Ethical Donations Acceptance Policy

Author:
Alok Bhatia

Policy Statement

ServePlanet is a non-profit, charitable organisation which welcome donations to fulfil its mission to protect and conserve the marine ecosystem and bring an end to the marine litter and plastic pollution through collaborations by sharing our values and vision for clean, healthy water bodies and finding sustainable solutions including scientific and technological innovation to reduce marine litter and plastic pollution and to eradicate poverty in UK, Europe, Asia and Africa by providing food, grants, education, training, healthcare and all the necessary support designed to enable individuals to generate a sustainable income, be self-sufficient and/or to integrate in society.

This policy sets out the criteria and approval process for ServePlanet to be able to accept a donation from an individual, company, foundation or any other source to ensure that we are not compromising our mission or values. By implementing this policy we have a robust, transparent and informed decision making process for all donations, which will mitigate the risk to our programming, staff, reputation, financial position or brand.

This policy is reviewed every three years by ServePlanet's Board of Trustees.

Background

We are committed to raising income to fund ServePlanet's projects finding long-term solutions for protection and conservation of environment and eradication of poverty. Donations from individuals, companies, foundations and other funders are vital to our organisation. It is therefore important to have robust and transparent decision-making process in accepting donations, to assess the potential risk and impact a donation may have. Any donation or engagement with a potential funder should be considered carefully and in line with ServePlanet's objectives and a robust due diligence process.

Minimum engagement

A donation is defined as:

• Cash (including legacies and sponsorship)

• Gift in kind / pro bono support

• Shares, investments or any other type of asset

Donations may be unrestricted or restricted (for example to a particular activity, project or research funding).

ServePlanet should never accept a donation or enter into a partnership that will result in:

• Anticipated negative impact on our organisational mission (from household to community to national and global levels)

• Unacceptable risk to ServePlanet's brand and/or reputation.

• Unacceptable financial risk.

• Unacceptable risk of low returns on investment of ServePlanet's time, energy, and resources.

• A breach of our ethics statement.

In any relationship, ServePlanet's independence must be protected, retaining the right to disagree and openly challenge partners and funders with whom we engage. Where the relationships are formally documented or contracted, the Memorandum of Understanding/contract should contain a clause to this effect.

Sectors that ServePlanet will not engage with

No engagement can be undertaken with companies and funders directly engaged in:

• Pornography.
• Arms or weapons manufacturing.
• Intentional use of exploitative child labour or forced labour in production or sourcing processes.
• Selling pesticides outside the WHO 1A and 1B guidelines for pesticide retailing.
• Manufacture and/or aggressive marketing or promotion of plastic products.

The sectors listed above will be reviewed by the Board of Trustees every 3 years with the purpose of assessing whether other sectors need to be added or whether very specific engagement criteria will enable ServePlanet to have a significant enough impact on harmful practices or impacts of the sector to balance any reputational risk.

Each new potential partner will be considered on a case by case basis and will only be granted sign off on approval from the Board of Trustees.

Assessing the risk and value of a donation

To understand and assess the potential risk associated with a donation or donor partnership, as a minimum, ServePlanet will conduct research via a risk assessment for an individual or due diligence for an organisation. The research will remain private and confidential.

ServePlanet adheres to the the "know your" principle as laid down in Compliance Toolkit: Protecting Charities from harm, Chapter 2: Due diligence, monitoring and verifying the end use of charitable funds, which complements and is in line with internationally recognised standards set out in Financial Action Task Force Special Recommendation VIII (FATF SR VIII): "charities should make best efforts to confirm the identity, credentials and good standing of their beneficiaries and associates undertake best efforts to document the identity of their significant donors

ServePlanet has developed standard due diligence process to ensure that we continually improve the way we assess appropriately the risks for each type of donor. For individuals, ServePlanet will only perform due diligence for donations above £25,000. ServePlanet will therefore hold the required information on donor organisations and individuals solely for this purpose for the duration that we work with them and 6 years after this period. See ServePlanet's Privacy Policy.

Common across each type of donor process is the research will cover the following so that an appropriate, informed decision can be made whether to proceed with engagement.

• Company, Funder or Individual's activities and alleged practices that may reflect poorly on ServePlanet or be counter to our mission of eradicating poverty and environment conservation and/or our agreed policy positions.
• The potential risk to ServePlanet's image and reputation with the public, our respective donors, and/or existing partners from negative publicity about the company or allegations of harmful business practices.
• An unacceptable risk of low returns on investment of ServePlanet's time, energy, and resources.

The research/due diligence includes the origin or source of funds, looking behind the organisation to the ownership of that organisation and how the funds have been generated, and establish that all taxes have been paid and there is no connection with proscribed organisations, groups or individuals. See ServePlanet's Anti Money Laundering Policy.

Following the research or due diligence, ServePlanet will discuss areas of concern with the company, funder or individual. This enables assessment of their openness to ServePlanet's ethics statement and establishes the groundwork for a strong, transparent engagement. This conversation will remain private and confidential until a decision is made on whether or not to proceed with the engagement.

Single or a series of anonymous donations in the strictest sense of £50,000 or above will be reported to the National Crime Agency (NCA) for review through their "Suspicious Activity Report" online service. If the funds are cleared by the NCA they will be regarded as acceptable. If the value of the anonymous donation is above £25,000 this will also be reported to the Charity Commission.

Timing of research

A risk assessment or due diligence is conducted at the outset of the development of the partnership with the company, funder or individual.

The research will be reviewed and refreshed on an annual basis, or in the event of a significant negative publicity incident.

Roles and responsibilities

The relevant team will complete the research. Potential donations which are deemed to be risky or which result in a red or amber rating through the due diligence process will be referred to the Board of Trustees in the first instance to enable immediate action. If there is a financial risk involved, the financial team will be consulted. For organisations, any high risk engagement will be referred to the Board of Trustees who will decide on whether the proposed engagement needs to be referred to the Ethics and Risk Committee. Decisions will be made within 3 working days for individuals and up to 10 working days for organisations.

Donation Refusal

Donations and/or gifts may be legitimately refused in certain circumstances but this must not be influenced by any personal viewpoints of the Trustees. ServePlanet will not accept gifts in cases where to do so would, considering all risks:

• Compromise ServePlanet's status as a charitable organisation
• Limit freedom of enquiry
• Create unacceptable conflicts of interest
• Cause material damage to ServePlanet's reputation (including deterring significant numbers of other donors or supporters)
• Cause financial loss to ServePlanet
• Cause damage to ServePlanet
• Be directly in opposition to ServePlanet's mission, objectives and publicly stated vision and values.

A decision to return a gift shall always be a matter for the Trustees to review having taken proper legal advice as necessary.

ServePlanet will not normally return a gift which has been accepted in good faith in compliance with this policy and the law.

Termination

If a partnership or prospect is going to be refused or terminated, then the appropriate team will let the company, funder or individual know as soon as possible, with a short explanation.

Complaints Review

ServePlanet will respond promptly to a complaint by a donor or prospective donor about any matter within this policy. A designated member will attempt to resolve the concerns in the first instance. A complainant who remains unhappy may request in writing a review of their complaint by the Trustees and will be advised of the outcome in writing.

ServePlanet currently accepts donations only through its bank account details of which are mentioned below:

Account No. : 96470140

Sort Code: 60-83-71

IBAN: GB79SRLG60837196470140

SWIFT/BIC: SRLGGB2L

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