|Revision||4||Approved By||Brian Eccles|
|Approved Date||01/03/2021||Review Date||2023|
References & Definitions
East Galway & Midlands Cancer Support: EGM
EGM-MA-01 Master List of Policies and Procedures
EGM and its Fundraising Volunteers shall follow the core principles contained in the Statement of Guiding Principles for Fundraising (“the Guiding Principles for Fundraising”) published by the Irish Charities Tax Research Ltd (February 2008), thereby confirming EGM’s commitment to best practice in fundraising, and ensuring that all fundraising activities are carried out in a respectful, honest, and open manner.
EGM shall respect the rights, dignity and privacy of its supporters, clients and beneficiaries. It shall not put undue pressure on anyone to make a gift, and where someone does not want to give or wishes to cease giving, that decision shall be respected. EGM shall not represent its clients or beneficiaries in a disrespectful way in its promotional activities, and where possible and appropriate, clients shall have an input into EGM’s promotional strategies. EGM shall take care not to cause unreasonable nuisance or disruption in its fundraising efforts.
EGM shall always act in an honest manner and shall be truthful in all dealings. It shall answer honestly all reasonable questions about its fundraising activities and fundraising costs and shall do so within a reasonable time frame.
EGM shall make information about its purpose and its activities freely available. It shall be transparent about who it is, the work it performs and how any support is used. EGM shall be accountable and shall provide a number of ways whereby those interested can contact the organisation and receive a reasonably timely response. EGM shall maintain a procedure in place to address complaints, a copy of which shall be available on its website.
Fundraising activities on behalf of EGM shall be carried out in compliance with statutory requirements (including those of the Charities Act 2009) and in compliance with internal and external audit controls.
EGM shall maintain clearly identified accounts / lodgements for its Fundraising Department.
Close working links shall be maintained between EGM’s finance and fundraising departments to ensure that funds are correctly identified, allocated and acknowledged by official receipts and that the procedures as laid out in this policy document are followed.
The Chairperson shall have overall responsibility for fundraising management within the organisation, ensuring that adequate and appropriate systems are put in place, that all necessary auditing and reporting requirements are carried out, and that staff employed within the Fundraising department have relevant experience and knowledge to carry out their duties in a thorough and competent manner.
The Fundraising Chairperson shall ensure that Fundraising Volunteers adhere to the Guiding Principles for Fundraising. The Fundraising Chairperson shall ensure the management and maintenance of accurate and complete records for all fundraising activities organised internally or externally on behalf of EGM. The Fundraising Chairperson shall ensure the execution of fundraising campaigns and events in a professional manner. The Fundraising Chairperson shall liaise with the Director of Services on a monthly basis to review fundraising income and expenditure.
The Fundraising Chairperson shall endeavour to ensure that all persons engaged in fundraising activities on behalf of EGM shall adhere to the Code of Conduct of Fundraisers (EGM-FR-01) and to best practice when raising and handling funds.
EGM’s Commitment to Donors
All donations received shall be used solely to further EGM’s service and operational objectives. Where donations are made for a specific purpose within the specified activities of EGM, the donors shall be assured that their gifts shall be used for the purposes for which they were given. Where EGM cannot apply the funds within a reasonable time frame to that purpose, or where the requested purpose is not in conformity with the objectives of EGM, EGM may allocate those funds to a purpose as close as possible to the original intended purpose following communication with the relevant donors.
Any information supplied by donors shall be used solely to fulfil their donation and shall not be shared with any other party for any reason unless permission is granted by the donor to do so.
All requests by donors to remain anonymous shall be honoured.
Donors may request to be permanently removed from EGM’s mailing lists by contacting EGM by email or postal mail. All requests to be removed from EGM’s mailing list shall be honoured, as per the Data Protection Act 2003. Regular opt-out clauses shall be provided in fundraising documentation.
EGM shall not sell or share donor lists. Donors who supply EGM with their postal address or email address may be contacted periodically by EGM for solicitation purposes and/or with information regarding upcoming events. If a donor requests not to receive further contact, this shall be honoured immediately.
