30 August 2022

Dear James,

Given Tortoise Media is now seeking answers to questions about the member demographics and the
internal procedures of private organisations, I thought it would be of interest to my readers to find out more
about your organisation in order to determine if it is fit and proper to make such inquiries. In particular to
find out who is behind the organisation.

Could you therefore provide me with

(1) Anonymised data you hold on the demographics of your organisation's membership:

(a) Particularly, we invite you to provide, where held, the number of members who:
(i) Pay for subscriptions;
(ii) Receive free subscriptions
(iii) Do not actually use their free subscriptions.

(b) We also ask you to provide data in respect of:

(i) The age range of members;
(ii) The geographic distribution of members; and
(iii) The genders of members.
(iv) The political leanings of members.

(2) An explanation of whether, and if so how, Tortoise Media keeps its membership database up to date,
particularly their correct email addresses.

(3) Anonymised data you hold on variations in member numbers over time, presented quarterly since
formation.

(4) An explanation of Tortoise Media’s system of compliance, including but not limited to the following
questions:
(a) How does Tortoise Media check that new members are who they say they are?
(b) How does Tortoise Media know that members and/or funders do not have ill intentions?

(5) An explanation of any third party compliance mechanisms that prevent you inflating your subscriber
numbers.

(6) An explanation of the circumstances by which you thought you were entitled to answers about the
organisation of private entities.

(7) A breakdown of what has happened to the reported £20 million spent and all of the donors from whom
funds for Tortoise Media were sourced.

If you could answer these questions without us having to resort to a mad claim for judicial review, that
would be very sporting of you.

Regards,

Paul Staines
Editor, Guido Fawkes