An acceptance and refusal of donations policy should be the foundation of all decision making for individual fundraisers, charity senior leadership and trustees. There is no one-size-fits-all approach to this and policies should be proportional to organisations’ capacity and resources.   

It is important to remember that having a policy in place will not necessarily prevent issues arising, but it will help you to:  

• Be compliant with the Code of Fundraising Practice and other legal requirements 

• Make sure decisions are consistent and grounded in both the agreed policy objectives of the organisation and the law 

• Avoid confusion between trustees, fundraisers, volunteers and staff as to who has the authority to take decisions in different circumstances  

• Protect the reputation of the charity against adverse public reaction from existing or potential supporters  

• Express your values and ethos - how they are relevant to achieving your charitable objectives and why certain types of donations might inhibit that 

For further information on writing policies, please see NCVO’s advice on developing policies and procedures.  

It is up to a charity’s trustees to make sure that the whole organisation is being run well and working in the best way to achieve the charity’s objectives. That includes setting the values of the organisation, agreeing policies for the organisation, and when appropriate, delegating authority for day-to-day running of the organisation to staff.  

It is sometimes not practical for trustees to evaluate every donation that comes into the charity, so often they will delegate authority to staff. There are many forms delegation could take, including: 

• An individual or a group might make an initial recommendation on a donation, and then escalate to a senior member of staff or trustee 

• An ethics committee comprised of fundraisers, lawyers and staff might evaluate the reputational risk of accepting certain donations 

• Trustees might be involved throughout the entire decision-making process. 

If the trustees have delegated the ability to make decisions on acceptance and refusal of donations, this should recorded in the policy, and be clear exactly who has overall responsibility for managing the process.  

When deciding what approach would work best, trustees could ask themselves: 

• What is in your charities’ governing document and does it include a specific power to refuse donations? 

• What are our charitable objectives?  

• What is our fundraising strategy and what are the kind of donors we typically work with? 

• What is the typical size of a donation the charity receives?  

• What are the most likely circumstance where you might need to consider refusing a donation?  

• Which members of staff could provide insight into whether to accept or refuse a donation? This will typically include the fundraising team, legal experts and other members of staff.  

The Charity Commission’s guidance It's your decision: charity trustees and decision making sets out some key considerations for trustees when making and delegating decisions.  

Establishing this is perhaps the most challenging part of a policy as all decisions must be in the best interest of the organisation and align with charity law.  

When deciding whether to refuse a donation, it is important to remember the Code of Fundraising Practice states you must not refuse or return donations, except in exceptional circumstances. Trustees should therefore only do so if accepting it would be more detrimental to the charity being able to achieve its objectives. 

Donations to charities should only be rejected if: 

• It would be unlawful to accept it (e.g. the organisation knows that the gift comprises the proceeds of crime); or  

• Accepting the donation would be detrimental to the achievement of the purposes of the organisation, as set out in its constitution - this anticipated detriment must be set against the benefit of having the funds from the donor, which would enable the organisation to pursue its purposes. 

Depending on the cause and people your organisation works with will dictate your decision making, but some questions you can ask yourself are:  

• What do the rules say?  

• What is in the charity’s governing document?  

• What would stop you from achieving your charitable objectives?  

• What could negatively impact key audience the charity works with e.g. supporters, service users, research partners?  

• It might make sense to consult with them directly or with people internally who work with them  

• Could accepting the gift be perceived as the donor exerting influence on the charity? If so, how can this be mitigated against? 

• Can we meet the conditions of the gift? And if we can, will fulfilling those conditions cost more than the amount of the donation?  

• What is the donor seeking to get in return for their donation, if anything?  

Third party platforms have opened up ways for supporters to make donations to charities and can be a valuable source income. There might be a small number of instances where this can cause confusion. Such as a donor might think they are donating to one charity, when they intended that donation for another.   

Overall, the platform is responsible for processing donations and ensuring that the associated data is processed legally and fairly, however, there are some steps charities can take to avoid problems:  

• Carry out due diligence on platforms prior to agreeing to work with platforms 

• Familiarise yourself with the platform’s acceptance and refusal policies 

• Consider if you will accept donations from unsolicited crowd funders. 

