The research behind the joint report with Transparency International was only made possible due to the government’s decision in 2014 to make its records available to the public free of charge. Due to the volume of Scottish Limited Partnerships (“SLPs”) incorporated during 2016 this information would have previously cost thousands of pounds. A similar investigation into limited companies would have cost considerably more. All of the information in the report was therefore obtained for free from open sources – predominantly the Companies House website. This guide aims to show members of the public how to access company data which can then be used to form the basis of similar investigations.
In the case of the recent report, the first step was to obtain details of the thousands of SLPs that were set up in 2016. At the beginning of every month Companies House publish a list of all the active companies in the UK in excel format, which can be accessed here. This list provides us with basic company information, consisting of company names and numbers, addresses and incorporation dates. SLPs can be identified from the alpha prefix ‘SL’ in their company number. It was therefore straightforward to extract these details from the spreadsheet and to compile a list of SLPs incorporated within the specified date range.
From there, the full information for every SLP could be accessed on the Companies House database. This database is currently in beta mode but provides the filing history of every company in the UK, as well as details of incorporation/dissolution dates, the details of company officers and annual returns listing shareholders. Another addition to the filing requirements of a company was introduced in 2016. Companies are now required to file confirmation statements, which show their Person of Significant Control (“PSC”). Although this requirement doesn’t currently extend to SLPs, it is a useful document when investigating other forms of corporate vehicle.
The first step once you have accessed the Companies House website is to search the register for the company you are interested in. This will then take you to the results page, from where you can click on the appropriate company name. In this case we will search for Progate Solutions LP, an SLP mentioned in the report. This takes us to the overview page for the SLP which shows their address, their company status (ie: whether they are active, dissolved or in liquidation), their registration date (when they were incorporated) and the type of company we are looking at.
The second tab shows us the filing history of the company. This shows us documents that have been filed at Companies House. For other forms of corporate vehicles, such as limited companies and LLPs you might expect to find documents such as accounts, annual returns and confirmation statements, all of which contain information which can be used to build a picture of the activities of and people involved with of a company.
In the case of SLPs however the filing history is usually quite short, due to the lack of filing requirements for this type of vehicle. For the report, we were interested in finding out who the partners of each SLP were. This information can be found in the incorporation documents for the SLP, which is the first document filed at Companies House. A pdf copy of this document can be found by clicking on the link next to its description.
In the case of Progate Solutions LP we can see that the company was incorporated on 15 May 2013, the general partner is CS Proxy Solutions Ltd and the limited partner is RM Everton Ltd. We can also see incorporation documents were presented by Georgios Bountakidis. On occasion, the location of each partner is recorded on the incorporation document itself, but in this case, the name of the partner is the only information we have. However, another Companies House search for RM Everton Ltd shows that a company with the same name is registered in the Marshall Islands. Additionally, Google searches can shed some light as to the whereabouts of partners.
The filing history also shows documents which detail any changes in the registered office of a Company and any changes in Partners or directors. It is therefore a useful tool when attempting to build a chronology of a company.
Other forms of corporate vehicle file more extensively than SLPs and Companies House and there is more information available to be viewed. Limited Company listings, for example, will always show a third tab, entitled ‘People’ which will list all of the past and present officers of the company (directors and secretaries), and an additional tab located underneath entitled ‘Persons with significant control’. This records the details presented by the company on the Confirmation Statement.
It should be noted that although Companies House is a useful tool for collating basic information it cannot be used as a basis for a full examination into the inner workings of a company. The books and records of a company, for example, cannot be viewed, and this kind of work is best left to forensic accountants and law enforcement. In the case of the recent report, the goal was to establish the scale of SLP incorporation, the identity of their partners and the countries where they originate from. For this purpose the Companies House website is currently a useful tool, and with the promise of additional features will continue to be important in this field of investigation.