Complaint Letter To the Secretary of State For Business & Trade: KEMI BADENOCH

Introduction & Context

This is a letter that Lighthouse Director Chris Nash sent to Mrs Badenoch, Secretary of State for the Department of Business and Trade in October 2023. This was in the hope, more than expectation, that she would feel a sense of honour and privilege in her role as the Secretary of State, being responsible for the Insolvency Service enough to take action accordingly to order an internal investigation and to right their wrongs.

This hope was short lived and her office has merely responded with an officious letter stating that the official Insolvency Service complaints procedure would suffice. Ms Badenoch has conveniently neglected the fact that the reason we at Lighthouse were writing to her in the first place was because their official complaints procedure was wholly inadequate! The seven sets of questions that we raised at the end of this complaint, at the bottom of this letter, all remain unanswered. 

X Post by Paul Waugh, Lighthouse Founder & CEO, 31 March 2023

“If a ruler listens to falsehood, all his officials will be wicked”.

Proverbs 29:12


Dear Mrs Badenoch, 

As the Secretary of State responsible for the Department of Business and Trade, I’m writing to you personally to formally lodge a complaint as well as provide recommendations to change and reform a gaping hole in your department. This gap provides vindictive individuals and unscrupulous organisations with the opportunity to malignantly abuse your, and thereby the taxpayers, resources. By implementing these reforms and changes you will be able to put your wrongs right, in line with your duty of Ministerial Accountability.  

This is a critical and urgent matter that not only needs to be addressed in our case, but to ensure many other small businesses and the human beings that make up those businesses, including their families, do not suffer the pain and damages caused by due negligence and incompetence on the Government’s behalf. More specifically, I am referring to your department’s failings and therefore you as Secretary of State.  With that in mind, I trust you will take great care in considering this complaint and I look forward to you and your department’s response. 

1. Overview: The Weaponisation of Your Department’s Resources By Predatory Trolls To Destroy Our Organisation and All Associated With It

Fundamentally, because of a lack of due diligence and responsible discernment , your department’s resources have been abused and weaponised to cause significant damages to our company, our work, our lives, our children, and our futures. Not only has this abuse of the State’s resources been for unlawful and private interests, but it undermines democracy and the Rule of Law.

Specifically, there has been a gamut of failings by the Secretary of State and the Insolvency Administration Service Department; 

  • This government agency under your control, was allowed to be weaponised by a group of predatory trolls and constructive saboteurs, who also weaponised media institutions like the BBC, in a bid to destroy me and my organisation. 
  • Indeed not only was it weaponised but your employees took the side of these predatory trolls, who were galvanised by how easy it was to deceive your employees. Imagine the glee of the predatory trolls when they realised that civil servants who are meant to be neutral and objective in their investigations, started to call them “victims” in official documents that were sent to Court! This was despite one of those predatory trolls admitting that his statement was biased and lacked the surrounding context.
  • The lack of assessment and verification as to the legitimacy of the claims by these predatory trolls is extraordinary and perturbing, given the levels of distress they were able to cause through using your department’s resources as a conduit for their malicious ends, at no cost to themselves. 
  • In contrast, we were threadbare and penurious in every form of resource that we needed, even to survive. We weren’t given any support or guidance by your department and as a result we could not comply with any request. We had no time, no money, no health and no energy. Indeed throughout we have been treated as though we are a corporate with the expectations of being able to respond like a corporate with corporate resources

2. Official Letter of Complaint To The Insolvency Service

I have also included, as an attachment to this letter to you, a letter of complaint that I have sent to the Official Insolvency Service Complaint channel. This outlines in detail, the mendaciousness of these predatory trolls that caused us such chaos, which indeed became life and death for some of those involved. 

Some of the most salient points from this Official letter are outlined below to give you an overview of why they are so serious and need your utmost attention, so that you can remedy them.

