Associated Country Women of the World: September 2019

Name and type of organisation: Associated Country Women of the World (registered charity no. 290367) an international aid charity 

Fundraising method: various

Code themes examined: misleading information, restricted donations

Code breach? Yes

The complaint 

The complainant said that their organisation had been misled by Associated Country Women of the World (ACWW) about fundraising that they had undertaken on ACWW’s behalf. The complainant said that their organisation had been led to believe that by ‘adopting’ a fundraising project, it was the only organisation raising funds for that particular cause. They have since discovered that this was not the case. 

What happened?

In 2017 ACWW operated a voluntary fundraising model whereby its member societies would ‘adopt’ a project to raise funds for initiatives in developing countries. ACWW would initially fund the project and the funds raised by the adopting member society would be used to ‘top up’ the ACWW Fund from which the grant was initially paid.

The complainant’s organisation adopted a project in 2017 and agreed to raise the full adoption pledge amount. The organisation’s previous relationship with ACWW had led them to understand that they would be the only organisation fundraising for that particular cause. When the organisation became aware that it was not the only organisation raising funds for the project it contacted ACWW to clarify matters. 

ACWW told us that five organisations had contributed to this particular project and that more funds than needed had been raised. It told us that the surplus had been paid into its central grant fund for future projects. 

ACWW told the organisation that it had ceased fundraising in this way in 2018 because of concerns about the fundraising model. However, it did not investigate or provide answers about what had happened in this specific case. 

The complainant told us that their organisation remained unhappy with ACWW’s response. 

Our decision

We found no evidence that ACWW set out to deliberately mislead its member societies or that the money raised was not intended to be used for its charitable objectives. However, we consider that in not making it sufficiently clear to its member societies that others could donate to the same project, or that it was in fact, raising money to replenish its funding pot rather than the actual project, it may have misled donors and therefore breached the code. 

We also found that ACWW did not make its member societies aware of what would happen should the target amount needed for a project be exceeded. On this basis, we found that it had breached the section of the code dealing with restricted donations. 

We found that ACWW should have recognised the organisation’s request for clarity as an expression of dissatisfaction. We found that by not addressing it as such and not investigating their specific concerns, it breached the complaint handling section of the code. We also found that ACWW did not have a publically available complaints policy in breach of the code. 


We recommended that ACWW:

  • conducts a review of its 2016 and 2017 adopted projects and how any surplus funds were used. We also recommended that, as part of this review, it considers how this was communicated to any relevant member societies; and
  • reviews our Complaints Handling Guidance for Charities in order to draft and implement a complaints policy.  

We recommended that the complainant’s organisation: 

  • takes measures to reassure itself that when running an appeal for a particular purpose, its members make donors aware of what will happen to funds received if the total funds raised are insufficient or exceed the target required.  


The charity accepted our recommendations. We concluded that in changing its fundraising model in 2018, ACWW had already addressed the issues that caused concerns in this case. We asked that ACWW and the complainant’s organisation write to us within two months of our final decision to outline the actions taken in response to our findings and recommendations.