If the title of this post sounds counter-intuitive, that’s because I’m still struggling to reconcile the inspiration for it: a statement by the CIC Regulator in their latest annual report about how they strive to help protect the CIC brand:
“our approach is to neither confirm nor deny whether an investigation is taking place…to protect the integrity of the CIC.” (p.12)
and if you follow this through to the CIC Regulator’s published guidance on making complaints about CICs, you’ll find that if you do raise a concern, you’ll find that this opaqueness goes ever further in that they won’t “publish or tell the complainant about the outcome.” (p4)
This seems to be a little odd at best for a number of reasons:
1) all other regulators are usually transparent about investigations they opened and reached a decision on (unless there are over-riding legal reasons or concerns);
2) a ‘back of the envelope’ study I did into CIC complaints a while ago found that we, the general public, were increasingly raising concerns about them to the Regulator, year on year — and…
3) …as most complaints received by the Regulator relate to a CICs governance, then why not share some of the details of these with us all, so we can better structure and manage CICs to avoid common pitfalls and mistakes in better protecting the shared brand and respective integrity of the wider CIC community..?
Worryingly, the CIC Regulator also reveals in this latest annual report, that for the first time since CICs were introduced (14 years ago) they’ve actually acted on a complaint to investigate the affairs of a CIC. (Although they don’t disclose any details of this, so we can’t learn from other’s mistakes in strengthening our own respective understandings and practices).
There’s a relationship between trustworthiness and transparency, and if the CIC Regulator isn’t being transparent about how they’re handling the concerns people are raising about individual CICs, then there’s a limit to how far we’ll not only be able to feel we can trust them to protect the reputation of the social enterprises they’re responsible for, but also how much faith individual CICs will have in them to act with any integrity themselves as their regulator.
All of this isn’t meant as another CIC-bashing post (goodness knows, I seem to make enough of those already!), but part of my questioning aloud about some of the wider practices in the social enterprise sector that more of us should surely be aware of and asking about, if we’re to make sure that as a movement, we’re as credible and impact-ful as we have the potential to be.