The charity was set up in 2009 to further public understanding of global warming and its possible consequences and of measures taken or proposed in response to it.
The regulator opened a case in May 2022 after complaints were raised about the charity's output and funding, subsuming further concerns raised in October 2022 into the existing case.
The Commission examined a range of concerns, including the educational value of the charity's research, its funding sources and its relationship with a wholly owned trading subsidiary and with a sister organisation.
Overall, the Commission has concluded that the trustees' response during the case has addressed the concerns. They have also agreed to make additional changes, which the regulator now expects them to complete. The Commission can revisit issues raised during the case should renewed regulatory concerns come to light.
The charity's research output and website content
The Commission examined how the charity ensures its output meets appropriately rigorous standards of objective analysis and factual research to support the conclusions being presented, which is required for educational research in charity law.
During the Commission's engagement, the trustees proposed, trialled and implemented a new system that enables a level of external review in preprint, allowing for comments, corrections and proposed amendments ahead of publication from experts and other interested parties. The trustees also made important changes to the content of the charity's website, which now displays links to a far wider range of sources of information on climate change including those that draw conclusions different to those presented by the charity, ensuring greater balance in the overall content of the charity's website.
Relationship with other organisations
A range of concerns were raised about the charity's relationship with its wholly owned trading subsidiary. In October 2021, the subsidiary changed its working name from Global Warming Policy Forum to Net Zero Watch to better distinguish its non-charitable campaigns from the charity's activities. Its company name was formally changed on 8 May 2023.
The regulator examined concerns that the charity was financially supporting Net Zero Watch and that Net Zero Watch had consistently operated at a loss. It found no evidence to back these concerns up.
The Commission considers the trustees' plan to end its ownership of the subsidiary to be an appropriate further step.
Concerns were also raised about donations from a separate USA sister organisation, American Friends of Global Warming Policy Foundation, and whether the charity had taken reasonable steps to ensure it received the largest possible share. This concern related to the fact that the charity, and the US organisation, had a director in common. While the Commission has no jurisdiction over a USA-based organisation, it concluded that there were appropriate procedures in place for conflicts of interests between the organisations to be managed and so the person holding roles at both organisations had no involvement in funding decisions.
The charity's funding
Whilst there is no legal impediment to any charity accepting funding from a particular industry, the Commission received, and accepted, strong assurances from the trustees that the charity, as a matter of policy, does not accept donations from the energy industry or anyone with a significant interest in an energy company. The charity demonstrated that its Protocol for the Acceptance of Gifts prevents it from accepting donations from such sources. The regulator has seen no evidence to contradict this. The charity offered assurances that its sister organisation - American Friends of Global Warming Policy Foundation - operates the same policy.
The law does not require charities to disclose their sources of income. However, the trustees have chosen to make public statements about the charity's funding to reassure the public as to its independence. The trustees are aware these statements cannot be false or misleading, which would be a failure in their duty to protect their charity's reputation.
Tracy Howarth, Assistant Director for casework at the Charity Commission said:
There are many charitable think tanks on our register, representing a range of intellectual traditions and outlooks. Our role is not to examine their worldview, but to ensure that charities demonstrate that they are furthering their purposes for the public benefit. All charities must comply with a range of legal obligations, which for educational charities includes ensuring balance across their outputs to allow people to make up their own minds.
We have engaged with the Global Warming Policy Foundation on a range of regulatory issues in some detail and over many months. During that time, the charity has made changes and improvements both to its charitable activities, and its relationships with third parties. We expect the trustees to now fully implement the proposed changes. On that basis, we are satisfied the concerns raised are now resolved.
