1. Scope

This policy governs the acceptance of donations by Caxton Youth Organisation and provides guidance to prospective donors and their advisors when making gifts to the charity.

This follows the Charity Commission Guidance and in accordance with the Fundraising Regulatory Code requirements and draws on guidance on accepting and refusing donations from the Government. The guidance can be found here: https://www.gov.uk/guidance/accepting-refusing-and-returning-donations-to-your-charity

2. Acceptance of Donations

In considering the acceptance of a donation, Trustees have a duty to demonstrate to the Charity Commission and the public that they have acted in the best interest of Caxton Youth , and that association with any prospective supporter does not compromise its reputation or act in a way that is detrimental to its charitable purposes. In the vast majority of cases, accepting financial support to further the Charity’s work will be the appropriate thing to do. When trustees decide to refuse a donation, they must only do so if to accept it would be more detrimental to the charity being able to achieve its objectives than rejecting it. Caxton Youth accepts all gifts to Caxton unless:

1. There is a question as to whether the donor has sufficient title to the asset given or is mentally competent to transfer the asset to the charity legally. Caxton reserves the right not to accept gifts offered.
2. It would be unlawful to accept the donation as Caxton is aware the gift comprises the proceeds of a crime
3. Accepting the donation would be detrimental to the achievements of the Caxton as laid out in our constitution. We recognise that such detrimental or anticipated detriment has to be set against the benefit of having the funds from the donor, which enables the organisation to pursue its purposes. This is likely to be that accepting the donation would be contrary to our ethics and values.  To refuse a donation there must be evidence that accepting the donation will be detrimental to Caxton achieving its purposes.

This policy applies to all donations including gifts received through capital campaigns and special projects: it applies to all gift sizes and to all gift types including:

• One time or regular cash gifts (from individuals and corporate sources)
• Legacies
• Trusts
• Events that generate donations (both Caxton owned and third party)
• Real estate with fair market value (FMV)
• Stocks, bonds and mutual funds with FMV
• Marketable tangible assets
• Life insurance policies
• Non-cash gifts.

When property other than cash, listed securities, or securities traded over-the-counter is involved, approval of the Finance, Risk and Income Generation Committee will be required.

Gifts in-kind: Caxton will accept appropriate in-kind contributions of skilled services and tangible assets consistent with the purpose and objectives of the charity, in accordance with established acceptance policies and procedures.

Partnerships: Before entering into any partnership for the purposes of fundraising Caxton Youth will ensure there are no conflicts of interest, or potential conflicts of interest relating to the partnership and will undertake due diligence which is proportionate to the scale and size of the partnership.

3. Know your Donor

Caxton will ensure that for any donation of over £1,000 they understand who the donor is and seek to understand the individuals or organisation’s business is to ensure the purposes are appropriate for Caxton to be linked with.  We will seek to understand the donors’ intentions of engaging with Caxton and ensure there is confidence Caxton can deliver what the donor is seeking to achieve.

Caxton will take additional steps to verify the purposes of an organisation or donor who seeks to make a donation from outside of the UK.  Further steps will be taken to verify the provenance of the funds.  If in undertaking due diligence around a donation Caxton becomes suspicious of activities taking place which may be illegal taking place Caxton will report this to the responsible authorities.

Money laundering: In accepting and recording gifts, Caxton will adopt money-laundering controls which may include due diligence checks on the donor and, where there is reasonable doubt, may refuse a donation or inform the relevant authority.

Reputational Risk: In accepting gifts, the Finance, Risk and Income Generation committee have discretion to refuse a donation which may pose a reputational risk to Caxton e.g. due to ethical issues.

In addition to scrutinizing any donation deriving from wealth creating activities that could be incompatible with our charitable objects, Caxton may also decide not to accept donations from individuals or organisations that are facing judicial proceedings in the UK or in another court until the proceedings have finished.

Caxton Youth reserves the right to review and return any donation on an individual basis. Where the Board is concerned about a donation or partnership, they may seek the views of the Charity Commission or an order from the Charity Commission sanctioning their decision. If the Board ultimately decide to refuse a donation or sponsorship, a careful record of the Board’s decision, and the reason for it, must be kept.

4. Restricted gifts

Caxton will only use a restricted gift for the purpose for which it is given. Restricted gifts will be clearly recorded in Caxton’s accounts, which are publicly available. If a restricted gift for a UK based project cannot be used for the purpose given, or ‘has been held for the period of the grant funding set out in the grant agreement, or 2 years if no timeframe set out in agreement, we will liaise with the donor to confirm if they are happy for us to continue to hold it for that purpose, or permission sought for alternative use or the donation will be returned.

5. Recording gifts and donations

Requests, acknowledgements and record-keeping for restricted or unrestricted donations or gifts will be completed by the Caxton fundraising team.

6. Confidentiality of information

Information learned by any representative of Caxton about a donor or the donor’s assets or philanthropic intentions and all details related to gift negotiation will be held in strict confidence, electronically or otherwise.

Donors will be encouraged to notify Caxton of their planned gifts, including bequests, and all such information will be kept confidential unless written permission to release it is obtained from the donor or his or her counsel or unless use of such information is required in the administration of the gift.

All relevant Freedom of Information Act and Data Protection legislation will be observed.

Some information will be held for Gift Aid recovery purposes.

 7. Who is responsible for the Donation and Gift Acceptance Policy?

Caxton Youth Organisation’s Board of Trustees is ultimately responsible for compliance with this policy, with the support of Caxton’s Finance, Risk and Income Generation Committee, and its CEO.

The Board takes ultimate responsibility for accepting or refusing a donation, sponsorship or gift. It is their responsibility to act in the best interest of Caxton when accepting gifts.

These policies and guidelines have been reviewed and accepted by Finance, Risk and Income Generation Committee which must approve any changes to, or deviations from, these policies.

This policy will be reviewed every year, or more frequently should legislative requirements change.

Policy Written By: Paige Kaye,

Role: Fundraising and Communications Manager

Policy Reviewed:      10^th April 2025

Policy Adopted:        29^th April 2025

Signed by:

Date: 29^th April 2025

Name:              Esther Norman (on behalf of the trustees)

Position:         Interim Chief Executive Officer

Date to be reviewed:            29^th April 2026