Formal Letter to the CWC Trustees and Leadership of DfE

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The Issue

Parents and Guardians of Canary Wharf College (East Ferry, Glenworth, and Crossharbour)

Formal Letter to the CWC Trustees and Leadership of DfE
Date: 10th November 2025

To:
John Afolayan · CWC Chair of Trustees
Margaret Raggett · Trustee
Andrew Sanderson · Trustee
Alan Parnum · DfE Regional Director
Sarah Fielding · London Regional Schools commissioner

 
Introduction
We, the undersigned parents and guardians of pupils at Canary Wharf College, request urgent clarification and immediate withdrawal of the proposed transfer of CWC schools to the University Schools Trust (UST) and all associated operational changes. Recent actions have eroded parental trust and raised questions about transparency, legality, and inclusivity. Parents do not consent to any alteration to the current school day, term structure, or governance model. All proposed changes should be withdrawn entirely.

This letter is accompanied by a parent petition with over 600 verified signatures to this date, a significant proportion given the total of around 1,000 pupils across the East Ferry, Glenworth, and Crossharbour campuses.

 
1. Lack of Consultation and Short Notice
Parents were informed of significant proposed changes with minimal notice and without any formal consultation process. The November 3rd letter clearly referred to 'proposals' and 'feedback', yet subsequent communications have reframed them as final decisions. This approach breaches the four Gunning Principles (R v Brent LBC ex parte Gunning, 1985), which require consultation at a formative stage, adequate information, sufficient time, and conscientious consideration of responses. Parents are gathering evidence to demonstrate that this consultation process does not satisfy the four Gunning Principles.

 
2. Governance, Representation and Transparency
CWC operates under a Local College Council (LCC) model that provides no decision-making authority for parents. Combined with the absence of parent trustees, this denies families meaningful representation. Parents request publication of the Trust’s current governance structure, the Register of Interests (as required by the Academy Trust Handbook 2024, s5.41.5.49), and confirmation that all conflicts of interest—including leases or financial arrangements—have been declared. Minutes of trustee and LCC meetings where these proposals were discussed should also be made public.

 
3. The Green Book and Staffing Argument
Parents support fair pay and improved conditions for all staff, including full parity for maternity pay and holiday entitlement. However, there is no requirement within the Green Book or Department for Education guidance that compels a change to pupil hours, term dates, or the wider school structure. The Trust has not in any way demonstrated that extending the school term is necessary to improve support-staff maternity pay.

The Trust has provided no financial case or analysis showing why this outcome cannot be achieved through direct HR adjustment. The Green Book changes can be implemented administratively without structural change, and the Trust has failed to present evidence that extending the term would improve staff pay or parity.

 
4. Inclusion of SEND Pupils and Community
SEND parents, staff and representatives were not consulted despite repeated references to SEND needs as justification for change. This appears inconsistent with statutory duties under Sections 20, 85 and 149 of the Equality Act 2010 and the SEND Code of Practice (2015). We request a formal SEND impact assessment, inclusion of SEND parent representatives in consultations, and a written statement confirming how SEND pupils will be supported.

 
5. Impact on Families, Stability, and Community Inclusion
The current 8:15–4:00 structure has been integral to CWC’s educational model for over a decade, supporting both academic achievement and family balance. Parents deliberately chose the school for its inclusive timetable, longer holidays, and flexibility for families with international and extended family ties.

Shortening the day and reducing holidays would increase childcare costs and reduce cultural and family connections, disproportionately affecting working parents, single-parent families, and lower-income households. This proposal would place the greatest burden on those least able to adapt, undermining inclusivity and stability.

 
6. Staff Retention and Recruitment
The proposed changes risk destabilising staff morale, recruitment, and retention. Longer holidays and the current timetable have been key incentives for attracting and keeping high-quality staff. Parents request confirmation that the Trust has carried out a full impact assessment on how these changes could affect recruitment, retention, and the quality of teaching.

