Against Breast Cancer and Recycling Clothes Company Ltd: December 2019 (1)

Name and type of organisation/s: Against Breast Cancer (registered charity no. 1121258) a health charity, and its agency, Recycling Clothes Company Ltd

Fundraising method: Charity bags

Code themes examined: the delivery of a charity bag to a ‘restricted address’, complaint handling, learning from complaints and the charity’s monitoring of third parties

Code breach?

  • Against Breast Cancer: Yes
  • Recycling Clothes Company Ltd: Yes

The complaint

The complainant made a complaint to Against Breast Cancer (the charity) regarding an unwanted charity bag that was delivered on its behalf by Recycling Clothes Company Ltd (RCC – the agency). In response, the charity told the complainant that their address would be suppressed to stop them receiving further charity bags. Subsequently they received two further charity bags.

What happened?

In addition to displaying a ‘no charity bags’ sign, the complainant took the step of complaining to the charity and having their address suppressed. This should have acted as an additional safety measure to prevent unwanted charity bag deliveries. Despite this, the agency went on to deliver another unwanted charity bag, at which time the entire street was suppressed. This did not prevent the third charity bag delivery eight months later.

We could see that the agency investigated why the complainant received its charity bags. In one delivery, the distributor said that they missed the sign and were unsure of which side of the road was applicable to the ‘restricted address’ house number. The agency said that another unwanted delivery was partly caused by a distributor’s map getting wet and becoming illegible, which obscured the fact that the complainant’s entire street was suppressed. We also reviewed how the charity were monitoring its agency’s compliance with the Code of Fundraising Practice (the code). The charity’s agreement with the agency contains the requirement on the agency to adhere to the code and to include this in its training of new and existing staff. We could see that the charity’s monitoring included thorough meetings with senior staff at the agency.

We have seen no evidence that the agency took any learning from the fact that the distributor could not identify which side of the road was applicable to the ‘restricted address’ house list and why the distributor missed the ‘no charity bags’ sign.

Our decision

We found that in continuing to deliver charity bags to the complainant, despite the presence of their ‘no charity bags’ sign and their address being suppressed, the agency breached the requirements of the code not to deliver charity bags to householders with a ‘no charity bags’ sign and engaged in fundraising that was unreasonably persistent.

However, we found that the agency had investigated the complaint. Therefore, we found that the agency had not breached the code in relation to complaint handling.

We were not satisfied that the agency had demonstrated sufficient learning from the complaints to prevent a recurrence. We therefore found that the agency had breached the section of the code in relation to acting on the learning from complaints.

We found that the charity responded appropriately to the complaints and had not breached the section of the code in relation to complaint handling. We found that the charity required the agency to adhere to the code. On this basis, we found that the charity had not breached this area of the code.

However, we found that the charity breached the code on monitoring third parties by not taking all reasonable steps to ensure the agency’s ongoing compliance with the code, nor demonstrating sufficient learning from complaints.


We recommended that the agency:

  • suppresses a quarter of a mile radius of the complainant’s address to minimise the risk of further charity bags being delivered to the complainant;
  • updates its policy and training in relation to situations where distributors cannot identify a restricted address; and
  • identifies whether the two distributors who delivered charity bags to the complainant have any further training needs in relation to observing ‘no charity bags’ signs.

We recommended that the charity:

  • reviews how it monitors the action that the agency takes in response to complaints regarding charity bag deliveries to households with ‘no charity bags’ signs and restricted addresses to ensure that the agency is taking all appropriate steps to prevent charity bag deliveries to those who do not wish to receive them.


The charity and agency accepted our recommendations. We asked that the charity and agency write to us within two months of our final decision to outline the actions they have taken in response to our findings and recommendations.