大象传媒

The Executive Complaints Unit investigated all aspects of the complaints which have been made and considered them in light of the relevant section of the 大象传媒鈥檚 Editorial Guidelines.听 The relevant guidelines are those on Accuracy (Section 3), Impartiality (Section 4), Harm and Offence (Section 5), Fairness to Contributors and Consent (Section 6) and Privacy (Section 7).听 The Unit took into account of all the previous correspondence from complainants and gave the programme-makers a further opportunity to respond to the concerns which have been raised.听 It considered evidence provided by both the complainants and by the programme-makers.听 It also carried out some additional research, including reading and viewing relevant by Lighthouse Global Media and by complainants.

The Unit summarised each substantive point of complaint and set out its finding in each case.听 References to 鈥渢he programme鈥� in this finding are intended to apply to both the podcast series and the television documentary except where specified.

1. The programme only featured individuals who had issues with Lighthouse.听 No attempt was made to include positive contributions from satisfied clients.听 This was evidence of a lack of due impartiality.

The 大象传媒 operates in the public interest, reporting stories of significance to the audience.听 There is no single definition of public interest but it includes freedom of expression and providing information which informs public debate and allows people to gain a better understanding of issues of importance.听 The 大象传媒 is entitled to produce content about any subject, at any point on the spectrum of debate, so long as there is a good editorial reason for doing so.

In this case, the programme-makers investigated a range of serious allegations which had been made about Lighthouse by a significant number of former clients and their relatives.听 The programme-makers spoke to more than 40 people with experience of Lighthouse and its head, Paul Waugh, who expressed concerns about the organisation and its culture.听 They alleged, for example, their lives and relationships have been damaged by the coaching and mentoring provided by Lighthouse.听 They described what they considered to be controlling and manipulative behaviour by Lighthouse associates.听 They said they had invested tens of thousands of pounds in Lighthouse but claimed to have received nothing of value in return.听 They said they were misled into making payments to Lighthouse and were subjected to undue pressure to make such payments.

These allegations from a number of former clients were based on first-hand experience of working with Lighthouse and were corroborated by documentary evidence and recordings of Lighthouse sessions and phone calls.听 Concerns about the management and running of Lighthouse which were made to the programme-makers were also supported by evidence gathered separately by the Department for Business, Energy and Industrial Strategy.听 It brought court action which resulted in Lighthouse being wound up in the public interest.听 Its investigation into Lighthouse was based on Lighthouse鈥檚 lack of transparency about the nature of its business, its failure to maintain or provide adequate accounting records, and its failure to co-operate with the Secretary of State鈥檚 investigation.听 It also alleged Lighthouse 鈥渕ade misrepresentations to clients to induce them into making payments and has pressurised clients into making payments鈥� and alleged 鈥淪ome clients (or family members of clients) have reported hostility when individuals have sought to distance themselves from LIG鈥�.

An investigation into the conduct of the organisation and those responsible for its management was, therefore, in the public interest.听 There was a clear editorial justification for examining the manner in which Lighthouse was run and the way in which some clients said they were treated.听 The investigation looked at allegations of control, manipulation and anti-social behaviour made against those responsible for running Lighthouse, as well as serious concerns about the conduct of the organisation and its leaders.听

Lighthouse was entitled to reject the allegations made by former clients and their relatives and to state those making such allegations were pursuing a personal agenda.听 The Lighthouse says, for example, 鈥淎lmost the entirety of the 大象传媒鈥檚 18 months of supposed 鈥榠nvestigation鈥� was spent focused on speaking to resentful individuals and abusive family members holding hateful grudges against and motives to want to destroy Paul Waugh and Lighthouse鈥檚 reputation and business鈥�.听 However, the programme-makers were entitled to investigate allegations made about Lighthouse by some former clients and to consider the evidence to support those allegations so long as it ensured relevant views and perspectives were given due weight and prominence.

Complainants said the programme did not include any contributions from clients who had a positive experience with Lighthouse and this resulted in a lack of due impartiality because it failed to reflect an appropriate range of views. The Lighthouse says 鈥渢he 大象传媒 made no attempt to interview or try to speak to anyone currently working at Lighthouse until shortly prior to broadcasting鈥�.听

The 大象传媒鈥檚 Editorial Guidelines refer to the concept of 鈥渄ue impartiality鈥� where the term 鈥渄耻别鈥� means 鈥渁dequate and appropriate to the output, taking account of the subject and nature of the content, the likely audience expectation and any signposting that may influence that expectation鈥�.听 Due impartiality is 鈥渕ore than a simple matter of 鈥榖alance鈥� between opposing viewpoints鈥� but it does require programme-makers to give due weight to significant opinions and perspectives which are relevant to the subject matter of an item.听

There are a number of reasons why, in the view of the ECU, it was not necessary to include contributions from current or former clients who say they have benefitted from their involvement in Lighthouse:听

1. The subject matter and content of the programme were clearly set out and the audience would have understood it was limited to examining the experiences of former clients and relatives who have raised serious concerns about Lighthouse;

2. The audience would have understood those former clients were expressing a personal view based on their own experience.听 The programme did not give the impression every client or associate of Lighthouse would have had a similar experience;

3. The aims of Lighthouse and the impact it seeks to have were adequately reflected.听 It was made clear former clients who appeared in the programme initially recognised the benefits of their involvement with Lighthouse;

4. The programme included a response to the allegations from those running Lighthouse.听 They were, by definition, the focus of the allegations and this ensured the requirements for due impartiality were met.

The subject matter of the programme and the gist of the evidence the programme-makers relied upon have been set out above (and will be examined in more detail in due course).听 On point c), the Executive Complaints Unit investigation took account of the numerous elements of the programme which set out the benefits clients said they experienced from their involvement with Lighthouse.听 It was made clear, for example, all those who expressed concerns about the organisation initially felt it was a force for good in their lives.听 For example:

• In Episode One of the podcast, Jeffrey Leigh-Jones described the benefits of joining a weekly call with Paul Waugh and other Lighthouse clients: 鈥淚t felt good being part of this thing on a Saturday. 听It felt very grounding. 听Um, and the topics were always so interesting and Paul Waugh could present, like, amazingly.听 Inspires you.听 Inspired me anyway鈥�.

• In the same episode, reporter Catrin Nye said: 鈥淭he Lighthouse philosophy really seemed to work. 听Friends noticed that Jeff was getting more disciplined. 听He could work longer hours, could focus for long stretches of time. 听He seemed more articulate. 听And he was creating a business plan for the South Pole trek.

Jeffrey Leigh-Jones:听 It was brilliant.听 I was motivated, I was inspired and, and I started working hard. 听I was disciplined and I just loved that feeling. 听I thought it was great鈥�.

• In Episode One of the podcast, a client referred to as Erin set out her initial thoughts on working with Lighthouse: 鈥淚t started off very positive, the Seven Habits book group was a nice light relief, it was good to be connected to others. 听And Jai was very good.听 Maybe he鈥檇 ring me once a week and then we鈥檇 have an official mentoring session which was a nice thing to do.

Catrin Nye: 听When Jai said he could see areas in her life that he could help her develop, like better emotional intelligence, Erin also decided to sign up for the Discipline Programme.

