This case summary was investigated using the 2019 Code of Fundraising practice, as the complaint was reported to us prior to 1 November 2025, when the new Code of Fundraising Practice was introduced.
Name and type of organisation(s): Atoma Union CIC (registered company no. 15686104) and Youth Works Union CIC (registered company no. 15790735)
Fundraising method: Collections – public (cash and card payments), street fundraising
Code themes examined: Fundraiser behaviour, licences and permissions
Code breach? Yes
The complaint
We received intelligence from a West Midlands local authority about possible street fundraising by Atoma Union CIC and its sister organisation Youth Works Union CIC without the correct permission. The local authority also raised concerns about inappropriate fundraiser behaviour.
We later received similar information from two local authorities in London, as well as complaints and enquiries from members of the public about the behaviour of fundraisers representing the CICs.
What happened?
Between May 2024 and December 2024, we received four complaints about possible street fundraising near Farringdon station. Two complaints described verbal and physical altercations with fundraisers.
We wrote to the director of both CICs. We explained that we had received complaints suggesting a possible pattern of aggressive and pressuring fundraising behaviour. We asked whether either CIC was actively fundraising on the streets and, if so, what process it followed to obtain the correct permissions.
Although the letter was signed for, we did not receive a response. We also tried to contact both CICs using the phone numbers on their websites, but neither number was valid.
In May 2025, we received intelligence from the Charity Commission for England and Wales. It explained that a local authority had raised concerns about fundraisers collecting cash and card payments in Leamington Spa town centre. The local authority confirmed that it had not issued a street collection permit. It also said it had received complaints from members of the public and Community Wardens, and described fundraisers as aggressive.
We wrote again to the CICs’ registered address asking for a response to the concerns raised but none was received.
A further letter went unanswered. This was re-sent by special delivery and again we received no response.
We also contacted local licensing teams in London. One council confirmed it had seen five to ten representatives at a time, usually following people outside Farringdon Station. Another confirmed that it had observed fundraising in 2024, including in the Covent Garden area. It said that no licence or permission had been issued and that their officers had issued warnings.
Our decision
In the absence of any information to the contrary, despite our repeated attempts to contact the CICs, we considered it reasonable, on the balance of probabilities, to conclude that both CICs were engaged in fundraising without the correct licences. We based this on stakeholder intelligence, complaints, enquiries about donations, and reports of money being exchanged for nothing in return. We received information from three local authorities indicating that both CICs had been actively soliciting funds. Two local authorities issued warnings instructing them not to fundraise without the correct licences.
We also considered concerns about fundraiser behaviour. One local authority described fundraisers as very aggressive. We received three complaints referring to behaviour that could be regarded as pressuring and, in one account, particularly aggressive.
We found that fundraisers representing the CICs were, in some instances, acting in a way that could reasonably be perceived as placing undue pressure on members of the public to donate.
Code sections considered
Code of Fundraising Practice, version effective 1 October 2019 (last updated 4 June 2021)
Section 1.1. General behaviour
- Standard 1.1.1: breach identified
Section 8.1. Behaviour when collecting money or other property
- Standard 8.1.1: breach identified
Section 8.2. Licences and permission
- Standard 8.2.1: breach identified
Our recommendations
Whilst both organisations considered in this investigation have since dissolved, we have decided to make recommendations to highlight the learning from this investigation for other CICs and charitable or philanthropic and benevolent organisations that may wish to consider engaging in street fundraising.
Should a charity or a philanthropic and benevolent organisation, such as a CIC, decide to undertake street fundraising, we recommend that it:
- Ensure that the appropriate licences and permissions are obtained before engaging in any public fundraising activities.
- Keep a record of all licences and permissions so that it can provide evidence if required.
- Familiarise itself with the code, paying particular attention to Section 1 (Behaviour when Fundraising) and Section 7 (Public Fundraising).
- Provide appropriate training to all its fundraisers so that they are aware of the requirements under the code as well as the behaviour expected.
- Ensure that it has adequate processes in place to monitor the behaviour of its fundraisers, and to take appropriate action where poor fundraising practices have been identified.
- Contact professional bodies such as the Chartered Institute of Fundraising for further guidance on street fundraising best practice.
Outcome
Both CICs had dissolved by the time we finalised our decision. We decided to proceed with the investigation to support learning within the sector, and the decision was shared with the companies’ director.
We will be sharing our findings with relevant stakeholders, the CIC regulator and the Metropolitan Police.