Overview
Last Updated: January 15, 2026Alcohol Ltd ("the Company") is committed to transparency and maintaining the highest standards of corporate governance. All directors, officers, employees, and contractors are required to declare relevant financial interests that could potentially conflict with their duties to the Company or affect their objectivity in decision-making.
This Statement of Financial Interests ("Statement") provides a public record of material financial interests held by key personnel within Alcohol Ltd. These declarations are made in accordance with the Company's internal governance policies, statutory requirements, and regulatory frameworks including the Office of the Registrar of Consultant Lobbyists standards.
This Statement is published for transparency purposes and does not constitute any representation, warranty, guarantee, or assurance regarding the financial position, creditworthiness, or future performance of Alcohol Ltd or any of its personnel.
⚠️ Important Legal Disclaimer
Personal investments and financial holdings declared herein are not associated with Alcohol Ltd and do not represent the views, endorsements, investments, liabilities, obligations, or commercial positions of the Company. These declarations are made solely for transparency and conflict-of-interest management purposes and shall not be construed as creating any legal, financial, or contractual relationship between such personal holdings and Alcohol Ltd.
Explicit Exclusions: Personal financial holdings, investments, shareholdings, securities, and all related financial interests are expressly and unequivocally excluded from serving as:
- A)Guarantees, sureties, or indemnities of any kind–whether express, implied, constructive, statutory, or otherwise–for any obligations, liabilities, debts, commitments, or contingent liabilities of Alcohol Ltd, its subsidiaries, affiliates, or related entities;
- B)Collateral, security interests, pledges, mortgages, hypothecations, liens, or other encumbrances for any loans, credit facilities, bonds, commercial paper, or other financial commitments of the Company;
- C)Underwritings, warranties, or representations regarding the performance, viability, creditworthiness, compliance, or future engagement of any third-party entities, alcohol industry participants, or Alcohol Ltd itself;
- D)Evidence of beneficial ownership, control, management influence, or material participation in the governance or operations of Alcohol Ltd or any affiliated entities;
- E)Representations of voting rights, economic interest, or claim to assets or earnings of Alcohol Ltd;
- F)Any form of security, recourse, or remedy for creditors, lenders, counterparties, or any other third parties in relation to Alcohol Ltd's operations or financial obligations.
Acknowledgement and Severability: Each director, officer, and employee hereby declares and irrevocably acknowledges that: (i) their personal financial holdings constitute entirely separate personal assets held in an individual capacity; (ii) such holdings have no legal, financial, contractual, or equitable nexus to Alcohol Ltd; (iii) Alcohol Ltd shall have no claim, lien, or interest in such holdings; and (iv) such holdings do not confer any rights, obligations, or liabilities relating to the Company's operations, governance, or financial position.
Liability Limitation: Alcohol Ltd expressly disclaims any and all liability, responsibility, or accountability for personal financial decisions, holdings, transactions, investments, or consequences thereof relating to its directors, officers, or employees. Any party relying upon this Statement does so entirely at their own risk and without recourse to Alcohol Ltd, its shareholders, or its personnel.
Directors' Financial Interests
Last Updated: January 15, 2026Stephen Grindley – Managing Director
Stephen Grindley is the Managing Director of Alcohol Ltd. Self-referencing of interest in Alcohol Ltd is not included in this report as it represents his role within the company rather than an external financial interest.
| Type of Interest | Details | Status |
|---|---|---|
| Shareholdings in Alcohol Companies | Public or private listed alcohol companies | None |
| Bond Holdings | Corporate or government bonds related to alcohol industry | None |
| Stock Options | Vested or unvested options in alcohol companies | 0 Options |
Summary (as of January 15, 2026): Stephen Grindley holds zero direct shareholdings, bond holdings, or stock options in any public or private alcohol company globally as of this declaration. This declaration does not include his directorship of Alcohol Ltd, which is excluded as per the self-referencing policy outlined above.
Exclusion of Index Fund Holdings
This statement does not include passive index fund investments such as the FTSE 250, FTSE 100, or DJIA (Dow Jones Industrial Average), even though these indices may contain alcohol or alcohol-related companies.
Rationale: Passive index funds represent broad market exposure and are not direct investments in specific alcohol companies. Holders have no active control over individual holdings within these indices, and the diversified nature of such funds means no single company forms a material interest.
Governance Principle: This declaration focuses on direct, material financial interests that could create genuine conflicts of interest or affect decision-making objectivity.
Employee Declarations
Last Updated: January 15, 2026All employees of Alcohol Ltd are required to complete a financial interests declaration form during onboarding and annually thereafter. These declarations are maintained confidentially within our HR systems and made available to relevant parties on a need-to-know basis for conflict management purposes.
Employees with significant financial interests in alcohol-related companies are required to disclose these interests to management and may be subject to restrictions on participation in certain projects or decisions.
