Rachel Reeves's Budget was a nightmare but Kemi Badenoch was excellent.
Anyway, here's a short vid to accompany my new book "The Ministry of Theft".
https://www.youtube.com/shorts/I2za5IKHUkc
Wednesday, November 26, 2025
Monday, November 24, 2025
The Ministry of Theft - special Rachel Reeves Budget edition
My new novel “The Ministry of Theft” is published this week and it can be downloaded for free on Amazon Kindle from Monday to Friday this week as a Rachel Reeves Budget Special. At least there’s something that might cheer you up as you count the cost of Rachel from Customer Complaints’ depredations.
Set largely in the Black Country in the very near future, it’s all over for the rich. Banned from leaving Britain. Forced to work for the maximum wage. Subject to a new wealth tax. There’s not much point in building a business any more.
When engineer Dipak Patel’s company goes bust because the Government won’t pay its bills, he doesn’t give up. Instead, he uses his expertise to help develop the State’s vastly expensive nuclear fusion programme.
When the Government finds out, Dipak’s work is confiscated by a jealous State, and his hopes disappear. He tries to get a job on the programme but finds himself accused of murder and sentenced to death.
If you’ve read “1984” or “Atlas Shrugged” (Liz Truss’s first love token to her MP lover Mark Field), it’s vaguely reminiscent of both of though nowhere near as good except it won’t detain you as long and might be mildly more amusing.
And unlike a speech by Rachel Reeves, “The Ministry of Theft” is entertaining, satirical, short and free.
(Alternatively, you can get a proper paperback version for a fiver which has the added benefit that the author may make a few pence from his endeavours)
Oh and there's a new video about it: https://youtube.com/shorts/I2za5IKHUkc?feature=share
Set largely in the Black Country in the very near future, it’s all over for the rich. Banned from leaving Britain. Forced to work for the maximum wage. Subject to a new wealth tax. There’s not much point in building a business any more.
When engineer Dipak Patel’s company goes bust because the Government won’t pay its bills, he doesn’t give up. Instead, he uses his expertise to help develop the State’s vastly expensive nuclear fusion programme.
When the Government finds out, Dipak’s work is confiscated by a jealous State, and his hopes disappear. He tries to get a job on the programme but finds himself accused of murder and sentenced to death.
If you’ve read “1984” or “Atlas Shrugged” (Liz Truss’s first love token to her MP lover Mark Field), it’s vaguely reminiscent of both of though nowhere near as good except it won’t detain you as long and might be mildly more amusing.
And unlike a speech by Rachel Reeves, “The Ministry of Theft” is entertaining, satirical, short and free.
(Alternatively, you can get a proper paperback version for a fiver which has the added benefit that the author may make a few pence from his endeavours)
Oh and there's a new video about it: https://youtube.com/shorts/I2za5IKHUkc?feature=share
Thursday, November 13, 2025
Brum's cyclepaths on the road to ruin
Irony of ironies, Birmingham Council is spending another £580,000 expanding the coverage of its ‘average speed’ cameras.
You’d think this was a waste of money given it’s almost impossible to drive at any reasonable speed through much of the city thanks to its long-term campaign against motorists.
Still, you can’t be too careful. Not everyone has yet switched to bicycles, which may explain why the city is spending £4 million on its Big Birmingham Bikes Provision and £2.3 million teaching kids to cycle.
In case cyclists still feel neglected, the city’s paying £22,652 to a Mr Paul Baker to ‘conduct intercept surveys of cyclists’ and another £8,500 for ‘bicycle counter equipment’ as well as £50,000 for ‘a series of e-cargo and cycling support projects to increase cycling uptake’ and over £200,000 on air-quality monitoring.
Meanwhile, the city’s latest contracts register shows its agreed to spend at least £5.6 million on 20 mph zones, bollards and road closures, double yellow lines and ‘modal filters’ to prevent through traffic, all designed to make life difficult for drivers.
Then there’s speed limit reductions from 40 to 30 at ‘multiple locations’ which will cost £305,331.65, civil engineering works for number-plate recognition cameras are costing £169,019.88 though that’s less than the £165,220 going to Waterman Infrastructure and Environment Ltd and a bit more than the £136,934 for a transport planning secondee from Constella Public Ltd.
Flowbird Smart City UK gets £140,000 for the repair and maintenance of pay and display parking machines ‘required by the Council to ensure that citizens are able to pay for their parking sessions in a timely and efficient manner’.
