Financial support from individuals and organisations is essential to deliver the aims of Team Domenica, supporting young people with learning disabilities to find and sustain employment. We welcome partnerships with, and gifts from, a wide range of supporters.

In exceptional circumstances, however, it may be necessary to refuse support if acceptance would prejudice the aims of Team Domenica, compromise its independence, or threaten its reputation.

The Board of Trustees (Board) of Team Domenica have overall responsibility to ensure that decisions are made in the best interest of the charity and our beneficiaries. This includes responsibility to “know your donor” and carry out appropriate and proportionate due diligence and risk assessment related to acceptance of gifts. This policy outlines how Team Domenica undertakes these responsibilities, ensuring due diligence is undertaken for relevant support and potential partnerships.

The policy outlines Team Domenica’s ethical approach to philanthropic funding and partnerships, and aims to make our approach transparent. Whilst the vast majority of support is extremely welcome, there may instances where the reputation and operation of the charity needs to be protected from claims of impropriety. Key areas are outlined in section 4 below, but are not exhaustive.

This policy relates to philanthropic support, and partnerships with, individuals, charities, and companies. The UK Government and its agencies, including research funding councils, are not covered by this policy.

Risks of accepting specific support include but are not limited to:

• reduction in support from others
• decline in volunteer numbers or applications to join as employees
• negative reaction from current employees
• negative media reports
• conditions that put Team Domenica’s independence at risk
• This policy outlines how we might review potential support, and clarifies how we would work with companies from certain industries.

This policy is informed by the following external advice:

Charity Commission:

Charities: due diligence, monitoring and verifying the end use of charitable funds (Compliance toolkit, Chapter 2)

https://www.gov.uk/government/publications/charities-due-diligence-checks-and-monitoring-end-use-of-funds

Chartered Institute of Fundraising:

Guidance on accepting, refusing, and returning donations: https://ciof.org.uk/IoF/media/IOF/Policy/iof-acceptance-refusal-and-return-a-practical-guide-to-dealing-with-donations-(5).pdf?ext=.pdf

And Treating Donors Fairly: https://ciof.org.uk/IoF/media/IOF/Header%20images/Treating-donors-fairly.pdf?ext=.pdf

Any updates to this advice will be taken into account when reviewing this policy.

When receiving donations, Team Domenica will closely consider areas such as the following (this list is not exhaustive):

• Evidence of exploitative practices
• Excessive fossil fuel dependency
• Supply of arms and ammunition
• Pay day and high interest loans
• Groups with known extreme political or ideological views or featuring on the government’s proscribed list of terrorist groups or organisations.

Fundraising and At Risk people

At Team Domenica we believe that people have a fundamental right make their own decisions and choices. In line with the Mental Capacity Act 2005, Team Domenica will act as if all people have capacity, until it becomes apparent they do not.

The Mental Capacity Act 2005 is underpinned by a set of five key principles:

1. A presumption of capacity – every adult has the right to make his or her own decisions and must be assumed to have capacity to do so unless it is proved otherwise.
2. The right for individuals to be supported to make their own decisions – people must be given all appropriate help before anyone concludes that they cannot make their own decisions.
3. That individuals must retain the right to make what might be seen as eccentric or unwise decisions.
4. Best interests – anything done for or on behalf of people without capacity must be in their best interests.
5. Least restrictive intervention – anything done for, or on behalf of people without capacity, should be the least restrictive of their basic rights and freedoms.

In the event that it becomes apparent that a person lacks capacity, the organisation should politely decline the offer of a donation, or refrain from making a request for a donation without asking about the individual’s capacity to make a decision.

We know that it may be difficult in some situations for fundraisers to decide whether or not someone is in a vulnerable circumstance or lacks capacity but our approach is always to err on the side of caution. 

Where a donor or potential donor may need additional support to make a donation, we will always offer further support to make a decision about whether to make a donation and guidance on how to do so. 

This applies to all fundraising, by our direct employees, volunteers or through a third party or agency. 

Anonymous donations

The Charity commission considers a serious incident to be anything ‘significant’ in the context of your charity. A full list of examples of what constitutes serious or significant can be found here. In line with guidance from the Charity Commission, donations over £25,000 where Team Domenica cannot identify the donor are reported to the Charity Commission as a Serious Incident. The Charity Commission is clear, however, that charities are free to accept anonymous donations where there are no suspicious circumstances.  

Restricted donations

Team Domenica is happy to restrict funding to specific areas of work, and will account for income and expenditure recognising restricted funds. We may, however, refuse donations with restrictions that cannot be met, but will always seek to communicate with the donor, or the executors in the case of a legacy, taking advice from the Charity Commission if appropriate.  

Gifts from employees, volunteers, and related individuals or organisations

Team Domenica welcomes and values support from these individuals and groups, but this does not confer on the donor any benefit or preferment beyond the usual recognition and stewardship offered to donors.  

Commercial Partnerships

Commercial partnerships are an important way for companies to support the communities within which they operate, as well as involve employees and customers in charitable activity.  

Particular care will be taken to review the benefits and risks to all parties before entering a commercial partnership.

Events, speakers and preventing radicalisation

Events are a common mechanism for raising funds. Occasionally third parties may use our spaces for a fee, or as a platform to raise funds for us. Team Domenica also plans and delivers events to raise funding and/or awareness of our work. Team Domenica staff vets all third parties, partners and speakers before they use our spaces or speak at our events. To do so we check public records and ensure partners do not feature in, or are associated, with organisations on the proscribed list.  

Money Laundering

Any evidence of money laundering is considered through due diligence, in line with the Know Your Donor guidelines from the Charity Commission. 

