Gift Acceptance and Ethical Fundraising Policy

This Gift Acceptance and Ethical Fundraising Policy provides a clear framework to guide the solicitation, acceptance, and management of philanthropic support. It ensures that all gifts align with the University’s values, strategic priorities, and legal obligations, while safeguarding the reputation of the institution and the trust placed in us by donors, staff, students, and the wider public.

Purpose

To assure adherence to the Fundraising Regulator’s Code of Practice and to provide transparency for the University’s donors and potential donors, this policy outlines how gifts and donors will be evaluated before gift acceptance and under what conditions gifts may be rejected. It is important to assert that no gift is without risk, and the rejection of a gift also brings risk with lost opportunity/impact for the intended beneficiaries. The following policy is about understanding, evaluating and minimising that risk so that we can continue to bring valuable philanthropic investment into the University for the benefit of students, research and the public. The University will not accept donations which are incompatible with the University’s mission, vision and strategy. Ethical decisions are made with the public trust and institutional integrity in mind. In order that the senior executive is sighted on all gifts in progress and accepted, an annual report will be provided to the University Leadership Team (ULT), along with a quarterly report to the Ethical Gift Acceptance Advisory Group (EGAAG).

Scope

This policy applies to all donations, including in kind donations and potential donations, such as donations which may come from: alumni, university staff, current students and their family members and friends, corporates, trusts and foundations and members of the public who may not be any of the aforementioned.
This policy also applies to all former donors to the university and existing / current gifts. If it comes to light that gift/s previously given, or gifts that we have accepted and are in the process of spending, or not yet spent, were not within the ethical boundaries outlined in the body of this policy, these gifts will be reviewed on a case by case basis and may potentially be returned to the donor. We will follow the same procedure with evaluating the return of funds as with new gifts, escalating to the right point of seniority depending on gift level and revert to that individual / body for a final decision. We reserve the right to return any gift that we decide later does not comply with our Gift Acceptance and Ethical Fundraising Policy and university values.
This policy does not apply to research funding.

Policy statements

This policy is organised into two sections:

Gift Acceptance
Ethical Fundraising

In undertaking fundraising activities, the Office of Philanthropy, Alumni & Supporter Engagement recognises the need to conduct its fundraising within the context of: The Fundraising Regulator’s Code of Fundraising Practice and CASE Europe’s Ethical Principles behind the Acceptance of Gifts.

The rights of donors to the university are outlined in the university’s donor promise.

Gift acceptance

When deciding whether to accept or refuse a donation, the University must follow the principles laid out in this policy as it is a publicly accountable body. The following guidelines apply to all types of donation, including cash, investments, property, gifts-in-kind of equipment, artwork, software or other non-monetary gifts.

To ensure the university is fully informed about a potential major gift or a prospective donor, proportionate due diligence will be carried out, as standard procedure by the Office of Philanthropy, Alumni and Supporter Engagement. The aim is to explore whether there are any concerns that raise issues of ethical or reputational risk, and to ensure as much transparency as possible in the donation process.
Preliminary checks will be carried out prior to engagement with a prospective donor where possible. Issues flagged during the initial due diligence screening of a prospect may be escalated up for consideration by the Ethical Gift Acceptance Advisory Group (EGAAG).
Gifts below £10,000 will not normally be subject to additional Due Diligence, unless requested. Gifts between £10,000 and £100,000, or cumulative donations exceeding £10,000, will be subject to an Enhanced Due Diligence prior to acceptance.
Gifts between £10,000 and £100,000, or cumulative donations exceeding £10,000, will be subject to an Enhanced Due Diligence prior to acceptance.
Gifts over £100,000, or cumulative donations exceeding £100,000, will be subject to a Full Due Diligence prior to acceptance.