Erin: 听They were very positive conversations. 听Everyone seemed very nice, very trusting. 听I could see others that had joined. 听They seemed like lovely people who I would like to work with and spend time with, plan things with project-wise.

The Unit鈥檚 investigation also took account of those element in the programme where people running Lighthouse set out, in their own words, the benefits of the work they were doing.听 The programme included public statements available on the Lighthouse website and on social media.听 For example:

• Paul Waugh explained his vision in Episode One of the podcast as follows:听 鈥淲hat we are doing is helping human beings actually gain control of themselves.听 Not for us to gain control of you, but for you to gain control because that鈥檚 where your power is鈥� To do what it takes on a mentorship level to actually build a human being, body, heart, mind, spirit, and then take the professional on that foundation and really build someone who鈥檚 focused, who's energised, who, who, who feels, who鈥檚 highly conscious, aware鈥�.
• In the television documentary Mr Waugh said: 鈥淲hat we鈥檙e doing is helping human beings to actually gain control of themselves.听 Not for us to gain control of you, but for you to gain control, because that鈥檚 where your power is鈥� Our responsibility is not only just to help you think well, feel well, eat well, look well, be well, but to raise your level of conscious awareness that you own enough of yourself that you know you鈥檒l never lose it鈥�.
• Jai Singh set out his understanding of Lighthouse in the programme: 鈥淛ust to give you a little bit of background on Lighthouse.听 We鈥檝e been going for about 16 years, I鈥檝e been involved for 11, I think, for my sins. 听We exist to help people to develop themselves so that they can improve themselves and improve the lives of others around them. 听Mentoring, coaching, counselling, leadership development鈥�.

The Unit took the view extracts such as those set out above served to ensure the programme gave due weight to the stated aims and objectives of Lighthouse and the benefits its supporters said it could bring.听 The audience was given a clear understanding of its purpose and recognised those who joined considered their initial involvement with Lighthouse to be a positive and empowering experience.听 The audience would have understood those who made allegations about Lighthouse changed their opinion of the organisation over time and were expressing their current view based on their individual experience.听

In relation to Point d) above, the Unit took account of the numerous occasions in the programme which set out the response of Lighthouse to the allegations made about it and its explanation for why former clients had made such allegations.听 For example:

• The podcasts repeatedly said:听 鈥淟ighthouse says it is the victim of a smear campaign by what it calls 鈥榩redatory trolls鈥� and 鈥榯oxic鈥� relatives and partners of those who are part of the group. 听Lighthouse says it has helped lots of people overcome the obstacles to their potential through mentoring, life-coaching, counselling and community support鈥�.

• Jai Singh told the programme:听 鈥淢any, many people are standing here, who鈥檝e actually benefitted.听 And you guys have only spoken to the people who have got some, a vendetta, right鈥�.

• Paul Waugh told the programme why he considered people who had left Lighthouse and their relatives considered it to be a cult: 鈥淏ecause they鈥檙e slurring us. 听They鈥檙e smearing us, that鈥檚 exactly what they do. 听These parents are child abusers that you鈥檙e supporting鈥�.

The Unit considered the audience was made aware of Lighthouse鈥檚 response to the allegations.听 There was no basis for inferring all clients at Lighthouse felt the same way and it was implicit other clients would have a different experience.听

In this context, there was no requirement to include contributions from clients who maintain they had a consistently positive experience.听 Due impartiality was achieved by ensuring the aims of Lighthouse were clearly set out and its response to the allegations made against it were given due weight.

This aspect of complaint is not upheld.

听

2. The programme included inaccurate and misleading information.听 Some complainants referred to 鈥�143 false and misleading statements鈥�.听 These statements were not set out but specific complaints included the following:

1. 1. It was inaccurate to say Lighthouse financially exploits members.听 This includes an allegation a client was pressurised into investing 拢131,000.听 The programme did not report clients were offered terms for having their money returned to them.

The programme included contributions from a number of people involved with Lighthouse in which they said they had been pressured into investing money in the organisation or pressured into paying significant sums to join coaching, mentoring or development programmes.听 For example:

• Jeffrey Leigh-Jones said he handed over tens of thousands of pounds to Lighthouse.听 He explained how after months of discussions with his mentor, Jai Singh, he re-mortgaged and then sold his house, giving around a third of the proceeds to Lighthouse.听 He said he was pressured into paying 拢25,000 to become a Lighthouse Associate Elect and was told the cost would increase dramatically unless he acted immediately.听 Separately, he explained he invested 拢30,000 in a publishing house which was intended to promote Lighthouse philosophy.听 In total, he said he invested 拢131,000.听 The programme reflected his initial willingness to invest in Lighthouse and the benefits he believed it would bring.听 It included him saying, for example, 鈥淚鈥檓 thinking I can achieve something here, it鈥檚 brilliant鈥� and 鈥淚t felt great.听 I was motivated, I was inspired and I started working hard. 听I could speak better, write better, I鈥檓 more in flow. Yeah I鈥檓 loving it鈥�.听 The programme also reflected how his opinion changed and how he now views his experience within the organisation.

• The programme included an interview with Erin who said she was encouraged by Jai Singh to take out credit cards and change her mortgage to raise capital to invest in Lighthouse.听 She said in the podcast 鈥淚 took out an interest free credit card, which was with information and support and encouragement, and the idea came from my mentor Jai. 听He was talking to me about how I should be changing my mortgage to be able to borrow money back鈥�.

• The programme included a recording of Jai Singh in which he explained why the cost of becoming an Associate Elect was due to increase and how quickly clients could expect a return on their investment: 鈥淵ou guys are the last ones who come in at 25K a pop and now it鈥檚 100.听 And it, you know, it鈥檚 because then, then, then we have to shut the door and we have to go and, you know, because then it鈥檒l be 100K and then the following year, 250, because people will just see, they鈥檒l, they鈥檒l be making that money back in less than a year鈥�.

• The programme interviewed Simon Perreira who explained how he was encouraged to become an Associate Elect:

Simon Perreira:听 They didn鈥檛 come straight up to me and said, 鈥楬ey, like, become a Lighthouse partner鈥�.听 It was a lot more gentle, steady approach.听 It was a big investment. 听So it was 拢25,000 to become what they called an, an Associate Elect. 听Like a Lighthouse trainee mentor, you know, in layman鈥檚 terms.

Catrin Nye:听 So you had to pay to become?

Simon Perreira:听 Yes, nothing was never described as pay - it was always, 鈥榶ou鈥檙e making an investment in yourself鈥�.

• Episode Three of the podcast included the following:

Catrin Nye:听 Many former team members and relatives told me Lighthouse helps or encourages mentees to borrow thousands of pounds to pay for mentoring courses.

Client 1:听 I was just like, you鈥檝e just given them 拢15,000 and they鈥檝e given you nothing. 听All of my friends, every single friend, he asked them to borrow money.

Catrin Nye:听 The voices you鈥檙e hearing here are actors but they鈥檙e all words of people who were either part of Lighthouse or had a close family member inside the group.

Client 2:听 I took out a loan for 拢10,000. 听At that time that was a million dollars for me.

