The Fundraising Regulator has found 11 fundraising code breaches following an investigation into Great Ormond Street Hospital Charity (GOSH), its fundraising agency Acwyre and subcontractor IBA Global.

The probe was launched earlier this year after GOSH self-reported concerns raised by a journalist at The Times about the culture and behaviour of fundraisers working for IBA Global, a sub-contractor hired by the charity’s fundraising agency Acwyre.

The concerns raised by the journalist, who went undercover as fundraiser at IBA Global, focused on claims that pressure-selling techniques were being used to garner donations.

The regulator found that the contract between Acwyre and IBA was “insufficient” and lacked “important details about monitoring processes and compliance expectations”,

This made it “difficult for the charity to be confident that standards were being upheld by the sub-contractor”.

IBA Global’s training also failed to tackle poor practice such as targeting vulnerable people and using “unreasonable persistence” and “undue pressure”.

“The evidence suggested a performance culture at the sub-contractor which focused more on successful sign-ups than on following the fundraising standards in the code,” said the regulator.

“As the charity is responsible for all fundraising carried out on its behalf, the charity was found in breach of the code.”

The regulator is calling for GOSH to tighten up its arrangements with Acwyre and its use of subcontractors. The charity also needs to review and update its fundraising training, it adds.

GOSH has agreed to comply with and has already begun implementing the recommendations, says the regulator. It adds that Acwyre is changing the way it works and that IBA Global says it is not currently involved in charity fundraising.

“We will continue to work with all parties involved in this case to support in the implementation of our recommendations to appropriate timescales,” said Fundraising Regulator chief executive Gerald Oppenheim.

“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.

“This is particularly the case where an agency uses a sub-contractor, as charities are still ultimately responsible for the fundraising carried out on their behalf.”

'We deeply regret any distress caused'

A spokesperson for GOSH says the charity takes the findings "extremely seriously" adding "the breaches in our door-to-door fundraising practices were unacceptable, and we deeply regret any distress caused to the public and our supporters".

They added: "GOSH Charity does not condone any fundraising practices and behaviours that do not comply with the high standards we expect.

"As soon as concerns were raised, we stopped working with the subcontractor involved, reported ourselves to the Regulator and commissioned an independent investigation.

"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.

"The Regulator has recognised the positive steps we have already taken. We remain committed to working with it to implement all further recommendations as well as taking steps to go above and beyond charity sector best practice.

"Door-to-door fundraising is one of the most effective ways for us to raise much-needed money and engage with people."

Wider concerns around subcontracting in fundraising

This year the Fundraising Regulator published the findings of a market inquiry into the use of subcontracting in face-to-face fundraising by charities and their agencies.

This found that this area of fundraising is blighted by ‘sales oriented’ staff who have left the commercial energy sector, which has been moving away from door-to-door sales in recent years.

Earlier this month the Chartered Institute of Fundraising updated its guidance following this inquiry.

A spokesperson for the Chartered Institute of Fundraising said it expects its members to fully adhere to the fundraising code “in order to meet the high standards expected of them and to protect those members of the public with whom they are engaging”.

They added: “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.

“We are confident that GOSH Charity is committed to fundraising best practice through the steps it has already taken to improve its practices and behaviours, including self-reporting to the Fundraising Regulator when this issue first came to their attention, improving training, and strengthening their compliance processes and how they record and handle complaints.”

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