Alcohol Ltd – Company Financial Interests
Last Updated: January 15, 2026As a lobbying and advocacy organisation, Alcohol Ltd maintains the following financial position and interest structure:
| Category | Details | Status |
|---|---|---|
| Direct Shareholdings in Alcohol Companies | Equity stakes in public or private alcohol producers, retailers, or distributors | None |
| Investment Income from Alcohol Industry | Dividends, interest, or returns from alcohol-related investments | None |
| Financial Loans or Guarantees from Industry Players | Any outstanding loans or guaranteed obligations from alcohol companies | None |
Company Organisational Structure & Commercial Model (January 15, 2026)
Alcohol Ltd is a commercial advocacy and lobbying organisation structured as a private company limited by shares under English law, registered at Companies House. The Company is funded through membership subscriptions, sponsorship arrangements, and commercial advisory services provided to industry participants.
Directors and employees are expressly permitted to hold financial interests in alcohol companies, provided such interests are declared in accordance with this Statement. The existence of such interests does not impair the Company's ability to operate, nor does it constitute a conflict unless such interest creates a material risk of bias in specific decision-making contexts.
This Statement is published for transparency and regulatory compliance purposes and does not constitute: (a) an admission of liability; (b) a warranty or representation regarding the financial condition of Alcohol Ltd; (c) a guarantee of future performance or solvency; or (d) a basis for third parties to extend credit or enter into transactions with the Company.
Update Frequency & Contact
This information is valid as of January 15, 2026 and will next be updated on January 15, 2027. Any changes to financial interests that occur during the year will not be recorded on this page until the next annual update date. Directors are required to notify the company within 30 days of any new financial interests or material changes to existing holdings.
For enquiries regarding this statement or to report potential conflicts of interest, please contact our Compliance team at compliance@alcohol.uk.
Company No. 04854930. Registered Office: The Limes, Bayshill Road, Cheltenham, GL50 3AW, United Kingdom.
Governance Framework & Legal Basis
Effective: January 15, 2026This Statement of Financial Interests has been prepared in compliance with the following regulatory, statutory, and internal governance frameworks:
- •Companies Act 2006: Directors' duties regarding disclosure of interests under s.175 and s.182;
- •Lobbying Act 2014 & ORCL Standards: Transparent disclosure requirements for consultant lobbyists and lobbying firms;
- •UK Corporate Governance Code 2024 (applied voluntarily as best practice): Provisions regarding director remuneration, conflicts, and related party transactions;
- •Alcohol Ltd Articles of Association: Company constitution and conflict management procedures;
- •Data Protection Act 2018 & UK GDPR: Lawful processing and safeguarding of sensitive personal financial information;
- •Modern Slavery Act 2015: Supply chain transparency and ethical sourcing requirements;
- •Bribery Act 2010: Anti-corruption and anti-bribery compliance obligations;
- •Alcohol Ltd Internal Conflicts of Interest Policy & Procedure.
Annual Certification & Verification Requirements
All directors, officers, and designated employees are contractually obligated to provide written certification annually (as of January 15 of each year) confirming:
- i)The accuracy, completeness, and truthfulness of all financial interest declarations;
- ii)Disclosure of all material financial interests that could reasonably be expected to influence judgment or create conflicts;
- iii)Understanding of the legal obligations and consequences of providing false or misleading information.
False, misleading, incomplete, or deliberately withheld declarations may constitute: (a) grounds for disciplinary action up to and including immediate dismissal; (b) breach of fiduciary duty; (c) potential basis for legal proceedings by creditors or stakeholders; and (d) possible criminal liability for fraud or misconduct in public office. Alcohol Ltd reserves the right to conduct independent audits, third-party verification, and investigation of any declared interests.
Conflict Management & Recusal Procedures
Directors and employees with material financial interests in specific third-party entities may be required to:
- •Recuse themselves from board decisions, votes, or negotiations affecting those entities;
- •Abstain from confidential or commercially sensitive discussions;
- •Restrict their participation in projects where their interests could reasonably bias decisions;
- •Submit to management review and approval before engaging in business development activities with such entities.
Scope Limitations & Exclusions from This Statement
This Statement does not disclose:
- •Passive index fund holdings (FTSE 100, FTSE 250, DJIA, S&P 500, etc.) absent direct knowledge of specific alcohol company exposure;
- •Diversified mutual funds or unit trusts where beneficiary has no material investment decision-making power;
- •Retirement savings, pension schemes, and SIPP investments (unless self-directed and containing direct alcohol company holdings);
- •Family members' separate financial interests (unless director has material involvement or control);
- •Employment compensation and standard employee benefits;
- •Directorship of Alcohol Ltd itself (self-referencing exclusion as noted).
Governing Law, Jurisdiction & Interpretation
This Statement of Financial Interests is governed by and construed in accordance with the laws of England and Wales. Any disputes, claims, or proceedings relating to this Statement shall be subject to the exclusive jurisdiction of the courts of England and Wales.
Interpretation: Headings are for convenience only and do not affect meaning. "Material" means information that a reasonable third party would consider significant for investment or credit decisions. "Alcohol company" includes producers, retailers, wholesalers, bottlers, distributors, and ancillary service providers to the alcohol industry. References to "directors and employees" include all officers, consultants, and agents acting on behalf of Alcohol Ltd.
Amendments: Alcohol Ltd reserves the right to amend this Statement, update standards, or modify disclosure requirements upon notice. Material amendments will be communicated directly to all affected personnel and published on this page with revised effective dates.