Annual report and financial statements of the Consumers’ Association 2020-21
Continued uncertainty has impacted all our stakeholders throughout the year, including consumers, businesses, policy makers and employees.
We’ve achieved a solid financial performance through innovation in our subscription model and the development of non-subscription revenue streams, and increased our reserves.
We’ve seen a healthy growth in traffic through relevance and availability of our expert content, and we are aiming for a broader and more diverse audience to benefit from our advice.
Our advocacy work is delivering change for consumers, from our work on Covid-19 travel refunds to scams.
Sustainability and diversity are becoming embedded across the organisation after significant focus in 2020/21.
Delivering our digital transformation has proved more challenging than we had hoped and will continue to be an ongoing focus for 2021/22.
We are finishing the year in a strong position to deliver our three-year vision, with engaged employees, a strong balance sheet and a clearly-aligned strategy.
My first full year as Chair of the Consumers’ Association has been challenging and rewarding in equal measure – challenging because of the continuing restrictions imposed on all of us by the pandemic, rewarding because of the remarkable progress the organisation has made nonetheless.
Consumers have continued to be confronted with a confusing and unstable environment in which I believe Which?’s role has been more important than ever.
I hope that as you read through this year’s Annual Report you will – like me – feel pride in the measurable achievements on behalf of consumers as your continuing support has enabled us to deliver strongly against our public benefit objectives as a charity. I am particularly struck by the headway we have made in getting the Which? message across to a bigger, wider and more diverse audience of members and supporters. This is thanks not only to our new membership model, but also to our commitment to being a more diverse and inclusive organisation in all respects. Although much remains to be done, a solid foundation has been built for the years ahead.
All of this amounts to good news for all UK consumers. And it owes much to the unity of purpose and the joinedup ambition and priorities of both the Council of Trustees and the Board of Which? Limited alongside our excellent Leadership Team and staff. My sincere thanks go to our CEO Anabel Hoult and her team, to Board Chair Judy Gibbons and our colleagues on the Council of Trustees and Board – all of whom have managed splendidly to overcome the difficulties associated with remote working. I am very grateful too for the continuing commitment of all our members and supporters. I’m both confident about and excited by the plans for the coming year – whatever the external circumstances may throw at us.
I’m happy to report that we have seen strong commercial momentum over the past year, thanks to our determination to press on with our ambitious commercial strategy, despite the overall uncertainty in the world around us.
Having a strong and successful commercial business is vitally important: it is the income from our paid-for services that enables our independence and funds the delivery of our charitable purpose.
We’ve seen strong results from our innovative new subscriptions model, which offers more membership choices that are more relevant and appealing to a wider range of people. As a result, our member base is stable and more profitable: the expected lifetime spend of a member has increased by around 20% and the cost of acquiring new members has been reduced.
We’re also working hard to ensure our members are informed and engaged, which has improved loyalty and retention, resulting in the lowest cancellation rates on record (down over 50% year-on-year). In addition, the revenue generated from new members is growing with a 33% increase year-on-year in the first three months of membership. These are positive indications of the effectiveness of the new strategy and provide confidence in the long-term sustainability of the subscription business.
Our revenue base is also becoming more diversified. Members appreciate help in all parts of the buying journey, from consideration through to purchase. Our Best Buy endorsements enable consumers to buy with confidence and provide us with a growing revenue source, and we increasingly provide a much broader range of click-to-buy links in our product reviews, to ensure consumers are directed securely to a suitable retailer.
There is a rigorous due diligence process in place across all of our commercial services to ensure that we maintain our independence and always work in the best interests of consumers. This is at the heart of everything that we do, whether it is charitable or commercial.
It has been another turbulent year for all of us at Which? – but we haven’t let the pandemic hold us back in our mission to be the UK’s consumer champion.
Many businesses and charities have been forced to batten down the hatches, just focusing on getting through an extraordinarily difficult time.
Which?, on the other hand, has kept moving forward. With strong foundations, we have been able to work towards emerging from Covid-19 in better shape than ever before – our own version of building back better. As with every year, we started from the point of considering the needs of UK consumers.
At Which?, we are defined by our role as the driving force for positive change for all consumers across the UK, and I am pleased to say it has been another year of significant wins. Our landmark claim against US chip manufacturing giant Qualcomm made headlines and could result in a multi-million-pound payout for UK mobile phone users.
We responded to a surge of scams during the pandemic with our scam alert service, which has had more than 300,000 sign-ups. We continue to challenge bad practices where we see them and are sending a clear message that manipulative practices, abuses of power and failures to protect consumers are unacceptable.
We have also been seeking more legislative power in this area, collaborating with other organisations to call on the government to strengthen the Online Safety Bill.
Meanwhile, at Westminster, a bill to make pensions safer and greener for everyone became an Act of Parliament in February, thanks to the hard work and expertise of different teams across Which? over many years.
I was determined that we would respond to inspiring movements for greater racial and social equality with actions, not merely warm words. Our Diversity and Inclusion strategic taskforce has given our colleagues a loud and clear voice when it comes to ensuring Which? is a place where everyone feels welcome.
Equally, we have further embedded sustainability at Which?, launching our Eco Buy endorsement, which will help millions of consumers to make greener choices and steer businesses towards upping their game, as Best Buy and Don’t Buy recommendations have done for many years.
We’ve been listening to member feedback and the thousands of stories of consumer experiences during the pandemic has demonstrated that our purpose – tackling consumer harm by making life simpler, fairer and safer for everyone is more important than ever.
Despite the challenges of Covid-19, we took the brave and necessary action to overhaul our membership offering. This has yielded impressive results already, replacing constant churn with a membership that has stabilised at 613,000 (2019/20: 610,000), and we aspire to see growth next year.
Ambitious plans will help us to take the next step, of reaching a larger and more diverse audience of consumers who share Which?’s values but don’t currently benefit from our advice and services.
We have plans in place to ensure we can confidently move forward with our essential work on our digital transformation programme in the coming year, to ensure a smoother journey for our members. We rightly set ambitious targets and we do not let bumps in the road or the unpredictable nature of the times we live in knock us off course.
I would like to thank all our staff, who have worked so hard and achieved so much during a full year of lockdowns and working-from-home conditions. I know that they will show the same dedication for our priorities in the year ahead – growing our membership, increasing our relevance to all UK consumers and amplifying our impact. To finish, I would like to share the reflections of Emmanuel Netsere, one of the four young apprentices who joined us this year. He said: “One of the most inspiring things about working at Which? is that it is a values-led organisation, and my favourite Which? value is ‘We’re Brave’. In today’s society, it’s so important to ask difficult questions and speak up for what we believe is right – and that’s how Which? achieves real change".
I know that if we aren’t afraid to ask ourselves hard questions, set ambitious goals and continue to put our values at the centre of everything we do, we can achieve even greater things together in the years to come.
As we reflect on another year of uncertainty brought about by the ongoing pandemic, our purpose – to make life simpler, fairer and safer for everyone – resonates more powerfully than ever. New challenges, such as the aftermath of Brexit and an increasingly digitalised landscape for consumers, means that we must work hard to remain relevant to consumers.
As a self-funded charity, the Consumers’ Association must have long-term financial stability, enabling us to achieve our charitable purpose and deliver important positive impact for consumers. We generate our own revenue through our commercial arm, Which? Limited, and don’t rely on grants or donations. Delivering our strategy and vision requires us to stabilise and ultimately grow our subscriptions revenue (2020/21: £75.4; 2019/20: £77.5), while simultaneously building the income from our other commercial services, such as our endorsement scheme and our Legal and Trusted Trader offerings. We’ve made good progress in year which you can read more about in this report.
As we look ahead, it is clear that the work we have done on our strategy over the past two years has laid the solid foundations for us to clearly and confidently set out our vision for the future and the actions we will take to make this a reality.
In the 2020/21 year, Which? has a lot to be proud of. We’ve delivered some significant achievements for consumers, particularly in a year that has seen the continuing challenge of a pandemic.
This includes our significant work on travel refunds and scams campaign. Positive outcomes include a strong year for our consumer work, where we were able to influence legislation to better reflect consumer interests. However, we also recognise there are areas in which we’ve fallen short and we must challenge ourselves in the year ahead to improve.
A key challenge has been meeting project targets for some elements of our digital transformation.
Over Christmas, a member rang our money helpline to alert us to a fake NHS text saying they were eligible for a Covid-19 vaccine. We immediately investigated, and found the text led to a fake – but highly convincing – NHS website.
We were able to work quickly to post an article on Which? Conversation, share it across our social media channels and add it to our scam alert email. Within 24 hours, 40,000 people had read the story and now our warning message has reached more than 600,000 consumers. We’re very thankful to the member who contacted us; they have helped protect more than half a million people during a really difficult time. It shows that our members play a key role in the work we do.
This has been a really effective way for us to get feedback from a wide range of members – it has seen 100,000 members sharing their thoughts in the 18 months since launch. We received just under 3,000 new product/investigation suggestions from members and nearly 200 ideas for topics we could cover in our supplements. As a result, we’ve fast-tracked the testing of some key product categories.
As with diversity and inclusion, we’ve been taking steps to embed sustainability across all areas of the business, both internally and externally. Externally we have launched initiatives such as the Eco Buy endorsement, which assesses the repairability, longevity and energy-efficiency of products, and have launched a new, free sustainability email update and we are trialling a new podcast series.
Internally we have made a number of green changes in our offices and in key business areas to offset the carbon we generate, including the products we test.
By 2024 we’ll be the UK’s most famous brand for championing consumers. Everyone will know we make life simpler, fairer and safer by offering independent advice, influencing businesses and policymakers, and tackling even the most sophisticated online consumer harm. We’ll have more members who are representative of our diverse society today, deepening our insights and giving us a more powerful voice. New revenue streams will mean more for us to spend on protecting consumers. Our free offer will make us more accessible, so more people will know that Which? is on their side.
