Immaanuveel: February 2026

Name and type of organisation: Immaanuveel (registered charity no. 1132782) 

Fundraising method: Face-to-face fundraising (private site), online fundraising platform  

Code themes examined: Use of funds, restricted campaigns, and complaints handling 

Code breach? Yes  

The complaint  

The complainant initially contacted the Fundraising Regulator in August 2023. The complainant reported their concerns that the charity had started a fundraising campaign to purchase a new church building, but the campaign was not clear about the price of the building. The complainant thought the fundraising campaign should have been stopped and the money returned to donors when the purchase was not successful. The complainant said the charity had not provided a response to their complaint.  

What happened? 

In 2019, the charity started a fundraising campaign asking for donations from members of the church and on a faith-based online fundraising platform. The church found a building which it hoped to buy and updated donors on the amount required. In 2020, the church found out the purchase was not successful, but the fundraising campaign continued. The church later made the decision to stop the fundraising campaign. However, it did not take down the page on the online fundraising platform. 

The charity placed the money raised into a completely separate charity bank account and has since used the funds to buy a new building. 

When the Fundraising Regulator contacted the charity, it initially declined to provide a response to the complaint, believing the complaint was made to hurt the reputation of the charity (as they had also approached two other organisations). They also thought as the complainant was no longer a church member, the charity was not required to reply. We thought the complaint deserved fair and balanced consideration from the charity, which eventually allowed us to provide the complainant with information related to their complaint. Following our own review of the information the charity provided, we found potential breaches of the Code of Fundraising Practice (the code) which required investigation. 

Our decision 

There were not any significant issues found with the fundraising campaign. The nature of a fundraising campaign to buy a building means this is likely to take some time, and there may be some unsuccessful attempts. We also understand in this case the Covid-19 pandemic made the process even longer. We found the charity updated donors appropriately. There was no information to suggest donors had asked for their donations back and been refused, and the funds were restricted. We therefore did not find a breach about the conditions attached to the donations. We did find that the charity did not include information about what would happen should the campaign fail within the fundraising material, and this was considered a breach.  

The charity did not have a complaints policy in place at the time of our investigation. It also did not have a policy about what it considered an unfounded or potentially reputationally harmful complaint. This made it difficult for us to assess its decision to not initially respond to the complainant due to the charity’s view that the complainant was acting in bad faith and was no longer a member of the church. We found the complainant was entitled to a response to their complaint, and this was therefore considered a breach.  

We noted the charity provided us with a response to the concerns when asked. We also advised the charity that any member of the public should expect to receive a response to a complaint about fundraising, they do not have to be a member of the church. Positively, the charity is in the process of completing these policies.  

We have also shared with the charity that from a regulatory perspective, all members of the church who donate are considered members of the public. Therefore, any fundraising campaign is a public fundraising campaign, needing the code to be followed and any concerns raised to be addressed.  

Code sections considered 

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

Section 2.4. Informing donors and treating people fairly 

Standard 2.4.3: breach identified  

Section 2.7. Using funds 

Standard 2.7.2: no breach identified 

Standard 2.7.5: breach identified

Our recommendations 

We recommend that: 

1. The charity completes a review of its fundraising policies and procedures, considering the requirements of the code. This should include (but is not limited to):
   • a publicly available complaints policy specifically for its fundraising; and
   • an unreasonable behaviour policy, including how the charity identifies unfounded and reputationally harmful complaints. 
      
2. The charity provides a written statement available to all potential donors to outline what will happen to funds should a campaign not be successful. (No longer applicable) 
    
3. The charity makes sure that all fundraising campaign information is consistent, including on its online fundraising platform. 
    
4. The charity creates a standard text to add to any future fundraising campaigns about what will happen to donations should a fundraising campaign be unsuccessful.  

Outcome 

Following our final decision the charity asked for our external reviewer to consider our decision in this case. However the external reviewer did not think that the reasons for this request met the criteria for review as per our process.  We will continue to work with the charity to support the implementation of our recommendations.