EGM shall accord appreciation and recognition to Donors for their gifts, as an essential part of responsible fundraising. EGM shall ensure that donors are aware of the value and necessity of their support.
EGM’s Donor Charter shall be published on EGM’s website.
Fundraising Marketing / Promotion / Communication
All fundraising marketing and/or activities carried out by or on behalf of EGM shall be clearly identified as pertaining to EGM. EGM’s name, logo, address, telephone number, web address and charity registration number shall always appear on fundraising materials.
Where fundraising events are organised to benefit EGM and a number of other charities through the one event, EGM shall ensure that all publicity materials relating to that event are proportionate for all charities involved and that there is no misrepresentation regarding the destination of the funds raised through that event. Insofar as is within the control of EGM, the names, logos, addresses, telephone numbers, web addresses and charity registration numbers of all organisations shall appear on the fundraising materials, for the information of donors.
EGM shall not participate in soliciting donations by telephone.
Communications between EGM and the public / donors shall, as a minimum, comply with Section 7 of the Guiding Principles for Fundraising.
The Fundraising Department shall communicate information about EGM’s services and fundraising needs with its supporter base, which includes the following:
- Memorial Walk Participants
- Christmas Card Outlets
- Event Organisers
- Community Groups
- Service Users
- Hospital Doctors
- General Public
Marketing tools employed to communicate information about EGM’s services and fundraising needs shall include, but shall not be limited to, the following:
- EGM’s Website and Social Networking sites
- Verbal, written, electronic communication
- EGM’s promotional Video(s)
- Distribution of Foundation newsletters
- Distribution of service information leaflets
- Press Releases
- Interviews on local radio
- Attendance and speaking at Fundraising Events
- Written communication throughout the fundraising process with third parties
- Informative Tours of EGM’s premises
Efforts to generate additional income shall be undertaken by:
- Reviewing existing support base and exploring means of expanding this base
- Developing press advertisements and radio commercials appealing for additional donor support
- Placing posters in key locations appropriate to specific events
- Issuing of Press Releases combining information in relation to events and appeals for additional support
- Promoting events through EGM’s annual Newsletter
- Highlighting the need for funds
EGM’s fundraising activities shall normally be restricted to the city and county of Galway. If EGM is approached by third parties in relation to potential fundraising activities in areas outside of Galway County, EGM shall contact the relevant Hospice organisation in that county to seek agreement regarding the proposed event.
EGM shall be open about whether those seeking donations on its behalf are volunteers or employees of EGM. Those fundraising on behalf of EGM shall ensure that prospective donors are aware of their status (i.e. volunteers, or employees of EGM).
It is current policy of EGM not to use paid third party agents for fundraising.
EGM shall ensure that all fundraising events organised by EGM requiring Garda Permits, church permits or special insurance provision are appropriately managed by EGM in compliance with any and all conditions pertaining to the approved permit and/or insurance. EGM shall endeavour to ensure that any fundraising events organised by members of the public, of which it receives advance notification, comply with all necessary permit and/or insurance requirements.
Gift Acceptance (Money or Property)
The responsibility for gift acceptance (or rejection) lies with the Board of Directors, delegated to the Chairperson. No gift shall be accepted which is conditional in any way or which binds the Chairperson to a particular course of action; any such gifts shall be declined. The Chairperson shall be guided by the Board of Directors with regard to the acceptance or otherwise of any potentially controversial gift, whether cash or non-cash. In exceptional circumstances the Chairperson and/or the Board of Directors may consult with a donor prior to acceptance or rejection of a donation.
Unconditional donations up to the value of €50,000 shall be accepted by the fundraising office via appropriate procedures. Any conditional donation or donation above €50,000 shall be referred to the Chairperson.