Our products and services will be a breeze to use, with every experience more personalised. And our content will have more direct impact, appearing more regularly in the right channels at the right time.
Sustainability will be second nature to us, and we’ll be unmistakably diverse and inclusive – more flexible in the way we work, with systems and processes that make it quick and easy for us to get our best work done. By 2024 we’ll be more relevant to more consumers, a bigger part of their daily lives than ever before.
Becoming a more diverse and inclusive employer has been, and will continue to be, a key part of our agenda. This is important both internally in how we embed this throughout our organisation, but also externally in how our advocacy work, product reviews, magazine content, membership model and services speak for all UK consumers. You will see diversity and inclusion mentioned throughout this report, as it becomes embedded in everything we do. Last year we informed you that we were holding ourselves to account by making seven anti-racism commitments.
Our member services give us the opportunity to hear about what we’re doing right and we also have our members who bring to light to issues we may not have been aware of. This was the case with our work in June 2021, when a Which? Conversation post discussing catalytic converters theft inspired Which? to look into the issue further. The data we gathered off the back of this conversation found that between 2019 and 2020 alone, incidents of catalytic converter theft in England, Northern Ireland and Wales rose 104% on average. We went on to cover this research in Which? Magazine as well as national media.
The Council of Trustees has a responsibility to follow the Charity Commission’s public benefit guidance. The Trustees are also bound by duties as charity trustees and under s172(1) of the Companies Act 2006 as company directors, in particular by their duty to promote the success of the Consumers’ Association to achieve its charitable purposes. The Trustees have discharged their duties, and in this report we provide an account of the year which demonstrates clearly how the Group’s significant activities, and those of the Consumers’ Association specifically, have contributed directly and indirectly to the delivery of the Consumers’ Association’s charitable purposes for public benefit and how the Trustees have discharged their s172(1) Companies Act duties and taken account of stakeholder interests.
We’ve been looking at new and innovative ways of addressing consumer harm in diverse audiences, and we’re pleased to announce that we are launching a pilot of the Which? Fund in 2021/22. The Fund will look to address consumer harm by awarding grant funding for high quality research aiming to improve understanding of the specific consumer harms experienced by diverse and disadvantaged consumer groups, and develop evidence-based solutions. We will bring more detail on this as the pilot progresses.
Which? is the UK’s consumer champion. As an organisation, we’re not for profit and all for protecting consumers – a powerful force for good, here to make life simpler, fairer and safer for everyone. We stand up for what’s right for consumers, their experiences drive us to make things better.
Our parent charity, the Consumers’ Association, is funded by our commercial subsidiaries. They generate income from membership subscriptions and businesses whose products or services earn our endorsements can, for a fee, use our name to promote them. We’re not influenced by third parties and we don’t accept freebies from product manufacturers or retailers.
We stand up for what’s right for consumers, their experiences drive us to make things better. Our research gets to the heart of the consumer issues that matter, and our expert advice is completely impartial. Same goes for our product reviews – our rigorous tests and expert recommendations help consumers to make better decisions. We investigate and make change happen – from tackling online scams to campaigning for safer products, we’re the independent consumer voice that influences politicians and lawmakers and holds businesses to account.
Everything we do is about championing consumers. We’ll always be on their side, fighting their corner and working to make them more powerful.
The charitable purposes of the Consumers’ Association, below, are set out in the Articles of Association, which is the charity’s governing document:
to advance education in such ways as the Trustees think fit, including through:
(i) undertaking, promoting and disseminating impartial, scientific and/or evidence-based analysis of or research into:
(a) the standards of goods and services available to the public as consumers; and
(b) ways in which the quality, safety and availability of such goods and services may be maintained and improved;
(ii) promoting and improving knowledge and understanding of:
(a) laws, regulations, public policies and business practices so as to empower consumers in their everyday lives;
(b) any aspect of public health and in the principles of physical and mental health; and
(c) life skills, including those relating to personal finance, digital and technology, horticulture and the home;
• to uphold and promote compliance with consumer laws, regulations and public policies, in particular through the exercise of the Association’s statutory powers for the benefit or protection of the rights of consumers;
• to protect and promote the safety of consumers;
• and to promote the interests of consumers who are restricted from accessing or using goods, services or data because of their youth, age, ill-health, disability, financial hardship or other disadvantage.
We analyse how much energy we have used in our offices and when our employees have been travelling on business to calculate our energy use and carbon emissions. Below is the 2020/21 assessment for the Consumers’ Association and Which? Limited. We have restated 2019/20 data due to a change in methodology and to provide consistent results.
The energy has been converted into greenhouse gas (carbon) emissions. From this assessment we have calculated a ratio of 0.91 tonnes of CO2e emissions per average employee in the Group, which is a reduction of 33% in comparison to 2019/20. This improvement in energy efficiency is largely due to the effect of the global Covid-19 pandemic that resulted in our staff working from home for an extended period.
0.91 tonnes of CO2e per average number of employees in the Group in the year to 30 June 2021, (2019/20: 1.36 tonnes of CO2e per average number of employees in the Group).
We have installed electric charging points to our head office car parking spaces in anticipation of a shift towards electrically powered vehicles and our energy contracts were re-procured selecting those companies that had the greatest sustainability credentials.
The electricity and gas quantities used in the year were taken from the suppliers’ invoices for use of our headquarter offices, 2 Marylebone Road in London. The conversion of gas from kWh to C02 e was based on gross calorific values. Conversion factors for this and the below were obtained here. The usage of gas and electricity in the offices not owned by the Group (Bristol and Cardiff) were estimated based on the floor area at each site by kWh for 2 Marylebone Road. In the prior year, an average usage per employee for 2 Marylebone Road was calculated and prorated for the headcount in those respective offices. The methodology was changed as using floor area provides a static calculation going forwards. The quantity of kWh used for transport is based on the mileage completed by employees on business expenditure and converted to kWh using ‘average car’ by size and ‘unknown basis’ of fuel-type conversion factors from the above website.
Our parent charity, the Consumers’ Association, increased the allocation of resources to delivering our charitable purpose, with charity spend increasing to just over £23.5m (2019/20: £21.9m). This spend is wholly funded by our commercial business.
After the allocation of charitable spend, together with non-trading income and costs, our net commercial activities generated a further £4.3m of profit, which combined with realised and unrealised gains on our investments of £4.8m, has more than offset a £1.8m loss on the revaluation of the pension scheme to deliver an increase in the Group’s reserves of £7.3m. The carried-forward reserves of £59.7m provide a healthy reserves position.
Our income from trading activities decreased by 2.7% to £88.1m, reflecting the continued reduction in our main source of income from subscriptions paid by our members for the magazines and advice. We have stabilised our member subscription numbers at 613,000 (2019/20: 610,000) after five years of decline thanks to the new membership options, which includes a digital-only option for new sales for the first time (read more in the downloadable pdf below). As the increase in subscriptions was weighted towards the end of the year, and reflects a number of differentiated offers, the subscription income has fallen from the prior year. The increase in subscriptions as we ended the year provides the opportunity to stabilise the subscriptions income in the coming year.
The fall in subscription income is partially offset as we have successfully grown our non-subscription income, with particular success from growing our partnership income because of providing members with improved access to make their purchasing decisions from our recommendations. Our endorsement income is in line with the prior year, as whilst the year started with challenges from continued issues with companies pulling their marketing spend, the story has become more positive towards the end of the year. Whilst the consumer subscription market remains challenging, key learnings from 2020/21 give us confidence, notably that under the tiered subscription model we have seen fewer cancellations and consumers are willing to sign up for annual subscriptions. We continue to focus our efforts on increasing conversion and delivering our digital transformation programme. For nonsubscription revenue, we hope to push our retailer links further, by targeting more integrations and looking for new retailers to help drive our existing switching propositions.
While investing in technology we have maintained a tight focus on cost control, delivering a year-on-year reduction in trading costs. We plan to increase the scale and pace of technology investment in the coming years to provide our members, audiences and employees with ever improved ways of engaging and working with us.
The charitable activities spend increased on the prior year, principally through the focus on the awareness-raising campaigns, particularly with regards to scams.
Our reserves position has significantly benefited from an increase in the value of our investments due to the improvement in economic sentiment from last year when the Covid-19 pandemic was in its early stages. This has resulted in an unrealised gain in investments of £4.1m, which has more than offset the unrealised loss from the revaluation of the pension scheme of £1.8m. As in previous years, we expect to continue to see volatility from both the investment performance and the FRS 102 pension valuation over the coming years.
We tackle consumer harm by making life simpler, fairer and safer for everyone. Our purpose has never been more important. It informs both our advocacy and influencing work and our commercial services.
We focus our support for consumers in four main areas: consumer rights, digital life, scams and money.
These areas have been carefully selected based on both where there is current (and future) consumer detriment and where we have the experience, expertise and ability to have the most positive impact. The following gives some insight into the vast amount of work we’ve undertaken in 2020/21 in areas as diverse as cancelled weddings and postal scams, to post-Brexit trade deals and pensions.
The changing consumer climate demonstrates that Which? is as relevant as ever and our purpose has never been more clear. The past year has presented many consumer challenges, some that have grown from existing areas of harm – such as scams or access to cash – and some that are emerging issues as a result of Covid-19 or the challenges Brexit and various trade deals have presented. Throughout all the consumer challenges, new and continuing, Which? has been flexible and responsive. We believe we have made strong progress and can be proud of what we’ve achieved.
This was a strong year making positive change happen for consumers. These examples show the different ways we created impact this year:
Directly supporting millions of consumers to deal with the challenges they faced this year, including via our rolling responsive programme of Covid19-related advice on travel, consumer rights and finances and our rapidly growing weekly scams alert email. We added new services and advice to help us grow our impact, including a mobile switching service, a new Eco Buy endorsement and a scams reporting tool.
Taking on big businesses when they haven’t been playing fair, and driving better enforcement. We successfully challenged regulators to clamp down on companies we felt could do better, driving investigations into airlines’ unfair refund practices and online platforms’ inaction on fake reviews. We also flexed our legal muscles with a collective redress legal challenge to the tech giant Qualcomm for systemic overcharging which could see mobile phone customers able to claim back millions.
