So you have the foundation, which has no assets in it, for liability purposes, and you're running this and you have your charity, which is providing services, and other groups...because in 18.4, it does say that you can use other groups within the WE group.
You say, “recover costs”. Are the costs defined? Who defines the costs? Do you define the costs? How do you load your overhead in? Are your salaries covered? Is all the remuneration that you've received covered into those costs? How do you determine what the costs are for your multiple companies that will be charged back to the foundation? It's clear: 18.4 says that you will contract to your other groups.