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Volunteers and interns

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Last updated 6th March, 2026.

This page deals with how far volunteers, including unpaid interns, are protected by the Equality Act 2010 (EqA) employment provisions, or perhaps by other Parts of the EqA.

Summary

  • Very often volunteers cannot claim under the EqA. Most charity volunteers will not be able to claim. Unpaid interns may be protected as being on “work experience”, if not otherwise covered.
  • Any volunteer seeking to argue that they are protected will be focusing primarly on the EqA employment provisions, below. This is partly because it is easier and less risky to make a claim to an employment tribunal than to a county court. Also (so far as I know) there are no precedents for claims by volunteers under other Parts (below) of the EqA.
  • A volunteer or intern is protected by the EqA employment provisions if:
  • There has been some discussion of whether volunteers – if not within the employment provisions – can claim under other Parts (below) of the EqA, namely Part 3 on service providers, and Part 7 on associations if admission to membership is regulated by the association’s rules and involves a process of selection. I’m not aware of any cases of volunteers claiming under these provisions.

“Volunteers come in many shapes and sizes, and it cannot be assumed that all will have the same status in law”
Elias LJ in the Court of Appeal, X v Mid Sussex Citizens Advice Bureau.

Link: Volunteers and employment rights (ncvo.org.uk).

Liability for acts of volunteers

This page is about rights of volunteers, where the volunteer is the victim of discrimination or harassment. A different issue is how far an employer is liable for discrimination by a volunteer: see Who is liable under the Equality Act>Staff who are not own ’employees’: eg volunteers, agency staff.

EqA employment provisions

Any volunteer seeking to argue they are protected by the EqA will be trying to bring themself within the EqA employment provisions, if possible (EqA Part 6). This is partly because it is easier and less risky to claim to an employment tribunal than to a county court, and also because (so far as I know) there are no precedents for claims by volunteers under other Parts (below) of the EqA.

Many volunteers are not protected by the EqA employment provisions. The main situations where a volunteer does fall within the EqA employment provisions are as follows:

Work experience, including interns

Work experience is covered by the EqA employment provisions as an “employment service” (subject to education rules, below), unless the individual is already within the employment provisions as a “worker” below, or as being covered by s.39(1)(a) below. For more, see my page Work experience. Under s.56(6) EqA work experience is seen as “vocational training”, which is an “employment service” by virtue of s.56(2)(a).

Therefore an intern or other volunteer is covered by the EqA employment provisions if it is work experience, even if they are not a worker (though subject to the education rules). In X v Mid Sussex Citizens Advice Bureau, 2012, the Supreme Court (at §20) expressly mentioned an intern as someone who might well be covered by the equivalent provision of the EU directive.

If an education provider has power to afford access to the work experience

Work experience to which an education provider (eg university) has power to afford access is discussed at Work placements related to education courses. If the person is not a “worker” (below) or covered by s.39(1)(a) below, then for this work experience:

  • discrimination by the education provider, and sometimes by the employer is covered by the EqA education provisions rather than by its employment provisions (so claims would go to eg a county court rather than employment tribunal),
  • most discrimination by the employer is potentially within the EqA employment provisions, but it can be unclear whether it is covered by the EqA at all.

If the person legally has a contract to do work (albeit without pay), they should fall within s.83(2) EqA, and so within the EqA employment provisions, either:

  • as having a contract of employment in the normal sense, or
  • more likely as someone who “contracts personally to do work” (other than as an independent business). This is known as being a “worker”. The detailed test is discussed on Employees, workers and beyond, but I discuss it on this page more specifically in relation to volunteers.

If there is genuinely no remuneration (other than reimbursement of actual expenses), it will normally be difficult to show that there is legally a “contract” – or, if there is, that it is a contract “to do work”. However, exceptionally it may be possible to show that there is. Also the language of any document can be important, in deciding whether it is intended to set out commitments rather than just expectations. There are more details below, and also cases: Technical note: Legal contract to do work (“workers”).

