Donation and Sponsorship Acceptance Policy

Context and Objective of Policy

Denville Hall 2012 is a registered Charity No 08174255. Each year, we have to raise an increasing amount of our income from donations and sponsorship to support our work and to fulfil our charitable aims.

We must act in the best interests of the Charity when deciding to accept or refuse a donation or sponsorship.

Denville Hall has a duty and desire to be sensitive to the general concerns of the public regarding ethical issues of fundraising. We recognise the need to conduct our fundraising responsibly, mitigating potential reputational, financial, or actual risk that may result from accepting gifts or sponsorship.

We have paid the Fundraising Regulator’s levy and agree to abide by its code of practice which is detailed here: https://www.fundraisingregulator.org.uk/code-of-fundraising-practice/code- of-fundraising-practice/.

We undertake to comply with relevant law and regulations, including the Proceeds of Crime Act, Data Protection, Tax and Gift Aid legislation, and Charity Commission guidance. All Denville Hall employees abide by the Fraud, Bribery and Corruption policy.

This policy sets out the principles and approach we take to considering donations and sponsorship and managing the associated risks. This policy applies to donations and sponsorship in cash and in kind, but not to gifts of archives and historically important assets which are covered separately by the acquisitions procedure.

 

Parameters of Policy

Denville Hall 2012 Trustees must, under general principles of charity law, take decisions as to whether to accept or refuse gifts or sponsorship, in the best interest of the Charity. Trustees must not allow individual or collective views on political or ethical issues, not directly related to the interests of the Charity, to affect their judgement when making these decisions. The Charity’s management and trustees are therefore prohibited from allowing their personal political or moral beliefs to influence their judgements about gifts or sponsorships and whether Denville Hall should reject them. The institution limits its judgments to the potential harm caused to the Charity and its collection by unethical sources of funding, rather than the potential harm done to society by alleged illegal or unethical activities of companies and individuals.

 

Risks

Denville Hall 2012 wish to uphold the highest standard of fundraising practice and compliance and to abide by the Fundraising Regulator’s Code of Fundraising Practice, and follow the key principles and behaviours of a fundraising organisation: to be legal, open, honest and respectful. Risks of not managing the ethical issues of fundraising include:

  • Reputational damage arising from association with organisations or individuals perceived to be engaged in unethical activities.
  • Acceptance of tainted donations and consequential reputational damage arising from complicity with illegal activities.
  • Financial loss arising from a failure to effectively manage relationships with potential donors or sponsors.
  • Failure to carry out Denville Hall’s statutory obligations as a result of relationships with donors or sponsor.

 

Policy

Donation and Sponsorship Acceptance

Denville Hall has a high profile nationally and internationally, and is actively engaged in fundraising, we seek support from a wide range of individuals and organisations to assist in achieving our objectives.

We consider each potential donation and sponsorship individually and do not maintain a specific list of requirements and exclusions. We assess all donations and sponsorships against four principles:

They must:

    • support the charitable objectives of Denville Hall
    • reflect the integrity of Denville Hall
    • not influence the provision of support to the Creative, Theatrical Industry not infringe the provision of residential places

 

Donation and Sponsorship Refusal

There are occasions when it is not possible for Denville Hall to accept a donation or sponsorship.

Denville Hall will only refuse a gift or sponsorship if

  • It would be unlawful to accept it (e.g. the Chrity is aware that the gift or sponsorship comprises the proceeds of crime), or
  • There is a significant risk that acceptance may cause harm to Denville Hall and any such harm is likely to be disproportionate to the benefit the Charity will derive from acceptance of the gift or sponsorship.
  • The conditions attached to accepting the gift or sponsorship outweigh its value to Denville Hall.
  • The donor is deemed to be ‘a vulnerable donor’ in accordance with the Fundraising Code of practice. In this occasion Denville Hall’s Working with Vulnerable Donor Policy is applied.

 

or when ‘Harm’ could arise:

  • Where acceptance of a gift or sponsorship interferes with or has the potential to interfere with, Denville Halls’ ability to fulfil its charitable aims, statutory obligations, or other objectives, including its ability to deliver its scholarships.
  • Where acceptance of a gift or sponsorship and any terms attached to it might lead to an undue and inappropriate third-party influence, or impression of such influence, on institutional decisions of Denville Hall.
  • Where the acceptance of a gift or sponsorship would substantially damage Denville Hall’s reputation among its supporters and the public at large, or incur criticism from the press, public, or any other relevant community of professionals.
  • Where by accepting a gift or sponsorship, existing and future relationships with donors and supporters will be jeopardised.
  • Where there is the risk of the donor or sponsor not being able to honour the gift or sponsorship in full or in part.
  • Where the acceptance of a gift or sponsorship could give rise to an inference of complicity with illegal activities.

 

Where Denville Hall Board is concerned about a donation or sponsorship, they may seek the views of the Charity Commission or an order from the Charity Commission sanctioning their decision.

