Ethical Policy

Here you will find Tommy’s Fundraising Ethical Policy. If you have any questions about the content, please don’t hesitate to get in touch.

Tommy’s raises funds for research into miscarriage, stillbirth and premature birth, and providing pregnancy health information to parents. We comply with and support the Fundraising Regulator's Promise to be legal, open, honest and respectful. We uphold their vision of a world where fundraising is ethical and giving is sustainable; where donors and fundraisers have respect for each other.

This policy outlines the ethical responsibilities of Tommy’s fundraising. All Tommy’s fundraising staff have a responsibility to be aware and have a thorough understanding of the ethical issues referred to in this policy. This policy is aligned to our values which are an integrated part of our fundraising.

Tommy’s Supporters

Tommy’s respects the rights of its supporters to clear, truthful information on the work of Tommy’s; to openly report how we spend donations and to manage donors' information responsibly and in line with The General Data Protection Regulation.

We will comply with the Charity Commission and UK law in every respect, including those regarding openness and honesty with our supporters and members of the public.

As members of the Fundraising Regulator’s scheme, we follow its Fundraising Promise.

In line with the Fundraising Regulator’s code our fundraising practices consider the needs of any possible donor who may be in vulnerable circumstances or may need extra care and information to make an informed decision. Our fundraising agency staff responsible for face to face fundraising receive relevant training to help them to identify and respond to the needs of any possible donor who may be in vulnerable circumstances or any donor at any time.

We respect the privacy and contact preferences of all donors. We will respond promptly to requests to update contact preferences or complaints and act as best we can to address their causes. Please see our Privacy Policy and Complaints Policy for more information.


Sustainability is integral to fundraising at Tommy’s. We strive for all our fundraising materials to be sustainably sourced. We actively promote recycling at all our fundraising events. All our fundraising communications are digital where appropriate. The sustainability of all new fundraising ventures is assessed. We ask that all third parties adhere to this policy.

Refusal Criteria

We abide by the law which requires us, in deciding whether to accept or refuse a donation, to consider which action is in the charity's best overall interest.

We do not accept donations from any organisation or individual who has generated a material amount of their turnover or wealth through the following activities as they are evidenced as being inherently harmful to pregnant women and children:

  • Tobacco
  • Alcohol
  • Pornography
  • Arms manufacturing and export
  • Manufacturers of Breast-Milk Substitutes (BMS): Tommy’s follows the World Health Organisation 1981 International Code of Marketing of Breast-Milk Substitutes. The aim of the Code is to help ensure the provision of adequate information on appropriate infant feeding and the regulation of the marketing of breastmilk substitutes, bottles and teats. Tommy’s believes that ‘follow-on milks’ fall under the Code’s definition of a breastmilk substitute: ‘any food being marketed or otherwise represented as a partial or total replacement for breast milk’. This means Tommy’s cannot accept money or advertise and/or promote products from companies that do not comply with this Code. For further information on the Code, download the International Code of Marketing of Breast-milk Substitutes [PDF].
  • Companies who produce and market home dopplers

We do not screen individual donations by their employers, this is inclusive of any matched corporate donations that may be received as part of an individual’s fundraising efforts. This is outside the scope of this policy and the capacity of Tommy’s.

We will not undertake business with companies or individuals who participate in activities which could cause detriment to the charity's reputation and could disproportionately decrease the amount of donations to further the work of the charity.

The responsibility of the judgement on whether Tommy’s should refuse a donation lays first with the Fundraising Director, then the Senior Management Team and ultimately the Board of Trustees.

Acceptance criteria

Tommy’s will ensure that all marketing and fundraising activities carried out on its behalf are consistent with this policy and best practice in the charitable sector.  Tommy’s will ensure that any donation from, or relationship with, a third party does not in any way compromise this policy, damage the reputation of Tommy’s or jeopardize future fundraising.

Tommy’s ensures that it complies with relevant legislation, including legislation on data protection, money laundering, and bribery.

Tommy’s will not accept donations in the following circumstances:

  1. The donor is known to be associated with criminal sources and/or illegal activity
  2. Accepting a donation may impact adversely on Tommy’s reputation

Additional checks will be made for unsolicited and anonymous significant donations. A donation may be refused if additional checks cannot provide enough assurance that the source complies with this policy

Corporate partnerships

Tommy’s corporate partnerships provide much needed support to achieving our charitable aims and objectives. In addition to the refusal criteria the following criteria provide a route by which the Fundraising Director of Tommy’s can review and assess donations:

  • Tommy’s will not promote any companies or brands by association knowingly linked to the harm or detriment of pregnant women or babies.
  • Tommy’s does not directly endorse products or services. Where a product or service is promoted by Tommy’s in connection with a third party, the nature of the relationship is made clear on the product. Tommy’s will make it clear that it does not seek to recommend that service or that third party above that of another which provides the same service but with whom Tommy’s does not have a relationship.
  • Tommy’s will only enter into corporate partnerships where the company adheres to our Modern Day Slavery Statement.
  • Only Tommy’s will have direct access to its database, target groups and beneficiaries. The way in which we share your information with our data processors is outlines in our Privacy Policy.
  • Tommy’s will review any monetary contributions to celebrity ambassadors or influencers to engage in corporate brand activity on a case by case basis.
  • To ensure that all cause-related promotions reflect Tommy’s values, any such initiatives will be reviewed by the Fundraising Director for final decision.

Pregnancy and Parenting at Work

Any organisation can purchase Tommy’s Pregnancy and Parenting at Work service supporting businesses to manage the health and wellbeing of employees through pregnancy and after, no matter their journey. This is aligned with our pregnancy information service vision to make pregnancy safer for all. 

For organisations wishing to apply to become a Tommy’s Pregnancy and Parenting at Work Champion one of the qualifying criteria is that they do not breach Tommy’s ethical policies. Customers are asked to confirm at the point of registration that they do not breach Tommy’s ethical policy and confirm this at renewal. Tommy’s will monitor all applications and perform spot checks at their discretion. 

Pregnancy information service

Tommy’s believes decisions about planning for pregnancy, pregnancy and birth should be made based on information free from commercial influence. We have a robust Information Production Policy to meet standards which show that we are a reliable and trustworthy source of health and/or social care information.

Where Tommy’s accepts advertisements from third parties for display on a website or other information product it will be clearly identified as advertising.

Tommy’s may accept sponsorship for information products from third parties. The editorial policy of such information products will remain solely with Tommy’s and the sponsorship will not affect the internal content of the product. Where it has been agreed with the third party, sponsorship will be acknowledged on the product.

Your donations

Unrestricted donations are very valuable to Tommy’s as they enable us to fully fund our work and develop and grow as an organisation to achieve our charitable aims and objectives. If supporters wish to make a donation to a specific area of Tommy’s work (for example to Tommy’s Research Centres), they may make a restricted donation by providing written instructions to this effect with their donation by writing to us at [email protected].