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The voice of Scotland’s vibrant voluntary sector

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TFN is published by the Scottish Council for Voluntary Organisations, Mansfield Traquair Centre, 15 Mansfield Place, Edinburgh, EH3 6BB. The Scottish Council for Voluntary Organisations (SCVO) is a Scottish Charitable Incorporated Organisation. Registration number SC003558.

Fundraising contractors need close monitoring says regulator in new report


Charities are responsible for fundraising carried out in their name

The Fundraising Regulator for England and Wales has today (26 March) published the findings of its first inquiry into the use of subcontracting in face-to-face fundraising.

The regulator’s recommendation to charities includes that subcontracting firms are monitored more closely and should receive appropriate training.

Charities and agencies also need to be satisfied that the payment model for fundraisers is appropriate and does not lead to bad practice.  

The market inquiry highlights how monitoring and oversight of subcontracted relationships are essential. Oversight should be rigorous enough for both charity and agency partners to be reassured that fundraising is being carried out safely and in line with the contract and the Code of Fundraising Practice.

Charities are ultimately responsible for fundraising carried out in their name, and therefore for the actions of all third parties they use to fundraise at each point in the supply chain.   

While the watchdog accepts that different charities will need different contractual arrangements, the report recommends that charities must have explicit discussions about whether subcontracting will be permitted in the contract with the main agency they contract with and expressly prohibited if not.

If subcontracting is permitted, charities and agencies must ensure that any subcontracted services are provided to a standard that is no less than that agreed in the primary contract.  

Training and monitoring should not be sacrificed or stretched for commercial considerations. Fundraisers must be well-trained and able to manage campaigns to a level that minimises the risk of poor behaviour and non-compliance with the Code of Fundraising Practice.    

The report also includes a recommendation to charities to ensure that fundraisers collecting on their behalf are remunerated in a way that reflects their skillsets and the values of the charity. While the Fundraising Regulator is not prescriptive about payment models, it remains the case that it is preferable that fundraisers should receive a living wage for their work.  

The inquiry also concluded that good fundraising partnerships should have a spirit of partnership that promotes positive behaviours, good workplace culture and oversight of the subcontracting supply chain.  

Face-to-face fundraising is a valuable and successful method for charities to raise money and to inform the public more about their cause. Nonetheless, the inquiry has concluded that there are important issues that need to be addressed by the fundraising sector. Charities and sub-contracted agencies should review their processes and take action to mitigate risks of poor practice.  

The Fundraising Regulator, The Chartered Institute of Fundraising and the Charity Commission for England and Wales are committed to working closely together around subcontracting for charities and agencies working in the sector.  

Jim Tebbett, head of proactive regulation and projects at the Fundraising Regulator, said: “As we have said before, it is crucial for charities to have a clear line of sight to those who fundraising in their name. It is clear from our inquiry and the workshops we ran with charity fundraisers and agencies that face-to-face fundraising is valuable for charities raising money for their causes, and there’s a widespread willingness to do the right thing. However, there are issues with subcontracting that need to be addressed by the charity sector.  

“We hope that through the recommendations made in the inquiry and our commitment to work closely with the Charity Commission for England and Wales, Northern Ireland and the Office of the Scottish Charity Regulator and Chartered Institute of Fundraising to issue more robust advice to the sector around the issue of subcontracting we can ensure more charities follow best practice and reduce incidents of poor practice that we have recently seen.”  

Holly Riley, head of strategic policy at the Charity Commission, said: “We welcome today’s report from the Fundraising Regulator which puts an important spotlight on the risks and issues that all trustees should be aware of when using subcontractors to fundraise on behalf of their charity.  

“As stated in our guidance, all charities should raise money in a considerate and responsible way, mindful that public generosity can never be taken for granted. We continue to work with the Fundraising Regulator in setting out expectations and supporting the sector to follow best practice.”

Regulation in Scotland is undertaken by the Scottish Fundraising Adjudication Panel.



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