Date: 27 July 2022
1. Introduction
Financial support from individuals and organisations is essential to deliver the aims of Anthony Nolan, leading to better treatment and support for people with blood cancer and blood disorders. 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 Anthony Nolan, compromise its independence, or threaten its reputation.
2. Policy statement
The Board of Trustees (Board) of Anthony Nolan 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 appropriate and proportionate due diligence and risk assessment related to acceptance of gifts. This policy outlines how Anthony Nolan undertakes these responsibilities, ensuring due diligence is undertaken for relevant support and potential partnerships.
The policy outlines Anthony Nolan’s ethical approach to philanthropic funding and partnerships and aims to make our approach transparent. Whilst the vast majority of support is extremely welcome, there may instances where the reputation and operation of the charity needs to be protected from claims of impropriety. Key areas are outlined in section 4 below, but are not exhaustive.
This policy relates to philanthropic support, and partnerships with, individuals, charities, and companies. The UK Government and its agencies, including research funding councils, are not covered by this policy.
Risks of accepting specific support include but are not limited to:
- reduction in support from others
- decline in volunteer numbers or applications to join as employees
- negative reaction from current employees
- negative media reports
- conditions that put Anthony Nolan’s independence at risk
This policy outlines how we might review potential support, and clarifies how we would work with companies from certain industries.
3. Relevant external bodies and advice
This policy is informed by the following external advice:
- Charity Commission:
Charities: due diligence, monitoring and verifying the end use of charitable funds (Compliance toolkit, Chapter 2)
- Chartered Institute of Fundraising:
Guidance on accepting, refusing, and returning donations
https://ciof.org.uk/events-and-training/resources/acceptance,-refusal-and-return-a-practical-guide-t
Any updates to this advice will be taken into account when reviewing this policy.
4. Details of the policy
Tobacco Industry
Anthony Nolan will not enter into a partnership with a tobacco company.
This does not automatically exclude support from individuals working within the tobacco industry from making personal gifts, including potential match giving from their employers.
We reference the joint protocol between Cancer Research UK and Universities UK which defines a tobacco company as:
"Tobacco Company" means a company, entity or organisation (or groups or combinations of the same) whose business other than for an insignificant part (less than 10% of its revenue), is the development, production, promotion, marketing, or sale of tobacco in any country of the world, or is a subsidiary or a holding company or affiliate of the same.
Pharmaceutical Industry
Anthony Nolan will accept support from pharmaceutical companies, or other companies involved in medical research, diagnostics, or treatment, as long as there is no risk to the charity’s independence. Non-commercial work with pharmaceutical companies is reported in our Annual Report.
More detail is available in the “Working with Pharmaceutical Companies” policy.
Other factors
Anthony Nolan will also consider other areas such as:
- Evidence of exploitative practices
- Excessive fossil fuel dependency
- Supply of arms and ammunition
- Pay day and high interest loans
This list is not exhaustive.
Fundraising and vulnerable people
Anthony Nolan has a full policy relating to fundraising and vulnerable people. Employees, volunteers, and partners follow this policy to ensure that vulnerable individuals are identified and communicated with appropriately.
Anonymous donations
In line with guidance from the Charity Commission, donations over £25,000 where Anthony Nolan cannot identify the donor are reported to the Charity Commission as a Serious Incident. The Charity Commission is clear, however, that charities are free to accept anonymous donations where there are no suspicious circumstances.
Anthony Nolan follows the principle of “know your donor” to ensure that support is not received that may be linked to, or the proceeds of, criminal activity, in line with our Anti-Money Laundering Policy.
Restricted donations
Anthony Nolan is happy to restrict funding to specific areas of work, and will account for income and expenditure recognising restricted funds. We may, however, refuse donations with restrictions that cannot be met, but will always seek to communicate with the donor, or the executors in the case of a legacy, taking advice from the Charity Commission if appropriate.
