Ethical Fundraising Policy
Updated August 2019
1.1. As Goodenough College’s Fundraising develops and grows, it is important that this income stream is guided by clear policies and procedures with regard to the criteria that determine whether gifts to the College should be accepted or refused. As an independent institution, it is right that the College makes its own decisions in the area in light of its own circumstances. This Policy should be read in conjunction with the College’s Anti Money Laundering Policy.
1.2. Having an Ethical Fundraising Policy enables a charity to express its values and ethos. Donations to charities should be accepted or rejected for proper, defined reasons.
1.3 The law (Charities Act 1992) states that Trustees can refuse donations if they are not in the best interests of the charity to accept. In deciding whether to accept or refuse a particular donation, the law requires Trustees to carefully consider, on the basis of relevant law (including anti-money laundering legislation) and the evidence available to them, which course of action will be in the College’s best interests. The law allows practical and ethical factors to be taken into account where they are relevant to the College’s charitable objects. In exercising this power, the Trustees must not allow personal views or prejudices to affect their conduct and decisions.
1.3. The Development and External Relations Team and the College Director should always be able to explain their decision making to the Executive Team and Trustees. They will use the Ethical Fundraising Policy to decide which supporters to approach and what support to accept. Once exclusions are agreed, decisions about whom to approach should be simplified. There will, however, always be uncertainties that will need greater consideration.
2. Goodenough College’s Ethical Fundraising Committee
2.1 Goodenough College’s Board of Trustees takes full responsibility for all decisions around the acceptance of gifts. An Ethical Fundraising Committee will be formed of a minimum of two Members of the Fundraising and Development Committee who are also Board Members but are not the Chairman of the Board, a member of the College’s Advisory Council, the Alumni Relations Chair on the Member’s Council plus the College Director and the Director of Development and External Relations.
2.2 The Committee should review the policy when it is felt necessary and meet at least annually to review the terms of reference and the business undertaken by delegated authority. 3. Goodenough College’s Charitable Objectives
3. Goodenough College’s Charitable Objectives
3.1 The objects for which the College is established are to organise, encourage and
assist the education in England of students (“Resident Members of the College”) from any part of the world, giving preference to students from the Commonwealth (with priority for students from those nations less able from time to time to provide resources and facilities of their own).
3.2 The Burn, the College’s academic retreat, offers short-stay versatile accommodation in Scotland. 4. Background
4.1 Goodenough College’s Board of Trustees (‘the Trustees’) has a duty to maximise the College’s income available to expend on pursuing Goodenough’s charitable objectives. This duty is a legal obligation.
4.2 Goodenough College actively seeks opportunities to work with individuals and external organisations to achieve shared objectives. It is vital, however, that the College acts primarily to further its own objects and also that it does not allow individuals and external organisations to bring the name of the College into disrepute. The College will adopt an attitude of professional scepticism in relation to its consideration of these matters.
4.3 Goodenough College, therefore, accepts financial support from, and works in partnership with individuals, companies and grant-making trusts on the following conditions:
- There are grounds for believing this will result in a benefit to British and international postgraduate students and academics
- The College is satisfied that neither the independence nor the integrity of the College would be compromised by accepting such support
- The College is satisfied that any publicity that results from accepting such support will be beneficial to the College.
4.4 This policy sets out the legal and ethical criteria which must be considered when accepting or refusing donations and also when deciding whether Goodenough College should be involved in opportunities connected with accepting donations, grants, sponsorships or other partnerships.
5. All opportunities
5.1 The following principles apply to all opportunities (including donations; grants;
Sponsorships; gifts of property, shares and other securities; pro bono work or other partnership or arrangement).
5.2 Goodenough College must refuse opportunities where:
i) the gift derives from any illegal activities such as (but not limited to) tax evasion, fraud or money laundering and where it is otherwise required to do so by specific, prevailing legislation.
ii) the source of the gift, or its ethical origin is unclear, and/or could impact on the College’s reputation were it to be accepted, regardless of value.
5.3 Goodenough College may refuse opportunities where:
i) the gift comes from an individual or organisation which is in direct conflict with Goodenough’s vision: ‘a fellowship of global citizens with shared values of
tolerance, respect, understanding, service and togetherness (reflecting the spirit of the UK and the principles of the Commonwealth);
ii) it is believed that the cost to the College of accepting a donation/opportunity will be greater than the value of the donation/opportunity itself;
iii) the gift is deemed to come from a vulnerable person or a person in vulnerable circumstances;
iv) the gift is made with the intention of influencing the College with an explicit or implicit exchange for favours or benefits;
v) the gift, through either its magnitude or nature, will unduly restrict the College’s ability to deliver or to be seen to deliver the full scope of its charitable endeavour;
vi) it is considered that the opportunity may, in the opinion of Goodenough College, bring the College into disrepute or involve the College in controversy or publicity which would do meaningful damage to Goodenough’s reputation and standing;
vii) it is otherwise allowed to by specific prevailing legislation.
All opportunities must clearly comply with the College’s Anti Bribery and Corporate Criminal Offences Policies
6.1 A donation from an individual or an organisation which is not aligned with Goodenough’s charitable cause and values may attract questions from our Alumni, Members and other supporters and may lead to materially adverse press coverage thereby damaging our reputation.
6.2.1 Donors must accept and, for gifts greater than £5K, sign appropriate gift agreements that confirm the management and governance of programmes. The College should employ its standard procedures relating to recruitment, admissions, management and governance for all capital and scholarships and bursaries funded by gifts.
6.2.2 Where the College offers to name a building, room, scholarship or any other aspect of its activities in recognition of a particular benefaction, the duration of such naming opportunity should be agreed between the donor and the College. In addition, the College reserves the right to withdraw such named recognition in the future, where:
- it transpires that the source of the funding is suspicious or arose in whole or part from any activity listed under the recommendations regarding the refusal of donations.