And

Catrin Nye:听 We鈥檝e been told repeatedly that some Lighthouse team members were told if they invested in Lighthouse programmes, they would make their money back very quickly.

Client 3:听 I was told that through mentoring you can earn hundreds of thousands.听 My mentor said 鈥榶ou trust me, don鈥檛 you?鈥�

Client 4:听 You had to invest a fair sum of money, but there were promises of big returns.

The 大象传媒鈥檚 Editorial Guidelines say 大象传媒 content should 鈥渁s appropriate to its subject and nature, be well sourced, based on sound evidence, and corroborated鈥� Claims, allegations, material facts and other content that cannot be corroborated should normally be attributed鈥�.听 The extracts above show the programme-makers obtained significant first-hand evidence to support claims made by people involved with Lighthouse that they were pressured and manipulated by associates into handing over significant sums of money.听 The claims were supported by relevant documentation, such as bank account statements, as well as recordings and transcripts of conversations between Lighthouse mentors and clients.听 Conversations between Jeffrey Leigh-Jones and Jai Singh, for example, appear to support Mr Leigh-Jones鈥� claim he was encouraged to sell his house to fund an investment in Lighthouse:

Jai Singh:听 Have you had any thoughts in relation to what you do?听 Umm and err, investment wise and that kind of thing, what is your鈥�?

Jeffrey Leigh-Jones: What do you mean what I do?

Jai Singh:听 Like you鈥檝e spoken about your house, you鈥檝e spoken about different things, so?

And

Jai Singh:听 The eighties and nineties are gone, property鈥檚 over.听 What鈥檚 it doing?

Jeffrey Leigh-Jones:听 Exactly, yeah, exactly.

Jai Singh:听 What鈥檚 it doing?听 It鈥檚 just in bricks and mortar and you know, it鈥檚 just rubbish.

Jeffrey Leigh-Jones:听 I fully agree, bro.

The programme gave a fair and accurate reflection of how clients initially responded to proposals to invest in Lighthouse.听 Their subsequent concerns about the undue pressure to which they say they were subjected were clearly attributed and presented in their own words, allowing the audience to judge what they said accordingly.听

Our research indicates the behaviour described in the programme would be regarded as wholly inappropriate by most reputable coaching organisations.听 The Association for Coaching鈥檚 says 鈥淢embers will not exploit a client or seek to gain any inappropriate financial or non-financial advantage from the relationship鈥�.听 The programme-makers spoke to people involved in the coaching profession who confirmed it would be considered unethical to offer financial advice or encourage clients to take out loans or credit to pay for sessions.

The programme-makers were also entitled to take account of evidence presented to the High Court in 2023 by the Department for Business, Energy and Industrial Strategy.听 It investigated the financial affairs of Lighthouse after noting none of the accounts it filed between 2013 and 2022 recorded any assets, liabilities or income, even though the Department identified money passing through two Lighthouse bank accounts.听 The formal petition to wind up Lighthouse in the public interest showed it had paid no payments to HRMC or any VAT but noted nearly all of the money coming into the organisation was paid out to Lighthouse members:

The Investigator has obtained statements for the period 29 August 2014 to 3 July 2022. 听Since 29 August 2014, on LIG鈥檚[1] main bank account, there are over 11,500 transactions with payments received totalling 拢2,462,122.66 and payments out totalling 拢2,460,395.80. 听Mr Waugh is the largest recipient and, of the 拢2,462,122.66 paid into its main bank account, 拢1,268,497.04 has been paid to Mr Waugh (which represents 51.5% of all income and 51.6% of all outgoings).

The Department of Business Petition also included evidence Lighthouse clients had been pressurised into paying money to the organisation.听 It said, for example:

58. The Petitioner considers LIG has made misrepresentations to clients to induce them into making payments and has pressurised clients into making payments.

And

64.听 Some clients state they have been manipulated during their time with LIG by LIG鈥檚 personnel into entering financial transactions to their detriment after receiving advice or guidance from LIG personnel.

65.听 Client1 was told by Jai Singh to apply for and max out 5 credit cards to make his investment.听 He sold his property investment after being told that property was on the way out. 听He also had taken out 0% credit cards to make payments to LIG. 听Client1 was encouraged to live off the loans and work for LIG for free.

The evidence therefore indicates the programme met the requirement for due accuracy in the way it presented claims about undue financial pressure from Lighthouse and its associates.

Some complainants said the programme failed to make it clear a number of former clients had been offered a refund of part of their investment.听 For example, 鈥渢he 大象传媒 has failed to publicise the fact that Lighthouse attempted to negotiate with multiple individuals, where merited, on finding fair ways to agree a return of money they invested, all of which were ignored鈥�.听 Complainants said this was evidence the programme gave a misleading impression of the extent to which Lighthouse pressurised people into giving money to the organisation or investing in it.听

The complaints do not set out details of any offers to return money to former members or provide evidence to show such offers were made.听 Some information has been published online however.听 The Lighthouse website has a page 鈥淒ebunking The Main Myths From The 大象传媒 Against Lighthouse鈥�.听 Myth 5 is titled 鈥淟ighthouse is financially exploitative鈥� and says:

8. 听Lighthouse cannot set a precedent for issuing undue refunds that have no merit because that would be future financial and business suicide.

9. 听However, Lighthouse has offered refunds on compassionate grounds and on a win-win basis in circumstances where that has genuinely been merited.

There is also a Lighthouse-produced which includes a section about Jeffrey Leigh-Jones which says 鈥淲hat Jeffrey clearly hasn鈥檛 told the 大象传媒 or Dawn is that his investment was offered back to him on a two year deal on compassionate grounds because of the sheer pressure he was getting from his family and from Dawn鈥�.听 It does not, however, say what terms, if any, were associated with the two-year deal or what the response was from Mr Leigh-Jones.听 It does not say if any money has actually been refunded.

This Unit has not seen any evidence money invested in Lighthouse has been refunded to former clients who have alleged they were pressured into making significant payments to the organisation.听 Copies of text messages exchanged between a former client and a senior member of Lighthouse, Chris Nash, were presented to the Independent Press Standards Organisation as part of Lighthouse鈥檚 about an article published in the in April 2022.听 These appear to indicate there were conditions attached to an offer of a refund.听 Other text messages involving Jeffrey Leigh-Jones, some of which were included in the podcast, suggest no refund has been made and appear to indicate Mr Leigh-Jones was told 鈥渢he more you get in the way and create havoc and controversy the more you will be breaking down the chance of any return on your investment. 听Go away鈥� Wait for two years鈥� we could easily just shut down because people like you are interfering with us鈥�.

A tweet posted by Paul Waugh on 31 March 2023, days before the programme was broadcast said:

What really gets up the noses of the Lighthouse refund desperados is that 1. They will never close us down EVER!听 We are expanding globally and rapidly!听 2. They will NEVER get a refund EVER and they KNOW it!!听 Instead they will boil in their own evil as the value at Lighthouse grows exponentially!

Furthermore, even if the offer of a refund was genuine or had resulted in money being returned, it would not negate the fact numerous former clients have claimed they were subject to undue pressure to hand money over to Lighthouse while they were involved with the organisation.听 The programme was entitled to report this.

