Insolvency Services 'Rap Sheet'

Listing the provable and evidential failures & misdemeanours of the UK Secretary of State and Insolvency Service

Introducing the INSOLVENCY SERVICE 'RAP SHEET'

This ‘Rap Sheet’ is a list of all the major failures and misdemeanours that the UK Insolvency Service have committed in their dealings with Lighthouse International Group and now Lighthouse Global, since their corrupt ‘investigation’ began back in June 2022. These points can all be backed up with evidence. 

This list is also a practical explanation as to how the UK Government is, by refusing to take responsibility for these failures, now setting a precedent for anonymous predatory trolls to essentially weaponise government departments and public resources against innocent parties for their own personal agenda and gain.

Click on the numbered points where you see a ⊕ to see the expanded points.. 

1. The precedent being set by the Secretary of State is that it can justify doing whatever it wants in the name of public interest and without public accountability

1.1 The Insolvency Service refuses to acknowledge it can be weaponised by anonymous predatory trolls to attack any business in the UK.

1.1.1 Multiple employees from different departments of the Insolvency Service have refused to listen and have ignored evidence of how its investigations, systems and processes can be and have been weaponised as part of malicious smear campaigns by predatory trolls.

1.1.2 The Department of Secretary of State for Business and Trade works on the basis that when another department makes a decision, that decision is followed blindly without question or any form of discernment and rigour.

1.1.3 The Insolvency Service and High Court for Justice refused to consider over 600 pages of condensed evidence proving that the investigation of Lighthouse International Group originated from individuals behind an orchestrated smear campaign.

1.2 The Insolvency Service’s incompetence creates the danger of new business precedents that put all pre-startup and fledgling businesses at risk of being shut down.

1.2.1 If a bitter ex-client complains to the Insolvency Service or Action Fraud stating (falsely) that they are a creditor or shareholder of a business and owed money, then these agencies can take these complaints as true without question or substantiated evidence without being challenged. 

1.2.2 If the Insolvency Service believes a complainant’s fabricated and false story that they are owed money, even when this can be provably refuted by the investigated company, then the Insolvency Service is able to keep insisting the complainant’s fabricated and false story is true.

1.2.3 If members of the Insolvency Service are unable to understand the work of a business, then that means there must be wrongdoing of some kind. 

1.2.4 It is treated as being illegal for a business to invest more than 18 years into pre-startup research and development just because the Insolvency Service doesn’t understand their work.

1.2.5 There should not be a recognisable legal entity for pre-startup status that promotes research and innovation prior to launching a fully-fledged business, because thorough research and discovery before scaling is treated by default as being against the public interest.

1.2.6 Accounting records, legal technicalities, court resources and compliance with unexplained demands from the Insolvency Service are more important than people’s lives, health and wellbeing.

1.2.7 The specific reporting and legal requirements laid out by Companies House are very stringent. If the Insolvency Service is genuinely concerned about companies not meeting these stringent regulations then they have a duty to investigate every single company that doesn’t meet these requirements, not just cherry-pick those that they are biased against in order to justify the cost of their investigation. 

1.2.8 Companies and organisations (like estate agents and property solicitors) which receive funds to be passed onto others would now need to declare all funds received as turnover to be taxed, rather than as money owed to their clients. 

1.2.9 Non-compliance because of a lack of resources and expertise with a falsely-triggered Insolvency Service Investigation means the business should be shut down on the basis of guilty until proven innocent.

1.3 The Secretary of State uses the term “Public Interest” as an excuse to force businesses to comply with any investigation regardless of whether it can be proven to be falsely triggered.

1.3.1 At both High Court hearings for the case of Lighthouse International Group, the original ground for the investigation (i.e. lack of commercial probity) was set aside and not discussed for the reason that the court lacked sufficient resources. 

  • Lack of commercial probity was the main justification for launching the investigation in the first place. 
  • This ground for the Public Interest Winding Up Petition was conveniently set aside when the Secretary of State’s legal counsel realised this could be proved false by Lighthouse International Group/Lighthouse Global and our substantial evidence. 

1.3.2 The Insolvency Service would rather continue a falsely-triggered investigation where there is no criminality to save face, than to have the humility to stop such an investigation.

1.3.3 The Insolvency Service uses all its powers, resources and expertise (such as the Public Interest Winding Up Petition under Section 124A of the Insolvency Act 1986) to close down any business for non-compliance regardless of whether the investigation can be proven to be falsely triggered.  

1.3.4 The Secretary of State for Business & Trade will abuse the term ‘Public Interest’ to justify its actions whilst not defining what actually is in the public interest or what the term public interest means.  

