The Haven Wolverhampton are registered with the Fundraising Regulator and abide by rules and regulations set out in the Code of Fundraising Practice. We commit to the high standards of the Regulator and our Fundraising Promise to all donors in line with the regulator can be found on our website.

This policy has been written using guidance from the Code of Fundraising and the Institute of Fundraising; specifically, ‘Treating Donors Fairly’.

The Fundraising Regulator Code of Practice states in the General Principles that:

i) “Fundraisers MUST take all reasonable steps to treat a donor fairly, enabling them to make an informed decision about any donation. This MUST include considering the needs of any potential donor who may be in a vulnerable circumstance or require additional care and support to make an informed decision.

ii) Fundraisers MUST NOT exploit the credulity, lack of knowledge, apparent need for care and support or vulnerable circumstance of any donor at any point in time”

iii) If a fundraiser knows or has reasonable grounds for believing that an individual lacks the capacity to decide to donate, a donation MUST NOT be taken.

iv) A donation given by someone who lacked capacity at the time of donating MUST be returned.

By ‘vulnerable’ we mean any individual who finds it difficult to make an informed decision about supporting or donating to the charity. There are several factors which can indicate vulnerability. It is not feasible to provide a comprehensive set of characteristics which would always identify vulnerability. However, we follow best practice as laid out in this policy and the bullet points below cover main indicators. We have faith in our fundraisers to identify vulnerability beyond or outside of these bullet points. Characteristics include (but are not limited to):

• physical and mental medical conditions
• disability
• learning difficulties
• times of stress or anxiety (e.g. bereavement, redundancy)
• financial vulnerability (where a gift from a donor may impact on their ability to sufficiently care for themselves or leave them in financial hardship)
• A lack of understanding/fluency in the English language
• Influence of alcohol or drugs
• any person under 18 years of age without parental/adult consent/presence

The Haven Wolverhampton value our supporters and want to ensure that those who choose to donate and support us are treated fairly and with care. All staff and volunteers involved in fundraising and marketing will read a copy of this policy demonstrating an understanding surrounding vulnerability and understand the actions taken by the organisation in given circumstances. Fundraisers will also keep up to date with the Code of Fundraising to ensure we always fundraise within best practice. The Haven Wolverhampton recognises that it may sometimes be difficult for fundraisers to assess the vulnerability of a supporter. In cases where a fundraiser is unsure, they must consult their line manager before accepting any donation. The team as a whole will always err on the side of caution when assessing vulnerability. If a member of the team believes they have interacted with a vulnerable supporter and is concerned about their welfare, they must follow The Haven Wolverhampton’s Safeguarding Adults, or Safeguarding Children’s Policies.

There are several indicators which can help to identify vulnerability by the different communication channels used by The Haven Wolverhampton’s Fundraising Team.

Communicating via phone or face to face
Indicators that a person may have a mental health vulnerability include:

• Asking irrelevant and unrelated questions
• Responding in an irrational way to simple questions
• Asking for questions or information to be repeated
• Taking a long time to respond or finding it difficult to respond
• Repeating questions they have asked
• Wandering off the subject
• Displaying signs of forgetfulness

Indicators of physical vulnerabilities:

• Unable to hear or understand what is being said
• Unable to read and understand the information provided to them
• Displaying signs of ill health e.g. breathlessness or discontent

Communicating via letter or email

We can at times identify vulnerability through written communications:

• A supporter who has emailed or written to us to tell us they are vulnerable
• The supporter’s family member or carer has indicated that they are vulnerable
• Someone whose handwriting is particularly shaky and hard to read. This is an indicator that the supporter is frail and to be cautious
• Sentences that don’t make sense or trail off

We will be patient and won’t rush the conversation – it’s better to have a longer conversation than cut this short and leave the person confused or agitated in any way.

We will ask if the person would prefer another method of communication e.g. offer to send information in the post or via email, so they have time to take in the information.

We will ask the person if they need to speak with anyone else before deciding.

We will check their understanding of what they have agreed to – for example, ask them to repeat this information back to us.

All of the above will help to make sure that the person comes first, and we give them time to make an informed decision, if they are capable of doing so.

Family member or guardian / carer contacting The Haven Wolverhampton to disclose vulnerability

• If we are alerted to a vulnerable supporter by a family member or carer, we will assess on a case by case basis to ensure compliance with GDPR as well protecting the vulnerable person.
• Where we are provided with information, we will act upon this, reviewing any donations previously made, returning these donations where appropriate, and we will ask what kind of communication, if any, is acceptable.
• Our database is updated to reflect wishes using the critical info box; ensuring the pop-up option is ticked. If the donor / carer wishes, they are removed altogether from our database. We cannot disclose any information to the family or carer regarding the supporter unless they have power of attorney.

The Haven Wolverhampton does not accept donations if we have reason to believe that a donor is vulnerable and lacks the capacity to make an informed choice about donating. We will not accept any donations where we feel that accepting the donation would be ethically wrong and/or harmful to the donor.

Should a situation arise where The Haven Wolverhampton becomes later aware that it has unknowingly accepted donations from an individual during a time that he or she was experiencing vulnerable circumstances, The charity will take all reasonable steps to return all donations accepted during this period.

If a donor is identified as vulnerable, the organisation should put in place measures to ensure that donations are not solicited from them in the future in the following ways through the database:

• use the critical information section, ensuring the pop-up option is ticked
• tick the donor as no correspondence
• update indictors to say ‘no fundraising marketing’ ‘no newsletter’

Age does not indicate whether a person is vulnerable or not. There are many older people who are active and leading comfortable lifestyles. Equally a much younger supporter could be in a vulnerable position. Therefore, The Haven Wolverhampton will not make a judgement based on age; vulnerability is assessed on individual circumstances. However, if a supporter is identified as being under the age of 16, then we will immediately stop them from receiving fundraising appeals and calls.