  • How your Insolvency Service department is Open To Abuse Because Of A Lack of Objectivity And Due Diligence (see point 3 below)
  • How these checks and balances enabled predatory trolls to use your department to gain credibility with media Institutions such as the BBC (see point 4 below)
  • How I and many of my fellow Directors and business associates have been treated with the utmost contempt and a lack of Duty of Care, especially by two employees; Gary Seymour and Karen Baldock who have been biased against us (see point 5 below)

How your Insolvency Service department abused the court process so that we were denied a fair trial to give full and fair disclosure of the facts (see point 6 below)

3. The Insolvency Service Is Open To Abuse Because Of Failings To Adequately Check The Legitimacy of The Complainants

Your Insolvency Service Department, in particular, allowed itself to be weaponised because of the complete lack of sufficient checks and balances on those with a vexatious and vindictive intent to abuse its services. The evil nature of this abuse is compounded by the very fact that your department established these services in the first place to safeguard the interests of the public. Instead they have been and are being used to destroy members of the public, such as myself and others, who are doing great work for society. The irony! This lack of prevention of such abuse in your department therefore allowed a very grave injustice to occur. I must demand from you that you take action to remedy this grave injustice and prevent it from ever happening again and make your wrongs right.

Some of the most salient points from this Official letter are outlined below to give you an overview of why they are so serious and need your utmost attention, so that you can remedy them.

  • How your Insolvency Service department is Open To Abuse Because Of A Lack of Objectivity And Due Diligence (see point 3 below)
  • How these checks and balances enabled predatory trolls to use your department to gain credibility with media Institutions such as the BBC (see point 4 below)
  • How I and many of my fellow Directors and business associates have been treated with the utmost contempt and a lack of Duty of Care, especially by two employees; Gary Seymour and Karen Baldock who have been biased against us (see point 5 below)

How your Insolvency Service department abused the court process so that we were denied a fair trial to give full and fair disclosure of the facts (see point 6 below)

4. The Predatory Trolls Used Your Department To Gain Credibility With Media Institutions Such As The Bbc To Further Destroy Us - Leading To Death Threats Against Us!

Anyone whose heart is invested in the pursuit of fairness, justice, truth and democracy will find this case extremely challenging and disturbing. You will see that this weaponisation of your department’s resources by the predatory trolls and constructive saboteurs led to their lies and the lies of the BBC wrongly gaining credibility, which led to me and those in my organisation receiving thousands of abhorrent and threatening messages, including death threats! Indeed a BBC team were at our court case and waiting for the outcome of the court hearing before they broadcast the aforementioned programme. It would appear that the predatory trolls, your department and the BBC have been in cahoots together to meet their own ends for their own private gains.    

This was a coordinated and concerted attack by the predatory trolls who were targeting Government agencies. It was your department that took their bait and further fuelled the abuse of their position by the BBC to profit for their own ends, at the expense of us and the common man. What is stopping  the system being abused again like this at the expense of the small man suffering under this tyrannical abuse of position and process?

This represents an extreme abuse of power. While I completely understand that you have no personal jurisdiction over the actions of the BBC, I want you to understand that actions by your department gave the predatory trolls and BBC further ammunition to attack innocent people. That such an official body funded by licence fee money, as instructed by Government and directed by a Royal Charter, could abuse its position in such a manner, is a major threat to the democracy that underpins the Rule of Law in this country. The Rule of Law is a sacred legal principle that enables democracy to be fulfilled at least at a basic level in order for society to function.   

The death threats and the hundreds of abhorrent and abusive messages have been reported to the police and are being investigated, which is once again costing the taxpayer. The predatory troll smear campaign, emboldened by their ability to weaponise the support of your department and its resources, has led to two of my close business partners attempting suicide. A matter I have no doubt you take extremely seriously. This threat and risk to life has caused everyone involved at Lighthouse a great deal of anxiety and extreme levels of fear. Everyone has a human right to go about their work and life in peace without the threat of harassment, let alone death threats. That two business partners have attempted suicide should show you the extreme level of persecution we have faced.

