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Who on earth do you think you are?

A long overdue focus on what the ACI and CMC have brought to the UK CBD industry

Ladies, Gentlemen, distinguish colleagues, and anyone who's decided that my words are worth a few minutes of their time, I'm about to do something that I would ordinarily advise against, and that is to focus on someone who could be deemed as my competition.

The ACI have recently taken it upon themselves to assume a level of authority in the CBD industry, however, the vast majority of the industry players I have talked to have concerns that the ACI are overstepping their market influence, and are engaging in anti-competitive behaviour.

After listening to these concerns, I have spent the last 7 days pouring over the ACI's Milestone page, and you might be interested in what I've found. I'm about to show you that it seems the ACI may have been doing that from the point of their inception, as did their founders the CMC before them.

Let's start from the start!

The CMC was founded on 11/06/2018, and claim that it was set up on the back of a successful campaign to legalise medicinal cannabis.

I notice that they don't mention the campaigns from families with epileptic children who drew attention to the legalisation of medicinal cannabis, and considering that we are nearly four years on and there are still only 3 or 4 NHS prescriptions for medicinal cannabis products, I find myself asking why they thought that battle had been won when all that really happened was that a piece of paper was signed. False hope was sown until the first medical cannabis clinics were set up. After that, false hope became broken bank accounts due to the still ongoing lack of NHS access.

The women who campaigned for medicinal cannabis are still campaigning for that access, and are in fact very active within the legal cannabis industry. Why would that be the case if they had got what they wanted back in 2018?

Looking back through time, I can only actually find one article where the CMC are quoted on the day that medicinal cannabis was legalised in the UK (01/11/2019), but I can't see them named as active in that campaign.

I wonder if those women would agree with me, in that access to legalised medicinal cannabis wasn't a totally successful campaign, but it certainly opened doors. From my perspective though, as the founder of The Hemp Hound Agency, if I had helped those women out to the point of where medicinal cannabis is now, I would be very hesitant to label it a successful campaign, especially when there are so many people who have to pay through the nose to manage their conditions.

Anyway, back on track!

Now just so we're on the same page, I am reminiscing of my time in the CBD world vs the ACI's Milestone page, which you can find here... I don't want to be sued after all!

January 2019 - the EFSA deem all cannabinoids as Novel Foods

They fail to mention that the EU hemp industry as a whole was invited to Brussels in March of that year to provide an argument as to why CBD products shouldn't be defined as Novel.

It's funny how some entities seem to gloss over this, there's even one validated company whose founder stated that the whole industry was told what was happening in January 2019 and that there's no excuse for companies who haven't provided enough information for a successful application.

Does this highlight the potential of two separate discussions around CBD though, where those who build the industry were led to believe that there was still a chance to fight against Novel Foods? I mean, you don't invite industry stakeholders to a meeting if the doors already closed, right?

The idea of two separate conversations is purely hypothetical, however there are a few indicators outlined below to that being the case, and considering the ACI/CMC maintained a stance that was completely against the vast majority of the UK CBD industry at the time, it's probable that they were part of those discussions... if they happened, of course!

June 2019 - CMC released their ground-breaking market research and policy report “CBD in the UK

I remember this report as it caused a stir. At the time, the CMC were telling its members that 280mg of CBD a day was OK for supplemental use, despite there being an industry agreement between another Trade Associate and MHRA that it was 200mg. To me, it was like someone asking for more rules, whilst breaking unwritten ones at the same time.

Here's an exert from that report - I would like to re-draw your attention to the Centre for Medicinal Cannabis (CMC) by name, and ask whether this is geared up for CBD companies, or medicinal cannabis focused companies?

Then there are the test results that are quoted on pages 4 and 5 in the report - with no disrespect to PhytoVista Labs, who are an excellent company, they weren't an independent lab at the time, and surely two or three labs testing the same products to make sure there's no calibration issues would have been more appropriate?

Just so we're clear though, I'm not in anyway saying that there wasn't teething problems for the CBD industry in 2019, but it's obvious to me at least that the CMC were coming at this not so much as a food product issue, but more in the medicinal context which you would expect from an 'association' with medicinal cannabis in the name.

July 2019 - Committee On Toxicology (COT) scoping paper on the potential adverse effects of CBD products

Forgive me, there's no distinction on this timeline. I can't tell if that's an industry milestone or a milestone for the CMC, which would be improper if it 'were' the case. It's bad enough that there's unconfirmed industry whispers of someone attending those COT meetings with undisclosed interests to GW/Jazz Pharma, the thought of a CMC insider in there as well REALLY puts a knot in my stomach!

