCCF may have come before St Helen's Bishopsgate in this timeline.

Elsewhere, in 1993, the The Areopagus Trust was founded. That is the date of the founding document referenced on the Charity Commission website.

Sadly the Charity Commission website only gives us the last 5 years of charity filings. So we have no available records about The Areopagus Trust from 1993-2018. We don't know who the trustees and staff were in the 90s, and details of the nature of the UCCF relationship. However, the founding document remains visible, with its focus on UCCF.

Let's focus on the Churchill Building. We don't know who owned it in these earlier years. It may have been used by the charity all along, or it may have been purchased/leased at some point.

In 1997, the year Tony Blair became Prime Minister, we find the first evidence that Cunningham lived in that building. The source? Planning permission. In 1997 planning permission was requested for the Churchill building:

Planning proposal 14th July 1997

If we look at the details we find the contact for the application is 'Mr Richard Cunningham':

Applicant name: Richard Cunningham

Maybe that means Cunningham owned the Churchill Building in 1997. Or maybe he had a significant role at the charity and they owned the building.  

Three years later Cunningham got involved in a different charity called Christian Heritage as a director (They later renamed to The Foundations Trust). In the paperwork he completed on 10th May 2000, he listed his address as the Churchill Building:

Richard Cunningham, Christian Heritage

The 'Annual return for 2000' for Christian Heritage, filed on 6th March, confirms the same details.

Each year, until 2008, these forms for Christian Heritage list the Churchill Building as his address. No return was filed for 2008. Maybe the rules changed for charity reporting from that year.

In 2003, Cunningham became a trustee of the Proclamation Trust. They are a charity founded by Dick Lucas when he was Rector of St Helen's Bishopsgate. They seem to have had a close relationship with that church; they are linked from the 2008 St Helens website with a handful of other organisations.  

The address he gave for his trustee details? The Churchill Building.

The current UCCF website tells us:

"Richard has been Director of UCCF: the Christian Unions since early 2004.  Immediately prior to that he was Executive Director of the Areopagus Trust, developing initiatives in confronting secular thought in universities across Britain and Europe and, at the same time, was Director of Evangelism at St Andrew’s Church, Oxford."

So, in 2003 he led the Areopagus Trust. I wonder when he began that role. The way this is phrased indicates he left that job when he became UCCF director.

In 2007 Cunningham joined forces with three other Anglican priests Nigel Beynon (then curate of St Helen's Bishopsgate), Jason Clarke (UCCF) and Hugh Palmer (Rector of All Souls, Langham Place) to found the Christian Events charity. This is the charity that underpins the Word Alive conference. He filled in the paperwork for director, and listed his address as... the Churchill Building.

Richard Cunningham: Christian Events

The names of these founders rather struck me. So I dug some more and discovered something interesting: 3 of these 4 are former staff members of St Helen's Bishopsgate. The exception is Jason Clarke.

The 2008 Christian Events annual return lists the address again. In the following years the annual returns don't mention trustee/director addresses. 

I've seen Twitter posts from a member of Cunningham's family in 2007 and 2016. They refer to the Churchill Building like a home. I'm not going to link to those for privacy reasons.

In 2013, the biography from the start of this post was displayed on the Kingham School website, stating that Cunningham lives in a type of property that matches that of the Churchill Building.

Helpfully, in 2016, the Proclamation Trust filed an annual return. That paperwork lists the UCCF director's address as the Churchill Building.

In 2017 there was more building work planned - for sleeping accommodation this time:

Churchill Building 2017 planning application

And the contact name? You guessed it: Mr R Cunningham.

2017 Planning application - Richard Cunningham

That planning application is the most recent evidence I have. Cunningham may still live at the Churchill Building, or he may have moved on since 2017.

In summary, there is evidence the UCCF Director lived in this building from 1997 to 2017.

The surprising owners of the Churchill Building

At this point I had a brainwave. Who actually owns this building now? 

These days anyone can get that data from the Land Registry, for a small fee of £3. So I did.

