Volunteering or Paid Work? The Store Credit Controversy at JBB

A Facebook post, attributed to “Jayne’s Baby Bank”, states:

“Saturday & Sunday Volunteers: £40 store credit 9am-5pm 8 hour shift, £50 store credit 5pm-10pm, free micro meal and snacks and drinks”

Other posts have advertised “volunteer” shifts at £20 and £25 store credit for shorter hours or other days. This arrangement appears to treat “volunteers” as paid workers, offering substantial store credit instead of reimbursing genuine expenses.

Volunteering vs Employment in UK Law

Under UK law, volunteers must not receive payment beyond genuine reimbursement of out-of-pocket expenses (e.g. travel, actual meal costs) — see GOV.UK: Pay and expenses for volunteers. Flat-rate “rewards,” vouchers, or store credit — whether £20, £25, £40 or £50 — can reclassify a volunteer as a worker or employee, which triggers legal obligations such as:

• National Minimum Wage
• holiday pay
• employer tax and National Insurance contributions

This position is confirmed by guidance from Tozers LLP and HMRC’s National Minimum Wage Manual. HMRC and the Low Incomes Tax Reform Group also warn that vouchers and similar benefits count as “payments” unless they are one-off, unexpected, and of minimal value.

Risks for Benefit Claimants & Disabled Volunteers

Benefit claimants must inform the DWP of any volunteer role — including hours, duties, and any perks received. Store credit of £20, £25, £40 or £50 per shift could be treated as notional earnings, leading to:

• reductions in Universal Credit, ESA, or other benefits
• possible disqualification from certain entitlements

For disabled volunteers, this could have severe financial consequences, with no employment protections in place.

Problematic “Goodwill” Defence

Two public statements attempt to justify the arrangement:

“Paid in stock and it won’t affect benefits/hmrc/tax credits as it is a gesture of good will from myself.”

“This is declared to HMRC and DWP as a gesture of goodwill from myself. This should not affect your tax or benefits.”

These claims are misleading because:

• Calling it “goodwill” doesn’t change the legal reality — fixed-value store credit (whether £20 or £50) is considered payment if it exceeds reasonable expenses.
• Declaration to HMRC/DWP is meaningless without formal employment records, public accounts, or verified compliance.
• If store credit is payment, it still triggers employment and benefit implications, regardless of label.

Unregistered Status & Misleading Branding

Despite presenting itself as a “charity shop,” Jayne’s Baby Bank are not registered with the Charity Commission, as required for legally operating charity shops (source, explanation). Reports suggest applications for registration have been rejected due to non-compliance (investigation). Despite this, trademarks and public materials still use “charity shop” terminology (branding analysis), raising transparency concerns.

Community Commentary & Legal Warnings

UK-based legal advice forums have repeatedly warned that:

“If you pay any money or give a voucher to a volunteer, you risk them being classed as a worker and owed at least minimum wage.” — LegalAdviceUK

“Systematically compensating volunteers for their work generally makes them employees under UK law.” — LegalAdviceUK discussion

These public experiences align with formal UK legal guidance: regular, fixed-value benefits are incompatible with genuine volunteer status.

Conclusion: Operating in a Legal Grey Zone

The “Jayne’s Baby Bank” appears to be:

• unregistered as a charity despite previously using “charity shop” branding
• offering store credit of £20, £25, £40 or £50 as de facto payment to “volunteers”
• relying on unverified “goodwill” claims to dismiss legal concerns

This creates significant risk for both the operator and vulnerable individuals — particularly those on benefits or with disabilities — and underscores the importance of strict compliance when engaging volunteers. Search our transcript engine for more.

Sherlock