Leukaemia and Myeloma Research UK and Fundraising Support Ltd: March 2023

Name and type of organisation/s: Leukaemia and Myeloma Research UK (registered charity no. 1161622) and its agency Fundraising Support Ltd

Fundraising method: Charity bags

Code themes examined: the delivery of a charity bag to a ‘restricted address’, complaint handling and third-party monitoring

Code breach?

  • Leukaemia and Myeloma Research UK: Yes
  • Fundraising Support Ltd: Yes

The complaint

The complainant told us that they did not want to receive charity bags from Fundraising Support Ltd (the agency) on Leukaemia and Myeloma Research UK’s (the charity’s) behalf. The complainant asked us to communicate this to the charity, which we did. Despite this, the complainant went on to receive two more charity bags.

What happened?

The complainant contacted us to say that they had received an unwanted charity bag. They asked us to contact the charity and ask it to stop deliveries to their address. We contacted the charity, which responded to apologise to the complainant and said that it would tell its agency of the complainant’s address.

When the complainant received another charity bag, we asked the charity why this happened. The charity did not respond at first. When the complainant received a third bag soon afterwards, we contacted the charity again. This time the charity acknowledged one of the further deliveries. It explained that its systems showed that a bag shouldn’t have been delivered, but that it may have been the result of human error. It also passed its further apologies to the complainant.

Our decision

The charity and its agency did not respond to our requests for up to date information for our investigation. When asked, the charity referred us to information it gave us from a previous investigation about a similar complaint. We were unable to see whether our previous recommendations about charity bag deliveries had been followed, and if the charity and the agency had done enough to resolve this complaint.

As the complainant did not have a ‘no charity bags sign’ displayed, the first delivery was not unreasonable. But the charity and its agency should have respected the complainant’s request not to receive any more charity bags. 

We also expected the charity to acknowledge all three of the deliveries received by the complainant, which it declined to do. Based on the second charity bag delivery alone, we found that the agency engaged in unreasonably persistent fundraising, and therefore was in breach of the Code of Fundraising Practice (the code).

We had similar concerns about the charity’s supervision of the agency in a previous investigation, and these issues arose again in this case. However, we were not provided with any new information by either the charity or the agency about this. We found the charity in breach of the code regarding its responsibilities in monitoring third parties.

The charity declined to acknowledge all the deliveries. When asked, the charity explained that each delivery was not complained about as laid out in its published complaints process, so it would not comment further. By refusing to acknowledge the whole complaint, both at the time and during our investigation, we found that the charity had failed to investigate this complaint thoroughly or fairly. The charity therefore breached the code in relation to complaint handling.


We recommended that the charity puts in place quality measures to monitor the work the agency carries out on its behalf. Specifically focusing on its ‘banned addresses’ list and including additions to: 

  • the compliance training materials of any third-party agency it uses that refer to this list and its routine use; and
  • the ongoing processes and procedures used to monitor the work of these third-party agencies and how this information is used, to make sure that preventable unwanted deliveries do not occur.

We recommended that the agency review its present system for communicating ‘banned addresses’ information to its delivery staff to identify whether the risk of further errors can be reduced.

Code sections considered

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

Leukaemia and Myeloma Research UK:

  • Standard 7.3.1: breach identified 
  • Standard 7.3.2: breach identified 
  • Standard 2.4.3: breach identified

Fundraising Support Ltd:

  • Standard 1.2.1: breach identified


As both the charity and its agency were found to be in breach of the code, we asked both organisations to act on the recommendations made. We explained that a failure from the charity to comply may result in its registration with the Fundraising Regulator being removed.

The charity provided us with further assurances about improvements it had made to comply with our recommendations.