And I found something surprising. In 2010 the Churchill Building changed ownership. It was bought by David Douglas Monteath and someone called Michael Stahel Farmer:

Churchill Building owned by David Douglas Monteath and Michael Stahel Farmer

You may recall that Monteath is the Settlor of the Areopagus Trust - the person whose funds drive the charity. I'm not familiar with that particular charity set up. He provides the funds, but control may be at arm's-length, in the hands of the charity trustees. Or Monteath may have considerable influence.

Research reveals that in 2002 someone called David Monteath was on staff at St Helen's Bishopsgate.

This seems likely to be the same person, given the other connections we've seen, although we can't be certain.  He was in charge of 'Tape Ministry'.

The Proclamation Trust also employed someone called David Monteath in a similar role in 2004. Their website that year says:

"On the audio front, we continue to develop in the area of digital media and website development. David Monteath has been working very hard on your behalf, and very soon there will be full online ordering facilities available via the web which will unleash many new opportunities."

That prompts an interesting question - when Cunningham was a trustee of the Proclamation Trust, from 2003-2018, was he living at accommodation funded by a staff member? If so, that would be a conflict of interest: how could Cunningham be effective in holding the leaders of the charity accountable when they managed someone who was his landlord or benefactor.

Michael Stahel Farmer is a new name for me. I should call him by his official title: Baron Farmer of Bishopsgate.

According to his website Farmer is a Christian who spent his career working in metals trading in the City of London. He is a former treasurer of the Conservative Party, and since 2014 has been a Conservative life peer in the House of Lords.

If we look at Companies House records, we find he has been a director of some interesting organisations. I think two of these are noteworthy:

Gospel Support and Homes Trust Limited sounds fairly anonymous. They say their purpose is to "encourage Biblically faithful gospel ministry across London". When you look at their filings you find that a significant chunk of this ministry is based out of St Helen's Bishopsgate. In fact, the charity was originally named Great St Helen’s Trust. 

Kingham Hill School Trust is the charity that underpins the school and theological college I talked about at the start of the post. Farmer was a trustee there from 2002-2014. That will cross over the time when Cunningham was a governor. Perhaps they knew each other.

What does this mean?

We don't know the arrangement Cunningham had with regard to the Churchill Building. He may pay rent. He may be granted use for free. There would be no concerns about that, except that for some, or all, of this period The Areopagus Trust likely had a commercial relationship with UCCF

That would create a conflict of interest. Imagine you're the person in charge of training at UCCF. Say you're offered a very good deal for residential training accommodation. You may want to take it, but are conflicted - what if that decision jeopardises Cunningham's accommodation arrangement with the current provider, The Areopagus Trust?

Are decisions like that made in the best interest of UCCF and their donors, or in the best interests of Richard Cunningham? There is no declaration of such a conflict of interests in the filings, or of any 'Related party transactions' with The Areopagus Trust. You can find details of what the Charity Commission required regarding these on page 89 of The Charities Statement of Recommended Practice (SORP).

Also, this arrangement may be an undeclared remuneration for the director. Is the accommodation a perk that every director gets? There is no mention of this in the UCCF filings at Companies House at any point in the last 20 years.

Charity Commission rules say charities must disclose:

"the number of employees whose total employee benefits (excluding employer pension costs) for the reporting period fell within each band of £10,000 (€10,000) from £60,000 (€70,000) upwards"

(Source: page 81 of the The Charities Statement of Recommended Practice (SORP) )

If this was part of the renumeration package for the Director, then shouldn't it have been disclosed according to those rules? In the most recent report UCCF say:

One employee in the £70000-£79000 range

(Source: page 22, Full accounts made up to 30 April 2023, UCCF Filings at Companies House)

The water is muddied here by the fact that the accommodation is coming from a charity separate from UCCF. However, The Areopagus Trust has a core mission to serve UCCF, and is likely to receive payments from UCCF.

Perhaps the most significant aspect of all of this is that it wasn't out in the open. It was very, very hard to uncover any of this information. Why would it be so opaque? 

I wonder which trustees knew about The Areopagus Trust.

I wonder who on the UCCF Leadership Team knew about The Areopagus Trust.


More UCCF blogs

The puzzling connection between UCCF and The Areopagus Trust

What's strange about the UCCF Leadership Networks?

Thursday 8 February 2024

What's strange about the UCCF Leadership Networks?