Each potential gift will be considered against a range of criteria determined by the University, which may include, but not be limited to the following criteria:

Is there any possibility that acceptance of the gift might:
- Seriously damage the reputation of the University both now and in the future?
- Restrict or encroach upon academic freedom?
- Require action that is illegal?
- Create unacceptable conflicts of interest?
- Harm the university’s relationship with other benefactors, partners, potential students or research supporters?
- Generate a potential financial liability or an unacceptable restrictive covenant?
Is there any reason to suspect that the proposed gift may be made from a source that arises in whole or in part from an illegal activity, or, more generally, from activities that may have:
- Evaded taxation or involved fraud?
- Violated international conventions in respect of e.g. human rights, money laundering?
- Limited freedom of enquiry, or encroached on academic freedom?
Is there any evidence indicating that the donor is currently not adhering to ethical practices in their supply chain procurement and management, or that they have failed to do so in the past? Does the donor expect any possible personal gain for example in respect of student admission or progression, or in the appointment of staff?
Will the gift cost the university more to administer than the benefit it derives from it?
Has the donor made the gift independently and voluntarily, free from coercion, undue influence or similar e.g. do we have reasonable grounds for believing, in the course of our engagement with the individual, that they are in vulnerable circumstances which mean they are unable to make an informed decision to donate?
Is the source of the gift transparent? The University of Salford will not accept gifts in the form of cryptocurrency.
Has the gift been solicited from an organisation or individual that has a history of discrimination against a protected characteristic, or contradicts the university’s Equity, Diversity and Inclusion Policy (EDI)?

Gifts coming from certain sectors that may be considered areas of concern (i.e. exploitive, immoral, and/or harmful in some way) will require further discussion to ensure a rounded and considered decision is made before the acceptance of any gift. Where such concerns exist, the issue must be escalated to the Ethical Gift Acceptance Advisory Group (EGAAG) for further consultation and advice before a final decision is made on the gift acceptance.

Any gift must be signed off by the responsible officer (s)/ body. If any potential donation gives rise for concern it will be escalated to the Ethical Gift Acceptance Advisory Group (EGAAG). This group will then provide a recommendation to the responsible Officer(s)/body. If a gift is institutionally significant the recommendation must be given to University Council.

The acceptance of any donations shall be subject to approval. Given the sensitive nature of certain gifts, it may be appropriate to escalate the decision around their acceptance beyond the officer(s) or body usually responsible.

Each responsible officer, member of a responsible body or the Ethical Gift Acceptance Advisory Group (EGAAG) must review the gift in respect of their role, not from personal opinion; and in line with guidance from the Charity Commission and industry bodies.

Philanthropic prizes may be approved by the relevant schools/faculties where the value of the prize is less than £3,000 per year, subject to the principles outlined in this policy.

Although the university may wish to publish the names of donors (and where they are a graduate, their course and year of graduation), this is the decision of the donor, and the university will respect the donor’s wish for privacy. Further information on donor rights can be found in the University’s Donor Promise.

Records will be kept for all donations to the University whilst they are current. They will be kept for the duration of the donor’s record and then minimised, as outlined in the Philanthropy, Alumni & Supporter Engagement‘s Records Retention Policy. At a minimum this record will include the donor’s name and address, the amount and date of the gift, and what the gift was given in support of. Where possible this will also include the donor’s telephone number and email address. The university recognises that certain elements of its fundraising activity mean that donor’s full details cannot necessarily be captured. In such instances, monies secured will be recorded as ‘Anonymous’, along with how they were sourced (e.g. donation tin) and the project they were given in support of.

A register of all active donors to the University will be kept and will be reviewed annually for any due diligence concerns that may arise during the lifetime of a gift. Any concerns raised will be escalated to the ‘group’.

A completely anonymous donation, i.e. one made through an intermediary who will not identify the donor, will not be accepted by the university.

All single gifts of £3,000 or above should have a written Gift Agreement, or other written agreement from the donor, unless the donor decides otherwise. It is recognised that on some occasions a gift agreement may not be possible to obtain. This document outlines a description of the gift and how it is to be used, as well as installment payment dates (if appropriate), recognition guidance, and donor and university obligations. The following statements will be included in all Gift Agreements as standard:

Statement of Academic Freedom

In accordance with fundraising regulations, philanthropic gifts do not afford the donor any expectation of benefit from the donation. The University will not accept any donation connected to any student or staff application to the university or any act that constrains academic freedom, i.e. gifts will be accepted which allow us to further our work in certain areas but we will not accept gifts which restrict our work. The university will not intentionally disclose or discuss sources or amounts of donations where they think that information might influence the fairness and objectivity of other university decision-making processes.

