SOS Children’s Villages UK and Zen Fundraising Ltd: May 2024

Name and type of organisation: SOS Children’s Villages UK (registered charity no. 1069204) and its agency Zen Fundraising Ltd

Fundraising method: Face-to-face fundraising (Private site)

Code themes examined: Fundraiser behaviour, vulnerable circumstances, complaints handling

Code breach? Yes 

The complaint  

The complainant contacted the Fundraising Regulator to complain to us about three separate incidents involving fundraisers who approached them in a shopping centre.

The first incident occurred in April 2023 when the complainant was walking through a shopping centre and answered “No” when they were approached by a fundraiser representing SOS Children’s Villages UK (“SOS”). They complained that the fundraiser continued to address them and that this led to an altercation with another member of the public which left them feeling unsafe. They told us they felt SOS discriminated against them because of their disability and did not properly investigate their complaint.

The second incident happened three days after the first incident. The complainant told us that the fundraiser spoke to them in the shopping centre despite them not wanting to be approached.

The third incident occurred the following month. The complainant was visiting the same shopping centre and encountered another of the fundraisers involved in the first incident. They complained about the fundraiser’s behaviour during this interaction. 

What happened 

The complainant is autistic and sometimes they use a body-worn camera for their protection.  We reviewed the camera footage from each of the incidents.  The first incident showed that a fundraiser for SOS Children’s Villages UK (SOS) continued to speak to the complainant after they clearly indicated they did not wish to engage. The fundraiser asked if the complainant was a police officer. This led to an exchange which left the complainant feeling uncomfortable.

As the complainant tried to leave, a member of the public who had been engaged with another fundraiser in the team made an insulting remark toward the complainant. The fundraiser who had addressed the complainant laughed in response. This led to a confrontational conversation which one of the fundraisers tried to de-escalate. The member of the public left.

Our decision

We considered the fundraisers’ behaviour as seen on the camera footage on the first incident. We found that the fundraiser who addressed the complainant had likely been trying to follow the code standards against approaching police and other uniformed officials. However, the complainant had already indicated they did not want to engage, and so this was a breach of the code. We also found that some of the fundraisers’ comments, and the laughter at the offensive remark by a passer-by, breached the code sections around politeness.

The exchange during the first incident included some discussion of the complainant’s disability. We did not find any evidence that the fundraisers breached the code standards requiring them to follow equality law, or that they discriminated against the complainant on the basis of disability.

Having carefully considered the evidence on the second and third incident, we determined that although these involved the same individuals, neither occasion involved fundraising activities and so we could not consider them further.

We also considered SOS’s handling of the complaint. Overall, we found that it had treated the complainant fairly and reached a reasonable conclusion taking appropriate remedial action. This included apologising for the fundraisers’ behaviour and arranging retraining for the fundraiser.  We were critical of SOS’s decision not to review the camera footage when investigating the complaint. However, we did not find that this omission in itself amounted to a breach of the code standards around complaints handling.

Code sections considered

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

  • Standard 1.1.2: breach identified
  • Standard 1.2.2: breach identified 
  • Standard 1.3.5: no breach identified
  • Standard 2.4.3: no breach identified
  • Standard 2.4.4: no breach identified


We found that SOS had taken reasonable steps to investigate the complaint and that it had remedied the breaches by apologising to the complainant and retraining the fundraisers to improve their awareness of vulnerability. We recommended that SOS review its general training programme to ensure that its fundraisers are properly equipped and skilled to interact with people who have disabilities.
We also recommended that it update its procedures to ensure that it considers all appropriate evidence, including video recordings, when investigating complaints.


SOS and Zen accepted our findings. Zen let us know that it has also updated its training so that fundraisers can better identify and take into account the needs of potentially vulnerable individuals.