5. Treated With Contempt by Your Department’s Employees who did not show us the Duty of Care needed with their lack of competence and bias

One of them, Adam Wallis, as you will read for yourself in the attached letter, was in direct communication with one of your department’s investigators, Mr Gary Seymour. Mr Wallis’s testimony to court is highly revealing of the contemptuous way he was treated by employees of your department, who have taken the side of the predatory trolls because of the malicious falsehoods and deliberate lies they have been able to manipulate and feed your employees with. It would be very fair to say that how he was treated is indicative of how all of my fellow Directors and business Associates have been treated by those within your department. Namely that we were guilty until proven innocent and this will be substantiated through evidence. 

This can also be seen through how another one of your department’s employees, insolvency examiner Karen Baldock, colluded with the predatory trolls on the Reddit forum. Our experiences with both of your employees are in the detailed complaint letter attached.

6. Abuse of Court Process

Yet proving ourselves innocent was impossible given the cunning legal manoeuvrings of the solicitors and barristers that your department is able to employ, along with the substantial energy and time resources that you have at your department’s disposal. This is why the predatory trolls used you, literally, to do their work at no risk or cost to themselves. In contrast, micro entities such as my own do not have any of these resources. As you can read for yourself, our organisation didn’t have any of the financial resources needed. Indeed we barely had the health to survive physically and emotionally, let alone mentally! 

7. Ministerial Accountability & The Need To Put Your Wrongs Right

In line with taking Ministerial responsibility for changing procedures that are open so easily to such abuse, I am appealing to you to do what is right and just and to ensure that what has happened to us is thoroughly investigated by yourself. No member of the public should have to endure what we have gone through. While I fully understand that there is a need for Public Interest petitions and such investigatory apparatus within your department, these need and must be used with the utmost of care. Instead we have a group of cruel, malicious and vindictive predatory trolls, some of whom are protecting rapists within their own families, taking advantage of specialist legislation with impunity and costing the taxpayers hundreds of thousands of pounds, if not millions! 

I would sincerely hope that as a Government minister acting at one of the highest levels of public service, that you would intuitively know the wrongs that need to be put right. Nevertheless I think it would be prudent to remind you of the enormous  reputational damage that we have suffered. For 16 years we have been working incredibly hard with enormous sacrifices for the good of humanity. We have done such work through understanding what are the barriers, obstacles and restraining forces that prevent people from achieving their potential and had not had a single legal complaint. Yet through the Insolvency Service we suddenly find ourselves in Court and on national TV. At the very least we are owed a public apology and compensation as discussed immediately below.

8. Compensation

In particular, the matter of compensation for ourselves needs to be addressed. Your department currently has a compensation fee set at £250. While it acknowledges this is a token gesture, there is nothing token about the damages and emotional carnage that myself and my fellow Directors and business associates have agonisingly endured. Whilst I appreciate that you too are on the receiving end of trolling, as well as lies and falsehoods in the media, have you ever had to experience a premeditated two year campaign of vitriolic and cruel harassment against yourself, backed by the resources of the state!? Where those attacking you would be happy to hear that you had committed suicide? This is the level of malice that I and my business partners have had to deal with daily and that has been compounded by your department! We must be adequately compensated for the nightmare that we have had to live through.

9. Distrust of Your Official Complaints Procedure

In line with you upholding the standard of Parliamentary ethics through Ministerial Accountability, quite frankly, given my current dealings with employees in your department, I have no trust and faith in your official complaints procedure which is one of the reasons I am writing to you. Furthemore, I feel it is imperative that, as a Government Head and Cabinet Minister, that you are informed of how your department is governed and operates. Were such procedures open to abuse in my organisation, I would want to know about them so that I can take responsibility to change them!