Equality Act 2010
Anthony Nolan may accept donations that limit benefits to people who share a protected characteristic under the Act, although this may exclude people with other protected characteristics. In keeping with the Act, Anthony Nolan will ensure that such cases will:
- Tackle disadvantage where it exists (for example. recruiting potential donors from specific ethnic backgrounds to increase the chance of a positive match for patients), and/or
- Achieve a legitimate aim in a proportionate way
To be clear, such donations would support planned charitable activity in keeping with our overall aims and strategy.
Gifts from employees, volunteers, and related individuals or organisations
Anthony Nolan welcomes and values support from these individuals and groups, but this does not confer on the donor any benefit or preferment beyond the usual recognition and stewardship offered to donors.
Commercial Partnerships
Commercial partnerships are an important way for companies to support the communities within which they operate, as well as involve employees and customers in charitable activity.
Certain partnerships with companies (for example. cause related marketing agreements) will also refer to the Anthony Nolan Modern Slavery Act policy, ensuring that they also comply with the Act. This is addressed during the contract management process before any agreement is signed.
Particular care will be taken to review the benefits and risks to all parties before entering a commercial partnership.
Money Laundering
Any evidence of money laundering is considered through due diligence, in line with the Know Your Donor guidelines from the Charity Commission, and Anthony Nolan’s Anti-Money Laundering Policy.
Charities are increasingly targets for money laundering, and we will question unusual donor requests (such as returning gifts via a different method to which they were received) as suggested within the Charity Commission advice.
As necessary, Anthony Nolan will also have regard to Proscribed Organisations and Financial Sanctions Targets as defined by the UK Government and listed here:
https://www.gov.uk/government/publications/proscribed-terror-groups-or-organisations--2
https://www.gov.uk/government/publications/financial-sanctions-consolidated-list-of-targets
Illegal Activity
Anthony Nolan will not accept support that is the result of illegal activity on the part of the donor.
In assessing this risk, in line with our Privacy Policy, only information from reputable public sources, such as national newspapers or government websites, is taken into account.
Returning Gifts
Anthony Nolan will not normally return a gift which has been accepted in good faith and in compliance with this policy. Exceptionally, subsequent events or the subsequent availability of additional information may give rise to the need to review a previous decision to accept a gift. (This concerns gifts outside the scope of the Fundraising and Vulnerable People policy).
The fundraiser responsible for the supporter relationship will review in the first instance and raise with Head of Team and the Director of Fundraising to make initial decision and escalate as necessary.
5. Roles and responsibilities
Day to day implementation of this policy is delegated to the Director of Fundraising and Chief Engagement & Marketing Officer who will assess whether potential major financial support, or a partnership requiring significant marketing or public relations efforts, should be reviewed by the Strategic Leadership Team or the Board before being accepted.
Individual fundraisers and Heads of fundraising teams are responsible for bringing relevant potential support to their attention using Anthony Nolan’s Due Diligence guidance.
6. Procedures for following the policy
The Director of Fundraising and Chief Engagement & Marketing Officer are routinely made aware of major donations or potential partnerships. They assess whether there is need for further discussion at Strategic Leadership level before potential sign off by the Board of Trustees. Information is provided using the Anthony Nolan Due Diligence Guidance and Template to ensure consistency of approach.
Likewise, the Strategic Leadership Team and Board are routinely made aware of major donations or partnerships.
- Fundraisers undertake ‘know your donor’ due diligence on new supporters or partnerships, escalating via Heads of teams if information is unclear or if there are concerns
- In particular, the Risk Monitoring section of the Due Diligence Research Template is completed
- Research information is securely stored on the Anthony Nolan Customer Relationship Management (CRM) system in line with our Privacy Policy (see Appendix A)
- In the case of concerns, a briefing will be produced, including the completed due diligence research form, and shared for discussion with the Director of Fundraising in the first instance, followed by the Chief Engagement & Marketing Officer
- Decisions to go ahead or decline support are recorded on the CRM system (see Appendix A)
- Senior Management and the Board are notified of decisions to decline support, with reasons via Chief Engagement & Marketing Officer