by Peter Kahl, 7 August 2025
The deeper I dig, the worse it looks.
Earlier this week, I formally wrote to Sir David Robert Bell KCB DL, raising serious concerns about overlapping governance roles and fiduciary transparency at the Higher Education Policy Institute (HEPI), where he is publicly listed as a trustee. He responded promptly—by email on 4 and 5 August—stating that he has not been a trustee since Autumn 2024.
However, the official Charity Commission register (GOV.UK) tells a different story: Bell is still listed as a current trustee, appointed 21 December 2016, with no recorded termination. As of 7 August 2025, his name remains on the register.
To resolve this explicit discrepancy, I sent a formal letter to the Charity Commission on 4 August 2025, requesting confirmation of his official status.
Today, 7 August, I also sent a formal open letter (PDF copy) to Nicholas Hillman, Director of HEPI, titled:
Formal Request for Governance Disclosure and Clarification Under Charity Law – Trustee Status of Sir David Robert Bell KCB DL
That letter was sent via email and is being dispatched by registered post today. It demands that HEPI disclose the date, method, and documentary evidence of Bell’s resignation—if such a resignation was validly executed and reported.
What this discrepancy reveals is not just a clerical oversight. It points to a wider problem of fiduciary opacity—a systemic failure to maintain accurate and truthful public records. For an organisation claiming independence and neutrality, that is untenable.
Consider this: of the five individuals currently listed as HEPI trustees on the Charity Commission register, only one—Professor Dame Helen Wallace—declares any other trusteeship, namely her role with the Bruges-Natolin UK European Scholarships Fund. The remaining four—Professor Dame Julia Goodfellow, Professor Dame Sally Mapstone, Mary Curnock Cook CBE, and Sir David Bell—all show ‘None on record’.
This is plainly inaccurate:
- Dame Julia Goodfellow serves (or has served) as President of the Royal Society of Biology and adviser to the University of Hertfordshire.
- Dame Sally Mapstone is Principal of the University of St Andrews and sits on the board of Universities UK.
- Mary Curnock Cook CBE chairs Pearson Education Ltd and the Dyson Institute and holds directorships at the Student Loans Company, the Student Room, and Education Cubed.
- Sir David Bell is Vice-Chancellor and Chief Executive of the University of Sunderland, Pro-Chancellor of the University of Roehampton, Chair of Cambridge University Press, and a non-executive director at The Economist Group.
- Dame Helen Wallace, while the only trustee to declare another trusteeship, also holds appointments in several prominent academic and research institutions—introducing additional potential conflicts of interest which have not been publicly disclosed.
In other words, four out of five trustees have failed to declare any other trusteeships or governance roles—despite holding multiple such appointments across influential institutions. These are not marginal posts. They involve strategic influence over publishing, finance, policy, and institutional governance in the UK education sector.
The Charity Commission’s guidance (CC29) is unequivocal: trustees must declare all roles that may give rise to conflicts of interest. HEPI’s apparent failure to ensure accurate declarations is a breach of basic transparency standards. Under section 60 of the Charities Act 2011, knowingly or recklessly providing false or misleading information on public records is a statutory offence.
This isn’t about paperwork. It’s about truth. It’s about whether an organisation purporting to guide national education policy is, in fact, governed by a tight inner circle of undisclosed power-holders with overlapping allegiances and undeclared interests.
HEPI’s influence on UK education discourse is disproportionate—and largely unaccountable. Its research and commentary are routinely cited in Parliament, in Whitehall, and across major media. It claims independence. It demands public trust. But without transparent governance, that trust is illusory.
When the public cannot even know who is on the board—or what interests they hold—we are no longer dealing with a think tank. We are dealing with an epistemic gatekeeper cloaked in public legitimacy, but operating behind closed registers.
- I await formal clarification from the Charity Commission.
- I await substantive reply from HEPI by 13 August 2025.
- Additional formal legal notices to the remaining trustees and to Director Nicholas Hillman will follow.
HEPI has a choice: correct the record, disclose the facts, and rebuild trust—or continue down the path of opacity and regulatory risk.
In solidarity,
Peter Kahl
Independent Researcher & Advocate for Transparent Governance
Cite this work:
Peter Kahl, ‘HEPI’s Role in the HigherEd Catastrophe: Transparency, Fiduciary Duties, and Conflicts of Interest Under Scrutiny’ (2025) available at <https://github.com/Peter-Kahl/No-Records-No-Clarity-Transparency-Gap-at-HEPI>
Creative Commons Attribution–NonCommercial–NoDerivatives 4.0 International Licence (CC BY-NC-ND 4.0)