  • Maritime and Coastguard Agency v Groom (below), 2026: Coastal Rescue Officers were called “volunteers”. However as well as expenses, they could claim remuneration for most of their activities if they wished. This was described as “compensation for any disruption to your personal life and employment”. The Court of Appeal held that they were “workers”. The court left open whether the same applied to their unremunerated activities.
  • Newham Citizens Advice Bureau v Murray, 2000: The EAT seemed to say that the relevant document set out obligations and commitments for each party despite there being no remuneration, but a tribunal should decide whether it was no more than a training contract, rather than the claimant being contracted personally to do work.
  • Migrant Advisory Service v Chaudri (below), 1998: A charity administrative assistant received flat rate payments. These were allegedly for expenses, but did not reflect expenses she actually incurred. The EAT upheld a tribunal decision that she was working under a contract of employment.
  • Armitage v Relate (below), 1994: An industrial tribunal (so not a binding precedent) held that a “volunteer” Relate marriage guidance counsellor was a worker protected by race discrimination legislation. Among other things, if she did not provide a minimum of 600 hours of counselling, she was required to refund part of the expenses of training her.

There are further cases in the Technical note below: Cases on legal contract to do work.

Arrangements for deciding to whom to offer employment

S.39(1)(a) EqA makes it unlawful for an employer to discriminate “in the arrangements [it] makes for deciding to whom to offer employment”. So, for example, the EqA employment provisions may apply if an organisation uses volunteering as a way of assessing an individual’s suitability for particular work there.

Before 2010, the equivalent provision in the DDA 1995 specifically mentioned the “purpose” of the arrangements. EqA s.39(1)(a) may be interpreted in a similar way. Focusing on purpose, the Court of Appeal held that the DDA provision did not apply in:

X v Mid Sussex Citizens Advice Bureau, [2012] UKSC 59 (particularly Arrangements for purpose of determining to who to offer employment)
The claimant was a volunteer at the CAB. One basis on which she claimed to fall within the DDA was that the CAB, in making available voluntary work for advisors, was entering into “arrangements which [it] makes for the purpose of determining to whom [it] should offer employment” (s.4(1)(a) DDA).

The Court of Appeal rejected her argument. The CAB’s purpose was to secure advisors to provide advice to clients, not to create a potential pool from which full time staff could be drawn.

Note: This case went on to the Supreme Court on another point. The Supreme Court decided that EU law did not extend protection (below).

An example relating to an intern where EqA s.39(1)(a) was held to apply, though only by an employment tribunal so not a binding precedent:

Towns v SL Media (gov.uk) Employment Tribunal, 2021
A job advert for a trainee personal assistant said the role started as an unpaid intern for two weeks, after which a comprehensive basic salary would be offered. The claimant left after three days as an intern, and claimed sexual harassment.

The tribunal found that the two-week unpaid internship was advertised as an unpaid trial period. Both parties contemplated paid work if she was satisfactory in the first two weeks. The claimant entered the “internship” because she understood it was likely to lead to paid work, not because she wanted any training or work experience to embellish her CV. It was part of the “arrangements for offering employment”, in the nature of an extended practical test following interview. Accordingly EqA s.39(1)(a) applied to allow her to claim.

Referring to cases on CAB volunteers (such as X v Mid Sussex above), the tribunal said that this was in no way like six months of carrying out a full range of duties of a CAB volunteer, where it was never contemplated that the volunteer would be paid more than expenses at any stage.

In Newham Citizens Advice Bureau v Murray, 2000 – a DDA claim by somone rejected as a trainee voluntary adviser – the EAT held that the employment tribunal had been wrong to say that the arrangements must be in relation to a specific job vacancy or vacancies. Presumably this would also apply to s.39(1)(a) EqA.

In Nagarajan v London Regional Transport (bailii.org), 1999, Lord Nicholls in the House of Lords agreed with an EAT decision to the effect that a predecessor provision in the Race Relations Act 1976 “encompasses more than setting up the arrangements, for instance, for interviewing applicants for a job. The phrase also includes the manner in which the arrangements are operated; for instance, the way the interviewing arrangements are in fact conducted.”

Special constables

The EqA Employment Code para 11.15 says that special constables are covered by s.42 and 43 EqA (police officers), and so are within the EqA employment provisions even though they are volunteers.

Office holders

Public office holders may fall within ss.50-52 EqA, discussed in the Employment Code from para 11.35, whether or not they are paid.

“Personal offices” within s.49 EqA include only those where the holder is entitled to remuneration (s.49(2)(b)).

European Union law did not extend protection

It was argued (before Brexit) that under the European Framework Employment Directive, employment-style protection against discrimination extended beyond the relatively limited categories of volunteers covered by the wording of the EqA employment provisions.