1.3.5 Insolvency Service Company Investigators will demand extensive information with short deadlines without explanation and expect complete compliance.

1.4 It is acceptable for the Secretary of State to break its own standards it imposes on others.

1.4.1 When the Insolvency Service Official Receiver Michael Bint first wrote to Paul Waugh he sent a webpage with “Examples of unreasonable customer actions or behaviour”. There were a number of these actions which himself and his department had themselves violated.  

1.4.2 Of the 61 statements, questions and requests made by Lighthouse Global to the Insolvency Services as part of the investigation, only 5 were answered, of which 3 were inadequately answered, leaving 2 (or 3%) answered sufficiently of the original 61 questions. 

1.4.3 Whilst Lighthouse International Group/Lighthouse Global was accused of a lack of transparency, it has been impossible so far to ascertain why the investigation into us was instigated and what it has cost the UK taxpayer so far, despite a Freedom of Information request.

1.4.4 The Insolvency Service has proudly published the High Court decision to wind up Lighthouse International Group (with our agreement in court), whilst the Insolvency Service has asked us to remove web pages that provably highlight the sheer lack of humanity and competence we have experienced from them since June 2022.

1.5 The Secretary of State for Business & Trade deems it acceptable to collude with, protect and sympathise with predatory trolls, convicted criminals and child abusers.

1.5.1 The Insolvency Service has ignored our provable claims that there are child abusers and coercively controlling family members in the group behind the smear campaign against Lighthouse International Group/Lighthouse Global who are also the sources behind their investigation. 

1.5.2 In the Secretary of State’s own evidence submitted to the High Court, they have ignored a communication stating that the group behind the smear campaign includes child abusers. 

1.5.3 In the Witness Statement from Insolvency Service’s Company Investigator (Gary Seymour) there is evidence of ongoing communication with his sources who are seeking to destroy Lighthouse International Group/Lighthouse Global. He has sympathised with their fabricated and false stories with him referring to sources as “victims”.   

1.5.4 The contact details and a request for information by Deputy Receiver Karen Baldock was published on Reddit which shows active collaboration between her and those actively seeking to destroy us at Lighthouse International Group/Lighthouse Global, including convicted criminals. This action of Mrs Baldock has been endorsed by Official Receiver Michael Bint.

2. The process for the Secretary of State for Business & Trade’s decision to investigate a business is open to being abused by those with malicious intentions

2.1 The Secretary of State for Business & Trade refuses to explain why it decided to investigate Lighthouse International Group.

2.1.1 At no point did Gary Seymour (as Insolvency Service Company Investigator) explain why he was investigating Lighthouse International Group/Lighthouse Global and yet expected total compliance. 

2.1.2 The requests from Gary Seymour were so broad and non-specific that the time and resources required by Lighthouse International Group/Lighthouse Global to comply was a form of punishment in itself. 

2.1.3 Complying with an Insolvency Service investigation without a clearly stated aim will inevitably find a breach of a technicality in virtually all businesses. Such technicalities will serve to justify the taxpayer resources invested into starting an investigation in the first place.  

2.1.4 The Insolvency Service and the Secretary of State for Business & Trade herself (Ms Kemi Badenoch) have deliberately refused to answer the question as to why there was an investigation into Lighthouse International Group/Lighthouse Global.

2.1.5 Despite clear evidence that the investigation into Lighthouse International Group/Lighthouse Global was falsely triggered, it appears there is no way for the decision to investigate to be reversed.

2.2 The Insolvency Service can be easily weaponised by predatory trolls through anonymous online reporting with no safeguards against this happening.

2.2.1 The Insolvency Service failed to investigate their sources and the motives of the sources in the investigation of Lighthouse International Group/Lighthouse Global.

2.2.2 The Insolvency Service’s Investigations and Enforcement Services complaint report form makes it extremely easy for a group of predatory trolls to report a business with falsehoods whilst hiding behind anonymity.

2.3 The Secretary of State for Business & Trade, Insolvency Service and Action Fraud refused to investigate the veracity of their sources and their motives.

2.3.1 The Insolvency Service’s investigation into Lighthouse International Group/Lighthouse Global was falsely triggered by a small number of bitter ex-clients who claimed to be creditors and shareholders in Lighthouse International Group. 

When challenged on why each government agency has failed to investigate their sources in official complaint letters (including what evidence they had for their complaint), each agency has continually avoided even acknowledging this question. Instead, they choose to cherry-pick what is convenient for them to answer (often done inadequately).

2.3.2 One of the Insolvency Service’s sources (Jeffrey Leigh-Jones) even admitted in his own words that his complaint was a “biased account” and that he had left out crucial “surrounding context”.

