Stepping Stones North Wales

Donations, Fundraising & Grants Policy.

Purpose of the Policy:

Stepping Stones North Wales (SSNW) is a registered charity and relies on income from a variety of sources including donations, fundraising and grants to secure its business activities.

We must ensure that by accepting any of these options we uphold any legal, statutory, or regulatory requirements, and maintain our reputation and adherence to our values.

This policy supplies guidance on how raising funds at SSNW will be managed to ensure that we maintain these standards and provide reassurance, and transparency of our processes to our donors and sponsors.

We are registered with the Fundraising Regulator and are committed to supporting good practice in fundraising.

This policy will be reviewed every year, or more frequently, as legislation, guidance from official bodies or industry best practice changes.

Definitions:

SSNW typically fundraises through the following means:

“Donations” are a gift for which no direct benefit is looked for. A donation may take various forms including cash, services or goods and can be from an individual or an organisation. A donor’s name or list of donors may be on display or included in publicity if SSNW chooses to do so by way of thanks, and if the donor agrees. It must be made clear to the donor that any decision to display or include the donor’s name is at the sole discretion of SSNW.

SSNW is entitled to claim Gift Aid on donations from individuals where a Gift Aid Declaration is made that confirms that the individual is tax resident in the UK and has paid tax during the period in which the donation is made. Donations are not subject to VAT.

“Sponsorship” is where a business provides money to secure the marketing and promotion of its business name, products, services, or image. Sponsorship may also include the giving of services or goods for the same in return. It is usually a taxable supply (see VAT appendix).

A “membership” scheme is where a donor makes a gift to a charity in return for a limited programme of benefits e.g., priority booking, exclusive content. The value of the benefits given must not outweigh the value of the membership. If the value of the benefits is less than the total value of the membership, then the membership may be divided into a donation and a payment for VAT purposes. SSNW employer membership does not fall into this category.

A “grant” is cash given to an individual or an organisation for a specific purpose. There is an obligation to fulfil any criteria the funding body may place upon the grant, i.e. to ensure the project that is funded satisfies their aims and objectives and goes ahead as outlined during the grant application process. Funding bodies usually require some level of profile in return for their grant, and this should be in proportion to the size of grant and agreed in writing before accepting the grant. This is usually in the form of a logo or line credit with agreed wording in publicity. Grants should always be documented in some form of written agreement between the parties. Grants are not subject to VAT, unless we supply goods or services in return.

Requirements:

SSNW will only accept funds if they meet the following requirements:

Benefit: there are strong grounds for believing it will result in benefit to SSNW clients. The benefit looked for should be viewed as good value for the level of support given and the resources required to secure it.

Integrity: the company, organisation, partnership, or activity will not bring SSNW into disrepute, damage our reputation or integrity, or be likely to result in loss of income for example through the following;

  • Strategic fit: partnerships, activities and the objectives of companies or organisations we work with, do not contradict SSNW’s mission, vision, and values.

  • Independence: donations, partnerships or activities do not compromise our independent status.

  • Influence: there is no attempt on the part of the partner, donor, company, or organisation to influence our policy or actions either explicitly or implicitly. All funding must operate within the requirements of SSNW Anti-Corruption & Bribery Policy (within the Staff Handbook).

  • Legality: partnerships, activities and the wider business activities of partner companies or organisations must be, as far as we can learn, wholly legal under applicable law.

  • Codes of Practice: acceptance of donations, partnerships and activities must follow the Fundraising Regulator Code of Fundraising Practice and the Fundraising Promise.

  • Standards: the partnership, company or organisation and activity must meet any appropriate and associated national or international standards and abide by any relevant regulations.

The role of Trustees:

Final responsibility for actions under this policy and our Fundraising Policy rests with SSNW trustees, who will be able to prove they act in ‘the best interests” of the charity. This means trustees will not be influenced by personal moral perspectives or judgements or derive any personal benefit from funding to the charity. Trustees will declare a conflict of interest where it exists.

Consideration of opportunities:

Some companies, organisations or individual donors will require special consideration before funding can be accepted from them.

