The discussion paper, Playing the percentages: Re-evaluating the ethics of paying fundraisers by commission, looks at 14 regularly deployed ethical arguments against commission payment, finding many of them weak, whilst also raising an additional argument regarding fundraiser wellbeing.

The paper says that ethical arguments warning of possible harm from this form of payment are rarely supported by evidence. Commission can also be singled out as unethical without this ethical reasoning being extended to comparable aspects of fundraising, such as bonus payments. ‘Straw man’ arguments are also often presented – weak positions that are easily argued against, especially that commission is a binary option: it can be paid on all donations received, or on none.

Rogare suggests that many of these traditional ethical arguments against commission are not strong enough to defeat two ethical arguments in its favour: that commission-based pay could result in more money being raised for good causes, and that it enables smaller organisations with little budget to engage in fundraising and compete with larger organisations.

However, Rogare also raises another argument against paying fundraisers commission, which is that if this became commonplace, it could harm fundraisers’ psychological wellbeing.

To protect fundraisers and other stakeholders, Rogare proposes 12 safeguards for when commission payments aren’t covered by fundraising codes of practice. These include undertaking a risk assessment of potential harms, paying commission only when there is demonstrable audit trail between the ask and the gift, and that commission should never be due on unsolicited gifts. Commission should never be part of the remuneration package for salaried fundraising staff working at a nonprofit, and only paid to agency or freelance fundraisers, and it should never be the sole form of remuneration.

Rogare also poses the idea that professional institutes could introduce a permitting scheme that would give permission to organisations to pay commission to fundraisers, providing these safeguards are in place.

Report co-author Heather Hill says:

“The sector needs to do better than saying ‘because the code says so’, when someone asks why commission-based pay is not permitted. ‘It’s unethical because the code says so’ is a response that fails to provide a rationale for the reason the code has taken such a position, and it fails to address situations for which there is no applicable code.

“This conversation is long overdue and we are pleased to offer this paper as a way of jumpstarting critical thinking around the issue.

“But we would like to make it clear that we are neither arguing for nor against commission-based pay for fundraisers, only evaluating the ethical arguments for and against.”

Picture by Getty Images on Unsplash+

As fundraisers, earning and maintaining trust is essential to inspiring generosity. Without trust, donor confidence erodes, and charities struggle to fulfil their mission.

How can charities and agencies maintain public confidence while ensuring sustainable revenue streams in an era of heightened scrutiny, transparency, and evolving donor expectations? The answer lies in robust self-regulation.

To build and strengthen public trust, charities must actively listen to and respond to community feedback. Self-regulation in charity fundraising isn’t just about protecting donors – it’s about supporting and empowering them too. At the F2F Congress in Vienna, I will explore how ethical self-regulation frameworks, grounded in principles-based codes of conduct, safeguard donors and provide them with new ways to meaningfully engage with the causes they care about. This proactive approach fosters deeper connections between donors and charities while reinforcing trust and transparency in the process.

Self-regulation is more than just compliance – it’s a fundamental pillar of ethical, sustainable, effective and impactful fundraising. Here’s why.

The case for self-regulation

The fundraising sector is dynamic and diverse, spanning different markets, cultures, and regulatory environments. However, the common thread across all regions is the need for ethical fundraising that upholds public trust.

The Public Fundraising Regulatory Association New Zealand has supported and empowered members since 2006 by providing a proactive framework for self-regulation that ensures charities and fundraising agencies operate with integrity beyond just legal obligations.

By developing and adhering to self-regulatory frameworks, fundraising organisations can:

• Set clear ethical expectations to ensure fundraisers operate with integrity.
• Enhance transparency and accountability to donors, regulators, and the public.
• Proactively manage risks related to reputational damage or public scepticism.
• Strengthen industry credibility by demonstrating collective responsibility.

Principles-based codes of conduct: a flexible and ethical approach

A core component of effective self-regulation is the adoption of principles-based codes of conduct. These frameworks go beyond fixed rules to establish ethical standards that guide fundraisers in diverse and evolving circumstances.