August 2019 - The CMC launches “Quality Charter” to put CBD industry on path to legal compliance, and announces partnership with the leading life-sciences regulatory services consultancy, Global Regulatory Services

Ok, at this point there were 2 key UK CBD focused associations, the CTA and Canna-Pro. There was of course the British Hemp Association (BHA), but they were a bit more broad in their focus. The latter (Canna-Pro) was newly formed, however the former (CTA) had already been championing compliance in the industry for at least 3 years by this point.

It's also worth noting that the founder of Canna-Pro was also a founding member of the CTA, and despite them going their separate ways in 2018, the vision for a sensible Hemp & CBD industry from both entities was pretty much the same. The CMC however, their opinion and direction in comparison to those who had been about longer than the five seconds they had, was 'interesting'...

Let's take a back step for a second, shall we? I've never seen the CMC with more than two dozen members at most. The other associations each had members in the hundreds, so I'll ask you one question. Who thought that the CMC 'spoke for the industry', let alone to the point where it could help put the industry on a path to compliance that to the best part, was being observed due to the advice from the existing associations at the time?

October 2019 - The CMC outline plans to undertake a comprehensive review of analytical testing for the UK cannabis industry, and they announce the formation of the Association for the Cannabinoid Industry (ACI).

This is another month I remember well - just before the ACI was announced, I had made a bit of a noise in regards to the CMC representing CBD food supplement manufacturers and listing them as members. It's the old 'medicinal vs supplemental' issue that the MHRA were pretty hot on back then, and I seem to remember writing an industry article at that time to raise that very issue. Then, just like that, the ACI was 'in formation'.

Ok, I'll be honest in that I did wonder if I had anything to do with that, but I probably didn't. That being said, this entry is the last time that the CMC are mentioned in a primary sense in the ACI milestones.

It's interesting that the CMC drew attention to analytical testing, this is an association who used one lab to paint a damning picture of an industry after all. It's also interesting because in the here and now, we're waiting for the Home Office (HO) to release guidance on appropriate testing methods halfway through the CBD Novel Foods application process. Any updates for that, as well as controlled cannabinoid levels, has the potential to be very disruptive to what has already been a painfully Novel journey.

85 days before the FSA announces key industry updates - I feel that this is worth mentioning, it always strikes me as suspicious when a company or organisation forms just before key industry dates, it's like they know something, or were part of a separate conversation...

The article is a joke, and I mean that politely. How can you say that there was a lack of consumer confidence if the market was effectively doubling in value on a year by year basis?

Then there's the 'fresh market data', that was provided by the CMC for 'their' launch of the ACI. I'm pretty certain there were a few grumbles about that when it was realised, if anything, it suggested that the ACI were more of a mouthpiece for the CMC, rather than a trade association for CBD product manufacturers it is supposed to be.

I would go as far to suggest that the ACI are just a repackaged, CMC lite! Kind of like Tony Blair's New Labour was the alternative Tory Party of the late 90's.

My tie is red, but my pants are blue...

But if I'm wrong, how does an association get the ear of the FSA within 85 days?

Does anyone else view that as abnormal? I feel that there's a mathematical equation waiting to be developed...

I think the two key components missing from this are the crossover members of the CMC and ACI, and the aggressive marketing campaigns that followed their inception.

That doesn't explain how the ACI rapidly gained the FSA's ear though, the only thing that would explain this would be the CMC forging a relationship with the FSA, before the FSA even knew what they were doing, and then they 'transferred' that relationship over to 'themselves', but wearing different clothes... You're still with me, right?

Apparently, it's that simple. In fact, some ACI workers double up for the CMC. One wonders how closely their ACI and CMC caps sit together on that hat stand...

December 2019 - The ACI commences Novels Foods applications for our members

For me, this was when the 'aggressive marketing' of the ACI became apparent. On some days I was getting 5 or 6 companies showing me emails that amounted to 'join us or die'. The strange, or stupid thing dependant on how you look at it, was that 90% of the companies contacted were in no way able to afford the ACI membership fees.

I suspect that the ACI knew this, and I suspect that the emails came with other intentions, rather than to boost their own membership quota. There are a hell of a lot of companies that have disappeared as a result of the uncertainty sowed during the run up to Novel Foods, that wasn't in anyway helped by the ACI's tactics and emails.

