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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 - Circumstances

2.1    If a donation is refunded or refused in the below circumstances, the Board will be notified, via the Audit and Risk Committee. The circumstances in which the Charity will refund or refuse a donation are: 

  • 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 or supporter (of any type) is connected to a high-profile activity, organisation or situation which has the potential to harm the Charity’s 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, Fundraising Regulator, Police and so on. 
  • 2.1.4    In the event that a committed donation is received, and we are later notified that the donor is deceased. Donations after the date of death can be refunded at the request of the Executor(s). 
  • 2.1.5  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. 
  • 2.1.6   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). 
  • 2.1.7     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). 
  • 2.1.8    Where we are notified a donation was intended for another charity and not Family Holiday Charity. 
  • 2.1.9    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. 
  • 2.1.10    Exceptional circumstances which we have not considered, and which could not reasonably have been expected in day-to-day charity operations. 

Refunding or Refusing Donations – Practice 

2.2    In any of the listed circumstances where donations may be due for refund, there are several steps that must be followed. 

2.3    Donation refund requests must be handled by the relevant senior manager who will undertake the necessary due diligence to establish the facts and check the circumstances. If the relevant departmental senior manager is a part of any complaint relating to the situation, the process should be handled by the Chief Executive.  Process steps must include: 

  • 2.3.1    Ensuring funds have been paid in and cleared the Charity accounts they were paid into, to avoid fraud 
  • 2.3.2    Requesting any evidence that the person requesting the refund has the authority to do so, potentially including asking them to confirm data, timings and so on.
  • 2.3.3    Other appropriate due diligence checks
  • 2.3.4    Where refunds requested are for funds via platforms such as Facebook, Just Giving, that the process laid out by these platforms is followed. Typically, the supporter must request the refund and the refund is made by the platform. 
  • 2.3.5    Clear notes are kept in supporter records, and for audit purposes
  • 2.3.6    Any refund that is required is approved by either the Finance Director or CEO 
  • 2.3.7    An advisory note is prepared for the Trustees via the Audit and Risk Committee 

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: 


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, are they fair and reasonable? 

What guarantees are in place that the partnership is able to continue to meet their contracted obligation. 

Legacy income 

Has the Will been signed under duress, or are their indicators that the deceased has changed their mind. Is the Will open to challenge for failing to leave proper provision etc and is there a chance therefore that the Charity will not receive what 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. 

3.4    Until Acceptance of Donations Part 2 is agreed by the Board, the below framework provides necessary practical and operational approach to support both ethical and compliant fundraising practice:

Activity area:  


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 

  • Flag where  money is donated from an individual via a trust /grant etc as a third party (is this a potential mask for source or money laundering) 


  • 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: January 2024

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