Munnyspinner,
I disagree with your interpretation of the above. The beneficiary of the valuable consideration would need to be the operator of the aircraft for this to be the case.
I suggest you read the CAAs interpretation:
http://www.caa.co.uk/docs/1428/summa..._transport.pdf
4 How to determine whether or not a flight is public transport.
4.1 To determine whether or not a flight is for the purpose of public transport of passengers, the first question is whether or not there are any passengers on board. This is not always entirely straightforward as an occupant may claim to be a member of the crew.
4.2 Having determined that there is at least one passenger on board, the next question is whether any payment has been given or promised which, if it had not been given or promised would mean that the passengers would not have been carried. If there is any payment which could fall into this category, consider what would have happened if the passenger had presented himself for carriage and announced that such a payment would not now be made. Would he still be carried?
No mention of the Operator, or who the payment is made to! Payment is for the raffle ticket, which is for the purpose of winning the flight; the fact that it does not pay for the flight is not relevant.
The following is a Flying Order taken from a CAA Recommended FOB
Order No 16 - Charity Flights
16.1 The carriage of a passenger on a private flight assumes that no money has changed hands for the purpose of the flight , other than cost sharing as described in ANO Art 130. Occasionally, unsuspecting pilots may offer a flight as a raffle prize at the local school or fete. Such a flight then becomes a public transport flight under UK law. Where the money paid for the ticket goes to a registered charity, and then subject to meeting certain requirements a private pilot may conduct this flight. The circumstances and requirements for Charity Flights are published in AIC 50/2000 (White 20)