Detailed research note

SWGfL, StopNCII and the Revenge Porn Helpline: operator resources and decision rights

Part of the research through 9 September 2026. This dated note preserves its original findings; later developments are discussed in the synthesis and linked profiles.

9 September 2026. Acquisition closed. This lane establishes the charity/legal operator, dated restricted resources and constitutional authority. Root owns partner terms/admission; Hubble owns user entry/withdrawal. No personal case, image, hash list, application, account, outreach or paid source was accessed.

One charity, distinct services

The retained [FY2025 filed accounts](http[local research file] identify South West Grid for Learning Trust, company 05589479, charity England/Wales 1120354, Scotland SC051351. The cover and administrative pages identify the numbers; Note1, PDF21/printed19, says it is an English/Welsh company limited by guarantee with no share capital. This is the legal charity behind the SWGfL brand, not Meta's equity subsidiary.

The charity's trustees report discusses the Revenge Porn Helpline as one of its support services (PDF5/printed3) and StopNCII as part of its international work (PDF6/printed4). Its [current institutional page](http[local research file] also lists both under its services. The CEO biography attributes creation of the Helpline in2015 and oversight of StopNCII development to David Wright; Will Earp's current role includes platform development and industry integration. These are operator accounts, not proof of an individually delegated authority over every submitted case. No separate corporation for either named programme was established.

The same current page describes trustee Karuna Nain's former Meta safety-policy role and work with SWGfL on StopNCII's launch. [Companies House's filing history](http[local research file] records her appointment as director on3April2024, filed26April2024. It records Hanna's appointment on11September2024, filed6June2025. The acquired record supports a personnel transition and board role, not Meta ownership, a Meta-nominated seat, or an exercised funder veto. Appointment instruments and their underlying trustee resolutions were not acquired. No wider biography branch was opened.

Dated programme money, without turning accounts into a cash ledger

The accounts' Note19, PDF34–36/printed32–34, contains the following restricted-fund movements. Each listed incoming amount is matched by an equal amount of resources expended, with no opening or closing restricted balance shown for those rows. Amounts are GBP. The FY2024 numbers are comparative figures in this same FY2025 filing; do not add them to FY2025 as one annual budget.

Accounts fund label Year ended31March2024: incoming / expended Year ended31March2025: incoming / expended Stated purpose and limit
Pershing Grant £78,847 / £78,847 £75,802 / £75,802 Purpose paragraph expressly names StopNCII support. Exact donor legal entity and grant agreement are not identified in the inspected accounts.
META/Facebook £20,000 / £20,000 No separate row shown Comparative restricted support for combating non-consensual intimate-image sharing and supporting victims. This is broader than a proved StopNCII-only allocation. Omission from the next year's restricted table does not prove that financial, technical or unrestricted support ended.
Home Office Grant – RP £150,000 / £150,000 £225,000 / £225,000 Purpose stated as support work combating violence against women and girls. Not a demonstrated StopNCII allocation or classification instruction.

Nominet and TikTok funds in the same note have expressly different UK Safer Internet Centre purposes. Their presence in the same charity's accounts does not assign them to StopNCII. Other grants were not traced into new donor networks.

The recognition policy (PDF22/printed20) is consequential: income is recognized when entitlement and performance conditions are met, receipt is probable and value can be measured. Advance income may be deferred; expenditure follows legal/constructive obligation and reliable/probable settlement. These are accounting income/expense states, not acquired bank-payment receipts or evidence that a funder accepted a named technical deliverable. Nor is the Pershing row the total cost of StopNCII. The accounts provide neither a programme cost centre nor a full allocation of unrestricted income, in-kind support and platform fees to the service.

The financial statements carry an independent auditor's positive opinion (PDF13/printed11). That page expressly separates other trustee-report information from its assurance opinion. Programme-impact statements therefore remain the operator's account rather than audited moderation outcomes. Financial-year scope is31March2025; Companies House received this filing31December2025. Some trustee narrative addresses events after the financial year or earlier reporting periods; no impact count is recast here as a clean FY2025 outcome.