This aspect of complaint is not upheld.

听

1. 2. It was inaccurate to say a Lighthouse mentor forced a client, Anthony Church, to come off his medication.

Anthony Church was introduced in the programme as someone who joined Lighthouse after years of struggling with anxiety, issues around self-confidence and a lack of self-worth.听 He explained he had a breakdown and attempted to take his own life before he became involved with Lighthouse.听 He said he had been prescribed two different types of medication to manage mental health issues including anxiety and depression.听

The programme made it clear Mr Church considered his initial experience with Lighthouse was of genuine benefit to him.听 It said he described his mentor, Jai Singh, as 鈥減atient and encouraging and said he wanted him to get his life back on track after everything he鈥檇 been through鈥�.听 Mr Church said he felt as though the sessions he had with Mr Singh were positive and initially helped him to feel more motivated.听

The programme went on to explain how after some months Mr Singh consistently encouraged Mr Church to reduce the dosage of his medication.听 The programme presented evidence of Mr Singh鈥檚 efforts to encourage Mr Church to limit, and then stop, taking his medication, including telling him how to prepare for conversations with his specialist to achieve that aim.听 The programme illustrated the kind of advice and instruction given by Mr Singh.听 For example:

Jai Singh:听 I know you鈥檙e having a few of these headaches and withdrawal symptoms and stuff like that.听 It鈥檚 just you are, you鈥檙e willing to suffer.

Anthony Church:听 That鈥檚 right. Yeah.

Jai Singh: 听But you鈥檝e got to ride those things.听 You know we have worked with a lot of people helping them off medication.听 So if we have a few days where we struggle because of that, that鈥檚 fine.听 It鈥檚 part of the process.听 Yeah.听 I鈥檇 rather have a few days of a dip and you come out of it stronger and healthier than be on medication that may numb you or make you feel tired or just, not have you working on all cylinders.

The evidence shows Mr Singh offered medical advice to Mr Church under the guise of coaching and mentoring.听 Mr Singh told Mr Church he was not a medical professional听 but he also told Mr Church to be 鈥減ositively sceptical鈥� of advice offered by qualified medics and cited previous experience he said he had of helping people to stop taking prescribed medication.听 This Unit has seen no evidence to indicate Mr Singh has any medical qualifications or any relevant expertise to suggest amendments to a person鈥檚 medication.听 The programme asked the head of professional standards at the British Association for Counselling and Psychotherapy to listen to several hours of the calls between Mr Church and Mr Singh.听 She told the programme:

We cannot identify any recognisable therapeutic model being used in these calls and would not describe what Jai is providing as 鈥榩rofessional counselling and mentoring鈥�.听 If one of our members engaged in such conduct in the context of a therapeutic relationship, we would investigate under our Professional Conduct Procedure.

The available evidence therefore supports the manner in which the programme presented the relationship between Mr Church and Mr Singh, and the nature of the intervention by Mr Singh in relation to Mr Church鈥檚 medication.听

This aspect of complaint is not upheld.

听

1. 3. It was inaccurate to say Jai Singh was 鈥渒ept in bondage鈥� by Paul Waugh for five or six years.

The programme made frequent reference to Jai Singh and included examples of his interactions with clients such as Jeffrey Leigh-Jones, Anthony Church and Erin.听 It included a sequence which was intended to show how he had changed during his time with Lighthouse and how this change had been influenced by his relationship with Paul Waugh.听

The programme included extracts from a telephone call between Mr Waugh, Mr Singh and Erin in which Mr Waugh and Mr Singh explained how the latter had changed over time.听 The television documentary described this as 鈥渢he process Jai鈥檚 been through to become who he is today鈥�.听 It included the following extract from the call:

Jai Singh: 听I couldn鈥檛 be trusted because of my negativity.听 I was pouring it into meetings, I was pouring it on the guys, the clients and so Paulie helped me and I was with a senior at all times.听 If I wasn鈥檛, I was by myself and my text messages were checked to, to people because I wasn鈥檛 aware of how much manipulation and toxicity there was there in seemingly positive things.听 And yeah, Paulie couldn鈥檛 trust me, I couldn鈥檛 trust myself.听 And so he helped me go back to square one really and rebuild, and kept me here and loved me through it. I was like that, I was 25, 26, 27.听 I appreciate those times now as hard as they were.

The audience would have understood they were hearing Mr Singh explain in his own words how Paul Waugh helped him deal with his 鈥渘别驳补迟颈惫颈迟测鈥� and to 鈥済o back to square one really and rebuild鈥�.听 The programme gave an accurate summary of the role Mr Singh believes Mr Waugh played in his development and the positive outcome which he says emerged.听

The evidence does not support the claim the programme implied Mr Singh was 鈥渒ept in bondage鈥�.听 It was clear Mr Singh engaged in the process willingly and of his own choice.听

This aspect of complaint is not upheld.

听

1. 4. The programme gave the misleading impression Simon Perreira was controlled and coerced by Lighthouse and senior associates.

The programme included contributions from Simon Perreira in which he set out, in his own words, his experience of being involved with Lighthouse.听 He explained he was mentored by Tom Hasker and he initially considered his relationship with Mr Hasker to be positive.听 He said, for example, 鈥淚 think it really helped me to be seen and heard.听 I felt here was someone I could share my experience with and my aspirations for the future鈥�.

He went on to explain how Mr Hasker moved into his rented flat and, in the podcast, he described how in hindsight he considered 鈥渢hat was kind of just one aspect of how Lighthouse tried to control kind of their, their members鈥�.听 Mr Perreira went on to explain how he ultimately decided to leave his own flat without giving his mentor any notice.听 He did so because he believed he was becoming isolated from many of the people who were important to him and felt he was being controlled by Lighthouse.听

The allegations made by Mr Perreira were similar to those described by other people who were involved with Lighthouse and the audience would have been aware he was expressing his own personal view of his experience with the organisation.听 Mr Perreira鈥檚 claims were put to Mr Hasker by the programme-makers in writing prior to broadcast and he was invited to respond; he chose not to do so.

As set out in the response to Point 1a, and as will be set out in Point 7, the programme gave due weight to the view of those representing Lighthouse including Paul Waugh and Jai Singh.听 The podcast repeatedly said, for example, 鈥淟ighthouse says it has helped lots of people overcome the obstacles to their potential through mentoring, life-coaching, counselling and community support鈥�.听 This ensured the audience was aware Lighthouse rejected the concerns raised by the like of Mr Perreira and allowed viewers and listeners to draw their own conclusions.听

This aspect of complaint is not upheld.

听

1. 5. It was inaccurate to imply Lighthouse seeks to separate people from their families.

The programme included contributions from a number of people formerly involved with Lighthouse who said they were repeatedly told families and family members were a negative and toxic influence.听 Contributors described how they were encouraged to sever ties with family members and partners, and the reasons they were given by Lighthouse associates for doing so.听 Jeffrey Leigh-Jones, for example, said:

I used to sit on these calls and I would hear people speaking about their families endlessly, or their mothers endlessly.听 Of course all families have difficulties and Lighthouse would find them, find them in your journal or find them in your personal mentoring.听 Other people鈥檚 families were generally destructive, narcissistic, cynical, hateful, didn鈥檛 want to let their family members go and would sabotage, um their potential.听 And they would sabotage Lighthouse as a whole. 听So other people鈥檚 families were dangerous.