 
7. Educational Evidence and Practicality
No data has been provided to support claims of pupil fatigue. We request publication of any educational, behavioural, or attendance evidence used to justify these proposals or confirmation that none exists. Parents also request detailed information on teaching hours gained or lost under the proposed changes, especially for KS4 GCSE coverage, and evidence that teaching time remains sufficient to deliver the full curriculum.

 
8. EDAs, Costs and Equality of Access
Parents seek clarity on after-school provision: whether it will be a two-hour block or split into 3–4pm / 4–5pm, the cost structure, and the prioritisation policy. Prioritising 'working parents' may contravene Equality Act 2010 duties. Access must remain equitable and affordable for all. Extending unstructured sessions without consistent grouping or structured learning may also increase poor behaviour and safeguarding risks.

 
9. Legal and Governance Obligations
Under the Academy Trust Handbook 2024 (s1.6.1) and the Gunning Principles, major decisions require meaningful stakeholder engagement. As an academy trust, CWC/UST has statutory safeguarding duties under Education Act 2002 s157 and the Education (Independent School Standards) Regulations 2014, supported by Keeping Children Safe in Education (2025). Trustees must also act in the best interests of pupils under the Companies Act 2006, the Trust’s Funding Agreement, and charity law obligations. We request confirmation that a full Equality Impact Assessment has been completed or, at minimum, that the Public Sector Equality Duty under Equality Act 2010 s149 was satisfied before proposals were made.

 
10. Requested Actions
Parents collectively oppose the proposed UST transfer and all related changes to the school day, term structure, or governance. We do not consent to these changes proceeding in any form or at any future date. We request:

  1. Withdrawal of the proposed transfer of Canary Wharf College schools to the University Schools Trust (UST) and all associated operational changes.
  2. The Trust to publish the evidence and rationale for all proposed changes.
  3. The Trust to conduct a transparent, lawful consultation involving parents, staff, governors, and relevant community stakeholders.
  4. The Trust to confirm that trustees have undergone Section 128 checks and all conflicts of interest have been declared.
  5. The Trust to demonstrate, using CWC’s latest financial figures, why it believes the school is 'unsustainable' and how a UST takeover would address that.
  6. An independent review by DfE/ESFA to assess the governance, HR, and equality implications before any transfer proceeds.

Yours faithfully,
Parents and Guardians of Canary Wharf College (East Ferry, Glenworth, and Crossharbour)

 

CC:
Steve Reddy - Corporate Director Children's Services for LBTH
Apsana Begum - Member of Parliament for Poplar & Limehouse

 

Appendix A

Legal and Policy Observations
Proposed Move to the 'Green Book' Terms and Conditions
Dr. Tianruo Gao
Senior Legal & Compliance Consultant
Associate Fellow of the Higher Education Academy

 
This document sets out, in the style of a legal opinion, the relevant factual background, applicable provisions of the National Joint Council for Local Government Services: National Agreement on Pay and Conditions of Service (commonly known as ‘the Green Book’), and an analysis of the CWC Board of Trustees (hereinafter referred to as ‘the Board’) stated rationale, as communicated both in writing and verbally to parents.

 
1. Scope and Applicability of the Green Book
1.1. The Green Book applies automatically only to local authority-maintained schools.
1.2. It applies to academies and multi-academy trusts (MATs), such as CWC Trust (hereinafter referred to as ‘the Trust’), only where the trust has expressly adopted it—either in full or in part—through its employment contracts. Adoption is therefore voluntary, not mandatory.
1.3. Accordingly, the Trust may lawfully:

adopt the Green Book in full;
adopt only selected provisions; or
adopt it with supplementary or varied clauses specific to the Trust.
There is no statutory or contractual requirement compelling the Trust to implement all or any parts of the Green Book.

 
2. Misstatement of Requirement to Work a Set Number of Weeks
2.1. The statement in the Board’s correspondence that ‘The Green Book requires employees working under it to work a certain number of weeks per annum’ is incorrect.
2.2. The Green Book provides a framework for pay, grading, leave, and working time but does not dictate the length of the school year or the number of working weeks.

