Introduction

 

Financial support from individuals and organisations is essential to carry out the mission and objectives of Well Foundation. 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 Well Foundation, compromise its
independence, or threaten its reputation.

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​Policy Statement

Well Foundation’s Board of Trustees have overall responsibility to ensure that decisions are made in the best interest of the charity and our beneficiaries. This includes responsibility to “know your donor” and carry out due diligence and risk assessment related to acceptance of gifts. Whilst the vast majority of support is extremely welcomed by Well Foundation, there may be instances where the risks of accepting specific support may be contrary to Well Foundation’s missions and values.

 

This policy outlines how Well Foundation, its trustees and members of staff undertake these responsibilities ensuring due diligence in relation to the acceptance and refusals of donations on behalf of Well Foundation. It outlines how we might review potential support, and clarifies how we would work with companies from certain industries.

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1. Applicability

1.1 This policy applies to all members of Well Foundation, including trustees, staff
members and volunteers. Therefore, everyone must follow this policy in accepting or refusing donations.

1.2 The following are covered by separate regulations;
Ex gratia payments.
Failed fundraising appeals.
If the funding offered may be a contract rather than a donation.

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2. Compliance

2.1 As a registered charity, Well Foundation complies with all relevant UK laws and
regulatory guidelines, including those issued by the Charity Commission, HMRC and
the Fundraising Regulator.

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2.2 Well Foundation would only refuse or return donations in exceptional
circumstances. In the event that the organisation considered such action, the circumstances and rationale for the decision made would be documented.

 

2.3 Well Foundation will only return a donation in accordance with Code of
Fundraising Practice (Institute of Fundraising 2025). As outlined in Code of Fundraising Practice (2025) 2.31 once a charity has accepted a
donation it can only return it:

 

● if the terms and conditions of the gift provide for it to be returned in
particular circumstances; or

 

● where the law specifically provides for the gift to be returned in particular
circumstances; or

 

● by way of an ‘ex-gratia payment’ (a payment made as a result of a compelling
moral, but not legal, obligation). This type of donation return will only be
permitted where the charity has received an order from the Charity
Commission for England and Wales.

 

2.4 In soliciting funds, Well Foundation will not knowingly mislead or provide false
information, nor put undue pressure on a donor, particularly if they may be
vulnerable.

2.5 If Well Foundation suspects that our charity has received a donation from an
illegal source, we will immediately notify the relevant authorities, including the
charity regulator.

2.6 Well Foundation also recognises our legal obligations to refuse or return any
donation:

● From a donor who does not have capacity to decide to donate

● That Cannot legally be given to Well Foundation e.g. where the donor does
not own the property that they are donating.

● Where, under the terms of the donation, must be returned in certain
circumstances.

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3. Acceptance of Donations

3.1 Well Foundation accepts donations on a good-faith basis, with the presumption
that donations are acceptable unless there is evidence to the contrary. Appropriate
risk-based due diligence is conducted to ensure that any associated risks are
mitigated to an acceptable level.

 

3.2 In deciding whether to accept or refuse a donation, we balance the potential
impact on our beneficiaries of declining the funding against the potential impact on the charity of accepting a donation that ought not to have been accepted. This
assessment may include risks such as harm to beneficiaries’ interests, reputational
damage, loss of public trust, and the risk of legal non-compliance.

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3.3 In reaching a decision, Well Foundation may consider factors including any
physical or mental health conditions, disabilities or learning difficulties the individual
may have; whether the individual is experiencing stress or anxiety; whether the
donation may affect their ability to adequately care for themselves or cause financial
hardship; their ability to speak and understand English; whether they are under the
influence of alcohol or drugs; and their age.

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3.4 Well Foundation will also take all reasonable steps to avoid asking for regular
donations from anyone aged under 18.

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3.5 Well Foundation has a full policy relating to ethical fundraising. This outlines how
we work to identify and communicate appropriately with vulnerable people in
regards to donations and fundraising. This can be accessed here.

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4. Cryptoassets

In deciding whether we will accept and hold donations of cryptoassets, we will
assess the opportunities, benefits, risks and limitations. In doing so, we will ensure
that we either have or source relevant expertise. If we decide to accept
cryptoassets, we will implement appropriate financial and other controls, and
manage the risk on an ongoing basis.

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5. Anonymous Donations

5.1 Well Foundation may receive donations via collection tins, online platforms, or
other means, and donors may choose to remain anonymous. The charity may accept
anonymous donations, provided appropriate safeguards are in place and any
suspicious circumstances are carefully monitored.

5.2 In line with the Charity Commission’s “know your donor” principle, trustees take
reasonable steps to identify donors and ensure that donations are not linked to, or
derived from, criminal activity. Donations will not be accepted if the assessed risk to
the charity outweighs the benefit of receiving the funds.

5.3 While there is no exhaustive list of suspicious indicators, examples include
unusually large donations, donations in cash, donations from overseas, or requests
for the charity to forward funds or pay a third party on the donor’s behalf. Any
suspicious donations will be reported to the Charity Commission as an incident.

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5.4 In accordance with Charity Commission guidance, donations over £25,000 for
which the donor cannot be identified must be reported as a Serious Incident.
However, the Commission allows charities to accept anonymous donations where
there are no suspicious circumstances.

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6. Refusal

6.1 Well Foundation will not accept a donation where there are reasonable grounds
to believe that:

● The activities being funded fall outside the charity’s objects.

● The individual or organisation holds views, or engages in activities, that are
incompatible with the charity’s values e.g. a company in the tobacco industry

● The donation may be an attempted scam, intended to launder money, evade
tax, or is otherwise illegal.

● The donation may confer private benefit, such as requiring the charity to
purchase goods or services from a specified company.

● Accepting the donation could result in a valid legal claim, or create a risk of a
claim against the charity.

● Conditions attached to the donation are so inflexible that they:

○ Undermine the charity’s independence;

○ Compromise the charity’s effectiveness; or

○ Restrict who may benefit to the extent that it undermines the
charity’s public benefit obligations.

○ The costs associated with accepting the donation would exceed its
value.

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7. Donor Recognition & Private Benefit

7.1 Well Foundation welcomes donations from commercial organisations but will not
accept donations where, in the trustees’ view, the purpose could reasonably be seen
as serving commercial gain. For example, this includes donations intended to allow a
company to market itself to customers or the public as ethical or supportive of our
work when its practices, products, or services do not align with Well Foundation’s
values.

7.2 Recognition for donors will be limited to standard expressions of thanks,
consistent with those given to similar donors. No additional recognition will be
expected or requested, ensuring that any private benefit remains incidental.

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8. Charity Commission Guidance and Approval

8.1 For complex or high-risk donation decisions, trustees may seek formal advice
from the Charity Commission for England & Wales.

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8.2 Where trustees have a moral obligation to refuse or return donations, they must
follow the ex-gratia process, including seeking the Commission’s consent, rather
than using the broader powers to return donations referenced in Charity
Commission guidance.

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​Regulatory Guidance
● Accepting, refusing and returning donations to your charity
● Code of Fundraising Practice
● Due Diligence and Fundraising
● Know your donor – key questions.
● Fundraising Regulator – behaviour when fundraising.