Donation Acceptance & Refund Policy

Purpose and Scope

This policy establishes NSEMM’s framework for accepting charitable donations and managing refund requests. It applies to all charitable donations received by NSEMM, including individual donations, corporate sponsorships, grants, and in-kind donations.

This policy does not cover primary purpose trading income from educational services, which is governed by separate trading policies. All donation processing must comply with charity law, anti-money laundering regulations, and NSEMM’s ethical standards.

Legal Framework and Compliance

NSEMM operates under strict legal obligations regarding donation acceptance derived from the Charities Act 2011 which establishes duties regarding charitable funds and proper application, the Proceeds of Crime Act 2002 which sets anti-money laundering requirements, the Data Protection Act 2018 which protects donor information, the Consumer Rights Act 2015 which defines donor rights and refund obligations, and Charity Commission guidance CC20 on charity fundraising.

Failure to properly manage donations can result in regulatory intervention, reputational damage, and legal liability for trustees. NSEMM maintains comprehensive procedures to ensure full compliance with all applicable legislation and regulatory guidance.

Donation Acceptance Criteria

Acceptable Donations

NSEMM welcomes donations that support our charitable objectives from appropriate sources. Individual donations include cash donations from individuals, regular giving arrangements, legacy gifts with appropriate legal documentation, memorial donations, and fundraising event proceeds. Corporate sponsorships encompass sponsorship from ethically aligned businesses, corporate charitable giving, employee fundraising initiatives, and matched funding schemes.

Grant funding includes charitable foundation grants, government grants, educational institution grants, and community grant schemes. In-kind donations cover educational materials and resources, equipment suitable for our activities, professional services such as legal, accounting, or marketing support, venue hire or meeting spaces, and training and development opportunities.

Prohibited Donations

NSEMM will not accept donations from sources that conflict with our charitable mission and ethical standards. Prohibited sources include tobacco companies and related businesses, gambling operators and betting companies, fast fashion companies with known exploitative practices, alcohol manufacturers and distributors, fossil fuel, oil, and gas companies, arms, defence, and weapons manufacturers, and adult entertainment businesses.

We also exclude companies involved in unethical pharmaceutical pricing practices, organisations linked to exploitation in healthcare markets, organisations with high education fees or exploitative pricing excluding non-profit universities, companies with poor data protection records, organisations using aggressive marketing tactics targeting minors, and any organisation requiring actions that compromise NSEMM’s neutrality or autonomy.

Prohibited donation types include cryptocurrency donations of any kind, property or real estate donations, share certificates or equity investments, overseas donations requiring complex compliance procedures, anonymous donations above £150, donations requiring complex tax implications, donations requiring professional valuation and ongoing administration, non-serviceable in-kind donations that cannot be safely managed, political donations that would imply endorsement, religious donations that would imply endorsement, and donations with conditions incompatible with our charitable objects.

Due Diligence Procedures

Enhanced Due Diligence for Donations over £150

All donations above £150 require comprehensive verification to ensure compliance with anti-money laundering requirements and charity law. Identity verification includes full name and address confirmation, government-issued ID verification where appropriate, company registration details for corporate donors, and beneficial ownership identification for corporate entities.

Source of funds confirmation requires documentation of legitimate income source, bank account verification, employment or business income confirmation, and inheritance or investment documentation where relevant. Sanctions and compliance checking involves HM Treasury sanctions list verification, Politically Exposed Persons screening, adverse media searches, and previous donor history review.

Corporate sponsorship requires additional checks including company registration and trading status, annual accounts and financial stability assessment, business activities and ethical alignment review, and reputation and media coverage analysis. All enhanced due diligence must be completed before donation acceptance and documented appropriately.

Basic Due Diligence for Donations under £150

Standard verification includes identity confirmation through name and contact details verification, reasonable identity checks where possible, and basic legitimacy assessment. Red flag monitoring involves watching for unusual payment patterns or methods, donations disproportionate to apparent means, multiple donations from related sources, requests for anonymity with suspicious circumstances, and payments from unexpected geographic locations.

The Financial Officer maintains responsibility for conducting all due diligence procedures, maintaining verification documentation, escalating concerns to trustees, updating due diligence procedures as required, and ensuring compliance with data protection requirements.

Approval Processes

Individual Donations

Individual donations under £150 receive automatic acceptance following basic due diligence. Donations between £150 and £1,000 require Financial Officer approval after enhanced due diligence completion. Donations over £1,000 require trustee approval following comprehensive assessment and verification.