Although many of the considerations of whether to work with a partner are similar to those when accepting a donation, there are some differences that should be taken into account:   

• A donation is given to your charity free from conditions attached to the gift, which can be given by another organisation, and your charity is not expected or required to fulfil any obligations in order to obtain the donation  

• A partnership is a relationship between two organisations, whether two charities or a charity and another type of organisation, that typically extends beyond offering support financially. They will have a vested interest in the work of your charity and its outcomes, and may request certain conditions to be met as part of the partnership. 

There are also some considerations to factor in at the different stages the partnership:  

• In negotiations, be as transparent about what is feasible to avoid confusion later down the line 

• Consider carefully what you want to be included in the partnership contract – give yourself some level of flexibility and keep the contract to key points 

• Consider creating a ‘ways of working’ or memorandum of understanding document that outlines key processes with partners 

• Be clear on what will happen if an agreement is broken. 

• If the partner has been found to have done something that goes against your charitable objectives, be clear on how you will respond 

In order to ensure good practice, here are some other areas you might consider when developing your policy:  

• How does it align with your fundraising strategy? For example, if your strategy focuses on major donors your policy should consider how to approach this area 

• Does your policy align with other policies? This could include: 

• The governing document  

• People in vulnerable circumstances or safeguarding policies  

• Equality, diversity and inclusion policies 

• Anti-racist policies  

• Green policies 

• Procurement policies 

• Accepting physical goods or gifts in kind policies (if this is separate from your accepting refusing donations guidance) 

• How often will you review and update your policy? 

• Are there special circumstances in which we might slightly change our position E.g. during an emergency appeal?  

• Will your policy be available publicly? 

Once you have an agreed policy and process in place, it is important that you have the right foundations to ensure it is carried out effectively. There are many ways to do this that will depend on your size and capacity.  

Some key principles that should underpin this are:  

• Transparency  

• Consistency  

• Fairness – to staff, the people your charity work with and the donor.  

Holding your charity to these standards and bearing them in mind as you make key decisions will help keep you on the right track.  

Whether charity employees are allowed to make their own decisions or it is required to be escalated, staff should be equipped with the knowledge, skills and tools to be able to take the right steps at the right time. Ensuring that the right training is offered, and that refresher training is given at appropriate times, is integral to this.  

Some steps charities can take to make this happen include:  

• Train staff on how to use the policy (and provide refreshers on that training where appropriate) 

• Make sure the acceptance and refusal policy aligns with other charity policies (see section x) 

• Be clear who is responsible for making what decisions 

• Where possible have clear timelines for decision making processes 

• Make it clear how staff should handle larger donations.

Due diligence is the range checks on individuals and organisations that give money to your charity so you can identify and manage any risks. The appropriate level of checks is likely to be in proportion to the size of the donation, for example a large donation might pose higher risks to an organisation than a smaller one. However, a series of smaller donations in quick succession may also be cause for concern.  

There is no one-size-fits-all approach to who carries our due diligence in a charity as this will be dictated by its capacity and resources. Some charities might have:  

• A team who research large prospective donors or partners 

• Individual fundraiser carries out due diligence for their prospects 

• Separate fundraisers or a head of department might carry out due diligence for a team. 

Whether you are an experienced researcher, or new to carrying out due diligence, here are some things to consider when researching a potential donor: 

• Was the donation solicited or unsolicited?  

• Unsolicited donations from new donors should be flagged on the day of receipt  

• What does the acceptance and refusal policy say about specific industries or work that might clash with your charitable objectives?  

• How far back will you research?  

• What sources and resources will you use to carry out your research? 

• What are the key themes or areas are you looking for information on?  

• How could any negative information impact the charity’s reputation?  

• Are you being objective and making decisions based on evidence, not opinions? 

• What good or positive news is there about the donor?  

• Where negative coverage is found, what has the individual done to rectify these issues, if anything?  

• Overall, what are the pros and cons of accepting the donation?  

Here are some practical tips to help you carry out due diligence:  

• Check Companies House for any information that could assist in verifying the donations’ source 

• Conduct a keyword google search related to the source 

• Refer to the tools offered by the Charity Commission:  

  • Risk assessment cycle  

  • Risk Matrix 

  • Risk assessment checklist 

Depending on the size and cause of the charity, some organisations might include colleagues in the decision on whether to accept or refuse certain donations, such as through an ethics committee or consultation with other departments. 