I've been looking at UCCF's Leadership Networks. Guess what? There are strange things going on there.

According to UCCF, the purpose of the Leadership Networks is to:

"equip students who face unique challenges in their field of study, and who will be entering areas of strategic and cultural significance"

At the time of writing these fields of study are:

The Networks produce resources, they run events, they provide mentoring, etc.



There are staff with responsibility for each network. According to UCCF's About the Team page, 10 staff members currently work full, or part-time, on one of these networks.

Someone, somewhere is donating money specifically for this work on a regular basis. I know this because from 2014 onward their annual filings list a 'Leadership Network Restricted Fund'. See the bottom line of this list:


(Source: Page 19, Full accounts made up to 30 April 2014, UCCF filings at Companies House)

A restricted fund is a ring-fenced pot of money. It exists because a donor (or many donors) has said "I want to give this money for x purpose". It's an administrative hassle, but it's common because donors are often inspired by a particular element of a charity's work. 

It would be unethical to use this money for a different area of work, without the permission of the donor. The Fundraising Regulator has rules about this:

"A donation must be used for the purpose for which it was given. If you want to change that purpose you should get advice from legal advisers or the relevant national statutory regulator before changing the purpose, even if the person making the donation has given you permission to do this."


The ring-fenced money that always adds up

The thing with restricted funds is that there's normally some money left. Because it's rare you exactly match the amount you spend to the amount you're given.

Imagine you're given £20,000 to produce an information pack for university freshers. You'd get quotes for each element: writing, design, printing, delivery costs. When the work is done aspects may go under or over budget. So you'd end up spending £17,658 or £19,110, say. It's unlikely you'd spend exactly £20,000.

And sometimes there are delays in spending the money, for example a key staff member may get a new job and recruitment stalls a project. So this money may take more than a year to spend. That would be fine: the money is ring-fenced, it's not going anywhere.

What's strange about UCCF's Leadership Networks is that for 4 years in a row this ring-fenced money was entirely used up each year.

In the 2014-2015 financial year (the year after the screengrab above), the Leadership Network Restricted Fund started with £186,108 in it. In the course of the year another £52,253 was donated. That may have come from a single donor, or from many donors. £49,336 was spent from the fund. And then something interesting happens: £189,026 was transferred out into general UCCF funds. The explanation for this was:

"£189,026 of costs were transferred from General Funds to the Leadership Network for the salaries and associated costs of both field and office staff"

(Source: Page 19, Full accounts made up to 30 April 2015, UCCF filings at Companies House)

Notice it's costs that were transferred, rather than money. I find it hard to follow that wording.

At the end of that financial year £1 was left,  ring-fenced for the Leadership Networks.

The following financial year followed a similar pattern. Donated funds came in, some was spent, some was transferred to UCCF General Funds. Nothing was left in the restricted fund at the close of the year.

That same thing happened again in the 2016-2017 financial year.

And, in the 2018-2019 financial year? You guessed it. 

It seems odd to me. I find it too perfect. One year where spending exactly matched funds would be possible. But four years in a row? 

It makes me wonder if they were following the Fundraising Regulator rules. It makes me wonder if they were respecting their donor's wishes.

Maybe they were. I've worked in three charities in the course of my career. That said, I've never been a fundraiser, so I may be showing my inexperience here. Contact details are on the top right if you think I've missed something here. 

The network that's hidden from view

There's something even stranger going on with the Leadership Networks. 

These operations get a decent amount of publicity: on the website, in emails for supporters, in posts on the UCCF social media accounts. That makes sense, right? Students need to hear about them so they can join them.

But there's a network that's never mentioned in any of those places.

Let me introduce the Apologetics Network.

We can learn about it in the UCCF filings for 2020-2021:

"The Leadership Network is pioneering a brand new stream 'Teaching Network' which (alongside all the other networks Arts, Apologetics, Music, Politics, Science, Theology and Law) will provide first-class digital resources across the disciplines and will form a stronger partnership with the Internship (Relay) programme enabling us to mentor and train a new generation of thought leaders within a blended format of physical and virtual meetings"

(Source: Page 4, Full accounts made up to 30 April 2021, UCCF filings at Companies House)

Similar mentions occurred in the UCCF filings for 2021-2022 and 2022-2023. 

