Mental Health Innovations is committed to its charitable aims and fundraises in order to provide services and research. We concur with the Fundraising Regulator's Promise to be open, honest, fair and legal.
Our funding policy seeks to cover the ethical issues and social responsibility within fundraising. All Mental Health Innovations staff involved in fundraising have a responsibility to be aware and have a thorough understanding of the ethical issues referred to in this policy.
Mental Health Innovations respects the rights of its supporters to clear, truthful information about the work of the charity; to openly report how we spend donated and statutory monies and to manage donors' information responsibly.
We will comply with the Charity Commission and UK law in every respect, including those regarding openness and honesty with our supporters and members of the public.
As members of the Fundraising Regulator's scheme we follow its Fundraising Promise, which helps to ensure that organisations raising money for charity from the public do so honestly and properly.
We will respect the privacy and contact preferences of all donors. We will respond promptly to requests to cease contacts or complaints and act as best we can to address their causes.
We abide by the law which requires us, in deciding whether to accept or refuse a donation, to consider which action is in the charity's best overall interest.
We will not, however, accept donations made by donors whose activities appear to be in direct conflict with the best interests of our service users.
We will not undertake business with companies or individuals who participate in activities which could cause detriment to the charity's reputation; which will disproportionately decrease the amount of donations to further the work of the charity, or go against the charities values.
The responsibility of the judgement on whether Mental Health Innovations should refuse a donation lies first with the Director of Income, the Executive Board and ultimately the Board of Trustees.
This policy recognises our legal requirements as a charity to maximise our income in line with our mission to use data driven analysis, clinical expertise and technological innovation to develop and sustain pioneering digital products and services that meet underserved needs and that improve the mental health of the UK population, whilst ensuring that our activities and behaviour comply with the law. This policy applies to funding for Mental Health Innovations (MHI).
MHI acknowledges that the generosity of our donors and partners enables us to carry out our charitable activities. While our aim is to maximise our income we recognise that on very rare occasions we may consider refusing a donation or other involvement with a sponsor or a particular activity. In such an instance we will act with the utmost integrity. We will respect any matters of legitimate confidentiality and, in conducting all discussions and conveying the decision, will aim to respect the dignity of the prospective donor.
We comply with and support the Fundraising Regulator’s Promise to be legal, open, honest and respectful. We uphold their vision of a world where fundraising is ethical and giving is sustainable; where donors and fundraisers have respect for each other.
This policy outlines the responsibilities of MHI fundraising. This policy applies to all employees and board members, regardless of location, grade/position, hours of work and type of contract, e.g. permanent, temporary or fixed-term.
This policy is aligned to our values which are an integral part of our fundraising.
This policy is due for review annually or following any relative legislative changes, whichever comes first.
The policy will be reviewed by the Director of Income. The final draft of the policy will then go to the Chief Executive Officer for approval.
This policy covers the following topics:
- MHI context
- MHI policy focus
- MHI supporters
- Process for receipt of gifts or other benefits for MHI staff
- Levels of authority
- Policy implementation
1.1. Mental Health Innovations seeks to improve mental health via digital mental health services, and our approach to raising funds is determined by this. The law allows for situations where a donation may be refused where we can demonstrate objective reasons to show that the acceptance of the donation would not be in our best interests. In all cases we will ensure we comply with the law and regulations of the Charity Commission, the Fundraising Regulator and other relevant regulatory bodies with powers instituted by statute.
1.2. All decisions on acceptance and refusal of donations or sale of donated items must be grounded in MHI’s vision, purpose, values and operational policies. Any decision should not be affected by personal, political, religious or commercial interests, or by personal views on political, religious or ethical issues that are not directly related to our work
1.3. In the instance that accepting a donation would be perceived to be clearly unlawful (e.g. the gift comprises the proceeds of crime), we would also refuse to receive this type of gift.
1.4. MHI will give due consideration to all potential fundraising activities before engaging in financial relationships with individuals or organisations.
1.5. MHI will conduct all fundraising activity lawfully and with due respect for individuals and companies that we may contact, with whom we develop relationships or partnerships, both past and present.
1.6. Any decision to refuse a donation or engage in a fundraising activity will be taken on a case by case basis, guided and limited by the provisions of this policy.
1.7. Our approach will be based on the following influencing factors:
- fit with MHI’s vision, mission or strategic plan
- fit with our income strategy
- fit with MHI’s policies or protocols
- any impact on our charitable status
- any impact on our reputation
- minimising risk of loss of significant donations from other sources
- existing contractual obligations
1.8. MHI will not pursue fundraising support or philanthropic relationships with companies which do not fit with this policy and the approach in 1.7 above. However, MHI may work with these companies to provide crisis support through the Shout service, or other future services of the charity, to their end customers. In providing this service to end customers, MHI may receive payment for Shout and MHI commissioned services.
1.9. MHI will accept anonymous gifts - whereby the identity of the donor is genuinely unknown – whilst retaining the right to return the gift if subsequent identification reveals the contravention of this policy. MHI will discuss with known supporters the acceptance of anonymous gifts. However, the decision to donate anonymously will not exempt the supporter from compliance with this policy.
1.10 MHI will be vigilant in identifying and avoiding cases of Tainted Charity Donations, whereby a prospective donor seeks to gain access to tax benefits, only for the capital or a benefit from the donation to end up back in the hands of the donor. The charity will endeavour to identify these cases and not accept these gifts. Tainted Charity Donations have been defined in Appendix 3.
1.11. We recognise that supporters are entitled to know how MHI spends the money they give. Therefore, an annual statement of accounts will be published, and in addition, all reasonable requests for information on expenditure will be welcomed and details supplied.
