The Fundraising Regulator has found 11 breaches of its code of practice after investigating Great Ormond Street Hospital Charity (GOSH), fundraising agency Acwyre, and subcontractor IBA Global.
GOSH had reported itself to the regulator, after an undercover reporter from the Times last year uncovered concerns about “pressure-selling tactics”, performance culture and the behaviour of fundraisers working for IBA Global.
The subcontractor had been hired by agency Acwyre, which had a contract with the charity.
GOSH previously opened its own external investigation and had filed a serious incident report to the Charity Commission in relation to the Times’ findings.
Insufficient contract
The regulator found that the contract between the agency and the subcontractor was insufficient, as it reportedly “lacked important details about monitoring processes and compliance expectation”, making it difficult for the charity to be confident that its standards were being upheld.
It found that the subcontractor's training materials did not cover everything required – including details about unreasonable persistence, undue pressure, and vulnerable circumstances.
Additional evidence uncovered by the regulator also suggested a performance culture at the subcontractor which “focused more on successful sign-ups than on following the fundraising standards in the code”.
The Fundraising Regulator has made several recommendations to GOSH regarding its arrangements with Acwyre, including its use of subcontractors.
It recommended that Acwyre should review its campaign agreements with relevant subcontractors, and that both GOSH and the agency consider their monitoring and compliance arrangements with the subcontractor.
It urged the charity to review and update its own training materials about the code, and recommended that the subcontractor aims to ensure an appropriate performance culture for charitable fundraising.
GOSH has agreed to comply with and has already begun implementing the regulator’s recommendations.
Acwyre has also begun to make changes to activies while IBA Global states it is not currently undertaking any charitable fundraising.
Gerald Oppenheim, chief executive of the Fundraising Regulator, said: “We are pleased all parties worked positively with us during the investigation, cooperated by sending us the information we needed. We had constructive dialogue with the charity and the agencies throughout.
“We understand the value to charities in using agencies to assist with their fundraising.
“However, it is vital that charities have oversight and effective monitoring of the work agencies are carrying out on their behalf to make sure their charitable values are upheld.”
GOSH taking findings ‘extremely seriously’
A GOSH spokesperson said: “We take the findings of the Fundraising Regulator extremely seriously and welcome all their feedback and recommendations.
“The breaches in our door-to-door fundraising practices were unacceptable, and we deeply regret any distress caused to the public and our supporters.
“GOSH Charity does not condone any fundraising practices and behaviours that do not comply with the high standards we expect.
“Over the past 18 months, we’ve tightened our agency relationships, strengthened compliance, improved fundraiser training and enhanced how we record and learn from complaints.”
Responding to the publishing of the investigation outcomes, a spokesperson for the Chartered Institute of Fundraising said: “The concerns investigated by the Fundraising Regulator must be taken very seriously and used as lessons learned in future to ensure this does not happen again.
“GOSH Charity also played a pivotal role in the development of the Chartered Institute of Fundraising’s new guidance around face-to-face fundraising partnerships – using their own experiences and lessons learned to advise on areas of improvement, particularly around compliance and the importance of having clear oversight of who is representing your charity when subcontracting is involved.”
Civil Society has contacted IBA Global and Acwyre for comment.