This milestone comes 30 days after the launch of the ACI, think about that for a second. How could a fresh faced entity get to a point like that in one month? most of us didn't even know what the definition of a new product was in 2019! Extract, product, white labelled... everyone was pretty much in the dark until mid-2020 when The Canna-Consultants came to the rescue and managed to get the FSA to make a distinction.

It's brave, isn't it? Applying for something that you don't know how to apply for, unless you knew the dynamics before everyone else, but then the industry as a whole didn't even find out that we were to follow requirements from 16 GW/Jazz Pharmaceutical lab reports until 13/02/2020, which was a good two months away from here...

It's also worth mentioning that at this point, the rest of the industry was still fighting against Novel Foods, and for the validity of whole-plant products. Isolate or narrow spectrum products, yes they are indeed 'Novel'. Nano-particle products, absolutely, and don't even get me started on Synthetic products! Those that are reflective of their source ingredients such as whole-plant products, are not 'Novel'. You can say that it is on a bit of paper, but all I'm reading is that 'someone' is trying to restrict companies as well as their products.

The CMC and ACI have always been against whole-plant products, their opinions of controlled cannabinoid levels, which are yet to come, pretty much verifies that.

February 2020 - Committee On Toxicology (COT) release CBD update report, and The Foods Standards Agency (FSA) provides clear regulatory guidance for the UK CBD industry

Remember when I said that the CMC were going against the 200mg RDA for CBD 'industry agreement', how unsurprised do you think I was when the ACI publicly endorsed the FSA guidance for 70mg as the RDA?

It's worth noting that approximately one year before this, the World Health Organisation (WHO) had suggested that 2,400mg a day was fine, and they even went as far as to say they believed hemp products with less than 0.2% THC should be de-scheduled. The COT however, dismissed all of the evidence used to make the WHO recommendations in favour of those previously mentioned 16 lab reports from GW/Jazz Pharmaceuticals.

This was the month that kept on giving: FSA accepted the COT recommendations and announced the 70mg RDA on 13/02/2020, which was roughly the same time as Trading Standards (TS) were going to most UK CBD stockists to buy, and create an inventory of products which were available before that date. Then at the Hemp & CBD Expo at the NEC (29/02/2020 - 01/03/2020), the FSA announced they were making that product list with the help of TS, and that there were two deadlines for the industry to observe.

And they were ridged

So, really quickly. 13/02/2020 - if you had no products on the shelves before then, you would not be invited to an 'industry amnesty', and would have to go through the entire Novel Foods process. This meant that if you chose to submit a Novel Foods application for a product created after this date, it would not be allowed for sale until the product is authorised, which can take longer than 18 months.

31/03/2021 - All products that were available before 13/02/2020 needed an application tied to them and submitted by this date, any later and you would again be subject to the entire Novel Foods process.

So how did the ACI react to the month of bombshells?

I've seen announcements that have be applauded, embraced, or flatly rejected. But never have I seen anyone do what the ACI did after the 70mg RDA announcement, which they were almost too ready for.

I said 'endorsed' earlier, it's probably more appropriate to say that they rolled over for a belly scratch, in the same way as a pet dog. Remember, as the CMC they advocated 280mg as an RDA, to embrace 70mg barely seconds after that FSA update... That to me was questionable, but not surprising.

I want you to consider something, a thought I had after seeing the ACI reply to the FSA. Could it be considered in anyway, at least up until this point, that the ACI/CMC 'raison d'etre' was to be disruptive in the industry? Bare that in mind as you read further!

March 2020 - The ACI launches it’s CBD safety certification initiative, and a YouGov poll was commissioned by The ACI that demonstrates overwhelming support for recent FSA guidance concerning CBD

Please note - the ACI milestone page provided a link to their press release about the 'findings' of their poll, however I have changed this so that the link goes direct to the poll itself.

So the safety certification initiative really was a crock, which might be the reason as to why there's no active link for it on their Milestone page.! There is a simple reason beyond that though, any company worth their salt would have a full suite of lab reports to cover every aspect of their products.

Back to that 'poll'... Apologies for my dyslexia, but how do you spell 'loaded questions'?

CBD_Q1. For the following question, by “cannabidiol (CBD)”, we mean the oil extracted from a cannabis plant (also known as a marijuana plant). Before taking this survey, were you aware of any cannabidiol (CBD) based products? ACI Poll question, Published March 2020

What type of a question is that? Most 'marijuana plants' express very little CBD, and pretty much everyone who knows about cannabis is aware of it.

If this was a sensible poll that wasn't meant to sensationalise an issue, it would have said "we mean the oil extracted from a hemp plant (also known as a cannabis plant with less than 0.2% THC)". Mentioning marijuana like that shows to me that the focus was more about scaring people than doing serious market research.