Unlike prescriptive regulations, principles-based codes emphasise intent, impact and context, and support fundraisers to make decisions based on ethical considerations rather than just ticking compliance boxes. Key principles often include:

• Honesty – Ensuring truthful and clear communication with donors.
• Respect – Upholding donor rights and dignity at every interaction.
• Accountability – Being answerable for fundraising practices and outcomes.
• Transparency – Providing clear information on how funds are raised and used.
• Sustainability – Ensuring responsible fundraising that considers long-term impact.

Building and maintaining trust

Trust is the foundation of all successful fundraising. Without it, donor engagement diminishes, and the communities and beneficiaries we serve are directly impacted. Self-regulation fosters trust by setting high ethical standards and demonstrating a commitment to responsible and transparent fundraising.

Strategies for maintaining trust include:

• Open and honest communication – Donors should know how their contributions make an impact.
• Clear complaints and compliance mechanisms – Avenues for addressing concerns must be accessible and effective.
• Third-party accreditation and oversight – Independent reviews help reinforce credibility.
• Consistent ethical behaviour across all channels – Whether in face-to-face fundraising, telemarketing, or digital marketing, integrity must remain at the core.

Future-proofing fundraising: the role of self-regulation in long-term success

As fundraising landscapes evolve ­– whether due to technological advancements, economic shifts, or regulatory changes – self-regulation provides charities and agencies with the flexibility to adapt without compromising ethical integrity. By embedding these frameworks within their operations, organisations can not only navigate challenges with confidence and ethical clarity, but innovate responsibly while maintaining donor trust, and establish long-term sustainability through consistent ethical practices.

About the International F2F Fundraising Congress

Where: Vienna

When: 28-30 April 2025

EFA discount: Thanks to the support of additional social funding for the event, the F2F Congress host Fundraising Verband Austria is pleased to be able to offer a 20% discount on tickets to EFA members and Fundraising Europe readers, accessible with the code EFA20 when booking here. 

More information: www.f2f-fundraising.com

Sessions at the F2F Congress on self-regulation include Angela Norton’s Building Trust & Sustainability: How Self-Regulation Strengthens & Future-Proofs Your Charity’s Fundraising, and Helping You Fundraise Sustainably, Ethically, and Effectively in Any Circumstance, co-presented with Matt Radford, which will delve into practical applications of the principles explored in the article, offering insights into how charities and agencies can embed ethical practices into their daily fundraising operations. View the full programme here, and read more in this month’s story.

About Angela Norton

With over a decade in charity fundraising, Angela Norton works to drive transformative self-regulation that is focused on supporter experience, ethics, transparency, and accountability. As national manager for the Public Fundraising Regulatory Association (PFRA), she collaborates with members to strengthen a self-regulatory framework that builds public trust and empowers support for valued causes.

Main picture by Vicki Hamilton on Pixabay

In June, Swissfundraising, the Swiss fundraising association, presented its first award for the ‘Best Fundraising Mailing in Switzerland’. Reputation effect on the sector and innovative strength were evaluated, as well as economic criteria such as average donation, and response or yield per item. However, the award stands out from other prizes in the fundraising community because the majority of the criteria relate to ethical principles and their implementation.

The Swissfundraising board’s decision to create such an award was based on the conviction that, on the one hand, fundraising mailings are and will remain a central instrument in the fundraising mix and greatly impact how the respective organisations are perceived, as well as the sector as a whole. On the other hand, despite the unbroken willingness to donate, there is increasing concern or even rejection of fundraising mailings among the Swiss population. These trends must be taken seriously and addressed.

Critical attitudes in the Swiss population

Six years ago, a study commissioned by Alliance Sud, an alliance of Swiss development organisations, showed that, in addition to identifying with the goals and work of aid organisations, the population also held some negative feelings towards the organisations themselves and particularly towards their fundraising.

Worryingly, this included negative stereotypes such as inefficiency or bureaucracy. Lack of transparency and authenticity due to exaggeration or oversimplification were also assumed, particularly in fundraising mailings. Rejection of the stereotype of misery and of the paternalistic narrative was also central. At the same time, the messages did not always seem to reach their audience as desired because the language was seen as often being technical, full of jargon and not very conversational. Furthermore, the study found that the credibility of fundraising mailings was in danger of dwindling if only success stories were communicated without self-criticism or discussion of challenges, problems and failures.