10. Abuse of The Public Interest

I sincerely hope that you look at and remedy the abuse of the Public Interest that your department has been complicit in. This unwritten constitutional principle has been severely exploited, abused and misapplied against us. When this is allowed to happen we have tyranny! As the ICAEW have said “Invoking the public interest requires justification of an ability and right to decide what is for the greater good, in the face of a natural suspicion that those proposing an action in the public interest are actually acting in their own interests”. I felt compelled to include this quote because it so succinctly epitomises the situation I am in. I am the victim of tyranny from your department dressed up as and justified as being in “the public interest”. The reality is that my situation was titillation to the interests of the public who love the sensationalism of a “corruption story” so expertly written with scriptwriters that could so easily have been taken from the production of Eastenders!

11. The Importance of Government, Reformation And The Need For The Right People

I want to make it clear that I truly believe a just, strong and righteous Government is of necessity and benefit for this country. As the great John Stuart Mill said, “A party of order or stability, and a party of progress or reform, are both necessary elements of a healthy state of political life.” It is vital therefore for the well-being of the public in this country that we have a healthy and active democracy through a functioning Government. However it is also vital that our politicians and the departments they run are held to account where they do not run as intended and hurt the public whose benefit they are originally designed to serve. It is therefore imperative that when such situations arise as they have here, that the situation is reformed. Governments like all forms of organisations are composed of individuals. These individuals need to be of high character and competence and where they are not these individuals need to be given the opportunity to reform by being held accountable for their actions and learning from them. It is imperative that your department learns from the grave mistakes it has made which has ruined the lives of many. 

12. Information Commissioner's Office (ICO)

It’s prudent to inform you of the developments that relate to personal and private information and data that was obtained illegally by the witnesses and sources who triggered your Department and effectively weaponised it in their attacks on Lighthouse and individuals at Lighthouse.

The misuse of private information and stolen intellectual property is a civil and criminal case respectively, as I’m sure you are aware. We are taking significant steps through the ICO to understand the extent of this matter and the extent of wrongdoing in relation to our case and the abuse of process, as well as the degree to which the lack of demonstrable duty of care and the lack of due diligence was carried out by your department. 

As a start of many steps, we are in the process of issuing Data Subject Access Request (DSAR) to the Insolvency Services to discover more. In addition to this, we have made a DSAR into the sources and witnesses who triggered your Department. This includes Mr Jeffrey Leigh-Jones who, along with the rest, have until the 26th September 2023 to respond to the DSAR and as such we are yet to hear from them, which raises the concern as to their involvement in this civil and criminal matter.

13. The David Vs Goliath Showdown: An Invitation To Support And Partake In A Powerful And Reformative Global Opportunity

What makes this smear campaign and constructive sabotage worse is that our right to reply live and in real-time has been denied. Censorship of this kind is tyrannical and a direct threat to this country. The ‘small man’ is at the mercy of such unscrupulous actions without having the levels of reach that the media have. As a result we have initiated a David vs Goliath Showdown series in order to stand up to tyrannical organisations who are censoring and suppressing the truth at the expense of others.  

In our case, our primary aim here is to set the record absolutely straight and to ensure the public receives a full and fair disclosure of the facts, presented live and in real-time. The opportunity to reach the same mass audience with damning evidence and sound reasoning is something the BBC has denied Paul Waugh and Lighthouse. In order to do so, we are inviting the BBC journalist Catrin Nye, her full team and all the relevant executives at the BBC, along with all of their sources and experts that were featured in ‘A Very British Cult’, to a live and prime-time public showdown. The reason why it is imperative for this being a live and real-time broadcast is to absolutely deny any opportunity for manipulative and/or deceptive editing practices that can come through the chop and cheat editing (propaganda) room floor.

Why this is pertinent to you is that as I have stated earlier, the BBC used your department and the winding up of Lighthouse through the courts as a means to borrow credibility in their broadcasts and thus you have aided our persecutors and constructive saboteurs in their attack. Therefore by default, it involves you and your department. Nevertheless, we would love this to be an opportunity for reform and to make right, as well as take a stand for the “small man” as part of the public interest and certainly your interest as Secretary of State for Business and Trade. 