April 2020 - The ACI establishes in-house Regulatory and Compliance Unit, headed by Dr Parveen Bhatarah, and the first ACI member submits CBD dossier for Novel Foods application

5 months into operation, the ACI have got someone in for compliance, which I've got to admit is no small feat! That being said, the link for this even is broken.

Allow me to pose a question though, how much do you think it will cost in wages for a Doctor to come into that position? I ask because the ACI charge a lot of money for membership, but they don't have very many members. It's also been suggested that they pay The Grocer a rather large sum of money a year to be able to get content to a wider but specific audience.

It looks like the ACI as of this point have 11 employees, which includes the founders. If 19 members are paying approximately £20/30k per year, it means their revenue would be approximately £380/570k. The company is based in London, so we can assume that all employees would be paid more than the national minimum wage, and the connections they have certainly to this point would easily take a good chunk of the higher estimate before we even get to further connections that are listed below.

As for the first submitted application, we'll touch on the outcome of that later in this article.

May 2020 - ACI hosts virtual CBD Novel Foods Symposium, and announces high-level discussions with the Laboratory of Government Chemists (LGC)

I seem to remember the FSA having to change their website after this symposium...

If memory serves, it was due to the ACI suggesting that there was more of a relationship with the FSA than the FSA were prepared to admit. I say 'prepared to admit', because there's definitely an element of hand holding there, I would even consider it possible that they have got as far as second base!

As for the 'high-level discussions', allow me to remind you of the CMC endeavour back in October 2019 in regards to conducting a comprehensive review of analytical practices for CBD products. I'd also like to point out that such meetings aren't exactly cheap. That's not a comment that I'm making in a suggestive way, it's just one of those things!

This is why I'm addressing finances, as I write this article whilst comparing my own timeline to that of the ACI, I find myself wondering if there's a backer, either on the payroll, silent, or through one of their members who maybe has more money to throw about than others. If there is, then there's an agenda at play that could end at the expense of the majority of the market.

June 2020 - ACI bolsters Regulatory and Compliance Unit with new hires, and announces CBD Safety Study Consortium to generate data to assess the safety of CBD

That's MORE money being spent! Don't get me wrong, you can spend your money however you see fit, but also remember... nineteen members!!!

September 2020 - Over 800 delegates attend the ACI’s “The Future of CBD in Grocery” webinar with The Grocer, the ACI officially launches landmark Safety Study Consortium, and FSA confirms that valid CBD novel foods applications must include toxicology safety study data

First off, lets talk about those 800 delegates. If all the other industry stakeholders are pretty much playing second fiddle by this point, where is ANY company going to go to find out what the hell is going on? The ACI trumpets this figure, but how many members do they have again?

Next comes the 'landmark' safety study consortium, which I can't take serious, just as much as the ACI, FSA and the COT can't take the WHO data seriously!

Finally, and this is the part that nearly made me wet myself, the 'rumour in the industry' as to why the FSA confirmed that toxicology reports were necessary was because an application, submitted after consultancy with the ACI, was rejected on the basis of not having a toxicology report. The so called 'join us or die' specialists messed up, first swing of the bat!

Now I COULD name that company, but I'm not an ass! The reason for this comment will become apparent further in this article.

October 2020 - The ACNFP, an advisory committee to the FSA, clarified key points relating to CBD novel food applications - emphasising the importance of ACI’s consortium approach to generating safety data

Here's a thought which is shared by many in the industry, are safety (animal) tests necessary? Seriously, it's not a nonchalant type of question, after all, how many years had CBD products been on sale before this point? Has anyone died? Has there even been a catalogued adverse reaction to any CBD product, as a result OF the CBD OR wider cannabinoid content?

Now ask the question: if cannabinoids come from cannabis, how many more years have cannabinoid products been available under the guise of being a cannabis based product?

Think about this very carefully, if ingestible cannabis products have been used since before written records, why are we splitting hairs over cannabis vs cannabinoids? If all but the ACI were trying to point this out, which they were, why does the opinion of one association with nineteen members count more that the hundreds of companies who were with the CTA, Canna-Pro, BHA or EIHA for that matter?

'This', "oh, someone confirmed some of our suspicions", really??? I don't need my neighbour to tell me my bagpipes sound shite for the first ten to fifteen minutes after I've tried to play them for the first time in several years, it's a given, just as much as it's a given that if the industry is being directed by pharmaceutical level toxicology reports, you would need them as part of a Novel Foods application...

