DONATIONS AND ETHICAL FUNDRAISING

Donations and Ethical Fundraising Policy

1) Purpose

To set out how we accept, refuse or return donations and fundraised income in a way that protects beneficiaries, upholds our values, and complies with law and guidance, including The Fundraising Regulator’s Code, Charity Commission Guidance and UK GDPR legislation.

2) Principles

• Public benefit & independence: Donations must further our objects and must not compromise independence.

• Integrity & transparency: We fundraise honestly, respect donor intent, and report clearly.

• Safety & respect: We protect vulnerable people and handle data lawfully.

• Value for money: We seek efficient, proportionate fundraising activities.

3) What we can accept

• Unrestricted funds: Preferred; enable greatest impact.

• Restricted funds: Accepted where the restriction aligns with our objects and is practical to deliver.

• Gifts-in-kind: Including donated tech, services or venues, where safe, legal and useful.

• Corporate support: Donations, sponsorship, employee giving, and matched funding that meet this Policy.

4) Conditions for acceptance

We will accept support only if it:

• Aligns with our charitable objects and values;

• Does not impose undue influence over strategy, operations, or research findings;

• Is not illegal, unethical, or high-risk (e.g., linked to criminality, sanctions, modern slavery, serious environmental or human-rights abuses);

• Is deliverable within our capacity and risk appetite and policies and procedures; and

• Is transparent: donor identity is known to the Charity (anonymous public recognition is allowed for in section 10).

5) Due diligence (risk-based)

• Standard checks: Identity, source of funds, Companies House/Charity overview, adverse media.

• Enhanced checks (trustee sign-off required) if:

  • Single gift ≥ £10,000 (individual) or ≥ £25,000 (corporate); or

  • Cumulative support above these thresholds; or

  • Higher-risk sectors/jurisdictions; or

  • Conditions/restrictions attached.

• Outcomes: Accept / accept with conditions / decline. Document rationale in a brief decision note.

6) Conditions & restricted gifts

• Conditions must be compatible with our objects and not create private benefit or control over governance.

• We will document restrictions, budgets and reporting in writing.

• If delivery becomes impossible, we will seek donor consent to vary; if not possible, we may return funds or apply to the Commission for a cy-près scheme (as appropriate).

7) Returning or refusing donations

We may refuse or return a donation if it:

• Risks significant reputational damage or conflicts with our values;

• Is suspected to derive from criminal activity;

• Imposes inappropriate conditions; or

• Cannot be used for the stated purpose.

Serious concerns will be escalated to the Board and, if necessary, to relevant authorities.

8) Corporate partnerships & sponsorship

• Must be arm’s-length and consistent with our values.

• Any recognition (logos, case studies) must not imply endorsement of products or unduly influence our independence.

• Written agreements will set deliverables, recognition, brand use, and termination rights.

• Where the donor is Tech-Takeback Ltd or provides services to us, the Conflict of Interest Policy and independent trustee approval apply; pricing and terms must

represent value for money.

9) Gifts-in-kind (including donated tech)

• We accept donated devices and services that are safe, lawful and useful.

• For Retail Gift Aid (sales of donated goods), we will operate the HMRC Retail Gift Aid scheme with compliant: donor declarations, proceeds notifications, and audit trails.

• For corporate donors, we will provide acknowledgment letters suitable for their tax and VAT records (not tax advice).

10) Anonymity & recognition

• Donors may request public anonymity; we still record their identity internally for due diligence and audit.

• Recognition will be proportionate and must not suggest undue influence.

11) Fundraising standards & vulnerable people

• We follow the Fundraising Regulator’s Code and have procedures for vulnerable circumstances (e.g., capacity, undue pressure).

• We do not conduct high-pressure fundraising or targeted asks to vulnerable people.

12) Gift Aid & records

• We will only claim Gift Aid where valid declarations are held and HMRC rules are met.

• Records (including Retail Gift Aid) will be retained per our Data Retention Schedule.

13) Data protection

• We comply with UK GDPR and PECR; lawful bases are documented; supporters can change preferences at any time.

• Data sharing with processors (e.g., email/CRM providers) is governed by contracts and security standards.

14) Roles & responsibilities

• Fundraising Lead / COO: Applies this policy, conducts due diligence, documents decisions.

• Trustees: Approve policy, oversee higher-risk/threshold decisions, monitor compliance.

• All staff/volunteers: Follow the policy; escalate concerns promptly.

15) Complaints & whistleblowing

• We operate a Fundraising Complaints process and signpost the Fundraising Regulator.

• Concerns about illicit finance or serious wrongdoing may be raised via our Whistleblowing route.
  
  Approval
  This policy has been approved by the Board of Trustees