2.3.3 The Insolvency Service didn’t even seek to verify with the Associate at Lighthouse Global (Mel Francis) whether the reports made by her family members (Tania Francis and Dagmar Spaeth) were in any way factual. They just took what her family members said as true. Mel Francis submitted a rebutal to their false accusations presented in Gary Seymour’s witness statement. Mel Francis has also since had to take Tania Francis to court in an attempt to cease Tania Francis’s obsessive harassment of her to the detriment of her health, reputation and business prospects.

2.4 We suspect that this investigation was part of an inside job.

2.4.1 MPs have shared that in all their years of experience, they haven’t heard of a case where a Micro-LLP such as Lighthouse International Group has been investigated using such a complex and specialised piece of legislation. Therefore it stands to reason that there is some form of bias and prejudice that is involved in order to use the state’s resources on such a small company.  

2.4.2 The one MP in particular saw no reason for the Secretary of State to initiate an investigation into a company the size of Lighthouse International Group and has written to Kemi Badenoch as the Secretary of State for Business & Trade regarding this matter. We are waiting a response. 

2.4.3 Lighthouse Global is aware that some of the predatory trolls have connections with people working in government agencies and departments.

3. The Secretary of State seeks to bully and intimidate businesses to comply with its investigations without question

3.1 The first letter sent to inform us of the investigation was so poorly formatted and presented it didn’t look genuine.

3.1.1 The initial letter from the Insolvency Service’s Company Investigator Gary Seymour was so badly photocopied, formatted and presented that Paul Waugh genuinely thought the letter was a hoax from the predatory trolls as part of their harassment campaign against him.

3.2 The Insolvency Service’s Company Investigator made excessive demands to be fulfilled in a short period of time with no explanation.

3.2.1 The lead investigator from the Insolvency Service, Gary Seymour, gave an exhaustive and extensive list of information that he required. He demanded he received this within a short deadline of 8 days from date of writing. Some of this information included information going back over a  decade.

3.2.2 This is a summarised list of what was expected in a week (16 points condensed into 12, but likely to be thousands of pages of information sourced from hundreds of thousands of pages of information):

  1. Full Financial Statements and management accounts from February 2012 to June 2022.
  2. Proof of all funding and expenditure through receipts and invoices from January 2019 to June 2023.
  3. Extensive details of all bank accounts, all bank statements from January 2019 to June 2023, all bank correspondence from August 2014 to June 2022.
  4. LLP organisation chart to include names, contact details, roles and responsibilities of all key staff members. 
  5. Detailed records of all remuneration and benefits paid to all LLP members from January 2019 to June 2022. 
  6. Registration documents for employer’s PAYE and NIC scheme as well as all returns from April 2019 to April 2022. 
  7. All correspondence with HMRC.
  8. All complaints to Lighthouse International Group from February 2012 to June 2022 which includes all associated correspondence. 
  9. Details of all legal disputes. 
  10. All promotional materials from February 2012 to June 2023 that includes website material, emails, social media promotion, brochures etc.
  11. Copies of all LLP partnership agreements.
  12. Detailed book-keeping and accounting records from January 2019 to June 2022.   

3.2.3 Gary Seymour disregarded Paul Waugh’s communications that he and everyone at Lighthouse was at breaking point emotionally and in terms of time and resources because of the intensity of the smear campaign against him and Lighthouse International Group/Lighthouse Global. This reality was ignored by Gary Seymour despite all the evidence on our various websites detailing the abuse we had been receiving. 

3.2.4 The demands of Insolvency Service company investigations are a punishment without reason and justification, especially for any business already struggling to keep heads above water because of attacks online and in the media. 

3.2.5 In the case of Lighthouse International Group/Lighthouse Global, the punishment was compounded by the fact that the Insolvency Service was deliberately ignorant of extensive publicly available information online about Lighthouse International Group/Lighthouse Global including the associated smear campaign.

3.2.6 The Secretary of State for Business & Trade was able to access all of Lighthouse International Group’s bank accounts and could not accept that the account was used as an intermediary account to pay Lighthouse Associates for self-employed income and to cover basic operating expenses.

3.3 When excessive demands were not met, the Secretary of State Investigator would make continual threats of fines and imprisonment whilst ignoring reasons for non-compliance.

3.3.1 Insolvency Service Company Investigator Gary Seymour continued to threaten Paul Waugh, Lighthouse International Group Directors and Adam Wallis (Lighthouse Associate) with the consequences of non-compliance of his demands based on the assumption of guilty until proven innocent.