It’s important that people have the opportunity to raise concerns or queries about accepting a donation, however, these should be based on the acceptance refusal policy and charitable objectives rather than personal objections. To make sure that decisions are fair and consistent charities could take the following steps:  

• Staff should be trained on the acceptance and refusal policy 

• Staff should be aware of the laws around accepting and refusing a donation 

• It should be clear who has been selected to make the decision and why 

• Timelines for when to make the decision should be clear and adhered to so as to avoid delays.  

It can be uncomfortable for fundraisers or other staff to communicate the decision to refuse a donation, if that is what is decided by trustees. Charities should therefore make sure they have the support to do so fairly and professionally so it does not negatively impact the donor.  

The reasons why this may be necessary are documented in the section ‘Circumstances when you would not accept a donation’. 

When communicating a refusal, some steps that can be taken include: 

• Explaining why you cannot accept the donation 

• Express gratitude for their interest in supporting you 

• Highlighting circumstances where this might change 

• Signpost to other opportunities to support the charity 

The Code also states you should also keep a record of the donation and the reason you refused it.  

These are just a few illustrations of potential situations in which you may need to think about these issues, rather than a comprehensive set of examples. Make sure you know the rules and seek help and advice if you need it, and always think about what is in the best interests of your organisation. 

Someone makes a donation which was intended for another charity  

A recent donor contacts you to say that they meant to make a donation to another charity with a similar name, but selected the wrong option on the online giving platform they used.  

While charity trustees do have the duty of fulfilling charitable aims through its assets, this donation was made in error by the donor and the assets were not intended to go to the charity.  

As this donation was not intended for you, you should return it.  

We’re worried that accepting a particular donation will impact our charity’s ability to achieve our objectives or raises qualms surrounding ethics  

You work at an animal welfare charity and get a call from an organisation who used to test on animals. They have a new CEO and want to make a donation to your charity. However, you’re worried about the reputational impact that this might have on your existing and potential new supporters.  

There are many variables that need to be considered before coming to a conclusion, and it is possible that whilst one charity would accept the donation, another would not depending on their current supporter base and how this could impact future donations. Here are some of the steps you could follow to come to a decision:  

1. Carry out due diligence on the company- how long have they stopped testing on animals? Have they been launching other initiatives to improve animal welfare?  

2. Communicate the findings of due diligence to relevant staff- this could be an ethics committee, or directly to charity trustees 

3. Assess the risk of refusing or accepting the donation- you can use this risk matrix  

4. Communicate your decision to the company  

5. Keep a record of the donation and your decision. 

Accepting a large unsolicited donation from an organisation  

A well-known public figure company has unexpectedly donated a substantial amount of money to our charity. 

The Fundraising Code of practice states that donations should only be rejected in exceptional circumstances, some charities would not consider this an exceptional circumstance and would accept the donation. 

Although there is nothing to indicate that the donation should be rejected, some charities would still choose to carry out due diligence checks on the individual prior to accepting.   

A donation has been offered but with special conditions attached 

An individual has offered us a significant sum of money to our hospice charity, but only to fund a specific area of patient care 

Charities should consider if they can meet the conditions of the gift prior to accepting. If they do choose to accept the donation, they will need to be able to demonstrate the money has been spent in line with the donors wishes.  

NCVO outlines how the key principals of fund accounting here.  

If someone in the charity has a personal objection about not accepting a donation 

We have been offered a donation from a large company, however, a colleague has raised serious ethical concerns regarding their impact on the environment.  

While ethical values and ensuring donations are in line with these values is important, this alone cannot be the reason to refuse a donation. 

However, if you are able to demonstrate that more harm than good would result from accepting the donation – for example, you would likely lose support from other donors – then you may have grounds to refuse as a result of the detriment caused.  

Some steps you can take in this scenario:  

1. Check your acceptance and refusal policy – is this company part of an industry from which your charity typically refuses donations?  

2. Carry out due diligence on the organisation 

3. Escalate the information (as well as the objection) to the appropriate decision makers.  

Remember: although individual staff members can have opinions on whether to accept or refuse a donation, the decision ultimately belongs to trustees or members of staff they have delegated the decision to.  

You receive criticism for accepting a donation from an individual or organisation  

Our mental health charity recently accepted a donation from a company and we are now receiving criticism for it on social media.  

There is no one-size-fits-all approach to this, how you proceed will depend on your approach to crisis communications.  

If this is an area you are still developing, Charity Comms has developed a Best Practice Guide to Crisis communications for charities.