Ethical principles for strengthening donation mailings

The important insights gained in this study and the subsequent discussions led to the creation of the ‘Manifesto for Responsible Communication’. In 2020 Swissfundraising also took up the discussion with the aim of promoting ethical practice in fundraising mailings and thus simultaneously contributing to the long-term acceptance of this fundraising tool. The idea was to create an award for best practice examples to raise awareness in the industry. To this end, Swissfundraising has further developed the conclusions of Alliance Sud on ethical principles. The ethical principles for responsible fundraising summarise the aspects outlined above in eight points:

1. The self-image and values of the organisation are communicated.
2. The objectives of the work, its impact and how it is measured are made transparent.
3. The language is appropriate for the target group, comprehensible and dialogue oriented.
4. An authentic picture of the work and its context is conveyed.
5. Contributors speak for themselves and are respectfully portrayed at eye level.
6. Challenges, setbacks and problems are addressed self-critically.
7. A sustainable solution perspective is shown.
8. The communication is relevant for the addressees and mobilises them.

Practical outputs

Hanspeter Bigler

About Hanspeter Bigler

Hanspeter Bigler has been working in fundraising for 25 years in nonprofit organisations and also as a consultant. He is a member of the executive board of Swiss Church Aid (HEKS/EPER), heads the communication and mobilisation division and is deputy director. Since 2024, he has also been president of Swissfundraising, the Swiss fundraising association. Hanspeter Bigler studied ethics and political philosophy as well as contemporary history at the University of Fribourg/Switzerland, is a certified NPO manager VMI and holds a master’s degree in communication management.

Picture by Aron Visuals on Unsplash

The Rogare paper, Take it or Leave It: The Ethics of Gift Acceptance and Refusal, is the result of work with the UK’s Chartered Institute of Fundraising to develop a richer ethics of gift acceptance and refusal. It is also a companion piece to the CIOF’s guidance on how to construct and write acceptance/refusal policies.

Claire Stanley, director of policy and communications at the CIOF says:

“There is no single solution to the challenges around deciding to refuse a donation, and every organisation needs to develop their own approach that will enable them to fulfil their charitable objectives.

“At the Chartered Institute, we have published guidance, co-created with our members, that provides an overview of current regulation and key considerations when creating an acceptance and refusal policy.

“Through our partnership with Rogare, we aim to go one step further and explore the ethical schools of thought that can guide decision making. Although guidance and policies are incredibly helpful to ensure that charities make consistent decisions and do not inadvertently breach regulations, they cannot account for every scenario or explain why people can have differing opinions on what is the right course of action.”

Pros & cons of reasons for donation refusal

The paper considers the ethical pros and cons of the main reasons for refusing a donation. One is that accepting it would cause harm to the charity, such as loss of further donations, or beneficiaries being less likely to use its services. Another is that there is a moral principle why the donation ought to be refused, such as:

1. There is a blanket prohibition on working with particular types of donor
2. The donor/donation doesn’t align with a charity’s organisational values
3. The donation comes from a source the charity considers to be morally unacceptable

However, whereas a decision based on harm is focused on the evidence about how much harm is likely to result from accepting a donation, making the same decision using values requires a fundraiser to make a subjective evaluation of the donor’s values and intent. Any such decision about a donor can be countered by a subjective opinion made by someone else – trustees, the media, regulators or the donor themself – that interprets the donor’s values and intentions differently.

Rogare adds that any decision based on evidence of harm sidesteps these kinds of he said/she said gainsaying arguments.

Rogare’s director Ian MacQuillin comments:

“If a donor/donation is so out of line with a charity’s values, then it is almost certain to result in some kind of harm, such as other donors stopping their giving, or beneficiaries being deterred from seeking help.

“A hypothetical example we use in the new paper is the case of a faith-based charity that is offered a donation from someone associated with sex work. Even though it probably feels totally counter-intuitive not to make the decision based on alignment with the charity’s values, we contend they could make the same decision based on harm. And that would go for most ethical decision making in most cases of tainted money.

“We’re not saying values don’t or ought not play a role in the ethics of gift refusal. But we are asking whether they are really needed in most cases.”