Protecting the things that matter to consumers. Our cash campaign launched a cash pledge that resulted in more than 200 retailers promising to continue to let consumers pay by cash for as long as they need to. Our trade policy work and food standards campaigning helped protect the UK food standards that consumers feel strongly about, with our evidence and our voice helping to influence a government commitment to maintaining the ban on hormone-treated beef in the UK-Australia trade deal.
Shaping a more ‘fit-for-purpose’ (consumer-focused) legislative and regulatory landscape. This year we influenced important new pieces of legislation to better reflect consumer interests, including the Pension Schemes Act. We also shaped the government’s approach to regulating the security of connected products and tackling online harms, as evidenced in the Product Security and Telecommunications Infrastructure Bill and the draft Online Safety Bill that should pass through Parliament in the next year. We also helped secure government commitments, from regulating Buy Now, Pay Later schemes, to consulting on stronger powers for the Civil Aviation Authority (CAA).
Each year we analyse our records and survey thousands of consumers to help us understand more about the difference we make. In 2020/21 we heard directly from more than 20,000 consumers about how we helped make their lives simpler, fairer and safer.
We supported consumers to make informed decisions about the things they buy, making it easier for them to avoid goods or services more likely to disappoint, with new Eco Buy advice introduced this year to help those who want to buy more sustainably. We also helped hundreds of thousands of consumers who might otherwise have found it difficult to take action that would benefit them (e.g. making a complaint or switching utility provider), including by expanding our support to include a new mobile switching service. Take-up of our practical support increased this year as we were able to respond to new difficulties or priorities created by Covid-19 – e.g. as we saw more interest in advice on using the internet to stay in touch during lockdowns and more interest in will-making because of the health threat of the pandemic.
“Critical support … Helped me adjust … so that I was able to use my computer online during the lockdowns.”
“Saved us a lot of time dealing with a complex topic … giving us greater confidence to fill in the forms and follow up as needed …”
“I’ve come away with greater awareness of which products are better for the environment.”
c5.5 million purchasing decisions supported – from white goods to face masks, from insurance providers to local traders
85% of consumers who see our endorsement logo while shopping say that it makes them less worried about choosing the wrong product or wasting their money
94% of members surveyed about our new Eco Buy scheme said they found our sustainability information helpful in their decision-making
c£2.3m estimated total saving made by consumers we helped to switch their utility provider this year
Our helplines supported consumers to tackle more than 75,000 money, legal and computing problems, and our online claims tools helped more than 40,000 consumers seek redress after problems with goods and services – e.g. refund claims for travel disrupted by Covid-19. Our investigations, campaigns and policy work protected consumers from being short-changed by unfair business practices as we successfully challenged businesses selling online with inadequate refund policies, insurance companies offering poor Covid-19 protection for travellers, and online marketplaces tolerating fake reviews. We continued to fight to make sure no consumers are unfairly ‘left behind’ in an increasingly digital world, with our leadership of the national fast-fibre broadband Gigabit Taskforce (gigaTAG) influencing government thinking on how to ensure all consumers can benefit from the best available broadband service, and our cash campaign winning firm commitments from banks and big businesses to protect cash for those who need it.
“It was just like calling a friend to discuss an issue and the advisor made the whole interaction stress free so that I was able to come away with a much clearer idea of what my options were ...”
“Gave me confidence to take on a big company and I managed to receive a full refund on a high-value item.”
c120,000 consumer queries and problems dealt with in person and online
£14m estimated value of the refunds paid out to consumers using our online claims tools
87% of callers to our helplines said our advice gave them the confidence they needed to tackle the problem they were facing
209 UK businesses signed our cash pledge and agreed to accept cash payments while there are still consumers who would prefer to, or need to, pay by cash
We have reduced the risk to consumers from scammers, from insecure smart products, and from unsafe products – including this year a number of ‘health’ products making misleading claims about Covid-19 prevention. This year to increase our impact on scams we established a powerful consortium of 17 highprofile businesses to support our call for better legislation and business accountability for keeping consumers safe when they go online. We also raised the profile of our scams alert service. After promotional activity our scams alert email is now reaching c300,000 consumers a week – and not only this but more than half of recipients (57%) say they share our scams advice with others, giving us an even bigger audience!
“I’ve distributed the information to elderly people in my care which has alerted and protected them.”
“Reading your information and advice has built my confidence to deal with these attempts to defraud and I also pass on the information to my neighbours.”
“Passing on your advice to a friend about an Amazon telephone message saved her £200 and … (we) dealt with a tax message threatening to send the police … don’t know how much that saved!”
81% scams alert recipients surveyed said they felt more aware of how to reduce the risk of scam, more confident about spotting a scam, and/or more aware of what to do if they were scammed
73% scams alert recipients surveyed this year empowered to use our advice and had taken at least one action to reduce their risk, avoid a scam or respond to a scam attempt
c£1.2m is the sum our scams alert recipients estimate we helped them keep out of the hands of scammers this year when they used our advice to prevent a scam or to get their money back after a scam
60 occasions where we made the online world a little less unsafe – as we forced companies to take down listings of unsafe or insecure products and fake adverts, and to make their websites and/or their customer emails more scam-proof
With many sectors facing ongoing, unprecedented pressure, consumers are too often sharing that burden and we have repeatedly seen businesses use the pandemic as an excuse to breach consumer law. Particularly hard-hit areas included travel and wedding refunds issues. To add to an already busy year, multiple trade conversations post-Brexit also gave Which? a lot to consider as we scoured the deals on the table for potential consumer harm.
The impact on travel as a result of the pandemic has continued into another year. We have made strong progress in tackling consumer harm over the past 12 months and we have delivered significant positive impacts for millions of consumers. We’ve been influencing key policy makers and provided relevant and responsive advice. Our investigations and subsequent submissions to the Competition and Markets Authority on cancellations led to it ordering some of the UK’s largest travel companies, including Loveholidays, Teletext and Lastminute.com to return hundreds of millions of pounds of withheld and delayed refunds to consumers.
Our influence in the travel sector was reflected by us being the only large consumer organisation invited by government to participate in the Global Travel Taskforce. Here we successfully defended efforts by airlines and holiday companies to amend and weaken key parts of consumer rights protection around cancellations, refunds, delays and package holidays, as well as feeding in consumer views on how travel should restart.
Covid-19 PCR tests for travel have become a crucial part of trips in the last year. Our research into the testing providers listed by the government found several firms didn’t actually exist, while others were misleading consumers over price. The research made the front pages and saw The Times, Daily Telegraph and Guardian do follow up investigations using our research, while forcing the government to remove three providers from its list and ordering others to amend their pricing.
The high financial and emotional cost of a wedding, coupled with the fact that the industry is largely unregulated, led to lots of consumers contacting us for advice on their rights to refunds on postponed and cancelled weddings. We ran a number of magazine and online articles on UKGI, a distributor behind several popular wedding insurance brands, after we were alerted to a number of denied claims. Following us submitting a subject access request, we found that UKGI had changed its terms and conditions, and discovered it was cynically insinuating some customers bought policies expecting to claim.
We challenged the firm for treating its customers in bad faith, reported it to the Financial Conduct Authority (FCA), and encouraged all its customers to go to the Financial Ombudsman Service (FOS). By February this year, the FOS had received 300 complaints and in June 2021 the ombudsman published it upheld 94% of these.
We have worked to bring a human face to this issue - highlighting it throughout Which? content as well as in the press. It’s also been one of our most engaged areas on Which? Conversation, bringing in nearly 700 comments and 110,000 page views.
National trade conversation Which? launched the National Trade Conversation in August 2020 to establish consumers’ priorities in trade deals and to inform policymakers as the UK continues international trade negotiations. The first of its kind in the UK, the event was a series of in-depth citizens’ dialogues and involved almost 100 people from across the country. The focus of the discussions was on what matters most to people about the consumer aspects of trade deals when the risks and benefits are explained in detail. There were four clear priorities emerging relating to: maintaining food and consumer product standards, digital rights and data protection, ensuring that all regions of the country can benefit, and protecting the environment. We have built on this research through wider influencing, including representation on key Department for International Trade advisory groups, and have been making the case for why consumer interests have to be central to trade deals. We also hosted an event with the Trade Minister to discuss the findings. In November, we published the findings and set out what consumers believe should be the priorities for the ongoing negotiations with countries including New Zealand and Australia, and for trade deals in years to come.
A major focus for Which? in the 2021/22 year will be the government’s proposals for reform of consumer and competition policy which will underpin many of the issues we work on and will be an opportunity to strengthen consumer rights, regulators’ powers, public enforcement and consumer redress. We will also focus on key sustainability areas including the transition to electric cars. We anticipate that the uncertainty around travel will continue for some time and therefore there will be much work for us to do in this area.
Travel editor Rory Boland was our most prominent spokesperson this year. He made 853 appearances as our primary travel spokesperson and was widely quoted in the national press, giving advice to consumers on travel restrictions, travel insurance and refunds.
We have found airlines regularly breaking the law over delay compensation, vouchers and refusing to help passengers get home when they cancel a flight. No airline in the UK has been fined or punished for breaking consumer law in 17 years, since the Civil Aviation Authority (CAA) gained its current powers. The government, having reviewed our evidence, committed to reform the enforcement powers that the CAA has on airlines that breach consumer rights.
We’ve seen text and email scams run riot as fraudsters have taken advantage of the confusion generated by the pandemic. Across the UK, people have lost £1.7 billion to scams in the last year (source: Action Fraud, Feb 2021). This has meant Which? has had much to do in fighting the seemingly neverending wave of scam threats by giving consumers the knowledge to spot and avoid them, or what to do if they have been affected by one.
