Friends of the Nation’s Libraries: November 2025

Name and type of organisation(s): Friends of the Nation’s Libraries (registered charity no. 313020) 

Fundraising method: Not known 

Code themes examined: Charity governance (fundraising) 

Code breach? No for the charity’s obligation to carry out due diligence, yes for their failure to have a complaints policy (since remedied) 

The complaint 

The complainant was unhappy because they believed Friends of the Nation’s Libraries (‘the charity’, formerly Friends of the National Libraries) failed to carry out any due diligence when accepting a large donation from a source the complainant viewed as controversial. They were also unhappy with how the charity handled their complaint. 

What happened? 

The charity carried out a well-publicised and successful fundraising campaign aiming to raise £15 million. Its goal was to buy an extremely valuable collection of historically significant books and manuscripts from prominent British authors, including Jane Austen. 

As part of this campaign, the charity contacted a grant-making foundation (‘the foundation’) which was linked to a person the complainant thought was controversial. The foundation was an internationally recognised body which had given donations to a large number of national UK institutions, and whose founder was knighted in 2017. The foundation offered to donate £7.5 million toward the charity’s goal. 

The charity accepted this donation by legal agreement in November 2021. It raised the balance of the target amount from other sources and legally committed to buying the collection in December 2021. 

The complainant contacted the charity in March 2022. They explained that they were concerned about the foundation’s patron. The complainant urged the charity to refuse the donation from the foundation. However, the donation had already been accepted by the charity around three months earlier, and the charity had already purchased the library.

The charity said that it carried out due diligence on all large donations. The complainant asked for more information about what checks the charity had done and received no reply. In March 2023, they asked for a copy of the charity’s complaints policy and again did not receive a reply. The complainant then referred the matter to the Fundraising Regulator. 

Our decision 

The Code of Fundraising Practice (the code) says that charitable organisations must carry out due diligence “appropriate for the size and nature of the donation”. It follows that when accepting a very large donation, as in this case, charities should 
take the utmost care. We asked the charity to outline the steps it took to make sure that it was appropriate to accept the donation. 

The charity could explain the due diligence steps that had been taken, including that it had formed a committee to review the donation. However, the charity was unable to provide any note or record of the decision to accept the donation. The failure to record such due diligence was not a breach of the code.

We decided, in this case, the high-profile nature of the campaign meant the charity had the unusual opportunity to liaise with the Department for Digital, Culture, Media & Sport (DCMS) and other national bodies which would not otherwise have been possible. It also publicised the donation widely, including in its annual report, which made sure the decision was transparent. We decided this was sufficient in this case. For these reasons, we found the charity did not breach the code in relation to carrying out due diligence on the donation. 

The charity explained that it has no staff resources and no permanent employees, relying largely on volunteers, and does not often carry out fundraising. We found that it breached the code in failing to have a complaints policy.  

Code sections considered 

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

• Standard 2.3.3: no breach identified
• • Standard 2.4.1: breach identified

Our recommendations 

None.

Outcome 

Since we opened our investigation, the charity has set up an ethics committee for the purpose of reviewing any future donations that are more than £20,000. The charity is aware of, and has reviewed, the Charity Commission’s guidance on due diligence, referred to above. The charity keeps formal minutes from meetings of the committee. We are therefore satisfied that the charity has taken the opportunity to learn from the complaint and strengthen its processes. It has also put an appropriate complaints policy in place. 

External Review 

This was requested by the charity when we issued our final decision. They did not dispute the investigation findings but felt that the decision and case summary were not presented fairly. The external reviewer agreed with the charity that some irrelevant factors had influenced the way that the outcome of the investigation was presented. We accepted the external reviewer’s recommendations and the wording of the investigation decision and the case summary was revised.