QUEEN’S UNIVERSITY BELFAST

Policy for Acceptance/Refusal of Gifts, Endowments and Legacies

Updated: 17 February 2021

1.         Introduction

The University’s preferred vehicle for receiving all philanthropic gifts is The Queen’s University of Belfast Foundation. The Foundation is an independent charity, established to receive and steward philanthropic donations on behalf of Queen’s University Belfast.  The Foundation Board members are charity trustees and are ultimately responsible for the charity. 

For operational purposes, the responsibility for approving the decision to accept a gift has been delegated by the trustees to the Director of Alumni Engagement and Philanthropy.

2.         Policy

2.1       This policy adheres to ethical practices as documented by the Institute of Fundraising and the Council for the Advancement and Support of Education (CASE).

2.2       The Alumni Engagement and Philanthropy Office on behalf of the Queen’s Foundation co-ordinates the University’s efforts to seek philanthropic support and will routinely receive gifts on behalf of the University.  No specific request for a philanthropic donation should be made without the prior approval of the Director of Alumni Engagement and Philanthropy.

Philanthropic donations offered to any staff member should be referred to the Alumni Engagement and Philanthropy Office.  Contact Jacqui McCormick, Donor Relations Officer, on 028 9097 5378 or email j.w.mccormick@qub.ac.uk.

Philanthropic gifts will normally be accepted by the Alumni Engagement and Philanthropy Office if they are (i) given without conditions in support of an existing fundraising project or programme and (ii) received from donors known to the Foundation or the Alumni Engagement and Philanthropy Office. 

In cases of doubt or where the donation exceeds a value of £1m the decision to accept or refuse will be escalated to the Vice-Chancellor and Registrar and Chief Operating Officer who may consult with the Chair of Senate before reaching a final decision.

2.3       All members of the University involved in fundraising should consult the Alumni Engagement and Philanthropy Office at an early stage in discussions with a potential benefactor.  In this way, the Office can advise on the use of these guidelines.  Consultation will also reduce the risk of uncoordinated approaches to a single potential donor, ensure familiarity with the process for accepting benefactions, and may provide an early warning of anyone unknowingly approaching a potential benefactor whose donation is unlikely to be acceptable.

2.4       In considering the acceptance of any gift, endowment or legacy, the Director of Alumni Engagement and Philanthropy will ascertain:

 (i)            That the purposes of the gift are compatible with the purposes of the University;

(ii)           That the gift is consistent with the University’s strategic mission, and with the goals outlined in the Institutional Strategy and the Corporate Plan;

(iii)          If the acceptance of the gift would create additional costs or burdens for the University;

(iv)          If there is published or other credible evidence that the proposed gift will be made from a source that arises in whole, or in part, from an activity that:

• Evaded taxation or involved fraud;
• Violated international conventions that bear on human rights;
• Limited freedom of enquiry, or encroached on academic freedom;
• Suppressed or falsified academic research.

(v)        If evidence exists that the proposed gift, or any of its terms, will:

• Require action that is illegal;
• Seriously damage the reputation of Queen’s;
• Create unacceptable conflicts of interest.

(vi)       If evidence exists that acceptance of the gift or compliance with any of its terms will damage the University’s reputation including deterring other benefactors.

2.5       Donations will be accepted on the clear understanding that the funder can have no influence over the academic freedom and independence of Queen’s University Belfast.  This principle covers decisions relating to student admissions, supervision and examinations and, where relevant, the conduct of research and publication of results.

2.6       All donations to the University, from whatever source, must be accounted for in accordance with the relevant accounting standard – Statement of Recommended Practice (SORP): New Charities SORP (FRS 102).  Regardless of where in the University donations are received, the Alumni Engagement and Philanthropy Office should be advised. 

2.7       If the University is approached by a donor unknown to staff, the Alumni Engagement and Philanthropy Office will undertake an additional screening procedure, over and above the due diligence outlined above (2.4).  This will include contacting Companies House and extensive online/background searches.  Registered charities are excluded from this procedure.*

            * Additional Note on acceptance of gifts from charitable entities: Where gifts are received from a Foundation or other charitable entity, the University will take all reasonable steps to ensure that the funding sources for that charity are consistent with this Gift Policy.  Where charities send audited accounts, and have full and current approved status with a recognised national regulatory body for charities, further due diligence on the sources of funding of those charities will not typically be undertaken, unless there are reasons to believe that reputational risk may be involved.  Those reasons may include, for example, any current or recent investigation into the activities of the Charity by the relevant regulatory body.  At the time of approval of this policy, such recognised regulatory bodies include:

• The Charity Commission for England and Wales
• The Office of the Scottish Charity Regulator
• The Charity Commission for Northern Ireland
• The Inland Revenue Service in the US through its 501(C) 3 regulations for tax-exempt non-profit corporation or associations
• The Canada Revenue Agency 

This list will be updated on a regular basis as similarly transparent regulatory bodies are created in other countries.  For all other charities due diligence will be undertaken, including requests where appropriate for audited accounts confirming the identity of donors to the charity, and this information will be included in reports and material collated for due diligence procedures (2.7 above).