The paper also looks at:

• How relevant fundraisers’ personal moral convictions are in deciding to refuse a donation
• The ethics of returning donations, which are not the same as those of refusal
• What new thinking is needed to facilitate sound decision making about sources of donations – such as the climate emergency – that might harm society as a whole, even if accepting the donation would be in the best interest of the recipient charity.

Rogare says that while the work is in the specific context of guidance from the Charity Commission as it relates to England and Wales, the ideas developed in the paper will also have relevance and applicability in many other countries.

Picture by moerschy on Pixabay

Rogare director Ian MacQuillin is one of four co-authors of a new academic paper which says that while there has been focus on disintermediation via digital crowdfunding, there are many other forms of disintermediation which require further examination.

‘A typology of disintermediated giving and asking in the non-profit sector’, published in the Journal of Philanthropy and Marketing, identifies three main types and four subtypes of disintermediation.

The summary of the paper promises:

“This paper will help fundraising practitioners reframe questions about the role they play and whether and how other types of actors are encroaching on their role (for better or worse).”

Under what Rogare calls the traditional model, charities turn resources (principally donations) into good or services to be used by beneficiaries. Disintermediation refers to non-traditional entities, such as individuals, commercial fundraising organisations, companies or even Governments, replacing the role of charities in this process.

A recent example was the transfer of money to individual Ukrainians via AirBnB bookings, following the Russian invasion. Rogare says that while some celebrated this ‘democratisation’ of philanthropy, it also risked exacerbating inflation and therefore wider challenges in the country. Another type of disintermediation is the creation of charitable platforms by private companies, enabling them to carry out work which traditionally would have been done through a partnership with an established charity.

The paper says that identifying the types and subtypes of disintermediation is a first step towards further examination of issues surrounding these and other actions.

Ian MacQuillin says:

“Some microlending sites intentionally position themselves as more ethical alternatives to charity because, the argument goes, it allows recipients of loans to work their way out of poverty rather than being passive beneficiaries of charity handouts. But does this ensure that all people who need help get it, not just those whose business proposition is attractive to lenders, and it might even reintroduce the notion of the ‘undeserving poor’ through the back door?

“Because we don’t have clear consensus of what we mean by disintermediation, these ethical questions often fly under the radar, and we struggle to come up with solutions because something that seems right for one type of disintermediation might be reject because it’s not appropriate for another type. This typology provides that clarity so we can better see what the ethical and regulatory issues are and so better target our solutions.”

Rogare’s next step will include extending and refining the typology, turning it into a more accessible paper aimed at fundraising practitioners, and organising a symposium on the issue in 2024.

Developed with War Child and SOS Children’s Villages, the guidance is based on discussions with other child-focused nonprofits including Clowns without Borders, Plan Sweden, and Save the Children. These took place as workshops earlier this year during a project run by War Child Sweden and SOS Children’s Villages Sweden to look into the issue.

In the workshops, the nonprofit participants considered whether the rights of children are always taken into account when their photos are used for fundraising purposes, along with the sector’s responsibility in this matter. Also discussed were how visual material can be used in fundraising without reinforcing stereotypes or power imbalances; the public’s growing awareness of the issue; and related topics such as white saviourism and the insights gained from understanding these.

Charlotte Rydh, secretary general of Giva Sverige, commented:

“Through the guidance, we want to increase knowledge of the issue, but also for it to serve as a starting point for organisations that want to develop or revise their own internal guidelines. In addition, the guidelines should encourage a common minimum level of ethical practice in the nonprofit sector.”

The guidance draws attention to the issues surrounding using images of children for fundraising purposes and offers advice to facilitate their more ethical use. Content includes a list of image types the working group has identified as particularly problematic and which therefore should be avoided for fundraising purposes. These include pictures of naked or deceased children, sexualised images, and those of injured children outside of a caring context. A picture of a child with a leg cast can, for example, be considered acceptable but not a picture of a child with an open wound damage.

It also outlines principles for using images of children in vulnerable situations more ethically, including around the giving and withdrawing of consent, the portrayal of vulnerability, and a list of key questions to ask internally when choosing an image. These include considering context, whether the child could choose how they wanted to be portrayed, and whether they were aware they were being photographed and was likely to have been able to give consent.

The guidance is available as a free download from the Giva Sverige site.