Relevant extracts include:

Part 2, paragraph 6.1:
‘The standard working week for full-time employees is 37 hours (36 in London). This may be calculated over a period other than a week in accordance with the provisions of Part 3.’
This clause sets the standard weekly hours, not the number of annual weeks.
Part 4.12 (Term-Time Only Employees):
Provides guidance on the calculation of pay and leave for staff who work term-time only. It does not prescribe a fixed number of weeks per year.
Parts 1 and 3:
Promote a ‘flexible approach to providing services… which meets the needs of employees as well as employers,’ leaving working arrangements to local negotiation and agreement.
The only instance of a fixed working-year reference appears in Part 3, Appendix 2 concerning nursery employees, who ‘should be available to work for 195 days in any year, of which 190 days will be days on which pupil contact is required.’ This provision is sector-specific and has no relevance to general school support staff at all three schools operated by the Trust.

 
3. Maternity Leave and Pay under the Green Book
3.1. The Interim CEO has verbally communicated to parents on several occasions that a principal rationale for altering the school term dates and day structure is to ensure that support staff ‘get the right maternity pay or the right salary.’ However, there is no provision within the Green Book that supports this position. Maternity leave entitlements and pay amount are not determined by the structure of the school day, the length of the school year, or the term dates.
3.2. Under Part 2, paragraph 11.4, all employees are entitled to:
‘26 weeks’ ordinary maternity leave followed by 26 weeks’ additional maternity leave, giving a total of 52 weeks’ continuous leave.’
This entitlement is universal, irrespective of hours worked, term length, or employment pattern. Nothing in the Green Book links the right to maternity leave with the duration of the school term or number of working weeks.
3.2.1. Employees with less than one year’s continuous service at the eleventh week before the expected week of childbirth (EWC) are entitled to Statutory Maternity Pay (SMP) only, where eligible, in accordance with statutory provisions. The Green Book does not reduce their entitlement to maternity leave but simply limits occupational maternity pay to those with one or more years’ qualifying service. Neither the length of the school term nor the number of weekly working hours affects eligibility or entitlement.
3.3. Employees with at least one year’s continuous service qualify for the Green Book’s occupational maternity pay, which supplements SMP as follows:

six weeks at 90 per cent of a week’s pay (offset by SMP if eligible);
twelve weeks at half pay plus SMP (if returning to work);
twenty-one weeks at SMP only; and
thirteen weeks’ unpaid leave.
Each element is calculated solely by reference to the employee’s ‘week’s pay’ as defined in paragraph 11.9(a):
‘The amount payable by the authority to the employee under the current contract of employment for working their normal hours in a week.’
3.3.1. For term-time-only staff, this is normally their annualised weekly pay (annual salary ÷ 52), following majority local authorities’ precedents, unless the contract specifies otherwise.
3.4. Statutory Maternity Pay (SMP), set by national law, is based on average weekly earnings during the eight weeks before the qualifying week. If that reference period falls partly within an unpaid school holiday, the average—and therefore SMP—will be lower. This variation arises from payroll timing, not from the Green Book itself or term dates. An employer that annualises pay or sets the contractual start of maternity leave within a paid term avoids this inequity.
3.5. Consequently, any disadvantage to support staff from reduced maternity pay would result from the Trust’s chosen pay-structure or timing of leave, not from Green Book provisions or length of terms. An MAT has wide contractual flexibility when setting pay structures, hours, and benefits for support staff. If the Board’s aim is to secure fair maternity outcomes, it can achieve this by contractual wording—such as annualising pay, adjusting reference-period dates, or providing a top-up clause—without changing term dates or the length of the school year.