3.         University Commitment

The University undertakes that:

(i)            All communications made to potential donors concerning a project will be honest, truthful, and comply with the law;

(ii)           The donor’s right to privacy will be respected;

(iii)          The gift will be applied for the purpose for which it was originally requested, unless explicit consent is given otherwise by the donor or, in the case of bequests, for the purposes described in the donor’s will or for similar purposes agreed with the donor’s executors;

(iv)         The gift will be handled responsibly and to the greatest advantage of the beneficiary;

(v)          The donor’s personal data will be respected, and there will be transparency in Queen’s communications with its donors;

(vi)         Any concerns raised in relation to the above points will be dealt with swiftly and effectively by the Alumni Engagement and Philanthropy Office.

The Donor Promise has been created to assure all donors and prospective donors of the integrity and accountability of the Development Programme at Queen’s University Belfast in full compliance with the General Data Protection Regulation 2018. (Annex A)

4.         Gifts in Kind

            Gifts of art works, silver etc can be accepted but these must also comply with the Acquisition of Art Works Policy approved by Senate.  Similarly, gifts of book collections etc may be accepted where these comply with the approved Library Collection Development Policy. 

5.         Related Policies

This Policy only relates to gifts, endowments and legacies received by the University and not those received personally by members of staff. 

The Policy should be read in conjunction with the following University policies and procedures:

• Code of Conduct;
• Policy on the Acceptance of Gifts, Gratuities and Hospitality;
• Register of Interests Policy;
• Bribery Policy.

The Bribery Policy, developed in response to the Bribery Act, enacted on 1 July 2011, is of particular relevance.  This requires the University to ensure, through due diligence and risk controls, that the receipt of a gift is not in relation to some inappropriate advantage that might be afforded to the donor.

6.         Further Information

Further information on the implementation of this Policy is available from the Alumni Engagement and Philanthropy Office on request. Contact Jacqui McCormick, Donor Relations Officer, on 028 9097 5378 or email j.w.mccormick@qub.ac.uk .

Approved by Standing Committee 7 June 2018

Annex A

Queen’s University Belfast

Our donor promise

Our work would not be possible without your support.  Your philanthropic gifts play a vital role in enabling us to transform the campus and enrich the student experience.

Your generosity has helped support pioneering research and has allowed us to address many global challenges.  Furthermore without your donations, students from disadvantaged backgrounds might never get the opportunity to realise their potential by gaining a world-class degree.

In return we want your experience of giving to The Queen’s University of Belfast Foundation to be a positive one.  Below is our promise to you.

You will:

• Be treated by all Queen’s staff and volunteers involved with the solicitation and receipt of donations in a fair, transparent, accurate and honest manner in accordance with all applicable laws and the professional code of fundraising ethics and good practice.
• Be informed whether those seeking donations are volunteers or employees of the University.
• Be informed of the identity of those serving on the Board of The Queen’s University of Belfast Foundation. Have access to the University’s most recent published financial accounts.
• Be informed of the way we intend to use donations and of our commitment to ensure they are used for the intended purpose.
• Be consulted if your donation cannot be used for its intended purpose and have it repaid if agreement cannot be reached within a short period of time for an alternative use.
• Be kept informed of the impact of your philanthropy and the University’s evolving needs and priorities.  You will receive progress reports and invitations to attend events to see at first-hand the impact of your support.
• Receive appropriate and timely acknowledgement, recognition and publicity for your donation.  If requested, your anonymity will be respected.
• Be assured that your right to privacy will be respected and that there will be full compliance with the General Data Protection Regulation 2018.
• Be asked in writing for permission to be cited in case studies and other promotional material prior to publication.
• Be allowed to limit the number/type of solicitations if requested.
• Receive a response within 30 days to a complaint about any matter relating to the University’s fundraising activities.

We welcome support from individuals, charitable trusts and foundations and organisations, and would be pleased to discuss ways in which relationships may be fostered with potential benefactors.

For further information on any of the above please contact Jacqui McCormick, Donor Relations Officer, on 028 9097 5378 or email j.w.mccormick@qub.ac.uk .This promise will change as we listen to you, our donors.