Strengthening direct dialogue fundraising: managing risks and building trust

Direct dialogue fundraising – whether on the street, at private sites, or door‑to‑door – remains one of the most effective ways for charities to raise funds and build long-term supporter relationships. But with its strengths come compliance risks. To stay ahead of regulatory expectations and safeguard their reputation, charities need robust frameworks for ethical practice, monitoring, and governance.

Below are key steps charities can implement to strengthen their approach.

Ethical behaviour standards and transparent pay structures

The recently updated CC20 guidance from the Charity Commission emphasises how charities should lean into their values when developing fundraising strategies. One area that often requires careful consideration is remuneration for subcontracted fundraisers. There is no perfect model; salaried, performance‑related, and hybrid approaches all have pros and cons. Trustees must debate and decide what models best fit their practice and articulate that to their fundraising suppliers. There is a movement to at least ensure that fundraisers earn the basic living wage, whatever model is adopted.

Strong vulnerability policies

Charities, especially larger ones, should have a comprehensive vulnerability policy with clear criteria and procedures. Practice can help those policies come to life, such as practical scenario-based training to help fundraisers recognise and respond sensitively. Additionally, a mystery shopping and monitoring programme can confirm that fundraisers’ behaviour matches expectations.

Oversight of subcontracting chains

Lack of oversight and visibility over subcontracting arrangements is a recurring cause of compliance failures. Updated guidance from the Chartered Institute of Fundraising (CIOF) emphasises the requirement from the Fundraising Regulator that trustees have a clear line of sight to everyone fundraising in their name.

To achieve this, charities should:

• map and approve the full subcontracting chain, including sub-sub-contractors.
• build clear contract clauses defining how sub-contracting works, monitoring and reporting frequency, expected behaviours and compliance standards.
• ensure agencies report on complaints, issues, and performance concerns.

While agencies provide oversight, the responsibility ultimately sits with the charity’s trustees.

Robust training, monitoring and complaint analysis

Regulators constantly stress that effective training and monitoring are fundamental to high quality, ethical fundraising. Charities must ensure that all fundraisers, particularly those employed via agencies, receive appropriate training and that compliance is monitored regularly.

This can be done by developing a core training programme covering ethics, vulnerability, safeguarding and regulatory compliance. Training is linked to regular field monitoring, including supervisor shadowing and independent observation. It can be a great way to involve trustees on mystery shopping exercises to increase their understanding of how it works.

Safeguarding fundraisers, especially in door-to-door roles

Door-to-door fundraising exposes fundraisers to isolation and safety risks. The updated Code of Fundraising Practice as well as CIOF guidance emphasises the need for fair working conditions, whistleblowing policies, and additional safeguards. Lone worker policies need to be applied to fundraisers too, including those working across sub-contracting chains. Real-time support channels and safety alerts will also provide a level of reassurance and support.

Enhancing transparency and accountability

Transparency is foundational to public trust. CIOF’s guidance emphasises clear communication, honest job advertising, and accountability for fundraising agencies. Charities can enhance transparency by ensuring all fundraisers clearly state who they represent and how donations will be used. They should also review recruitment materials to ensure they accurately portray the nature of the role. It is also helpful to create a culture where complaints are not feared but treated as near-misses and opportunities to improve.

Direct dialogue fundraising can thrive with the right controls in place. Combining internal vigilance with external assurance strengthens public trust and protects both donors and fundraisers.

How we can help

At Moore Kingston Smith Nonprofit Advisory, we work with fundraising charities to provide:

• compliance audits, governance reviews, and risk assessments;
• development of policies and training frameworks;
• independent monitoring and assurance over field activity;
• strategic advice to ensure fundraising aligns with charity values.

Contact us for a free, no-obligation consultancy session to explore how we can help.