Erin described how she was frequently told her family upbringing and her parents were to blame for preventing her from achieving her goals:

The focus just went increasingly on, you know, a troubled childhood, facing my parents and anyone else that I was close to that, you know, might have had a negative effect on me in my earlier years.听 So really, gradually pushing ourselves to blame our parents and families for stopping us reaching our potential.

The programme included evidence from recordings and transcripts which appeared to support the perception of people like Mr Leigh-Jones and Erin that Lighthouse knowingly tried to turn people against their family members and partners.听 For example, the programme included recordings of Paul Waugh talking to Mr Leigh-Jones about his partner:

And one of my enemies is a fucking chick called Dawn I鈥檝e never met鈥� She鈥檚 toxic鈥� What is it?听 Do diamonds shoot out of her arsehole?... I know how this works. 听People like you, murder, murder, women like that, you know that.听 I can see you mashing her face and you want, and you do it, and then suddenly you realise, I see it in your eyes. I see the rage.

The programme included a recording of Paul Waugh talking to Erin about her family:

Why aren鈥檛 you taking it out on them? 听You are so fucked up.听 Let me tell you now, your parents owe you shit. 听Your parents owe you time in prison. 听They owe you to make you well. 听They owe you to invest in you.

And

You need to invest in yourself because you鈥檙e broken.听 This doesn鈥檛 come from nowhere.听 This comes from the abuse you鈥檝e got as a child.听 You come from a family of serpents and pricks and cowards.

The programme included a recording of Jai Singh talking to Jeffrey Leigh-Jones about his partner:

You may love her, but she doesn鈥檛 love you. 听Doesn鈥檛 love you. 听No matter what she says, no matter what you say. 听Come on man. 听Wake up and smell the fucking coffee, Jeffrey. 听This woman鈥檚 no good for you, she鈥檚 not who you think she is.

The audience would have understood they were hearing genuine exchanges between Lighthouse members and clients.听 These edited exchanges were representative of the kinds of discussions where the influence of families and family history was raised.听 The programme also included edited extracts from Lighthouse sessions which showed clients initially agreed their families were having a negative impact on their lives and their ability to achieve their goals.听 For example:

Jeffrey Leigh-Jones:听 I鈥檓 just tired of it, man. 听I鈥檓 tired of it. 听I want positive support around me.听 I said, I said what I didn鈥檛 want was negativity around Lighthouse.

Jai Singh:听 People get tired after they鈥檝e been punched a lot.

And

Jeffrey Leigh-Jones:听 Dawn, that woman has a heart of gold, but I just cannot connect it to my work here.

Jai Singh:听 Umm.

Jeffrey Leigh-Jones:听 And that鈥檚 a problem man.

Jai Singh:听 It hurts right?

Jeffrey Leigh-Jones:听 I just love her man and I just feel it bro you know, feeling of distrust, yeah.

Jai Singh:听 Yeah.

The audience would have judged the contributions they heard in the knowledge the people expressing concerns about Lighthouse had changed their original opinion about the negative influence of their families as a result of their experience over time.

The podcast included a specific response from Lighthouse to the claim it seeks to separate clients from their families as follows:

Lighthouse says it is the victim of a smear campaign by what it calls 鈥減redatory trolls鈥� and 鈥渢oxic鈥� relatives and partners of those who are part of the group. Lighthouse says it has helped lots of people overcome the obstacles to their potential through mentoring, life-coaching, counselling and community support.

The podcast included a clip from Paul Waugh in which he gave his perspective on the negative influence of some families:

Let me tell you now, for free, the only cults I鈥檝e met are families. 听The people that are coming out of families, these toxic groups called families.

This reflects the view expressed on Lighthouse鈥檚 which confirms it does have concerns about the role of families in the lives of some clients.听 The website says the allegations made by people in the programme are 鈥渃laims made by toxic families who have coercively controlled and abused their grown children/siblings their whole lives and are trying to actively sabotage their development鈥�.听 It goes on to state 鈥淎 malignantly toxic family will feel incredibly threatened by a member鈥檚 intention to grow and do what they can to sabotage their efforts, as is the case in those publicly smearing Lighthouse鈥�.

The programme presented an accurate summary of the concerns raised by people formerly involved with Lighthouse and an accurate portrayal of Lighthouse鈥檚 view of the negative influence of some families.

This aspect of complaint is not upheld.

听

1. 6. It was inaccurate to say Lighthouse exercises coercive control over its clients.

The programme included contributions from people formerly involved in Lighthouse who believe they were subjected to undue pressure.听 They set out, in their own words, their experience of behaviour they considered to be controlling and manipulative.听 This included, but was not limited to: pressure to hand over significant sums of money (see Point 2a); pressure to change prescribed medication (see Point 2b); pressure to sever ties with family members and partners (see Point 2e); psychological stress; and intimidation.

The audience would have understood they were hearing the personal views and perspectives of people no longer involved with Lighthouse. 听Their views were supported by recordings which appeared to verify their recollections.听 The audience听听 would have judged their contributions accordingly.

One former client, for example, described how she was subjected to psychological stress when she questioned the value of her work with Lighthouse.听 Erin told the programme 鈥淚 started to feel as though I couldn鈥檛 think anything unless my mentor said it was a healthy thing to think or a true thing to think鈥�.听 The documentary included recordings of comments made by Paul Waugh to Erin to illustrate the stress to which she says she was subjected:

Erin:听 Paul Waugh seemed obsessed with talking about sexual abuse - about how damaged I was.

听Paul Waugh:听 You need to invest in yourself because you鈥檙e broken.听 This doesn鈥檛 come from nowhere.听 This comes from the abuse you鈥檝e got as a child.听 You come from a family of serpents and pricks and cowards.

听Erin:听 Because of what had happened to me, I was a dangerous person to be around.

听Paul Waugh:听 Are you mad or narcissistic? 听Are you mad or psychopathic? 听Which one are you?

听Erin: 听They were just telling me how awful I was, how dare I, you know, question anything about Lighthouse. 听And I thought, my gosh, perhaps I am really damaged.

Paul Waugh:听 I鈥檓 telling you now. You鈥檝e got to stop doing it, it鈥檚 not, it鈥檚 not acceptable, Ok?听 Treating us as if we鈥檙e trying to do you over.听 Do you know what, do you know what your biggest fear ought to be? 听Not that we鈥檒l take money from you, that we鈥檒l actually think that you鈥檙e too unhealthy to be here.听 You鈥檙e a cynical little old witch.

Erin:听 And then they said if you leave, if you turn against us, remember we have all your secrets.

Paul Waugh:听 Every conversation you鈥檝e ever had is taped.听 Every journal you鈥檝e ever written, is stored.听 Are you helplessly so fucking stupid?

The programme presented a duly accurate summary of the concerns raised by people formerly involved with Lighthouse.

This aspect of complaint is not upheld.

听

3. The programme used private video, audio and transcripts which were obtained illegally.听 The material contained private information which was broadcast without consent.