Our free email scam alert service, launched in April 2020, has become increasingly popular over the last year. The service informs people of scams currently in circulation, as well as offering helpful tips on how to spot them. In March 2021, we launched our scams sharer tool on our website, which encourages those who have been affected by scams to share their story with us after they have reported it to the relevant authorities. This has helped us gather useful data, such as the most popular types of scams, as well as real life accounts of the impact scams can have on an individual. These case studies have helped us bring life to the issues when talking to those in the corridors of power, as well as in our magazine and media work on our scams campaign. Our posts on Which? Conversation each week have collectively seen 3.5m views, and the comments we get provide an accurate bellwether of where and when scams are happening, enabling us to be responsive to consumers when it comes to what scams are active.
In May 2021, Which? played a leading role in bringing together a coalition of 17 organisations to write an open letter to the government calling for fake and fraudulent content that leads to scams to be included in the scope of its forthcoming draft Online Safety Bill. More than 2,000 campaign supporters tweeted their backing for our calls, and our joint letter received 38 pieces of press coverage, reaching 11.78m people. Less than a week later, the Department for Digital, Culture, Media & Sport announced that usergenerated fraud will be included in the draft Online Safety Bill, giving online platforms legal responsibility for tackling fraudulent user-generated content on their sites for the first time.
It was important to work with key stakeholders to ensure scams can be tackled from all directions and so we convened a workshop with UK regulators, government departments and major tech platforms, including Facebook, Twitter and Google, to discuss how we can go about tackling fake and fraudulent adverts online.
To bring our scams marketing campaign to life we created three characters: Identity Thief, Bank Impersonator and Savings Swindler as engaging reminders to be vigilant. The marketing campaign also served to promote Which?’s free scam alert service, to help people feel informed, rather than anxious. The campaign drove over 200,000 sign ups to the service.
The scams landscape is ever more complex as scammers’ tactics evolve. Which?’s strategy is to tackle scams holistically. We must ensure that banks and financial services, telecoms operators and digital (social media and search) platforms all do their bit to protect consumers and that gaps in the current legislation are addressed. A key weapon in the fight against scams is intelligence, and so in the coming months we will assess the landscape of intelligence sharing in the UK and bolster our scams data capture and analytics capabilities in collaboration with other organisations.
-In the world of social media, having a celebrity engage with your content is a surefire way to ensure more eyes will see your message. We were pleased to see football legend Gary Lineker share his support of our scams campaign with his 7.8m followers on Twitter.
-Which? research found that £700,000 is being lost to bank transfer scams every day.
When Maria Teresa Jackson, 63, realised that she had lost over £120,000 of her retirement savings to a fraudster, she was in a complete state of shock. She had been groomed over a number of weeks, after clicking on a cryptocurrency investment advertisement that she had seen on a social media website. Given that the investment platform appeared to be endorsed by celebrity Bear Grylls, and the placement of the advert was on a trusted social media platform, Maria Teresa had been lulled into a false sense of security. Unbeknownst to her, she had been transferring her retirement funds into a criminal’s bank account.
Following the scam, Maria Teresa experienced sleeplessness, high levels of anxiety and felt despondent. She did not receive the support from her bank that she had hoped for – she is still fighting for full reimbursement today.
The turning point in coming to terms with what had happened occurred after Maria Teresa posted a comment about her experience on our online community space – Which? Conversation. Maria Teresa was approached by the Which? team to support the campaign to ‘Stamp out Scams’. Initially, Maria Teresa was hesitant – the fraud had not only erased her lifetime savings, it had destroyed her confidence. She felt as though she could not make much of a difference.
She was determined to use her ordeal to help others, however, and agreed to become a campaign advocate. Talking to journalists about her experience was cathartic – she overcame her nerves, and spoke eloquently about her experience with national news journalists. Maria Teresa’s story has now been featured by several national news outlets, including ITV news. Maria Teresa feels proud to raise awareness of an increasingly prevalent crime, and provide reassurance and comfort to other fraud victims. Speaking about her new campaigner status, Maria Teresa said:
“It feels great to be part of the solution.”
Which? research found that three in five people have received a scam delivery text in the last year.
So far the scam alert service has seen over 300,000 sign ups, with those registered receiving regular alerts straight to their inbox as Which? discovers them.
We received 1,600 scam reports in the first 20 days after launching the scams sharer tool.
Our scams sharer tool shows us what types of scams are the most common, with telephone (33%) and text messages (32%) the ones most regularly reported to us.
The rapid migration of goods and services to online has brought many benefits to consumers, but it has also created some significant challenges and detriments. Reliable and fast connectivity is becoming increasingly important and services such as broadband need to show they can support our needs. We’ve also highlighted areas that present real consumer harm, such as fake reviews. We’ve seen everyday items from kettles to toys go online, but the security and lifespan of these products can all too often leave a lot to be desired. Which? has ramped up our focus in this area to ensure consumer rights and safety are protected, be it in physical or digital spaces.
In a Which? survey seven in 10 people (71%) said they had used their internet connection more since the outbreak of the pandemic, with nearly two thirds of those saying their use has increased substantially. Therefore, it is vital that consumers and businesses across the UK have a fast, reliable and stable connection if our economy is to thrive in a future defined by global communication. In August, the Department for Digital, Culture, Media and Sport asked Which?, the Confederation of British Industry and the Federation of Small Businesses to convene the Gigabit Take-up Advisory Group (GigaTAG), to look into how to stimulate demand among consumers and businesses for gigabit-capable broadband. In its final report, the GigaTAG found the main barriers to the adoption of these connections for both consumers and businesses include a lack of awareness and understanding of gigabit broadband and little perceived benefit of gigabit broadband. Our report provided a set of recommendations to tackle those barriers, including the need for clear and common terminology to describe gigabit broadband and its benefits in straightforward terms.
In March 2021, the product safety regulator, the Office for Product Safety and Standards, launched a call for evidence looking at the safety of products sold online, including through online marketplaces. This is an issue Which? has been campaigning on for several years. Then in June, the National Audit Office published a report into the UK’s product safety system which found that there are gaps in the Office for Product Safety and Standards’ powers over products sold online. Which? fed into the National Audit Office’s report.
As everything from our fridges to our doorbells becomes connected to the internet, Which? found some of these products are at risk of hacking, and during our research we found 12,000 attempts come from across the globe in a single week. Working with cyber security specialists we found hacking attempts coming from all around the world, with some of these being for malicious purposes, such as attempts to log into the devices with a weak default username and password. Which? has voiced public support for the Product Security and Telecommunications Infrastructure Bill, expected to be introduced in 2022, which aims to regulate insecure connected products. Among its provisions is that default passwords on connected products, such as ‘admin’ or ‘123456’, will be made illegal. We would like to see this supported by strong enforcement.
In our digital products workstream we are undertaking policy work into the longevity of devices with industry partners. Another key area of work for us is health data. We embarked on this topic since the increasing use of digital health, fitness and wellbeing trackers, apps and services – accelerated by the pandemic. As lifestyle data and services blend with patient data and public health services, there is significant work to be done to ensure consumers’ rights are protected.
Following on from our work in device security, we will develop work on product lifespan. The two are connected; and longevity is a natural expansion of our work on smart products. There is also a real opportunity for Which? to lead in the area of sustainability and digital products.
In June 2021, following on from a number of Which? investigations into fake reviews, the Competition and Markets Authority announced that it is investigating Amazon and Google over concerns that they have not been doing enough to combat this issue on their sites.
The pressures of the pandemic have caused even more bank and ATM closures and cash payments being refused by many retailers, and has also spurred on an increasing popularity of buy now, pay later consumer borrowing that leaves customers prey to an unregulated industry and at risk of borrowing what they can’t afford. Which? has often had to react quickly to the changing consumer trends, as well as continuing our work on longer-term goals such as influencing the Pension Schemes Bill.
Our campaign on access to cash has continued in 2020/21. We’ve worked hard to pressure the government, regulators and businesses to take stock of the issue and to act.
Here’s what we’ve achieved:
• We launched our Cash Friendly Pledge, which now has 200 businesses signed up to accept cash in stores, including major supermarkets and pharmacies.
• Bank CEOs responded positively to our public calls for a commitment to LINK and Post Office Banking Framework, until either the introduction of legislation or the current agreement ends in 2022.
• The Public Accounts Committee’s report on the production and distribution of cash included a number of our recommendations and we were invited to give a private briefing to the Committee on our insights on cash and views on the National Audit Office’s report in October to inform their recommendations.
Buy now, pay later (BNPL) credit is an innovative form of consumer borrowing that places the costs of credit on the retailer, allowing consumers to pay after a short delay, or in installments, at no extra costs. However, it is not regulated by the Financial Conduct Authority (FCA) and BNPL is not risk free, with those missing repayments incurring penalties, being charged late fees and seeing their credit ratings damaged. We published a policy report, Under Pressure: Who Uses BNPL, including extensive in-depth research profiling of typical users of buy now, pay later providers such as Klarna, Clearpay and Laybuy. Which?’s new research shows that the typical BNPL user has characteristics that contribute to consumer vulnerability: they are more likely to have experienced a major life event or to have defaulted on another form of credit/household bill in the last twelve months than non-BNPL users. The report strengthened the case for greater regulation to ensure consumers are aware of the risks of buy now, pay later providers – namely that they could fall into debt and if they do, firms may take action.
We will continue our work on pensions, cash, BNPL as well as our work on Authorised Push Payment (APP) scams to ensure the right mandatory protections are put in place to make sure that banks reimburse victims when they are not at fault.
We held our Cash Summit, a virtual event to which we invited major figures from the payments industry. The event featured speeches from the Financial Conduct Authority and HM Treasury and panels with major banks, digital payment companies and the Bank of England.
When the government published its consultation on cash legislation, it included proposals to make the Financial Conduct Authority the single regulator for the cash system – which was our main policy ask. Additionally, it outlines plans for geographic access requirements to be flexible and to deliver a range of solutions to ensure people can withdraw cash.