Management of Fundraising Complaints and Feedback
EGM shall ensure that all dealings and communications with supporters and the general public are open and honest. The continual growth and success of EGM is significantly reliant on the support of those involved in fundraising activities on behalf of EGM. The Fundraising Volunteers shall listen attentively to, and respond promptly to, all views and opinions, comments and complaints. The Fundraising Volunteers shall strive to learn from any constructive criticisms and shall act quickly to rectify any relevant issues raised in complaints received.
All complaints received by any member of the Fundraising Volunteers shall be referred to the Fundraising Chairperson. The Fundraising Chairperson shall report the Incident. The Fundraising Chairperson shall process and respond to the complaint in accordance with the Fundraising Complaints Procedure (EGM-FR-03).
In the event that the complainant is not satisfied with the outcome of EGM’s formal investigation, he/she shall be informed by the Chairperson of the procedure for referring the complaint to the Monitoring Group of the Irish Charities Tax Research Ltd, and shall provide the complainant with full contact information within 7 days of being informed of the complainants dis-satisfaction.
All matters of illegality shall be addressed immediately to An Garda Síochána by the Chairperson.
Management of Money Received Through the Post
All post received shall be opened and recorded by whoever is working in the office, if there is money then a support volunteer will be asked to come and verify the amount before it is recorded and placed in the safe. This shall ensure accountability in relation to all monies received through the post.
All monies received through the post or in any other manner shall be acknowledged/receipted using the official Receipt Book.
A receipt shall be confirmed by two signatures.
Once received at EGM, under no circumstances shall money be stored / held in any location other than in the designated Foundation safes.
Staff are expressly forbidden to bring money direct to the bank for lodgement unless authorised to do so (in each individual case) by the Fundraising Chairperson, Finance Manager, Director of Services or Chairperson.
Management of money received at The Centre (including Funeral Boxes and Collection Buckets)
Money received at the Centre shall be counted and receipted jointly by whoever is working in the office and by a member of the Fundraising Group/Support Worker. Outside of weekday working hours (9am-5pm), or in the event of a member of the Fundraising Volunteers not being available to countersign the receipt, the receipt issued by EGM shall be countersigned by the donor, or by the person representing the donor.
Receipt of Funeral Boxes
When a Funeral Box (hereinafter “Box”) is returned to the Centre, whoever is in the office or a member of the Fundraising Group/Support Worker shall record it as ‘returned’ in the “Donation Box Sheets” folder which is retained in the office.
If the Box is received during normal office hours (Monday – Friday, 9am – 5pm, excluding Public Holidays) a member of the Fundraising Team or the Director of Services/Support Worker shall be requested to receive the Box from the person(s) returning the Box. When the member of the Fundraising Team arrives at Reception, he/she shall offer the person returning the Box the opportunity to witness the opening of the Box and the counting of the contents at the Centre. If this offer is accepted, the person returning the Box shall co-sign the receipt when the counting process is completed.
If the person returning the Box declines to wait, or if the Box is returned outside of normal office hours, the Director of Services/ Support Worker or Fundraising Team Member (as appropriate) shall issue the person with a receipt marked “uncounted”, noting the number of the Box on the receipt along with the name of the deceased. The person who brought in the Box shall, at the same time, also be informed by the person receiving the Box that the Box shall be opened and the contents counted jointly by two members of the Fundraising Volunteers at the earliest possible opportunity, and that a formal receipt for the counted contents will be issued to the next-of-kin.
Receipt of Collection Buckets
If a Collection Bucket (hereinafter “Bucket”) is received during normal office hours (Monday – Friday, 9am – 5pm, excluding Public Holidays) a member of the Fundraising Team or the Director of Services/Support Worker shall be requested to receive the Bucket from the person(s) returning the Bucket. When the member of the Fundraising Team arrives at Reception, he/she shall offer the person returning the Bucket the opportunity to witness the opening of the Bucket and the counting of the contents at the Centre. If this offer is accepted, the person returning the Bucket shall co-sign the receipt when the counting process is completed.
