KWC - Due Diligence, Directors' Report & Financial Statements

Summary

A request was made for due diligence documents and financial statements regarding a £2.2 million grant to King William's College, resulting in the partial disclosure of Treasury Board minutes and internal correspondence highlighting concerns over the college's financial forecasts and growth plans.

Key Facts

• The Treasury approved financial assistance to King William's College following a request from the Department for Enterprise.
• Internal correspondence from July 2025 revealed errors in the college's financial spreadsheets and a lack of capital development plans.
• Treasury officials noted the college's 5-year plan appeared flat with no significant growth in international pupils, making the case for support harder to construct.
• The response included extracts from Treasury Board meeting minutes dated 12 March 2025.
• Part of the requested information was withheld under exemptions, though specific exemption clauses were not detailed in the provided text.

Data Disclosed

• £2.2 million
• 12 March 2025
• 31 August 2019
• 31 August 2020
• 31 August 2021
• 31 August 2022
• 31 August 2023
• 2023/24
• 2024/25
• 2025/26
• 2026/27
• 15 August 2024
• 25 July 2024
• 0.5m pa
• 3%
• 5%
• 13%
• 1.3m
• 440 Island pupils
• £2 million

Original Request

Further to the revelation that King William's College (KWC) will receive a grant/loan c£2.2 million of taxpayer's money and the public availability of KWC Directors' Reports and Consolidated Financial Statements I seek the following: Such information relating to any financial and other due diligence conducted by the Treasury (if any) on KWC and its subsidiary companies in relation to KWC's funding request and approval. This includes but is not limited to scrutiny of successive Company Directors' Reports & Consolidated Financial Statements and other accounts, monthly budget and cash flow analysis, Independent Auditor's Reports etc; and Details (confirmation (or otherwise) of holding, date of receipt and any correspondence requesting the copies of the same) of the KWC Directors' Reports & Consolidated Financial Statements and such other relevant (KWC) Company Accounts held by the Treasury for the company's last five financial years ending 31 August 2020 to 31 August 2024 inclusive together with such other accounting documentation produced to date; and Such information held which corroborates the assertion made in KWC Directors' Report & Consolidated Financial Statements for the year ended 31st August 2023 regarding the College's contribution to the local economy. This includes but is not limited to supply chain value and the claim that by educating circa 440 Island pupils they relieve the local Government of circa £2 million of education costs annually; and Correspondence both internal to the Treasury and other areas of government, KWC auditors, The College and any other stakeholder relating to any matter reported in the Directors' Report and Consolidated Financial Statements and other KWC accounting documentation.

Data Tables (2)

Data Tables (reformatted)

Full Response Text

Part 1 Extracts of information relating to any financial and other due diligence conducted by the Treasury on King William’s College (KWC) in relation to the Department for Enterprise’s request for Treasury concurrence to approve financial assistance to KWC. The following extracts have been taken from the Treasury Paper submitted by DfE and are comments of Treasury officers in relation to the paper:

The following is an extract from the Treasury Board meeting minutes dated 12 March 2025 where the Treasury Paper submitted by DfE was considered:

3 Year Forecast to 26_27 = Actual summary financial information for years ended 31 August 2019, 31 August 2020, 31 August 2021, 31 August 2022 and 31 August 2023. Actual to date summary financial information for year 2023/24. 3 year forecast for years 2024/25, 2025/26 and 2026/27.
Information for DfE Meeting July 2024 Updated = contains 2 spreadsheets titled: Page to Present Externally = including pupil numbers, staff data, expenditure and income, for the years up to August 2021, 2022 and 2023. This is the same information as the attachment above title ‘DfE Info for 19_7_24 meeting’.
Internal use with forecasts = including pupil numbers, staff data, expenditure and income for the years up to August 2024 and August 2025.

