What regulators and sector-wide bodies say

Many sector-wide bodies and regulators, from the Charities Commission to the Museums Association, lay out what they expect from organisations undertaking fundraising and accepting corporate sponsorship. In many ways, their policies and guidance overlaps but each has a particular perspective, from the the legal responsibilities of trustees to ensuring that robust due diligence processes are in place.

Scroll down for more information on: Museums Association, International Council of Museums, Arts Council England, Charities Commission, Fundraising Regulator, Institute of Fundraising and the National Audit Office.


Code of Ethics, the Museums Association

MA Code of Ethics

This is a broad set of principles governing all aspects of museum work which all Museums Association (MA) members sign up to. On fundraising and sponsorship, they say…

“Carefully consider offers of financial support from commercial organisations and other sources in the UK and internationally and seek support from organisations whose ethical values are consistent with those of the museum. Exercise due diligence in understanding the ethical standards of commercial partners with a view to maintaining public trust and integrity in all museum activities.”

You can view the full code and find out more here.


Code of Ethics for Museums, International Council of Museums (ICOM)

ICOM Code of Ethics

Like the MA, ICOM also has a ‘Code of Ethics for Museums’ which sets the minimum standards of professional practice and performance for museums and their staff. They note that…

“The governing body [of a museum] should have a written policy regarding sources of income that it may generate through its activities or accept from outside sources. Regardless of funding source, museums should maintain control of the content and integrity of their programmes, exhibitions and activities. Income-generating activities should not compromise the standards of the institution or its public.”

You can view the full ‘Code of Ethics for Museums here.


Arts Council England (ACE)

ACE Logo

As well as distributing funding, Arts Council England plays a central role in shaping the debate on fundraising. In 2016, the outgoing Chair of ACE Sir Peter Bazalgette gave a speech where he highlighted that…

“Boards [of trustees] need to have foresight, and to be able, for example to develop a clear and consistent policy around ethical sponsorship, deciding what is or is not appropriate for their particular organisation… What matters is clarity, consistency and transparency.”

You can read his full speech here. Also, ACE’s 10-year strategy ‘Great Art and Culture for Everyone (2010-20)’ has five goals. Goal 3 is to create a sector where…

“The arts, museums and libraries are resilient and environmentally sustainable”

And more specifically…

“In response to changing economic conditions and cuts to public funding, we want to encourage and enable more private giving to our funded organisations. We are also committed to embracing environmental sustainability and reducing our carbon footprint, both within the Arts Council and the organisations we fund.”

You can read full details of how ACE intends to implement Goal 3 here. What this goal means in practice is still emerging but by placing their objectives on sustainability and fundraising alongside one another, ACE is perhaps inviting arts organisations to consider how these areas are connected.


The Charities Commission

Charities Commission Logo

The Charities Commission (CC) provides several guides that are relevant to fundraising and ethics. However, several of these guides provide specific advice and outline some of the essential structures and policies that should be put in place by charities and charitable organisations.

The following guidance is specifically directed towards trustees but is also relevant to staff with responsibilities for fundraising…

“Before decisions are made about whether an agreement with a commercial partner is in your charity’s best interests you should have effective systems in place to ensure that…the partner is a suitable and appropriate body to work with – a significant aspect of a trustee’s legal duty to protect charitable assets, and to do so with care, means that there should be proper due diligence checks on those organisations that work closely with the charity; ensuring that the appropriate level of research and checks are carried out will help you and your co-trustees to satisfy yourselves about the solvency, integrity and reputation of the partner and their ability to deliver to an acceptable standard.”

You can read ‘CC20 – Charity fundraising: a guide to trustee duties’ in full here.


Code of Fundraising Practice, Fundraising Regulator

Code of Fundraising Practice

The Code of Fundraising Practice sets out the principles and guidelines for organisations that engage in fundraising activity. This code is enforced by the Fundraising Regulator. It is the Charities Commission’s expectation that all charities and charitable organisations should adhere to the Code of Fundraising Practice.

While the Code as a whole is applicable, it includes a dedicated section on ‘Corporate Partners’. In particular, that section notes that…

“Organisations MUST carry out a process of due diligence, proportionate to the scale of the relationship, before engaging in a partnership.”

You can read the full code here.


The Institute of Fundraising

IoF logo

The Institute of Fundraising (IOF) previously hosted and enforced the ‘Code of Fundraising Practice’, prior to the formation of the Fundraising Regulator. However, the IoF provides a range of resources and guides on how to fundraise effectively, accountably and follow best practice.

The IOF’s ‘Charities working with business guidance’ is perhaps one of the most detailed and specific descriptions of the provisions a charity needs to make when working with companies and corporate partners. It states that…

“A policy on working with companies, agreed by the trustees, is essential for a charity to be able to engage effectively with the corporate sector. The policy should define the parameters of associations across all types of corporate and partnership activity. However this is just the first step. There needs to be a process for decision-making, including a clear delegation of responsibilities, since working with companies is the classic example of where value judgements need to be made. All those responsible for the development of these relationships should be given specific instruction on the charity’s boundaries on corporate engagement and at what point the decision making body decides whether or not an initiatives should proceed. The complexity of the issues that need to be addressed will define the process.”

The full ‘Charities working with business guidance’ can be viewed here.


The National Audit Office

NAO logo

The National Audit Office (NAO) is a body that scrutinises public spending for parliament and, within that remit, undertakes investigations into the spending of money by DCMS and those cultural institutions that it funds.

Its recent report ‘Due diligence processes for potential donations’ published in July 2017, gives specific guidance on fundraising, several examples of best practice, as well as highlighting areas where the sector is falling short. While the report’s primary focus was arrangements made by museums and galleries for gifts and donations, many of its conclusions are relevant to sponsorship.

For example, they note that…

“In the best-practice examples [of policies and processes on donations], the risk factors identified for potential donations were not only those which implied legal risk or issues with the provenance of the donation but also took into consideration whether the source implied any conflict of interest with the entity’s charitable objectives.”

You can read the Museums Association’s article summarising the report here, or read the NAO report in full here.

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