If a fundraiser, staff member, or volunteer has concerns over how their organisation is fundraising they should be able to raise the issues without fear of repercussions.

Charities should attempt to resolve issues and concerns internally in the first instance, but the issue might need to be escalated to the Fundraising Regulator (or other regulatory body) where necessary.

The Code of Fundraising Practice states that:

“Fundraising organisations MUST have a clear and published internal procedure for members of staff and volunteers to report any concerns they may have regarding their organisation’s fundraising practice. This could be either a standalone policy or part of a wider whistleblowing policy made available to staff and volunteers. In either case, the policy MUST include:

i) The type of issues that can be raised and the process for doing so;

ii) How the person raising a concern will be protected from victimisation and harassment;

iii) How and what the organisation will do in response to receiving such information;

iv) How an individual can escalate their concerns on fundraising practice to the Fundraising Regulator or the Independent Fundraising Standards and Adjudication Panel for Scotland in the event that internal consideration is not possible.”


There is some flexibility in how your organisation can meet this standard in the Code.  Some charities may already have general, organisation-wide whistleblowing policy, and can incorporate a fundraising element into that. Other charities may choose to make a procedure on whistleblowing on fundraising practices clear in their staff and volunteer handbook, and draw it to the attention of staff and volunteers as part of an induction or training process.

What’s important is that the outcome is achieved: that any member of staff or a volunteer is easily able to report any concerns in a safe and trusted environment and that the concern is appropriately dealt with.

So, while you have a choice in how you introduce and embed a procedure on whistleblowing, it might be helpful to think about the following:

  •   Does this need to fit in with any other, existing, organisation-wide whistleblowing policy?
  •   How are you going to promote this to you staff and volunteers?
  •   How will you promote this procedure to any third parties you work with?
  •   Do you need to discuss this with your trustees?
  •   What will the process be once an issue or concern has been raised?
  •   Check with relevant teams across the organisation – you may need to discuss with HR or other colleagues
  •   Review the policies or agreements with external agencies or partners – you may want to check their procedures on whistleblowing too
  •   If you are agreeing a new organisation-wide policy, you might need to involve your Board to sign off and approve


We know that some charities, particularly larger ones, may already have existing internal ‘whistleblowing’ procedures in places. This could be because of the nature of the work they do, or the particular sector that they work in. The whistleblowing procedure on fundraising does not have to be independent of a wider whistleblowing policy, and can be incorporated into your existing procedures.

Protection in law already exists for employees under the Public Interest Disclosure Act if they report concerns about serious wrongdoing at their charity that relates to a legal breach, criminal offence, danger to health and safety etc. This does not include fundraising, and does not apply to volunteers. For more information, refer to guidance from the relevant charity regulator below.

If you have any further questions about the Code of Fundraising Practice and what is required, contact the Fundraising Regulator

Further guidance and resources:

-          Charity Commission: Charities and whistleblowing - key points

-          Office of the Scottish Charity Regulator: Whistleblowing to OSCR

-          Public Concern at Work: The Whistleblowing Charity