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Fundraising Policy

Acceptance of Donations Policy Part 1

1. Who is this policy and for and what does it cover 

1.1 This policy applies to trustees, staff and supporters (donors and suppliers) of Family Holiday Charity. 

1.2 The Charity must consider any ethical and moral obligations in accepting donations that may conflict with its mission and objectives. The decisions the Board makes about this form the Acceptance of Donation policy.   

1.3 Within the overarching policy framework for Acceptance of Donation there are some more practical matters, around how we will refund donations, and our due diligence when accepting donations.  This forms Part 1 of the Acceptance of Donations policy.  

1.4 The Fundraising Code (issued by the Fundraising Regulator) specifies that we should not “refuse or return donations except in exceptional circumstances” (Code 2.3.1).  

1.5 This paper outlines the definitions of ‘exceptional circumstances’ in which we would refuse or return donations.  

1.6 Some of these circumstances occur with reasonable frequency and so clarity is required for operational efficiency. 

1.7 Outside of this framework, a pragmatic approach to Acceptance of Donations is taken, with anything that is ‘out of the ordinary’, outside the Scheme of Delegated Authority or which has additional considerations – ethical or practical – is referred to the Audit and Risk Committee, the Chair or the Board. This action is taken by the CEO.   
 

2. Refunding or Refusing Donations

2.1 Donations are refunded in the following circumstances – if any of these situations occur, the Charity will being them to the attention of the Board, via the Audit and Risk Committee for guidance and decision.

2.1.1 If a donation is found not to meet the Acceptance of Donation Policy, and where keeping the donation would expose the charity to reputational risk (loss of trust, loss of support from other parties and so on) and would be out of step with our values.

2.1.2 A donor (be that Trust, Individual, Corporate and so on) is connected to a high-profile activity which has the potential to harm the charities reputation and trust, either by direct or indirect association, or because the activities or behaviours are not in line with the charity’s values.  

2.1.3  If we are required to return the donation by relevant authorities, such as Charity Commission, Police etc  

2.1.4 Exceptional circumstances which we have not considered and which could not reasonably have been expected in day-to-day charity operations.  

2.2  In the following circumstances, donations may be refunded but these matters are handled at operational level and with the involvement of relevant senior management.  A key part of processing any refunds in these circumstances is undertaking the required due diligence and fact-checking.  The Board are updated about actions taken.  

2.2.1 If a donation is found to have been solicited from a donor who does not have full capacity to make the donation (including being a minor) and/or where undue pressure has been exerted to solicit the donation (either directly or by a third party we are working with) and there is evidence to support this position. This includes a minor participating in the small charity lottery.  

2.2.2    A genuine error has been made in monies arriving in our bank account which were not intended for us (wrong account no or sort code etc), or where a double donation has been made in error (either the supporters or ours).  

2.2.3    Where monies have been taken from a card during a period of fraud or identity theft and this is confirmed in writing by the card company and/or relevant authorities such as the police.  

2.2.4    Where we are notified a donation was intended for another charity and not Family Holiday Charity.  

2.4 Reason 2.2.4 is fairly common where charities have similar missions or aims, and when supporters donate to more than one charity.  The matter is handled in the Fundraising Code (2.3) outlining the necessary process steps to take.  It is a cross-sector agreement that refunds are made in this situation in order to develop trust in all charities.  

2.5 In any case where a refund is made, the process is always to ensure that funds paid in have cleared accounts they were paid into, as a way of avoiding fraud.   

2.6 If donation refunds made via platforms such as Facebook and Just Giving are requested, the process laid out by these platforms must be followed. Typically, this means the supporter asks the platform for the refund and the refund is made by the platform, and processed back to the charity with other batched transactions. 

2.7 In all cases, clear notes about the transaction and reasons need to be kept for audit purposes. 

3. Due Diligence in Fundraising and Accepting Donations

3.1 The charity’s approach to fundraising and reputational management must both comply with Regulatory frameworks, and be proportionate to our size, capacity and resources.   
3.2 There are several areas where the application of due diligence in soliciting donations and in managing and accepting donations should be applied, such as: 

Activity 

Potential questions or concerns 

Large and one-off donations 

Is the money from a legitimate source, has it been obtained legally and ethically 

Trusts, grant making bodies & foundations 

How are these organisations funded? Is the funding ethical and does it fit with our criteria?  

Partnerships – Corporate 

Does the partner engage in activities outside our Acceptance policy? 

Is the partner able to meet the financial commitments of our partnership?  

Partnerships – Gift In Kind 

What are the conditions of the offer, eg access to data or other information?  

Legacy income 

Has the Will been signed under duress? Is it open to challenge for failing to leave proper provision etc and are were therefore likelihood we will not achieve all that is laid out in the will  

3.3 Our broad approach to mitigating these risks is in development and, subject to publication of Acceptance of Donations Part 2, where this can be updated accordingly. In the meantime, this provides a practical operational framework and approach which supports both ethical and compliant fundraising practice:  

Activity area:  

Actions:  

All areas 

  • Ensure that donations and partnerships are referred in line with the authority level identified in the SODA (Scheme of Delegated Authority) 

Individual donors 

  • Undertake background checks for single donations over £10k (UK bank money laundering limit) via publicly available records.  

  • If the donation is over £10k, refer the donor to our Acceptance of Donation policy and ask them to confirm that their donation complies.  

Trusts, Grants & Foundations 

  • Undertake desk-based research from publicly available records about funding sources and highlight any areas for concern 

  • Share our Acceptance of Donation policy with funders and ask them to confirm their funding sources comply 

  • Make clear notes if money is being donated from an individual via a trust /grant etc as a third party (is this a potential mask for source or money laundering) 

Partnerships 

  • Review ethical credentials against Acceptance Policy limits 

  • Understand partners motivations of partnership. 

  • Ensure agreement is in place (eg CPA) to underpin commitment 

  • Follow payment schedule guidance on approaching non payment  

Legacy notifications 

  • Highlight concerns or questions raised through probate or estate administration  

  • If have questions about sources of income for the estate, flag with Executor or solicitor for confirmation (in line with Acceptance of Donation policy). 

Policy Review 

This policy is reviewed annually. 

Next review date: July 2023