In this live and raw real-time debate, the BBC, its sources, Mr Waugh and Lighthouse will have a platform to answer key questions, present any and all concrete and tangible evidence, along with its provable context, in front of the worldwide court of public opinion. Such an opportunity to respond fully, fairly and properly to the public, having been requested multiple times by Mr Waugh and fellow Lighthouse partners, but outright denied by the BBC in an act of deliberate censorship. It is most certainly in the public interest. This is even more so the case, given the stark and prolific levels of deception through lies, falsehoods, misinformation and/or disinformation that the BBC have committed, which will be categorically proven through this planned pay-per-view event. This is an event which will go ahead in front of a global audience whether the BBC, their sources and experts agree to take part or not.

In line with this, I enclose a link to our David vs Goliath website below (click on image). The homepage on our website also contains a video preview of our upcoming series of Lighthouse vs the BBC.

The David vs Goliath Showdown is a wonderful opportunity for the right people and organisations to be involved in this inaugural production by Lighthouse Global Media, which will be an ongoing series that will feature many other cases and situations. It will give ordinary people and companies/organisations that require a large scale public platform and sufficient reach for them to set the record straight in other matters to do so; whether dealing with the legacy media, the government, corporates, or whoever it may be who are suppressing the truth and abusing their responsibility.

14. Next Steps

As someone with a promising political career who is being seen as a future Prime Minister, I trust that you would feel compelled by your conscience to fulfil your ministerial duty. As a bare minimum this would include investigating, remedying and apologising for your department’s failures and reforming them so they cannot happen again. The Government and its resources must never be used to destroy the innocent public. It must be a vehicle for the continual improvement of the wellbeing of the nation it serves.   

15. Questions

In addition to the questions that I have asked in my official complaint letter sent to the Insolvency Service, I feel the following are pertinent to being addressed by you as Secretary of State, given the respect and thoroughness they deserve.

Questions relating to the Public Interest:

  • Why was the investigation into Lighthouse regarded as being in the Public Interest when there are so many bigger organisations that have a far greater impact on society and that aren’t being investigated?! We are a micro-entity! 
  • If this investigation was regarded as being in the Public Interest then why isn’t an adequate time set aside for a court case where defendants have the opportunity to provide full and fair disclosure of the facts? In our case we had to defend ourselves on a charge based upon accounting technicalities. If that was the case then there ought to be hundreds of thousands of such court cases per year! 

Questions relating to the legitimacy of the claimants:

  • What does the Insolvency service have in place to ensure that the reports made online are not a co-ordinated smear campaign, designed to weaponise government departments? What are the consequences for claimants who are found to have misled the Insolvency service with maliciously false statements in order for there to be a deterrent against its abuse? 

Question/s relating to the Insolvency Service’s internal investigating process and the employees involved:

  • How do you ensure your employees are objective both in the process of investigating companies and complainants, so they are not biased against lies and falsehoods from either party? What provisions are in place where this objectivity is not at the level required for the process of investigation to be fair.  For example, in our case we had one of your employees call the claimants, who are in reality predatory trolls, “victims” and another employee say that some of them are “creditors!” 

Question/s relating to the resources this investigation has taken:

  • How much did this whole ‘investigation’ by Gary Seymour including the court costs and subsequent work by Mrs Baldock cost the Insolvency Service and by virtue of that the taxpayer?  

Questions to relating to resources given to defendants to be able to fairly defend themselves and the options available to them to rectify any mistakes discovered:

  • Why weren’t we given any state support to defend ourselves? The predatory trolls had your full backing but we weren’t offered any support, including any financial and/or legal support, so that we had the opportunity to defend ourselves. 

Questions relating compensation owed to Lighthouse:

  • What remedial and compensatory measures does the Insolvency Service have where they realise they have acted with gross negligence, if not outright bias and collusion with unlawful and criminal claimants?


Kind regards,

Chris Nash

Lighthouse International Group 

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