Examples include funders that:

  • may have unethical practices about the manufacture of their products e.g. animal welfare, human rights;

  • promote or are involved in tobacco, pornography, weaponry, or similar activities;

  • are in financial or legal conflict with Stepping Stones;

  • as far as SSNW is aware, do not uphold the same values of our Equality, Diversity & Inclusion Policy.

  • Donors/funders that may be considered contentious should be discussed with the CEO and the Chair of the Board before being accepted.

The above list is not exhaustive, and SSNW retains the right to decline funding from any funder, which the charity in its sole discretion considers inappropriate.

Authority to proceed:

All gifts (including sponsorships) should be agreed through the CEO to ensure they are documented and handled in line with this Policy and other charity procedures. Gifts can only be accepted providing that proper authority for approval has been secured.

The thresholds for approval are as follows:

  • Gifts up to £5,000 = CEO approval

  • Gifts above £5,000 to £25,000 = CEO and the Board

  • Gifts above £25,000 to £75,000 = Full Board approval

Transparency:

A copy of this policy will be displayed on our website and given to third parties who undertake any fundraising on our behalf.

Process for managing Corporate Sponsorship:

Before sponsorship can be secured, the following steps must be undertaken:

  • Research: businesses approached should be researched to ensure the best fit in line with this policy.

  • Valuation: benefits to be offered to a sponsor must be valued to ensure proposals are fair and reasonably priced.

  • Benefits: all crediting & branding permitted must be agreed in advance based on the valuation.

  • Invoicing: full payment should be received before the activity sponsored takes place.

  • Contracting: all sponsorships over £1,000 should be documented with a written contract.

  • Evaluation: sponsors should be provided with an evaluation demonstrating return on investment after the activity.

  • Review: sponsors should not be contracted for longer than 3 years without consideration of whether the partnership still presents best value for SSNW

All sponsorship is unrestricted income to the charity as a service provided in return for payment. All sponsorships must be recorded on and shared with Stepping Stones’ accountants.

Process for managing Donations & Grants:

  • When a donation or a grant is received, staff should ensure the following:

  • Clarify where the donation or grant will be spent and whether it should be treated as unrestricted or restricted funds.

  • Document the gift and log any relevant details agreed such as management of the gift and activity funded, decision making for any changes to the activity supported, payment schedule etc.

  • Procedure for thanking the funder, ensuring that benefits of significant financial value are not given that will conflict with this policy or significantly offset the value of the gift.

  • If the gift is made by a UK resident taxpayer, undertake full documentation for possible Gift Aid claim purposes.

SSNW need to know the source of funds to ensure it complies with this policy.

All donations must be recorded on the Finance System

Grant information must be shared with SSNW accountants.

Handling Memberships:

A “membership scheme” is where a donor makes a gift to a charity in return for a limited programme of benefits e.g., priority booking, exclusive content. The value of the benefits given must not outweigh the value of the membership. If the value of the benefits is less than the total value of the membership, then the membership may be divided into a donation and a payment for VAT purposes. SSNW employer membership does not fall into this category.

Data Protection:

SSNW will administer all fundraising in line with its GDPR Policy.

Funders will never be given direct access to mailing lists or data held by SSNW unless it has the express permission of the data subject.

All funders have a right to request access to their data and may obtain this by contacting a member of the team.

SSNW acknowledges the donor’s right to privacy and will uphold the values of the Fundraising Regulator’s Fundraising Promise.

Should any funder or donor wish to make a complaint about fundraising, then they may do so under the SSNW Complaints Policy.

Gift Aid:

We will seek to maximise all donations by claiming gift aid from HMRC wherever possible. Donors will be asked for a gift aid declaration, which will be stored on the Finance system

Claims will be made to HMRC in line with the requirements of current legislation.

Use of agencies & third parties:

On occasion, we may work with third parties, sponsorship agencies, consultants, and partners on our fundraising. Where such parties are engaged, they must also adhere to this policy.

The use of their services must be communicated to prospective donors, and the value of their use must be assessed to ensure that significant ROI is obtained.

External reference materials: