1. Policy Statement
Al-Waris Foundation recognises that modest gifts and hospitality may sometimes arise naturally during charitable, professional, community or overseas activities.
However, gifts and hospitality must never:
- improperly influence a decision;
- create an obligation;
- compromise independence;
- reward favourable treatment;
- conceal bribery or corruption;
- create an unmanaged conflict of interest;
- damage public confidence in the charity.
Trustees, volunteers and other representatives must act in the best interests of Al-Waris Foundation when making decisions on its behalf.
2. Purpose
This policy establishes the charity's approach to:
- gifts received;
- gifts offered;
- hospitality;
- supplier gifts;
- contractor gifts;
- donor gifts;
- beneficiary gifts;
- overseas customs and hospitality;
- conflicts of interest;
- recording and approving gifts;
- prohibited gifts;
- suspected bribery.
3. Scope
This policy applies to:
- trustees;
- staff where applicable;
- volunteers;
- authorised representatives;
- project leads;
- fundraisers;
- consultants acting on behalf of the charity;
- overseas representatives.
It applies to gifts or hospitality offered because of a person's association with Al-Waris Foundation.
4. Core Principles
Any gift or hospitality connected with Al-Waris Foundation should be:
- lawful;
- reasonable;
- proportionate;
- transparent;
- infrequent;
- incapable of improperly influencing a decision.
The appearance of impropriety should be considered as well as actual impropriety.
5. Definition of a Gift
For this policy, a gift may include:
- goods;
- vouchers;
- discounts;
- free services;
- personal benefits;
- tickets;
- accommodation;
- travel;
- meals;
- promotional items;
- other things of value.
Ordinary charitable assistance received as a beneficiary is not treated as a gift under this policy.
6. Definition of Hospitality
Hospitality may include:
- meals;
- refreshments;
- event invitations;
- entertainment;
- accommodation;
- travel;
- conference attendance;
- other hosted activities.
Reasonable refreshments provided during an ordinary meeting will not normally require formal treatment as significant hospitality.
7. General Rule
A gift or hospitality may be accepted where it is:
- modest;
- reasonable;
- lawful;
- connected with a legitimate relationship or activity;
- unlikely to influence the recipient.
Where there is doubt, the gift or hospitality should be declared before acceptance where practicable.
8. Prohibited Gifts
A gift must not be accepted where it:
- is intended to influence a charity decision;
- is offered in exchange for favourable treatment;
- is linked to awarding a contract or grant;
- is cash or a cash equivalent offered personally in suspicious circumstances;
- would create an improper obligation;
- would breach applicable law;
- could reasonably be regarded as a bribe.
9. Cash Gifts to Individuals
Cash offered personally to a trustee, volunteer or representative because of their charity role should normally be declined.
Where the person genuinely intends to donate to Al-Waris Foundation, they should be directed to an authorised charity donation method.
Charity donations must not be treated as personal gifts.
10. Cash Equivalents
Particular caution should be exercised with:
- gift cards;
- vouchers;
- prepaid cards;
- cryptocurrency;
- transferable credits;
- other readily convertible benefits.
Material cash-equivalent gifts should normally be declined unless there is a clear legitimate reason and appropriate approval.
11. Low-Value Promotional Items
Low-value promotional items may normally be accepted.
Examples include:
- pens;
- notebooks;
- calendars;
- inexpensive branded merchandise.
They do not normally require formal declaration unless circumstances create a conflict or concern.
12. Indicative Declaration Threshold
As an internal governance control, a gift or hospitality with an estimated value of £50 or more should normally be declared and recorded.
Multiple smaller gifts from the same source should be considered collectively where they appear connected.
The £50 figure is an internal control threshold and does not mean that anything below £50 is automatically acceptable.
13. Gifts Above the Threshold
A gift worth £50 or more should not normally be personally retained without appropriate approval.
