Alex TLC receives no Government funding and so we’re completely reliant on the generosity of people like you.
The funds you donate allow us to work towards our vision of support and access to treatment for everyone living with leukodystrophy.
We’re so grateful for your support and want to ensure that you have a positive experience with Alex TLC.
We’re registered with the Fundraising Regulator and commit to our fundraising being legal, open, honest and respectful, meeting the standards set in their Code of Fundraising Practice.
Our Fundraising Promise:
We will commit to high standards
We will be clear, honest and open
We will be respectful
We will be fair and reasonable
We will be accountable and responsible
1. Introduction
Financial support from individuals and organisations is essential to deliver the aims of Alex TLC, leading to better support for people with leukodystrophies. We welcome partnerships with, and gifts from, a wide range of supporters.
In exceptional circumstances, however, it may be necessary to refuse support if acceptance would prejudice the aims of Alex TLC, compromise its independence, or threaten its reputation.
2. Policy statement
This policy relates to philanthropic support, and partnerships with, individuals, charities, and companies.
The Board of Trustees of Alex TLC have overall responsibility to ensure that decisions are made in the best interest of the charity and our beneficiaries, based on Charity Commission guidance https://www.gov.uk/government/publications/charities-due-diligence-checks-and-monitoring-end-use-of-funds. This includes responsibility to “know your donor” and carry out appropriate and proportionate due diligence and risk assessment related to acceptance of gifts.
This policy outlines how Alex TLC undertakes these responsibilities, ensuring due diligence is undertaken for relevant support and potential partnerships.
The policy also outlines Alex TLC’s ethical approach to philanthropic funding and partnerships and commitment to make our approach transparent. Whilst the vast majority of support is extremely welcome, there may be instances where the reputation and operation of the charity needs to be protected from claims of impropriety. Key areas are outlined in section 4 below but are not exhaustive.
Risks of accepting specific support include but are not limited to:
This policy outlines how we might review potential support and clarifies how we would work with companies from certain industries.
3. Relevant external bodies and advice
This policy is informed by the following external advice:
Charity Commission:
Charities: due diligence, monitoring and verifying the end use of charitable funds (Compliance toolkit, Chapter 2)
Chartered Institute of Fundraising:
Guidance on accepting, refusing, and returning donations
Any updates to this advice will be taken into account when reviewing this policy.
4. Details of the policy
Tobacco Industry
Alex TLC will not enter into a partnership with a tobacco company.
This does not automatically exclude support from individuals working within the tobacco industry from making personal gifts, including potential match giving from their employers.
We reference the joint protocol between Cancer Research UK and Universities UK which defines a tobacco company as:
“Tobacco Company” means a company, entity or organisation (or groups or combinations of the same) whose business other than for an insignificant part (less than 10% of its revenue), is the development, production, promotion, marketing, or sale of tobacco in any country of the world, or is a subsidiary or a holding company or affiliate of the same.
Pharmaceutical Industry
Alex TLC will accept support from pharmaceutical companies, or other companies involved in medical research, diagnostics, or treatment, as long as there is no risk to the charity’s independence or perception of bias towards specific conditions. Non-commercial work with pharmaceutical companies is reported in our Annual Report.
More detail is available in the “Working with Pharmaceutical Companies” policy.
Other factors
Alex TLC will also consider other areas such as:
This list is not exhaustive.
Anonymous donations
In line with guidance from the Charity Commission, donations over £25,000 where Alex TLC cannot identify the donor are reported to the Charity Commission as a Serious Incident. The Charity Commission is clear, however, that charities are free to accept anonymous donations where there are no suspicious circumstances.
Alex TLC follows the principle of “know your donor” to ensure that support is not received that may be linked to, or the proceeds of, criminal activity.
Restricted donations
Alex TLC is happy to restrict funding to specific areas of work, and will account for income and expenditure recognising restricted funds. We may, however, refuse donations with restrictions that cannot be met, but will always seek to communicate with the donor, or the executors in the case of a legacy, taking advice from the Charity Commission if appropriate.
Equality Act 2010
Alex TLC may accept donations that limit benefits to people who share a protected characteristic under the Act, although this may exclude people with other protected characteristics. In keeping with the Act, Alex TLC will ensure that such cases will:
To be clear, such donations would support planned charitable activity in keeping with our overall aims and strategy.
Gifts from employees, volunteers, and related individuals or organisations
Alex TLC welcomes and values support from these individuals and groups, but this does not confer on the donor any benefit or preferment beyond the usual recognition and stewardship offered to donors.
Commercial partnerships
Commercial partnerships are an important way for companies to support the communities within which they operate, as well as involve employees and customers in charitable activity.
Particular care will be taken to review the benefits and risks to all parties before entering a commercial partnership.
Money laundering
Any evidence of money laundering is considered through due diligence, in line with the Know Your Donor guidelines from the Charity Commission.
Charities are increasingly targets for money laundering, and we will question unusual donor requests (such as returning gifts via a different method to which they were received) as suggested within the Charity Commission advice.
As necessary, Alex TLC will also have regard to Proscribed Organisations and Financial Sanctions Targets as defined by the UK Government and listed here:
Illegal activity
Alex TLC will not accept support that is the result of illegal activity on the part of the donor.
In assessing this risk, in line with our Privacy Policy, only information from reputable public sources, such as national newspapers or government websites, is taken into account.