 
4. Parental and Community Position
4.1. Parents fully support fair pay and improved conditions for all staff, including full parity for maternity pay and holiday entitlement. However, there is no requirement within the Green Book—or within Department for Education (DfE) guidance—that compels a change to pupil hours, term dates, or the wider school structure.
4.2. The Trust could, if it wishes to enhance fairness for support staff, do so immediately through direct HR action. For example, the Trust could:

re-grade support staff roles,
adjust pay to align with NJC scales, or
adopt Green Book parity through contractual variation.
All of these actions are standard practice across many academies that have aligned with the Green Book while maintaining their existing educational calendars.
4.3. Parents therefore request:

written clarification of the legal basis for linking Green Book adoption to changes in pupil hours or term structure; and
confirmation that all other, less disruptive HR options have been properly considered.
4.4. Parents also request consideration of a compressed-hours clause, allowing support staff to work equivalent total hours within existing school days and term dates. This would achieve contractual parity without adversely impacting students or families.
 
5. Impact of Proposed Changes
Altering the school day or extending the academic term might affect the total contracted hours and pay calculations for some employees, depending on the individual wording of their contracts and how hours are annualised. While a small number of staff might experience neutral or marginal benefit, others—particularly part-time or lower-paid employees—could face material disadvantage in relation to hours, earnings, or work–life balance.

Before proceeding, the Board should therefore provide a comprehensive, evidence-based analysis demonstrating:

  • the specific effect on total hours and annual earnings for each staff category;
  • the proportion of employees likely to benefit versus those adversely affected;
  • that any potential benefits materially outweigh the disruption to pupils, parents, and family life; and
  • how additional commuting time and costs, particularly for lower-paid or part-time staff, would be mitigated.
    Such analysis is essential to ensure that any proposed structural change is necessary, proportionate, and consistent with the Trust’s duty of care to staff and families.

 
6. Alternative Measures
If the Trust’s aim is to ensure parity and fairness for staff, it could:

  • incorporate Green Book pay, grading, and maternity provisions into existing contracts;
  • insert supplementary clauses (e.g. enhanced maternity pay, top-up clause); or
  • agree compressed or flexible hours arrangements, thereby achieving compliance without reconfiguring the school calendar.
    Such approaches would deliver the intended employment benefits while preserving educational continuity.

 
7. Conclusion
In summary:

The Green Book does not require a specific number of working weeks per year.
The Trust, as a MAT, is not legally obliged to adopt the Green Book in full.
There is no legal or policy basis for linking Green Book adoption to changes in pupil hours or term dates.
Staff welfare, including pay, maternity benefits, and work–life balance, is determined by contractual terms and pay structure—not by the length of the school term or the number of teaching weeks.
Less disruptive HR alternatives exist and should be explored in good faith.
Parents and staff should be fully consulted with supporting evidence before any structural changes are made.
Accordingly, I respectfully submit that the Board should pause implementation of Phase 2, obtain independent HR and legal advice on the available options, and engage in transparent consultation with all stakeholders.

 

Appendix B
Supporting Evidence on School Hours and Impact
(Prepared by Dr. Ilaria Peri, Senior Lecturer at Birkbeck Business School, Fellow of the Higher Education Academy, November 2025)

 
There is little empirical evidence that shorter school days reduce fatigue or enhance wellbeing. By contrast, longer, structured, and mandatory school days have documented benefits for learning, engagement, and educational equity. Reflecting this, the DfE has introduced minimum core school hours to ensure all pupils receive sufficient daily instructional time, providing a consistent framework for teaching and learning, and encouraging specialist settings and alternative provision to extend their core week where appropriate (DfE, 2021, 2023; EPI, 2024b).

 
Academic Achievement Impact
UK data (EPI, 2024) show +0.17 GCSE grade and +0.05–0.07 Key Stage 2 gains per extra weekly hour; overall impact = +3 months learning progress (EEF, 2025).
Cross-country findings (Lavy, 2015; Bingley et al., 2018; Hincapie, 2016; Dominguez and Ruffini, 2020) show 0.05–0.10 SD increases in test scores with longer instructional time.
Reducing instructional time may limit learning opportunities (EPI, 2024).
 
