Prohibited money collection practices

 

Providing false or misleading information 

The public must not be provided with false or misleading information about key issues in connection with money collection campaigns. False or misleading information cannot be given about the purpose of the money collection, the organiser or the organiser’s mission. 

Potential donors must always be given enough facts to enable them to make an informed decision about whether or not to donate to the campaign. This also means not concealing key information or emphasising unessential facts. Even factual information can be misleading if unessential facts are emphasised so as to obscure the big picture. 

For example, donors cannot be sent products or gifts that could, due to a bill enclosed with the items, make them think that they have to pay for the goods.

Harassing or pressuring donors

Potential donors must never be harassed, pressured or coerced into donating. Donations must always be voluntary, and those who choose not to donate must not be pressured or made to feel guilty in any way. 

For example, individuals who have previously declined to donate and asked to be left alone must not be sent any marketing circulars or approached again.

Running raffles in connection with money collection campaigns

Running raffles in connection with money collection campaigns is prohibited. This means that donors cannot be entered into any kind of prize draw. All promises of a random chance of winning something are prohibited. In other words, raffles cannot be used as a way to entice the public to donate money.

Obscuring the line between money collection and member recruitment

Money collection campaigns must not be run in a manner that creates a risk of the public’s confusing the campaign with the organisation’s attempts to recruit new members. In other words, it must always be obvious to donors that they are participating in a money collection campaign. 

Asking an individual to donate to a campaign and recruiting them as a member during the same telephone conversation, for example, is forbidden. This is because it can be difficult for the individual to understand what exactly they are being asked to get involved in if several different alternatives are presented to them at the same time. 

It is also important to draw a clear line between an organisation’s normal member recruitment and money collection in the form of recruiting supporting members. If an organisation’s rules specify the terms of supporting membership and the benefits and obligations of supporting members as well as the membership fees charged from supporting members or the way in which the fees are calculated, the recruitment of supporting members is deemed to comply with the organisation’s normal member recruitment rules. Organisations also need to keep a list of their supporting members. Individuals who are being recruited as supporting members cannot be asked to make a monetary donation at the same time.

Recruiting supporting members can constitute money collection, if the terms of supporting membership and the benefits and obligations of supporting members are not specified in the organisation’s rules and if being a supporting member confers no special benefits to such “members”. In such cases, supporting members are not entitled to the membership benefits that other members get in return for paying the membership fee. Collecting membership fees from supporting members without offering them anything in return constitutes money collection. To avoid any confusion, these kinds of money collection campaigns cannot be portrayed as campaigns to recruit supporting members.

Obscuring the line between money collection and business

Money collection campaigns must not be run in a manner that creates a risk of the public’s confusing the campaign with a business operation. In other words, it must always be obvious to donors that they are participating in a money collection campaign.

Many organisations that run money collection campaigns also raise money by, for example, selling a variety of products. This is perfectly alright, and no money collection permit is required. However, a clear distinction must be made between product sales and money collection. There can be no product sales while a money collection campaign is running, and product sale offerings cannot include any elements of money collection. 

Using product sales as a way to disguise what is actually a money collection campaign in order to circumvent the rules on money collection permits and small-scale money collection notices is prohibited. What is presented as product sales can actually constitute money collection if, for example, an inflated price is charged for the products with the excuse that the proceeds will be used to promote a good cause. Another example would be an organisation’s selling a commodity that merely has symbolic value. 

Both money collection campaigns and product sales must always be advertised in a way that leaves the public with no doubt about the objective of the operation: donors to a money collection campaign must understand that they are donating to promote a good cause, and buyers and sellers in a conventional business transaction must recognise that money is changing hands in return for goods, even if the proceeds are being donated to charity.

Rewarding donors

Money collections are usually not allowed to reward donors in any way, and it is usually as well prohibited to hand out rewards to donors. Since donations are always voluntary and given without the expectation of anything in return. Rewards can blur donors’ perception of the nature of the campaign and make them think, for example, that they are purchasing a product. Money collection campaigns can never be designed in a way that creates a risk of the public’s confusing the campaign with a business operation.

Donors can, if desired, be rewarded with collection emblems, symbolic keepsakes of little value. The collection emblem can be for example, a pin or a sticker, which functions as a symbol for participating to the collection. The collection emblem is given to the donors as a compliment for the donation. Therefore, it is prohibited to use a product as a collection emblem that has financial value. In order to avoid confusion, items handed out as collection emblems cannot be sold either, and different items must be used as merchandise.

Promotional items can be also be handed out in connection with appeals for donations. The items must not confuse the public. Donations are always voluntary, and accepting promotional items must not make members of the public feel compelled to donate or think that they are being rewarded for their donation. Collection emblems and other similar gifts cannot be handed out as promotional items; promotional items and collection emblems must be clearly distinguishable from each other. Money collection campaigns also cannot be marketed aggressively or otherwise unethically.

Publishing the donors name does not count as giving a reward or a collection emblem. Donors can be offered an opportunity to have their name or other details published, for example, in a commemorative plaque, on a website or on television. There is no obstacle for this in the Finnish Money Collection Act.

Money collections can also organise events to thank their donors. For example, donors can be invited to an organisation’s public events or to special gatherings of stakeholders. These kinds of events do not count as rewards.

Chain letters and pyramid schemes

Money collection campaigns must not be based on chain letters or pyramid schemes. In other words, chain letters and pyramid schemes cannot be used to collect monetary donations or virtual currency.

Chain letters are communications in which recipients are promised financial benefits if they pass the message on to others. Chain letters can also be sent by email. 

Pyramid schemes are a way of recruiting members via a promise of benefits all or some of which materialise through payments made by others who join the scheme later down the line.

More information about pyramid schemes and chain letters is available here.