Can you see how it was spoken of in the same way as the other networks? Like it had already existed for a few years, or more before that point.

This network is strange, because it has no publicity anywhere. There's not been a single Twitter post from UCCF. There is not a one mention on the 1000+ pages of the current website. How do students learn about it?

It's strange because there are no staff members associated with it. I looked through the About the Team page again to check. 

It's strange because Apologetics isn't a subject one normally studies at University, not like Law or Theology. 

Why is this network so hidden? 

Does it actually exist?


More UCCF blogs

The puzzling connection between UCCF and The Areopagus Trust

Who are UCCF?

Wednesday 27 December 2023

The puzzling connection between UCCF and The Areopagus Trust

I've been looking at the annual filings of UCCF. The most interesting thing? What's missing from the reports.

(If UCCF are unfamiliar, I've written an introduction: Who are UCCF?)

Like Soul Survivor, UCCF has a number of connections to other charities and churches. And yet their filings rarely show any transactions with those charities. 

Is that plausible? 

Well, let me tell you about The Areopagus Trust.

The Areopagus Trust has no website and uses no social media channels. The only information available about them comes from the filings they're required to make with the Charity Commission.

I tell a lie. They are mentioned in one other place on the Internet: on the biography page of the UCCF CEO, Richard Cunningham:

"Richard has been Director of UCCF: the Christian Unions since early 2004.  Immediately prior to that he was Executive Director of the Areopagus Trust, developing initiatives in confronting secular thought in universities across Britain and Europe and, at the same time, was Director of Evangelism at St Andrew’s Church, Oxford."

If we look at the Charity Commission website, we find a statement about the purpose of The Areopagus Trust:

"(a)for or towards such charitable purposes and to make donations to such charitable institution or institutions at such time or times and in such manner as the trustees may in their absolute discretion think fit (b)without prejudice to the generality of sub-clause (a) the trustees shall apply the trust fund in particular towards the provision of facilities and accommodation for the use of students who are members of the Universities and Colleges Christian Fellowship (UCCF) and who are attending a course of study given by the charity in order to train and educate them in apologetics and biblical exegesis with the object that they embrace the christian faith more intelligently and to enable them to relate that faith in a skilful and convincing manner to the secular society."

I find it hard to follow, but it does seem to centre UCCF in its mission.

The annual filings of The Areopagus Trust give some more info about this relationship:

"During the year the Trust continued to provide accommodation and facilities to enable courses of study to be run for students at its principal place of operation. The Trust received fees for the provision of the facilities from the Universities and Colleges Christian Fellowship (UCCF), who took responsibility for all expenses arising in connection with the courses."

(Source: Page 2, Accounts and TAR 2019, Charities Commission website)

I've worked in charities, but I know little about trusts. The gov.uk website has some useful information about trusts. They use this definition;

"A trust is a way of managing assets (money, investments, land or buildings) for people. There are different types of trusts and they are taxed differently.

Trusts involve:

-the ‘settlor’ - the person who puts assets into a trust 

-the ‘trustee’ - the person who manages the trust

-the ‘beneficiary’ - the person who benefits from the trust"

In the case of The Areopagus Trust, the settlor is identified as someone called David Douglas Monteath.

Each year the income of the trust is composed of donations (made, perhaps, by Monteath), fees and investment income. I think that the fees here are from UCCF, because no other charity gets mentioned in any of the available reports, and UCCF is central to the purpose statement of the charity. That is an assumption on my part. 

If that assumption is correct, UCCF made these payments to The Areopagus Trust over the last 6 years:

  • £16,000
  • £17,500
  • £20,000
  • £21,000
  • £17,500
  • £21,000

In total the trust says they received fees of £113,000 in that time period.

So what? UCCF probably pay all sorts of organisations in fulfilling their mission, right?

There are two reasons I bring this up.

Firstly, I find it strange that UCCF makes no other mention of this charity. I went through their last 15 years of filings, and there's not a single mention of The Areopagus Trust.

Secondly, the UCCF CEO, Richard Cunningham, had a significant connection to the Trust from 2003 until at least 2018. 