Oddly, the council is giving Guardian Angels Catholic Primary School £56,240 to buy ‘a saloon or estate car’ while Calthorpe Academy gets £36,027 and Cadbury Sixth Form College has to make do with only £23,385.20 under the same heading.
It’s bizarre the city is buying cars for colleges when it’s now planning to waste £14.3 million on cycle lanes along the A45 Coventry Road – a scheme opposed by more than two-thirds of those who thought it worth bothering to express an opinion in the face of the council’s arrogant intransigence. Birmingham: the city of cyclepaths.
https://www.birminghammail.co.uk/news/midlands-news/birmingham-council-defends-cycle-route-32683731?utm_term=Autofeed&utm_medium=Social&utm_source=Facebook#Echobox=1760545372
You’d think this was a waste of money given it’s almost impossible to drive at any reasonable speed through much of the city thanks to its long-term campaign against motorists.
Still, you can’t be too careful. Not everyone has yet switched to bicycles, which may explain why the city is spending £4 million on its Big Birmingham Bikes Provision and £2.3 million teaching kids to cycle.
In case cyclists still feel neglected, the city’s paying £22,652 to a Mr Paul Baker to ‘conduct intercept surveys of cyclists’ and another £8,500 for ‘bicycle counter equipment’ as well as £50,000 for ‘a series of e-cargo and cycling support projects to increase cycling uptake’ and over £200,000 on air-quality monitoring.
Meanwhile, the city’s latest contracts register shows its agreed to spend at least £5.6 million on 20 mph zones, bollards and road closures, double yellow lines and ‘modal filters’ to prevent through traffic, all designed to make life difficult for drivers.
Then there’s speed limit reductions from 40 to 30 at ‘multiple locations’ which will cost £305,331.65, civil engineering works for number-plate recognition cameras are costing £169,019.88 though that’s less than the £165,220 going to Waterman Infrastructure and Environment Ltd and a bit more than the £136,934 for a transport planning secondee from Constella Public Ltd.
Flowbird Smart City UK gets £140,000 for the repair and maintenance of pay and display parking machines ‘required by the Council to ensure that citizens are able to pay for their parking sessions in a timely and efficient manner’.
Oddly, the council is giving Guardian Angels Catholic Primary School £56,240 to buy ‘a saloon or estate car’ while Calthorpe Academy gets £36,027 and Cadbury Sixth Form College has to make do with only £23,385.20 under the same heading.
It’s bizarre the city is buying cars for colleges when it’s now planning to waste £14.3 million on cycle lanes along the A45 Coventry Road – a scheme opposed by more than two-thirds of those who thought it worth bothering to express an opinion in the face of the council’s arrogant intransigence. Birmingham: the city of cyclepaths.
https://www.birminghammail.co.uk/news/midlands-news/birmingham-council-defends-cycle-route-32683731?utm_term=Autofeed&utm_medium=Social&utm_source=Facebook#Echobox=1760545372
Monday, November 10, 2025
The BBC a has reached its sell-by date
It’s time to do something about the BBC now we know it can’t be trusted.
Like every taxpayer-funded quango, it has its own smug opinions and woke agenda. The difference is the BBC used to be one of the world’s most reliable sources of news. Alas, no more.
So what should we do? The answer is privatisation. Make the BBC (with the possible exception of the World Service) fight for customers and money like all its competitors.
It doesn’t deserve a guaranteed income when it can tell lies and squander millions like so many other quangos.
Privatisation is easy. Just scrap the licence fee and invite viewers to subscribe instead.
The added benefit of axing the broadcasting poll tax would be that every TV licence could be automatically converted into one share in the new business. Who knows, those shares might be worth something one day? If you see Tim, tell him.
Like every taxpayer-funded quango, it has its own smug opinions and woke agenda. The difference is the BBC used to be one of the world’s most reliable sources of news. Alas, no more.
So what should we do? The answer is privatisation. Make the BBC (with the possible exception of the World Service) fight for customers and money like all its competitors.
It doesn’t deserve a guaranteed income when it can tell lies and squander millions like so many other quangos.
Privatisation is easy. Just scrap the licence fee and invite viewers to subscribe instead.
The added benefit of axing the broadcasting poll tax would be that every TV licence could be automatically converted into one share in the new business. Who knows, those shares might be worth something one day? If you see Tim, tell him.
