Donation Acceptance & Due Diligence
Donations are essential to our mission and support our work helping Somerset communities to thrive. In line with our regulatory responsibilities as a registered charity, it’s essential for Somerset Community Foundation’s staff team and trustees to manage any risk associated with donations and setting up new funds.
This means carrying out research or checks on individuals and organisations that give money to our charity.
Our policy follows the Code of Fundraising Practice as detailed by the Chartered Institute of Fundraising and aligns with the Charity Commission’s Compliance Toolkit.
When we carry out checks on donations
For us to manage risk we’ll carry out checks on any donation which meets one or more of these criteria:
- The gift is worth £5,000 or more.
- SCF have concerns about the provenance of a donation or any characteristics that raise concerns or suspicions, such as donations coming from overseas.
- Where donations come from organisations or individuals where the source of the funds, or the personal or business activities of the organisation or individual, may cause reputational risk to the charity.
- Any donation coming from a business or individual within a very high-risk or high-risk category as defined by our Donation Acceptance & Due Diligence Policy.
We will also carry out checks on existing donors whose donations meet one of the above criteria at least every three years or if any information comes to our attention which we believe may result in the donor failing our due diligence checks.
If our findings raise questions about whether the source of a donation is from criminal activity, we’ll inform the National Crime Agency and comply with its requirements and our legal obligations regarding reporting of evidence relating to proceeds of crime. We may also seek advice from the Charity Commission where necessary or appropriate.
How we conduct checks on donations
We’ll carry out research on any individual and/or company involved with the gift, based on the Charity Commission’s Know Your Donor Key Questions. We may also speak with people already known to SCF to seek their knowledge/input and on occasion may conduct peer references (references will always be flagged to the donor in advance of requesting them). Donors can request to see any research compiled about them in line with our Privacy Statement.
We will record our findings and store them alongside any other information about a donation. We will use the findings to decide whether acceptance would:
- Breach any obligation under charity law or other legislation (including but not limited to the Proceeds of Crime Act, Sanctions and Anti Money Laundering Act and the Bribery Act).
- Involve unacceptable risk of damage to Somerset Community Foundation’s reputation.
- Be incompatible with the purposes or the strategic and charitable objectives of SCF.
- Be inconsistent with the general ethos of SCF.
- Create undue additional costs or burdens for SCF.
How we decide whether to accept or refuse a donation
The Trustees (and their delegates) ultimately have the responsibility to decide, based on evidence available to them, whether the charity’s best interests are served by accepting or refusing a donation. In doing so they must be able to demonstrate that they have acted in the best interests of the charity, irrespective of any individual or collective personal interest or bias, in every case.
SCF will consider donations from individuals and donations from companies based on the level of potential risk involved. The CEO, with advice from the Philanthropy and Marketing Director, is responsible for
determining the risk associated with a donation.
Any donations rated High Risk will be referred to SCF’s Finance & Governance Committee with a recommendation to accept or refuse, and any donations rated Very High Risk will be referred directly to the Board. Finally, any decision to refuse a donation will be made by the SCF Board.