Part 4 Extracts from correspondence relating to any matter reported within King William’s College accounting documentation
Email from Department for Enterprise dated 15 August 2024

around  bringing the above to light and understanding what their longer term plans look like without the tax.   Then offline can consider options.    ITIP / NI as an example clearly amounts to around half of this cost and as the Treasury Minister suggested anything that was considered might have to be more broadely to the education / childcare sectors   Kr M   From: Lewin, Mark (DFE) To: Stewart, Andrew; Randall, Caldric (Treasury) Subject: RE: Re: Follow up - current matters discussion Date: 25 July 2024 13:47:52 Thanks   Quick glance a. The s/s has errors in – div/0.    Easily fixed but they really do need to share a sheet that works.     b. I thought their 5 year plan was very much about growth (in pupil nos) , product development (growing int’l pupils) and cost realisation (Campus) – this plan is more or less flat .   a little bit of growth on income – around 0.5m pa  /3%, and a bit of cost savings.    But pupil nos largely same and no increase in int’l.    That’s a harder case to construct support around “staying” – whereas I thought we would be asked to support a plan which substantially grows.  c. No capital / development plan.   Need to see the costs needed to accommodate Buchan and the cash realised from sale somewhere in the plan? d. They were going to model the same above with and without VAT and VAT recovery.   Doesn’t do that.    They say they can accommodate 5% (as they can fully recover this -hence its not included as assumed at zero net effect) – but you did ask to see it shown at full value – which would presumably  then be 5% recovery year on year, and 1- 2% for capital works so the net cost would be around 13% and should be shown in accounts that this at around 1.3m keeps them loss making Just my initial skim ! Kr M       From: Stewart, Andrew Andrew.Stewart@gov.im Sent: Thursday, July 25, 2024 6:19 AM To: Lewin, Mark (DFE) Mark.Lewin@gov.im; Randall, Caldric (Treasury) Caldric.Randall@gov.im Subject: Fwd: Re: Follow up - current matters discussion   FYI gents   Haven’t had time to look through as yet.     Andy

Freedom of Information
Seyrsnys Fysseree

The Treasury Government Office,
Douglas Isle of Man, IM1 3PU

Telephone: (01624) 685605 Email: FOI.Treasury@gov.im

Government Website: www.gov.im

Our ref: 4648917 23 June 2025

Dear ###,

We write further to your request, received 12 May 2025, which states:

"Further to the revelation that King William's College (KWC) will receive a grant/loan c£2.2 million of taxpayer's money and the public availability of KWC Directors' Reports and Consolidated Financial Statements I seek the following (Numbering added by Treasury):

Part 1 Such information relating to any financial and other due diligence conducted by the Treasury (if any) on KWC and its subsidiary companies in relation to KWC's funding request and approval. This includes but is not limited to scrutiny of successive Company Directors' Reports & Consolidated Financial Statements and other accounts, monthly budget and cash flow analysis, Independent Auditor's Reports etc; and

Part 2 Details (confirmation (or otherwise) of holding, date of receipt and any correspondence requesting the copies of the same) of the KWC Directors' Reports & Consolidated Financial Statements and such other relevant (KWC) Company Accounts held by the Treasury for the company's last five financial years ending 31 August 2020 to 31 August 2024 inclusive together with such other accounting documentation produced to date; and

Part 3 Such information held which corroborates the assertion made in KWC Directors' Report & Consolidated Financial Statements for the year ended 31st August 2023 regarding the College's contribution to the local economy. This includes but is not limited to supply chain value and the claim that by educating circa 440 Island pupils they relieve the local Government of circa £2 million of education costs annually; and

Part 4 Correspondence both internal to the Treasury and other areas of government, KWC auditors, The College and any other stakeholder relating to any matter reported in the

Directors' Report and Consolidated Financial Statements and other KWC accounting documentation."

Our response to your request is as follows:

As previously advised we extended the standard processing period because some of the information which was subject to disclosure may have been exempt from disclosure to you on the grounds it was qualified exempt. We have now finished considering whether qualified exemptions to disclosure apply, including consulting with a third party, and have determined that no qualified exemptions apply.

Part 1
The Enterprise Act states that the Department for Enterprise (DfE) are required to come to Treasury for approval if financial assistance requests are over the maximum amount. Therefore DfE submitted the financial information to Treasury to take into consideration as part of the funding request and approval.

Based on the information submitted to and held by Treasury please find attached Appendix 1. This details the information relating to any financial and any other due diligence conducted by the Treasury on DfE’s request for Treasury concurrence to approve financial assistance to KWC.