Equity and Inclusion Impact
Reductions in instructional time risk widening attainment gaps, since disadvantaged and SEND pupils are less likely to engage effectively in independent or home-based learning outside school hours, relying more heavily on structured, teacher-led instruction (OECD, 2021; EPI, 2024).
Extending the school day can particularly benefit disadvantaged pupils, especially those from low-income backgrounds, while also supporting multilingual and minority pupils, helping to narrow opportunity gaps (EEF, 2023; CPAG, 2021).
Larger gains for low-SES and rural schools in Colombia (~0.065 SD vs. 0.048 SD for high-SES; Hincapie, 2016).
Holidays and family visits abroad can support multilingual pupils in maintaining their home-language skills and cultural identity (Alzayed, 2015).
 
Wellbeing and Behaviour Impact
Structured enrichment provided during longer school days can:

Improve pupils’ wellbeing, sense of belonging, and inclusion, particularly for children from low-income backgrounds (CPAG, 2021).
Reduce exposure to crime, drugs, and early pregnancy, offering safer environments (OECD, 2021).
Link to better long-term outcomes—higher adult earnings, delayed childbearing, and improved socio-emotional skills and positive behaviour (IDB, 2020, 2023; CPAG, 2021).
 
Impact on Families, Stability and Community Inclusion
Shorter days increase childcare burdens and reduce parental (especially maternal) workforce participation (Zuchner, 2012; CPAG, 2021).
All-day schooling supports family wellbeing and stability, easing daily logistics (Zuchner, 2012; CPAG, 2021).
Studies show fewer parent-child conflicts and improved family climate with full-day schooling (Fisher, Theis & Zuchner, 2014).
 
References
Alzayed (2015). Preserving Immigrants’ Native Language and Cultural Identity in Multilingual and Multicultural Societies. Int. J. Humanities Soc. Sci.
Bingley et al. (2018). The Timing of Instruction Time: Accumulated Hours, Timing and Pupil Achievement. Institute of Labor Economics.
Child Poverty Action Group (CPAG). (2021). How Extended Schools Can Help Tackle Child Poverty.
Contreras and Lepe (2023) (IDB, 2023). Extended School Day. Inter-American Development Bank.
Department for Education (2021). Review of time in school and 16 to 19 settings.
Department for Education (2023). Length of the School Week Non-Statutory Guidance.
Dominguez and Ruffini (2020) (IDB, 2020). Long-Term Gains from Longer School Days. Inter-American Development Bank.
Education Endowment Foundation (EEF, 2025). Extending School Time. London: EEF.
Fisher, Theis and Zuchner (2014). Narrowing the Gap? The Role of All-Day Schools in Reducing Educational Inequality in Germany. Int. Journal for Research on Extended Education. 2(1).
Gavriloiu (2024) (EPI, 2024). An evidence review into the length of the school day. Education Policy Institute.
Hincapie (2016) (IDB, 2016). Do Longer School Days Improve Student Achievement?: Evidence from Colombia. Inter-American Development Bank.
Hodge and Gavriloiu (2024) (EPI, 2024). A longer school day: the attainment benefits of an extra hour a week. Education Policy Institute.
Lavy (2015). Do Differences in Schools’ Instruction Time Explain International Achievement Gaps? Evidence from Developed and Developing Countries. The Economic Journal. 125(58). F397–F424.
Robinson (2024) (EPI, 2024). Access to extra-curricular provision and the association with outcomes. Education Policy Institute.
Radinger and Boeskens (2021). More Time at School: Learning Better. Paris: OECD Publishing.
Zuchner (2012). Daily School Time, Workforce Participation, and Family Life: Time Spent in School as a Condition of Family Life. The Politicization of Parenthood: Shifting private and public responsibilities in education and child rearing, 281–297.

 

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The Decision Makers

Margaret Raggett
Margaret Raggett
John Afolayan
John Afolayan

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