If you were asked to create an ethical fundraising policy, what would you do and where would you start?
With the latest wave of bad news stories – especially the Presidents Club scandal, which saw charities scrambling to hand back donations – I’ve been contacted for advice by several organisations who, quite sensibly, want to avoid getting in a similar position themselves.
An ethical fundraising policy sets out what your organisation is willing to do and not do in relation to fundraising, based on some agreed ethical principles. This often includes (but shouldn't be limited to) when you may choose to reject a donation.
If this sounds like a straightforward exercise, it shouldn’t be. It goes without saying that ethics aren’t black and white, so putting together this policy must involve careful thought and reflection.
Here are six guiding principles to keep in mind if you're creating an ethical fundraising policy:
1. Start a conversation - don’t search for a template policy
A common mistake is to assign this task to one member of staff, and ask them to find an example policy that can be adapted quickly for your organisation.
However, creating an ethical fundraising policy goes right to the heart of your appetite for risk, your charitable objects and the areas of particular sensitivity for your cause. As such, it's crucial that trustees and senior management are involved.
This process should start with a conversation. This is arguably the most important stage, since you need to debate different scenarios and views, and arrive at a position that feels right for your organisation. This is usually a thought-provoking exercise that improves everybody’s understanding and appreciation of the complexities involved. If you treat creating the policy as a box-ticking exercise, you’ll miss out on this valuable development opportunity.
2. Take a broad view – don’t over-react to one event
It's common to be prompted into action by a single event, like a high-profile bad news story. This isn’t a problem as such, but you shouldn't let it skew your whole approach.
In the wake of the Presidents Club scandal, many charities are focused on whether they should accept (or return) certain donations. However, this is only part of the puzzle – your policy may need to cover the ethical standards you expect your suppliers to meet, how you check those standards, and how you interact with vulnerable donors.
It's helpful to start by making a list of all the circumstances and ethical dilemmas your charity needs to consider. This should be informed by the types of fundraising that you do and your existing risk assessment, as well as by external events.
3. Define your attitude towards risk – avoid making decisions that you’ll reverse later
Keeping everyone happy is rarely possible, as recent developments show. Many people were outraged that charities like GOSH had accepted donations from the Presidents Club, but others were reportedly angry when they considered handing them back.
There are no right or wrong answers, so you need to judge what feels appropriate for your organisation, anticipate how your supporters and beneficiaries might react, and be prepared to justify your decision. It's no good having a policy in place, then caving in as soon as you put it into practice and people object.
Defining your organisation’s attitude towards risk is essential – this is why trustees and management must be involved. Accepting some donations can be risky, but being totally risk-averse is a risk in itself – it can demoralise staff, or damage your financial position. This is inevitably a sensitive balancing act. It may be helpful to consult key donors and beneficiaries when creating your policy, to anticipate objections in advance.
4. Make it relevant to your cause – don’t be over-simplistic
When defining whether to accept or reject donations from individuals and companies, you may be tempted to start by creating a list of 'no go' areas, like if they are linked to alcohol, drugs, gambling or pornography.
Unfortunately, the world isn't that simple - household name companies sell alcoholic products, and established publishing companies produce pornographic magazines. If you're not careful, you could find yourself turning away a lot of donations!
You need to be more specific and mindful of your cause and charitable aims. It's not about what staff or trustees personally think is ethically correct, but whether a donation might damage your mission or beneficiaries. An animal welfare charity might be reluctant to accept a donation from a cosmetics company, but happy to do so from an alcohol brand - whereas an addiction charity might take the opposite view.
5. Include specific processes and procedures - not just general guidelines
Your policy should not only set out your position, but explain how to action it - for example, do you subject donations over a certain amount to more rigorous background checks? What do those checks involve? How do you go about reporting serious incidents?
This will help staff to put your policy into action, and also show anybody reading it that you're serious about fundraising ethically, rather than just treating it as a tickbox exercise.
6. Make your policy part of the bigger picture - don't see it as enough in isolation
It's tempting to sign off your ethical fundraising policy and assume it's 'job done' - but in reality, this is an ongoing commitment and part of a larger compliance picture.
Your policy shouldn't just sit in an obscure corner of your shared drive. It must be an ongoing reference point that's displayed clearly for staff to refer to when needed, and part of induction processes for staff and volunteers. Fundraisers should feel able to raise any concerns or discuss situations they feel unsure about. Management and trustees should review your policy periodically, in response to changing fundraising practices, issues affecting the sector, and changes to your own fundraising portfolio and risk assessment.
Aside from creating an ethical fundraising policy, you may also want to, for example, review your Data Protection compliance ahead of the arrival of GDPR, ensure your trustees are aware of their legal fundraising duties as set out in the Charity Commission's CC20 document, or produce a short supporter promise outlining your commitment to good fundraising (I've always liked this example from Mind).
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