Appendix 1 includes comments from Treasury officers on the information submitted and the relevant minute from the Treasury Board meeting where the funding request was considered.

Part 2 Please find attached Appendix 2 which shows what accounting documentation is held by Treasury and the date it was received.

Please note some of the information within Appendix 2 is out of scope for this part of the request and does not relate to KWC’s accounting documentation held by Treasury. Therefore this information has been redacted and labelled as follows – Out of scope.

While our aim is to provide information whenever possible, under section 20 of the Act, we are not required to provide information in response to a request if it is already reasonably accessible to you, whether free of charge or on payment of a fee.

The correspondence requesting KWC financial information to get a complete understanding of the situation has been released as part of a previous Freedom of Information request. This information can be accessed via the FOI disclosure log and searching for case ID 4485917. The information is located at the bottom of page 42 and carries over to page 43, within Appendix 2. The FOI disclosure log can be accessed at https://services.gov.im/freedom-of-information/search

Also, some of the information within Appendix 2 contains personal data and while our aim is to provide information whenever possible, in this instance we are unable to provide some of the information you have requested because it is absolutely exempt under section 25 of the Act (absolutely exempt personal information).

The information to which this exemption applies includes individual’s names and email addresses.

The reasons why this exemption applies are that: • The Treasury is satisfied that the information amounts to personal data of which you are not the data subject; and • The Treasury is satisfied that disclosure of the information would contravene one of the data protection principles as set out at Article 5 of the General Data Protection Regulation as it applies in the Isle of Man pursuant to the Data Protection (Application of GDPR) Order 2018, namely that the Treasury can only disclose the information where it would be fair, lawful and meet one of the conditions for lawful processing in Article 6 and in this case, none of those conditions have been met.

Part 3
Based on the information held by Treasury please find attached Appendix 3 which details information regarding KWC’s contribution to the local economy.

Please note some of the information within Appendix 3 is out of scope for this part of the request and does not relate to KWC’s contribution to the local economy. Therefore this information has been redacted and labelled as follows – Out of scope.

Part 4 Based on the information held by Treasury please find attached Appendix 4 which is correspondence relating to any matter reported within KWC’s accounting documentation.

Some of the information within Appendix 4 contains personal data and while our aim is to provide information whenever possible, in this instance we are unable to provide some of the information you have requested because it is absolutely exempt under section 25 of the Act (absolutely exempt personal information).

The information to which this exemption applies includes an individual’s name.

The reasons why this exemption applies are that: • The Treasury is satisfied that the information amounts to personal data of which you are not the data subject; and • The Treasury is satisfied that disclosure of the information would contravene one of the data protection principles as set out at Article 5 of the General Data Protection Regulation as it applies in the Isle of Man pursuant to the Data Protection (Application of GDPR) Order 2018, namely that the Treasury can only disclose the information where it would be fair, lawful and meet one of the conditions for lawful processing in Article 6 and in this case, none of those conditions have been met.

Please quote the reference number 4648917 in any future communications.

Your right to request a review
If you are unhappy with this response to your freedom of information request, you may ask us to carry out an internal review of the response, by completing a complaint form and submitting it electronically or by delivery/post.

An electronic version of our complaint form can be found by going to our website at https://services.gov.im/freedom-of-information/Review . If you would like a paper version of our complaint form to be sent to you by post, please contact me and I will be happy to arrange for this. Your review request should explain why you are dissatisfied with this response, and should be made as soon as practicable. We will respond as soon as the review has been concluded. If you are not satisfied with the result of the review, you then have the right to appeal to the Information Commissioner for a decision on; 1. Whether we have responded to your request for information in accordance with Part 2 of the Freedom of Information Act 2015; or 2. Whether we are justified in refusing to give you the information requested.
In response to an application for review, the Information Commissioner may, at any time, attempt to resolve a matter by negotiation, conciliation, mediation or another form of alternative dispute resolution and will have regard to any outcome of this in making any subsequent decision. More detailed information on your right to a review can be found on the Information Commissioner’s website at www.inforights.im. Should you have any queries concerning this letter, please do not hesitate to contact me. Further information about freedom of information requests can be found at www.gov.im/foi.

I will now close your request as of this date.