3.3.2 All representatives from the Insolvency Service continually state their authority to order people to comply together with threats of fines, court and even imprisonment. 

3.3.3 There were multiple explanations of the predatory trolling that we had been subjected to, a lot of which was publicly available information through online blogs, articles and YouTube videos. This included testimonies from Lighthouse Global Associates expressing the severity of what they were experiencing.

3.4 The Secretary of State Investigator sought to intimidate Lighthouse Associates through their conduct of harassment. Through this they repeatedly disregarded the mental health and wellbeing of Associates at Lighthouse Global including an Associate in a suicidal state through an unsolicited visit to his house of residence.

3.4.1 The Insolvency Service has shown a complete lack of care, no compassion and no recognition of the stress and damage caused by their actions. They have behaved as a cold-hearted bureaucracy with a closed-minded, inhuman, uncaring mentality in the face of reason from us at Lighthouse International Group/Lighthouse Global.

3.4.2 When the Insolvency Service asks questions, it does not accept responses that don’t fit in with their biased and prejudiced view. In the case of Lighthouse International Group/Lighthouse Global they have maintained a view conceived initially through believing lies of predatory trolls. 

3.4.3 The degree to which they have harassed Lighthouse International Group/Lighthouse Global can be seen in their conduct with Adam Wallis who was not a Director of Lighthouse International Group. In the space of a month, Adam received 21 letters at his home address in relation to the Insolvency Service investigation. He personally received 2 letters, 5 emails and 2 voicemail messages in this time. He also received a visit to his private residence just two days after he had attempted suicide. Gary Seymour persisted after this house visit with another email that included a threat of fines and imprisonment. Despite Adam’s subsequent complaint, Insolvency Service employees continued to visit this same address.

3.4.4 The Insolvency Service has also continued to email Paul Waugh threatening him with court hearings while he was officially signed off sick and they were very aware of the fact.

3.5 Mentions of child abuse in the evidence received by the Secretary of State’s own sources were ignored.

3.5.1 In Gary Seymour’s evidence submitted to the Court there is an email exchange between a Lighthouse Global Associate (Jai Singh) and one of their sources (Anthony Church). In an email there is an explanation that some of the predatory trolls behind the Insolvency Service investigation are hiding child abuse in their family and want to destroy Lighthouse International Group/Lighthouse Global so that their secrets aren’t revealed. Therefore Gary Seymour was well aware of this reality but chose to ignore it and not question his sources either. 

3.5.2 Furthermore, Lighthouse International Group/Lighthouse Global developed a public website which explained the provable lies behind a libellous article that the Daily Mail had written on Lighthouse International Group/Lighthouse Global. This website explained who was behind the predatory trolling and was once again ignored by the Insolvency Service. 

3.6 The Secretary of State Investigator accepted evidence that was biased and without context whilst sympathising with the perpetrators of the campaign.

3.6.1 The Insolvency Service has been completely biased in favour of the provable lies of their sources. For example, Jeffrey Leigh-Jones admitted in writing that his evidence was biased and lacking context. This was accepted and presented as evidence to the High Court of Justice without question or any form of scrutiny. 

3.6.2 Insolvency Service Investigator Gary Seymour requested his sources provided details of ALL communications with Lighthouse International Group/Lighthouse Global. However, in the case of the ex-clients what was received and presented as evidence to the High Court was a tiny percentage of all communications that would contradict the false accusations made.   

3.6.3 The evidence of how much Gary Seymour was taken in by the fabricated stories of his sources was the way in which he references his sources as “victims” in his witness statement to the High Court of Justice filed with the Public Interest Winding Up Petition. 

3.7 The Secretary of State Investigator ignored all publicly-available information about the smear campaign against Lighthouse Global.

3.7.1 There were 40+ articles available through a variety of platforms and social media backed up by evidence. All these articles were completely ignored. 

3.7.2 The Insolvency Service wanted Lighthouse International Group/Lighthouse Global to be guilty because of non-compliance with their demands and even the acknowledgement of evidence of a smear campaign would be inconvenient as it reveals their lack of due diligence in their decision to instigate.

3.8 The Secretary of State Investigator chose to ignore all positive testimonies of the work by Lighthouse Global.

3.8.1 In contrast to a handful of negative complaints by the Insolvency Service’s sources, there were 21 deeply personal testimonies from Lighthouse Associates and 59 Lighthouse client testimonials submitted to the High Court as 306 pages of evidence on 20th February 2023. Many of these testimonies were also publicly available online on Lighthouse Global’s community site at the time of the Insolvency Service investigation and completely ignored. 

