Acceptance and refusal of donations policy

Summary

The purpose of this policy is to allow the University to make clear, consistent, compliant and ethical decisions regarding the acceptance or refusal of donations.

1. Updates to this policy

1.1. This policy has been updated to align to the new University of Bristol policy management framework. 

1.2. Decision makers have been changed to reflect current senior leadership roles and responsibilities.

1.3. Guidance in previous version outside the scope of acceptance and refusal of donations has been removed.

1.4. Monetary triggers for due diligence and decision making have been made consistent across all types of giving and types of donor.

1.5. Guidance on specific sources used for due diligence has been removed to reflect current practice.

1.6. Due diligence guidance has been aligned with wider University compliance processes regarding the Assessment of Third Party Suitability and Foreign Influence Registration Scheme.

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2. Introduction

2.1. The University of Bristol is committed to conducting its fundraising activities ethically and responsibly. This policy ensures transparency and consistency in accepting and refusing donations, protecting the University's reputation and compliance with legal and regulatory obligations.

2.2. This policy reflects the ethical principles behind the acceptance of gifts developed by CASE Europe and guidance on accepting, refusing and returning donations published by The Charity Commission.

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3. Scope

3.1. This policy applies to the Board of Trustees and all University staff engaged in fundraising or managing philanthropic donations on behalf of the University, including those working for University subsidiaries.

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4. Definitions

4.1. Code: The Fundraising Regulator's Code of Fundraising Practice.

4.2. GED: The University's Global Engagement Division.

4.3. Data Protection Statement: GED Data Protection Statement as updated from time to time.

4.4. Donor: A person (or persons) who gives philanthropically to the University, including individuals, charitable trusts and foundations, corporate organisations and government agencies.

4.5. Donation or gift: A philanthropic donation or philanthropic gift and include any form of philanthropic support received by the University, including cash, stocks and shares, property and gifts in kind of equipment, artefacts, etc.

4.6. Donor charter: The University's stated commitments to donors as updated from time to time.

4.7. Fundraising: All fundraising activities of the University including soliciting gifts/donations, managing relationships with donors, bidding for and managing philanthropic funding and the receipt and stewardship of funds raised.

4.8. Legal advice: Advice from the University's Legal Services team in the first instance and/or, where deemed to be appropriate, external legal advice.

4.9. Naming Policy: The University's policy and guidelines for the naming of University buildings, centres, posts and awards.

4.10. Prospect: A person (or persons) who has indicated a willingness or intention to give to the University or is assessed as possibly being so willing, including individuals, charitable trusts and foundations, corporate organisations and government agencies.

4.11. University: The University of Bristol.

4.12. UEB: The University Executive Board. 

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5. Responsibilities

5.1. Board of Trustees: Ultimate authority over fundraising and donation decisions.

5.2. Vice-Chancellor, Chief Financial Officer, Chief Operating Officer and Registrar and Executive Director of Global Engagement: Approval for high-value and sensitive donations.

5.3. Global Engagement Division (GED) staff: Conduct due diligence, approve donations within delegated authority, and ensure compliance.

5.4. All University staff: Must refer prospective donors to GED staff for assessment before soliciting or accepting donations.

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6. Policy statement and core principles

6.1. As a charity, the University is obliged to accept all donations unless it would be unlawful to do so or would be detrimental to the achievement of the University's charitable educational purposes.

6.2. In recognition of this obligation, it is the University's policy that it will accept all donations except those that it judges to be obtained from activities which are or could be deemed to be unlawful whether in the United Kingdom or overseas or those which could otherwise adversely affect the reputation of the University or compromise its academic freedom or integrity.

6.3. Each donation will be considered on a case by case basis in accordance with the procedures set out in this policy. The University's general position is that it will only refuse a donation where, in the University's opinion:

1. The donation results from unlawful activities (including unlawful discrimination, violation of international conventions on human rights or any form of theft, bribery, fraud, tax evasion, money laundering or terrorist activity) whether in the UK or overseas.
   
   
2. The donation requires any unlawful action by or on behalf of the University or its staff or Trustees or was obtained by means that are outside of the scope and spirit of the Code.
   
   
3. The donation derives from any activity that limits freedom of enquiry or is contrary to the University's core values of impartial, independent research, scholarship and teaching.
   
   
4. The activities of the donor are otherwise contrary to the values and strategic goals of the University, such that association with the donor could adversely affect the reputation of the University or its ability to further its charitable educational purposes.
   
   
5. The conditions attached to the donation tie it to a specific activity which is likely to cause an unacceptable actual or perceived conflict of interest for the University or any of its Trustees and/or is not in keeping with values and strategic goals of the University.
   
   
6. The donation could give rise to an actual or perceived conflict of interest between the donor and their activities and the area of work or research being funded at the University.
   
   
7. The donation is likely to cause unacceptable damage or injury to third parties.
   
   
8. The donation risks harming the University’s relationship with other donors or inhibiting unreasonably the University's ability to seek donations from other sources.
   
   
9. The cost to the University of accepting the donation is calculated to be greater than the financial value of the donation itself.

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7. Due diligence process

7.1. For the purposes of due diligence and gift approval, donation levels are defined as either individual gifts (including pledges and gifts-in-kind), or the total amount donated by a single donor over a rolling five-year period. If a donor's cumulative giving over five years meets or exceeds a donation threshold, the corresponding due diligence and approval process applies.

