Random Musing

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Mr Raccoon


I have read (Old Holborn amongst others) that the UK Association of Chief Police Officers (ACPO) is a Limited Company. Considering their regular news presence and frequent advice to UK police forces to (amongst other things) ignore the law (to ignore the EU court judgement on DNA retention policy until the Home Office decides what to do being one example), I think most people would find it surprising that they are a self serving corporation separate from the UK government and UK police.

Finding myself at a loose end at the weekend, I decided to have a look at their website to see for myself.

As a brief background, all UK Limited companies must disclose certain information on official documents which includes websites for example.

From the Companies House website we have the following extract of the Companies Act 2006 :

6. What additional information must I disclose?

On all its business letters, order forms and websites a company must display:

* the part of the United Kingdom in which the company is registered (ie England and Wales, or Wales, or Scotland, or Northern Ireland);

* the company’s registered number;

* the address of the company’s registered office;

* if a company is exempt from the requirement to use “limited” in its name, the fact that it is a limited company;

* if the company is a community interest company which is not a public company, the fact that it is a limited company;

* if it is an investment company as defined by section 833 of the Companies Act 2006, the fact that it is this type of company;

* if it is a company which has chosen to display its share capital, it must display the amount of paid up share capital.

Further particulars to appear in business letters, order forms and websites

Section 7

2(d) in the case of a limited company exempt from the obligation to use the word “limited” as
part of its registered name under section 30 of the Companies Act 1985(a) or article 40 of
the Companies (Northern) Ireland Order 1986(b), the fact that it is a limited company;

In a nutshell, they have to display company number, registered office, registered country and the fact they are a Limited company if they are exempt from having Limited in their name.

From ACPO’s website we have an About Page and Home Page, neither of which mention any of the above details.

It is only when we get to the Contact Page that we see the following :

1st Floor, 10 Victoria Street, London SW1H 0NN

Company Number: 3344583
Registered in England & Wales

At this point, I was wondering what their status actually is as they don’t have Limited in their name but do display some of the details required by a Limited company, albeit not on the about page and also not mentioning whether the address is the registered office or not.

I then went to Companies house and paid my £1 to see their latest annual return which gives us this :

Name & Registered Office:
Company No. 03344583

Company Type: PRI/LBG/NSC (Private, Limited by guarantee, no share capital, use of ‘Limited’ exemption)

This quite clearly shows they are a Limited company but also shows that they are exempt from using the word Limited in their name. You will recall from the Companies Act 2006 that this information must be stated clearly along with the other particulars yet looking on all the sections of their website, I cannot see any reference to Limited or their exempt status.

Under the 2006 Companies Act, it would suggest that an offence has been committed here :

10.—(1) Where a company fails, without reasonable excuse, to comply with any requirement in
regulations 2 to 9, an offence is committed by—
(a) the company; and
(b) every officer of the company who is in default.
(2) A person guilty of an offence under paragraph (1) is liable on summary conviction to—
(a) a fine not exceeding level 3 on the standard scale; and
(b) for continued contravention, a daily default fine not exceeding one-tenth of level 3 on the
standard scale.

The question remaining in my mind is whether this is a deliberate omission to hide their status from a casual reader or an unfortunate oversight.

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