Picture by Joduma on Pixabay

The recommendation is made in a paper in the Journal of Philanthropy and Marketing that calls for a new way of thinking about the ethics of the framing of charity services users. Co-authors, Ian MacQuillin (director of Rogare), Jess Crombie (London College of Communication) and Ruth Smyth (Boldlight and a member of the Rogare Council), highlight that such framing has remained elusive, with arguments gravitating between two antagonistic poles.

At one pole is the ‘Fundraising Frame’, which argues that fundraisers need to present those images and tell those stories that will motivate people to give the most money to provide services, even if this means showing distressing images of services users, sometimes termed as ‘poverty porn’. At the other end of the spectrum is the ‘Values Frame’, which argues that charities ought to tell and present more positive stories and images of services users, which protect their dignity and challenge stereotypes, even though there is a general acceptance this will likely result in less money raised.

The authors propose the solution of basing ethical framing on whether services users have exercised ‘agency’ and ‘voice’ in telling their own stories, thus becoming ‘contributors’ to charities’ fundraising as well as users of their services.

This puts an onus on charities to consult with and include their service users about their marketing and fundraising communications to enable them to become contributors, and the paper outlines some ways in which this could be accomplished by drawing on the literature of “co-creation” of services.

Jess Crombie says:

“Many charities, as a matter of course, have ethical gift policies to guide them about when to accept, refuse or return a donation. We have these policies so we can pre-empt those ethical issues and have an ethical decision-making framework for navigating any that do pop up.

“In the same vein, charities should also have ethical contributor policies that stipulate the processes and identify ethical dilemmas in gathering service user/contributor-generated content.”

She adds that a “key component” of such policies “must be the implementation of a genuine consent process rather than one that merely legally protects the organisation”.

The paper – titled The Sweetest Songs – is the culmination of Rogare’s project to explore the ethics of the framing of service users. It includes a literature review of the research into the efficacy of positive (whether messages are presented as gains) and negative (messages presented as losses) in fundraising materials.

Ian MacQuillin adds: “With this paper we have moved the discussion about framing ethics beyond a play off between money raised against whether services users’/contributors’ dignity has been protected. Ethical framing is now contingent on whether service users/contributors have exercised voice and agency in contributing to their own framing and telling their own stories. Other things being equal, fundraising frames are ethical when contributors have choice in what stories are told, and get to tell their own stories, and unethical when they do not.”

For more information, read the paper here.

Photo by Larm Rmah on Unsplash

The study, conducted by Blue State, surveyed 1,494 individuals in the UK. It found that two thirds (67%) of people said they would donate to a stereotypical / white saviour image, despite recognising these images as problematic.

Out of these, almost 1 in 5 (23%) elected to donate to an image they had just seconds ago indicated as problematic and undignifying for children.

The findings held across all age groups, though younger demographics were more likely to favour neutral or positive images.

The research highlights the difficulties for charities and fundraising organisations in decolonising charity communications and moving to more ethical creative models.

Lizi Zipser, director of global strategy and insights at Blue State said:

“Traditional fundraising relies on creating a state of discomfort in donors, which they can alleviate by stepping in to help. We’ve all felt it, when faced with a communication from a charity. The images and stories touch people, making us upset that the world could be so unfair ­– and it’s that strong emotion that compels individuals to donate.” 

“Decolonising your fundraising, and creating a more ethical model requires a complete rethinking of what your fundraising communications are trying to do. If an organisation simply relies on a model based on upsetting your donors, but then dilutes the emotion by using neutral and more rational imagery and language – no wonder some are not seeing the same results. 

“It comes down to psychology and to building a programme built on other strong motivators to action. This means understanding your donors better and how your organisation fits with their identity, their need for belonging, their personal history and values, and how giving to the organisation connects them with others who also want to see a better world.” 

Photo by Shelagh Murphy from Pexels

Aiming to ensure that fundraisers maintain the highest ethical standards, the Italian Fundraising Association (ASSIF) has developed a Memorandum of Understanding addressing the way in which fundraisers are remunerated and deterring organisations from running payment on commission schemes.

All those that adhere to the memorandum are awarded the fundraising ribbon, as a symbol of quality and of the organisation’s commitment to its donors, partners and the wider public. To date, 50 nonprofits have been awarded with or have applied for the ribbon.

