Bayo Randle was appointed in August 2025 as an Inspector under section 37B of the Trade Union and Labour Relations (Consolidation) Act 1992 [TULRCA] to investigate the financial affairs of Unite the Union. 

The investigation concerned whether the union had complied with its duties under section 28 of TULRCA in respect of the year ended 31 December 2021, and whether any failure to do so amounted to an offence under section 45. 

Bayo’s final report was submitted to the Certification Officer on 14 August 2026 and has been published by the Certification Officer. Among other things, it addresses the meaning of “satisfactory system of control” under section 28(1)(b). There is case law touching on the provision, but none construing its meaning. 

In a statement published on 20 August 2026, the Certification Officer recorded Bayo’s finding that the union had failed, during the year ended 31 December 2021, to establish and maintain a satisfactory system of control contrary to section 28(1) (b), and that Bayo did not find the breach to have arisen from refusal or wilful neglect. 

The Certification Officer’s decision and the report are available here.