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A legal disclaimer

 

Ethical Fundraising Policy

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Effective Date: November 11, 2025
Last Updated: November 11, 2025

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Purpose

Cultivating Generosity is committed to promoting and practicing the highest standards of ethical, accountable, and transparent fundraising.

This policy ensures that all fundraising activities conducted by or on behalf of Cultivating Generosity and its clients:

  • Respect donors’ intentions and rights;

  • Uphold public trust and integrity; and

  • Align with recognized national standards, including the Imagine Canada Standards Program and the AFP Code of Ethical Standards.

 

Guiding Principles

Our fundraising activities are grounded in the following principles:

  1. Integrity: All activities will be conducted honestly, transparently, and in good faith.

  2. Respect: Donors, clients, and beneficiaries will be treated with dignity and confidentiality.

  3. Accountability: Funds raised will be used as intended and reported accurately.

  4. Transparency: Financial and operational practices will be open and accessible to stakeholders.

  5. Stewardship: We act as responsible guardians of the trust placed in us by clients, donors, and the community.

  6. Equity and Inclusion: Fundraising messages and practices will respect diversity and promote inclusivity.

 

Scope

This policy applies to:

  • All consulting, training, or campaign management services provided by Cultivating Generosity;

  • All staff, contractors, and partners representing Cultivating Generosity; and

  • All client projects in which Cultivating Generosity is engaged to design, advise, or implement fundraising activities.

 

Alignment with National Standards

Cultivating Generosity commits to compliance with:

  • Imagine Canada Standards Program, Section C: Fundraising Practices

  • AFP Code of Ethical Standards

  • Canadian Code for Volunteer Involvement

  • CRA Guidance CPS-028: Fundraising by Registered Charities

  • Personal Information Protection and Electronic Documents Act (PIPEDA)

  • Canada’s Anti-Spam Legislation (CASL)

 

Donor Rights and Expectations

We adhere to the Donor Bill of Rights, as developed by AFP and endorsed by Imagine Canada.
Donors can expect:

  1. To be informed of the organization’s mission, how donations are used, and its capacity to use gifts effectively.

  2. To be informed of the identity of those serving on the organization’s governing board and to expect responsible stewardship.

  3. To have access to the organization’s most recent financial statements.

  4. To receive acknowledgment and recognition consistent with their preferences.

  5. To have their personal information handled with confidentiality and in accordance with privacy laws.

  6. To expect that relationships with representatives will be professional in nature.

  7. To be informed whether fundraisers are volunteers, employees, or consultants.

  8. To have the opportunity to delete their name from mailing lists.

  9. To feel free to ask questions and receive prompt, truthful answers.

 

Professional Conduct

All representatives of Cultivating Generosity will:

  • Adhere to the AFP Code of Ethical Standards.

  • Disclose any potential or perceived conflicts of interest.

  • Refrain from exploiting relationships for personal or financial gain.

  • Represent the client organization truthfully in all communications.

  • Decline to participate in or support any activity that is illegal, deceptive, or unethical.

 

Compensation Practices

Cultivating Generosity follows the AFP Standards of Professional Practice, which strictly prohibit percentage-based or commission-based compensation.

Our compensation model is based on time, expertise, and value delivered, not the amount of money raised.
This ensures that all professional judgment is exercised in the best interests of the client and their donors, free from conflicts of interest.

 

Fundraising Communications

All fundraising materials, digital content, and campaign messages created by or for Cultivating Generosity must:

  • Be truthful, accurate, and evidence-based;

  • Avoid undue pressure, manipulation, or emotional exploitation;

  • Reflect the mission, impact, and values of the organization;

  • Include clear calls to action and contact information; and

  • Respect accessibility standards (AODA) and inclusive language practices.

 

Stewardship and Use of Funds

Cultivating Generosity will advise and support clients to ensure:

  • Funds are used only for the purposes for which they were given;

  • Donors receive prompt acknowledgment and recognition;

  • Gifts are recorded and receipted in accordance with CRA requirements; and

  • Donors are informed of the results of their philanthropy.

 

Confidentiality and Data Protection

All donor and client information will be handled in accordance with the PIPEDA and our internal Privacy Policy.

We will:

  • Collect and store only necessary donor information;

  • Protect data through secure systems and limited access;

  • Never share or sell donor lists; and

  • Obtain consent before adding any contact to mailing lists or sharing testimonials.

 

Conflict of Interest

Cultivating Generosity staff and associates must avoid any situation that creates a real or perceived conflict of interest.
Where such conflicts exist, they must be disclosed immediately to the client and, if necessary, to the public.
Examples include:

  • Personal or financial interests in vendors or contractors;

  • Receiving personal gifts or benefits from donors;

  • Serving in a governance role with a client organization without clear disclosure.

 

Third-Party Fundraising

If Cultivating Generosity supports or advises on third-party fundraising events or campaigns:

  • All parties must comply with this policy and the AFP Code of Ethical Standards.

  • Any partnership must have a written agreement outlining responsibilities, brand use, and financial transparency.

 

Accountability and Reporting

We will monitor compliance with this policy through ongoing review of practices and feedback from clients and partners.
Any concerns or breaches of this policy can be reported confidentially to:

Cultivating Generosity
Attn: Ethics & Accountability Officer
Email: <ethics@cultivatinggenerosity.ca>
Phone: 249-535-1501

Reports will be reviewed promptly and handled with confidentiality and fairness.

 

Review and Continuous Improvement

This policy will be reviewed annually to ensure it remains current with:

  • Legal and regulatory changes;

  • Updates to AFP and Imagine Canada ethical frameworks; and

  • Evolving best practices in ethical philanthropy and nonprofit governance.

 

Compliance Summary

This Ethical Fundraising Policy complies with:

  • Imagine Canada Standards Program – Fundraising Practices Section

  • AFP Code of Ethical Standards (2024 Edition)

  • CRA Fundraising by Registered Charities (CPS-028)

  • PIPEDA (Privacy Act)

  • CASL (Anti-Spam Legislation)

  • AODA (Accessibility for Ontarians with Disabilities Act)

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