However, UK courts held that the European Directive did not extend protection for volunteers:

X v Mid Sussex Citizens Advice Bureau, Supreme Court, 2012
The claimant was a volunteer adviser at a Citizens Advice Bureau. She was asked to cease to attend as a volunteer, and alleged that this was disability discrimination. The employment tribunal found that her volunteer post did not fall within the Disability Discrimination Act 1995 (DDA).

She argued that the EU directive required her to be protected. She said the word “occupation” in the Directive covered part-time unpaid volunteers whose activities were a sufficiently significant or important part of the “employer’s” function.

The Supreme Court disagreed, and refused to refer the matter to the EU Court of Justice. “Occupation” in the Directive refered to access to a sector of the market, such as being able to become a solicitor, or a plumber for example, rather than getting a post with a particular employer.

Other parts of the EqA?

So far as I know, there are no precedents for claims by volunteers under the EqA outside of its employment provisions, dealt with above.

I discuss below whether a claim might sometimes be brought under EqA Parts 3 or 7. Such a claim would go to the county court (sheriffs court in Scotland).

Volunteer as service user?

An organisation which takes someone on as a volunteer may in some cases be seen as providing that person with a service that it provides to the public (or to a section of the public), so that Part 3 of the EqA applies.

“Volunteers … may be protected under the services provisions of the [Equality] Act if the organisation providing the volunteering opportunity is providing a service to the volunteer. This has not yet been tested in the courts.”

Para 3.6, Equality and Human Rights Commission Sexual harassment and harassment at work: technical guidance (EHRC website), updated 2024

A volunteer might be seen as receiving a service provided to the public particularly if, say:

  • a disability charity uses volunteers who are themselves the target of its charitable objectives to provide them with opportunities to increase their skills, eg a cafe using particularly people with disabilities to prepare and serve food – but this might well fall within the EqA employment provisions anyway, as work experience (above);
  • perhaps if the organisation has as its object the provision of services to volunteers.
    (On both bullet points: Morris, Morris & Sigafoos The Impact of the Equality Act 2010 on Charities (pdf), University of Liverpool, 2013, p.81-82, discussing the Tom Royston paper below.)

A claimant would want to argue that having them volunteer involves the charity providing to the claimant a service that the charity provides to the public, within EqA Part 3. This argument may well be difficult if essentially the claimant (and other volunteers) are giving up their time with a view to advancing the charity’s objecitives, even if (like with any job) they also value the experience they gain.

It does not seem to be sufficient that the volunteer benefits from other services the charity provides to the public generally. The discrimination or harassment must be “in providing” or “in relation to the provision of” the service being provided to public (s.29(2)(3)) – or, on a reasonable adjustment claim, the PCP must put the claimant at a disadvantage in relation to the provision of the service (EqA Sch 2, para 2(4) with s.20(3)).

Volunteer as member of an “association”?

A person volunteering as a member of an association may be covered by the provisions on ‘associations’ in Part 7 EqA, if admission to membership of the association is regulated by its rules and involves a process of selection.

For example, the EHRC’s Equality Act 2010: A guide for political parties (equalityhumanrights.com) says that political parties will normally meet the EqA definition of an “association”. Also, thinking of Uttley v St John Ambulance below where a discrimination claim by a member of St John Ambulance was dismissed, might that organisation be an association within Part 7 EqA?

For discrimination by the association against existing members, other than failure to make reasonable adjustments (below), s.101(2) is wide – particularly “any other detriment”. For those who are not yet members, assessing ability to do work may sometimes be part of whether one is granted membership, to which s.101(1) can apply. S.101(4) on harassment is also wide. In addition s.101 includes people who are “associates” by reason of their membership of another association (s.107(6)).

An issue that might be disputed on a Part 7 reasonable adjustment claim in relation to volunteer work by an existing member is whether the PCP puts the member at a disadvantage in relation to “access to a benefit, facility or service” within EqA Sch 15 para 2(4)(a) (with s.20(3)). Reasonable adjustments relating to admission to membership are within Sch 15 para 2(4)(c).

There is discussion of Part 7 and other issues in a paper by Tom Royston, Treating volunteers as ‘members of an association’ and the implications for English discrimination law in the International Journal of Discrimination and the Law, 2012: doi.org/10.1177/1358229112446367. The paper also suggests, for example, that a volunteer working for a Citizens Advice Bureau might be a “member” of the bureau (in the ordinary usage of the word “member”), so as to be protected under Part 7 EqA.