While ASSIF states that fundraising and ethics usually go hand in hand, the association set out to reward Italian nonprofit organisations that are willing to commit to guaranteeing a remuneration structure that encourages and incentivises long-term supporter relationships.

Jara Vernarecci, ASSIF Board member and coordinator of the initiative, says:

“Since the ultimate goal for fundraising is to develop long-term relationships and strategies capable of securing the organisation’s financial sustainability, the right pay structure should reflect this approach and should not be fully based on results.

“Nonprofits are the main allies in guaranteeing the high ethical profile of our profession. Any work paid exclusively as a percentage of commission sends the wrong message to fundraisers and also to donors since it’s rarely transparent and it aggravates the investment burden that every organisation should guarantee for its own development.”

The association is working in partnership with Italianonprofit and with the support of sector suppliers to encourage nonprofits across the country to commit to the new standards.

Photo credit: Photo by Christopher Czermak on Unsplash

When confronted with the dilemma of whether to accept of refuse a questionable donation, many charities start from the position that they ought to turn it down. That seems to be the default position.

What might be the reasons for turning a donation down?

If the donation has come from illegal means, say – such as proceeds of crime or money laundering – then that ought to be a relatively easy decision.

And if it conflicts with your cause – the classic case of a cancer charity not accepting support from a tobacco company ­– then that should be (relatively) simple to determine.

But it’s a lot harder to determine whether you should turn down a donation because it will damage your charity. This presents an empirical question; one that you can test to arrive at an answer that is supported by evidence.

For example, Great Ormond Street Hospital was very quick to announce it would return a donation given to it three years previously by the Presidents Club, when an undercover journalist reported the sexist behaviour of donors at this fundraising event. But following public support, GOSH reversed this decision. The charity could have saved itself this about face by going out to supporters and beneficiaries to ask them whether the charity should return the donation, and what they would be likely to do if the charity kept it.

Confusion often arises when people make ethical decisions because they don’t think that evidence has anything to do with ethics, because ‘ethics’ is about principles and values and, they reason, evidence can’t change those.

If it is ‘wrong’ – i.e. ‘unethical’ – to accept a donation because it conflicts with your values, then the fact that accepting the donation provides a lot of money with which to do good can’t suddenly make it right or ‘ethical’.

There is some confusion here about what ‘ethics’ is. Following the high-profile case of the Presidents Club in the UK earlier this year, the Institute of Fundraising issued new guidance on acceptance and refusal of donations. This talks about refusing donations that are contrary to an organisation’s ‘ethics and values’. But while it says these are important, the guidance also says they cannot be the decisive factors.

It then lists three factors – loss of donations, loss of volunteers and an inability to recruit staff, all of which are supported by evidence – that need to be considered when deciding to accept or refuse a donation, separately to a charity’s ‘ethics’.

Of course, this process of assessing evidence is not separate to a charity’s ethics. It’s everything to do with ethics. This is consequentialist ethics – deciding the right thing to do based on its outcomes – maximising good consequence and minimising bad ones.

Not only could it be unethical to accept a donation that was detrimental to your charity, it could also be unethical to refuse a gift that was not detrimental to your charity, even if it did conflict with some of your values.

And this leads to another point of confusion. If we consider detrimental effects on donations, volunteers and staff recruitment, as supporting evidence not to accept the donation, then that lack of evidence of any detrimental effect – or better still, evidence of positive and beneficial effects – gives you a plausible reason to accept the donation.

Still, the processes and thinking fundraisers use are skewed towards refusal.

When approaching an ethical dilemma about whether to accept or refuse a donation, charities often go in asking themselves the question: “Should we turn it down?”

So they look for reasons to turn the donation down and, lo and behold, they find them.

Instead, they should be asking a different question: “Are there any reasons why we shouldn’t accept this donation?”

This is the same ethical dilemma and the same evidence, but the way you phrase the question forces you to look at the evidence in a different way and in doing so, you might get a different outcome.

Viewed from this perspective, if a charity can’t find any good reasons not to accept a questionable donation, then accepting it should be perfectly ethical.

About Ian MacQuillin
Ian MacQuillin is director of Rogare, the fundraising think tank at Plymouth University’s Hartsook Centre for Sustainable Philanthropy.