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Think tank calls for clarity on areas of proposed Code changes

Think tank calls for clarity on areas of proposed Code changes

Greater clarity on the proposed changes in the to the whistleblowing process, and the area on ensuring a charity’s values are reflected by the third parties it works with have been called for by fundraising think tank .

The Fundraising Regulator’s consultation on the Code of Fundraising Practice closes today.

In its consultation response document, Rogare says that while most of the changes proposed seem proportionate and sensible, greater clarity is needed in these two areas.

It believes that it should be made very clear that the whistleblowing process should be to report illegal activity or activity that is not compliant with the Code, and not to register complaints about a type of fundraising an employee’s charity is using.

The document states:

‘We would recommend that guidance on part i) of the new rules states that the whistleblowing process would be for breaches of the code of practice, or any other breaches of any other legislation or regulation (such as ASA rules, data protection, or fraud). It should be made clear that the whistleblowing process is not available to people simply to register their dislike of particular types of fundraising.’

In response to the Regulator’s proposed changes regarding ensuring the values of the organisation are reflected in the policies, performance objectives, indicators and, where applicable, the incentives of the third party, Rogare says it believes the Regulator should be policing facts, not values, both from a philosophical perspective and a practical one.

It states that ‘values are nebulous and it will be difficult in practice to decide whether the values of an organisation are reflected’, and adds:

‘We do not think it is the role of the regulator to become involved in regulating a charity’s values, or how it communicates those values. We think this could lead to any regulator exceeding its regulatory remit by imposing its own values about how the thing it regulates ought to be done, rather than sticking to the facts about how that thing is or isn’t done according to the code.’

The consultation opened in February, and is the Fundraising Regulator’s first into the Code. It has asked for views on:

  • Charity trustees
  • The fundraising ask
  • Solicitation (disclosure) statements
  • Raising concerns about fundraising practice (Whistleblowing)
  • People in vulnerable circumstances
  • Charity collection bags
  • Third parties
  • General questions on the Code


Melanie May is a journalist and copywriter specialising in writing both for and about the charity and marketing services sectors since 2001. She can be reached via

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