Campbell v Charity Commission: the First-tier Tribunal overturns a five-year trustee disqualification order

On 1 October 2026, the First-tier Tribunal overturned the Charity Commission's five-year disqualification of Naomi Campbell as a charity trustee. The decision, concerning Fashion for Relief, demonstrates that whilst trustees each bare ultimate responsibility for complying with core governance requirements, an assessment of the conduct of individual trustees will also be an important consideration.

Campbell’s role focused on fundraising and raising the charity’s profile, while fellow trustee Bianka Hellmich assumed responsibility for its financial, legal and regulatory functions. The Tribunal found that the most serious misconduct, including unauthorised payments and misuse of funds, resulted from Hellmich’s conduct and had been concealed from Campbell. The deception involved forged documents and a false email address used to impersonate her.

The Commission had made their disqualification order under section 181A of the Charities Act 2011 and relied on Condition D which provides that the person had been a charity trustee at the time there was misconduct and/or mismanagement in the administration of the charity and:

• the person was responsible for the misconduct or mismanagement; or
• knew of the misconduct or mismanagement and failed to take any reasonable steps to oppose it; or
• contributed to or facilitated the misconduct or mismanagement.

The Tribunal found that Campbell met Condition D(a) above in respect of the failures to keep proper minutes and file accounts on time. It was considered that these acts were the responsibility of all trustees including Campbell. Whilst these failings satisfied the relevant statutory condition, the Tribunal found that they did not, in the particular circumstances, establish that Campbell was unfit to act as a trustee.

The Tribunal emphasised the benevolent approach taken towards charity trustees where there is no dishonesty or wilful misconduct. Campbell’s response when concerns emerged, including pressing for independent professional advice, was considered reasonable.

The decision is a reminder that where Trustees allocate specific responsibilities among themselves, that does not remove shared accountability for core governance requirements.