Gift Acceptance Policy

Copies of the university’s Gift Acceptance Policy and Donor Promise are available on the university website or directly from the Office of Philanthropy, Alumni and Supporter Engagement. The university retains the right to revoke the Gift Agreement should information become available which indicates that the gift breaches the guidelines outlined in the Gift Acceptance Policy.

Amendments to use of gift

All restricted donations will be applied to the purpose for which they were originally intended. The university’s priorities will change from time to time and, should this happen, alternative uses for restricted donations will be discussed with the donor or the donor’s representative where possible. If, after reasonable effort, the donor’s representative cannot be contacted, appropriate officers of the University shall nominate an independent panel to review the gift and shall act within the spirit of the original gift in determining any variation to its use.

Gift Agreements must be co-signed by someone more senior than the member of staff who solicited the gift. If a gift of £3,000 or over is offered or received without a Gift Agreement, written approval is required from the officer(s) that would co-sign the Gift Agreement.

Gifts for a specific project must be regulated by a single Gift Agreement. Multiple Gift Agreements must not be used for a single gift.

No individual, centre, department or school can accept a philanthropic donation without first consulting the Office of Philanthropy, Alumni and Supporter Engagement. This does not apply to discussions with Research Councils and similar grant awarding bodies over potential competitive bids for funds, nor funding sources identified by the university’s research team.

Tax efficient giving

The university may seek to recover tax, e.g. through Gift Aid, where appropriate and with the consent of the donor. We will also need to comply with any appropriate and relevant tax authority in the reporting of gifts made. We will also maintain an appropriate charitable status both within the UK and other overseas territories. We will not advise donors on tax efficient giving but may wish to make donors aware of potential vehicles that are tax efficient and may increase the value and benefit derived from a gift. All donors will be advised to ensure they have received independent advice on tax efficient giving.

Ethical fundraising

Fundraising practices

All gifts will be handled by the Office of Philanthropy, Alumni and Supporter Engagement in accordance with the University Financial Regulations, Donor Promise, Counter-Fraud Policy and the Anti-Bribery Policy. It is agreed that the university will actively seek philanthropic funding on the basis that the project is approved by the Head of the Office of Philanthropy, Alumni and Supporter Engagement as being strategically important to enhancing the university’s academic standing, institutional reputation, or income generating potential.

All university fundraising solicitations and communications will:

Accurately describe the University’s activities and the intended use of donated funds;
Respect the privacy of those who benefit from the university’s activities;
Comply with UK GDPR and the Data Protection Act 2018.

Training will be in place to ensure that volunteers and employees who solicit or receive funds on behalf of the university shall:

act in accordance with all applicable laws
adhere to the provisions of applicable professional codes of ethics and standards of practice;
cease solicitation of a prospective donor upon request;
disclose immediately to the university any actual or apparent conflict of interest, personal association, or potential personal benefit.

Paid fundraisers, whether staff or consultants, will be compensated by a salary, retainer or fee, and commission or commission-based payments. Compensation policies for fundraisers, including performance-based compensation practices (such as salary increases or bonuses) will be consistent with the university's policies and practices that apply to non-fundraising personnel.

Any concerns raised in relation to the university’s fundraising activity will in the first instance be directed to the University Secretary.

Acceptable sources of funding

The university will not knowingly work with or seek to work with individuals or organisations where activities include practices which are inconsistent with our mission and values, or which may jeopardise the reputation of the institution.

The Office of Philanthropy, Alumni and Supporter Engagement and those working on its behalf have a duty to maximise resources and opportunities. If a donation is refused, the university must be able to demonstrate that it has acted in line with its institutional vision and strategy.

Policy enforcement

What happens when the policy / procedure is not followed

If gifts to the university are pledged or made which do not fit within the gift acceptance and ethical fundraising requirements outlined in this policy, they will be rejected and returned to the donor/potential donor. Any gifts previously made by such a donor will also be reviewed and may potentially also be returned.

Breach of this policy by members of university staff may result in disciplinary action in accordance with the university’s relevant policies. It could also lead to civil or criminal proceedings.

This policy will be reviewed every three years to ensure it remains relevant and accurate. The policy will also be reviewed against any gift acceptance decisions made within year to ensure all procedures are complied with.