The programme explained Lighthouse makes recordings and transcriptions of meetings attended by people involved in the organisation, as well as every coaching and mentoring session.听 Clients have a copy of these recordings because they are encouraged to listen back to the calls and to reflect on their coaching and mentoring sessions.听 The programme-makers were given copies of some of these recordings and transcripts which were stored on devices owned by former clients.听 The programme-makers have confirmed the recordings were used with the permission of those former clients.

A small number of complainants said the recordings had been stolen and/or the use of them was illegal.听 This would be a matter for the relevant authorities.听 However, this Unit has considered whether the use of the recordings and transcripts was justified in the context of the programme.听

The 大象传媒鈥檚 Editorial Guidelines say 鈥淭he 大象传媒 respects privacy and does not infringe it without good reason鈥�.听 This recognises there may be circumstances in which the public interest outweighs a legitimate expectation of privacy.听 The guidelines state 鈥�We must be able to demonstrate why an infringement of privacy is justified, and, when using the public interest to justify an infringement, consideration should be given to proportionality; the greater the intrusion, the greater the public interest required to justify it鈥�.

The nature of the recordings used in the programme, and the circumstances in which they were recorded, means those involved would, presumably, have had an expectation their contribution would not be shared beyond those involved in Lighthouse.听 In the view of this Unit, those who featured in the recordings and who did not give the programme-makers informed consent to use their contributions therefore had an expectation of privacy (in that their words may have been seen or heard by people involved in Lighthouse but not beyond).听 The Unit therefore considered whether it was warranted to infringe that expectation and whether the public interest in broadcasting the recordings outweighed the right to privacy.

As set out in the response to previous heads of complaint, there was a legitimate public interest in reporting serious allegations which had been made about Lighthouse by a significant number of former clients.听 The allegations were based on first-hand experience of working with Lighthouse and corroborated by other contributors.听 The allegations covered an extended period of time and included undue financial pressure, psychological stress, manipulation and intimidation.

The use of the recordings was, therefore, warranted in the public interest and any infringement of individual rights to privacy was justified.听

The Executive Complaints Unit also took account of the extent to which Lighthouse itself appeared to consider recordings it made to be inherently private and confidential.听 The Unit took account of evidence which could be construed as indicating Lighthouse was prepared to publish information about clients which it obtained in coaching and mentoring sessions.听 For example, a former client understood Paul Waugh to imply he would release private information about them by saying 鈥渆very conversation you鈥檝e ever had is taped.听 Every conversation, every journal you鈥檝e ever written, it鈥檚 stored鈥�.听

The evidence shows Lighthouse did publish private information about former clients prior to the 大象传媒 broadcasts, including a video which identified, by name, a client who was a victim of sexual abuse[2].听 Paul Waugh also confirmed Lighthouse has revealed information about a former client to her employers and explained in the programme why it had done so:

Because I would want to know that that鈥檚 how my people or people I work with or employees handle their problems. 听And the companies are grateful for us telling them, they, they鈥檙e glad we鈥檝e told them. 听Some people have been fired for this.

Lighthouse has subsequently published information and extracts of Lighthouse recordings in videos which would appear to indicate it believes there are situations in which it is justified to infringe an individual鈥檚 expectation of privacy.

This aspect of complaint is not upheld.

听

4. Audio recordings used in the programme were specifically chosen and edited to support a biased and prejudicial agenda.

The programme-makers investigated a range of serious allegations which had been made about Lighthouse by a significant number of former clients.听 As set out previously, there was a legitimate public interest in investigating and reporting the concerns which were raised.听 The allegations were supported by information contained in the recordings and transcripts and so there was a justification for using edited extracts to illustrate the range of significant issues identified by former Lighthouse clients.听 This Unit has reviewed relevant transcripts and is satisfied the edited versions which were included in the programme were a fair and accurate reflection of conversations and exchanges between Lighthouse associates and clients.

The audience would have understood those who featured in the programme were expressing personal views based on their own experiences.听 The programme did not state or imply every client or associate at Lighthouse would have had a similar experience to those presented in the programme.听 The programme also made it clear the former clients initially found their experience at Lighthouse to be positive and beneficial and only changed their opinion after many months of engaging with the organisation.听 For example, Jeffrey Leigh-Jones said the following about his mentor, Jai Singh:

I thought he was smart. 听He could speak well, and he was interested in, you know, the same ideas that I was interested in. 听If, if we鈥檙e talking about what makes a person successful, he鈥檇 have a lot of good things to say on that.

And in a recording of a session with his mentor he said:

I don鈥檛, I don鈥檛 feel like, um, like, I have the abilities that you do.听 Like I, I, I listen to you and, and you are so good at responding with, with wisdom, and you鈥檙e very good at being present.听 Whereas with me, I can, I can lose my focus a little bit.

The audience would have understood those featured in the programme changed their impression of Lighthouse and the impact it was having on their lives over time.听 This was clearly set out in the programme.

This aspect of complaint is not upheld.

听

5. It was inaccurate and misleading to describe Lighthouse as a 鈥渃ult鈥�.

The programme repeatedly referred to Lighthouse as a cult and reflected the view of former clients who believed it was a cult.听 Lighthouse has rejected the definition and it is 鈥渁 healthy community鈥�; it maintains the term 鈥渃ult鈥� is 鈥渁 deliberate slur being used by predatory trolls and abusively controlling family members at the heart of a constructive sabotage smear campaign against Lighthouse and cult experts whose interests are to label groups as cults鈥�.

The programme-makers justified the use of the term in relation to Lighthouse on the basis of extensive discussions with relevant experts.听 The podcast explained 鈥淲e have now spoken to ten different cult experts from the UK, US and Canada.听 This includes five PhDs, two winners of the Margaret Singer Award for cultic studies, and three accredited therapists with extensive experience working with ex-cult members鈥�.听 The documentary said:

Catrin Nye:听 Everyone you鈥檝e heard from that鈥檚 been part of Lighthouse believes it鈥檚 a cult. 听Every person we鈥檝e spoken to who鈥檚 had a family member inside Lighthouse believes it鈥檚 a cult. 听But we also wanted multiple expert opinions from specialists.

Graham Baldwin, Catalyst:听 I鈥檝e been doing this work for about 30 years now.听 We get more calls about Lighthouse than any other group in this country.

Janja Lalich, Lalich Center on Cults and Coercion:听 Lighthouse International, in my opinion, meets the criteria for a cult. 听I鈥檇 say it鈥檚 on the extreme end of the continuum.

Natalie Feinblatt, Psychologist:听 It seems to me that Lighthouse group is a cult. They monopolise their members鈥� time, energy, and are financially exploiting them.

The programme also spoke to Alexandra Stein, an expert who has written extensively about cults.听 She set out the generally accepted criteria for defining a group or community as a cult and the numerous ways in which, in her expert opinion, Lighthouse appears to meet those criteria.听 This is what she said in the documentary:

Catrin Nye:听 When did you first hear about Lighthouse?

Alexandra Stein:听 I had someone come to my practice to seek some help.听 I consider Lighthouse a very classic example of a cult. 听It fits all the criteria that I use.

Catrin Nye:听 And what is that?