Our expert reviews and advice are two of the ways we deliver our purpose, and the revenue for our paid-for content helps to fund the charitable work we do on behalf of all UK consumers. This year we’ve expanded our expert product reviews and endorsements to ensure we’re keeping up with consumer trends and demands.
With people stuck at home during the numerous lockdowns, we saw a shift in shopping habits, what products proved most popular and so we responded to provide relevant and timely information.
• We added 41 new categories of gardening recommendations to the Which? website and the Which? Facebook gardening group swelled to 11,600 members.
• Our health content reached an audience of more than six million (2019/20: 1.5m).
• Our travel content reached more than seven million people, up from one million in 2018/19.
• Our first Black Friday working from home was a resounding success, with organic sessions on our website up 406% from last year.
This year, we have rolled out new sustainability-focused content, both through our member-only articles but also more widely to our visitors through our website and free newsletters and social media. Our online sustainability stories have seen nearly one million views since November 2020, and our sustainability newsletter has gone from strength to strength. We’ve seen there is appetite for this type of content, and that Which? is perfectly placed to provide information and advice to support more sustainable consumer choices. We also created an interactive digital supplement, ‘Making sustainable choices’ giving handy tips on how to live more sustainably – from eating less meat to reducing plastic waste.
We trialled our new podcast, Which? Investigates, in May with the first season focusing on sustainability issues. So far, the episodes have been listened to 14,000 times, reaching number one in Apple UK's documentary podcast chart and receiving excellent feedback.
While Which? Best Buy endorsements have always considered a product’s durability and effectiveness, the need to highlight products that are kinder to the environment has become more important than ever to UK consumers. Which? research found more than half of consumers now consider sustainability when buying home appliances. We launched our new Eco Buy that assesses the repairability, longevity and energy efficiency of products. We launched the endorsement in November 2020 and have gradually added to the product categories to bring the total awarded an Eco Buy to more than 60, with a view to continued expansion.
85% of readers found our ‘Making sustainable choices’ supplement useful and
82% agreed the supplement increased their awareness of our commitments to sustainability.
We’ve welcomed guest writers on to Which? Conversation from various sustainability-focused organisations, such as the Energy Savings Trust, Citizen’s Advice and Nesta, on a range of topics.
As part of our commitments to diversity and inclusion we have reviewed our content and channels to ensure better representation and we’re also developing ways to support editorial teams to make sure investigations and other articles represent the experiences of all minority groups. We have a new repository of diverse stock imagery, and are ensuring the language we use is fully inclusive. We have reviewed all 133 of our product content areas to see if we can make them more relevant to consumers of diverse ethnicities, including the selection of products, the tests we perform and the content that we produce. This has identified a number of opportunities for improvement, which are now being rolled out.
We will continue to review our content, products and services to ensure these appeal to the breadth and diversity of UK consumers. As we look to encourage people from more diverse socio-economic backgrounds to join Which?, we will build upon our free newsletters to supporters, which help to highlight the work that Which? does across a greater spread of audiences, as well as look to different channels such as podcasts and social media to find those who may not consume the typical media we would target.
We will increase the number of product categories in our Eco Buy endorsement and also visibility of our sustainability advice, including through increased video and social media content, in an effort to bring awareness of our sustainability work to new audiences.
More than 85% of readers of our Travel magazine say they are likely to continue their subscription next year, reflecting the expert advice we’ve given during a year of travel uncertainty.
“I have been a member of the Consumers’ Association (Which?) since issue number two of the magazine and have every intention of remaining a member. I am a widower aged 96 looking after myself at home; I look forward to each issue with pleasurable anticipation.”
Despite the uncertainty brought about by the pandemic, Which? has continued to be brave in making changes to our membership model to ensure our long-term success. While successful at driving high volumes of new members, our previous membership offering – which was in place for 10 years – saw very high cancellation rates in the first year. Over the past five years new membership volumes have been unable to offset the underlying cancellation rates, so our paid membership has been in decline.
As part of our three-year strategy to drive growth, we have transformed our offering to deliver value over volume.
In September 2020, we successfully launched our new membership model – for the first time offering a choice of memberships, including a more affordable digital package and the re-introduction of annual payment options. So far, the numbers are looking very positive, with the retention of members who have joined through the new membership packages at an all-time high, and we have seen a 50% reduction in monthly cancellation rates in 2020/21: 2.64% (2019/20: 5.30%). This also helps us have more impact for consumers and supports our ambition to help a larger and more diverse range of consumers going forward.
Our endorsements not only help us drive revenue for Which? that helps us fund our vital work for consumers, it also gives us an opportunity to celebrate the best products and services, and through our Don’t Buys to hold offenders to account. The challenges faced last year, such as businesses reducing their spend on marketing, continued into this year as part of the ongoing impact of Covid-19.
Our income has remained steady at £5.77m in licence sales in 2020/21 (2019/20: £5.79m). However, we have expanded the range of products and services eligible for a Which? Best Buy endorsement, and added two endorsement categories through our Eco Buys and Cheapest Supermarkets, so we feel this puts us in a good position for the future.
We have recruited 20 members to get early access to the new Which? app, to collect feedback from members and ensure it’s fit for purpose at each step of product development. We’re planning to have a permanent group of testers once we have launched the app publicly, to continue collecting feedback for new features we may want to try out in the future.
We include links to retailers on our reviews to make the member buying journey easier; we call these ‘affiliate links’. Over the last year we have managed to directly integrate 13 retailers into our price engine, increasing our product coverage to 61% in those areas where we can provide links. This provides a smoother journey for consumers by helping them to complete their purchases via our website, as well as delivering more revenue for Which?. Our independence and impartiality is at the very heart of the Which? ethos and no link with any third party – whatever form that may take – will ever affect our thorough and objective approach to what we do. We have increased the revenue contribution from affiliates from £0.5m in 2019/20 to around £1.05m in 2020/21.
We launched a new mobile phone contract comparison service, Which? Switch, which delivers around 200 switches a month – and provides a useful new service for our members.
We have had another good year in Which? Trusted Traders, holding trader retention strong at 85% as well as meeting our revenue and profit targets. We have also had success this year in strengthening our partnership channel with the aim of increasing the reach of Trusted Traders and helping reduce consumer detriment in the home improvement sector.
With the changes we’ve made to our membership offering and as we look to broaden our appeal to new audiences – which includes a drive to encourage more sign-ups from a more diverse consumer base – we expect to see a growth in membership. This will be supported by our new digital proposition to improve the member experience of our content.
Tech, Legal and Money services have played a critical role in advising members on issues that have been drawn into sharp focus through the year, for example, advising those who are less tech-savvy on how to set up a video call. In fact, our Tech Support teams took 21,535 calls and received 7,238 emails.
With the changes we’ve made to our membership offering and as we look to broaden our appeal to new audiences – which includes a drive to encourage more sign-ups from a more diverse consumer base – we expect to see a growth in membership. This will be supported by our new digital proposition to improve the member experience of our content.
Our three-year vision includes our commitment to transform systems that manage relationships with members and audiences. Which? will be able to use these systems to enhance the way in which members experience our content. For example, we will be able to directly share specific relevant offers and products to those who are most likely to need them and when they are most likely to need them, based upon their interactions with us and the activities of similar customers. This means Which? can deliver a member- and customer-led experience.
A key phase of the digital transformation includes delivering a new customer database and payment management system. It will also include self-service capabilities, enabling members to update their details or subscription online as well as over the phone.
We have faced some challenges in meeting our schedule and objectives on this important project. While we have delivered some aspects, we have not made as much progress as we had planned, including migrating the organisation to a singlecustomer management system. We are redoubling our efforts in this area and we are confident that we are now making important progress and will start to see the benefits across the organisation in the year ahead.
Reserves policy The Council of Trustees’ policy is to annually review the Group’s reserve levels to ensure they are sufficient:
• Ensuring there is sufficient working capital across the Group;
• Providing some protection against potential risks that could impact the organisation; and
• Offering some flexibility should investment need to be made within the business.
All our reserves are unrestricted, with no material amounts designated for specific purposes in future years. The Council of Trustees anticipates that reserves might be used to fund the Group objectives and the commercial business. Where reserves are used to fund the commercial business, this is expected to benefit the charity’s funding in the medium to long term and also contribute to making consumers’ lives simpler, fairer and safer.
Total Group reserves increased by £7.3m to £59.7m at June 2021, reflecting £4.9m of net incoming resources from trading activities (after accounting for £23.5m of expenditure on our charitable activities). Key points to note from the balance sheet include:
The £1.2m increase in intangible assets reflects our continual investment to improve our digital platforms after taking into consideration depreciation.
Year-on-year decrease of £1.6m in tangible assets largely reflects the depreciation of our Marylebone Road longleasehold premises and fixtures, fittings and equipment across our sites. A proportion of the property of Marylebone Road has been reclassified as an investment property as we leased the ground floor to a third party during the year.
The investment fund increased by £5.2m during the year, with the contributing factor largely being an increase in unrealised gains due to the recovery of the market.
All cash balances were held with Barclays, and this year we additionally placed £2m in a Barclays green deposit account.
• Creditors due after more than one year fell by £1.3m due to the continued repayment of the mortgage balance on Marylebone Road.
• The defined benefit pension liability is recognised at £9.6m (2019/20: £9.9m). Cash contributions of £2.2m improved the deficit and limited the loss in the year.
In the year, Which? Limited made £17.5m (2019/20: £4m) of gift aid contributions to the Consumers’ Association. As the Consumers’ Association is a registered charity, no corporation tax was payable on its net outgoing resources.
During 2020/21 the Group operated both a defined contribution and a hybrid pension scheme. The hybrid scheme combined the features of defined benefit (final salary) and defined contribution schemes and in March 2019 was closed to future accruals. At 30 June 2021, the hybrid scheme, valued under the FRS 102 accounting basis, had a £9.6m liability (£9.9m liability in 2019/20). During the previous financial year, the company agreed to the 31 March 2018 triennial valuation on a technical provisions basis and subsequent recovery plan with the pension trustees. The valuation was a £10.7m deficit (31 March 2015 – £14.7m deficit). The company and the pension trustees are finalising the position on the next triennial valuation, as at 31 March 2021.
