Ethical Gift Acceptance and Refusal Policy
Policy Statement
Orchard Trust welcomes donations that support its charitable purposes and enable it to deliver greater impact for the people and communities it serves.
Orchard Trust will accept donations where it is lawful and appropriate to do so and where acceptance is consistent with its charitable purposes and Orchard Trust’s responsibilities to its beneficiaries, supporters and wider stakeholders.
This policy supports Orchard Trust’s commitment to ethical fundraising and to the standards set out in the Fundraising Regulator’s Code of Fundraising Practice and relevant Chartered Institute of Fundraising guidance.
Accepting donations
Orchard Trust will normally accept donations unless there is a clear and appropriate reason not to do so.
Orchard Trust will undertake due diligence proportionate to the size and nature of a donation and the circumstances in which it is offered. Small, routine donations from known sources will not normally require formal due diligence.
Additional checks may be appropriate where a donation is unusually large, unsolicited, anonymous, made through an intermediary, subject to unusual conditions, comes from an overseas source, or presents financial, legal or reputational risks.
When a donation may be refused or returned
Donations will only be refused or returned in exceptional circumstances.
These may include where:
- accepting the donation would be unlawful;
- there are reasonable grounds to believe the donation is connected to criminal activity, sanctions or another prohibited source;
- conditions attached to the donation would prevent Orchard Trust from pursuing its charitable purposes or compromise its independence;
- acceptance would be materially detrimental to Orchard Trust’s ability to achieve its charitable purposes;
- the donor is seeking inappropriate influence over Orchard Trust’s decisions, activities or beneficiaries; or
- the risks associated with accepting the donation clearly outweigh the benefit to Orchard Trust and its charitable purposes.
- where a donation is suspected to have been made by an individual in vulnerable circumstances or lacking capacity, decision-making and returns will follow the processes set out in Orchard Trust’s Fundraising and Vulnerability Policy.
Orchard Trust will consider each case on its individual circumstances. Ethical, reputational and stakeholder considerations will form part of the assessment, alongside the potential benefit of accepting the donation.
Decision-making and records
Decisions to refuse or return a donation will be made by the Board of Trustees or by staff acting under authority delegated by the Board.
Orchard Trust will maintain an appropriate written record of significant decisions to refuse or return donations, including the reasons for the decision and any due diligence undertaken.
Where a donation is subject to conditions or restrictions, Orchard Trust will ensure that these are understood, lawful and capable of being complied with before acceptance.
Concerns and escalation
Any member of staff, volunteer or trustee who has concerns about a proposed donation should raise them with the appropriate senior member of staff or trustee.
Where there is uncertainty about whether a donation should be accepted, refused or returned, Orchard Trust may seek appropriate professional or legal advice.
Related Policies
Fundraising and Vulnerability policy
Complaints policy
Data Protection
Privacy policy
Review
This policy will be reviewed periodically by the Board of Trustees and updated where necessary to reflect changes in charity law, regulation and good fundraising practice.
Training Statement
All staff, during induction are made aware of the organisation’s policies and procedures, all of which are used for training updates. All policies and procedures are reviewed and amended where necessary and staff are made aware of any changes. Observations are undertaken to check skills and competencies. Various methods of training are used including one to one, on-line, workbook, group meetings, individual supervisions and external courses are sourced as required.
| Signed: Nick Budd
Board of Trustees |
Issue Date: 18th September 2026
Reviewed: |

