British Limbless Ex-Service Men's Association (BLESMA): April 2026

Name and type of organisation(s): British Limbless Ex-Service Men's Association (BLESMA) (registered charity no. 1084189); St Helena Hospice Limited (registered charity no. 280707); SKW Southeast Ltd (a limited company)

Fundraising method: Door-to-door fundraising for a lottery / regular giving

Code themes examined: Treating donors fairly, complaint handling, house-to-house collections, agreements with third-party fundraisers, monitoring third-party fundraisers

Code breach? Yes 

The complaint

The complaint was about door-to-door fundraising directed at a potentially vulnerable person living in a private retirement community where cold calling was not allowed. The complainant said their parent had dementia, was partially sighted and had no clear recollection of the visit. They also said the donor’s contact details had been recorded incorrectly. The complaint was later referred to us as part of wider concerns about fundraising activity at the donor’s residence. 

What happened?

In April 2024, the complainant contacted the charity after discovering that their parent had been recruited for regular lottery payments. The fundraising was carried out through a chain of organisations. Blesma had an agreement with another charity St Helena Hospice Limited (“SHH”), which carried out the activity through its wholly owned subsidiary. SHH also contracted with another company, SKW Southeast Ltd (“SKW”) which employed the fundraiser involved in the complaint. SKW has since been dissolved.

The complainant explained that the donor lived in accommodation for over-50s where signs said cold calling was not permitted. They were also concerned that the donor was vulnerable because they had dementia and were partially sighted. They said the donor did not clearly remember the visit, and that the details recorded during the sign-up process were wrong.

SHH, handling the complaint, agreed that the donor’s home was in an area with “no cold calling” signs. It apologised, returned the payments and wrote on the charity’s behalf to every donor recruited in the same residential area to explain the error and offer them the chance to cancel. It also carried out a site visit, gave the fundraiser a verbal warning, added refresher training on vulnerable people, introduced extra checks during welcome calls and subsequently removed the fundraiser from future campaigns.

We investigated both the incident itself and the wider arrangements behind the fundraising. This included looking at whether the fundraiser should have identified the donor as potentially vulnerable, whether the “no cold calling” signs should have stopped the approach, how the complaint was handled, and whether the charity had enough control over fundraising carried out on its behalf through its supply chain. 

Our decision

We found it was more likely than not that the donor’s circumstances should have made it apparent to the fundraiser that they were potentially vulnerable. The donor’s details were recorded incorrectly, including their name and address, and an email address was collected even though the donor reportedly did not have one. On balance, we found this suggested the donor was having difficulty providing information and that the fundraiser did not take the additional care that should have followed. We therefore found breaches of the code relating to treating donors fairly.

We did not find a breach in relation to complaint handling. We were satisfied that the response to the complaint was thorough and proportionate, and that lessons were acted on. We considered it a positive outcome that after receiving the complaint, SHH proactively wrote to other donors recruited in the area to ensure they were happy to continue giving.

We found a breach of the rule on house-to-house collections because the fundraiser knocked on doors in a residential area where signs made clear that cold calls were not permitted.

On wider governance and oversight of the third-party fundraisers/fundraising agencies, we found that the charity had written agreements in place and did not breach the code requirement to have a contract.

The standards governing agreements with professional fundraisers do not apply directly to the agreement between the two charities. However, we considered that as a matter of good practice this should meet the same requirements.  

We also found that the onward agreement between SHH and SKW did not include all the protections required by the code. However, we could see that the charity had policies and processes to address these concerns.  We therefore concluded that Blesma breached technical standards relating to contracts and monitoring. 

We acknowledged that the arrangement differs from the more traditional model where charities contract directly with fundraising agencies, in that SHH effectively manages fundraising for several other charities.  We did not consider that there was evidence of serious systemic failings in its handling of these relationships. We nevertheless found that the general principle that Blesma must take overall responsibility for its fundraising applied to these agreements.  

Code sections considered

Code of Fundraising Practice, version effective 1 October 2019 (last updated 4 June 2021)

1.3. Informing Donors and Treating People Fairly

• Standard 1.3.7: breach identified
• Standard 1.3.8: breach identified
• Standard 1.3.9: breach identified

Section 2.1. General Duties

• Standard 2.1.1: Breach identified

Section 2.4. Complaints and concerns about fundraising

• Standard 2.4.3: no breach identified
• Standard 2.4.4: no breach identified

Section 7.2. Contracts and agreements

• Standard 7.2.1: no breach identified
• Standard 7.2.4: no breach identified
• Standard 7.2.8: no breach identified
• Standard 7.2.9: breach identified

Section 7.3. Monitoring that fundraisers are meeting the code

• Standard 7.3.1: breach identified

Section 8.4. Further standards that apply to particular locations and activities

• Standard 8.4.3: breach identified 

Our recommendations

The fundraising activity that gave rise to the complaint breached code standards relating to treating donors fairly and house-to-house collections. We consider that SHH’s response to the complaint on Blesma’s behalf was comprehensive, and sufficient to remedy these breaches. We are not making any recommendations in relation to these.

Having considered the information we have seen concerning Blesma’s overall control over this method of fundraising, we recommend that it should:

• Review its contract(s) with SHH and other professional fundraisers it works with (including any subcontracted organisations) and ensure that these meet the requirements of the law and the code which apply to contracts with professional fundraisers. We acknowledge that the arrangement between the two charities differs from the more traditional model where charities contract directly with fundraising agencies and not strictly subject to these requirements, however under the principle set out in standard 2.1.1 Blesma (and other charities working with SHH) should have the same protections over fundraising throughout the supply chain.
• Consider its procedures for monitoring fundraising carried out by SHH and any other professional fundraisers it works with (including any subcontracted organisations) and implement additional measures to ensure that it is regularly monitoring their performance and compliance with the code. This might include:
  • Defining procedures for monitoring and learning from complaints received about its fundraising
  • Ensuring it has oversight of any subcontracting agreements its agents enter into
  • Performing its own checks on welcome calls carried out for its new supporters
  • In-person visits to its agents’ offices and/or shadowing fundraisers – including subcontracted workers.

Outcome

The response to the original complaint included an apology, the return of payments, contact with other donors recruited in the same residential area, refresher training on vulnerable people, extra welcome-call checks and the removal of the fundraiser from future campaigns. We will continue to liaise with the charity to support its compliance with our recommendations following our investigation.