3.8.2 In the High Court hearings the Insolvency Service barrister, Matthew Parfitt, referred to Lighthouse testimonies as statements from “happy clients” which showed no recognition for the depths of vulnerability and appreciation expressed for the difference Lighthouse International Group/Lighthouse Global has made in their lives.  

3.8.3 To ignore such extensive evidence in terms of both quantity and quality of evidence shows the Insolvency Service were not investigating Lighthouse International Group/Group in the true public interest. They were looking for as much information as possible that would corroborate their biases that were instigated by their sources’ lies and malicious falsehoods.

3.8.4 In its decision to wind up Lighthouse International Group, the Secretary of Trade for Business & Trade is stating the following is in the public interest:

  • The complaints of 5 ex-clients are considered more important than 80 deeply personal testimonies.
  • 6 family members of clients (current & former) with an agenda to destroy a business to cover over family abuse are credible sources for an investigation and do not need to be examined.
  • The unchallenged opinion of a complainant with bias and lack of context carries greater weight than a signed testimony.
  • If an Insolvency Service Company Investigator asks a source to provide evidence of all communications with a company, it is acceptable to leave out any evidence that contradicts their claims. 
  • The Daily Mail is a trustworthy and authoritative source of information for making legal decisions. 
  • There is no possible way to prove a smear campaign, even with repeated public statements and hundreds of pages of substantiated evidence.

4. The Secretary of State will use a Public Interest Winding Up Petition & High Court process to shut down businesses on technicalities, not evidence

4.1 The Secretary of State did not make sure that the directors of Lighthouse International Group were aware of the Public Interest Winding Up Petition and associated court hearing.

4.1.1 When it was not in the Secretary of State for Business & Trade’s interests to ensure that the Directors of Lighthouse International Group/Lighthouse Global knew about the High Court hearing, the Insolvency Service did not make more effort than they were legally required to do. The Directors only found out about the High Court hearing by chance online through The Gazette.  

4.1.2 This is in contrast to when the Insolvency Service believed an issue was in their interests to follow up on. Gary Seymour was relentless in his communications with Paul Waugh, Lighthouse Directors and Adam Wallis. Gary Seymour would make numerous attempts to contact the Directors incessantly using various avenues. This included turning up unannounced on the doorstep of a Lighthouse Associate who had recently attempted suicide.

4.2 Directors of Lighthouse International Group were offered no support or resources to prepare for and represent themselves in the High Court.

4.2.1 Lighthouse International Group/Lighthouse Global did not and could not comply with the Secretary of State because the investigation was unjust, we lacked the resources and we lacked the expertise to respond. The Insolvency Service knew that non-compliance is a legal technicality that provides sufficient grounds to wind up anyone challenging its demands and reasons for investigation.

4.2.2 As a result the Insolvency Service knew that no plea to the Judge or evidence submitted would lead to the case being thrown out of court. 

4.2.3 On a number of occasions, the legal counsel representing the Insolvency Service explicitly stated that they were barred from giving legal advice to Lighthouse International Group/Lighthouse Global. This would often mean just giving the bare facts of the process they were using and the relevant dates and times for the Lighthouse International Group/Lighthouse Global to adhere to.

4.2.4 What compounds the injustice of having to defend a falsely-triggered investigation is that even a petty-theft criminal would have been offered legal aid. We had nothing, not even a booklet explaining the process we would have to go through.

4.2.5 As a result we had to defend ourselves by representing ourselves at Court in the face of complex legal procedures and vehicles. This removed Lighthouse Associates further away from their cost-covering work supporting vulnerable people. As well as the court days themselves, hundreds of hours were spent preparing our evidence without the expertise required. 

4.2.6 In contrast the Insolvency Service has a host of resources at their disposal and they don’t hesitate to use them once they have decided on a course of action.

4.3 The plea that there was an abuse of process was disregarded by two High Court Judges without considering evidence.

4.3.1 The reasons for an abuse of process was made very clear in evidence and both High Court hearings.

4.3.2 The judge at the first High Court hearing ignored our plea that there had been an abuse of process and set aside hundreds of pages of evidence proving the investigation was falsely triggered.

4.3.3 At the second High Court hearing, evidence proving the Insolvency Service’s investigation was part of a constructive sabotage smear campaign could not be presented, even though without the smear campaign there would’ve been no investigation triggered in the first place.

4.4 The Secretary of State and its legal counsel knew from the outset that the Public Interest Winding Up Petition would be enforced on the ground of non-compliance and an accounting technicality no matter how much the corrupt nature of the investigation was exposed.

4.4.1 The Insolvency Service has worked on the assumption of guilty till proven innocent and over the course of over 18 months has been hellbent on finding any technicality to prosecute with in order to justify the huge expense of their corrupt investigation.  