Sexual harassment consultation response, 2021

The UK government (Conservative at the time) discussed interns and volunteers in part 4.3 of its Consultation on sexual harassment in the workplace: government response (gov.uk), July 2021. Note that the scope of the EqA is the same for disability as for sex discrimination.

The government distinguished those “working for free” from “pure” volunteers. The first group, it said, “refers to those who are working to gain professional experience and who would likely consider themselves to be interns”. Examples highlighted by people responding to the consultation included those working in the film and television industry or working for political parties. The government believed that “in almost all cases these groups would, and should, be covered by the protections in the [Equality] Act, as even without being paid they would likely be considered to be workers.” In other words, the government considered that they are nearly always protected by the existing EqA employment provisions, discussed above. (Note: It is not clear whether by “workers” here, the government intended to include a person on “work experience” above, who can be within the EqA employment provisions under ss.55-56 EqA (employment services) even if not within the definition of “worker” (or more precisely, even if not within the EqA definition of “employee” which means the same as “worker”).

As regards other volunteers, the government was concerned that extending EqA protections to people carrying out ad hoc, informal volunteering, or to those supporting small, volunteer-led organisations, could create a disproportionate level of liability and difficulties for the organisation. However the government said it might be appropriate to extend protection to those volunteering for large organisations whose employees would already be within the scope of the EqA, and to people volunteering in a more formal capacity that closely mirrored a workplace relationship. It was not clear whether the then government intended to extend the current EqA protection for charity volunteers, either as regards sex discrimination or more generally.

More on arguments for change

In 2009 volunteers were considered by the House of Commons Committee on the Equality Bill. The government set out in the committee why it did not intend to legislate for volunteers (col 440-441, Public Bill Cttee, 23rd June 2009 (parliament.uk)).

Earlier, in April 2009, the House of Commons Work and Pensions Committee had said it “strongly” believed that disability discrimination protection should apply to volunteers. “Volunteers currently have less legislative protection against discrimination than someone going into a sweet shop.” See paragraphs 134-137 of committee report The Equality Bill: how disability equality fits within a single Equality Act (parliament.uk).

See also Opinion Piece from the Guardian: Who will help the volunteers? (theguardian.com), 19th November 2009.

This supplements Legal contract to do work (“workers”), above.

If legally the person has a contract to do work (albeit without pay), they should fall within s.83(2) EqA, either:

  • as having a contract of employment in the normal sense, or
  • more likely as someone who “contracts personally to do work” (other than as an independent business). This is known as being a “worker”. The detailed test is discussed on Employees, workers and beyond, but I discuss it on this page particularly in relation to volunteers.

The contract need not be in writing, though it may help if it is.

Guidance

Some guidance on this test:

Discussion

If there is no remuneration (other than actual expenses), it will usually be difficult to show that there is legally a “contract” – or, if there is, that it is a contract “to do work”. In England and Wales, preconditions for the existence of a contract include intention to create legal relations, and consideration (ie broadly, value going to the individual in return for a promise to work). Apart from the question of whether there is consideration, absence of remuneration will be a pointer – though not conclusive – to there being no intention to create a legal obligation to work (below SE Sheffield Citizens Advice Bureau v Grayson).

It can be seen from contrasting that case with Newham Citizens Advice Bureau v Murray (below), that the language of any document can also be important, in deciding whether it is intended to set out commitments rather than just expectations.

The contractual obligation to work need not be under an umbrella agreement requiring, say, so many hours per month. It may be just in respect of a particular occasion when the volunteer agrees to come in, as with call-outs of Coastal Rescue Officers in Maritime and Coastguard Agency v Groom (below). Presumably if, once on a shift, the volunteer is not contractually free to walk away at any time, they will be a worker. The question is whether walking out before the end of the shift would be a breach of contract, not whether it would breach expectations, or would be dishonourable etc.

Also, although not a binding part of the decision, the Court of Appeal there suggested that “in suitable circumstances” a person might qualify as a worker even with an “‘if’ agreement (‘If you walk to York, I will pay you £100’)” (§61). But if so, that does not seem to apply to an “if” agreement just to pay expenses (next paragraph).

It is consistent with not being a “worker” that if the volunteer works, then the organisation is contractually obliged to pay expenses (such as travel) incurred in working, and indemnify for any liability in respect of negligence at work (below SE Sheffield Citizens Advice Bureau v Grayson). Such an obligation on the organisation need not mean that the volunteer is obliged to work. But in Migrant Advisory Service v Chaudri (below), the claimant was held to be an employee where a so-called expenses allowance was not in respect of actual expenses.