In accordance with our normal accounting and record-keeping procedures, all incoming funds are required to be supported by documentation evidencing their source. We receive money from various sources and every reasonable effort is made to verify those sources. 

All members of staff responsible for monitoring incoming funds will check the documentation associated with each item and verify the source of the funds. Any anomaly in the documentation, or any unexpected amounts or payers, will be reported immediately to the Head of Fundraising who will investigate the item/s.  A report will be sent to the Director of Fundraising, Marketing and Communications for escalation to the Senior Leadership Team and the Board of Trustees if needed. Particular vigilance will be given in accordance with our procedures outlined in 6.  

As necessary, Team Domenica will also have regard to Proscribed Organisations and Financial Sanctions Targets as defined by the UK Government and listed here: 

https://www.gov.uk/government/publications/proscribed-terror-groups-or-organisations–2

https://www.gov.uk/government/publications/financial-sanctions-consolidated-list-of-targets

Illegal Activity

Team Domenica will not accept support that is the result of illegal activity on the part of the donor.  

In assessing this risk, in line with our Privacy Policy, only information from reputable public sources, such as national newspapers or government websites, is taken into account.  

Returning Gifts

Team Domenica will not normally return a gift which has been accepted in good faith and in compliance with this policy. Exceptionally, subsequent events or the subsequent availability of additional information may give rise to the need to review a previous decision to accept a gift. (This concerns gifts outside the scope of the Fundraising and Vulnerable People policy).  

The fundraiser responsible for the supporter relationship will review in the first instance and raise with the Director of Fundraising and Communications to make initial decision and escalate as necessary.  

Day to day implementation of this policy is delegated to the Head of Fundraising who will assess whether potential major financial support, or a partnership requiring significant marketing or public relations efforts, should be reviewed by the Director of Fundraising and Communications, followed by the wider Senior Leadership Team or the Board before being accepted. Individual fundraisers are responsible for bringing relevant potential support to their attention. 

General Procedures

The Director of Fundraising and Communications is routinely made aware of major donations or potential partnerships. They assess whether there is need for further discussion at Strategic Leadership level before potential sign off by the Board of Trustees.  

Likewise, the Senior Leadership Team and Board are routinely made aware of major donations or partnerships.  

Fundraisers undertake ‘know your donor’ due diligence on new supporters or partnerships, escalating via heads of teams if information is unclear or if there are concerns.  

Research information is securely stored on the Team Domenica Customer Relationship Management (CRM) system (Donorfy) in line with our Privacy Policy.  

In the case of concerns, a briefing will be produced, including the completed due diligence research form, and shared for discussion with the Director of Fundraising and Communications. 

Decisions to go ahead or decline support are recorded on Donorfy. 

Senior Management and the Board are notified of decisions to decline support, with reasons, via the Director of Fundraising and Communications. 

The following guidance will be followed with regard to money laundering and at risk people: 

Fundraising and at risk people

When determining a person’s capacity to donate, and in line with the Institute of Fundraising’s guidance on Treating Donors Fairly, Team Domenica fundraisers, volunteers or third parties will consider the following: 

• any physical or mental-health condition the person may have 

• any disability the person may have 

• any learning difficulties the person may have 

• whether the person is facing times of stress or anxiety (for example, following the death of a loved one or redundancy) 

• whether a donation is likely to affect the person’s 

• ability to sufficiently care for themselves or leave them in financial hardship 

• how well the person can communicate and understand what they are being told 

• whether the person is under the influence of alcohol or drugs 

• the person’s age 

Money Laundering

On receiving a donation, particular vigilance should be applied to:  

• Unsolicited donations offered at short notice or via an unknown third party 

• Donations offered in the form of a loan 

• Donations from an unknown source, where the identity and reason for the gift is unclear. Donations over £25,000 that fit this criteria will be reported to the Charity Commission. 

• Donors who ask for all or part of a donation to be returned at a later date 

• Donations offered for a specific project where the donor insists that a particular third party is used as a partner or supplier on the project 

• Donations that are conditional upon the donor having control over a revenue or investment benefit from the donation, such as a share of income generated by the donation or the transfer of surplus capital at the donor’s behest 

• Payments from any organisation that are to be held in Team Domenica’s bank account for a period of time and then returned to the organisation or passed onto another organisation (known as conduit funding) 

• Donations that have unusual or disproportionate conditions attached 

• Donations where there are grounds for reasonable suspicion that it represents the proceeds of crime, or is not legally or legitimately owned by the donor 

• Proposals that Team Domenica should make offers of financial support, or loans of property or facilities 

• Requests to refund regular donations 

If any of the above apply, the potential donation should not be accepted but should be referred to the Director of Fundraising and Communications (or in their absence the CEOs) who will escalate to the Board of Trustees. 

Donations should be refused in the first instance, and the potential donor reported to the Director of Fundraising and Communications (or in their absence to the CEOs), if: 

• Donations are offered in foreign currencies (especially on condition that all or part of the principal sum should be returned to the donor in sterling or another currency) 

• Donations are offered anonymously or through an intermediary who is not prepared to identify the donor  

• The donor is believed to have acted illegally in the acquisition of funds, for example where funds are tainted because they may be the proceeds of crime 

• The donor is not believed to have legal or legitimate ownership of the funds or the gift to the charity is a cheque for over £25,000 

• Convert large quantities of cash into another currency 

• Pay a fee to release funds to be donated to the charity 

If the Trustees suspect money laundering as a result of these situations or others, they will report this to the bank and to the appropriate police authorities. 

Reports to the charity commission on serious incidents, including money laundering, should be made via: 

https://register-of-charities.charitycommission.gov.uk/report-a-serious-incident