DCH 181 Sue Ryder Care
AH/CW
28 June 2004
Francene Graham
Committee Assistant to the Joint
Committee on the Draft Charities Bill
Scrutiny Unit, Room G10
7 Millbank
London SW1P 3JA
SUE RYDER CARE RETAIL'S SUBMISSION TO THE
JOINT COMMITTEE
CONSIDERING THE DRAFT CHARITIES BILL
As the Director in charge of Sue Ryder Care's Retail
operation, I would like to make the following submission to the
Committee to assist in its deliberations on the above draft Bill.
- Sue Ryder Care Retail supports the stance taken
by the Association of Charity Shops in its submission to the Joint
Committee.
- Our main reason for concern in the draft Bill
is the notification required and the precision of timing that
the draft Bill envisages. From Sue Ryder Care's experience, this
would significantly increase our workload. There is no doubt
we would have to establish a reporting system, a system of control,
and assign personnel to ensure that both reporting and compliance
were adhered to. This will be a cost in time and a financial
cost; a charge against the Charity's income that I am sure is
not envisaged by the spirit of the draft Bill.
We would also be concerned and fail to understand
how Local Authorities would usefully handle this information
on the basis that it is being requested by the draft Bill. If
you were to take the example of a town with 15 charity shops,
it is not uncommon these would be reporting into a Local Authority
probably on a weekly or fortnightly basis. It would then require
personnel within the Local Authority to process, review and then
take action. It is difficult to see how Local Authorities would
want to handle that level of detail on the regular basis that
the draft Bill envisages.
- We believe that the best way forward is for the
Charity to register with the Local Authority indicating that over
an annual period the appropriate frequency with which it intends
to carry out collections and at any time be available for scrutiny
by the Local Authority. In this way the Local Authority is not
over encumbered with information; yet we believe the spirit behind
that envisaged by the draft Bill would be met as the Local Authority
would know who was operating within its jurisdiction.
- Were then "rogue" collectors or those
not of a reputable status to be operating within a Local Authority,
this would easily be highlighted by those charity operators approved
by the Local Authority and appropriate action taken, particularly
if the public awareness of the standard and significance of the
Association of Charity Shops Kite Mark scheme continues to grow.
28 June 2004
- Government in previous documents has recognised
the role that charity shops play within our communities not only
in raising essential funds for the promotion of its aims, but
also in terms of recycling unwanted goods. Such a regulation
as envisaged within the draft Bill regarding the reporting of
collections will place an additional financial cost on the Charity
in order to ensure its compliance, and create additional bureaucracy
within the Local Authority whose benefit on receiving this information
it is difficult to calculate.
- However, it could be possible for Local Authorities
to sample how charitable retail collections work within the scope
of its boundaries, and Sue Ryder Care could see the benefit for
the Local Authority in establishing say one month in the year,
when collections could be reported; the Local Authority could
then project manage this information to meet the expectation behind
the proposed legislation.
- Charity retailers are concerned to not only operate
within the law, but also within the spirit of good customer service
and the protection of its parent charity's reputation. Retailers
will not put themselves at risk in what is today a highly competitive
sector; self regulation by the charity in order to protect its
competitive advantage and its good name would be sufficient, we
believe, to ensure we stay within the aims of the draft Bill.
The Association of Charity Shops, whilst not a policing organisation,
still requires of its members to operate to the highest standards
and each member has signed an agreement to that effect. We are
not likely to risk our reputation within our own sector by going
outside the aims of the draft Bill.
- In short, we believe the reporting required by
the proposed draft Bill of Charitable Merchandise Collections
is too onerous, would create additional financial cost and more
bureaucracy within the Local Authority, and we do not see the
benefit of receipt of this information on such a frequent basis
being realised by the Authorities. Our own desire to preserve
our reputation both within the sector and within the community
would ensure that Sue Ryder Care Retail would operate within our
acceptable self regulated framework, sponsored by the Association
of Charity Shops, rather than the conditions envisaged within
the draft Bill. However, we would agree, were Local Authorities
to initiate a pilot or sample study once a year, we would be delighted
to cooperate on such a basis, as we have done on very many occasions
in the fields of Trading Standards and Health & Safety, as
from that some real benefit could ensue.
Yours sincerely
ALAN HODGES
Director of Retail
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