Around £1.2 billion has been “wasted” on “fake apprenticeships” that have taken up half of all starts since the apprenticeship levy was introduced in May 2017, according to new research. 

The study by think tank EDSK goes on to recommend that apprenticeships should be for level 3 only, while standards at level 2 and degree-equivalent courses should be defunded. 

This is the third report into the apprenticeship system by EDSK director Tom Richmond (pictured), a former senior adviser to previous skills ministers Nick Boles and Matt Hancock, who told FE Week with this latest publication: “We have the full two years of data on the levy and we can now see exactly what is happening. 

The apprenticeship levy is now descending into farce

“In the past, I have looked at the foundations of the reform and the history and what might have happened.  

“Now we can see, and I don’t think anyone has done this analysis before, who is being supported, what is being supported and why it’s being supported.” 

What he has found is that the levy is “descending into farce” because employers and higher education providers are “abusing” it by “rebadging existing courses and degrees for their own financial gain”. 

He said employers have used up over £550 million of levy funding on rebadged management training and professional development courses for more experienced employees. As a result, the most popular apprenticeship in the country is now becoming a ‘team leader / supervisor’ – accounting for almost 1 in 10 apprentices. 

This will be of no surprise to FE Week readers, as this newspaper has warned about the unstoppable rise of management apprenticeships since 2016.

A further £235 million of levy funding has been used to deliver various “low-skill and generic jobs” that are now counted as an apprenticeship, including working on a shop checkout and serving drinks in a bar. 

The most “surreal” example of a rebadged apprenticeship Richmond could find was the level 3 sporting excellence professional, which challenges learners to “competently perform the professional sport in which they train”. 

“In other words, the apprentice will be playing sport,” Richmond writes. 

He also highlighted a new cabin crew standard that has a minimum duration of 12 months for training, whereas airlines are currently advertising cabin crew training – not through the apprenticeship route – that lasts just three-weeks. 

Meanwhile, he says, universities rebadging bachelor’s and master’s degrees as apprenticeships have used up £450 million of the levy to date, even though these degrees can already be funded through the student loan system.

Richmond said they’re allowing employers to draw on huge amounts of levy funding to use courses like the level 7 ‘accountancy/taxation professional’, which spent £174 million since 2017 by claiming to cover a number of different accountancy and auditing roles.

A member of the Commons Public Accounts Committee, Layla Moran, said she had “serious concerns” about the government allocating one provider up to £40 million in nine months to teach this controversial management consultancy apprenticeship, following FE Week analysis in March 2019.

Richmond isn’t the first person to flag these issues: Ofsted chief inspector Amanda Spielman warned in 2018 that existing graduate schemes were being “rebadged as apprenticeships,” and the National Audit Office reported last year “some employers use apprenticeships as a substitute for training and development that they would offer without public funding”. 

Richmond’s report, entitled Runaway Training, recommends rebranding the apprenticeship levy as the technical and professional education levy to incorporate all work-based learning from level 4 to level 7.

The term “apprenticeship” should be newly defined and restricted to training at level 3 only, which should be fully-funded by government like A-levels. 

It adds that Ofsted should be made the sole regulator for any apprenticeships and technical and professional education, including provision in universities. 

Currently, Ofsted and the Office for Students (OfS) share responsibilities for inspecting apprenticeships, with the latter monitoring higher levels, a decision Richmond says is “hugely problematic” as the OfS has “no expertise” in the area and does not have the power to enter premises to conduct on-site inspections. 

An OfS spokesperson said the watchdog’s “quality assessment process” includes “on the ground quality and standards reviews”. 

“We also have clear powers to require information, set specific conditions and impose sanctions if providers fail to meet rigorous standards,” she added. 

The report is being released ahead of an expected budget from the Treasury next month and the later spending review, which will set the apprenticeship budget for the next five years. 

It also comes at a time of increasing pressure for the levy: after the Institute for Apprenticeships and Technical Education predicted the levy would be overspent this year and the National Audit Office expressed concern about the financial sustainability of the apprenticeship system, the DfE’s top civil servant warned of “hard choices” that needed to be made. 

A Department for Education spokesperson said their reforms “mean apprenticeships are better quality”, lasting for a minimum of 12 months with at least 20 per cent off the job training. 

She added that legislation introduced in 2017 meant an apprenticeship had to meet set criteria and the minimum quality requirements. 