1.12. Our registration with the Fundraising Regulator in July 2019 means we are committed to best practice in Fundraising and adhere to the principles as set out in their Code of Fundraising Practice.
1.13. Where it is deemed not to be in the best interests of MHI to accept or keep a donation, we may seek advice or authority from the Charity Commission.
MHI respects the rights of its supporters to clear, truthful information on the work of MHI; to openly report how we spend donations and to manage donors' information responsibly and in line with The General Data Protection Regulation.
We will comply with the Charity Commission and UK law in every respect, including those regarding openness and honesty with our supporters and members of the public
As members of the Fundraising Regulators scheme, we follow its Fundraising Promise.
In line with the Fundraising Regulators code of fundraising practices consider the needs to any possible donors who may be in vulnerable circumstances or may need extra care and information to make an informed decisions.
MHI corporate partnerships provide much needed support to achieving our charitable aims and objectives. In additional to the refusal criteria the following criteria provide a route by which the Director of Income and Head of Corporate Services can review and assess donations:
MHI does not directly endorse products or services. Where a product or service is promoted by MHI in connection with a third party, the nature of the relationship is made clear. MHI will make it clear that is does not seek to recommend that service or that third party above that of another.
MHI will only enter into corporate partnerships where the company adheres to the Modern Day Slavery Statement
To ensure that all cause-related promotions reflect MHI values, any such initiatives will be reviewed by the Director of Income for final decision.
Receipt of gifts or other benefits for MHI staff
2.1 No member of MHI staff will benefit individually or collectively from donations, loans or other material support given to the charity.
Levels of authority
2.2 Any decision to refuse very significant or very high profile relationships – such as a significant Charity of the Year, or a potential donation in excess of £1,000,000 a year – will be the responsibility of the Board of Trustees. All other decisions to refuse a donation or a corporate relationship will lie with the Senior Management Team with final responsibility residing with the Chief Executive Officer.
2.3 Anonymous donations with a value over £25,000 should be reported to the Charity Commission as a serious incident (this does not apply in Scotland or Northern Ireland).
3.1. Forms and templates that form the toolkit for this policy. Appendices included.
- Appendix 1: Policy Implementation
- Appendix 2: Fundraising Incident Reporting Form
- Appendix 3: Tainted Charity Donations
4.1. Policies to be read in conjunction with this one, related documents or links to other useful material:
- MHI Anti Fraud, Bribery and Corruption Policy
- MHI Anti-Money Laundering and Counter Terrorism Policy
- MHI Conflict of Interest Policy
- MHI Whistleblowing Policy
- MHI Data Classification Policy
- MHI Safeguarding Policy
- Charity Commission: Compliance Toolkit (2011)
- Charity Commission: Charities and Fundraising CC20 (2016)
- Fundraising Regulator: The Fundraising Promise
- Data Protection Act 1998
- The General Data Protection Regulation
- The Charities Act 1992
- The Charities Act 2011
- Charities (Protection and Social Investment) Act 2016
- Freedom of information Act 2000
- The Bribery Act 2010
- The Finance Act 2011
- Proceeds of Crime Act 2002
- Terrorism Act 2000
- The Charities and Trustee Investment (Scotland) Act 2005
- The Charities Act (NI)
Appendix 1: Policy implementation
The policy will be incorporated into the induction programme for all MHI employees.
1.2 Responsibility for implementation
It will be the responsibility of the Director of Income to ensure compliance with the policy through recording of case incidents wherever relevant and escalating to the CEO as required by the policy.
The Funding Policy will be reviewed on an annual basis, initiated by the Director of Income at an appropriate meeting with the CEO. The review will consider all case histories recorded over the previous twelve months in reflecting the aims of MHI.
Appendix 2: Fundraising Incident Reporting Form
Please see below content of information to be captured to enable reporting incidents.
Date that incident occurred:
- Date incident identified (if later)
- Date CEO notified
- Date Board of Trustees notified
- Name of person reporting incident
- Phone number of person reporting incident
- Incident type: (highlight the incident type below)
- Conflict with MHI vision, mission or business plan
- Conflict with Income Strategy
- Conflict with MHI policies or protocols
- Threat to charitable status
- Threat to MHI reputation
- Risk of loss of significant donations from other sources
- Breach of existing contractual obligations
- Other (please name)
1.2 Description of the incident (include policies, legislation and/or functions affected):
1.3 Have any steps been taken to contain or reduce the impact of the incident? If yes, please
- CEO decision
- Board of Trustees decision
- Date resolved
- Incident Reference Number: (please refer to incident log for sequential number)
Appendix 3: Tainted Charity Donations
3.1 The Tainted Charity Donations rules are based on a purpose test which considers the effects of, and circumstances in which the donor or someone connected to the donor, entered into arrangements to make the donation, and whether those arrangements are deemed to obtain a financial advantage.
3.2 Three conditions, A, B and C must be met for a donation to be a tainted charity donation. Where all three conditions are satisfied, the donor loses any tax relief that they would have been entitled to claim, had the donation not been tainted.
An additional charge to tax may also arise where the donation would have been eligible for relief under the Gift Aid Scheme (for individual donors only).
The three conditions which must be met for a donation to be tainted are:
- Condition A - the donation to the charity and arrangements entered into by the donor are connected.
- Condition B - the main purpose of entering into the arrangements is for the donor, or someone connected to the donor, to receive a financial advantage directly or indirectly from the charity.
- Condition C - the donation isn’t made by a qualifying charity-owned company or relevant housing provider linked with the charity to which the donation is made.
All three conditions must be met for the new rule to apply.