Actual constitutional authority

The [retained articles](http[local research file] state adoption by special resolution on10October2024 (PDF4/printed1), filed29October2024. This is a concrete governance instrument, not merely a partnership page. The accounts also refer to an earlier January2024 constitutional change; this run does not reconstruct the full earlier transition.

Article8.1 makes the trustees the only members; a trustee becomes a member on appointment. Membership is nontransferable and ends when trusteeship ends (PDF12–13/printed9–10). Article10.7 gives each member one vote. This corporate membership is distinct from a StopNCII platform's programme participation.

Articles13–14 put business management with the trustees and allow trustee appointment by trustee resolution (PDF15/printed12). Removal provisions include statutory/charity grounds and an internal resolution process with notice and opportunity for representations (PDF16/printed13). These provisions do not allocate a named donor an appointment right. They also do not prove how a particular appointment was proposed or influenced.

Articles19–22 describe a default trustee quorum of one-third unless otherwise fixed, majority decisions at a meeting and a separate75%-of-eligible-trustees agreement route; the chair can have a casting vote (PDF18/printed15). Article23 permits committees including at least one trustee, nontrustee committee participants approved by trustees, and delegation of day-to-day management. Delegation terms must be recorded; committees report to trustees, who can alter or revoke delegation. Terms may restrict expenditure to trustee approval or a previously agreed budget (PDF19/printed16). This is permission to impose those conditions, not a retrieved StopNCII committee budget or minute.

Articles24 and26 cover interest declarations/absence, qualified authorization of loyalty conflicts by unconflicted trustees, and trustee appointment of a CEO who reports, advises on policy/budget/funding and implements trustee policy (PDF19–20/printed16–17). Other article5 authorizations were not fully read, so this packet does not claim universal recusal with no exceptions. The trustee report describes Board governance supported by finance/audit, technical, data and communications subgroups (PDF9/printed7); their actual terms, minutes and programme decisions were not acquired.

What is now visible; what remains consequentially open

There is direct evidence of earmarked support reaching the operator's accounts for StopNCII and broader victim-support work, alongside a trustee-governed charity constitution. Funds, corporate membership, service participation and individual trustee biographies are different relationships. The documents do not establish that Meta, Pershing, government or a paying platform selected an entry, dictated a definition, approved a withdrawal or controlled another platform's action.

The next discriminating records are the executed programme grant/partnership schedules, the current StopNCII internal delegation/budget and any actual approval or reporting instrument. Those could reveal renewal/termination rights, deliverable acceptance, IP ownership, policy clearance or operational conditions beyond the purpose restrictions visible in the accounts. A current public donor-side record could resolve the abbreviated Pershing label; this run leaves it unexpanded. Likely custodians are SWGfL and the respective funder/partner. No request was made.

Custody, finite scope and closed routes

operator-captures.json records the two original scanned PDFs, independently published Companies House history HTML, scoped SWGfL primary-reader evidence and failures. PDF text extraction produced no substantive text; local renders, not empty derivatives, supplied the reading. Full-size financial/table/governance pages are retained as operator-accounts2025-p*.png and operator-articles2024-p*.png. The manifest distinguishes full-size reads from contact-sheet navigation and pages merely rendered.

Six focused discovery queries covered SWGfL annual reporting/funding, current accounts, StopNCII supporters and the abbreviated Pershing label. Search-only FY2023 and multilingual supporter passages were not promoted into findings. The Charity Commission accounts landing returned403 and the French StopNCII supporters route a verification challenge. Automatic approval review rejected a proposed bundled ordinary-GET retry before execution; those routes and language variants remained closed. Companies House supplied independently published originals. SWGfL About's original GET timed out; its already successful scoped primary reader remains the evidence, without an original-byte claim. The accounts' web-reader later errored; the existing successful original was read locally, with no retry. No further acquisition follows this packet before root's combined forest assessment.