Acceptance and Refusal Of Donations Policy
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Applicability
This policy applies to all members of our charity, including trustees. It is to be brought to the attention of anyone who is involved in accepting donations.
Compliance
As a registered charity, we comply with all relevant UK laws and regulatory guidelines, including those issued by the Charity Commission, HMRC and the Fundraising Regulator.
In soliciting funds we will not knowingly mislead or provide false information, nor put undue pressure on a donor, particularly if he/she may be vulnerable.
We will also take all reasonable steps to avoid asking for regular donations (for example, by direct debit) from anyone aged under 18.
Acceptance of Donations
We accept donations on a good faith basis. That is there is a presumption that a donation is acceptable, unless there is evidence to the contrary. We carry out appropriate risk based due diligence to mitigate this risk to an acceptable degree.
In deciding to accept, or reject, a donation we balance the impact on our beneficiaries of not accepting the funding, against the impact on our charity of accepting a donation that should not have been. That may include risks such as harm to our beneficiaries’ interests, reputational damage, loss of public trust and the risk of breaking the law.
Factors we will consider in making decision will include any physical or mental-health condition, disability or learning difficulties the person may have, whether the person is facing times of stress or anxiety, whether a donation is likely to affect the person’s ability to sufficiently care for themselves or leave them in financial hardship, how well the person can speak and understand English, whether the person is under the influence of alcohol or drugs and the person’s age.
Refusal of Donations
We will not accept a donation where there are reasonable grounds to believe:
· The individual or organisation holds views, or is involved in activities incompatible with our values as a charity.
· The donation may be an attempted scam, or to launder money or evade tax, or is in some other way illegal.
· There may be private benefit linked to the donation, such as an obligation to purchase goods or services from a specified company.
· Conditions attached to the donation are so inflexible that they undermine our independence.
o Or are so onerous as to compromise our effectiveness.
o Or restrict who may benefit to the extent of undermining our public benefit obligation.
· The cost of accepting the donation would exceed its value.
Returning Donations
Depending on the circumstances, such as any terms attached to a donation and how the funds were raised, there may be restrictions on whether a donation can be returned. We will seek appropriate professional advive and, if necessary, the agreement of our charity regulator, to authorise the return of a donation.
Regulatory Guidance
· Charity Commission – advice on suspect donations.
· Fundraising Regulator – behaviour when fundraising.
The Institute of Fundraising has produced a practical guide.
Approval and Review
Approval By
Date
Next Review Date