EDINBURGH INTERNATIONAL FILM FESTIVAL LIMITED (the “Charity”)
A Charity Registered in Scotland – SC053218
1. Introduction
The CEO coordinates and reports on all philanthropic fundraising across the Charity. This function is important and central to the Charity’s plan to significantly increase income from the private sector and therefore create a sustainable and growing fundraising culture to support the Charity’s vision.
This donations policy (“Policy”) outlines the Charity’s policy regarding philanthropic fundraising. It is relevant to all members of staff and provides information, including contact information, relating to identification and proper accounting procedures for donations.
2. Purpose
Philanthropic funding represents additional private sector financial support that enables the Charity to invest further in key strategic areas such (add aims).
We need to account accurately for and record all funds raised or pledged to measure fundraising activity and income generation throughout the Charity, for audit purposes and both internal and external regulatory bodies.
The purpose of this Donations Policy is therefore to:
Define philanthropic income and ensure all donations are correctly recorded and reported in the Charity’s philanthropic returns for both internal and external bodies;
Explain how to properly maximise donation income. At present this can be done by asking UK donors to complete a Gift Aid declaration which allows the Charity to reclaim tax on any donations from individuals paying UK income or capital gains tax;
Ensure donors are identified and stewarded correctly and all approaches are co- ordinated and professionally managed; and
Ensure donations are compatible with the Charity’s objectives and consistent with the goals of the Charity.
3. Scope
This Policy applies to all staff.
4. Definitions
A gift or donation is a voluntary transfer of money by a donor or other asset, made with philanthropic intent for the benefit of the organisation. After receipt, the organisation must own the donation in full and any work, project or intellectual property that results. The donor may not retain any explicit or implicit control over a gift after acceptance by an organisation and there must be no contractual conditions attached to the donation.
Philanthropic funds can, for example, fund the following:
- Buildings, land and equipment/other assets that become or remain the property of the Charity;
- Staff appointments, providing there is no donor control over the appointment and neither consultancy nor work on research contracts is included;
- Endowment of lectures and other academic activities.
5. Sources of philanthropic funds may include the following:
- Gifts from individuals, of cash and other instruments of wealth, including shares;
- Gifts-in-kind (or donated assets) including property, art, equipment;
- Legacy income;
- Monies from charitable trusts and foundations;
- Gifts from companies;
- Gifts from overseas governments or their agencies and foundations (please also see Anti- Bribery policy).
6. Procedure for all Donations, Endowments and Legacies
The CEO will coordinate fundraising across the Charity, maintain details and advise the Chair of the Board of all donations for reporting and audit purposes, and ensure any contact made with donors is relevant and any future approaches are co-ordinated. If the CEO is aware of all donations, then s/he can ensure they are consistent with the goals and policies of the Charity and refer anyone who wishes to approach a donor, to ensure no conflicting requests or multiple approaches from different parts of the Charity are made. All intentions to approach existing or potential donors should therefore be notified to the CEO before contact is made.
7. Acceptance/Refusal
In considering the acceptance of any donation, endowment or legacy, the Charity will consider if the donation is compatible with the purposes of the Charity and consistent with the aims & goals outlined in the Charity’s Business Plan. The CEO will also consult with the Chair of the Board to ensure that any gift complies with any relevant, current legislation.
The Charity will not accept any donation or pledge which is deemed, following investigation research, to have been funded through activities which:
- Are unlawful (including any form of theft, fraud, tax evasion, money laundering or terrorist activity), whether in the UK or under the jurisdiction of the country from which the pledge is made;
- Violate international conventions that bear on human rights; or
- Limit freedom of enquiry, or encroach on academic freedom.
- In addition, the Charity must be able to confirm that acceptance of a donation will not:
- Lead to a conflict of interest with the ethics and principles of the Charity;
- Require an action or actions on behalf of the Charity or its staff which may be deemed illegal;
- Harm the Charity’s reputation and relationship with other benefactors, partners or funders; or
- Constitute any form of bribery.
As part of the due diligence involved in accepting a gift, the Charity will identify if there are any present or upcoming Charity tenders for work that may be of interest to the donor. If there is a possible link no donation will be accepted or discussed until the Charity has ensured that there is no possible conflict of interest.
For donations that will be referred to the Board of Governors for approval the Charity may engage a third party to carry out due diligence in addition to the due diligence carried out by the Charity.
8. Responsibility levels for acceptance of philanthropic gifts
The Charity’s Scheme of Delegation defines the levels of responsibility for the acceptance of philanthropic gifts, as summarised below: –
CEO Approval
Chair of Board Approval
EIFF Board of Trustee Approval
Donations & other philanthropic gifts
Up to £5,000
Up to £25,000
£25,001 & above
Notwithstanding the financial parameters defined above, prior permission must be sought from the Chair of the Board if there is any question that a donation may put the reputation or brand of the Charity at risk.
Ongoing research and due diligence will be maintained on all high value donors to the Charity following the donation.
9. Recording and Reporting
The CEO will ensure donors are given a Gift Agreement, where appropriate. Once donated income has been identified, the Chair of the Board should be advised and the Charity’s Accountants provided with all support information and relevant paperwork.
This information should be recorded for auditing purposes. The minimum information required is as follows:
- Name and address of donor;
- Name of staff member(s) involved;
- Amount and purpose of donation including project/department the gift is to support;
- Copies of supporting letters, proposals, communication with and from the donor.
- Stewardship
- All donors should be properly thanked by either the CEO of the Charity or the Chair of the Board.
- Other considerations
Gift Aid is a way for the Charity to increase the value of monetary gifts from UK tax paying individuals by claiming back the basic rate tax paid by the donor. It can increase the value of donations by 25% at no extra cost to the donor. Gift Aid declarations, once returned, should be sent to the Charity’s Accountants, who will process the claim and ensure the tax refund received is credited to the appropriate project code. If you are unsure if Gift Aid can be claimed, please raise with the Charity’s Accountants.
Board Oversight
A report on all individual philanthropic gifts and donations exceeding £5,000, contracted or accepted by the Charity in the preceding quarter, are to be reported to the Board. This report will also include advance notice of any anticipated funding activity the CEO may seek to accept in the following quarter.
10. Anonymous donations
There may be occasions when the donor wishes to remain anonymous. In this situation, the identity of the donor must be disclosed to the Board. The Chair of the Board will ensure that the monies are not from an unlawful activity before the donation is accepted (see Financial Regulations for the Charity’s Anti-Money Laundering Policy). The donor’s details will remain anonymous from the rest of the organisation.
11. Responsibility and Contacts
The CEO has overall responsibility for actioning this Donations Policy and for ensuring that it is effectively implemented, that progress is monitored and that the Donations Policy is regularly reviewed.
The CEO has responsibility for the accounting procedures.
Policy Last Amended: March 2024