4.4.2 The Insolvency Service knew that legally the Courts would never condone non-compliance with their investigation, no matter how falsely and maliciously it was triggered. Therefore Lighthouse International Group/Lighthouse Global was already guilty before stepping into the court, regardless of what evidence was presented.

4.4.3 Every single business in the UK would likely be guilty of transgressing an accounting technicality of some kind if scrutinised in depth. Therefore the Insolvency Service sets the precedent that all businesses in the UK should be investigated on the suspicion that accounts may not be accurate and those unwilling to comply will be wound up. 

4.4.4 Surviving an investigation from the Insolvency Service is purely a matter of having the human and financial resources as well as the legal expertise available to defend itself. Any business lacking the resources and expertise to defend itself against a falsely-triggered investigation is doomed to be wound up once the decision to investigate is made. 

4.4.5 Lighthouse supplied a balance sheet every year to Companies House. Any mistakes were made in good faith, not because of financial irregularities. Accounting inaccuracies are common. For instance, the Financial Reporting Council (FRC) stated that when analysing records between 2012/13 to 2017/18, that in 2017/18, 27% of FTSE 350 audits were assessed and did not meet the standard that they required. The FRC expects inaccurate accounting which is why their target is that 90% of audits are “good or requiring limited improvement.” 

4.4.6 Just because the Secretary of State doesn’t listen to and accept Lighthouse International Group/Lighthouse Global’s situation, doesn’t make us guilty of acting against the public interest. Lighthouse International Group complied with Companies House reporting requirements for its legal status as a micro LLP, whilst all Lighthouse Associates remain in communication with HMRC regarding their personal tax. 

4.4.7 Lighthouse International Group has never had a turnover anywhere close to the audit threshold and is a micro LLP, yet through the Insolvency Service investigation and subsequent court hearings it was being treated more stringently than a corporate. 

5. The Insolvency Service wastes taxpayer money in its attempts to liquidate a business without assets and creditors

5.1 The Insolvency Service is trying to liquidate a company when there are no assets to liquidate.

5.1.1 The Insolvency Service continues to believe, despite all the explanations and reasoning that we have given them, that Lighthouse International Group has assets to be liquidated. 

5.1.2 The Insolvency Service’s Company Investigator Gary Seymour asked in his witness statement to the High Court whether Lighthouse International Group had any further bank accounts because the transaction levels were so low in our only account (less than 25 transfers per week on average with the majority being low financial amounts).

5.1.3 In line with the above, a key part of our evidence (that was rejected by the Insolvency Service and the High Court) was demonstrating that Lighthouse International Group/Lighthouse Global was a research organisation barely covering costs and hence was a pre-startup. This evidence was rejected despite demonstrating that most Lighthouse Associates earned below the tax threshold on an annual basis.  

5.1.4 There was no recognition by the Insolvency Service of the lack of legal options to register as a pre-startup and therefore the decision for Lighthouse International Group to register as a micro LLP was the closest viable option.

5.2 The Insolvency Service insists there are creditors and shareholders when there are none.

5.2.1 The Insolvency Service has, despite explanations to the contrary, believed the lies of its sources stating they are creditors and shareholders despite actually being bitter ex-clients looking for an undue refund.

5.2.2 The Insolvency Service Official Receiver, Michael Bint, refers to the investigation sources as ‘contingent creditors’ despite them failing to provide evidence they are creditors or shareholders.

5.2.3 The Insolvency Service have demonstrated a lack of character and competency in relation to their work. They really struggle to understand basic concepts such as customers are different from creditors and shareholders. To make this point we have had to give them basic examples such as, if you are the customer of a hotel, it does not make you a creditor or shareholder of that hotel.

5.3 The Insolvency Service through their conduct of harassment has repeatedly disregarded the mental health and wellbeing of Associates at Lighthouse Global.

5.3.1 To the present day, the Insolvency Service continue to show a complete lack of care, compassion and recognition of the stress and damage caused by their actions. 

5.3.2 When the Insolvency Service asks questions, they do not accept responses from Lighthouse International Group/Lighthouse Global which do not fit with their biased and prejudiced view based on their sources with a vitriolic agenda.

5.3.3 The degree to which they have harassed Lighthouse International Group/Lighthouse Global can be seen in their revisiting of Adam Wallis’s address as explained above.

5.3.4 The Insolvency Service has continued to threaten Paul Waugh with court hearings to demand compliance despite being signed off sick. 

