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Our Fundraising Policy

1.0 Introduction
The Malcolm Bradbury Trust (MBT) is a registered charity (England and Wales Charity Number 1188896) that seeks for donations and support from members of the public, charitable foundations and companies in support of its charitable objectives:
• to promote the public knowledge and appreciation of the works of Malcolm Bradbury by such means as are charitable; and
• the advancement and promotion of the arts for the benefit of the public, particularly but not exclusively by the provision or support of educational courses, programmes, activities and opportunities to encourage more people to take part in the arts, particularly those who are disadvantaged socially, economically or through physical or mental health problems.

Trustees have overall responsibility for fundraising, even though this responsibility may be delegated to officers to carry out. There is no single specific statute to guide trustees in law on this matter. However, there are relevant legal principles that trustees and their advisers must ensure are met when deciding whether or not to accept donations.

The law requires trustees, in deciding whether to accept or refuse a particular donation, to consider which course will, taking an overall view, be in the charity’s best interests. The law allows practical and ethical factors to be taken into account as long as they are ones that are likely to affect the specific interests of the charity.

This policy covers only funds raised through donations and grants it does not cover funds raised through sponsorship or other forms of partnership funding in recognition that fundraising is a different activity with different aims and different accounting rules.

MBT is not registered with the Fundraising Regulator due to the small size and scale of the core activity of the charity . However, our fundraising policy is closely aligned with the regulators code of conduct. Registration with the Regulator will be reviewed by the Trustees as the charity and its fundraising activities develop and grow.

This document aims to ensure that we are compliant with the law and follow best practice appropriate for our current resource and size of fundraising programme.

2.0 Purpose
The purpose of this policy is to,
• set out the basis on which we ask for, assess and process monies raised through fundraising activities
• enable trustees and the fundraisers who support them to make clear and consistent decisions regarding the acceptance or refusal of donations.

3.0 General Fundraising policy
3.1 The Board of Trustees
• will always act in the best interests of the charity, and avoid any conflict of interest
• will provide written explanations for refusing a donation
• will decide upon all potential donations that have conditions attached
• will make the final decision if there is differing opinion within the organisation
• will apply to the Charity Commission for an order authorising the decision if it is felt the refusal of a donation will cause a dispute or negative publicity
3.2 All fundraising activities undertaken by MBT (or those representing us) will be legal, open, honest and respectful.
3.3 The trustees of MBT (and their delegates) will act in the best interests of the Charity when deciding to accept or refuse a particular donation. The principles guiding whether a donation can be accepted or refused are attached at Appendix 1.
3.4 All funds raised for a particular cause will be used for that cause. In the event that funds are left over and cannot be expended on the specific activity/cfause, MBT will ringfence the funds for future campaigns and activities with close alignment/place in the main funds of MBT to expend on its charitable activities?
3.5 We will never use coercive tactics or place undue pressure on any individual to make a donation to MBT.
3.6 We will never make an unreasonable intrusion on a person’s privacy.
3.7 Our approach to fundraising activities will be set out in our Annual Report, and we will declare any complaints or failure to comply with a scheme or standard cited.
3.8 We will set out our complaints procedure on our website and will respond to any complaints in a timely, respectful, open and honest way.
3.9 We will comply with duties of confidentiality and data protection law at all times.
3.10 We will publish our policy on our website

4.0 Policy on Assessment of Donations
4.1 The procedure for accepting uncontentious donations will follow the standard financial authorisation levels of £2500.00
4.2 We will not carry out due diligence on donors responding to specific fundraising campaigns and donating as per the suggested donation levels.
4.3 We will undertake due diligence on individuals and organisations that give money to us. The level of due diligence will be scalable in accordance with the size of donation but will apply to all donations over £10,000. The assessment will be based on,
a. Does the donation contribute to our charitable purposes and our stated priorities?
b. Does the donation come from a source which will bring the charity into disrepute?
c. Does the donation place conditions on the charity? and to what extent they are in the charity’s best interests.
4.4 Screening will be undertaken by the Chair with support from Trustees and will include
• a standard search of publicly available material designed to highlight potential areas of controversy or concern. This will normally employ a combination of adverse news searches on the internet, a registry check such as Companies House data, charity commission registration etc. as appropriate.
• bespoke screening of major donors by the Chair of the Board? The results of the initial screening will be reviewed by the Board and kept on record
• Include the conclusions of donor searches in standard fundraising reports to the board.
• Inform the Board of potentially contentious or suspicious donations
• identify if any contentious or suspicious donations need to be flagged to the Charity Commission.
• recommendations to the board for acceptance or refusal
4.5 Policy Review
We will review this policy every 3 years or at the point that regulations change in response to changes to the Fundraising Code made by the Fundraising Regulator

MBT Board of Trustees November 2021