Which? recognises the value of successful management of risk as a key driver in the delivery of our strategy and objectives as we seek to manage downside risks and assess opportunities to continually improve how we champion UK consumers.
Our formal approach to risk management is delivered through the application of our risk framework, which sets out the mechanisms through which the organisation identifies, evaluates and monitors its principal risks and the effectiveness of the controls put in place to mitigate them. During the year, we have enhanced our risk framework through the agreement of a set of risk appetite statements which are designed to support effective decision making. The Council of Trustees has overall responsibility for ensuring the effective management of risk within the Group, and approves the Group’s risk appetite statements, risk framework and risk management strategy, in addition to receiving regular reports on principal risks and how they are evaluated and monitored. The Group Audit and Risk Committee, a joint committee of the Council of Trustees and the Board, in addition to other responsibilities described on page 31, is responsible for providing oversight of the risk management framework, monitoring its effectiveness and the Group’s review of the risks. The Group Audit and Risk Committee has at least one member with recent and relevant financial experience.
The Group maintains risk registers which identify and evaluate the likelihood of occurrence and the impact of significant, financial, operational, compliance, external and strategic risks. The Leadership Team is responsible for the day-to-day management of key risks and ensuring effective mitigation is in place. With the support of Group Risk they regularly review the principal risks facing the Group. Group Risk continues to work with teams across the organisation to further embed and strengthen our risk management arrangements, to ensure they are operating effectively and provide relevant and timely reporting to the Council of Trustees, the Group Audit and Risk Committee and subsidiary boards.
As at the end of 2020/21, the principal risks – those considered material to the achievement of our strategy or future prospects – were identified as outlined below. The Council of Trustees has given consideration to these risks and has satisfied themselves that they are being managed appropriately.
Again, the Council of Trustees continued to adopt six guiding principles to cover relationships with third-party organisations where we receive a commission, referral fees or other benefits, for delivering a commercial service to consumers. These principles can be viewed on our website.
Which? takes a zero-tolerance approach to slavery and human trafficking and is committed to ensuring they do not take place in our organisation and supply chains. Although we consider the sectors in which we and our supply chains operate to be at lower risk, we continue to review our internal policies and supplier arrangements to ensure ongoing compliance to the UK Modern Slavery Act. Our anti-slavery statement can be viewed on our website
Our ability to offer relevant and accessible advice to consumers is contingent on the delivery of benefits from new technologies, adapting our ways of working, and our approach to innovation. We are working to transform our digital resources and have found this more challenging than expected. We remain focused on recruitment and retention of the right skills and capabilities to deliver these changes, and manage key supplier relationships. We are also mindful of the external risks, including cyber threat, and continue to invest to ensure that our systems and data are adequately protected against misuse.
The impact of Covid-19 on businesses and consumers has been unprecedented. Our business continuity plan has helped us continue to respond promptly to changes in the environment to ensure the continuity of operations and to provide relevant support and advice to consumers through the Coronavirus Hub. We have also been listening and responding to the needs of our colleagues, prioritising their wellbeing and offering greater flexibility, proposing changes to our total reward offer to seek to increase alignment to our strategy.
It has been a year of change. A large part of the UK government is focused on dealing with the implementation of the Brexit deal and prioritising economic recovery after multiple UK lockdowns, while consumer behaviours are changing in response to significant cultural shifts. We actively monitor such developments, political appetite, and bandwidth to support policy interventions and we continue to seek opportunities to address consumer harm. We have embedded diversity and inclusion and sustainability into our strategy.
Maintaining our independence and being true to our values in all that we do are really important to us. We continually need to ensure that our own customer offerings put consumers first and do not give rise to corporate hypocrisy. We seek to understand and remediate operational weaknesses and continually review our offerings to iterate and improve the consumer experience.
Our financial model relies on us growing and diversifying our consumer audience, improving the proportion of website visitors who pay for a subscription, and diversifying our revenue streams. This requires continued focus on our proposition, price and user experience. It is also in part dependent on planned technology changes and ensuring our cost base is proportional to our income. We monitor the Group’s performance and invest in key initiatives such as launching tiered membership and setting up crossfunctional teams to improve our consumer offering to ensure we are putting our resources to best effect. Our three-year plan focuses on generating sufficient funds to reinvest in the Group to enable the charity to deliver for beneficiaries.
The Consumers’ Association is the parent of the Which? Group. It is established as a company limited by guarantee (no. 00580128) and a registered charity (no. 296072). The Consumers’ Association is governed by its Council of Trustees and wholly owns the trading company Which? Limited.
Which? Limited is a registered company (no. 00677665) and generates the income for the Group to enable it to provide its many products and services to, and deliver impact for and with, UK consumers.
The Which? Limited Board (the Board) sets and oversees the commercial direction of Which? Limited within the context of the Group strategy, vision and values, with the aim of delivering a long-term sustainable financial return for the charity. The Board, which is appointed by the Consumers’ Association, is chaired by Judy Gibbons and consists of four other independent non-executive directors and Anabel, our CEO.
Which? Limited owns a small financial services company, Which? Financial Services Limited (no. 07239342), regulated by the Financial Conduct Authority, and Which? Legal Limited (no. 08109992), which remains dormant.
The Council of Trustees sets the strategy for the Group to enable the charity to deliver its charitable purposes; provides scrutiny, support and stretch to the Which? Limited Board and the Leadership Team to drive progress and deliver impact; and stewards the charity to make best use of its resources, protecting and conserving its assets for consumers tomorrow as well as today.
The Council of Trustees aims to focus its time in five key areas: strategy to deliver our purpose, operational performance, financial performance, risk, and governance (including culture and stakeholder matters), balancing the time spent on each.
• monitored delivery of our audience-led commercial strategy approved in the last financial year;
• approved the new simplified vision and three-year plan; approved new decision-making frameworks, which support our purpose, strategy and vision;
• continued to hold focused and challenging regular operational and performance review conversations, thanks to enhanced reporting from the Leadership Team; and
• provided oversight and support for the CEO and the Leadership Team in managing the organisation through the ongoing Covid-19 pandemic and its envisaged future hybrid working model.
The Council of Trustees consisted of 15 Trustees at 30 June 2021.
Following members’ approval of our new Trustee appointment process in 2019, all Trustees now stand for re-appointment by members every three years and may serve up to a maximum of nine years, although they may be appointed for longer than that in exceptional circumstances. New Trustees are initially appointed by the Council of Trustees and, within a year, their appointment is approved by members. The process was implemented for the first time last year and continues to help us build a Council of Trustees with the diversity of thinking, background and expertise that the organisation needs.
In December 2020 the Council of Trustees appointed Christopher Woolard, who brings depth and breadth of experience in policy and regulation to the Council of Trustees through senior roles held with the Financial Conduct Authority, Ofcom, the BBC and in the Civil Service. Christopher’s appointment will be submitted for members’ approval at the 2021 AGM.
Four Trustees have also been put forward for re-appointment by the members, each having reached the end of a three-year term: Shirley BaileyWood, Christine Forde, Donald Grant and David Woodward; all have served six years or fewer on the Council of Trustees.
The Council of Trustees is supported in its work by a number of specialist committees, sub-groups and working groups. This approach ensures that Trustees have sufficient oversight of key issues for the charity and that the Council of Trustees as a whole receives the assurance it needs to support its decision-making. A list of our formal committees and each of the members of them are set out on page 60, while the table above summarises their responsibilities.
The chief executive, Anabel Hoult, implements the Group strategy as developed and agreed by the Council of Trustees and the Board, and looks after the day-to-day running of the Which? Group, with support from the Leadership Team and from over 680 staff based in Cardiff, London, Capel Manor Gardens and at home. Neither Anabel nor any member of her Leadership Team are Trustees.
As a charity, we aim to apply the high standards set by the Charity Governance Code. This means we adopt an ‘apply or explain’ approach to the Code. The Trustees are satisfied that the charity applies the seven principles in the Code.
The Council of Trustees supports a culture of continuous improvement and aims to continue to strengthen its governance, in line with the Code’s recommendations as well as with the aims and recommendations of the 2019 Governance Review.
Our work during the year included continuing to ensure we provide new Trustees and directors with an excellent induction programme, to quickly give them a clear understanding of the organisation. In year, we have supplemented this with formal and informal training and workshops, available to all Trustees, on Trustee duties and charitable spend, our digital transformation, Which?’s legal powers, our finances and the organisation’s new reward approach.
We have also completed a comprehensive review of the Council of Trustees’ committee structure and of the role, remit and membership of each committee in the context of our new three-year plan. Together with new delegated authorities, this clarifies the responsibilities and the accountabilities of Trustees, nonexecutive directors and the CEO and enables sharper focus on the areas of greatest risk.
We continue to build on our work to ensure that the Council of Trustees can provide expert and effective oversight of the organisation and is representative of the diversity of UK consumers. This includes the appointment, in August 2020, of two independent members of our Nominations Committee: Elizabeth Oni-Iyiola and Michelle RajkumarClifford. They joined us with a remit to help us assure the fairness and robustness of our Trustee appointment process and to further develop diversity and inclusion.
In their first annual report to the Council of Trustees this year, the independent members confirmed that the search process and appointment for new Trustees and non-executive directors in 2020/21 was conducted on a fair, transparent and inclusive basis and was coupled with an increased focus on attracting a wider, qualified and diverse set of candidates. It also includes recommendations for how we can improve our diversity pipelines.
The Group’s work to strengthen our commitments to diversity and inclusion across the organisation is explained on page 36. In 2020, we asked our Trustees, Which? Limited nonexecutive directors and independent committee members questions about diversity of background and perspectives and compared their responses with UK national averages. Our survey identified that key areas for us to improve diversity were age, disability, Asian background and social mobility.
