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”. 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. 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.
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:
- 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.
- 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.
- If we are required to return the donation by relevant authorities, such as Charity Commission, Fundraising Regulator, Police and so on.
- 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).
- 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 or vulnerable person) 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.
- 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).
- Where we are notified, a donation was intended for another charity and not Family Holiday Charity and there is some evidence to support this.
- Where monies have been taken 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.
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. The process will be overseen by an appropriate person (e.g. Director or Financial Controller):
- Ensuring funds have been paid in and cleared the Charity accounts they were paid into, to avoid fraud.
- 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.
- Other appropriate due diligence checks that are proportionate.
- 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.
- Clear notes are kept in supporter records, and for audit purposes
- Any refund that is required is approved by either the Finance Director or CEO.
- 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 as well as appropriate and proportionate to the size and nature of the donation.
3.2 There are several areas where the application of due diligence in soliciting donations and in managing and accepting donations should be applied, including:
- Assessing whether the money is from a legitimate source and have been obtained legally and ethically.
- Any conditions or contractual obligations attached to a donation, whether they are reasonable and able to be honoured – including partnership agreements.
- Specific cases, such as receiving Gifts in Wills may attract other proportionate diligence checks.
3.3 Internal processes align with this including ensuring:
- Donations and partnerships are in line with the authority levels identified in the Scheme of Delegated Authority.
- Where outside these levels are referred to Audit and Risk and/or Board for approval.
Policy Review
This policy is reviewed annually.
Next review date: November 2026