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FRSB finds RSPCA and Battersea Dogs & Cats Home breached Fundraising Code in Direct Debit campaign

FRSB finds RSPCA and Battersea Dogs & Cats Home breached Fundraising Code in Direct Debit campaign

The (FRSB) has upheld a complaint about donor recruitment campaigns for the RSPCA and Battersea Dogs and Cats Home.

The FRSB found that both charities, and their fundraising agency Fundraising Initiatives Ltd (FIL), had failed to comply with the Code of Fundraising Practice. The agency had been contracted to recruit donors for the charities who would give regularly via Direct Debit. The fundraising took place at several private sites, including supermarkets and shopping centres.

The FRSB judged that:

  • FIL had “misled site owners about the focus of its fundraising activities”
  • RSPCA and Battersea had failed adequately to monitor the agency’s compliance with the Code
  • all three organisations had breached the Code by failing to comply with the requirements of fundraising sites, where owners had prohibited the collection of Direct Debit payments.


The adjudication report follows a complaint from an individual that alleged that, between July and September 2015:

  • neither charity had been adequately monitoring the agency’s delivery of their fundraising campaigns
  • neither charity knew the specific locations where FIL was fundraising on their behalf
  • FIL had not made the site owners aware or obtained necessary permission for securing Direct Debit donations.
  • FIL fundraisers were not presenting the required solicitation statement to potential supporters.

When the complainant was not satisfied with the charities’ initial response, he took it to the FRSB in September 2015.

The FRSB was not able to judge the issue of whether the fundraisers would have completed the required solicitation statement because the complainant had not made a donation and the solicitation process had not been initiated. Nevertheless, the FRSB in its report underlined the importance for fundraisers to be fully briefed on the content of any solicitation statements. They should be able not only to deliver compliant fundraising pitches but also be able to answer more general questions about the campaign.

What is a solicitation statement?

A solicitation statement must, by law, be delivered by fundraisers whilst soliciting for donations from the public. Such a statement must name the fundraising agency in question, the name of the charity it is representing, the cost of the campaign (including the amount of remuneration given to the fundraising agency – in other words – the ‘notifiable amount’) and how that ‘notifiable amount’ has been calculated.


In October 2015, one month after the complaint was raised with the FRSB, FIL went into administration and the agency ceased trading.

The FRSB acknowledges in its report that “significant remedial action” has been taken by both the RSPCA and Battersea to address the shortcomings identified in this case.

This was one of the last adjudication rulings to be published by the Fundraising Standards Board, which has now been replaced by the . The report has been passed to the Regulator, which took responsibility for regulating charity fundraising on 7 July 2016.

Stephen Dunmore, CEO of the Fundraising Regulator, commented on the report, saying:

“This adjudication report identifies once again the need for charities to monitor closely the compliance of their fundraising agencies with the Code of Fundraising Practice and to comply with the requirements in relation to site-specific fundraising.   Effective monitoring of third parties is essential if donors are to be treated with respect and provided with the information necessary to make informed choices.

“The Fundraising Regulator is considering what further actions need to be taken arising from the report’s findings and recommendations.”

The adjudication report is available for download from the FRSB’s website.


Howard Lake is a digital fundraising entrepreneur. Publisher of UK Fundraising, the world's first web resource for professional fundraisers, since 1994. Trainer and consultant in digital fundraising. Founder of Fundraising Camp.

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