Executive Summary
- The Meeting: Gareth Penn and Collette Osborne lobbied Treasury Financial Secretary on 21 March 2024
- The False Claim: Told ministers apprenticeships were in "severe decline" - contradicted by official data showing strong growth
- The Agenda: Lobbied for mandatory registration and lower VAT threshold - policies that would expand their commercial operations
- The Concealment: Failed to disclose that Penn operates insolvent Good Salon Guide and Osborne sells insurance/business services
The Meeting
On 21 March 2024, Gareth Penn (H&BC Registrar) and Collette Osborne (H&BC Vice Chair) secured a meeting with Nigel Huddleston MP, the Financial Secretary to the Treasury - one of the most senior tax officials in the UK government.
The meeting was arranged following lobbying about Autumn Statement 2023 tax changes. They came prepared with a specific agenda: convince Treasury that the hair and beauty sector faced a crisis requiring government intervention.
FOI Document Reference
Request: FOI2024/06014 and FOI2024/07188
Date: Meeting held 21 March 2024, documents released April-May 2024
Contents: Meeting notes (readout) and ministerial briefing document
The False Claims
What They Told Ministers
The briefing document prepared for the minister reinforced this narrative, stating the H&BC's concerns included:
- "Pressures from increases to the National Minimum Wage"
- Impact on ability to take on apprentices
- "Long-term risks to the skills base"
This was demonstrably false.
What the Data Actually Showed
At the time of the meeting (March 2024), official Department for Education statistics already showed:
| Academic Year | England Starts | Change | Status |
|---|---|---|---|
| 2021/22 | 5,530 | — | Baseline |
| 2022/23 | 6,340 | +810 (+14.6%) | Growth |
| 2023/24 | 7,350 | +1,010 (+15.9%) | Strong Growth |
What H&BC Told Treasury
"Severe decline in the number of hairdressers able to take on apprentices"
Source: Treasury Meeting Notes
What Official Data Showed
Two consecutive years of double-digit growth. Scotland more than doubled apprenticeship starts.
Source: Department for Education, Skills Development Scotland
Critical Finding
Penn and Osborne made objectively false claims about apprenticeships to Treasury ministers. The data contradicting their narrative was already publicly available when they made these statements.
The Undisclosed Conflicts of Interest
The Treasury briefing document identified Penn and Osborne's H&BC roles but included biographical information that significantly understated their commercial interests:
Collette Osborne: "Vice-Chair of the Hair Council, and is the founder of Salons Owners United, a group that helps salon owners across the UK to coordinate and share resources."
What the Briefing Didn't Disclose
Undisclosed Commercial Interests
- Gareth Penn's Good Salon Guide: Insolvent company with £127,000 deficiency, relies on H&BC referrals, would benefit from mandatory registration
- Collette Osborne's Salon Owners United: Sells insurance products, business services, training courses - positioned as "solutions" to sector "crisis"
- Insurance Partnership: H&BC and Osborne collaborate on insurance forms requiring H&BC registration to access products
- Phorest Funding: Software company funds BHC crisis reports, benefits from fear-driven "modernisation" narrative
Neither Penn nor Osborne disclosed that the policies they were lobbying for - mandatory registration and increased compliance pressure - would directly benefit their commercial operations.
The Lobbying Agenda
The meeting notes reveal a carefully coordinated lobbying strategy with three primary objectives:
1. Mandatory Registration
Who benefits: Mandatory registration would force all salon businesses to join H&BC's register, expanding revenues and creating captive market for Penn's Good Salon Guide and Osborne's services.
2. VAT Threshold Reduction
Who benefits: Lower threshold forces more businesses above VAT registration, making them "legitimate" customers for H&BC services and Osborne's compliance-focused business offerings.
3. Insurance Industry Coordination
Who benefits: This directly references the H&BC/Sentio insurance form scheme requiring H&BC registration to access insurance - a product Osborne sells through Salon Owners United.
