Mr. Ivan Cooper:

In regard to concrete examples, this is where it gets a bit tricky. The issue is that an organisation cannot come out and say, "What we are really about is promoting human rights but we had to play the system so we had to devise these memo and articles that make it look as though our purposes are not about promoting human rights". It is difficult to identify concrete organisations that have found themselves in this circumstance where, effectively, what they have had to do is re-characterise themselves as being about addressing certain issues when in fact if the promotion of human rights was a charitable purpose they might have more properly characterised themselves as being first and foremost about promoting human rights. The circumstance currently is that the promotion of human rights is not regarded as a charitable purpose in and of itself, so organisations cannot effectively claim that one of their purposes is about the promotion of human rights. It is a kind of catch-22 situation. Dr. Oonagh Breen has indicated one of the consequences of that. This is where it ties in with the advocacy question. I have referenced the advocacy and the lobbying question.

It is not a charitable purpose for an organisation to be a full-blown campaigning organisation that does no service delivery work or no information and advice and support work with a particular beneficiary group but only regards itself as being a purely advocacy organisation. Revenue has historically raised issues in regard to that. The current Charities Regulator is expected to continue that approach. What it means is that purely lobbying activity or purely advocacy activity is not regarded as charitable. Organisations that do that have to show that the advocacy activity they are doing is in furtherance of delivering the charitable purpose. That ties back across to the idea of human rights which is regarded, as Dr. Breen has indicated, as being essentially political in nature because it is solely concerned with changing the rights or legislative status quo. It is therefore deemed as being effectively a form of advocacy activity. That, it seems to me, is the complicating factor. There are organisations that have ended up structuring themselves in such a way, as Dr. Breen has indicated, whereby they have a charitable entity that conducts research and activity and another entity that is not directly related to them that does the advocacy work that does not have charitable status. It is, arguably, unnecessary.