The Captain Tom Moore Foundation: Daughter and son-in-law disqualified by the Charity Commission

I’m sure we all recall the heroic efforts of the late Captain Tom Moore in 2020 when the Covid-19 pandemic took hold of the country. Captain Tom completed the amazing feat of walking 100 laps of his garden and raised £38 million for NHS charities. He inspired many to donate and join him and he received a knighthood for his contribution. Unfortunately, Sir Tom passed away in February 2021, at the age of 100.

His family set up The Captain Tom Moore Foundation in June 2020 to make grants to worthy causes important to Sir Tom. Sir Tom’s daughter, Hannah Ingram-Moore, her husband, Colin Ingram-Moore, and other charity trustees led the foundation.

Less than a year after its registration, the Charity Commission opened a case into the foundation after becoming concerned about potential mismanagement and misconduct by the charity trustees. In particular, the regulator was concerned that variations of the name “Captain Tom Moore” were registered as trademarks in the name of a company called Club Nook Limited, with seemingly no consideration for the potential loss of profit for the foundation. Club Nook Limited is a private company controlled by Hannah Ingram-Moore and Colin Ingram-Moore.

Before opening the inquiry, the Commission was asked to consent to the employment of Hannah Ingram-Moore as CEO of the foundation, on a salary of £60K per year for 3 days a week. The Commission requested further evidence that proper benchmarking had been carried out. The trustees sought to provide further evidence along with a new proposal to appoint Hannah-Ingram Moore on a salary of £100K on a full-time basis. The regulator was not satisfied with the evidence and refused to give consent.

The Commission’s inquiry looked at whether:

  • the trustees were responsible for mismanagement and/or misconduct in the administration of the foundation and whether this resulted in any financial losses to the charity;
  • any such financial losses were as a result of unauthorised private benefit to Sir Tom’s daughter and her husband;
  • the trustees had adequately managed conflicts of interest, including with private companies (i.e. Club Nook Limited) connected to Sir Tom’s family; and
  • the trustees had generally complied with their legal duties and responsibilities under charity law.

The Charity Commission has now confirmed that it has disqualified Hannah Ingram-Moore and Colin Ingram-Moore from acting as charity trustees and/or holding senior manager functions within a charity for 10 years and 8 years respectively. Put simply, the regulator considers them unfit to hold such a position due to their misconduct/mismanagement whilst at the helm of The Captain Tom Moore Foundation. The inquiry is ongoing.

The Ingram-Moore family has issued a statement in response to the disqualification order that they “fundamentally disagree” with the decision, and questioned the regulator’s motives.

It should be made clear that the £38 million raised by Captain Tom in 2020 had already been distributed to NHS Charities and is not under investigation.

What next for Sir Tom’s legacy? In July 2023 the foundation confirmed it had ceased actively seeking donations or making payments to charities to focus on the inquiry, which the Commission has yet to conclude. It is clear that his legacy is under threat due to the monumental reputational damage suffered by the foundation, however, there is no denying that the image of Captain Tom Moore and his walking frame provided inspiration and hope to many during the early days of the Covid-19 pandemic.

For charities and the third sector, the foundation is a reminder to charity leaders of the importance of complying with their duties and responsibilities under charity law. This includes:

  • making decisions only in the best interests of the charity;
  • identifying and managing conflicts of interest and conflicts of loyalty, which a conflict of interest policy can help with;
  • being aware that private benefits to trustees and/or family members/connected persons present a clear risk to your charity, must be carefully managed and may require Charity Commission consent.

If you would like advice about any of the issues raised in this article, please contact Bethan Walsh, Head of Charities.

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