A spokesperson for the IfATE said it works “closely with thousands of employers as well as many other stakeholders to make high quality apprenticeship standards available across the whole economy”.

“This has led to a broader variety of apprenticeships up to degree-level being available to employers, a far better reflection of the nation’s skills requirements than if apprenticeships were limited to level 3,” he added.

Sector reaction

Sector organisations have reacted strongly to the report, with Association of Employment and Learning Providers chief executive Mark Dawe stating that Richmond “sounds like a scratched record”. 

He said apprenticeships “should be available to employers of all sizes to access to the full range of apprenticeship programmes from level 2 through to level 7”. 

“AELP totally rejects his claim that the new level 2 standards in England fall short of the International Labour Office definition of a ‘proper apprenticeship’ and the caricatures used bear no resemblance to the reality of what is actually being learnt by the apprentice,” Dawe added. 

University Vocational Awards Council chief executive Adrian Anderson believes EDSK has “got the wrong end of the stick,” as the apprenticeship system is about “enabling employers to invest in their staff to increase productivity”. 

David Hughes, the chief executive of the Association of Colleges, warned that “simply stopping level 2 apprentices will not solve the problem; in fact it would risk shutting some of the most vulnerable people out of education and training”. 

“Problems also exist at the highest levels – MBAs and other high-level training being rebadged as ‘apprenticeships’ need to be examined,” he added. “Their growth has been at the expense of chances for younger people looking for their first opportunity in the workplace.”

For the last 12 days of 2019 we’re running back through the previous 12 months of FE Week. Last up is December…

FE Week reached a milestone 300^th edition this month, our front-page story of which exposed how Hull College Group had paid former staff substantial sums to stop pursuing bullying and pay-related sexual discrimination claims.

The HR director joined the group’s chief executive on a leave of absence after an ongoing independent investigation found dozens of pay-offs and non-disclosure agreements.

The big national news for the month centred on the general election, for which we put together a supplement with our sister title FE Week, and took each party to task on their promises for education.

The Conservatives ended up winning the election by a landslide majority, with former skills minister Anne Milton and her opposite number Gordon Marsden falling as two high profile FE casualties.

Prime minister Boris Johnson will have a number of new FE promises to fulfil including £600 million a year for a new National Skills Fund, £1.8 billion for college capital projects and a UK Shared Prosperity Fund to replace EU funding, including the European Social Fund.

Also in December, Alfie Earlam, a T-level student at New College Stamford and Quibble Content who described himself as “one of the few lucky students trialling them,” wrote for FE Week about the benefits of the programme for both employers and students.  

FE Week continued our campaign on loan scandal victims this month, revealing that the government had not contacted hundreds of people in scope despite having the power to cancel their debts.

Our last edition of the year included with an interview with Capital City College Group’s chief executive Roy O’Shaughnessy who blamed “inept” staff for its deficit unexpectedly rising to £9.7 million.

This latest disclosure comes after an already rocky few years for CCCG, in which unplanned multi-million-pound deficits of £5 million in 2016/17 and £6 million in 2017/18 have already led to job cuts.

We finished on some heart-warming news as Oldham College learners teamed up with BBC Breakfast to deliver a Christmas tree and a carol concert to a lonely local pensioner.

For the last 12 days of 2019 we’re running back through the previous 12 months of FE Week. Here’s what happened in November…

This month we revealed adult learners were being forced to pay back loans for courses which they had not started or were even aware they had signed up to.

One such learner, Grzegorz Bogdanski, said all the authorities involved had “washed their hands” of his case.

FE Week spoke to 12 other Southampton-based Polish building and construction workers who also claimed that they have loans due for courses they did not complete with Edudo Ltd, which later collapsed.

However, in our next edition we were able to report that Edudo’s prime contractor, West London College, had promised to pay off almost £250,000 in loans debt for the 59 victims, in our biggest win of the year.

Bogdanski said he was “so overjoyed it’s hard to describe its sensational feeling”.

Yet more good news came when Newcastle and Stafford Colleges Group received a grade one from Ofsted. Principal Karen Dobson said the ‘outstanding’ result came about because the amount of time inspectors speaking to people on campus “played to our strengths”.

The feat was all the more impressive considering the group was formed through a merger in 2017, when Newcastle College was rated ‘good’ but Stafford College was ‘inadequate’.