Efforts to improve diversity and inclusion are supported by organisation-wide people initiatives, such as unconscious bias training and reverse mentoring. You can find out more about the 2019 Governance Review on our website.
The Council of Trustees expects to undergo an external review of its effectiveness every three years. The triennial reviews are supplemented by lighter-touch internal reviews in intervening years based on a Trustee appraisal, including input from chairs, committees and the Leadership Team and a skills and experience audit. As the Governance Review was completed in 2019, the next external review is due in 2022.
The Board and Council of Trustees receive regular updates from the Chief Executive, the Leadership Team and the Policy and Advocacy Committee on key stakeholder relations and engagement activities and current issues. They also receive relevant feedback obtained from our interaction with stakeholders and ensure that our purpose, mission and values play a fundamental role in the way that we deliver our strategic goals and operate day-to-day.
The Council of Trustees has a duty to promote the success of the Consumers’ Association for the benefit of UK consumers. That success depends on our ability to engage effectively with our stakeholders and to take their views into account. When making decisions, the Council of Trustees has regard to:
• likely consequences of any decisions in the long term;
• the interests of our people; and
• the need to foster our relationships with third-party stakeholders.
For Which? this includes UK consumers, policy makers and businesses that sell goods and services to UK consumers, our suppliers and customers, and others;
• the impact of our operations on the community and environment;
• the desirability of maintaining our reputation for high standards of business conduct; and
• the need to act fairly as between members of the Consumers’ Association.
UK consumers are our beneficiaries and we’re here to tackle consumer harm by making life simpler, fairer and safer for them. It’s our members who fund the vital work we do for UK consumers. Most of our income comes from subscriptions – we receive no money from government, public donations, or other fundraising income. Members receive access to dedicated content and advice, and also have the opportunity to get more involved in the organisation by becoming ordinary members, which gives them more say in how we’re run – by taking part in our Annual General Meeting (AGM), at which they take highlevel decisions relating to our governance.
We aim to understand the landscape of current and emerging consumer issues better than anyone else, to be relevant to consumers and a part of their daily lives. Across the organisation we undertake quantitative and qualitative research with consumers and members, listen to member stories received via our website and helplines, and speak to users of our website to help craft the best digital experience for them. This year we looked at ways in which Which? Conversation could be changed to improve engagement and regular participation, including higher input from Which? staff and experts on site, and specific events to provide consumers with useful information and advice. We introduced two new pilots: a new Facebook travel group where members can engage with Which? and with each other, and a Have Your Say email programme. We have also introduced a Put to Rights column where we help someone with a specific consumer problem.
A significant part of the quantitative feedback is gathered through Which? Connect, a research panel of more than 38,000 members who, through surveys and focus groups, feed directly into our work – from the magazine articles we write to our national campaigns. Consumer research and member feedback has informed recent decisions by the Council of Trustees, resulting in the provision of content available to all in front of the paywall with the aim of increasing our membership and helping a larger and more diverse range of consumers, and the provision of a new tiered membership system with a cheaper digital option, introductory discount and annual payment options.
Every year at the AGM the Council of Trustees updates ordinary members on how we are achieving our charitable purpose and how we are performing financially.
We completed a review of the Member Governance Committee during the year and concluded that it is not fulfilling what it needs to, so we are now looking into new and better ways for members’ and consumers’ voices to be heard at our meetings.
We engage with and influence businesses to deliver public benefit through tackling consumer harm, holding businesses to account and recognising high standards. We also engage businesses in our advocacy work, for example our work on connectivity, scams, sustainability and data. Our engagement helps to uncover harm, inform our policy, influence business practice, and identify opportunities for collaboration and the co-creation of solutions that deliver better outcomes for consumers. As a responsible organisation, we also consider the impact of our decisions on our suppliers, endorsement holders, traders and retail partners.
Through our policy and campaigning work, our product testing and the Group’s endorsement schemes (including Which? Trusted Traders) and investigative journalism, we engage and influence businesses to help them to stand out from the crowd and to deliver higher standards for consumers, helping good businesses to thrive and holding bad ones to account.
Throughout the last financial year, we have continued to pay our suppliers well within our agreed terms of 30 days and have not experienced any significant delays internally as a result of the pandemic. We reviewed our processes following the change to working remotely to ensure that we were able to continue paying our suppliers on time while also ensuring that robust controls remained in place to mitigate against the increased risk of fraud. We’ve also enhanced our processes and improved engagement to ensure greater alignment between us and key suppliers, with more regular check-ins and reviews.
We engage with policymakers in order to deliver our purpose and mission. Not only do we need to influence policymakers, including regulators, we are also accountable to the Charity Commission and the Financial Conduct Authority (FCA) as bodies that regulate the Group.
Which? works closely with politicians, civil servants, regulators and other experts and organisations to build better policy by providing robust evidence, insight and expert knowledge, focusing on delivering the right outcomes for consumers. During the year, the Policy & Advocacy Committee was established and has looked at the impact being delivered through our engagement with policymakers and has also reviewed impact priorities. The Council of Trustees receives regular reports on this engagement along with recommendations. We often invite our Trustees to our external events, for example our cash summit.
We engage with the Charity Commission and the FCA when relevant matters arise and have regard to their guidance in the running of the organisation.
Which? colleagues are responsible for delivering the overall strategy set by the Trustees, are the face of Which?, and work hard on the day-to-day tasks needed to keep the organisation running effectively.
We engage with colleagues, or their representatives, through regular communications, including through the Which? Intranet, regular email updates from the Leadership Team, team and Group meetings, and social channels, such as Slack. We also use Group and team meetings along with Intranet content and email to promote a common awareness on the part of all employees of the financial, economic and other factors affecting Which?’s performance. In this way, we also ensure that employees are informed about matters that concern them. We consult with them regularly, too, so that we can take their views into account when making decisions that are likely to affect their interests, including through our quarterly employee survey. We ensure to feedback the results of these surveys.
A number of employee groups provide a dialogue between the Trustees, Leadership Team and staff. Feedback from such groups has been influential in our work around diversity and inclusion and has informed decisions such as creating our new reward principles. The Council of Trustees receives regular reports on and considers engagement with our people, from employee survey outcomes to decisions such as that to close our Bristol office.
You can read more around our current and future sustainability and diversity and inclusion achievements and commitments below, including our new Which? Investigates podcasts and our roundtables on sustainability.
We also partner with and contribute funding to a number of other organisations to amplify our work – notably International Consumer Research and Testing Limited, Consumers International, the Bureau Européen des Unions de Consommateurs – and we have supported the work of the Research Institute for Disabled Consumers (RIDC) through charitable donations of £75,000 in-year. In addition, we also have regard to other factors that we consider relevant to the decision being made. These include the interests of our pensioners, which is a particular focus of our Joint Pensions Working Group of Council Trustees and Pension Trustees.
Council Trustees do not receive any payment for their services. They are reimbursed for travel and accommodation expenses incurred when attending Council and committee meetings and other official events. During 2020/21, claims were made by 0 out of 15 Trustees (2019/20: 9 out of 15) totalling £nil (2019/20: £8,053). This is because all meetings were held virtually this year. As we move back to more in-person meetings we expect this will go up in 2021/22. Insurance costs for the year to protect Council of Trustees members against liabilities arising from their office totalled £7,000 (2019/20: £12,728). Non-executive directors on both the Which? Limited and Which? Financial Services Limited boards are remunerated for their services. The total remuneration in the year for Which? Limited non-executive directors was £91,458 (2019/20: £92,916). In Which? Financial Services Limited, which operates within a regulated environment, the total remuneration was £20,000 (2019/20: £51,917).
Colleague wellbeing has been a key concern over the last year as the weight of consistent home working, lack of in-person interaction and general anxieties regarding physical and mental health were felt. We have continued to listen to and learn from our colleagues and provide support through a number of wellbeing and development initiatives.
Our colleagues have faced their first full year of remote working and we’ve also onboarded more than 150 new starters remotely. We have continued to listen to and learn from our employees and provide support through a number of wellbeing and development initiatives. We’re planning a move to hybrid working later in the year (subject to any changes in government advice) and will be approaching this on a test and learn basis as we reopen our offices.
One certainty will be the need for less office space, and so we made the difficult decision to close our Bristol office, as well as lease out the ground floor of our London office. Colleagues at Bristol will be relocated to our existing Cardiff location for the days they are in the office.
A great place to work It’s important to Which? that current and prospective employees see Which? as a great place to work. This means we have the pick of the best and brightest to join our teams. In May 2021 we were named as a winner in the Public Relations and Communications Association Workplace Champion awards, which recognises teams that go the extra mile to establish positive and inclusive working environments for colleagues.
Internally, we look to recognise colleagues who go above and beyond or demonstrate they share Which?’s values. At the end of the year we give out a Values Sharer of the Year award, with the winner receiving a £1,000 contribution towards a learning opportunity of their choice.
“To be granted the Values Sharer award is an honour and a privilege – being recognised for your character and hard work feels very humbling. It’s a great initiative to be able to celebrate those living their values for the support of others.”
Conor Bannister, Values Sharer of the Year award winner 2020.
We haven’t lost sight of colleague development as we worked from home and continue to encourage people to own and grow their careers with a number of support measures. In 2020/21, we supported 88 colleagues to obtain professional qualifications and attend external professional development programmes and have increased engagement with LinkedIn Learning, and in the year 369 colleagues viewed 740 hours of learning. We have also focused on upskilling leaders and managers to support colleagues with disabilities and mental health issues.
Our quarterly engagement survey has been particularly important as colleagues have spent over a year away from the office, their managers and their colleagues. We’ve seen improvements in some areas but also dips in others, as the benefits and challenges of a full year of homeworking and our closure of the Bristol office are realised.
We’ve seen positive scores from colleagues valuing the flexibility that working from home can bring and how it affects work-life balance. We’ve worked hard to ensure that despite working remotely, all colleagues understand the purpose of Which? and can connect to it, and ensure that everyone understands the role they can play – this has been reflected in the improvements to the relevant engagement scores.
