The National Deaf Children’s Society (NDCS) committed six breaches of the Fundraising Regulator’s code, according to an investigation into door-to-door practices.

The regulator’s probe also found that sub-subcontracted fundraising firms involved, Solution Cardiff Ltd and Vantage Consultancy Ltd, were responsible for six breaches.

The probe was launched three years ago after a journalist contacted the charity with concerns while undercover as a new employee at one of the sub-subcontractors. Wales Online investigations editor Conor Gogarty’s article had raised concerns that fundraisers were being encouraged ‘to behave in ways’ that breached the regulator’s code.



The regulator details that the charity had hired agency Smile Fundraising Limited for its fundraising, with work subcontracted to The Interactive Team Ltd, who then sub-subcontracted Solution Cardiff Ltd and Vantage Consultancy Ltd.

Among breaches by NDCS was a failure to clearly reflect its expectations throughout its fundraising supply chain, which reduced its ability to oversee contractual arrangements.

At the time of the fundraising activity looked at “the charity did not routinely review or approve the contracts used beyond its direct relationship” with Smile Fundraising Limited, although the regulator said that “this was not an unusual practice within the sector at the time”.

The regulator also found that both Vantage Consultancy and Solutions Cardiff had breached its code “regarding the standards expected of those actively involved in face-to-face fundraising activities”.

This finding related to video footage provided by the journalist that showed sub-subcontractors “engaging in persistent and unreasonable fundraising, attempting to fundraise from a potentially vulnerable individual and making deliberately misleading claims”.

According to the Fundraising Regulator the charity had “ended its relationship with the two sub-subcontractors before the journalist’s information was published”.

The NDCS “also provided evidence that, once concerns were identified, it took steps to strengthen its oversight arrangements”.

This included “additional compliance discussions with its agency, changes to how new fundraisers were supported to understand the pay model, and a benchmarking exercise to review remuneration approaches”.

An NDCS spokesperson said: “We regret that we did not have full oversight of our agencies’ subcontracts at the time of this investigation, which relates to work carried out in April 2023.

“As the Regulator acknowledges, our approach reflected common practice at the time. That said, we fully accept the Regulator’s finding that this fell short of the standards expected of us, and we welcome their ruling that agencies must now share these subcontracts with the charities they work with.

“This clarity will help strengthen fundraising standards across the whole charity sector. We have since revised our processes to ensure full oversight and compliance going forward.”

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