Same Circle, Different Logos: When Community Governance Starts Eating Itself
There’s a point in any piece of local scrutiny where you stop asking
“Is this just one organisation?”
and start asking
“Hang on… why does this keep happening?”
Welcome to that point.
Over recent months I’ve been pulling together governance, funding and financial data relating to a small cluster of Sandwell-based organisations. What started as a single review has now become a full Master Foundation Document (MFD), cross-referenced, evidence-logged, and — crucially — escalated to regulators.
And the picture that emerges is… familiar.
Different names.
Different logos.
Same ecosystem.
Same patterns.
Same silence.
Let’s Start With the Money (Because It Always Starts There)
Take the Confederation of Bangladesh Organisations (CBO).
According to its published accounts (year ended 31 March 2025), this is not a small, informal “passing the biscuit tin” operation:
- Annual income: ~£352,000
- Total funds / reserves: ~£772,000
- Current assets: ~£491,000
- Fixed assets: ~£284,000
- Including freehold property valued at £250,000
That’s three-quarters of a million pounds in total funds.
Which means — and this is important — scrutiny is not only reasonable, it is proportionate.
Déjà Vu: Operating Deficits, But the Reserves Are Fine, Thanks
Here’s where the tune starts sounding familiar.
CBO’s accounts show:
- An operating deficit for the year
- At the same time as designated funds are maintained or increased
- Alongside substantial property and land holdings
Now, none of that is automatically improper. But when deficits coexist with healthy reserves and locked-away assets, the obvious question is:
What is the reserves policy actually for — and how is it being applied?
That question was asked.
It was asked politely.
It was asked in writing.
No response.
Same Table, Same Guests: The Consortium Connection
Public records show that CBO has acted as an organisational director of Sandwell Consortium CIC.
So has Bangladeshi Women’s Association.
Which means:
- Organisations that receive Consortium-linked funding
- Also sit within the Consortium’s governance structure
- While acting as delivery partners for Consortium-branded programmes
That doesn’t automatically mean anything improper is happening.
But it does mean that independence, conflict-of-interest management, and transparency matter more — not less.
When the same organisations keep reappearing at the commissioning table, the coordination table, and the delivery table, people are entitled to ask whether challenge has quietly left the room.
Current Assets: Cash, or “Money We’re Hoping Turns Up”?
Another familiar note in the accounts:
- Current assets of ~£491,000
- Creditors of just ~£3,700
Which raises the sort of dull but important question accountants love and PR teams don’t:
How much of that is cash in the bank — and how much is money owed, delayed, conditional, or dependent on delivery?
That question was also asked.
Still no reply.
Property, Land and “Income Generation”
The accounts reference:
- Freehold premises
- Land holdings
- Language around retail or income-generation activity
Again: not wrong.
But once charities drift towards development and trading, governance expectations increase sharply.
Is it primary purpose trading?
Ancillary?
Non-primary with a subsidiary?
Who signs off the risk?
Reasonable questions.
Still silence.
Attempts to Engage: Documented, Polite, Ignored
Let’s be very clear about process.
- 24 December 2025 — a detailed, evidence-based, non-accusatory email was sent to CBO trustees and senior management
- 19 January 2026 — a formal escalation followed, asking at minimum for acknowledgement or a response timetable
Both emails relied only on:
- Published accounts
- Public registers
- Verifiable facts
Both emails were ignored.
No acknowledgement.
No response.
No engagement.
Silence becomes part of the evidence when it’s repeated.
Escalation: Because At Some Point, You Have To
Given the lack of trustee engagement, matters were escalated appropriately.
On 20 January 2026, the Charity Commission for England and Wales formally acknowledged receipt of a Raising Concerns submission relating to CBO (reference CRM26:004945639).
The concerns raised focused on:
- Governance transparency
- Conflicts of interest
- Reserves and asset management
- Failure to engage with reasonable public-interest scrutiny
Assessment is now underway.
That is not drama.
That is process.
And Here’s the Bit That Really Matters
When you line up:
- CBO
- BWA
- Sandwell Consortium
…and compare governance roles, funding dependency, financial patterns, and responses to scrutiny, you don’t see three isolated cases.
You see a system.
A system where:
- The same organisations recur across governance and delivery
- Public funding is heavily relied upon
- Operating deficits coexist with protected reserves
- And scrutiny is met not with explanation, but with silence
None of this proves wrongdoing.
But it does explain why regulators, funders and the public are entitled to look more closely.
Final Thought
Transparency isn’t hostile.
Scrutiny isn’t personal.
And accountability isn’t optional once you’re handling public money, property assets, and six-figure reserves.
If organisations want public trust, they don’t get it by saying nothing.
They get it by answering.
#Sandwell #CharityGovernance #PublicMoney #Transparency #Accountability #VoluntarySector #SameOldCircle #FollowTheMoney #GovernanceMatters
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