Possible outcomes include:
- declining it;
- returning it;
- accepting it on behalf of the charity;
- using it for charity purposes;
- sharing it appropriately;
- donating it;
- allowing personal retention where justified and approved.
The decision should be recorded.
14. High-Value Gifts
High-value personal gifts connected with charity business should normally be declined.
Where refusal would create a serious cultural or diplomatic difficulty, the gift may be accepted temporarily on behalf of Al-Waris Foundation and referred for a decision about its appropriate use.
15. Gifts Register
Al-Waris Foundation should maintain a proportionate Gifts and Hospitality Register.
The register may record:
- date;
- recipient;
- donor/provider;
- description;
- estimated value;
- reason;
- whether accepted or declined;
- approval;
- final treatment.
16. Trustee Gifts
A trustee should declare material gifts or hospitality received because of their trustee position.
A trustee must not use their position to obtain inappropriate personal benefits.
17. Approval of Trustee Gifts
A trustee should not be the sole decision-maker regarding their own material gift.
Where approval is required, it should be considered by another unconflicted trustee or the Board as appropriate.
18. Supplier Gifts
Gifts from existing or prospective suppliers require particular caution.
A gift should normally be declined where:
- procurement is underway;
- a contract renewal is being considered;
- pricing is being negotiated;
- supplier performance is under review;
- the gift could reasonably influence a decision.
19. Contractor Gifts
Contractors must not be permitted to secure favourable treatment by providing personal benefits to people involved in:
- contractor selection;
- project approval;
- payment approval;
- quality inspection;
- performance assessment.
20. Procurement
No gift or hospitality may be accepted as consideration for:
- selecting a supplier;
- overlooking poor work;
- approving an inflated invoice;
- releasing payment;
- changing a specification;
- avoiding procurement controls.
See the Procurement and Purchasing Policy.
21. Discounts
A discount generally available to:
- the charity;
- charities generally;
- all customers;
- members of a recognised scheme;
will not normally constitute a personal gift.
A special personal discount offered to a decision-maker because of charity business may require declaration.
22. Supplier Samples
Legitimate product samples supplied for evaluation may be accepted where reasonably necessary.
Samples should not become an inappropriate personal benefit.
Material samples should normally remain charity property unless there is a reasonable documented reason otherwise.
23. Donor Gifts to Representatives
A donor may occasionally offer a small personal gift as an expression of appreciation.
A modest token may be accepted where:
- no favour is expected;
- no donor decision depends upon it;
- acceptance would not create an inappropriate obligation.
Material gifts should be declared.
24. Gifts From Beneficiaries
Beneficiaries may sometimes offer small gifts as an expression of gratitude.
Representatives should consider:
- the beneficiary's circumstances;
- value;
- cultural context;
- safeguarding;
- potential financial hardship.
A gift should be politely declined where accepting it could disadvantage the beneficiary or be inappropriate.
25. Gifts to Beneficiaries
Reasonable items provided to beneficiaries as part of legitimate charitable activity are not prohibited gifts.
They should be treated as charitable assistance or project expenditure and recorded appropriately.
26. Personal Gifts to Beneficiaries
Trustees, volunteers and representatives should exercise caution before personally giving money or significant gifts to individual beneficiaries outside an approved programme.
This can create:
- safeguarding issues;
- favouritism;
- dependency;
- confusion about the charity's role;
- unequal treatment.
Where assistance is needed, it should normally be considered through an authorised charitable process.
27. Hospitality Received
Reasonable hospitality may be accepted where it supports legitimate charity activity.
Examples may include:
- refreshments at meetings;
- reasonable meals during project discussions;
- attendance at relevant professional events;
- reasonable hospitality during overseas project visits.
28. Excessive Hospitality
Hospitality should be declined where it is:
- lavish;
- disproportionately expensive;
- primarily entertainment with little legitimate charity purpose;
- frequently offered by the same supplier;
- likely to influence a decision.
29. Meals
A reasonable meal provided during:
- meetings;
- project visits;
- conferences;
- overseas work;
may normally be accepted.
The context and value should be considered.
30. Events and Tickets
Free tickets or invitations to events may be accepted where attendance has a legitimate charity purpose.
Examples may include:
- networking;
- stakeholder engagement;
- training;
- representation of Al-Waris Foundation.
High-value entertainment unrelated to the charity's work should normally be declined.
31. Travel and Accommodation Offered by Third Parties
Third-party-funded travel or accommodation requires additional scrutiny.
Before accepting material travel or accommodation, consideration should be given to:
- purpose;
- value;
- provider;
- conflicts;
- independence;
- reputational risk.
Significant arrangements should normally receive prior approval.
32. Overseas Hospitality
Al-Waris Foundation recognises that hospitality customs vary between countries and communities.
Reasonable local hospitality may be accepted where refusing would be unnecessarily discourteous and acceptance creates no improper obligation.
Cultural custom does not justify bribery or corruption.
33. Overseas Gifts
In some cultures, refusing a gift may cause significant offence.
Where a material gift cannot reasonably be refused:
- accept it politely where lawful;
- explain where appropriate that charity rules apply;
- record the gift;
- refer it for an appropriate decision.
Acceptance in these circumstances does not automatically mean the individual may personally retain it.
34. Facilitation Payments
Facilitation payments are not permitted merely because they are customary locally.
No representative should make an unofficial payment to secure or accelerate a routine action unless there is an immediate and genuine threat to personal safety.
Any payment made under duress should be reported as soon as reasonably practicable.
35. Bribery
Al-Waris Foundation prohibits bribery.
No person acting for the charity may:
- offer;
- promise;
- give;
- request;
- agree to receive;
- accept;
a financial or other advantage intended to induce improper conduct.
See the Anti-Fraud, Bribery and Corruption Policy.
36. Gifts to Public Officials
Particular caution must be exercised regarding gifts or hospitality involving:
- government officials;
- police;
- customs officials;
- regulators;
- politicians;
- public-sector employees.
No gift may be used to obtain improper official treatment.
Professional advice should be obtained where necessary.
37. Political Gifts
Charity resources must not be used to provide personal gifts intended to:
- support a political party;
- secure political influence;
- reward political support.
Legitimate engagement with public officials on matters furthering the charity's purposes should remain distinct from political donations.
38. Religious and Community Leaders
Reasonable hospitality involving religious or community leaders may be appropriate where it supports legitimate charitable engagement.
Their position must not exempt the relationship from:
- conflict controls;
- bribery controls;
- safeguarding;
- financial accountability.
39. Fundraising Hospitality
Reasonable hospitality may be provided at fundraising or donor-engagement events where:
- expenditure is proportionate;
- the purpose is legitimate;
- charitable funds are used responsibly.
Fundraising expenditure should be appropriately recorded.
40. Hospitality Provided by the Charity
Al-Waris Foundation may provide reasonable hospitality for:
- meetings;
- volunteers;
- project partners;
- donors;
- professional advisers;
- community representatives;
- events.
The expenditure should have a legitimate charity purpose.
41. Alcohol
Al-Waris Foundation will not normally purchase or reimburse alcoholic drinks.
This applies to hospitality provided using charity funds unless the Board has expressly determined that exceptional circumstances justify otherwise and doing so is lawful and appropriate.
42. Personal Hospitality
Personal hospitality unrelated to Al-Waris Foundation must not be charged to the charity.
The fact that charity matters were briefly discussed during a personal social event does not automatically make the expenditure charitable.
43. Family Members
The charity should not routinely pay for hospitality provided to family members of trustees, volunteers or representatives unless their attendance serves a legitimate charity purpose.
Any such material expenditure should be appropriately justified.
44. Plus-Ones
Where an event invitation includes a guest or plus-one, the charity should consider whether accepting the additional benefit is appropriate.
A personal guest's costs should not automatically be borne by Al-Waris Foundation.
45. Conflicts of Interest
A gift or hospitality may create a conflict even where there is no intention to influence a decision.
Relevant interests must be declared and managed under the Conflict of Interest Policy.
46. Perceived Conflicts
The charity should consider how a reasonable external observer might view the arrangement.
A gift may be inappropriate even where the recipient believes personally that it would not influence them.
47. Repeated Gifts
Repeated low-value gifts from the same source may collectively become inappropriate.
Frequency should therefore be considered alongside individual value.
48. Timing
The timing of a gift can increase its significance.
Particular caution is required when a gift is offered:
- before a procurement decision;
- before a grant decision;
- before an invoice is approved;
- during a dispute;
- during contract renewal;
- following poor contractor performance.
49. Gifts During Tendering
People participating in a tender or competitive procurement process should normally decline gifts or hospitality from participating suppliers while the process is active.
50. Grant Recipients
Trustees or representatives involved in grant decisions should not accept material personal gifts from:
- applicants;
- prospective recipients;
- existing recipients;
where this could influence or appear to influence grant decisions.
51. Partner Organisations
Modest reciprocal hospitality between partner organisations may be legitimate.
However, partnership relationships must not be used to provide inappropriate private benefits.
52. Contractors Overseas
Overseas contractors must not be permitted to substitute gifts or hospitality for:
- proper quotations;
- project evidence;
- invoices;
- quality;
- warranties;
- contractual performance.
53. Project Inspections
A person inspecting a project should retain sufficient independence to report defects accurately.
Hospitality from a contractor must not influence:
- completion approval;
- quality assessment;
- evidence review;
- final payment.
54. Personal Commissions
No trustee, volunteer or representative may personally retain an undisclosed:
- commission;
- referral payment;
- rebate;
- cashback;
- supplier incentive;
arising from charity expenditure.
Any benefit properly belonging to the charity should be credited to Al-Waris Foundation.
55. Cashback and Rewards
Where charity expenditure generates:
- cashback;
- loyalty rewards;
- rebates;
- account credits;
the benefit should normally belong to the charity where reasonably practicable.
Incidental personal reward points generated through an individual's own payment method should be considered proportionately and must never influence purchasing decisions against the charity's interests.
56. Donations From Suppliers
A supplier or contractor may donate to Al-Waris Foundation.
A genuine donation does not automatically prevent the charity from doing business with the donor.
However:
- procurement decisions must remain independent;
- the donation must not purchase favourable treatment;
- conflicts should be considered;
- material arrangements should be transparent.
57. Conditional Donations
A donation must not be accepted where its condition effectively requires the charity to provide an improper private benefit or procurement advantage to the donor.
See the Fundraising Policy.
58. Gifts Intended for the Charity
Where a gift is clearly intended for Al-Waris Foundation rather than an individual, it should be treated as a charity asset or donation as appropriate.
It should be recorded according to its nature and value where material.
59. Donated Equipment
Equipment donated to the charity may need to be:
- recorded;
- inspected;
- added to the asset register;
- valued where appropriate;
- checked for suitability.
The charity is not obliged to accept unsuitable donated equipment.
60. Unwanted Gifts
Where a gift accepted by the charity is not useful, the charity may consider:
- returning it;
- donating it;
- using it as an authorised fundraising prize where lawful;
- disposing of it appropriately.
Any restrictions imposed by the donor must be considered.
61. Personal Use of Charity Gifts
A charity-owned gift or asset must not simply be taken for personal use without appropriate authority.
Low-value consumable items may be dealt with proportionately.
62. Recording Decisions
Material decisions should record enough information to demonstrate:
- what was offered;
- by whom;
- estimated value;
- context;
- decision;
- reason;
- approver where required.
63. Refusing a Gift
Where appropriate, a person may explain:
"Thank you, but Al-Waris Foundation's policy does not allow me to accept this personally."
