If you don't want to hear the answer, don't ask the question!
The CAA have never objected to CRI(SPA)s - such as 'PFA coaches' (or LAA-LAA coaches now) - conducting relevant NPPL conversion training for those who already hold a NPPL.
Hence there is an emergent NPPL route which uses Microlight instructors (who can be paid) for the NPPL(Microlight), then a CRI(SPA) (who cannot be paid without a CPL) to conduct SSEA conversion training......
The NPPL is issued by an ICAO member state. Don't stir things up unnecessarily please - it won't help anyone. And if you're
that concerned, then become a JAR-FCL FI(A)......
You'll be asking the CAA to rule on the PIC/Pu/t issue for club checks next....