ESG Enforcement Tracker

Key facts:

Three former directors of Ethical Forestry Limited have been convicted of fraudulent trading following an SFO investigation that began in 2017. Matthew Pickard, Stephen Greenaway and Paul Laver pleaded guilty to the offence and are awaiting sentence.

Following the collapse of Ethical Forestry Limited in 2015, the SFO opened a criminal investigation into tree-based investment schemes run by the Ethical Group, which included the Ethical Forestry Limited.

In 2023, the SFO charged former company directors of Ethical Forestry Limited, Stephen Greenaway, Paul Laver and Matthew Pickard. The directors were charged with two counts of conspiracy to commit fraud by false representation contrary to section 1 of the Criminal Law Act 1977 and one count of fraudulent trading contrary to section 993 of the Companies Act 2006.

The allegations relate to the running of Ethical Forestry Limited, a tree-based investment scheme, between January 2008 and December 2015. Ethical Forestry Ltd was said to operate tree plantations in Costa Rica and sold investments, starting at £12,000, in fast-growing hardwood saplings on their sites, offering a return once the trees were grown, logged and sold.

The SFO investigation found that the directors defrauded around 3,000 UK investors over seven years, who collectively put around £70 million into the venture. Employees of Ethical Forestry Ltd would cold-call members of the public and offer pension reviews, using false company names (such as Pension Review Scheme and Richmond Solutions). The employees would then encourage people to withdraw their savings from legitimate pension schemes to invest in a tree planting project in Costa Rica.

Aside from the initial planting, no money was allocated to maintain the trees or keep up with commercial harvests, so the investors did not see any returns. The funds were alleged to have supported the directors’ lifestyles, including expensive holidays, high value properties, and luxury cars. £2.77 million of investor funds were said to have been diverted and used to administer a tax avoidance scheme for the directors’ own benefit. 

Initially the defendants had pleaded not guilty in March 2025; only to plead guilty to fraudulent trading in January 2026. The case had been listed for trial in May 2026 before Southwark Crown Court. The defendants are due to be sentenced in May 2026.