Corporate Sponsorships

All corporate sponsorships require trustee approval regardless of value due to potential reputational implications and ethical considerations. Enhanced due diligence is mandatory for all corporate partnerships. Formal agreement documentation is required for all sponsorship arrangements, and regular review of ongoing partnerships ensures continued alignment with NSEMM values.

In-Kind Donations

In-kind donations under £500 require Financial Officer assessment and approval following suitability and safety evaluation. Donations valued at £500 and above require trustee approval and professional valuation where required. All in-kind donations undergo suitability and safety assessment by trustees to ensure they can be safely managed and effectively utilised.

Grant Funding

All grant applications require trustee approval before submission to ensure alignment with charitable objects and organisational capacity. Grant acceptance occurs automatically if within approved terms and conditions. Grant modifications require trustee approval for significant changes to terms, scope, or reporting requirements.

Donation Processing Procedures

Receipt and Acknowledgment

All donations are acknowledged within 48 hours of receipt with appropriate receipt documentation including charity registration number. Donations are recorded in the financial management system immediately upon receipt, and due diligence processes are initiated according to the relevant procedures for the donation amount and type.

Documentation requirements include donor contact details and communication preferences, donation amount and payment method, restriction or designation details, Gift Aid eligibility and declaration, and due diligence completion confirmation. This documentation is maintained securely and in compliance with data protection requirements.

Financial Management

Charitable donations are processed through the JustGiving platform and held in designated charitable donations bank accounts with clear separation from trading income accounts. Restricted and unrestricted donations are tracked separately using the financial management system to ensure appropriate fund management and reporting.

All donations are recorded in the financial management system with monthly reconciliation against bank statements. Quarterly reporting to trustees provides oversight of donation activities and compliance. Annual reporting to the Charity Commission ensures regulatory compliance alongside adherence to accounting standards and audit requirements.

Restricted Donations

Acceptance Criteria

Restricted donations are accepted when restrictions align with NSEMM’s charitable objects, specific purposes are achievable and measurable, timeframes for implementation are realistic, administrative burden is manageable, and legal and regulatory compliance is maintained. Each restricted donation requires careful assessment to ensure NSEMM can fulfill the specified requirements effectively.

Management Requirements

Written agreements outline specific restrictions, clear success criteria and reporting requirements, timeline for implementation and completion, and processes for handling surplus or shortfall funds. Regular progress updates are provided to donors alongside financial tracking of restricted fund expenditure, annual reporting on restricted fund outcomes, and trustee oversight of restricted fund management.

Refund Policy

General Principle

Charitable donations are gifts made voluntarily to support NSEMM’s objectives and are generally non-refundable. However, NSEMM recognises certain circumstances where refunds may be appropriate to maintain donor confidence and comply with legal requirements.

Refund Eligibility

Automatic refund circumstances include donations taken in error due to technical issues, duplicate donations processed unintentionally, donations exceeding intended amount due to processing error, and fraudulent transactions not authorised by account holders. Discretionary refund circumstances cover donor requests for refund within 24 hours of donation, significant changes in donor circumstances affecting ability to donate, discovery that donation source conflicts with NSEMM policies, and legal requirements for refund under consumer protection law.

Refund Process

All refund requests must be submitted through NSEMM’s contact page including donation details and reason for refund. Identity verification is required for all refund requests, and processing timelines are communicated to donors upon receipt. The Financial Officer reviews all refund requests with consultation from trustees for unusual or complex cases. Legal advice is sought where consumer rights are unclear, and decisions are communicated within five working days.

Refunds are processed within 14 days of approval and made to original payment methods where possible. Refund confirmation is provided to donors, financial records are updated to reflect refund transactions, and Gift Aid reclaims are adjusted where applicable.

Non-Refundable Circumstances

Excluded donations include those older than 24 hours except where legal obligation exists, in-kind donations that have been utilised, grant funding with contractual obligations, donations where funds have been committed to specific projects, and legacy gifts that have entered probate process. These exclusions ensure organisational sustainability while maintaining appropriate donor protections.

Anti-Money Laundering Compliance

Risk Assessment

NSEMM maintains a low risk profile for money laundering due to our focus on small individual donations, transparent charitable purposes, clear ethical donation policies, and comprehensive due diligence procedures. Regular risk assessments ensure continued appropriateness of our anti-money laundering measures.