7.2. Due diligence is triggered by the following levels of donation:

1. Donations or total giving less than £25,000: Generally accepted without due diligence unless concerns arise regarding the donor or the source of funds.
   
   
2. Donations or total giving greater than or equal to £25,000: Require a preliminary screening, including routine background research and a check for high risk factors such as sanctions, politically exposed persons, and enforcement actions.
   
   
3. Donations or total giving greater than £100,000: Require a full due diligence report, including:
   
   
   • Verification of donor identity.
     
     
   • Assessment of the donor’s background, reputation, and source of wealth.
     
     
   • Compliance checks against sanctions, politically exposed persons (PEP) lists, and regulatory concerns.
     
     
   • Review of any potential conflicts of interest or reputational risks.

7.3. In addition to the monetary value triggers, a full due diligence report must be carried out in relation to any donation which, in the opinion of the Executive Director of Global Engagement, could give rise to significant public interest or potential controversy or which raises complex questions regarding acceptability. This may include:

1. Donors or potential donors based or operating in jurisdictions where regulation is weak.
   
   
2. Donors or potential donors connected to industry sectors where the sector increases the likelihood of conflict or potential controversy.
   
   
3. Unsolicited approaches from previously unknown donors or prospects, particularly where there is no clear connection to the University or the proposed area of support.
   
   
4. Donors or potential donors where enhanced risk factors and/or other concerns emerge from the Preliminary Screening.
   
   
5. Donors or potential donors and associated projects which may require registration under the Foreign Influence Registration Scheme.

7.4. Where required, due diligence must be carried out before a gift agreement is entered into with the donor.

7.5. University staff will avoid, as far as reasonably practicable, cultivating philanthropic relationships with prospects that do not meet the requirements of the Core Principles set out in section 6.

7.6. In exceptional circumstances, GED staff may instruct third parties to carry out due diligence in relation to a prospect or donor on the University's behalf. 

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8. Decision-making authority and approval process

8.1. The delegated authorities and approval process are as follows:

1. Donations under £100,000: Can be approved by GED staff provided no significant risks or concerns are identified during due diligence OR can be escalated to the Executive Director of Global Engagement.
   
   
2. Donations between £100,000 and £500,000 (or escalated as above): Can be approved by the Executive Director of Global Engagement OR can be escalated by them to the Chief Operating Officer and Registrar if deemed necessary.
   
   
3. Donations between £500,000 and £1 million (or escalated as above): Can be approved by the Chief Operating Officer and Registrar OR can be escalated by them to the Vice-Chancellor and Chief Financial Officer if deemed necessary.
   
   
4. Donations over £1 million (or escalated as above): Can be approved by the Vice-Chancellor and Chief Financial Officer OR can be escalated by them to the Board of Trustees if deemed necessary.

8.2. Following the referral of prospective donations, the appropriate decision-maker(s) may:

1. Decide that discussions with the prospect/donor should be suspended pending further investigation.
   
   
2. Make a decision either to accept or refuse the donation.
   
   
3. Escalate the decision to the next level of approval.

8.3. Decisions should be escalated if the decision maker considers there to be significant likelihood of the donation contravening the University’s policy statement.

8.4. Decisions made for a particular donor are valid for 5 years but may be reviewed at any time if any new risks or concerns are identified.

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9. Decision-makers’ duties

9.1. Trustees and their delegates must take all decisions relating to the acceptance or refusal of donations in the best interests of the University.

9.2. When deciding whether to refuse a donation, decision-makers must do so only if they judge that to accept the donation would be more detrimental to the University than to refuse it.

9.3. If a potential conflict of interest is identified involving a decision-maker then they must withdraw from the decision-making process. If they are the sole decision-maker then the decision will be escalated as per the approval process.

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10. Refusing and returning donations

10.1. Donations may be refused if they conflict with the guidelines in this policy. The University does not need to establish an overwhelming case for refusing a donation; decision-makers merely have to act reasonably in deciding whether the University's interests would be served best by accepting or refusing the donation. If a donation is refused, GED staff must document the decision and rationale.

10.2. In cases where a donor or donation presents unforeseen legal, ethical or financial complications after acceptance, the University reserves the right to revisit the approval and, if necessary, return the donation following legal consultation.

10.3. The decision making process for returning donations follows the same process as that for accepting donations.

10.4. Once the University has accepted a donation, it must only return it:

1. If the terms and conditions of the gift provide for it to be returned in particular circumstances and those circumstances apply; or
   
   
2. Where the law specifically provides for the gift to be returned in particular circumstances.

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11. Documentation and record keeping

11.1. GED staff must ensure that the appropriate documentation is completed for every donation. The specific documentation required is a matter for GED, depending on the value of the donation and any other relevant factors.

11.2. GED staff must document all due diligence and all decisions made regarding approval or refusal of donations.

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12. Donation due diligence and decision making table

Table 1: Donation amounts, due diligence requirements and decision makers

Donation amount	Due diligence	Decision maker	Can escalate to
<£25,000	Not required	GED staff	Director of GED
>£25,000	Preliminary required	GED staff	Director of GED
>£100,000	Full review	Director of GED	COO & Registrar
>£500,000	Full review	COO & Registrar	VC & CFO
>£1,000,000	Full review	VC & CFO	Board of Trustees

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