DONATIONS ACCEPTANCE POLICY/MONEY LAUNDERING POLICY

Asian Welfare Trust (AWT) Donations Acceptance Policy sets out the principles and processes that the AWT

will follow when seeking donations and the basis for accepting or refusing donations from individuals and

organisations.

The policy aims to ensure that decisions are taken by those with the appropriate level of authority, are

grounded in agreed principles and comply with legal and regulatory requirements.

This policy does not cover the following, which are covered in other policies:

• Healthy people
• International and commercial partnerships
• Receiving gifts and hospitality Principles

The AWT is an exempt charity under Schedule 3 of the Charities Act 2011 for the purposes of UK Charity

legislation. Exempt charities are organisations whose purposes are charitable but are accountable to a body

other than the Charity Commission; the AWT is accountable to the Office for group as its delegated charity

regulator. Although exempt from registering with the Charity Commission, higher education institutions

must comply with the requirements of charity law and other relevant legislation.

The AWT wishes to uphold the highest standards of fundraising and to abide by the Fundraising Regulator's

key principles and behaviours of fundraising organisations: to be legal, open, honest and respectful.

The AWT is required to comply with the relevant law and regulations when seeking and accepting donations

including, but not limited to, legislation on the proceeds of crime, data protection, tax and gift aid, mental

capacity, the the AWT’s own policies including, but not limited to, Anti-Bribery Policy , Anti- Money

Laundering Policy and Procedures and Counter Fraud Policy and Response Plan November 2021.

As such they are expected to act in the best interests of the AWT in pursuing its purposes as set out in the

constitution, including the issues of accepting or refusing donations. All fundraising must be channelled

through the people to ensure adherence to the AWT Donations Acceptance Policy.

Fundraising

The AWT fundraises from a wide variety of sources including individuals, companies, trusts and

foundations.

Our fundraising supports the objectives in our service:

An appeal for Fatema Tuz Zahra ®. Darul Uloom Orphan Madrasha boys & girls, Sonaimari, Noakhali, Bangladesh. We are currently constructing a new building for orphan boys & girls who are most and helpless. These orphan children are collected from different rural areas of Bangladesh. This vulnerable madrasa is supporting them by providing accommodation, Islamic education, as well as vocational training. Now we need to expand our accommodation for more people, and therefore we need your help.

Accepting and refusing donations

The AWT will accept donations which meet its objectives and mission and which are consistent with this

policy.

Decisions are taken on a case-by-case basis with the chairman that a donation can be refused in any circumstances when to accept the donation would be more detrimental to the people ability to achieve its objectives than refusing it.

Circumstances whereby the AWT will refuse or consider refusing a donation:

• The funds for the donation have come from an illegal source or with an illegal condition, or cannot legally be given to the AWT.
• The donor is not prepared to reveal their identity to the AWT, which prohibits due diligence, or refuses to take part in the due diligence process. A donor can remain anonymous publicly.
• The donor is considered unable to make independent financial decisions.
• The acceptance of the donation might result in influence in decision-making at the AWT.
• The acceptance of the donation would impinge on the policy freedom of the AWT.
• The nature or level of the donation would result in unacceptable current or future financial liabilities for the AWT.
• The required terms and conditions of the donation cannot be met by the AWT.
• The acceptance of the donation would do serious harm to the AWT’s relationship with the member of the board.
• The acceptance of the donation would cause material damage to the reputation of the AWT, disproportionate to the advantages gained from it.
• Careful consideration will always be given to accepting a donation from a current or prospective group or their close family.

The AWT does not maintain a list of donors from which donations are not accepted, however our fundraising is consistent with our Responsible Investment Policy and the approach that the AWT follows in considering environmental, social and governance (‘ESG’) issues.

Due Diligence process for accepting or refusing a donation:

All fundraising at the AWT seeks to support the orphan people objectives and mission in adherence with our

values. Due diligence will include financial and reputational consideration using publicly available materials

and where appropriate the advice of individuals who have knowledge of the donor. Due to time and resource

implications, due diligence will be carried out when cultivation of a donation is in the planning stages, not for

every prospective donor identified.

Donations from charitable foundations registered and regulated by regulatory authorities in the UK or US

will not normally be subject to due diligence, the board team may refer a registered charity for review if there is

concern of any risk associated with the foundation, its founder or trustees.

The position of existing donors may change over time, as such updated reviews will be carried out on current

donations at regular intervals (every 3 years) and any concerns referred to the Director of AWT.

Authority for accepting or refusing a donation

The Chairman of AWT is responsible for the Donations Acceptance Policy.

Donations will be referred to the Chairman and Sectary by the Director of AWT should any circumstances above be met or there is any concern about acceptance of the donation.

The Chairman and Sectary will consider the due diligence concerns and may approve the donation at this stage or seek further discussion with the charity commission. If the Chairman and Sectary is considering refusing the donation, they must refer this to the charity commission.

Donations will always be referred to the charity commission if:

• The prospective donation meets any of the circumstances documented above.
• They are above £1 million (total cumulative value of giving).
• There is a significant ‘naming’ acknowledgement associated with the donation (above £500,000 total cumulative value of giving).

The Chair of the Council may convene a subgroup of the charity commission (of minimum 4 members including the Chair) to consider accepting and refusing donations in a timely manner outside of regular charity commission meetings. This will ensure the AWT can swiftly approve acceptance of larger donations when the due diligence process has raised no concerns. The subgroup will identify any further due diligence required and recommend accepting or refusing donations to the charity commission.

The decision to accept or refuse a donation, when agreed at charity commission, will be recorded in charity commission and on the AWT’s CRM system and, if appropriate, referred to the Office for group and the Charity Commission. The records of donations being accepted or refused will therefore be available for review should circumstances change in relation to the donor.

Returning donations

In truly exceptional circumstances, where new information comes to light regarding the criteria listed above, a donation may be returned to the donor providing that the terms and conditions of the donation allow for it to be returned, and the law specifically allows for the donation to be returned.

Policy Manager: Director of Asian Welfare Trust

Approval Route: Audit and Risk Committee (ARC) recommendation to Charity Commission.

Approved: October 2024, Next Review: October 2026