If there is payment of (or a right to claim) remuneration beyond actual expenses the person is normally likely to be a “worker”, and so able to claim under the EqA. That may also be the case if there is other consideration such as a promise to train the volunteer.

Examples of cases where courts have held volunteers were or may be “workers” (ie contractually obliged to work) are set out above: Legal contract to do work>Examples of successful claims. There are further cases, and more detail on them, below.

Basically the following are cases on whether or not a so-called volunteer is an “employee” as defined in the EqA, or (substantially the same test) a “worker” within other employment legislation. See Employees, workers and beyond>Technical note: statutory definitions of “worker”.

In Groom below, so-called volunteers were held to be “workers” in respect of activities for which they could claim remuneration if they wished. The court left open the position on their other activities.

Maritime and Coastguard Agency v Groom, [2026] EWCA Civ 6, Court of Appeal
The court held that Coastal Rescue Officers (CROs) had legal rights as “workers”, despite being called volunteers. For many of their activities they had the right to claim remuneration, if they chose to do so.

The Court of Appeal held that legally, on each call-out for an activity in respect of which they could claim remuneration, there was a contract under which they agreed to perform services. So they met the definition of being a “worker”. The court did not need to decide whether the same applied to their other activities.

Note: Although this was not a case on the EqA, a “worker” would also be protected by the EqA.

In some cases there may be an “umbrella” contract governing all assignments, but Groom illustrates that there does not need to be. There may just be a separate contract for each assignment or call-out.

X v Mid Sussex Citizens Advice Bureau [2012] UKSC 59 (see particularly No contract in this case)
The claimant was a volunteer welfare rights adviser. The volunteer agreement signed by her was described as being “binding in honour only … and not a contract of employment or legally binding”. It was emphasised to her that she was under no legal obligation to attend work, but that it was anticipated that there would be a level of trust and a hope that the expectations reflected in the agreement would be honoured.

Though other points were appealed, there was no appeal against the employment tribunal’s decision that no legally binding contract existed between the claimant and the CAB, and particularly that there was no obligation on the claimant to provide services. Therefore, applying the definition of employment in s.68(1) DDA, the claimant was not in employment.

Note: This case went on up to the Supreme Court, which held that EU law did not extend protection (above).

An unsuccessful claim, where there was no payment apart from expenses, and the “Volunteer Agreement” was expressed as being to “clarify the reasonable expectations” of the volunteer and bureau:

SE Sheffield Citizens Advice Bureau v Grayson (bailii.org), Employment Appeal Tribunal (EAT), 2003
Volunteers at the bureau were held not to be employees/workers within the Disability Discrimination Act 1995. (The claimant, who herself was an employee, therefore had no claim, because at the time the DDA did not apply to an employer with fewer than 15 employees.)

Similarly to the EqA, the DDA defined employment to include “employment … under a contract personally to do any work”. The EAT said that to fall within this, it would be necessary to be able to identify an arrangement under which, in exchange for valuable consideration, the volunteer was contractually obliged to render services to the employer, or else to work personally for it.

The volunteers here were not paid, apart from reimbursement of actual expenses. This was the “most striking pointer” against them having a contract of service or for services. Further, the “Volunteer Agreement” (which was not signed by anyone) was expressed as being to “clarify the reasonable expectations” of volunteer and bureau – which the EAT said was not the language of contractual obligation. That document set out a “usual minimum commitment” of six hours, which (said the EAT) was not saying volunteers must work those hours, let alone that there was a legal obligation to do so. Volunteers were expected to give as much notice as possible of holiday arrangements, so the bureau could organise its rota, but the Volunteer Agreement said nothing about the amount of holiday they could take.

As regards training provided to volunteers, the EAT said the crucial question was not whether any benefits flowed from the bureau to a volunteer in consideration of work actually done. Like many similar charitable organisations, the bureau provided training for its volunteers, and expected of them in return a commitment to work for it. But the work it expected of them was expressed to be voluntary, was in fact unpaid, and all the Volunteer Agreement purported to do was set out the bureau’s expectations of its volunteers. It was open to a volunteer at any point, with or without notice, to withdraw their services from the bureau, in which event the bureau would have no contractual remedy against the volunteer. So the volunteers were not employees/workers within the DDA. [Contrast Armitage v Relate, below]

The EAT accepted that there might be a legal contract to reimburse the volunteers for expenses, and to indemnify them for negligence claims by clients, if they worked for the bureau. But there was no contract obliging them to do any work for the bureau.

