GIFT ACCEPTANCE AND FUNDRAISING POLICY

Overview
The Governors of Wellington College welcomes offers of donations of all sizes which enable its continuing development over the long term. Wellington College is a registered charity, number 309093.

Potential donors who are considering making a gift are invited to contact the Head of the Community to discuss ways in which their donations may most appropriately be used.

By law, irrespective of internal delegation, the ultimate responsibility in respect of the acceptance or refusal of all donations lies with the Governors. They must ensure that the best interests of the charity have been served in accepting or refusing the donation in question.

Both practical and ethical considerations should be taken into account as long as they are ones that are likely to specifically affect the College. Personal views or outside interests must not affect the Governors’ or fundraisers’ judgement.

Basic principles
Donations must be freely given with no expectation of anything in return other than due thanks and recognition. The Governors are pleased to accept lawful donations which are given in good faith and which are compatible with the school’s aims, values and strategic objectives. The Governors do not accept donations when a condition of acceptance would compromise its autonomy, integrity and reputation.

Where the potential donor is a person or a company whose activities are not directly related to the charitable objects of the charity, but the charity nevertheless wishes to avoid association with the donor, great care should be exercised in coming to a decision. Acceptance of a donation does not imply any endorsement of the donor’s opinions or policies.

Where it can be shown clearly that the cost to the charity of accepting a donation will be greater than the value of the donation itself, the Governors can refuse the donation.

The College, as a subscriber to the Fundraising Regulator, intends to abide by Code of Fundraising Practice.

Ethical Fundraising Principles

Fundraising solicitations on behalf of Wellington College will:

be truthful;

– accurately describe the intended use of donated funds; and

– be made in accordance with any applicable requirements under charity law and the Institute of Fundraising Code of Fundraising Practices

Volunteers and employees who solicit funds on behalf of the school shall:

– adhere to the provisions of these guidelines;

– act with fairness, integrity, and in accordance with all applicable laws;

– adhere to the provisions of any applicable professional codes of ethical practice which apply to them as individuals;

 – cease solicitation of a prospective donor who identifies solicitation as harassment or undue pressure;

– disclose immediately to the Master and Governors any conflict of interest; and

– not accept donations for purposes that are inconsistent with the College’s strategic and educational objectives.

Paid fundraisers, whether employed staff, short-term contractors or consultants, will not be paid finders’ fees, commissions or other payments based on either the number of gifts received or the value of funds raised. They will be compensated by a salary, hourly wage or fee. Their compensation will be consistent with the College’s policies and practices that apply to non-fundraising personnel.

Any donor records held by the Wellington College Community Office will be maintained in accordance with the College’s data protection policy which can be found on the College website.

The College will not sell its donor and alumni lists and contact details.

The Governors will be informed at least annually of the number and nature of any complaints received from donors or prospective donors about matters that are addressed in these guidelines.

Donor Thanks and Recognition

– Formal acknowledgement of all donations will be sent to each donor upon acceptance of the gift.

– Unless the donor wishes to remain anonymous, the donor’s name may be listed in an annual donor report, on the community/College website and may also appear in other print and online materials prepared by the Community Office. The amount given will not normally be stated, and will only ever be specified with the donor’s written consent.

– In cases where a donor wishes to remain anonymous, such anonymity will be respected for all public purposes. The College will, however, disclose details of any donor where it is required to do so by law, by any governmental or other regulatory authority, or by order of a court. The identity of anonymous donors will also be known to the Master, the Head of the Community, the Chair of Governors, and to those College staff who process the gift.

Gift Acceptance
The vast majority of donations will be perfectly acceptable and arise from formal appeals. Such donations can be accepted by the Community Office without further referral.

However, there may be occasions where the source of the donation or the purpose of the donation requires consideration.

Such circumstances may include where:

– It is not immediately clear whether the donation would be in the best interests of the College;

– Large sums of money are involved (currently any donation over £1m, and where there are significant naming rights attached);

– The donation is not in the form of money (e.g. property or shares);

– The donation does not form part of the formal appeals currently in process;

– It can be shown clearly that the cost to the College will be greater than the value of the donation itself;

– Any conditions attached to the donation are;

– Contrary to the objectives of the College

– Regarded as unreasonable in relation to the nature of the support in terms its size or impact on the work of the College

– Likely to divert the College from pursuing its current objectives or priorities

– Unlikely to be practically achieved by the College.

– The donation is from a company not an individual, even if organised by an individual known to the College;

– The donor is not someone with whom the College wishes to be associated;

– The donation is from an overseas country which places restrictions on its residents making donations overseas; or

– The donor or the donor’s close family or friends will derive benefit from the donation

– The Governors need to take reasonable and appropriate steps to know who their donors are; particularly where significant sums are involved or the circumstances of the donation give rise to a notable risk. Therefore, there will be occasions where the Community Office requires further information to ensure that they can identify and verify the donor in order to have assurance of the provenance of funds and the conditions attached to them.

Referral of donations
Current appeals

If any of the above circumstances arise, the fundraisers should refer the donation, prior to accepting it, in the first instance to the Master. If required the Head of Community, the Master and Bursar will then discuss and document their decision making process. If, in their judgement, the donation requires further consideration prior to acceptance, they will refer the matter to the Chair of Governors.

All donations must be accepted in writing, thanking the donor for their generous gift.

General
Any donations which have yet to be accepted should not be banked until the decision to accept is made (in many cases for such donations they will have been discussed prior to any financial transaction being completed).

Gift aid
Donors are encouraged to make a gift aid declaration wherever possible as this benefits both the College and the donor themselves.

If the donor or a person connected with the donor will benefit from a service or an item which is connected to the donation then care must be taken to ensure that the donor is aware of the specific gift aid rules in this case.

Refusal of donations
Care must be taken before refusing any donation as there needs to be a good legal reason to do so. Also, it is clearly a sensitive matter which requires careful handling so as not to “lose” the donor from future appeals.

However, having considered the issues noted above, there may be the rare occasion where a donation should be refused.

Consideration may be given to asking the donor whether they would consider re-directing their donation to a current appeal.

In summary, the College may refuse a donation if acceptance is considered likely to:

– damage the effective operation of the College in fulfilling its objective

– Cause harm to relationships with other stakeholders

– Create an unacceptable conflict of interest

– Damage the College’s reputation.

Return of donations
The return of a donation should be a very rare occurrence. Once a donation has been accepted, it should only be returned if the terms and conditions of the gift provide for it to be returned in particular circumstances.

In England and Wales, the law provides for the return of donations of more than £50 made by credit/debit card within a 7 day cooling off period. In Scotland this applies for donations of £100 or more.

Disclosure of donations
Information about donors is protected by the Data Protection Act 1998.  The College will not share information about donations unless agreed separately with the donor. A donor’s request to remain anonymous will be respected.

Acknowledgement of donations
The Head of the Community or the Community Manager writes to all donors to thank and acknowledge their generosity. Donations over £10,000 are acknowledged with a letter from the Master, and over £100,000 by the Chairman of Governors.