November 2020 - ACI marks our first year anniversary

This report is premature, and came out on 06/11/2020, two weeks before the ACI actually first birthday. Yep, if I'm writing this, I'm going there!

In black and white, their list of reports makes it look like they've been busy, yet the ACI have never talked to the industry that their efforts are allegedly for, in that year or any other for that matter!

December 2020 - Food Standards Scotland clarifies their CBD position to ACI and our members

Check that link, and tell me if you find anything about Scotland in there!

Doesn't it sound like the Scottish FSA deliberately held a meeting to talk specifically about ACI concerns? We'll never know though, because the actual link to the article isn't there. The same can be said for some of the rest of their Milestones, October 2019's CMC entry for analytical testing for example has an ACI release about them creating a partnership with Surrey TS, and is dated for February 2021.

January 2021 - ACI becomes first cannabis membership organisation to form partnership with Trading Standards

Take note of this event, as there's the potential for someone to be using it in an attempt to 'thin the herd'!

February 2021 - ACI submits novel foods application to FSA on behalf of CBD safety consortium

This is nearly one year after the first application was submitted by the ACI, which was the one they didn't think a toxicology report would be needed for.

March 2021 - ACI submits paper to Home Office recommending clarity on THC limits for CBD products

Two weeks before that Novel Foods application submission deadline, but two weeks after the ACI had submitted their members applications? What is the point of this action if it wasn't to be disruptive to the industry???

I find myself wondering - if the ACI managed to get everyone onboard to submit applications with their THC limits in mind, would they then be using their political influence to push for the HO to take their suggestions seriously? I say that, more so to give you a heads up that the ACI have got a lobbying arm now, and considering how they have managed themselves so far, you know they will be putting it to good use...

April 2021 - ACI submits response on behalf of our members to ACMD’s call for evidence on cannabinoids in CBD products

"ACI members met for an exclusive event on 12 April to run through ACMD’s questions and ensure our response aptly reflects feedback from CBD industry leaders."

So the ACI make suggestions on THC in March, and one month later the HO and ACMD release a 'call for evidence', which the ACI reply to. That's awfully convenient, don't you think?

The ACI are the only ones in the UK CBD industry who are calling for restrictions on THC levels, so there was no feedback from 'industry leaders', only an association with 19 members.

Actually, I tell a lie. There is someone else who is trying to get THC and other controlled cannabinoids restricted, that being the infamous GW/Jazz Pharmaceuticals. I've been asked if I've found any connections between them and the ACI. All I can say is that other than intent on controlled cannabinoids and a window to the HO, I found this report from the ACI and CMC which mentions GW fifteen times, and an interview Steve Moore and a publication called New Frontier Data where a quote reads:

“We have already had a huge influence on the global cannabinoid market – including the most successful medical cannabis company in history in GW Pharma – and could now lead the world by being the first to properly regulate CBD.” Steve Moore, Co founder of ACI and CMC. New Frontier Data, April 19, 2022

GW/Jazz are the enemy of the CBD food supplemental market, if they have any kind of relationship with an association, you can be sure it's because they get something out of the arrangement, and not the other way round. We already know that GW harbour intentions to restrict peoples access to controlled cannabinoids, and that they feel the CBD industry needs further political direction. Sound ACI'ish to you at all?

May 2021 - ACI launches new membership package to support businesses enter the new regulated consumer cannabinoid markets, and launches a consumer CBD market sizing report - Green Shoots - and calls on government to exploit this great economic opportunity

The Green Shoot report is something I've touched on above, in that it mentions GW 15 times, but you won't see them mentioned in the ACI press release for the report...

As for the new membership package - feel free to tell me what you think, but I still smell 'Novel Intentions' all over it. Where's the provisions for other cannabinoid focused industries? I see nothing there for farmers, cosmetic, vape, or whole-plant cold-press products... although the latter is Novel Exempt, and that's not in the ACI remit.

There is one part of their package that I feel must be brought up though

One of the reasons why I'm writing this is due to the fact that the ACI, through Surrey TS, have been identifying companies who are yet to be listed. This is after they wrongly identified at least 2 companies as having rejected Novel Foods applications in an industry publication, when one was actually Novel Exempt, and lost a contract with Amazon!

Now I don't know what's worse, publishing a list that's been shown to be incorrect and has had an adverse effect on companies as a result, or allowing your members to use that list to tout for extra business whilst knowing it's wrong and not addressing it, which is something else I've been made aware of! But then there's targeting companies through TS, knowing full well that the FSA Novel Foods list is still incomplete.

What's more is that the ACI now have a website where non-ACI companies can report others for not being on the FSA list. Again, knowing that the list isn't complete makes this a bit of a shyster move.

Recently, the ACI have portrayed themselves as 'The CBD Novel Foods Police'. Do you think that their actions are honourable, or are they acting like bent coppers?

June 2021 - Government TIGRR report includes ACI recommendations, and ACI opens Brussels Office

March, the ACI call for clarity on THC levels. April, they submit a response to the HO/ACMD call for evidence on controlled cannabinoids, and then June happens.

There's one thing that needs to be addressed when it comes to this TIGRR report, and that is that it focuses on CBD products in a medicinal context only.

Slight side fact - the MHRA are mentioned 35 time is a 130 page document, you may find why quite interesting...

The ACI make a bold claim here, but they don't include a link to the report itself. I think that's deliberate for one or two reasons, it's either not true, or they were hiding the fact that the ACI focus is that of the CMC... medicinal over supplemental.

As for the Brussels Office, that's it for me! I would really like to see the ACI and CMC financial records to find out who's bankrolling them, because from what I see, they must be in negative equity at this point.

November 2021 - ACI launches First November Group with the Centre for Medicinal Cannabis

Hellooo, lobbying arm...

I don't know about you, but I hate lobbying. It tends to benefit a minority, which if we're looking at straight numbers, is exactly how you could view the ACI.

Again though, lobbying costs money, especially if you get the provided "24/7 political and parliamentary engagement and advocacy on behalf of our members" as this group suggests.

I've been writing this article for a few days now, but out of all I've found as opposed to what I knew, this and a possible link to GW actually worries me. As I mentioned above, the ACI have a 'knack' of making sure their opinion is heard over others, they've effectively taken that from the street, through the FSA, and placed it nicely (for them) in political chambers. I don't like that, not one bit!

March 2022 - All Novel Foods applications linked to ACI's CBD safety consortium receive Novel Foods validation from FSA, ACI partners with CMC and First November Group to launch The Hodges Review, a review of UK public policy and regulatory stewardship of the legal cannabis industry

First things first, no! All ACI applications are 'awaiting evidence' which will allow them to become validated, apart from one which has in fact been rejected. I won't name this company, mainly because it would be rude, but mostly because the list is not completed yet and that company could successfully contest the rejection of their application. Until I see a completed list, the only companies I'm calling out is the validated ones who didn't have a product before 13/02/2020, and that's more against the FSA for not upholding their own rules fairly than anything else.

But back to that lobbying arm, that basically brings a Professor into the fold. Considering some of the content of this timeline, I wonder if First November was there before their creation in all but name.

Representation – We represent our members at the highest level so their voice is heard and a favourable regulatory environment exists. ACI membership package, released 17/05/2021

It's something I'm not going to find out anytime soon, the company number for First November Group is the same as the one for the CMC, which is almost as interesting as the fact that I can't find a company number or presence on companies house for the ACI. Both entities don't have a 'trading as' on their website, either.

Interesting AND Convenient!

All the way through this piece, I've been questioning the finances of the ACI. That would be dodgy territory for some, but I have outlined the reasons already: 11 staff, contract of sorts with The Grocer, contract with Surrey TS, multiple reports commissioned, other relationships with other agencies and that all aggressively marketed... Oh, and of course ties to a Professor through their lobbying arm whilst already having a couple of qualified Doctors in tow.

Then there's the back and forth between the FSA, which I used to think that the high membership fees the ACI charged was what enabled them to keep as active as they have, but then we're talking 19 members against that as well as the rest of their costs.

The accounts that are attached are for The Centre for MC, and are for the 2019/2020 tax year. The ACI was launched on 20/11/2019, and 2020/2021 tax year is yet to be uploaded.

I can't say any more than that, other than the fact that I am suspicious. Should there be a justifiable reason why the ACI doesn't exist as a separate entity on Companies House with its own accounts or isn't listed as "trading as", and why First November Group has the same company number as The Centre for MC but isn't listed as a joined entity or 'trading as', I will happily set the record straight for those who like me, are curious.

But in the here and now

Back to the naughtiness, and that question I asked earlier in this article. Could it be viewed that the ACI and CMC are disruptive, and further to this, have they engaged in anti-competitive behaviour?

I think the answer to that is 'yes', but has any of it been illegal? I'll be sending this to the Competitions and Market Authority, asking them to investigate whether or not that is the case.

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