A case where travel expenses only were paid, but the EAT overturned a tribunal decision that the claimant was not a employee/worker and sent it back to be reconsidered:

Newham Citizens Advice Bureau v Murray, Employment Appeal Tribunal (EAT), 2000.
This was a claim under the Disability Discrimination Act 1995. The claimant argued that it had been discriminatory for the citizens advice bureau (CAB) to reject him for a role as a trainee voluntary adviser. This was an unpaid role, but travel expenses would be reimbursed.

The document that the claimant would have signed, had he been accepted for the role, included various commitments by both parties, such as the claimant’s commitment to volunteer two particular days a week, and the CAB’s commitment to provide training.

The employment tribunal (ET) said that there was no obligation on either party, and decided that the DDA did not apply. The ET said the CAB could terminate the relationship at any time, and there was no obligation on the “trainee” volunteer adviser to attend if he chose not to.

The EAT overturned this decision and sent it back for reconsideration. After summarising the terms of the document, the EAT said that it set out for each party a series of separate obligations and commitments. No tribunal properly directed could conclude that there was no obligation on either party. Also the absence of pay was only one of a number of factors to be weighed in the balance. Furthermore, clearly a volunteer would have a legal right to claim for travel expenses.

An ET would need to consider whether the contract was an employment contract or contract personally to do any work (in which case the DDA applied), or was no more than a training contract under which the claimant was not contracted personally to do any work but simply contracting to undergo training in the manner prescribed. The ET would have to receive evidence on what actually happened in terms of the mix between formal training, supervision whilst at work, and work performed during the training period.

Note: A further issue in this case was whether it was in any event arrangements for determining to whom to offer employment (above).

Uttley v St John Ambulance (bailii.org), EAT, 1998
The claimant was a member of St John Ambulance. She had regularly attended public events (such as concerts, football matches and other public sporting events) as a member, providing first aid services to the public and participants in the event. She was not paid a wage or salary for any of these activities. She was paid actual out-of-pocket expenses, and would receive what might be termed “fringe benefits” in the form of refreshments or meals provided by the organisers of the events she attended. In addition, of course, she obtained free entry to those events when on duty.

The EAT upheld a tribunal decision that the claimant could not claim under the Sex Discrimination Act 1975, because if there was a contract, it was not a “contract personally to execute any work or labour” within the 1975 Act. (A lot of the argument related to the claimant’s submission that under rules applicable in this case, there was an obligation to maintain “efficiency”, which the EAT rejected.)

Note: On these facts, another issue might now be whether the claimant was protected under EqA Part 7 as a member of an association (above), in a county court claim.

A case where flat-rate “expenses” not reflecting any actual significant expenses of the so-called volunteer were held to be remuneration, and she could claim for discrimination:

Migrant Advisory Service v Chaudri (bailii.org), EAT, 1998
The claimant “volunteered” for a charity, working as an administrative assistant 12 hours a week, Mon-Thurs 10am to 1pm. She was paid a flat rate of £25 per week, later increased to £40. The charity said this was an agreed flat rate for expenses paid to all volunteers. However, the claimant lived close by, and did not take a lunch break. The tribunal put it to the charity’s chairman that if she had walked to work and left at lunchtime to go home and make herself a meal, her actual expenses for the day would be negligible.

The EAT held that the tribunal was entitled to decide that the weekly sums she received were remuneration, so she was to be treated as working under a contract of employment, albeit an oral one. Therefore she was entitled to claim for unfair dismissal and sex discrimination.

An industrial tribunal decision so not a binding precedent, but an interesting example of a tribunal being willing to treat a “volunteer” as an employee or worker within employment legislation:

Armitage v Relate (ncvo.org.uk), Industrial tribunal, 1994 (IT Case Number: 43438/94)
A “volunteer” Relate marriage guidance counsellor was held to be a worker protected by race discrimination legislation. After a rigorous training process, she was required to refund part of the training expenses if she did not provide a minimum of 600 hours of counselling. She was also required to provide a minimum amount of hours each week.
See further on this case Volunteers and the law: information sheet (causewayvc.org). I haven’t seen the full tribunal decision.

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