Alexandra Stein:听 Firstly, the cults are started and often continue to be led by a charismatic and authoritarian leader.听 But they鈥檙e also bullies, so I kind of refer to them as charismatic bullies.听 The structure is steeply hierarchical, everything comes from the leader, but importantly, the structure is heavily isolating.听 Then you have this process of what I call brainwashing, or we could also call coercive control.听 And then the final point is that if you do this to people, you can then exploit them.听 So we see these phenomena like people selling their houses, giving all their money to somebody.听 They鈥檝e gone through this process. They didn鈥檛 do it because they were stupid.

The evidence indicates there are sufficient aspects of the way Lighthouse is run for experts to conclude the description of it as a cult was justified.听 It was, therefore, duly accurate and reasonable for the programme to use the term in relation to Lighthouse.

The programme-makers put the allegation to Lighthouse in advance of broadcast and invited it to respond.听 The programme-makers set out what they meant by the term to ensure Lighthouse had sufficient information to offer an informed response, as follows:

That the organisation monopolises people鈥檚 time and energy and is financially exploitative. 听That it has a charismatic and authoritarian leader. 听That the structure is hierarchical and isolating. 听That it uses a process of coercive control. 听That criticism of Lighthouse is not tolerated and will get you punished.

The programme-makers also put the point directly to Paul Waugh following the High Court hearing in March and included his response, as follows:

Catrin Nye:听 How do you feel, Paul, about the fact that so many people think you鈥檙e running a cult?

Paul Waugh:听 We鈥檙e not running a cult. 听Because they don鈥檛 know what a cult is.听 They don鈥檛 know.听 If you ask them what鈥檚 the difference between a cult and a community that supports people, they wouldn鈥檛 be able to tell you.

Catrin Nye:听 Why do you think so many people say it?

Paul Waugh:听 Because they鈥檙e slurring us.听 They鈥檙e smearing us, that鈥檚 exactly what they do.听 These parents are child abusers that you鈥檙e supporting.听 And you supported Jimmy Savile, you鈥�

Catrin Nye:听 Me?

Paul Waugh:听 You.

Catrin Nye:听 Ok.

Paul Waugh:听 You supported Jimmy Savile and his paedophilia.听 You gonna take that out or are you gonna keep it in?

This aspect of complaint is not upheld.

听

6. The programme had direct, negative consequences for people associated with Lighthouse.听 It caused undue stress and anxiety and led to serious health consequences for some working with or for Lighthouse.听 The programme-makers did not give due consideration to the consequences of broadcast.

The Editorial Guidelines on Harm and Offence say programme-makers should balance the right to broadcast innovative and challenging content with their responsibility to protect the vulnerable.听 In practice, this means programme-makers should consider the potential harm or distress which may be caused by the broadcast of a programme and decide whether or not this outweighs any public interest in reporting a story of significance to the audience.听

The guidelines and associated guidance set out specific considerations to ensure due care is given to contributors, potential contributors and sources who may be regarded as at risk of significant harm as a result of taking part in 大象传媒 content.听 However, these considerations do not generally extend to those who may be affected by the subject matter of a programme but who are not directly involved in its production. 听It is generally understood, for example, the reporting of certain news events, such as those involving loss of life or human suffering, can cause distress.听 This does not mean news bulletins cannot or should not report on events which some members of the audience may find distressing.听 Programme-makers are expected to weigh up the requirement to convey the reality of events against the need to avoid causing unnecessary offence or harm.

The Executive Complaints Unit is aware Lighthouse contacted the 大象传媒 in advance and asserted the lives and well-being of people it described as vulnerable would be put at risk if the programme was broadcast.听 The Unit has seen the correspondence which set out details of those said to be at risk.听 The Unit is not in a position to judge the validity of the concerns raised by Lighthouse but, as set out previously, it takes the view there was a legitimate public interest in broadcasting serious allegations made by people formerly involved with Lighthouse.听 The Unit considers this public interest outweighed any duty of care the programme-makers may have had to people who were not contributors to the programme and outweighed any potential for the programme to cause unnecessary harm or offence to people connected to Lighthouse but who were not named.听听

This aspect of complaint is not upheld.

听

7. The programme-makers only approached Lighthouse after it had completed its investigation and had decided to present Lighthouse as a cult.听 Lighthouse was not given an appropriate or timely opportunity to respond to the allegations made in the programme.听 Lighthouse contacted the 大象传媒 in September 2022 and made repeated attempts to co-operate and share evidence.听 The 大象传媒 should have offered Paul Waugh a live prime-time interview.

The 大象传媒鈥檚 Editorial Guidelines set out the requirements which must be met when a programme includes serious allegations against an organisation or individuals:

When our output contains allegations of wrongdoing, iniquity or incompetence or lays out a strong and damaging critique of an identifiable individual or organisation, those criticised should normally have a right of reply, unless there is an editorial justification to proceed without it.

They go on to say any allegations should be set out 鈥渋n sufficient detail to enable an informed response鈥� and those subject to any allegations should be given 鈥渁n appropriate and timely opportunity to respond鈥�.听 The Guidelines make it clear 鈥淎ny parts of the response relevant to the allegations broadcast should be reflected fairly and accurately and should normally be broadcast or published within or alongside the material containing the allegations鈥�.

The evidence from the extensive exchange of correspondence between the 大象传媒, Lighthouse and named individuals indicates these requirements were met.

The programme-makers received lengthy and frequent emails from a number of senior associates at Lighthouse in October 2022.听 The correspondence drew attention to numerous issues including, but not limited to:

• The complaint Lighthouse had made to the Independent Press Standards Organisation (IPSO) about an article in the Daily Mail on 19 April 2022.听 It described the article as 鈥渓颈产别濒濒辞耻蝉鈥� and 鈥減ernicious in the way that key context and background is left out to present a biased and prejudiced view against us鈥�.听 (The complaint was subsequently in full by IPSO.)

• Numerous articles on the Lighthouse website setting out its response to allegations made in the newspaper.听

• Personal details of individuals who had spoken publicly about their experience with Lighthouse.

• Allegations about such individuals which appeared to be designed to undermine their credibility.听 For example 鈥渋t鈥檚 prudent that you know that many of your sources are currently being investigated by the police for harassment and hate speech (including racist and religious hate speech) against us鈥�.

The programme-makers subsequently sent separate emails to Paul Waugh and Jai Singh on Monday 13 February 2023 in which they were informed 鈥渨e are working on an investigation into Lighthouse International Group鈥�.听 Both men were invited 鈥渢o meet with us next week for a filmed interview to answer our questions about Lighthouse鈥�.听 They were offered four dates the following week on which the interview could take place and were asked to respond by Thursday 16 February.听 Mr Waugh initially responded the same day and said 鈥淔antastic. 听Look forward to it. 听Will confirm date鈥�.听 Mr Singh sent an email on 16 February in which he said he was 鈥渧ery happy to accept in order to have an opportunity to set the record straight鈥�.