If Denville Hall Board ultimately decide to refuse a donation or sponsorship, a careful record of the Board’s decision, and the reason for it, will be kept.

Anonymous Donations

Denville Hall is not able to accept genuinely anonymous donations, because such donations prohibit a proper risk assessment. Donations excluded from this are low-level donations received via on-site cash donation boxes, donation app or via JustGiving (or similar) page. The identity of donors who prefer to give anonymously must be known to the Appeal Director, development team and Finance Manager and Chair of the Board and when required the Trustees responsible for Audit.

 

Policy in Practice

Appeal Director operates the policy under delegated authority from the Board of Trustees, who retain overall responsibility for decisions relating to the acceptance of gifts or sponsorship. They are responsible for ensuring donations and sponsorships are monitored as they are received by the Charity. The department accepts donations and sponsorships which abide by the principles above and have no risk attached.

A risk assessment will be carried out on all prospective gifts or sponsorships of £50,000 in value and above, including Corporate and Individual Memberships, exercising due diligence to seek assurance that the acceptance of gifts or sponsorship is in the best interest of the Charity. Risk assessments will also be carried out when:

  • Corporate Members renew their membership
  • Recurring gifts or instalment payments of existing gifts or sponsorship are greater than£200,000, in which case a risk assessment will be undertaken for each payment.

Risk assessments will be updated to include any significant areas of concern they may have arisen since the previous assessment was carried out.

If department members have any concerns around a donation or sponsorship, these are raised with Appeal Director, who can refer them to the Chair or Board for further investigation.

 

Where there is concern in relation to the criteria, and in accordance with the Code of Fundraising Practice, we will undertake due diligence to establish the legitimacy of the donation or sponsorship. This may include requirement of proof of identity and proof of the source of funds.

Our general research, in accordance with Data Protection guidelines and Denville Hall’s Privacy Policy, may include reference to HM Treasury and Office of Financial Sanctions list and Companies’ House database of disqualified directors.

Fundraising staff must also raise concerns about any donation or sponsorship when they have reasonable grounds for believing that an individual lacks the capacity to make a decision to donate, and must not exploit vulnerable circumstances of any donor.

Should the circumstances of the donor or sponsor change at any point during the relationship with Denville Hall, we reconsider the donation or sponsorship against these criteria.

Appeal Director will refer concerns to the Chair, and subsequently to Denville Hall Board.

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

Benefits relating to donation and sponsorship are negotiated by the Appeal Director, in consultation with senior management colleagues and referring to the board approved sponsorship matrix. For significant and long-term benefits, such as naming rights, Board approval will be sought.

Denville Hall will consider conflicts of interest in relation to donation and sponsorship from members of the Board, in accordance with Denville Hall’s Policy on Conflicts of Interests.

Risk assessments will not be performed on funding received from statutory bodies such as the Arts Council or National Heritage Lottery Fund.

 

Risk Assessment

When carrying out a risk assessment, potential indicators of ‘harm’ will be identified by Denville Hall’s research, and recorded as part of the assessment process. Indicators could include:

  • The source of a gift or sponsorship is alleged to have participated in illegal activities, including financial crime, or has previously been found guilty of such crime.
  • The source of a gift or sponsorship is found to be listed on international or legal exclusion lists. A donor’s professional, personal or network status would incur a noteworthy conflict of interest.
  • The source of a gift or sponsorship is affiliated with present or past actions that would be liable to incite protest from Denville Hall supporters, stakeholders, and the public.
  • The financial origin of a gift or sponsorship is suspected to be illicit.

In seeking to limit its exposure to risk the Trustees of Denville Hall are committed not to establish partnerships with individuals or corporate entities whose primary enterprise involves activities which may harm Denville Hall or its objectives.

 

Research

In order to compile Risk Assessments and make informed decisions, Denville Hall shall undertake its own research into the origin of potential gifts or sponsorships. The Appeal Director and Development team will pursue these assessments responsibly, taking care to present their findings without bias. In exceptional circumstances Denville Hall’s Appeal Director in consultation with the Chair may choose to commission additional, freelance or external research.

 

Risk assessments will consist of an overview of publicly available information supported by censure details obtained from services such as the Factiva and Dow Jones Risk Centre database. Sources of publicly available information include Companies House, 192.com (UK Electoral Roll and Directory Enquiries), and information that has been published in articles/newspapers (we use Factiva, a global news database). In order to protect subject rights, risk assessments shall clearly distinguish between allegation and fact, and shall ensure all research is corroborated across multiple sources.

Respecting Denville Hall’s responsibility to safeguard its prospects’ data rights, risk assessments shall be produced at the earliest opportunity prior to the acceptance of a gift or sponsorship and only shared with those making decisions on the risk. Information will be stored and treated in compliance with Denville Hall’s privacy policy.

–

This policy was approved by the Board of Trustees on 1st February 2025 A formal review will be carried out every two years.

Policy Trustees Approval February 2025 Reviewed Annually or when Code of

Fundraising Practice changes.
Policy Review by Appeal

Director

 September 2025