Great Ormond Street Hospital Charity, Acwyre Ltd and IBA Global Ltd: August 2025

Name and type of organisation: Great Ormond Street Hospital Charity (registered charity no. ‍1160024), Acwyre Ltd (company no. 07570871) and IBA Global Ltd (company no. 04814261) 

Fundraising method: Door-to-door, regular gift fundraising  

Code themes examined: Third-party fundraising arrangements and contracts, fundraiser behaviour, monitoring and compliance. 

Code breach? Yes  

In January 2024, the charity submitted a self-report to us. This followed contact from a journalist at The Times, who raised concerns about the performance culture and behaviour of fundraisers working for a sub-contractor. The sub-contractor had been hired by an agency working on behalf of the charity.  

We opened an investigation, considering information from the journalist, the charity, the agency, and the sub-contractor. We also reviewed: 

• contracts between the parties
• training materials
• the charity’s monitoring of third-party contractors
• compliance and review arrangements; and
• internal reports about the agency’s performance. This included an external and independent investigation the charity had commissioned.  

All parties worked positively with us during the investigation.  The charity sent lots of helpful information and had ongoing constructive dialogue with us throughout.  

Third-party fundraising arrangements and contracts 

The charity’s contract with the agency was detailed and set clear expectations in line with the Code of Fundraising Practice (the code).  

The agency was contractually responsible for the performance of the sub-contractor.  However, we found the contract between the agency and the sub-contractor was insufficient. It lacked important details about monitoring processes and compliance expectations. This would have made it difficult for the charity to be confident that standards were being upheld further down the supply chain. 

It is a positive step that the charity now reviews contract templates agencies use with sub-contractors. It is also positive that the agency has increased its own capacity to do compliance work.  

Fundraiser behaviour 

The sub-contractor’s compliance-related training materials did not cover everything that was needed – including details about unreasonable persistence, undue pressure, and vulnerable circumstances. This information was clearer in the charity’s own training material, but there were still some gaps. Overall, the evidence suggested a performance culture at the sub-contractor which focused more on successful sign-ups than on following the fundraising standards in the code. We found several separate behavioural compliance issues at the sub-contractor and one of the fundraisers of concern was responsible for training others.  

The charity is ultimately responsible for all fundraising carried out on its behalf. In this case, the behaviour of fundraisers, as experienced by potential donors, was shown as directly linked to compliance concerns at the agency and the underlying issues we identified during our investigation. We have considered the breaches of the code in light of this, finding the charity in breach where there are concerns further down the fundraising supply chain.   

The charity has completed further work on its training programme for fundraisers, including the material of its sub-contractors, which will increase compliance at the doorstep.  

Monitoring and Compliance 

The charity showed a good approach to the monitoring and compliance of the agency’s activities and is clearly committed to its obligations in this area. The agency’s activities were largely around the monitoring and compliance of its sub-contractor. It appeared that the charity provided information to the agency via its reviews. The agency was responsible for making sure the sub-contractor took any required actions. This was not an unusual practice within the sector at the time. 

We did not see a clear approach by the agency to ensuring compliance. Its activity mainly focused on responding to individual complaints. Given this, and the concerns about fundraiser behaviour witnessed, we found the arrangement was insufficient. It limited the effectiveness of the charity’s own monitoring, compliance and review processes. However, it is positive that the agency and the charity have since expanded their compliance teams.  

The charity had an effective complaint handling process and showed how it learned from the complaints received. However, the agency was found to be lacking in this area. Further work is being undertaken with the agency to address this.

Other areas of the code 

Our investigation showed that the charity was compliant in relation to solicitation statements, its payment of fundraisers, and seeking consent for use of personal data.  