We then explored why colleges across the country have been entering more students for GCSE maths and English re-sits than government policy requires, and revealed that a move to campus-level Ofsted grades for college groups is back on the cards and could be introduced as soon as next September.

The Association of Colleges held their annual conference for 2019 for two days at the end of November, where six college leaders shared the “heart-wrenching” impacts of government funding cuts after speaking anonymously to FE Week.

Elsewhere, Highbury College’s principal was suspended and their chair quit “for the good of college, staff and students” following FE Commissioner intervention.

This newspaper profiled the new president of the National Union of Students Zamzam Ibrahim this month. The former vice-president of society and citizenship said “we need to do much more about access to courses” and pledged her support for a national education service with an emphasis on lifelong learning.

FE Week also investigated the growing trend of the use of therapy dogs in colleges after a dog that helped students struggling with mental-health issues won praise from Ofsted inspectors.

 

Adult participation in education has fallen to record low with almost four million ‘lost learners’ since 2010, according to new data from the Learning and Work Institute.

The policy, research and development organisation urged the government to put lifelong learning “at the heart of its domestic agenda” after just one in three adults were found to have taken part in learning in the last three years.

It called for a national mission to be set up to reverse the decline, “backed up by sustained additional investment, and a cross-government strategy”.

The 2019 survey by the Learning and Work Institute showed that adult participation has fallen 10 percentage points since 2010, from 43 per cent down to 33 per cent – the lowest figure on record.

It is equivalent to 3.8 million fewer adults taking part in learning since the start of the decade.

The proportion declined from 35 per cent in 2018, 37 per cent in 2017 and 41 per cent in the previous survey in 2015.

Adult learning is heading in the wrong direction

Learning and Work Institute has been tracking the number of adults taking part in education or training in the UK since 1996.

Stephen Evans, chief executive of Learning and Work Institute, said the figures “should be a real cause for concern”.

“With our economy set to undergo transformational change in the coming years, lifelong learning has never been more important.”

The fall in participation followed a significant decline in investment over the last decade.

Between 2009-10 and 2018-19, government spending on adult education excluding apprenticeships decreased by 47 per cent, according to the Institute for Fiscal Studies.

After winning a majority in the general election on December 12, prime minister Boris Johnson has a new FE promises to fulfil.

The Conservative manifesto said the party would launch a £600 million a year “new National Skills Fund” towards creating a “right to retrain” if they formed the government, amounting to £3 billion over the Parliament.

Adult education had been snubbed in the Chancellor’s Spending Review, which handed £400 million to students aged 16 to 19 but nothing for older learners.

Former chair of the education select committee, Robert Halfon MP, called adult learning “one of the most important challenges facing our nation”.

He said: “We need to do more, looking again at personal learning accounts or social credits to those undertaking adult learning, as well as tax credits for businesses who retrain their workers.

“We must also ensure that we have Adult Community Learning Centre in every town in the country.”

The survey also found inequalities in access to learning.

Adults in lower socio-economic groups (DE) were almost half as likely to take part in learning at 21 per cent, than those in higher socio-economic groups (AB) at 41 per cent.

In addition, only 18 per cent of adults who left school at 16 or younger took part in learning compared to 40 per cent of those who stayed on in full time education until at least 21.

The 2019 survey included 5,244 adults aged 17 and over across the UK, with fieldwork conducted in September 2019.

Learning and Work Institute claimed increasing the number of adults accessing education and training will provide economic benefits by being “vital both to boosting productivity and to supporting adults to adapt to rapid economic change”.

Commenting on the findings, Matthew Fell, CBI Chief UK Policy Director, said: “Adult learning is heading in the wrong direction at precisely the wrong time for our economy and our society. “Technology is rapidly changing the world of work and driving up demand for new and higher skills.”

He claimed nine in ten workers will need some form of reskilling by 2030, and as a result, “we need the partnership of the century between individuals, business and government to ensure that everyone can benefit from the opportunities created by new technologies”.

“Lifelong learning will be one of the defining issues of our age – countries who get it right will have an exceptional competitive advantage,” Fell added.

A Department for Education spokesperson said: “This government is investing in Britain’s people to level up skills across the country. The National Skills Fund will invest an extra £600 million a year to help people learn new skills so they can return to work or further their careers.