Pattern of Deception
The Treasury meeting fits a broader pattern of manufactured crises used to justify commercial expansion:
Social Media Claims
BHC posts "Apprenticeships in the industry have collapsed. From 16,000 to under 5,000" - cherry-picking peak year vs trough while ignoring recovery
Parliamentary Report
BHC tells Parliament apprenticeships "set to reach zero by 2027" - extreme extrapolation contradicted by two years of growth data
Treasury Lobbying
Penn/Osborne claim "severe decline" in apprenticeships to Treasury ministers - false at time of meeting
Commercial Exploitation
H&BC register, Good Salon Guide, SOU services, insurance partnerships all positioned as "solutions" to manufactured problems
Why This Matters
1. Misleading Treasury Ministers
Making false claims to government ministers about sector conditions is not legitimate advocacy - it's systematic deception designed to secure favorable policy outcomes that serve commercial interests.
2. Concealing Financial Motivations
The Treasury briefing document presented Penn and Osborne as independent sector representatives. It failed to disclose that:
- Penn's company is insolvent and relies on H&BC referrals
- Osborne sells insurance and services positioned as crisis solutions
- Both benefit directly from policies they lobbied for
- Their organisations coordinate commercially (insurance forms, BHC reports)
3. Wasting Government Resources
Treasury officials prepared briefing documents, ministers allocated meeting time, and departments followed up on issues raised - all based on false premises designed to serve lobby group commercial interests.
4. Undermining Policy Development
When policymakers receive false data from organisations claiming to represent sector interests, it distorts the evidence base for decision-making and potentially leads to harmful interventions.
Legal Implications
Making false representations to secure favorable treatment or policy outcomes potentially engages:
- Fraud by false representation (Fraud Act 2006 s2)
- Abuse of position (Fraud Act 2006 s4)
- Misleading Parliament (if similar claims made under oath or in formal submissions)
Treasury's Response
To their credit, Treasury officials appear to have been appropriately cautious about the claims. The meeting notes record:
Importantly, Treasury's subsequent FOI response noted:
No Further Meetings Planned
"A search of relevant officials' and Ministers' future engagements in the next three months did not reveal any upcoming meetings or planned engagements between HM Treasury and organisations representing the Hair and Beauty Industry/Personal Care sector."
Treasury also clarified that Department for Business and Trade leads the government's relationship with this sector - suggesting they may have been skeptical of the claims.
What Should Have Been Disclosed
Proper disclosure in a ministerial briefing would have included:
| Individual | H&BC Role | Should Have Disclosed |
|---|---|---|
| Gareth Penn | Registrar |
|
| Collette Osborne | Vice Chair |
|
The Evidence Trail
The FOI documents are part of a larger evidence package showing systematic fraud:
Connected Evidence
- H&BC/Sentio Insurance Form: Creates false requirement for H&BC registration to access insurance products
- BHC/CBI Report (Feb 2025): Phorest-funded crisis report with false claims to Parliament
- Penn Refusal Letter: Admits treating statutory body as commercial property, refuses transparency
- The Good Hairdressing Guide Limited t/a Good Salon Guide Insolvency: Companies House records show £48k deficiency
- "One Voice" Instagram Post: Shows BHC coordination between supposedly independent bodies
Conclusion
The Treasury meeting documents reveal a sophisticated lobbying operation built on false data and concealed conflicts of interest.
Penn and Osborne told Treasury ministers that apprenticeships were in "severe decline" when official data showed strong growth. They lobbied for mandatory registration and lower VAT thresholds - policies that would directly benefit their commercial operations - without disclosing those financial interests.
This isn't legitimate industry advocacy. It's systematic deception designed to secure government intervention that serves private commercial interests at public expense.
When lobby groups make false claims to ministers while concealing commercial motivations, it corrupts the policy-making process and potentially constitutes criminal fraud.
Source Documents
All documents available for independent verification:
- FOI2024/06014 - Treasury Meeting Notes, 21 March 2024
- FOI2024/07188 - Treasury Ministerial Briefing Document
- Department for Education - Apprenticeship Statistics (FOI Response)
- Skills Development Scotland - Modern Apprenticeships 2020-2024
- BHC Parliamentary Report - February 2025
- H&BC/Sentio Insurance Form
Full source archive: data.salonlogicpro.co.uk/sources/
Every claim in this article can be verified against official government documents. Challenge our analysis: analysis@salonlogicpro.co.uk