6. The Secretary of State for Business &Trade seeks to cover up the incompetence of multiple governmental departments through acting as judge, jury and executioner

6.1 The Secretary of State for Business and Trade, Kemi Badenoch, refused to respond to our letter of complaint and hence left the Insolvency Service to be judge, jury and executioner.

6.1.1 Kemi Badenoch’s department has ignored Lighthouse Global’s letter of complaint and our questions in relation to the whole corrupt investigation into Lighthouse International Group that has resulted in millions of taxpayer funds being wasted. Kemi Badenoch’s department insists that it has to be dealt with by the Insolvency Service. This shows just how little accountability the Insolvency Service is subject to.

6.2 There has been a huge inter-governmental departmental cover up to hide their mistakes

6.2.1 Action Fraud passed complaints about Lighthouse International Group onto the Secretary of State without confirming the truth of the complaints made.

6.2.2 When Lighthouse Global submitted a Data Subject Access Request to Action Fraud, the department tried to delete information rather than provide the information requested.

6.2.3 The Secretary of State decided to investigate Lighthouse International Group without challenging Action Fraud on whether the complainants were creditors of Lighthouse International Group as they stated.

6.2.4 The Insolvency Service Investigator, Gary Seymour, failed to acknowledge the noticeable evidence of there being a smear campaign against Lighthouse Global, whilst sympathising with the perpetrators of the campaign.

6.2.5 The High Court of Justice ignored our plea that there had been an abuse of process and set aside hundreds of pages of evidence proving the investigation was falsely triggered. 

6.2.6 The High Court did not accept our lack of resources as a reason for not complying with a falsely triggered investigation whilst preventing us from presenting key evidence in a court hearing because of a lack of court resources.  

6.2.7 The Secretary of State, the Insolvency Service and the High Court have persistently refused to even acknowledge the provable claims that they have been weaponised against Lighthouse Global based on malicious falsehoods.

6.2.8 The Deputy Receiver for the Insolvency Service, Karen Baldock, has colluded with those behind the anti-Lighthouse smear campaign to the point she believes the lie that they are creditors.

6.2.9 The Official Receiver for the Insolvency Service, Michael Bint, has explicitly stated that he will not address any of our points or evidence regarding the predatory trolling of Lighthouse Global.

6.3 Lighthouse Global has asked the Insolvency Service 61 questions in relation to the investigation of Lighthouse International Group. The Insolvency Service has only addressed 5 and provided any form of adequate reply to 2.

7. One rule and significant consequence for the public, another rule with no consequence for the Government

7.1 Mrs Kemi Badenoch was reported to Action Fraud for hacking, something she admitted to and was not prosecuted.

7.1.1 Kemi Badenoch, the Secretary of State for Business & Trade, was reported to Action Fraud for hacking into a Labour MP, Harriet Harman’s website. The irony is that the Secretary of State has done something illegal and unlawful and suffered no consequence. 

7.1.2 Yet Lighthouse International Group/Lighthouse Global, who have not done anything criminal, are treated like criminals and evidence is ignored. Under the Computer Misuse Act of 1990, hacking is considered a criminal offence in the UK. Yet Mrs Badenoch was not prosecuted and evidentially shows that it is one rule for them with no consequences and another for the public with punitive consequences.

7.2 The Insolvency Service will brazenly publish inaccurate information about Lighthouse International Group on its website, but threaten legal action for us publishing facts and evidence about their incompetence on our David vs Goliath online platform.

7.2.1 On 6th April 2023, the Insolvency Service published a press release online “Mentoring and coaching company shut down for financial irregularities – Lighthouse International Group wound up by the High Court in the public interest.” This press release was full of inaccuracies, almost written as if it was not present at the High Court hearing on 28th March 2023: 

