Market inquiry report: subcontracting in face-to-face fundraising
This report evaluates feedback from the workshops, analyses the discussions that took place in them and outlines our proposed next steps.
Download the market inquiry report 2024
Charities and agencies need to focus on due diligence and contract management
Although there were many examples of good practice, and a widespread willingness to do the right thing, both charities and agencies need to tighten their contracts and focus more on due diligence and contract management. Charity trustees should be assured by their executive teams that any fundraising partnerships comply with the Code of Fundraising Practice and reflect the values of their charity.
Recommendation to review processes and take action to mitigate risks
Every charity and agency that engages in face-to-face fundraising should review their processes and take action to mitigate risks of poor practice. Training and monitoring should not be sacrificed or stretched for commercial considerations. Charities and agencies should ensure that they can train fundraisers and manage their campaigns to a level that minimises the risk of poor behaviour and non-compliance with the code. Robust monitoring is also essential so that both the charity and agency partners can be reassured that fundraising is being carried out safely and in line with the contract.
Contractual relationships should be reviewed and discussed
While we accept 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.
Payment models for fundraisers should be appropriate to avoid bad practice
Charities should 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.
We will work closely with sector bodies to produce new or updated advice
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.
"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."
Jim Tebbett, Head of Proactive Regulation and Projects at the Fundraising Regulator