MR MATTHEW RALPHS

Disqualified from

2020-11-23

Date of birth on record

November 1982

Between 22 March 2016 to 28 April 2020 Matthew Sheldon Ralphs (Mr Ralphs) caused or allowed Safety Guide Limited (SG) to trade with a lack of commercial probity by making misrepresentations to customers in order to induce them to make payments to SG in respect of advertising in its magazines, without providing any discernible benefit to those customers, in that: • SG made unsolicited calls to customers purporting to be working in partnership with schools as a non-profit organisation rather than making it clear that SG was a profit-making business. • SG misled sponsors into believing that Safety operates as a charity/not for profit organisation. • SG used oppressive and objectionable sales techniques to coerce customers into placing orders. • SG used oppressive and objectionable techniques to pressurise customers into making payments. • SG failed to print magazines of a suitable standard or educational value and failed to distribute the magazines adequately, or at all. • Between 22 March 2016 and 28 April 2020, SG’s bank statements record receipts of £2,502,482 and payments of at least £866,155 to Mr Ralphs. Matthew Sheldon Ralphs (“Mr Ralphs”) failed to ensure that Safety Guide Limited (“SG”) maintained adequate accounting records from 27 September 2016 to 28 April 2020 or alternatively if such records were maintained he failed to preserve and/or deliver up such records to the Official Receiver. The absence and/or failure to deliver up the accounting records has had the following consequences: • The inability to establish the true level of sales by SG. There is a significant unexplained discrepancy between the amount of sales recorded in the filed accounts and trial balances of SG of £1,381,613, the sales receipts in SG’s bank accounts of £2,502,482 and the sales spreadsheets held by SG. • The inability to establish the financial position of SG. There are 17,570 sales invoices that appear to be missing from the schedule of sales invoices produced by SG, which records sales of £1,381,613 in the period 27 September 2016 to 28 February 2019, whilst receipts in to SG’s bank account for the same period total £2,502,482. • The inability to identify the nature and purpose of the SG’s banking transactions including receipts that continued to be credited to SG’s bank account from March 2019 (£479,608). • The inability to establish the true extent of payments made by SG to or for the benefit of Mr Ralphs and others. The director’s current account entries in SG’s records cannot be reconciled with the payments made to Mr Ralphs from SG’s bank accounts, showing a discrepancy of £269,917. • The inability to identify payments made to SG’s employees and self-employed sub-contractors. There are no invoices to support the expenditure of £941,573 for subcontract labour charges shown in the filed accounts and trial balances of SG. • The inability to determine whether SG has properly accounted to HMRC for PAYE income tax and national insurance contributions. In particular, commission/bonuses totalling £926,087 were paid to employees but were not included in the PAYE records and SG does not appear to have correctly charged VAT on certain invoices.