  1. Lighthouse International Group was not shut down for financial irregularities. Any alleged financial irregularities are pure speculation! 
  2. The Insolvency Service does not acknowledge that Paul Waugh asked Judge Jones to wind up Lighthouse International Group when he saw that there would be no opportunity to challenge the fact (with extensive evidence) that the Insolvency Service investigation was falsely triggered by predatory trolls.  
  3. The Insolvency Service makes it seem that Lighthouse International Group used life coaching services as a front for a fraudulent enterprise. The reality is that Lighthouse Associates worked tirelessly to serve clients for very little remuneration in comparison to the hours worked (including those providing false testimony to the Secretary of State for the Public Interest Winding Up Petition).
  4. The Insolvency Service reported that £2.4m was received as if it was an extortionate amount of money. However, the Insolvency Service failed to acknowledge the time period for which these funds were received (bank accounts dating back to 2014) and the number of Lighthouse Associates involved in serving clients to receive these funds (up to 20-30 individuals). 
  5. The Insolvency Service also tried to portray Lighthouse as a highly active business by totalling all its transactions over a 10 year period which was 11,500 transactions. However they double-counted these transactions because of how the payments are processed and hence failed to note this was an average of 13 transactions a week which is one per Associate of relatively nominal amounts (0-£200) which explains why virtually every Associate barely covers their costs. The fact they double-counted the number of transactions either illustrates the incompetence of the Insolvency Services over something so basic. The alternate option, if not incompetence, shows a sinister agenda to create a false perception of Lighthouse and justify their agenda. 
  6. The Insolvency Service states that it was somehow underhanded that Paul Waugh received more than half of these funds when; Paul Waugh has, on average, worked at least 18 hours per day for Lighthouse International Group since its original inception in 2004. Additionally Paul Waugh reinvested much of what he received into supporting Lighthouse Associates over this time as was proven in evidence submitted to the High Court. We calculated in evidence submitted to the High Court in 2023 that Mr Waugh’s hourly earnings since 2014 was £23. 
  7. The Insolvency Service stated that it was unable to ascertain what Lighthouse International Group/Lighthouse Global does when there is extensive educational material about the work we do and the impact that our work has made on the lives of clients and Lighthouse Associates. More than 75 incredibly personal and heartfelt testimonies were submitted to the High Court in February 2023, but were dismissed by the Secretary of State’s legal counsel. 
  8. The Insolvency Service presented that Lighthouse International Group’s reporting of nil assets to Companies House was fraudulent. This was actually done in good faith because there were no fixed assets or debtors in the company and the amount of cash in the account was at petty cash levels in essence.
  9. The Insolvency Service failed to recognise that Lighthouse International Group was a pre-startup research fraternity registered as an LLP because there is no legal entity meeting the Directors’ requirements.
  10. The Insolvency Service merely stated that Lighthouse International Group and its Directors did not comply with the Insolvency Service investigation rather than explaining the reasons for not complying to the level demanded. 
    1. There was no mention of the constructive sabotage smear campaign behind the instigation of the investigation. 
    2. Similarly there was no recognition that this smear campaign had decimated the resources of all at Lighthouse International Group which rendered us unable to respond. 
    3. With the lack of resources, Lighthouse Directors did not have the resources to access the legal expertise to respond to specialised aspect of British law full of room for misinterpretation and technicalities.  
  11. The Insolvency Service refused to publish the level of stress caused by the orchestrated constructive sabotage smear campaign that led to two Lighthouse Associates trying to commit suicide. In so doing the Insolvency Service basically states that full compliance with its investigation is more important than human life.   
  12. A statement is made commending the professionalism of the Insolvency Service investigations team when Lighthouse Directors presented 14 provable reasons why the Insolvency Service Investigator (Gary Seymour) was not objective in his investigation.
  13. The Insolvency Service states that Lighthouse International Group was wound up in the public interest, but fails to state why shutting down Lighthouse International Group is in the interest of the everyday man or woman on the street, especially those finding the Insolvency Service weaponised against them.

7.2.2 On 17th October 2023, Lighthouse Global published a page “Extra Lessons For Karen Baldock, Dean Beale, Michael Bint & Gary Seymour – UK Insolvency Service” on davidvsgoliath.global. This page presented the following information:

  1. The reasons for publishing the exchange of communications with the Insolvency Service following the High Court hearing on 28th March 2023. 
  2. The names of those behind the constructive sabotage smear campaign of Lighthouse International Group for the last 3 years (including the Insolvency Service’s sources).
  3. The reasons why the Insolvency Service investigation into Lighthouse International Group was falsely triggered. 
  4. Email from Paul Waugh to Karen Baldock, Insolvency Service Senior Examiner & Deputy Official Receiver that calls out the fact that the Insolvency investigation was falsely triggered.   
  5. Email from Michael Bint, Official Receiver at the Insolvency Service to Paul that asks him to take the blog post with his email to Karen Baldock.
  6. 4 emails in response from Paul Waugh that call out the corrupt nature of the Insolvency Service investigation into Lighthouse International Group and that this will be exposed globally through David vs Goliath and other forms of media.

7.2.3 On 21st November 2023, Lighthouse Global published a page “A Gross Failure In Their Duty Of Care By Michael Bint And The UK Insolvency Service” on davidvsgoliath.global. This page published an email from Lighthouse Global Director Chris Nash presenting the evidence backing up the reality of how inhumanely the Insolvency Service has treated Lighthouse International Group/Lighthouse Global Associates, most notably the treatment of Adam Wallis who had attempted suicide during the time of the Insolvency Service investigation.