Returning gifts
Alex TLC will not normally return a gift which has been accepted in good faith and in compliance with this policy. Exceptionally, subsequent events or the subsequent availability of additional information may give rise to the need to review a previous decision to accept a gift. More information can be found in our Donation Refund Policy.
5. Roles and responsibilities
Day to day implementation of this policy is delegated to the Fundraising Manager who will assess whether potential major financial support, or a partnership requiring significant marketing or public relations efforts, should be reviewed by the Senior Management Team or the Board before being accepted.
6. Procedures for following the policy
Major donations or potential partnerships are assessed to establish whether there is need for further discussion at Senior Management level before potential sign off by the Board of Trustees.
Likewise, the Senior Management Team and Board are routinely made aware of major donations or partnerships.
Fundraisers undertake ‘know your donor’ due diligence on new supporters or partnerships, escalating via the CEO if information is unclear or if there are concerns.
In the case of concerns, a briefing will be produced, and shared for discussion with the CEO in the first instance, followed by the Senior Management Team.
Decisions to go ahead or decline support are recorded on our CRM system.
Senior Management and the Board are notified of decisions to decline support, with reasons via the CEO.
We believe that giving to Alex TLC should be a positive experience for all.
Alex TLC has an obligation to protect vulnerable people and those in vulnerable circumstances.
We recognise that some of the people we engage with through our fundraising activities will not always have the capacity to fully understand the nature of the donation they are being asked to make or the consequences of making that donation.
What is a vulnerable person?
According to the Institute of Fundraising’s ‘Treating Donors Fairly’ guide, the term ‘vulnerable person’ includes two groups: (i) people without capacity and (ii) people in vulnerable circumstances.
A person without capacity is someone who does not fully understand the nature of the donation they are being asked to make, or the consequences of making that donation. They are legally unable to donate on their own.
According to the Mental Capacity Act 2005, a person might not have capacity if they have conditions including but not limited to:
• dementia
• a severe learning disability
• a brain injury
• symptoms of alcohol or drug misuse.
A person in vulnerable circumstances is someone who does understand the nature and consequences of donating, but they find it difficult to immediately make an informed decision about the choices offered to them. They are legally able to make a donation on their own, but they might not be in the best state of mind to do so.
Although there’s no precise way of telling if a person is in vulnerable circumstances, some examples might include someone who:
• has had a recent bereavement
• is unable to understand the language spoken to them
• has an undiagnosed or temporary mental health condition, such as anxiety
• has certain conditions or limitations such as severe sight or hearing impairments.
Identifying vulnerable people
We know that it may be difficult in some situations, for fundraisers to decide whether or not someone is in a vulnerable circumstance or that they lack capacity.
The approach of our fundraisers is always to treat everyone fairly and to err on the side of caution. This applies to all of our fundraising by our direct employees and by Alex TLC volunteers or through a third party associate.
Alex TLC staff, volunteers, and third party associates will follow the Institute of Fundraising’s guidance, and when considering whether a person is vulnerable, they will take into account factors such as:
Fundraising and people without capacity
Whenever we suspect that someone we engage with is lacking capacity, we will take steps to respectfully cease the contact in a way which seeks to:
In the context of fundraising, this can be done by concluding the conversation immediately and respectfully.
Fundraisers should do so politely, without:
Fundraising and people in vulnerable circumstances
Whenever we suspect that someone we engage with is in vulnerable circumstances, we will not accept their donation until we know that they’re no longer at risk of making an ill-informed decision due to their vulnerability. Again, we will do this in a way which seeks to:
We will take steps to provide additional support to make sure that they’re happy with their decision to donate. This is because we believe that everyone has the right to donate if they wish to and are able to do so. This support can include, for example:
Again, our fundraisers should do this politely, without:
Under charity law, charities are not permitted to refund donations, other than in specific circumstances. We may make donation refunds in exceptional circumstances where it is in the best interest of the charity to do so.
This policy applies to all trustees, other volunteers, employees, contractors, and third-party representatives of our charity. Its requirements should be reflected in other policies and procedures, agreements and contracts, as necessary.
Refunding donations –basis
Once we have accepted a donation it can only be returned:
If an appeal:
Refunding donations – made in error
Where a donation has been made in error or made by a person who should not or could not have done so, we may consider a refund. We will take all circumstances into account, including reputational and fraud risk, and make our decision in the best interests of the charity. Examples of situations in which we may consider a donation to be a mistake are as follows.
Approval
If we decide not to make a refund, the individual/organisation will be advised in writing, including the basis of our decision. An appeal may be made in writing to the Board of Trustees but must be received within 28 days of the date of the original decision. The trustees’ decision will be final.
In certain circumstances, we may require the approval of the regulator to refuse or return a donation. We will seek regulatory and/or professional legal guidance whenever appropriate, or if any doubt exists.
Recording decisions
The full circumstances of any refunds approved by the Board of Trustees will be recorded and retained with any supporting documentation or approvals for audit purposes.
If we can be of any assistance or if you have any questions about this policy please email us on info@alextlc.org; write to us at Alex TLC, 45 Peckham High Street, London, SE15 5EB; or call us on 020 7701 4388.
If you have any concerns about our fundraising practices or have a complaint to make, you can find more details of how to report this in our Complaints Procedure.
