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.

1. Introduction

Tommy’s is dedicated to finding causes and treatments to save babies’ lives as well as providing trusted pregnancy and baby loss information and support. 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.

2. Definitions of key terms

The following sets out the definitions of key terms used in this policy:

  • Tommy’s: within the context of this policy, all reference to Tommy’s encompasses the activities of LLHM Ltd.
  • Our values: evidence-driven, inclusive, collaborative, courageous
  • Restricted donations: donations or funding that have been made for a specific purpose agreed by the donor.

3. Purpose and scope of policy

This policy outlines the ethical responsibilities of Tommy’s fundraising. All Tommy’s fundraising staff have a responsibility to be aware of 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.

3.1 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 staff and any relevant agencies responsible for 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.

3.2 Sustainability

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.

4. Principles of ethical fundraising

4.1 Refusal criteria

We follow the Fundraising Regulator code and guidance from the Chartered Institute of Fundraising and Charity Commission before refusing a donation. Our principal duty is to further our purpose, and we will only refuse a donation in exceptional circumstances, as donations are essential to achieving our purpose. If we decide that we must refuse a donation, we keep records of our decision and reasons for it. Donations are only refused if we believe the damage to Tommy’s in accepting a donation will outweigh the benefit to Tommy’s of that donation.

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 birthing people, and children:

  • Tobacco
  • Alcohol
  • Pornography
  • Arms manufacturing and export
  • Companies who produce and market home dopplers

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 from or advertise and/or promote products from or with:

  • Manufacturers of Breast-Milk Substitutes (BMS)
  • Companies that do not comply with this Code
  • Companies where the primary business is the manufacturing or sale of infant feeding products

For further information on the Code, download the International Code of Marketing of Breast-milk Substitutes.

Where an individual fundraises for us and receives a donation from their employer, we do not screen these donations, including any matched corporate donations 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 from others to further the work of the charity.

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
  • Accepting a donation may constitute a bribe

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, and associated polices in section 6.

Tommy’s may refuse donations from an individual fundraiser who we believe has brought Tommy’s into disrepute during the course of their fundraising activities.

The responsibility of the judgement on whether Tommy’s should refuse a donation lies with the Fundraising Director for donations of less than £5,000 (for Tommy’s) or the Race Director (for LLHM), then the Senior Leadership Team for donations under £15,000 and then the Board of Trustees for donations over £15,000.

Before a donation is refused or returned, those making the decision will consider and act in the best interests of Tommy’s and will only refuse the donation if they believe the damage will outweigh the benefit of the donation. Records will be maintained which document any issues around the raising of the funds, any reputational concerns, and the financial impact of refusing a donation. In arriving at their decision, legal advice and/or advice from the Charity Commission may need to be sought.

The responsibility of the judgement on whether LLHM Ltd should refuse the fee lies first with the LLHM Race Director, then the Senior Leadership Team and ultimately the LLHM Ltd Board of Board of Directors for significant partnerships.

4.2 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, tainted donations and bribery.

4.3 Due diligence checks

In addition to the refusal and acceptance criteria, due diligence checks provide a route by which the Fundraising team, or anyone accepting money from businesses, individuals, or trusts, can review and assess the suitability for donations and partnership.

Due diligence means carrying out proper 'checks' on those organisations and individuals that give money to Tommy’s. These include taking steps to identify and verify the identity of the donor and assess any risks.

Due diligence will be carried out for significant donations of £20,000 or more annually as a single or cumulative gift, from businesses, philanthropic trusts and foundations, and individuals. In addition, due diligence checks will be done for cause-related marketing activities at any value where Tommy’s is considering entering into a relationship with a commercial participator.

4.4 Fundraising partnerships with businesses

Tommy’s partnerships with businesses and their philanthropic foundations 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 team of Tommy’s can review and assess donations and partnerships:

Tommy’s will not promote any companies or brands by association knowingly linked to the harm or detriment of pregnant women and birthing people, 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 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 information with our data processors is outlined in our Privacy Policy.
  • Tommy’s does not pay celebrity ambassadors or influencers to engage in brand or partnership activity
  • To ensure that all cause-related promotions reflect Tommy’s values, and to comply with the Fundraising Regulator’s Code of Practice, any such initiatives will be reviewed by the Fundraising Director or Deputy Director (for Tommy’s) or the Race Director (for LLHM) for final decision using the due diligence process. Prior to using Tommy’s name or logo in connection with the sale of any product, a written commercial participator agreement must be in place between the business and Tommy’s.
  • When deciding to partner with or accept funding from pharmaceutical companies we will adhere to the following additional principles to ensure that Tommy’s ability to offer independent and unbiased pregnancy information is not impacted:
    • When we accept funding, it is in line with the ABPI Code of Conduct for Pharmaceuticals
    • We will not accept funding from a pharmaceutical company where the promotion of a specific drug or treatment is required, either explicitly or implicitly.

4.5 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.

4.6 Fundraising partnerships with businesses

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 and/or restricted donations 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.

4.7 Gifts in Kind from businesses

Gifts in kind are donations of goods, services, and skills, donated free of charge or at a discounted rate. Some examples might be raffle prizes, office equipment, use of a meeting room or items to giveaway to event participants.

All gifts of this nature must go through the same acceptance and refusal process as outlined in this Ethical Policy. Gifts in kind with a wholesale value of £20,000 or more from a single business must be checked and considered through our due diligence process.

Whereby there will be significant promotion or marketing reach about a gift in kind donation, (e.g. a donation for all runners at an LLHM event where number of people in receipt is large) but the value is less than £20,000, a due diligence check must also be completed.

The responsibility of the judgement on whether Tommy’s should refuse a gift in kind donation due to non-compliance with this ethical fundraising policy lies first with the Fundraising Director (for Tommy’s) or the Race Director (for LLHM), then the Senior Leadership Team and ultimately the Board of Trustees.

4.8 Restricted 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. Restricted donations to a particular area of Tommy’s work are managed by Tommy’s Philanthropy & Partnerships team and are only possible for gifts over £1,000. Please contact [email protected] if you wish to discuss a major gift with us.

5. Roles and responsibilities

5.1 All staff

All staff should be made aware of this policy.

5.2 All fundraising staff

All fundraising staff are responsible for having a good understanding of this policy and must comply with this policy. The policy is reviewed and discussed at Fundraising meetings.

5.3 Heads of teams

Fundraising and LLHM Heads of teams are responsible for ensuring that the people in their teams are made aware of this policy during their induction to the organisation, and that team members have a good understanding of this policy and comply with it from the start of their employment.

5.4 Fundraising Director and Race Director

Responsible for ensuring the policy is understood and reviewed at Fundraising and LLHM meetings and that the policy is kept up to date with any changes in Charity Law that may impact on it.

5.5 Trustees

The board of trustees are responsible for approving the policy.

6. Related policies

Related policies are:

  • Privacy policy
  • Complaints policy
  • Data protection policy
  • Modern day slavery statement
  • Fraud, Bribery and Corruption policy