Transformation for Veterans and ECS Textiles: September 2019

Name and type of organisation/s: Transformation for Veterans (registered charity no. 1141508) an armed forces charity, and ECS Textiles, an agency

Fundraising method: charity bags

Code themes examined: complaints handling processes and restricted addresses

Code breach?

  • Transformation for Veterans? Yes
  • ECS Textiles? Yes

The complaint

The complainant received unwanted charity bags from ECS Textiles (the agency) on behalf of Transformation for Veterans (the charity) in October 2018 and May 2019. The charity and agency did not respond to their complaints to them.

What happened?

When the complainant sent emails to both organisations to request not to receive any further charity bags, neither organisation responded. However, the agency confirmed that it had added her address to its ‘do not deliver’ list. Despite this, the complainant received two further charity bags.

The agency told us that in most instances unwanted charity bags were delivered due to ‘human error’. However, it did not tell us whether it had investigated the complainant’s concerns and concluded that human error was the reason in her case.

The charity said that it had no record of the complainant’s initial email, and it did not know what action was taken in respect of her second email, as the staff member working at the time had left the charity.

The charity told us that the agency deal with all complaints about charity bags and that it is not involved in the day-to-day running of the agency’s work.

Our decision

We found that by continuing to deliver charity bags to the complainant, the agency made an ‘unreasonable intrusion to a person’s privacy’ and therefore breached the Code of Fundraising Practice (the code).

We found that the agency also breached the code as it did not respond to the complainant and therefore had not acted respectfully. It also failed to investigate, appropriately respond to, and learn from the complaint, in breach of the code.

We found that the charity did not have appropriate monitoring in place for a third-party fundraising on its behalf and therefore was also in breach of the code.


We recommended that Transformation for Veterans:

  • Reviews the learning from this complaint and how it records and responds to complaints.
  • Reviews and amends its Commercial Participator Agreement with ECS Textiles to ensure it underlines the importance of the code, providing specifically for adequate oversight and monitoring arrangements.
  • Puts in place measures to monitor the work of ECS Textiles, such as: reviewing its approach to contract management and training; reviewing compliance material for third-party fundraisers, and shadowing third-party fundraisers to ensure the work is being delivered effectively.
  • Reviews the code to ensure it is fully compliant and understands its responsibilities.

We recommended that ECS Textiles:

  • Reviews the compliance training it provides to staff, in particular in relation to restricted addresses.
  • Reviews the learning from this complaint and how it records and responds to complaints.

We also asked that both Transformation for Veterans and ECS Textiles write to us within two months of our final decision to outline the actions they have taken.


The agency accepted our findings and recommendations. The charity confirmed that it will implement our recommendations.