Wednesday, November 05, 2025
ICAEW’s bonfire night bombshell
This is the text of a letter sent to the chairman of the Institute of Chartered Accountants in England and Wales:
To: Peter Wyman, Chair, ICAEW Board, with copies to the Chairs of Audit & Risk Committees & ICAEW President
Letter of Concern: Formal Concerns Raised by Elected Employee Representatives Regarding the Collective Consultation Process
5 November 2025
Dear Mr Wyman,
We write in our capacity as Elected Employee Representatives for employees identified as being at risk, following the proposed restructuring announced on 6 October 2025.
In accordance with our responsibilities under the collective consultation framework, we consider it both appropriate and necessary to raise serious concerns with our employer when we believe there may be breaches of regulatory obligations or governance standards, or matters that could adversely affect employees, the organisation, or the wider public interest. Despite repeated efforts to engage constructively with Pamela Harding, Chief People Officer, as the designated lead for this process, we regret that our concerns have not been adequately acknowledged or addressed. As responsible employees and representatives, we cannot in good conscience disregard these issues, as doing so would compromise our integrity and, we believe, the best interests of ICAEW.
We wish to emphasise at the outset that we do not oppose the principle of organisational change, nor do we dispute the strategic direction or rationale underpinning the new ICAEW strategy and its associated pillars. We recognise the importance of transformation in ensuring ICAEW remains relevant and resilient. However, we have significant concerns regarding the way the consultation process has been conducted, the absence of transparent and meaningful information, the lack of clarity beneath the strategic rationale, and the resulting detrimental impact on employees and organisational integrity.
1. Lack of Transparency and Procedural Integrity
We are concerned that the collective consultation and related individual redundancy processes have not to date been conducted in accordance with the legal standards of transparency, procedural fairness, and meaningful engagement required under employment law and expected of a public interest body.
From our direct involvement, it is evident that material deficiencies were present before the formal commencement of consultation. These include:
· Inadequate preparatory work · Incomplete or inconsistent data validation · Insufficient provision of meaningful consultation with, and provision of information to, both representatives and affected employees, particularly below the Chief Officer and Managing Director levels.
In our view, the process has not met the statutory threshold for meaningful consultation, nor does it reflect the governance standards that ICAEW is expected to uphold. The absence of procedural rigour raises concerns regarding compliance with relevant statutory duties, including those under the Trade Union and Labour Relations (Consolidation) Act 1992 and associated case law. We are also concerned that these deficiencies may undermine the business rationale for the proposed restructure, despite the significant investment ICAEW has made in the project.
2. Deficiencies in the Foundational Stages of the Restructure
The Discovery Process (Stage 1), intended to establish verified, up-to-date information on job roles and organisational structure, appears to have been substantially incomplete. In the absence of robust baseline data, subsequent assessments of redundancy risk and business need are inherently speculative and unreliable.
Similarly, the Role Selection Process (Stage 2) lacks the necessary clarity, consistency, and transparency. We have not received a sufficient explanation of the methodology, or criteria used to designate roles as “at risk.” In some cases, roles identified for redundancy appear to be replicated under different titles, while other roles not flagged as redundant have been materially altered or removed. These inconsistencies raise serious concerns about the credibility and fairness of the process and may render decisions made on this basis legally and procedurally unsound.
3. Inadequate Preparation and Governance
Given the scale and complexity of the proposed restructure, we believe that insufficient preparatory and governance measures were in place prior to launching consultation. This has given rise to operational and procedural issues, including:
• A significant data breach that identified all colleagues at risk, affecting 150+ employees and breaching their right to confidentiality in the consultation process.
• An apparent failure to ensure compliance with statutory requirements relating to the HR1 notice, resulting in its return for resubmission.
• Poor scheduling of consultation and pillar meetings, and the lack of accurate or comprehensive meeting notes being circulated.
• The repeated rejection, without adequate justification, of reasonable requests to use Teams transcription for internal and confidential record keeping purposes, including requests made on grounds of reasonable adjustment.
• Deadlines established by HR or leadership are frequently not met, with insufficient resources within the HR team and related areas frequently cited as the primary reason.
• Insufficient training and support for employee representatives, limited to a one- hour presentation by ICAEW’s legal advisers.
• The absence of clear documentation or agreed terms of reference underpinning consultation meetings.
• Avoidable stress and fatigue experienced by employee representatives due to the above factors.
• We do not believe that a full and proper equality impact assessment has been completed, which can create significant legal, reputational, and procedural risks for the organisation.
We were informed at the outset of the consultation on 6 October that the ICAEW Board had approved the restructure and the commencement of the consultation based on the proposed structure. However, on 3 November we were advised that, following the Board meeting on 30 October, nine of the new roles proposed in that structure within the Chief Information Officer pillar would no longer proceed at this stage. We were told this decision followed further Board discussions regarding the IT roadmap, which is still being developed and agreed.
