Wellington College (the College) is a registered charity, number 309093. The Governors of Wellington College welcome offers of donations of all sizes which enable the College’s continuing development over the long term.

Potential donors who are considering making a gift are invited to contact Murray Lindo, the Director of Development and Head of the Wellington College Community (DDHC) 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.  Additionally, staff must adhere to the College’s Conflicts of Interests Policy and Anti-Bribery Policy at all times.

This document is one of a number of documents that contain guiding principles that relate to the way funds are raised and manged for the benefit of the College and its strategic objectives.

2.Basic principles

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

The Community Office on behalf of the Governors will 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, in addition to the specific processes identified in section 5 below, there may 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 (please refer to section 5. Gift Acceptance)

Where the potential donor is a person or a company whose activities are not compatible with the charitable objects or Values 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. Please refer to section 5.5.

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

3.Ethical Fundraising Principles

3.1 Fundraising solicitations on behalf of Wellington College will:

a. be truthful;

b. accurately describe the intended use of donated funds;

c. be made in accordance with any applicable requirements under charity law and the Institute of Fundraising Code of Fundraising Practice.

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

a. adhere to the provisions of these guidelines;

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

c. adhere to the provisions of any applicable professional codes of ethical practice which apply to them as individuals as well as to the College values of Courage, Kindness, Integrity, Respect and Responsibility;

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

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

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

3.3 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.

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

3.5 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.

3.6 All policy principles apply on a cumulative basis per donor i.e., if a donor makes a donation of two £5,000 gifts this will be treated as a £10,000 donation and the principles followed accordingly in respect of the donation which triggers the cumulative threshold and any subsequent donations.

4. Donor Thanks, Recognition and Disclosure

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

4.2 The HCDD writes to all donors to thank and acknowledge their generosity. Donations over £10,000 are acknowledged with a letter of thanks from the Master, and over £100,000 by the Chair of Governors.

4.3 Unless the donor wishes to remain anonymous, the donor’s name may be listed in a 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 be published without the donor’s written consent.

4.4 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 HCDD, the Chair of Governors, the COO, the Legal and Compliance Director and to those College staff who process the gift.

5. Gift Acceptance

5.1 Gifts up to £10,000

Unless any of the considerations set out in section 5.5 apply, gifts up to £10,000 will normally be accepted by the Community Office without further investigation if they are given without conditions in support of an existing fundraising project or programme.

5.2 Gifts over £10,000

Unless any of the considerations set out in section 5.5 apply, donors offering pledges valued at over £10,000 will be reviewed against an external database.

5.3 Gifts over £25,000

Donors offering pledges valued at over £25,000 will be reviewed against an external database. Upon approval, they will then be asked to complete a Deed of Gift agreement that outlines the details of the gift, the project to be supported (if designated) and a donation payment schedule. The agreement will be signed by the donor and (on behalf of the College) by the HCDD and the Head of Finance. Oral pledges are not officially logged until the signed Deed of Gift has been received.

5.4 Gifts over £250,000 or with naming rights

Donors offering pledges valued at over £250,000 or making a donation which is applicable for naming rights will be reviewed against a full screening via Kroll and referred to the Master the COO, the Chair of the Business and Finance committee and the Chair of Governors.  Upon approval, they will then be asked to complete a Deed of Gift agreement that outlines the details of the gift, the project to be supported (if designated), a pledge payment schedule and naming rights (if applicable). The agreement will be signed by the donor and (on behalf of the College) by the HCDD and the Head of Finance. Oral pledges are not officially logged until the signed Deed of Gift has been received.

Referral of donations

5.5 If any of the further considerations listed below arise or the HCDD otherwise has any concerns in connection with a donation, prior to accepting any donation or, in the case of those for which a Deed of Gift is relevant, signing a Deed of Gift, the HCDD should refer the donation in the first instance to the Master. The Master may then choose to consult with the Legal and Compliance Director, the COO and Head of Finance in order to decide whether further due diligence is required and whether to accept or refuse the donation. The Master may also refer such matters to the Chair of Governors.

Such considerations include (but are not limited to) where:

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

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

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

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

5.5.5 The donation will damage the effective operation of the College in fulfilling its objective.

5.5.6 The donation will cause harm to relationships with other stakeholders.

5.5.7 The donation will create an unacceptable conflict of interest.

5.5.8 The donation will damage the College’s reputation.

For the avoidance of doubt, donations cannot be accepted if the donation is:

a. Illegal for the College to receive or for the donor to donate.

b. Contrary to the objectives of the College.

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).

6. Refusal of donations

Care will be taken before refusing any donation. However, having considered the issues noted above, there may be the rare occasion where a donation should be refused.

7. Gift Aid

Donors are encouraged when applicable, 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.  If a recent Gift Aid Declaration is not currently held on file (we keep all Gift Aid Declarations for 6 years) by the Community Office for the donor, or when a substantial gift is made (over £20,000), then one will be provided at the time the offer of a donation is accepted.

The Community Office will maintain appropriate records to enable tax to be reclaimed under the UK Gift Aid scheme. This will be an auditable record for every gift and donor (individual, trust or corporate), held in an electronic database and will demonstrate the nature of the contribution and any benefits provided such as fund designation and naming rights. Regular audits will be carried out, and information may be required by bodies such as HM Revenue & Customs in respect of gift aid claims. While the responsibility lies with the donor to update the Community Office about their tax status under the Gift Aid scheme, we will always remind donors about their responsibilities (i.e. having paid enough tax in that year) when claiming Gift Aid as set out by HMRC.

8. 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.