“The National Retraining Scheme is supporting adults whose jobs are evolving through the use of AI or automation so they can retrain and open up the path to a new and exciting future.”

She added: “Our investment in adult education has supported over a million people in 2018/19 to progress into work, further study, or an apprenticeship.

“This includes fully funded courses in English and maths, for adults who need to improve their literacy and numeracy. From 2020 we will also provide full funding for adult basic digital skills courses so more people can develop these essential skills to get ahead in work and in life.”

For the last 12 days of 2019 we’re running back through the previous 12 months of FE Week. Today we take a look at October…

Colleges received a welcome boost when analysis revealed 78 per cent of them had received the top two Ofsted grades – ‘outstanding’ or ‘good’ – a record high proportion since comparable records began in 2015.

After being shown FE Week’s analysis, Gavin Williamson described FE as a “vital” part of the education system and expressed his thanks to all lecturers, leaders and support staff for their hard work.

The education secretary also defended his old sixth form, Scarborough Sixth Form College, after it dropped out of offering digital T-levels, as he pledged to convene business leaders in an attempt to address shortages of work placement opportunities.

One week later it was announced that NCFE and City & Guilds had won contracts to deliver the second wave of T-levels.

The Association of Employment and Learning Providers also held its autumn conference this month, where chief executive Mark Dawe alleged that sex discrimination may lay behind decisions on funding rates.

Thousands of students, staff and people who love colleges across the country then signed pledge cards and handed them to their local MP to mark this year’s Colleges Week.

Hannah H from National Cyber Security Centre told us why it is vital that everyone in the FE sector understands their own role in protecting their networks, following a string of cyber hacks.

She provided five measures colleges could take to make any attack less likely to succeed in the first place and, if they are affected, to reduce its impact.

FE Week also continued its revelations about Hull College Group. The investigation of the college surviving on bailout funding was understood to include more than £100,000 spent on a computer game app, computer game-style cinema advertising and a PR agency that promoted a music event and computer game.

The spending on hiring an orchestra was described as “concerning” by the college’s local MP, Emma Hardy, a member of the education select committee.

Meanwhile, the government announced plans for a radical overhaul of its subcontracting rules amid high-profile cases of “deliberate” fraud, and a former adviser to the minister for higher education expressed “concern” that dozens of providers delivering level 6 and 7 apprenticeships are still going without inspection, more than four years after the courses began.

We also sat down with Charlotte Bosworth, the managing director of Innovate Awarding, who told Jess Staufenberg that she is quite happy to be known as the “end-point assessment woman”.

Staufenberg then set out what Lord Agnew’s appointment as a minister for FE might mean for the sector, having closely followed his career in the schools sector, where his reputation divides opinion.

A former specialist college principal has been made a dame while a well-known champion of adult education has been recognised with a CBE in the New Year’s honours list.

Nearly 20 other leading figures from the FE and skills sector, including three general FE college principals and a gold medallist from WorldSkills UK, have been awarded accolades by the Queen.

Dr Caroline Allen, who retired from Orchard Hill College this summer after 32 years, received a damehood for her services to education.

She guided the college, which trains students with learning difficulties, to an Ofsted grade one in 2013. She also headed up the Orchard Hill Academy Trust.

“I’m absolutely delighted to be receiving this honour,” Allen said.

“I have been privileged to work with very talented students with special needs and with highly skilled staff, senior leaders, board members and governors at Orchard Hill College & Academy Trust.

“It is a unique and remarkable organisation and I owe the achievement of this honour to the support and commitment of the people there.”

Dr Sue Pember was one of five people from the adult education community to be honoured, receiving a CBE.

The former director of FE at the Department for Education and now policy director of adult education network HOLEX said she feels “this honour is not just about me but also recognises the work the sector does with adults who may have missed out at school and adult education gives them a second chance.

“I hope that everybody who has supported me throughout my career feels some pride in the fact that I have received this honour because I would not be in this position without their help, support and continued enthusiasm, energy and passion for lifelong learning.”

Also picking up a CBE was Christine Hodgson, chair of the Careers and Enterprise Company.

Five FE and skills sector representatives were recognised with OBE’s, including principal of City College Norwich Corrienne Peasgood.

She joined City College Norwich in 1997 as a lecturer in plumbing and became its leader in 2012.

“I feel hugely honoured to receive this award,” said Peasgood, who is also on the board of the Association of Colleges.

“It points to what can be achieved through collaboration, teamwork, and inclusiveness – and to the importance of removing our institutional hats, from time to time, and working out together what is right for students or for a particular sector.”

Another AoC board member and college boss to pick up an OBE was Graham Razey.

The now chief executive of the EKC Group has spent 25 years in the college sector. He has recently been appointed to the DfE’s Principals’ Reference Group, as well as becoming a National Leader for FE.

“From the very first lesson I delivered, I was hooked on how FE transforms lives,” Razey said.

“I am truly honoured to receive this OBE and hope in some way that it helps to raise the profile of technical and vocational education.

“I have been blessed with having a great network supporting me, but I would like in particular to thank my wife and son who have been my rocks, and with whom I look forward to celebrating this honour.”

Head of the National Careers Service, Louise Proctor, has also been honoured with an OBE.

She said she is “passionate about the power of careers advice and how it can change lives for the better” and added she is “inspired every day by the talented, hardworking people that I work with”.

Among the FE and skills figures recognised this year with an MBE is Diana Batchelor, principal of Abingdon and Witney College, who has spent 36 years in the further and adult education sector.

She joined Abingdon College in 1992 as the head of community education and became principal in January 2016.

“I am quite amazed to have been recognised in this way and very grateful,” Batchelor said.

“I’ve always had the very good fortune to work with fantastic colleagues without whom I couldn’t have achieved anything at all.”

Two WorldSkills UK representatives ­– painting and decorating training manager Peter Walters and former beauty therapist gold medallist Kaiya Swain – received an MBE and British Empire Medal respectively.

Swain said she “couldn’t believe” the news when she heard about it.

“Taking part in WorldSkills competitions and winning gold in Abu Dhabi changed my life,” she added.

“It gave me the confidence to grow my own beauty business Kaiya Swain Beauty and I hope through my continued support for WorldSkills UK I can inspire more young women to follow their career goals.”

Who got what in FE and skills:

Damehood

Dr Caroline Allen, principal and chief executive officer, Orchard Hill College and Academy Trust – for services to education

CBE

Christine Hodgson, chair, Capgemini UK and chair, The Careers and Enterprise Company – for services to education

Dr Susan Pember, director of policy and external relations, HOLEX – for services to adult education

OBE

Pauline Anderson, director of learning and skills, Derby City Council and chair of the trustees of the Traveller Movement – for services to children and young people in Education

Florence Davies, head of director general office and policy profession lead, Department for Education – for services to diversity and inclusion

Corrienne Peasgood, principal of City College, Norwich – for services to safeguarding and construction skills in Norfolk

Louise Proctor, head of National Careers Service – for services to education and careers

Graham Razey, chief executive of the EKC Group and memberof the principals’ reference group – for services to education

MBE

Diana Batchelor, principal of Abingdon and Witney College – for services to further and adult education

Elaine Billington, lately chair of the North West Apprenticeship Ambassadors Network – for services to apprenticeships and young people in North West England

Jenifer Burden – for services to education

John Butler, lately chair of governors at Furness College – for services to FE

Aziza Chaudry, quality manager for Adult Education Wolverhampton – for services to education

Francis Clayton, chair of the Yorkshire and the Humber Apprenticeship Ambassador Network – for services to apprenticeships

Lisa Dancer, adult education quality manager – for services to adult learners with mental health issues in the London Borough of Hillingdon

Carolyn Keen, chair of governors, Westminster Adult Education Service – for services to adult education and the community in London

Dominique Unsworth – for services to apprenticeships

Peter Walters, training manager at WorldSkills UK – for services to the WorldSkills competition

Yolande Stanley, former pâtisserie and confectionary training manager at WorldSkills – for service to young people in the hospitality industry

British Empire medal

Amanda Reeve, curriculum manager at Norfolk County Council Adult Learning – for services to education

Kaiya Swain – for services to the WorldSkills competition

For the last 12 days of 2019 we’re running back through the previous 12 months of FE Week. Here’s what September included…

It was scoops galore for FE Week this month, featuring our front page about Highbury College principal Stella Mbubaegbu’s £150,000 expenses, which prompted government intervention.

The story, which was picked up by a number of Fleet Street newspapers, reported how she had spent college money on first-class flights, five-star hotels, and lobsters and cocktails. It followed a year-long freedom of information battle.

We also revealed how Brooklands College’s future was in the balance following a £20m apprenticeship subcontracting scandal. It was told to pay the funding clawback owing to its dealings with training firm SCL Security Ltd.

The DfE then confirmed it was “carefully monitoring” an investigation into Hull College Group following allegations of nepotism and inappropriate use of funds.

In other news, the new education secretary Gavin Williamson wrote for us, saying that he was “determined to put FE centre stage”.

And Lord Agnew was given responsibilities for FE and used his first opinion piece for FE Week to warn that he would “not hesitate to step in” on college spending.

He said he was “100 per cent” committed to helping providing colleges, who he said have a responsibility to the taxpayers who fund them, with the support they need to deliver high quality education.

The first provider to be inspected under Ofsted’s new inspection framework also spilled the beans the “very different” regime. The watchdog’s focus has moved from outcomes to the “quality of education” and what is being called the three I’s: intent, implementation, and impact.

And we sat down with Simon Connell, the new chief executive of the Baker Dearing Trust, who is on a mission to change perceptions of university technical colleges, while Sam Parrett, boss of London South East Colleges, said it’s worth trying to see if the football transfer process could work in the regulated world of FE.

For the last 12 days of 2019 we’re running back through the previous 12 months of FE Week. Today we take a look at August…

There was no print edition this month during the summer holidays but there was no let-up for FE Week: Chancellor Sajid Javid announced a £400 million boost for 16- to 19-year-old learners, which he called “the biggest increase for a decade”.

It included £190 million to increase the base rate of funding for that age group, to £4,188. There was also £120 million to help deliver “expensive but crucial” subjects, such as engineering, in the funding package.

The funding will come into effect in 2020/21 and cover the 257 colleges in England, as well as other FE providers like school sixth forms.

We also jetted off to Russia for WorldSkills Kazan 2019 with Team UK. WorldSkills is a biennial competition that featured more than a thousand competitors from over 60 countries.

Four days of skills competitions took place at the event and the UK won two golds, one silver, one bronze and 15 medallions of excellence – for those who achieved the international standard in their chosen skill.

Aircraft maintenance gold medal winner Haydn Jakes told FE Week winning “was a really pleasant surprise” while the other UK gold medal winner, Rebecca West, who placed first in beauty therapy, said she felt “really, really amazing and so proud”.

The medal winners got their moment of glory at the dazzling closing ceremony, which was attended by Russian president Vladimir Putin.

The WorldSkills flag was then handed over to China, marking the start of the run-up to WorldSkills 2021 in Shanghai.

The UK came in 12th place in the medal table overall, missing out on the top ten of participating countries for the first time in ten years.

For the last 12 days of 2019 we’re running back through the previous 12 months of FE Week. Here’s what July involved…

There was bad news for the sector this month after FE Week found only seven per cent of college principals were from a Black, Asian or minority ethnic background. Our analysis also showed that three out of nine English regions had an all-white set of principals.

Ali Hadawi, principal at Central Bedfordshire College – one of just 13 non-white general FE college bosses of 185 identified in FE Week’s study – said he was “not surprised” by the numbers and called for a “programme that targets the under-represented to understand what holds them back”.

Further outrage struck in the sector when the ESFA demanded all subcontracting contracts, for both adult education budget and apprenticeship funding, include for the first time a “list of individually itemised, specific costs for managing the subcontractor”.

Mark Dawe, chief executive of the Association of Employment and Learning Providers, said a “simple solution has been ignored and instead, this immensely bureaucratic process appears both out of the blue and shockingly late in the day”.

Meanwhile, it was good news as Energy Coast became the second-ever ‘outstanding’ UTC, and FE Week sat down with Milton Keynes principal Julie Mills, who spoke about completing a PhD on prison staff, the college’s institute of technology and some of the other 400 ideas she has “every day”.

In the last issue of the academic year, we also featured the principal leading the first sixth-form college to become a converter academy.

Matthew Grant, from Priestley College in Warrington, described what he felt was the key to success: “Where I’ve heard there might be issues with academising is where a sixth-form college has joined an existing academy trust and all the trustees are already in post, all the policies are there, and there’s no opportunity to influence the culture or the way it operates.

“We’ve ensured our trustees didn’t come mainly from one organisation within the trust.”