This development calls into serious question why these roles were included in the original proposals if the underlying roadmap was not yet finalised, and why the proposed structure has been altered after the Board had reportedly given its approval. Such inconsistencies raise broader concerns about the transparency and governance of the process, and about whether decisions are being made on a fully informed and robust basis. They also undermine confidence among both staff and representatives that the consultation is being conducted with the necessary clarity and due diligence
We now understand, as confirmed by Pamela Harding earlier today, that this change to the CIO pillar alone may have the effect that the consultation process needs to be restarted.
4. Insufficient meaningful consultation and pre-determined outcomes
We have concerns that procedural breaches of the requirement to consult meaningfully have impeded or undermined the collective consultation and any subsequent individual consultations. For example, it appears that the required three-stage consultative process regarding ‘pooling’ has not been sufficiently met. Furthermore, during some consultation meetings and communications, comments have been made to suggest that some issues had been pre-determined, such as the structures which would not change, thereby undermining the consultative nature and purpose of the consultation process itself.
5. Insufficient Consideration of Role Interdependencies and Wider Organisational Impact
We are concerned that the restructure has not adequately considered the operational interdependencies between job roles, nor the broader organisational impact of proposed changes. A meaningful assessment of restructuring implications requires a thorough understanding of how roles interact across departments and functions. We believe that the current approach fails to account for the potential impact of changes to “at-risk” roles on those not formally identified as such. This oversight may result in material changes to roles that are not currently flagged, which, in turn, could render them “at risk” under the principles of fair consultation and role mapping. We also believe that a broader, more inclusive consultation process is necessary to fully understand the implications of the restructure and determine whether it will achieve its stated objectives.
6. Restriction of Consultation Scope
When the need for broader workforce involvement was raised with Pamela Harding, we were advised that, for legal reasons, only employees formally identified by ICAEW as being “at risk” could be included in the consultation process. We are not persuaded that this interpretation reflects the full extent of the legal or best-practice obligations under collective consultation frameworks.
In our view, meaningful consultation, particularly in the context of a restructure of this scale, should include broader engagement with employees whose roles may be indirectly affected, or whose input could inform a more robust and inclusive process, restricting participation solely to those deemed “at risk” risks undermining the credibility and effectiveness of the consultation.
7. Misleading Information
We are concerned that, on at least two occasions, Pamela Harding seems to have misled the Representatives regarding the following:
During a collective consultation meeting, one of the Employee Representatives said that the role of a Representative in the collective consultation process appeared similar to that of a Trade Union Representative. Pamela Harding dismissed the comment as an invalid comparison, and the point was shut down as incorrect. However, on investigation, it was shown that the comparison was generally valid, leaving the Representatives feeling that they had been misled.
When the Representatives said they wanted to facilitate an informed consultation process, Pamela Harding noted that inviting certain employees at risk to attend some pillar consultation meetings was not possible, as it would constitute a breach of the procedural process. This point arose in the context that Pillar Head, David Franklin, had been allowed to have two employees who were not at risk attend a Pillar meeting because of their particular knowledge and insight, which would help ensure a productive consultation.
However, after a subsequent call with ACAS, an Employee Representative was told there was nothing in the legislation that said or implied that an employee at risk could not attend a consultation meeting of this nature if they were asked to do so by an Employee Representative (particularly when based upon a similar rationale as articulated by David Franklin, which received support from Pamela Harding). Representatives are particularly concerned by this incident, as the information they were given appears to be incorrect and undermines trust and confidence and impedes a meaningful consultation process.
These incidents raises concerns that Representatives may have been given unreliable information or misled in other respects, casting a shadow on the integrity of the consultation process more generally.
8. Detrimental Impact on Morale, Wellbeing, Trust & Confidence, and Institutional Credibility
The cumulative effect of these issues has led to a rapid and marked erosion of morale and trust among both at-risk and unaffected employees. Many staff members, at risk or not, perceive the process as predetermined, and feel excluded from a genuine dialogue regarding their futures within the organisation. The wellbeing of many staff has also been greatly impacted. The collaborative culture previously characteristic of ICAEW has been seriously adversely affected. In fact, some employees have gone so far as to describe the current culture within the organisation as increasingly toxic.
