Volunteers play an important role within many charities. Conducting proper due diligence as part of their recruitment and management is an essential part of getting to know them and can also reduce the risk of fraud.

Introduction

Volunteers are one of the public faces of charity. While most have good intentions and are honest and trustworthy, corrupt behaviour by even one volunteer can reflect poorly on a charity and sometimes the sector as a whole.

By putting appropriate policies, processes and practices into place for the recruitment and management of volunteers, charities will be more likely to identify when fraud has been committed by a volunteer and, even better, prevent it from happening in the first place.

Common risks

• Shop volunteers stealing from the till.
• Volunteer fundraisers stealing or refusing to return fundraising materials provided to them.
• Shop volunteers stealing items donated to a shop by members of the public.
• Volunteer fundraisers using items provided to them as fundraising raffle prizes for their own purposes.
• Office volunteers stealing personal data from a secure database without authorisation.
• Volunteers submitting claims for travel expenses that do not relate to their voluntary role (ie, falsifying expenses).

What is due diligence?

This refers to the practical checks you can make to confirm the identity, credentials and good standing of the individuals who give their time to your charity.

It is important to get to know your volunteers in this way because they may have access to such things as charity funds, personal data and restricted physical locations, all whilst being in a position of trust in the eyes of the public and your charity’s beneficiaries.

Basic checks

Depending on the role a volunteer has applied for, it is important to establish what level of screening you will need to undertake on them. Some volunteer roles may require additional screening, for example if the volunteer is working with children or adults at risk.

• It’s important that you verify the identity of everyone who is volunteering with you. Ask each volunteer for two pieces of ID: one piece should contain a photo of them and one should provide their address and be dated within the past six months.
• Ask for references for your volunteer. Some organisations stipulate that referees must have known volunteers for at least two years and cannot be related to the volunteer through blood or marriage. Ideally, at least one reference should be a professional reference, such as their current or most recent employer or volunteer coordinator/tutor.
• Ask volunteers to declare any unspent criminal convictions. Criminal history checks may also be required in certain circumstances.
• Perform online searches to see if there are any areas of concern about your volunteer in the public domain (eg, newspaper reports of past misdemeanours).
• Ensure your volunteer agrees in writing to abide by your charity policies and processes. Check from time to time that your volunteers know what these are.

Warning signs

Certain kinds of behaviour can be red flags for volunteer fraud.

• A reluctance or an objection from your volunteer to your requests to provide certain information during the recruitment process (eg, unspent criminal convictions).
• A reluctance by your volunteer’s referees to provide references for them.
• Difficulty keeping in touch with your volunteer.
• Difficulty getting information from your volunteer in response to your questions.
• A perceived behavioural change in your volunteer (eg, your shop volunteer changes their shift pattern or suddenly begins to live beyond their means).

None of these are clear-cut evidence of fraud, but they might point to the need for further investigation.

Handling suspicions

If you suspect fraud:

• report your suspicions to the appropriate manager (check your organisation’s whistleblowing policy for details);
• do not try to investigate the matter yourself; and
• do not talk to other colleagues about your concerns.

Taking action

If you suspect volunteer fraud act promptly.

• Refer to your response plan which explains how, when and by whom the suspected fraud will be investigated, reported and resolved. This might include engaging external professional support.
• Report the incident to your relevant national law enforcement agency. In the UK this is Action Fraud (England, Wales and Northern Ireland) or Police Scotland (Scotland).
• Report matters promptly to your charity regulator. For reports to the Charity Commission for England and Wales treat it as a serious incident. Use the online form to make your report, stating what happened and how you’re dealing with it.

Checklist

BUILDING YOUR CHARITY’S DEFENCES.
Ask yourself:

• Do we have a clear up-to-date picture of the risks associated with volunteer fraud?
• Have we identified and put in place the appropriate controls to combat the risks?
• Have we got a counter-fraud policy (supported by guidance and processes) that applies to all staff and volunteers?
• Are our counter-fraud policy and processes effectively communicated to all volunteers at the point of recruitment and at regular intervals during their service, so we can be comfortable that they have read and are abiding by them?
• Have volunteers been provided with appropriate training for their role?
• Do we regularly review and improve our counterfraud policy, guidance and processes?

Other resources

The Charity Commission for England and Wales has produced a range of resources covering this area as part of its compliance toolkit. See chapter 3 in the toolkit, ‘Fraud and financial crime’.

The Charity Commission for England and Wales has produced guidance on how to recruit and manage volunteers. See ‘How to manage your charity’s volunteers’.

Preventing Charity Fraud contains resources to help charities prevent, detect and respond to fraud.

ACKNOWLEDGEMENT.
This helpsheet was kindly prepared by Cancer Research UK.

DISCLAIMER.
Published 2019. Last updated August 2021.
© Fraud Advisory Panel, Charity Commission for England and Wales and Cancer Research UK 2019, 2021. Fraud Advisory Panel, Charity Commission for England and Wales and Cancer Research UK will not be liable for any reliance you place on
the information in this material. You should seek independent advice.
This work is licensed under a Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International License.

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