The mental and physical wellbeing of all employees has been paramount as homeworking continued through 2020/21. We gave all colleagues an extra day off in November and in June to use as a ‘self-care day’, which saw almost the entire organisation closed. We ensured the support Which? offers, such as free external counselling, has been visible and regularly promoted through our weekly ‘Wellbeing Wednesdays’ event.
Becoming a more diverse and inclusive employer has been, and will continue to be, a key part of our agenda. We launched our diversity and inclusion vision internally through our ‘Everyone Week’ internal campaign and encouraged colleagues to pledge how they’re planning to contribute to our vision. Diversity and inclusion is also one of the key themes for content we send to our colleagues. Since launching our internal Let’s Talk event series for colleagues we have held events on race in the workplace, disabilities in the workplace, Black History Month, sustainability and LGBT+ allyship.
We have reviewed our recruitment processes with an external partner and have identified an action-focused plan to ensure our recruitment processes are inclusive. As part of this process, which supports our anti-racism commitments, we have introduced a number of new processes, including advertising our roles across a wide range of job boards, including specialist diversity job boards such Verdica and Stonewall.
We’re also pleased to have recruited our first set of four paid apprentices and are currently recruiting more, and we have signed up to the 10,000 Black Interns programme with a commitment to take in our first two apprentices in summer 2022.
In order to ensure we are properly informed in the make-up of our employees, in December 2020 we gathered data from colleagues across the organisation in our ‘what makes you, you’ survey. This also supported one of our anti-racism commitments. While elective, we saw a 85% response rate, which will be invaluable in ensuring we’re representing the voices of all colleagues. A colleague diversity and engagement group used the data gathered to form the basis of two subgroups, one looking at diversity and the other at inclusion. These groups have since worked to complete our first equal pay audit.
We have initiated a number of commitments to sustainability to drive our work in this area, both internally and externally. You can see a number of examples of where we’ve already been hitting these commitments through the year, and you can read a full breakdown of this here.
We’ve been partnering with other consumer organisations and sharing expertise. As well as the combined expertise, this also brings the benefits of international government influence to tackle the world’s sustainability challenges. We’ve also been delivering more significant research-based projects and producing a regular flow of sustainability content.
Internally, we’ve run materiality assessments of our offices and have already offset the carbon emissions produced by our travel and testing team researchers travelling for business. We’ve also introduced new electric charging points at our London office and have introduced a network of sustainability champions.
In June 2020, we launched our anti-racism commitments as part of our work to make Which? more diverse, inclusive and reflective of UK society and the consumers we represent. Here’s a little about how we have worked towards each of these commitments over the last year.
We’ve been working with an independent consultancy, Global Diversity Practice (GDP), to provide unconscious bias testing to inform training for leaders and managers, as well as other diversity and inclusion workshops. We also extended unconscious bias training to all colleagues. We formed our Diversity and Inclusion Strategic Taskforce, made up of colleagues from across all of our offices who volunteered to help shape our diversity and inclusion people strategy. Colleagues were encouraged to continue the conversation about anti-racism and racial inequality in diversity and inclusion-focused internal social channels.
We’ve also looked at our product reviews and content to ensure these are more inclusive. With regards to two-way conversation, we have established draft guidance for moderators on Which? Conversation as for what to allow, and what to discourage or remove, and have updated the terms and conditions, and community guidelines to emphasise appropriate behaviour.
Our reward policy plays an important role in helping us to attract and retain real talent and to motivate our people, ensuring that Which? can respond to key consumer issues and drive positive impact as the UK’s consumer champion. We heard from our employees that our previous reward approach was not well understood and did not support our strategic goals. During this year, we started a multiyear review of reward principles. We launched the new principles process with colleagues, and specific changes to elements of our total reward package are planned to take effect in 2021/22.
We talk openly about reward at Which? so that everyone understands our approach, how it works and what it means for them.
If the organisation has a great year, we want everyone to be able to share in that success and for individuals to feel directly their individual contribution towards that. Individual capability and demonstration of living our values and behaviours will be at the heart of salary progression. We actively involve our people to inform and develop our approach to reward so that it resonates with everyone and strengthens employees’ connection with Which?.
We externally benchmark all remuneration, mindful that we are a not-for-profit Group, owned by a charity and that our funding model is very different from many other charities. That’s because we generate all our revenue through our commercial subsidiaries, not through donations or grants. This also means we compete for talent in both the commercial sector and charity sector, and that our CEO and senior leaders receive both fixed-base salary and variable pay as part of their benchmarked total reward package. The variable pay element is capped at a maximum of 50% of basic salary for the CEO and 30% for Leadership Team members. It is calculated depending on performance over the year, with performance criteria set at the start of the financial year and achievement assessed by the Remuneration Committee.
Our gender pay gap outlines the difference in pay between men and women at the snapshot date of 5 April 2020. Our mean hourly pay gap for the Group, which includes Consumers’ Association and Which? Limited employees was 2.23%. This was a decrease of 0.8% versus the reported gap from April 2019. This gap is driven mainly by the higher proportion of male versus female employees in traditionally higher-paying male-dominated sectors such as Technology and Commercial. Our bonus gap also decreased to 21.23%. This can be attributed to two main factors:
• A number of our male key employees did not receive a bonus payment in the reporting period as this related to the previous financial year when they were not in role.
• For the reporting period there were a higher number of females vs males that received either a sales incentive payment or a personal bonus payment. We are expecting our pay gap figures to increase in the next reporting period as a higher number of male key employees will be eligible for a bonus payment within the reporting period, however we expect this figure to remain well below the national average.
Our key employees are defined as employees from our Leadership Team – the CEO and her direct reports. The total remuneration for our key employees was £2.22m as noted on page 51. This is an increase of 7.8% year-on-year. This increase was expected as we had a number of vacant roles within our Leadership Team for the 2019/20 financial year. While all those vacancies have now been filled, not everyone was in role for the full 12 months of 2020/21, in particular we have had changes to both our Chief Financial Officer and Chief Technology Officer. This means we expect total remuneration for key employees to increase in the coming year as we expect all key employees will have been in role for a full financial year.
Our highest-paid employee is our CEO:
Anabel joined the organisation in October 2018 and since that time there has been no change made to her remuneration package.
Below you will find the CEO pay ratio. This is the ratio of the CEO, our highestpaid employee when compared against the employees that represent the 25th, median and 75th percentile.
This calculation has used method A in line with the government recommendation. We have included any employee who has worked for at least one month during the calendar year to ensure an accurate full-time equivalent pay can be calculated. To ensure a like for like comparison we have calculated the full-time equivalent for any of the following:
• Employees who work part-time
• Employees who did not work the full 12-month period
• Employees who received reduced pay for any reason during the year.
This would include maternity pay, shared parental pay or statutory sick pay. All forms of pay and benefits have been included in the calculation of the pay ratio, but we have excluded any payments that do not relate to roles being performed. This includes payments made for first aid and fire marshall responsibilities or payments that related to compensation for loss of office. Our reported figure is significantly less than the average median ratio of the FTSE 350, which is 53:1.
The Council of Trustees is responsible for preparing the Council of Trustees’ report (incorporating Strategic report) and the financial statements in accordance with applicable laws and regulations. Company law requires the Council of Trustees to prepare financial statements for each accounting period. Under that law, the Council of Trustees has prepared the financial statements in accordance with the United Kingdom Financial Reporting Standard, comprising FRS 102 ‘The Financial Reporting Standard applicable in the UK and Republic of Ireland, and applicable law (United Kingdom Generally Accepted Accounting Practice)’. Under company law, the Council of Trustees must not approve the financial statements unless it is satisfied that they give a true and fair view of both the Consumers’ Association and the Group and of the incoming resources and application of resources including the income and expenditure of the Group for that year.
In preparing these financial statements, the Council of Trustees has:
• selected suitable accounting policies and ensured they have been applied consistently;
• observed the methods and principles in the Statement of Recommended Practice (SORP): Accounting and Reporting by Charities (2015);
• made judgements and accounting estimates that are reasonable and prudent;
• stated whether applicable UK Accounting Standards, comprising FRS 102, have been followed, subject to any material departures disclosed and explained in the financial statements;
• and prepared the financial statements on the going concern basis.
The Council of Trustees is responsible for ensuring adequate accounting records are kept that are sufficient to show and explain the organisation’s transactions and disclose with reasonable accuracy at any time the financial position of Consumers’ Association and the Group and enable it to ensure that the financial statements comply with the Companies Act 2006. It is also responsible for safeguarding the assets of Consumers’ Association and the Group and hence for taking reasonable steps for the prevention and detection of fraud and other irregularities. The Council of Trustees is responsible for the maintenance and integrity of the corporate and financial information included on its website. Legislation in the United Kingdom governing the preparation and dissemination of financial statements may differ from legislation in other jurisdictions.
After making enquiries the Council of Trustees has reasonable expectation that the Group has sufficient resources to continue in operational existence for at least 12 months from the date the financial statements were approved. Given that there are no material uncertainties inherent across the Group, the Council of Trustees continues to adopt the going concern basis in preparing these financial statements. Further information about the adoption of the going concern basis can be found in the principal accounting policies within the financial statements.
Our financial statements (which can be found in the pdf download at the bottom of this page) are made up of:
• a consolidated statement of financial activities (SOFA); designed specifically for charities, showing the income generated across the Group and how those monies have been spent;
• balance sheets for both Consumers’ Association and the Group, showing the total assets and liabilities as well as total reserves; and
• a consolidated cash flow statement showing how the Group cash balance has changed over the year.
These financial statements, including the Strategic report, comply with the current statutory requirements, the Articles of Association, the Financial Reporting Standard (FRS 102), the Charities Statement of Recommended Practice (SORP) 2015 and the Charities Act 2011. These principal statements are supplemented by extensive notes, providing further insight into the financial performance of the Group, and together form the financial statements of the Group.
2 Marylebone Road, London NW1 4DF 8 October 2021