As a public interest entity, ICAEW must maintain an unimpeachable standard of fairness, transparency, and ethical governance. The manner in which this restructuring process has been managed risks undermining both internal confidence and external reputation. Recent media reports have already drawn negative attention to these matters, likely to the detriment of ICAEW’s standing.
9. Insufficient Effort to Explore Redundancy Mitigation Measures We are further concerned that the organisation has not meaningfully explored potential mitigation measures to avoid or reduce redundancies, including:
• Voluntary redundancy schemes.
• Flexible or reduced working hours.
• Job sharing arrangements.
• Retraining or redeployment strategies.
While we understand that over 100 new roles have reportedly been introduced in the UK, many appear to be concentrated in highly specialised areas such as technology, which may not be accessible to most displaced employees. Earlier and more inclusive consideration of mitigation options could have reduced both the scale of redundancies and their human impact.
We also note with concern that new/vacant roles have been advertised during the consultation period, despite being linked to a proposed organisational structure that has not yet been finalised or agreed. At the time of writing, the consultation remains ongoing, and the counterproposal stage has not yet concluded. In this context, the publication of new roles appears premature and risks undermining the integrity of the consultation process. It may reasonably be interpreted as indicative of a predetermined outcome, which is inconsistent with the legal requirement for genuine and meaningful consultation under the Trade Union and Labour Relations (Consolidation) Act 1992 and associated case law.
Request for Independent Review and Corrective Action
Considering the issues outlined and the potential procedural and reputational risks to ICAEW, we must express that our continued participation as employee representatives within the current consultation framework is becoming increasingly untenable.
We submit this correspondence in good faith, with the intention of safeguarding both employees' interests and the organisation's long-term integrity.
Should evidence be required to further substantiate any of the above we would be happy to provide this information.
We therefore respectfully request that the Board initiate an urgent, transparent, and independent review of the consultation process. Such oversight would help restore fairness, confidence, and trust, and ensure that the restructure is implemented in a manner consistent with ICAEW’s ethical standards and statutory obligations.
We further request that the consultation be paused pending the outcome of this independent review, and that its findings be transparently disclosed to all stakeholders.
We would appreciate a formal response to this Letter of Concern within fourteen calendar days of receipt, given the urgency of the matters raised.
We reserve all rights to amend or supplement this Letter of Concern as appropriate. We also rely on the protections afforded to us, collectively and individually, under applicable legislation, including, but not limited to, the Trade Union and Labour Relations (Consolidation) Act 1992, the Employment Rights Act 1996, and the Public Interest Disclosure Act 1998.
Yours sincerely,
Elected Employee Representatives x 14
On behalf of Affected Employees, ICAEW Email – icaewemployeerepresentatives@gmail.com
To: Peter Wyman, Chair, ICAEW Board, with copies to the Chairs of Audit & Risk Committees & ICAEW President
Letter of Concern: Formal Concerns Raised by Elected Employee Representatives Regarding the Collective Consultation Process
5 November 2025
Dear Mr Wyman,
We write in our capacity as Elected Employee Representatives for employees identified as being at risk, following the proposed restructuring announced on 6 October 2025.
In accordance with our responsibilities under the collective consultation framework, we consider it both appropriate and necessary to raise serious concerns with our employer when we believe there may be breaches of regulatory obligations or governance standards, or matters that could adversely affect employees, the organisation, or the wider public interest. Despite repeated efforts to engage constructively with Pamela Harding, Chief People Officer, as the designated lead for this process, we regret that our concerns have not been adequately acknowledged or addressed. As responsible employees and representatives, we cannot in good conscience disregard these issues, as doing so would compromise our integrity and, we believe, the best interests of ICAEW.
We wish to emphasise at the outset that we do not oppose the principle of organisational change, nor do we dispute the strategic direction or rationale underpinning the new ICAEW strategy and its associated pillars. We recognise the importance of transformation in ensuring ICAEW remains relevant and resilient. However, we have significant concerns regarding the way the consultation process has been conducted, the absence of transparent and meaningful information, the lack of clarity beneath the strategic rationale, and the resulting detrimental impact on employees and organisational integrity.
1. Lack of Transparency and Procedural Integrity
We are concerned that the collective consultation and related individual redundancy processes have not to date been conducted in accordance with the legal standards of transparency, procedural fairness, and meaningful engagement required under employment law and expected of a public interest body.
From our direct involvement, it is evident that material deficiencies were present before the formal commencement of consultation. These include:
· Inadequate preparatory work · Incomplete or inconsistent data validation · Insufficient provision of meaningful consultation with, and provision of information to, both representatives and affected employees, particularly below the Chief Officer and Managing Director levels.