No further justification is normally required.
64. Returning a Gift
Where a gift has already been received and later determined to be inappropriate, it may be returned with a polite explanation.
The return should be recorded where the gift was material.
65. Donation Instead
Where appropriate, a person wishing to show appreciation may be invited to make a donation directly to Al-Waris Foundation instead of providing a personal gift.
No pressure should be applied.
66. Safeguarding
Gifts and hospitality must never be used to:
- establish inappropriate relationships with beneficiaries;
- obtain private access to children or adults at risk;
- encourage secrecy;
- bypass safeguarding boundaries.
Suspicious gift-giving involving beneficiaries should be escalated.
67. Data Protection
The Gifts and Hospitality Register may contain personal information.
Records must be:
- relevant;
- accurate;
- appropriately secured;
- retained only as necessary.
See the Data Protection and UK GDPR Policy.
68. Confidentiality
Sensitive information about gifts, allegations or investigations should be shared only with people who reasonably need access.
Confidentiality must not be used to conceal misconduct.
69. Reporting Concerns
Anyone who suspects that a gift or hospitality represents:
- bribery;
- corruption;
- fraud;
- coercion;
- procurement manipulation;
- safeguarding misconduct;
should report the concern promptly through an appropriate route.
70. Whistleblowing
A person may use the Whistleblowing Policy where they reasonably believe serious wrongdoing has occurred.
Retaliation against someone for raising a genuine concern is not acceptable.
71. Investigation
Material suspected breaches may be investigated.
The investigation should be:
- proportionate;
- fair;
- appropriately documented;
- sufficiently independent.
Relevant evidence should be preserved.
72. Criminal Concerns
Where bribery, fraud, corruption or another criminal offence may have occurred, Al-Waris Foundation should consider:
- professional advice;
- law-enforcement reporting;
- regulatory reporting;
- preservation of evidence.
73. Serious Incidents
A significant bribery, corruption or governance incident may require consideration under the Serious Incident Reporting Policy.
The trustees should assess whether reporting to the Charity Commission or another authority is required.
74. Breaches
Breaches of this policy may result in:
- requirement to return a gift;
- repayment;
- removal from a procurement decision;
- restriction of financial authority;
- suspension of duties;
- volunteer management action;
- termination of contractual arrangements;
- governance action;
- investigation;
- regulatory or law-enforcement reporting.
75. Training and Awareness
People with significant responsibility for:
- procurement;
- overseas operations;
- grants;
- contractor management;
- financial approvals;
should understand the requirements of this policy.
76. Monitoring
The charity may periodically review:
- Gifts and Hospitality Register entries;
- supplier relationships;
- repeated gifts;
- unusual hospitality;
- procurement conflicts.
Patterns may be considered even where individual gifts are below the declaration threshold.
77. Related Al-Waris Foundation Policies
This policy should be read alongside:
- Constitution;
- Trustee Code of Conduct;
- Conflict of Interest Policy;
- Anti-Fraud, Bribery and Corruption Policy;
- Procurement and Purchasing Policy;
- Financial Controls and Reserves Policy;
- Expenses Policy;
- Grant Making Policy;
- Fundraising Policy;
- Overseas Operations and Partner Due Diligence Policy;
- Sanctions and Terrorist Financing Policy;
- Safeguarding Children Policy;
- Safeguarding Adults at Risk Policy;
- Whistleblowing Policy;
- Serious Incident Reporting Policy;
- Data Protection and UK GDPR Policy;
- Records Retention and Disposal Policy.
78. Review
This policy will be reviewed:
- at least annually;
- following a significant bribery or corruption concern;
- following material procurement misconduct;
- following significant changes to overseas operations;
- where existing controls are found to be inadequate;
- following relevant legal or regulatory developments.
79. Approval
Version: 2.0 Status: Approved Approved by: Board of Trustees Approval date: 25/08/2026 Next scheduled review: 24/08/2027