If the person returning the Bucket declines to wait, or if the Bucket is returned outside of normal office hours, the Director of Services/ Support Worker or Fundraising Team Member (as appropriate) shall issue the person with a receipt marked “uncounted”, noting the number of the Bucket/s (located on the underside of the bucket). The person who brought in the Bucket shall, at the same time, also be informed by the person receiving the Bucket that the Bucket shall be opened and the contents counted jointly by two members of the Fundraising Volunteers at the earliest possible opportunity, and that a formal receipt for the counted contents will be issued to the event organiser.
Procedure for collection and management of cash by volunteers on behalf of the Fundraising Department.
Volunteers from time to time may be requested by the Fundraising Department to collect money on behalf of EGM.
Volunteers shall carry I.D. at all times while carrying out such duties.
Prior to a volunteer departing from EGM to collect monies from a third party, a member of the Fundraising Department shall telephone the third party responsible for handing over the monies and shall furnish him/her with the volunteer’s details and expected time of arrival.
When the volunteer arrives to accept the monies from the third party, the volunteer shall jointly complete Form EGM-FR-02 “Collection of Money on Behalf of EGM” with the third party.
The person from the Fundraising Department accepting the monies from the volunteer shall complete the final section of Form EGM-FR-02 in the presence of the volunteer. If the volunteer is not present at the time the monies is being counted, the monies shall be counted, and the contents verified, jointly by two members of the Fundraising Department, one of whom shall complete and sign the Form EGM-FR-02.
Recording and lodgement of monies
All monies received at EGM is to be entered into the Cash Book to show when the monies were received, the amount received and when it was banked. This must be signed and verified by two people.
Payments and transfers
Prior to final submission these are to be checked to ensure the correct account is selected and the correct amount is entered to avoid any transactional errors. This must be witnessed, checked for errors and verified by two people.
A full external audit shall be conducted by the nominated independent Auditors on an annual basis. The annual audit shall include a thorough check on all monies received and all payments made. The audit shall include a review of accounting processes and safeguards in place. A full report on the annual audit shall be sent by the independent auditors directly to the Chairman of the Board of Directors, with a copy to the Chairperson, Finance Chairperson and Director of Services. Upon receipt of this Auditors’ Report, a meeting of the Board shall be convened. A representative of the independent Auditors shall attend the meeting. The Annual General Meeting of the Board shall then be convened. At the AGM, the Finance Chairperson shall report on the Auditors’ findings. Having discussed the matter fully and have addressed the concerns (if any) raised by the Independent Auditors, the Board shall approve the Annual Accounts, which shall then be made available to the appropriate external agencies, including the Companies Office.
Procedure if Fraud or Theft Suspected
Any fraud or theft that is detected or suspected shall be reported immediately to the Finance Chairperson, Director of Services and Chairperson of the board, and an Incident Report completed by the person detecting or suspecting fraud/theft.
The Chairperson and Director of Services shall have primary responsibility for the investigation of all suspected fraud or theft and shall co-ordinate all investigations. Investigations may be internal or may involve external agencies such as an Garda Síochána.
Free and unrestricted access to all company records shall be made available to the investigation team, who shall have liberty to examine, copy and or/remove all or any portion of the contents of files, desks, cabinets and other storage facilities on the premises without prior knowledge or consent of any individual who may use or have custody of any such items. CCTV recordings shall, if appropriate, be reviewed as part of the investigation. In exceptional circumstances, covert CCTV surveillance may be arranged in support of the investigation.
If the investigation substantiates that fraudulent activities have occurred, the Chairperson shall issue a report to appropriate personnel, and to the Board of Directors.
Decisions to instigate disciplinary procedures, to prosecute or to refer the investigation results to the appropriate law enforcement and/or regulatory agencies for further investigation or action shall be made in conjunction with EGM’s legal advisors and senior management.
Corrective action and recommendations to prevent recurrences of fraud shall be put in place including fraud education/training with a risk analysis of areas of vulnerability and pro-active fraud auditing.