- the actions of the donor lead the alignment of the College with the named party to materially damage the College or its ability to deliver its charitable objectives.
- the donor does not meet its commitments in full and in line with the agreed timescale.
7. Commercial Participation Agreements
7.1 Fundraising through commercial participation covers much corporate fundraising, sponsorship and other exchange of benefits. Goodenough College is not obliged to
enter into these arrangements but when it does care needs to be taken to ensure that deals of this kind do not damage the College’s reputation or are in some other way not in the best interests of Goodenough College. Goodenough should not become involved with any person, organisation, business or cause which, in the opinion of the College, might bring the College into disrepute or involve Goodenough in controversy or publicity which would do damage to the College’s reputation and standing. At all times Goodenough College must enter into a written agreement with all corporate partners. This agreement will set out clearly the nature of the partnership and the obligations of each party.
8. Goodenough College’s Fundraising Ethics Process for Governance
8.1 The Ethical Fundraising Committee advises those with the authority to accept donations on behalf of the Board and advises the Board on the Ethical Fundraising policy.
8.2 Board Trustees delegate daily decisions on acceptance of donations to the College’s Development and Executive teams and the Chairman of the Board who will work to the following sign off procedure.
8.3 The Director of Development and the Director of Finance and Resources will ensure that the Fundraising and Development Committee (and, when the College has chosen to accept such a gift, the Audit Committee) is made aware of any potentially suspicious donations and any significant and potentially contentious issues. They will also both ensure that the Director is kept properly informed.
9. Sign Off Procedure:
Value of Gift, Decision on Acceptance can be made by:
Under £15k, Director of Development and External Relations
Between £15k and £50k, Director of Development and External Relations and Director of Finance and Resources in agreement
Between £50k and £100k, Director of Goodenough College
Between £100k and £1m Fundraising and Development Committee by majority. The Chairmen of the Board and of the Audit Committee should be informed of any unresolved disagreement amongst the members of the Fundraising and Development Committee
Over £1m, The Board, acting in the knowledge of the advice of the Fundraising and Development Committee.
9.1 The Ethical Fundraising Committee must review any gift over £100k prior to submission to the Fundraising and Development Committee, the Chairman of the Board or the Board as a whole for a recommendation.
9.2 If those with the above authority are unable to conclude whether a gift of less than £100k should be accepted or rejected under the Ethical Fundraising Policy, then the gift must be referred to the Ethical Fundraising Committee for a recommendation.
9.4 If those with the delegated authority do not feel able to accept the recommendation of the Ethical Fundraising Committee then the matter must be referred to the Board as a whole for a binding decision.
9.5 It is the responsibility of the Director of Development and External Relations to provide the Director of Finance and Resources (or nominee) with sufficient information to properly record and account for the gift, any restriction and the utilisation of the gift.
9.6 It is not envisaged that referral to the Ethical Fundraising Committee will be necessary on a frequent basis but having the security of the system in place will give reassurance to the Development & External Relations team.
9.7 The biggest risk is when a donation is made from a source that is unexpected, i.e. when a donor comes to us without being approached first. This is more likely to happen as the College’s fundraising activities reach new audiences and the work of the College becomes better known.
9.8 The College’s international partner organisations, such as the London Goodenough Association of Canada and the Chapel and York Foundation, will be made aware of this policy. They must not accept a donation to support the College from:
- a donor that the College has refused support from; or
- a donor that would not meet the requirements of the College’s ethical fundraising policy were the donation to be received direct to the College;
- as the College would not then be able to accept subsequent support from the international partner.
9.9 All donations accepted or rejected over £100K will be reported to the College’s Audit Committee. Goodenough College’s Development and Finance teams will take all reasonable steps to ensure that they are aware of the source of funding for each gift, and have processes in place to satisfy themselves that the funds do not derive from activity that was illegal or runs counter to the core values of the College.
9.10 Using the Ethical Fundraising Policy the majority of decisions should be able to be made reasonably easily within the team.
9.12 A truly anonymous donation, where the College only deals with an intermediary who will not identify the donor, even to the College Director or a Board Director, should not be accepted. The risks of accepting a gift without a proper understanding of its provenance are too great.
9.13 A gift by a donor who wishes for their name to remain anonymous to all but the Trustees and senior staff of the College should be dealt with, as far as possible, in exactly the same way as other gifts. If the donor is prepared to reveal their name to the Director, and/or the Director of Development and External Relations, it will fall to those executives to determine its acceptability in terms of the current ethical guidelines; if not, paragraph 9.12 applies. The Ethical Fundraising Committee will be required to have sight of such gifts of a value in excess of £15k for final approval. The donor must be informed of this process from the beginning of any discussion.
9.14 Unsolicited donations from new donors should be flagged to the Director of Finance and Resources as soon as the Development and External Relations Department become aware of the receipt, so it can be decided if the donation requires reviewing.
9.15 If the College is asked to refund a donation made in error, then it must ensure that it complies with relevant Anti Money Laundering requirements. Any refund in excess of £10,000 must be authorised by the Director of Finance and Resources, or the Director on the recommendation of the Head of Finance.
9.15 The College is a member of CASE (Council for Advancement & Support of Education), a professional association serving educational institutions and the advancement of professionals who work on their behalf in alumni relations, development, communications, marketing and allied areas. As such the College fully subscribes to the following:
- Case Europe: Ethical Principles behind the Acceptance of Gifts
- CASE Statement of Ethics
- Principles of Practice for Fundraising Professionals
- Donor Bill of Rights.
9.16 Governance should be reviewed on a biennial basis or more frequently if it is felt necessary. Terms of reference and processes should also be reviewed on a biennial basis, or more frequently if felt necessary.