The programme-makers received no further correspondence from Mr Singh but received a series of subsequent emails from Mr Waugh in which he set out a number of conditions for agreeing to be interviewed.听 These included written permission from the programme鈥檚 sources 鈥渓egally allowing us to bring our and the relevant and appropriate evidence to the table鈥� and he also requested to be given notice of 鈥渢he questions you鈥檙e going to ask us鈥�.听 The programme-makers responded by stating 鈥淭he 大象传媒 does not send specific questions to any interviewee鈥� but explained 鈥淲ithin the interview we would provide enough information and detail about the arguments and allegations for you to understand them and give an informed response鈥�.听 Mr Waugh responded by setting further conditions.听 For example:

We would also be potentially (subject to counsel) willing to provide data protected evidence (including our recent submission of 600 pages of evidence to the courts in relation to your sources which completely refuted their accusations) for your perusal without your sources permission under the safeguards of an NDA. 听At least then you would know where you stand legally, morally and ethically even though you would not be able to use it.

The programme-makers acknowledged receipt of Mr Waugh鈥檚 emails on 24 February and sent a formal 鈥渞ight of reply鈥� letter to Mr Waugh, Mr Singh and a number of other named individuals on 6 March which noted:

We are writing to you to let you know that we are conducting an investigation into Lighthouse and expect to broadcast a documentary and podcast in the near future. This includes all associated companies, partnerships and organisations.

The letters to Mr Waugh and Mr Singh also said:

We have invited you for an interview and the deadline for that has now passed so we are sending you the below points.

The various letters set out details of specific allegations and invited the recipients to respond by 15 March.听 Members of Lighthouse sent a number of further emails setting out their criticisms of the programme-makers鈥� approach and raising concerns about the content of any programme.听 The programme-makers subsequently wrote on 20 March and extended the deadline for a formal response to 22 March.听 A further extension was offered on 27 March:

In putting these allegations to you for a third time, we want to make it absolutely clear that we welcome receiving any evidence you see fit to include in your response. We are happy to again extend the deadline to 5pm on Wednesday 29th March.听

It is clear from the extensive exchange of emails Lighthouse had no confidence the programme-makers would give fair consideration the evidence it said it wished to present and remained concerned about the manner in which the 大象传媒 had conducted the investigation.听 An email sent to the programme-makers on 23 March, for example, said:

As it stands this entire approach is almost completely unjust and if the documentary were to be broadcast without the full evidence you have available through us, you would be complicit in slander, defamation, character assassination, and smearing, along with gross misconduct and we will litigate.

The Executive Complaints Unit recognises the concerns expressed by Lighthouse but the evidence indicates it was given sufficient detail of the allegations the programme-makers intended to include in the programme.听 It was in a position to offer an informed response and was provided with an appropriate amount of time to provide such a response.听 Lighthouse was clearly aware in October 2022 of the broad allegations which had been made against it and Mr Waugh confirmed in an email of 15 March 2023 that Lighthouse had decided to prepare its own video and online responses 鈥淕iven that the 大象传媒 have chosen not to receive our damning evidence (especially the evidence that totally proves that the 大象传媒 are supporting and championing child abusive and sexually abusive families and their members in a smear campaign against us)鈥�. 听听The allegations against Lighthouse were set out in appropriate detail and the deadline for a response was extended on two separate occasions.

The Unit also took account of the interview with Paul Waugh which was recorded after the court hearing and included in the programme.听 Mr Waugh explained why he did not respond to the programme-makers鈥� request for an interview:

Catrin Nye:听 We鈥檝e sent you all of our allegations in huge detail and you鈥檝e not responded to any of them.

Paul Waugh:听 Well, that鈥檚 well, there鈥檚 a reason for that.

Catrin Nye:听 Why is that?

Paul Waugh:听 Because I want to know the context of what those things are. 听Where did that come from? 听A lot of it is just absolute nonsense.听 I am responding. 听I鈥檓 responding. 听I鈥檓 responding. 听I鈥檓 responding with our own documentaries, with our own videos. 听We鈥檙e doing it.

The evidence indicates Lighthouse was treated fairly and given a fair opportunity to respond to the allegations made about it.

This aspect of complaint is not upheld.

听

There were three separate, but related, points of fairness raised in complaints submitted to the Executive Complaints Unit.

Firstly, some complainants said Lighthouse was treated unfairly because an initial offer to engage with the programme-makers was not acted upon.听 A Lighthouse Senior Partner, Warren Vaughan, wrote to the programme-makers on 24 September 2022 and said 鈥渙ur Chairman and Founder, Paul Waugh, would relish the opportunity to sit with you and help you in your investigations鈥�.听 The programme-makers responded on 3 October 2022 to say 鈥淚t is not 大象传媒 practice to respond to enquires of this kind鈥�.听 Complainants have said this was evidence the programme-makers did not carry out their investigation in good faith and had no intention of giving Lighthouse an appropriate opportunity to explain the work it was doing or respond to allegations made about it.

This Unit recognises the concern which has been raised but, as set out above, the requirements of the Editorial Guidelines to offer an appropriate and timely right of reply were met.听 It is generally accepted journalists are entitled to gather relevant evidence and conduct a thorough investigation before presenting such evidence to the relevant people and inviting them to respond.听

This aspect of complaint is not upheld.

听

Secondly, some complainants objected to the manner in which the programme-makers interviewed members of Lighthouse, including Paul Waugh, after the High Court hearing which resulted in Lighthouse being wound up in the public interest.听

As explained previously, the requirement of the Editorial Guidelines is to ensure those facing allegations are given an appropriate and timely right of reply.听 In circumstances where the subject has refused to be interviewed or failed to respond to requests for an interview, section 7.3.36 of the Guidelines says interviews such as the one conducted outside the High Court are permissible, so long as they are proportionate and in the public interest.

The evidence from the recording indicates Mr Waugh was invited to answer questions and did so willingly.听 Mr Waugh and Lighthouse were clearly aware of the 大象传媒 investigation and the allegations it had put to Lighthouse and so he would not have been taken unawares by the questions put to him.听 He responded to allegations in his own words and his comments were included in the programme (see, for example, Point 5 above).听 Members of Lighthouse were also filming for their own purposes and so there was no sense in which filming by the 大象传媒 can be regarded as an unwarranted infringement of privacy.

This aspect of complaint is not upheld.

听

Thirdly, some complainants said Paul Waugh should have been offered the opportunity to take part in a live broadcast interview.听 Mr Waugh and Lighthouse were given an appropriate opportunity to take part in a pre-recorded interview for inclusion in the programme.听 They declined to do so unless specific conditions were in place.听 For example, Mr Waugh (Myth 1, Point 4) he would 鈥減rovide material evidence to prove Lighthouse鈥檚 innocence鈥� if the 大象传媒 agreed to sign a non-disclosure agreement.听 The programme-makers declined to sign an NDA and explained the reason why in the podcast: 鈥淧aul Waugh says the evidence he has to disprove them all [allegations made in the programme] is data protected. 听He then says he鈥檒l send it to us if we sign a non-disclosure agreement, although that would mean we wouldn鈥檛 be able to report on it anyway鈥�. 听

There was no requirement to offer a live interview.听 Lighthouse was given an appropriate right of reply and the programme included its response to the significant allegations made against it.

This aspect of complaint is not upheld.

Not Upheld

听

[1] Lighthouse International Group

[2] See Timecode 1.00