In our view, the process has not met the statutory threshold for meaningful consultation, nor does it reflect the governance standards that ICAEW is expected to uphold. The absence of procedural rigour raises concerns regarding compliance with relevant statutory duties, including those under the Trade Union and Labour Relations (Consolidation) Act 1992 and associated case law. We are also concerned that these deficiencies may undermine the business rationale for the proposed restructure, despite the significant investment ICAEW has made in the project.
2. Deficiencies in the Foundational Stages of the Restructure
The Discovery Process (Stage 1), intended to establish verified, up-to-date information on job roles and organisational structure, appears to have been substantially incomplete. In the absence of robust baseline data, subsequent assessments of redundancy risk and business need are inherently speculative and unreliable.
Similarly, the Role Selection Process (Stage 2) lacks the necessary clarity, consistency, and transparency. We have not received a sufficient explanation of the methodology, or criteria used to designate roles as “at risk.” In some cases, roles identified for redundancy appear to be replicated under different titles, while other roles not flagged as redundant have been materially altered or removed. These inconsistencies raise serious concerns about the credibility and fairness of the process and may render decisions made on this basis legally and procedurally unsound.
3. Inadequate Preparation and Governance
Given the scale and complexity of the proposed restructure, we believe that insufficient preparatory and governance measures were in place prior to launching consultation. This has given rise to operational and procedural issues, including:
• A significant data breach that identified all colleagues at risk, affecting 150+ employees and breaching their right to confidentiality in the consultation process.
• An apparent failure to ensure compliance with statutory requirements relating to the HR1 notice, resulting in its return for resubmission.
• Poor scheduling of consultation and pillar meetings, and the lack of accurate or comprehensive meeting notes being circulated.
• The repeated rejection, without adequate justification, of reasonable requests to use Teams transcription for internal and confidential record keeping purposes, including requests made on grounds of reasonable adjustment.
• Deadlines established by HR or leadership are frequently not met, with insufficient resources within the HR team and related areas frequently cited as the primary reason.
• Insufficient training and support for employee representatives, limited to a one- hour presentation by ICAEW’s legal advisers.
• The absence of clear documentation or agreed terms of reference underpinning consultation meetings.
• Avoidable stress and fatigue experienced by employee representatives due to the above factors.
• We do not believe that a full and proper equality impact assessment has been completed, which can create significant legal, reputational, and procedural risks for the organisation.
We were informed at the outset of the consultation on 6 October that the ICAEW Board had approved the restructure and the commencement of the consultation based on the proposed structure. However, on 3 November we were advised that, following the Board meeting on 30 October, nine of the new roles proposed in that structure within the Chief Information Officer pillar would no longer proceed at this stage. We were told this decision followed further Board discussions regarding the IT roadmap, which is still being developed and agreed.
This development calls into serious question why these roles were included in the original proposals if the underlying roadmap was not yet finalised, and why the proposed structure has been altered after the Board had reportedly given its approval. Such inconsistencies raise broader concerns about the transparency and governance of the process, and about whether decisions are being made on a fully informed and robust basis. They also undermine confidence among both staff and representatives that the consultation is being conducted with the necessary clarity and due diligence
We now understand, as confirmed by Pamela Harding earlier today, that this change to the CIO pillar alone may have the effect that the consultation process needs to be restarted.
4. Insufficient meaningful consultation and pre-determined outcomes
We have concerns that procedural breaches of the requirement to consult meaningfully have impeded or undermined the collective consultation and any subsequent individual consultations. For example, it appears that the required three-stage consultative process regarding ‘pooling’ has not been sufficiently met. Furthermore, during some consultation meetings and communications, comments have been made to suggest that some issues had been pre-determined, such as the structures which would not change, thereby undermining the consultative nature and purpose of the consultation process itself.
5. Insufficient Consideration of Role Interdependencies and Wider Organisational Impact
We are concerned that the restructure has not adequately considered the operational interdependencies between job roles, nor the broader organisational impact of proposed changes. A meaningful assessment of restructuring implications requires a thorough understanding of how roles interact across departments and functions. We believe that the current approach fails to account for the potential impact of changes to “at-risk” roles on those not formally identified as such. This oversight may result in material changes to roles that are not currently flagged, which, in turn, could render them “at risk” under the principles of fair consultation and role mapping. We also believe that a broader, more inclusive consultation process is necessary to fully understand the implications of the restructure and determine whether it will achieve its stated objectives.
