The Bank of Joe My Opinion – Roy Clinton MP – Shadow Minister for Public Finance

𝐆𝐢𝐛𝐫𝐚𝐥𝐭𝐚𝐫 𝐂𝐨𝐦𝐦𝐮𝐧𝐢𝐭𝐲 𝐈𝐧𝐢𝐭𝐢𝐚𝐭𝐢𝐯𝐞𝐬 𝐋𝐢𝐦𝐢𝐭𝐞𝐝

Gibraltar Community Initiatives Limited (‘GCIL’), a company limited by guarantee of its members (Haim Levy and Anthony Provasoli, as per the public records at Companies House), was incorporated on 6 February 2020. It is registered as a charity (no 321) and has charitable objects such that under Article 55 of its Articles of Association its income may only be distributed for ‘benefit of the Gibraltarian community on any level’. Since incorporation, over six years ago, this has grown into a considerable group of at least 15 identified companies some whose purpose is unknown. Its subsidiaries can be listed as follows:

Company Name Number Date of Incorporation

Community Supplies and Services Ltd 119528 10 February 2020

Wonderworks Media Limited 119545 12 February 2020

Community Homes Ownership Limited 121192 26 May 2021

World Wide Work Services Limited 123009 22 December 2022

Community Credit Union Limited 123047 17 January 2023

CI (Directors) Limited 123048 17 January 2023

Rooke Holdings Limited 123049 17 January 2023

CCP Limited 123050 17 January 2023

CCEC Limited 123051 17 January 2023

Transitional Homes Hostel Limited 123054 17 January 2023

EBS Limited (Eastern Beach Sheds) 123055 17 January 2023

CEHO Limited (Community Elderly Homes Ownership) 123077 20 January 2023

RMB Investments Company Limited 113725 24 November 2015

RMB Investments Company Limited was acquired from the Gibraltar Development Corporation’s subsidiary Economic Development & Employment Company Limited on 8 September 2023. The group also purchased a 51% interest in the Gibraltar International Mint Limited (No 110307) from the Gibraltar Savings Bank. Some of these companies in the GCIL group have been identified as forming part of the delivery of Sir Joe’s National Economic Plan and have received direct or indirect funding from the Gibraltar Savings Bank.

𝐆𝐢𝐛𝐫𝐚𝐥𝐭𝐚𝐫 𝐒𝐚𝐯𝐢𝐧𝐠𝐬 𝐁𝐚𝐧𝐤 𝐋𝐞𝐧𝐝𝐢𝐧𝐠 𝐭𝐨 𝐆𝐂𝐈𝐋 𝐂𝐨𝐦𝐩𝐚𝐧𝐢𝐞𝐬

Community Supplies and Services Limited was identified as the client in the architectural drawings for the Rooke nursing home site which it is believed is now owned by Rooke Holdings Limited. It is Rooke Holdings Limited that has invited expressions of interest for the running of the Rooke site. From answers to Parliamentary questions it is estimated that £38 million of funding was indirectly provided by the Savings Bank to this project which remains empty.

As at 31 December 2025, the Savings Bank has directly lent £4 million to CEHO Limited which is developing the elderly homes for purchase at the old Laguna Estate carpark and £ 1 million to Community Homes Ownership Limited whose only project is known to be at Hargraves.

EBS Limited owns and controls the Eastern Beach Sheds but it is unknown how these have been funded or their cost.

It is evident that elements of the GCIL group operate in such a way as to execute GSLP Government plans, indeed GCIL is mentioned in the GSLP 2023 Manifesto on page 39. Funding is provided by Sir Joe from the Gibraltar Savings Bank while retaining any profits within a private charitable structure outside the control of any future Government.

𝐓𝐡𝐞 𝐏𝐫𝐢𝐧𝐜𝐢𝐩𝐚𝐥 𝐀𝐮𝐝𝐢𝐭𝐨𝐫’𝐬 𝐑𝐞𝐩𝐨𝐫𝐭

In his report on the accounts of the Gibraltar Savings Bank for 31 March 2024, the Principal Auditor disclosed that the Savings Bank had indirectly invested a total of £50.5 million in loan notes issued by Community Credit Union Limited. This was not a direct purchase but channeled first via its subsidiary GSBA Limited and then the Gibraltar National Mint Limited owned by GSBA. When the GSD questioned the purpose of this transaction in July 2025, Sir Joe refused to give details other than saying the money was ‘invested in national projects’ and ‘infrastructure investment’ (PR 539/2025).

Without the disclosure made by the Principal Auditor in his 2018/19 annual report neither Parliament, nor the people of Gibraltar would have been aware of this transaction and the existence of Community Credit Union Limited which is part of the GCIL charity group.

𝐂𝐨𝐦𝐦𝐮𝐧𝐢𝐭𝐲 𝐂𝐫𝐞𝐝𝐢𝐭 𝐔𝐧𝐢𝐨𝐧 𝐋𝐢𝐦𝐢𝐭𝐞𝐝

When probed in Parliament on 14 January 2026 by both myself and the Leader of the Opposition, Sir Joe stated that Community Credit Union Limited ‘provides funding to private sector projects that promote economic and social benefits to Gibraltar’. Furthermore he stated that it did not form part of his National Economic Plan but that it was ‘an initiative from the business community’. This raises some serious concerns as to what sectors of the business community have lobbied for the creation of Community Credit Union Limited so as to obtain credit.

On 15 January 2026, the Chief Minister in answers to questions stated that Community Credit Union Limited did not actually hold a money lending licence but that he, as Minister of Finance, had granted

it an exemption under s 30 (1) (e) of the Financial Services (Money Lending) Act ‘on the basis that they are acting in the public interest of Gibraltar and its people’.

Sir Joe Bossano made it clear that he authorised political investment of Savings Bank money into Community Credit Union based on business cases presented to and evaluated by the Treasury Department. When asked as to why this scheme was not advertised to the general business community Sir Joe responded ‘the reality is that without advertising people approach me so why should I have to advertise it?’. As to whom Community Credit Union Limited is lending money?.. the Chief Minister responded that ‘as this is not a Government-owned company, we are unable to provide this information’. So we have a situation where Sir Joe makes decisions to fund projects backed by Community Credit Union Limited, evaluated by Treasury but the Government claims to have no information as to the lending activities of the company.

This game of smoke and mirrors is compounded by the widely repeated observation on Main Street that the Savings Bank has provided loans to a private business group that have been buying a considerable number of local businesses (a least one of which has a substantial Government contract) in recent months.

𝐓𝐡𝐞 𝐁𝐚𝐧𝐤 𝐨𝐟 𝐉𝐨𝐞

In the final analysis Community Credit Union Limited is nothing more than ‘The Bank of Joe’ in which Sir Joe Bossano is the sole judge as to whether loans it grants to businesses are to be financed by the Gibraltar Savings Bank or not. It may be that there is sound financial logic to providing finance in this way through Community Credit Union Limited, but given the secrecy surrounding its creation and evident closed group of business interests that has access to it, it begs the question why? Why is the Bank of Joe even necessary given the existence of Credit Finance Company Limited which is owned by the Government and has a Money lending licence? Why if this lending is so profitable it is done through the GCIL charitable structure outside the control of a Government elected by the people? Who asked for the creation of the Bank of Joe? and who is really benefiting from its financial support? At a time of great financial uncertainty for the general business community, given the EU Treaty, some may ask why is it that the Bank of Joe is only for the select few and not open to all? In this respect the inclusive approach of the Bank of Dave had it right where this GSLP Government continues to get it wrong.