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

Section 1.2. Asking for support 

• Standard 1.2.1: breach identified (charity, agency and sub-contractor)
• Standard 1.2.2: breach identified (charity, agency and sub-contractor) 

Section 1.3. Informing donors and treating people fairly 

• Standard 1.3.1: breach identified (charity, agency and sub-contractor)
• Standard 1.3.9: breach identified (charity, agency and sub-contractor) 

Section 2.1. General duties (Responsibilities of charitable institutions and those who govern them) 

• Standard 2.1.1: breach identified (charity) 

Section 2.4 Complaints and concerns about fundraising 

• Standard 2.4.3: no breach identified (charity)
• Standard 2.4.4: breach identified (charity) 

Section 2.5 Paying fundraisers 

• Standard 2.5.4: no breach identified (charity)
• Standard 2.5.5: no breach identified (charity) 

Section 3.5 Direct marketing    

• Standard 3.5.2: no breach identified (charity) 

Section 7.2. Contracts and agreements 

• Standard 7.2.4 breach identified (charity)
• Standard 7.2.9 breach identified (charity) 

Section 7.3 Monitoring that fundraisers are meeting the code. 

• Standard 7.3.1 breach identified (charity)
• Standard 7.3.2 breach identified (charity) 

Section 7.4. Solicitation (disclosure) statements for paid third-party fundraisers and commercial participators   

• Standard 7.4.4: no breach identified (charity) 

Section 8.3 Exemptions   

• Standard 8.3.1 breach identified (charity and agency )

We recommended that: 

1. The charity reviews its arrangements with the agency, specifically:

• Its use of subcontractors, and the way due-diligence and responsibility for performance in this context is defined, for both closed and open network contracts.
• The level of detail required within the agency and sub-contractor’s agreement about the agency’s monitoring and compliance activities and the sub-contractor’s reporting requirements.
• Increased clarity about how the agency ensures sufficient, effective and regular oversight of the day-to-day activities of any sub-contractor. 
   

2. The agency reviews its Campaign Agreements with relevant sub-contractors and provides specific details regarding:

• Its monitoring and compliance activities of the sub-contractor’s compliance with the code, including the method and frequency.
• The sub-contractor’s specific obligations regarding the code and its requirement to protect donors.
• The subcontractor’s reporting requirements for its own methods of ensuring compliance and their effectiveness.
   

3. The charity and the agency consider their monitoring and compliance arrangements with the sub-contractor, specifically:

• Oversight of training material and training sessions provided to fundraisers which relate to expectations set out in the code.
• The sub-contractor’s assessment tools for fundraiser knowledge of and adherence to the code.
• The sub-contractor’s ability to identify and respond adequately to thematic concerns identified within complaints or from any relevant party.
• The charity should also consider its ability to understand and influence the performance culture created for fundraisers working on behalf of the charity. 
   

4. The charity continues to review and update its own training materials about the code to:

• Ensure that it reflects the most up-to-date information from the Fundraising Regulator.
• Provides clarity on the practical applications for fundraisers.
• Clearly defines and quantifies expectations related to undue and unreasonable pressure for those fundraising on the charity’s behalf.
• Ensure this level of detail is reflected in all code compliance training material provided to its fundraisers.  
   

5. The charity and the agency consider its categorisation and interpretation of complaints data. This should include:

• The methodology of how complaints data is recorded and interpreted so it can readily identify any potential harms and non-compliance, and the root causes for this. 
• What indicates a ‘concerning’ number of complaints as a ratio of the activity and whether there may be other helpful indicators to review and analyse.
• The agency’s categorisation of the severity of complaints to reflect the importance of code adherence and the corresponding actions required.  
   

6. The charity considers further ways to identify potential thematic compliance issues within the full supply chain in addition to feedback obtained from complaints.  
    
7. The sub-contractor develops its ability to ensure an appropriate performance culture for charitable fundraising. This should include:

• An appropriate level of detail about the requirements set out in the code, including undue pressure and unreasonable persistence; informed consent; vulnerable circumstances and use of personal information.
• Inclusion of the practical application of the code’s requirements as it relates to expected behaviour of fundraisers on the doorstep.
• Assessment of a fundraiser’s understanding of the compliance requirements placed upon them.
• Emphasising the importance of the code as a central theme in the information and training provided to fundraisers.