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: We R Blighty Community Interest Company (registered company no. 14349080)
Fundraising method: Collections – public (cash), digital - social media
Code themes examined: Misleading information, evidencing claims, fundraiser behaviour, licence and permissions, working with others (professional fundraisers)
Code breach? Yes
The complaint
We R Blighty is a community interest company (CIC) that fundraises for UK service veterans and employs them to do this fundraising. The investigation was launched because of ongoing regulatory concerns, following multiple complaints received between October 2023 and June 2024. The complaints, and information from the public, local authorities, and other organisations, all raised similar concerns. This included whether the CIC had appropriate licences and permissions to carry out street fundraising, claims made by the CIC verbally and in its fundraising materials, and the behaviour of its fundraisers that was seen by donors to be unprofessional and aggressive.
Because this was a fairly new CIC with charitable aims, we met with its founder and director in June 2024 to better understand its fundraising practices. During the meeting, he explained that fundraisers were self-employed, that employing veterans was one of its charitable aims, and that the organisation faced challenges in obtaining fundraising licences. He also expected court action from the City of London Police about fundraising in their jurisdiction. Following this meeting, and further public complaints, we decided to open a formal investigation in July 2024.
What happened
On 19 July 2024, we wrote to the CIC about our investigation, and asked for information, including details on fundraising materials and solicitation statements, fundraiser contracts and payment structures, and training. We also asked for information on licensing and permissions, communications with local authorities, fundraiser conduct, and its links with other organisations. The CIC responded to all our requests for information and repeated its position that legislation does not require it to have any licensing or permissions to fundraise in public. The CIC also explained that they had plans to begin selling a magazine.
During the investigation, we were contacted again both by complainants and public bodies explaining that the CIC was fundraising without permission. Members of the public also reported fundraisers being aggressive and overly persistent. In October 2024, we were contacted by two separate public bodies that provided credible information that the CIC was regularly fundraising without local authority permission in Kent, and without permission from the Metropolitan Police across three sites in central London. On 25 June 2025, the CEO pleaded guilty to a number of offences under the Police, Factories, etc. (Miscellaneous Provisions) Act 1916 about unauthorised fundraising by the CIC at City of London Magistrates Court.
Our decision
Licences and permissions
Information from the CIC, complainants and various authorities have all clearly shown that the organisation has been fundraising in public without the correct permissions. While the CIC explained they believed such permissions were not required, the evidence available, including the City of London court action against the CIC, clearly shows this is not the case.
Misleading information and behaviour when fundraising
From the information available, we concluded that it was more likely than not that donors could have been misled by confusing messaging or fundraising materials. This includes materials suggesting a link with a well-known national veterans’ charity, which the CIC has since confirmed it does not work with. We were also concerned about the costings in some of the fundraising materials that the CIC could not show good enough evidence for. There was also enough information available for us to conclude on balance that some fundraisers for the CIC acted in an aggressive and unprofessional way towards both potential donors and public officials.
Working with others – professional fundraisers
The CIC confirmed that its fundraisers are self-employed. This is allowed under the Code of Fundraising Practice (the code), but as these fundraisers still meet the legal definition of professional fundraisers, the charitable organisation employing them is responsible for them and their behaviour. We found that the CIC did have agreements in place to manage this, but that these did not meet all the standards required under the code. In particular, there was not enough monitoring in place to make sure that fundraisers kept to the code, or procedures to review the arrangements in place to support compliance.
Code sections considered
1.1. General behaviour
- 1.1.1 Breach identified
- 1.1.2 Breach identified
- 1.1.3 Breach identified
1.3. Informing donors and treating people fairly
- 1.3.1 Breach identified
- 1.3.2 Breach identified
7.2. Contracts and agreements
- 7.2.1 No Breach identified
- 7.2.4 Breach identified
- 7.2.9. Breach identified
7.3. Monitoring that fundraisers are meeting the code
- 7.3.1 Breach identified
8.2. Licences and permission
- 8.2.1 Breach identified
Our recommendations
If We R Blighty continues to fundraise in the same way it is currently doing, we recommend that the CIC:
- Reviews all onboarding and training materials to include explicit expectations of compliance with the code and standards required by fundraisers operating with the public, both on the street and on private sites. This includes standards of behaviour while fundraising, training on how to protect potentially vulnerable donors, handling of complaints and performance management.
- Introduces agreements with professional fundraisers that comply with legal requirements and the standards in the code.
- Introduces arrangements for monitoring its third-party fundraisers to make sure that they keep to the code. This should include arrangements for regular reviews of the performance of its fundraisers.
- Urgently creates a complaints policy and makes this publicly available to better manage fundraising concerns.
- Puts into place a system for recording and responding to complaints.
- Only fundraises where it has the necessary permissions and licences as required by the relevant bodies or authorities.
If the CIC does change its operating model so that its current third-party fundraisers become vendors of newspapers or periodicals, we recommend:
- If it decides to continue to fundraise, it must obtain the necessary licences and permission before it does so.
- In addition, it should comply with standard 7.2.5 of the code, which requires a written agreement with third-party fundraisers if they will be selling goods or services.
- If it decides it will not continue to fundraise, and only to sell newspapers or periodicals, we expect the CIC to cease public fundraising activities and make sure its vendors do not continue to ask for donations, unless it has obtained the necessary licences and permissions.
Outcome
The CIC has confirmed that it has accepted our findings and explained that it is taking steps to engage with our recommendations. We will continue to liaise with the CIC to ensure it is meeting our recommendations.