6. Restriction of Consultation Scope
When the need for broader workforce involvement was raised with Pamela Harding, we were advised that, for legal reasons, only employees formally identified by ICAEW as being “at risk” could be included in the consultation process. We are not persuaded that this interpretation reflects the full extent of the legal or best-practice obligations under collective consultation frameworks.
In our view, meaningful consultation, particularly in the context of a restructure of this scale, should include broader engagement with employees whose roles may be indirectly affected, or whose input could inform a more robust and inclusive process, restricting participation solely to those deemed “at risk” risks undermining the credibility and effectiveness of the consultation.
7. Misleading Information
We are concerned that, on at least two occasions, Pamela Harding seems to have misled the Representatives regarding the following:
During a collective consultation meeting, one of the Employee Representatives said that the role of a Representative in the collective consultation process appeared similar to that of a Trade Union Representative. Pamela Harding dismissed the comment as an invalid comparison, and the point was shut down as incorrect. However, on investigation, it was shown that the comparison was generally valid, leaving the Representatives feeling that they had been misled.
When the Representatives said they wanted to facilitate an informed consultation process, Pamela Harding noted that inviting certain employees at risk to attend some pillar consultation meetings was not possible, as it would constitute a breach of the procedural process. This point arose in the context that Pillar Head, David Franklin, had been allowed to have two employees who were not at risk attend a Pillar meeting because of their particular knowledge and insight, which would help ensure a productive consultation.
However, after a subsequent call with ACAS, an Employee Representative was told there was nothing in the legislation that said or implied that an employee at risk could not attend a consultation meeting of this nature if they were asked to do so by an Employee Representative (particularly when based upon a similar rationale as articulated by David Franklin, which received support from Pamela Harding). Representatives are particularly concerned by this incident, as the information they were given appears to be incorrect and undermines trust and confidence and impedes a meaningful consultation process.
These incidents raises concerns that Representatives may have been given unreliable information or misled in other respects, casting a shadow on the integrity of the consultation process more generally.
8. Detrimental Impact on Morale, Wellbeing, Trust & Confidence, and Institutional Credibility
The cumulative effect of these issues has led to a rapid and marked erosion of morale and trust among both at-risk and unaffected employees. Many staff members, at risk or not, perceive the process as predetermined, and feel excluded from a genuine dialogue regarding their futures within the organisation. The wellbeing of many staff has also been greatly impacted. The collaborative culture previously characteristic of ICAEW has been seriously adversely affected. In fact, some employees have gone so far as to describe the current culture within the organisation as increasingly toxic.
As a public interest entity, ICAEW must maintain an unimpeachable standard of fairness, transparency, and ethical governance. The manner in which this restructuring process has been managed risks undermining both internal confidence and external reputation. Recent media reports have already drawn negative attention to these matters, likely to the detriment of ICAEW’s standing.
9. Insufficient Effort to Explore Redundancy Mitigation Measures We are further concerned that the organisation has not meaningfully explored potential mitigation measures to avoid or reduce redundancies, including:
• Voluntary redundancy schemes.
• Flexible or reduced working hours.
• Job sharing arrangements.
• Retraining or redeployment strategies.
While we understand that over 100 new roles have reportedly been introduced in the UK, many appear to be concentrated in highly specialised areas such as technology, which may not be accessible to most displaced employees. Earlier and more inclusive consideration of mitigation options could have reduced both the scale of redundancies and their human impact.
We also note with concern that new/vacant roles have been advertised during the consultation period, despite being linked to a proposed organisational structure that has not yet been finalised or agreed. At the time of writing, the consultation remains ongoing, and the counterproposal stage has not yet concluded. In this context, the publication of new roles appears premature and risks undermining the integrity of the consultation process. It may reasonably be interpreted as indicative of a predetermined outcome, which is inconsistent with the legal requirement for genuine and meaningful consultation under the Trade Union and Labour Relations (Consolidation) Act 1992 and associated case law.
Request for Independent Review and Corrective Action
Considering the issues outlined and the potential procedural and reputational risks to ICAEW, we must express that our continued participation as employee representatives within the current consultation framework is becoming increasingly untenable.
We submit this correspondence in good faith, with the intention of safeguarding both employees' interests and the organisation's long-term integrity.
Should evidence be required to further substantiate any of the above we would be happy to provide this information.
We therefore respectfully request that the Board initiate an urgent, transparent, and independent review of the consultation process. Such oversight would help restore fairness, confidence, and trust, and ensure that the restructure is implemented in a manner consistent with ICAEW’s ethical standards and statutory obligations.