You see, the contact address he gave for some of his trusteeships:

Matches the contact address given for the main premises of The Areopagus Trust:


So what was Cunningham's relationship with The Areopagus Trust? He's not listed in any of the available filings for the charity.

Some possibilities...

  1. Maybe he is close friends with the staff member (1 is listed), or the trustees, and they let him use their building as a contact address for 15 years.
  2. Maybe he is the single staff member, drawing a salary from The Areopagus Trust as well as UCCF.
  3. Maybe he lives at the building, in some sort of unpaid-caretaker-role. 

This matters because these possibilities would each present a conflict of interest. Is paying the Areopagus Trust for training facilities in the best interest of Richard Cunningham or in the best interest of UCCF?

Maybe there's another explanation. Do let me know if you can see one - my contact details are at the top-right.

Long-time readers will remember that Charity Commission rules say 

"disclosure must be made of transactions involving trustees, related parties, staff renumeration and ex-gratia payments"

(Source: The Charities Statement of Recommended Practice (SORP), page 86 )

If Cunningham lives at that location, or works there, my understanding is that it must be disclosed in the UCCF annual filling.

In the last 15 years of filings... there is no mention of such a disclosure. 

So, what is Cunningham's relationship with the Areopagus Trust? And if it's significant, why have the UCCF trustees not disclosed it in the annual filings?

Who are UCCF?

UCCF have been in the news. Who are they, and why do I care?

University and Colleges Christian Fellowship (UCCF) are a 95-year-old charity with over 100 staff and a turnover that hovers around the £4 million mark. They also have the biggest gap year programme I've ever heard of.

UCCF supports Christian Unions (CUs) in universities. A CU is a student society of Christians from a variety of backgrounds. CUs vary in size and scale. Some have 300 members, others have 8. 

CUs are run by students. But CU leaders seem to have a fair amount of interaction with UCCF. There's training, support, and resources for missions and events. So they are involved, but you might not appreciate how much unless you were on the leadership team of a CU.

I joined a CU at university. It was a gathering for Christians of all denominations. We had weekly services and regular small group meetings. The CU was a big, positive part of my life.  I'm aware that the positive experience may have been shaped by my spiritual journey and the fact that I was a straight white man. 

That was 20 years ago now, so things will have changed a bit. And how a CU works may vary from one to another. 

At CU I barely heard of UCCF. But I now realise that they will have been having a lot of interaction with the leaders of my CU, and will have had an influence on the formal rules that were in place. For example, the leader of my CU was always male.

Remember, the leaders of CUs are students. So each year some will graduate and the leaders will change. In that context I can imagine the support of UCCF may shift into influence, as new leaders look for guidance. For example, did the male-only-leaders thing come from UCCF's influence?

(Update - 7/2/14 - I've heard from some credible sources that some CUs had/have female leaders. Seems like this varied from CU to CU. Maybe this has shifted since my time in the late-90s.) 

UCCF have been in the news. There has been an investigation, and while this happened the CEO and one of the directors stood down. 

And? Well, it's unclear what has happened. We've had some press stories, and publicity from tweeters like Jonathan Severus and Old Boundaries. UCCF have put out a fairly strange statement. And at the same time half of their trustees have resigned, which hints of problems behind the scenes.

There's a line in the statement that grabbed me:

"The investigation found a small number of instances where the termination of CUSWs’ contracts had been badly handled and conducted in ways that caused them considerable upset and were potentially unlawful."

So I thought I'd take a look. Because our actions reveal our character. Which, ironically, is the kind of thing we heard at CU talks. If one aspect was 'potentially unlawful', according to the lawyer hired by the trustees, then other aspects may also be.

A few more things about UCCF:

  • Christian Unions are all over the country. So many of their staff are regionally based, and a fair amount of travel must feature.
  • I mentioned their gap-year programme. It's called Relay. It's pretty big: about 70 people each year. 
  • They run an annual conference for CU leaders called Forum.
  • They jointly organise a spring-time festival for Christians called Word Alive. This used to be part of Spring Harvest until the 2000s.
  • They're based in Oxford, having relocated from Leicester in the early 2000s. 


See also

The puzzling connection between UCCF and The Areopagus Trust