Monitoring Procedures

Transaction monitoring includes regular review of donation patterns and amounts, investigation of unusual or suspicious transactions, maintenance of donor verification records, and annual risk assessment review and update. Reporting requirements encompass filing Suspicious Activity Reports when required, cooperation with law enforcement investigations, maintenance of confidentiality during investigations, and seeking legal advice for complex compliance issues.

Record Keeping

Documentation requirements include five-year retention of all donation records, due diligence documentation and verification evidence, refund processing records and justifications, and training records for staff handling donations. This comprehensive record keeping ensures compliance with regulatory requirements and supports effective governance.

Data Protection and Privacy

Donor Information Management

Data collection and use involves minimal data collection necessary for processing and compliance, clear privacy notices provided to all donors, consent obtained for marketing communications, and regular review and updating of donor preferences. Security measures include secure storage of donor personal information, access controls limiting staff access to donor data, regular security audits and vulnerability assessments, and incident response procedures for data breaches.

Donor Rights

Individual rights include access to personal information held, correction of inaccurate information, deletion of information where legally permissible, and withdrawal of consent for marketing communications. NSEMM ensures all donor rights are respected and facilitated through appropriate procedures and staff training.

Training and Responsibilities

Staff Training Requirements

The Financial Officer receives annual anti-money laundering training, charity finance and compliance training, due diligence procedure certification, and regular updates on regulatory changes. All staff receive basic awareness of donation policies, recognition of suspicious transaction indicators, escalation procedures for concerning donations, and data protection and confidentiality requirements.

Governance Oversight

Trustee responsibilities include quarterly review of donation procedures and performance, annual policy review and updating, oversight of large or complex donations, and approval of corporate sponsorships and partnerships. Audit and compliance involves annual independent audit of donation procedures, regular compliance monitoring and reporting, investigation of policy breaches or concerns, and continuous improvement of procedures and controls.

Gift Aid

If you pay tax in the UK, we can claim Gift Aid on your donations. This means the government will add 25% to your donation at no cost to you. For example, if you donate £10 for your lesson, we’ll receive an extra £2.50 from the government.

By agreeing to Gift Aid, you confirm that you are a UK taxpayer and understand that if you pay less Income Tax and/or Capital Gains Tax than the amount of Gift Aid claimed on all your donations in that tax year, it is your responsibility to pay any difference.

You must notify us if you:

• Want to cancel your Gift Aid declaration

• Change your name or home address

• No longer pay sufficient tax to qualify for Gift Aid

Higher or additional-rate taxpayers can claim additional tax relief through their Self-Assessment tax return or by contacting HMRC.

Emergency Procedures

Fraudulent Donations

Immediate response involves suspending processing of suspicious donations, preserving evidence and documentation, contacting relevant authorities if required, and implementing additional security measures. Investigation processes include internal investigation led by the Financial Officer, external legal advice obtained if necessary, cooperation with law enforcement investigations, and review and strengthening of prevention measures.

System Failures

Contingency arrangements include manual processing procedures for system outages, regular backup of donation records and data, alternative communication channels for donors, and recovery procedures for lost or corrupted data. These procedures ensure continuity of donation processing during technical difficulties.

Performance Monitoring

Key Performance Indicators

Donation management metrics include average processing time for donation acknowledgment, due diligence completion rates within required timeframes, refund processing times and resolution rates, and donor satisfaction with donation experience. Compliance metrics encompass number of donations requiring enhanced due diligence, compliance with anti-money laundering requirements, data protection compliance and incident rates, and training completion rates for relevant staff.

Annual Review Process

Policy effectiveness assessment involves evaluation of policy compliance and effectiveness, review of donation trends and patterns, evaluation of due diligence procedures, and update of procedures based on regulatory changes. Continuous improvement includes stakeholder feedback collection and analysis, benchmarking against sector best practices, implementation of improvement recommendations, and regular consultation with legal and compliance advisors.

Related Policies

This policy should be read alongside NSEMM Constitution and Charitable Objects, Financial Management Policy, Data Protection Policy, Risk Management Policy, and Anti-Fraud Policy. These documents provide additional guidance on specific aspects of donation management and organisational governance.

Contact Information

For donation-related queries or refund requests, please use our contact page on the NSEMM website. All donation processing is managed by the Financial Officer under trustee oversight. For urgent donation compliance concerns, contact the Designated Safeguarding Lead or Chair of Trustees through the same contact channels.

This policy is reviewed annually and updated to reflect changes in charity law, regulatory requirements, and operational experience. All staff receive training on policy requirements and updates to ensure consistent application of donation acceptance standards.