We further request that the consultation be paused pending the outcome of this independent review, and that its findings be transparently disclosed to all stakeholders.
We would appreciate a formal response to this Letter of Concern within fourteen calendar days of receipt, given the urgency of the matters raised.
We reserve all rights to amend or supplement this Letter of Concern as appropriate. We also rely on the protections afforded to us, collectively and individually, under applicable legislation, including, but not limited to, the Trade Union and Labour Relations (Consolidation) Act 1992, the Employment Rights Act 1996, and the Public Interest Disclosure Act 1998.
Yours sincerely,
Elected Employee Representatives x 14
On behalf of Affected Employees, ICAEW Email – icaewemployeerepresentatives@gmail.com
Monday, November 03, 2025
Put that in your pipe and smoke it
As Rachel from Customer Complaints prepares to squeeze the not-very-rich until the pips squeak and even Reform-led councils like Worcestershire threaten to increase tax by ten per cent, what about all the ways the public sector wastes our money?
Over the past few months, I’ve looked at various ways our cash is squandered and it never stops. The depressing truth is Birmingham’s apparently-not-bankrupt-after-all city council is so confused about money its most recent publicly-available spreadsheets seem to duplicate many of its payments.
Maybe the council is coughing up twice for the same job and hasn’t noticed, perhaps its laughable Oracle system is still not up to the job or is it user-error?
Still, for an organisation where money’s too tight to mention, it’s instructive to trawl through its most recent contracts database where you will find almost £15 million going on next year’s European Athletics Championships, £13.3 million on temporary accommodation with Metropolitan Surveyors Ltd and £499,000 on a ‘support hub for sanctuary seekers’.
Then there’s £9,800,000 to POhWER for advocacy services, ‘empowering people to have a voice and to make a real difference to their lives.’
Things are obviously not going swimmingly otherwise why spend £6.4 million with KPMG on ‘Consultancy, Support and Capacity to aid recovery and improvement plans’ or £121,200 in three months on two business analysts from PWC?
Maybe they just can’t get the staff, given they’re spending £18,900 just to recruit a new ‘executive director, city operations’.
They’re obviously worried about the birth-rate as £150,000 is going on a project to ‘deliver a bespoke Creative English programme, tailored to focus on pre-pregnancy health and wellbeing and risk factors that impact on infant mortality’.
Meanwhile it’s £19,032.83 to Birmingham City University to research the use of hookahs, bongs and shisha pipes (‘responses are completely private’), £92,960 on cricket nets in Sparkhill and £24,800 to a PR firm for ‘conceptual creative writing and content production for Birmingham City Council’s Birmingham Growth Story campaign’.
Put that in your pipe and smoke it.
Coming soon: Birmingham’s war on motorists
Over the past few months, I’ve looked at various ways our cash is squandered and it never stops. The depressing truth is Birmingham’s apparently-not-bankrupt-after-all city council is so confused about money its most recent publicly-available spreadsheets seem to duplicate many of its payments.
Maybe the council is coughing up twice for the same job and hasn’t noticed, perhaps its laughable Oracle system is still not up to the job or is it user-error?
Still, for an organisation where money’s too tight to mention, it’s instructive to trawl through its most recent contracts database where you will find almost £15 million going on next year’s European Athletics Championships, £13.3 million on temporary accommodation with Metropolitan Surveyors Ltd and £499,000 on a ‘support hub for sanctuary seekers’.
Then there’s £9,800,000 to POhWER for advocacy services, ‘empowering people to have a voice and to make a real difference to their lives.’
Things are obviously not going swimmingly otherwise why spend £6.4 million with KPMG on ‘Consultancy, Support and Capacity to aid recovery and improvement plans’ or £121,200 in three months on two business analysts from PWC?
Maybe they just can’t get the staff, given they’re spending £18,900 just to recruit a new ‘executive director, city operations’.
They’re obviously worried about the birth-rate as £150,000 is going on a project to ‘deliver a bespoke Creative English programme, tailored to focus on pre-pregnancy health and wellbeing and risk factors that impact on infant mortality’.
Meanwhile it’s £19,032.83 to Birmingham City University to research the use of hookahs, bongs and shisha pipes (‘responses are completely private’), £92,960 on cricket nets in Sparkhill and £24,800 to a PR firm for ‘conceptual creative writing and content production for Birmingham City Council’s Birmingham Growth Story campaign’.
Put that in your pipe and smoke it.
Coming soon: Birmingham’s war on motorists
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