Fundraising Ethical Policy
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 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.
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.
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:
- 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.
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:
- The donor is known to be associated with criminal sources and/or illegal activity
- 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
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.
- 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 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.
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].
Tommy’s upholds its employees’ UK employment rights, and will not support or deal with any organisation known to be involved in slavery or human trafficking.
Slavery occurs when one person deprives another person of his or her liberty for personal or commercial gain. It is a crime and a violation of human rights. Modern slavery can take various forms, including forced and compulsory labour, and human trafficking.
This statement applies to all people working for Tommy’s or on Tommy’s behalf in any capacity, including employees at all levels, directors, officers, agency workers, volunteers, agents, suppliers, consultants or other contractors, third-party representatives and business partners.
Nature of our supply chain
Tommy’s supply chains include the provision of courier services, the buying of fulfilment services, office maintenance and cleaning, event management and the buying of branded clothing and promotional goods.
Tommy’s will not knowingly work with any supplier who does not provide a written contract of employment, compliant with local law, to its employees, including grievance provisions which offer a safe and confidential way for employees to raise concerns.
Tommy’s will not knowingly benefit indirectly or directly from forced or involuntary labour. All work in our supply chain must be undertaken willingly, and workers must have the freedom to terminate their employment, having completed an agreed notice period, without penalty.
Suppliers, sub-contractors or service providers to Tommy’s must ensure that workers are paid at least the minimum wage of their location, and workers must not be forced to work in excess of the maximum average working week permitted by the law of their location.
Employees must avoid any activity that might lead to, or suggest, a breach of this policy. You must notify a Director of the Charity immediately if you believe or suspect that a conflict with this policy has occurred or may occur in the future. An employee who raises a genuine concern in good faith in connection with this policy will not be detrimentally treated by the Charity.
Breach of this policy
Any employee who knowingly breaches this policy will be subject to the disciplinary process.
We may terminate our business relationship with other individuals and organisations engaged with us, if there is any breach by them of this policy.
Responsibility for this policy
The Senior Management Team has responsibility for implementing this policy and ensuring that those under Tommy’s control comply with it. This policy will be reviewed annually by the Human Resources Manager.