Grant Making Policy

1. Policy Statement

Al-Waris Foundation may further its charitable purposes by making grants to:

individuals;
families;
registered charities;
other not-for-profit organisations;
community organisations;
overseas organisations;
project partners;
other eligible recipients;

where the trustees are satisfied that the grant will further Al-Waris Foundation's charitable purposes and provide public benefit.

The trustees are responsible for ensuring that charitable funds are applied only for proper charitable purposes.

Grant-making decisions must therefore be:

consistent with the Constitution;
evidence-based;
proportionate;
properly authorised;
subject to appropriate due diligence;
appropriately documented;
monitored according to risk.

2. Purpose

This policy establishes the principles and procedures used when Al-Waris Foundation:

awards grants;
provides financial assistance;
funds external organisations;
funds overseas partners;
makes payments to organisations delivering charitable activity on its behalf.

The policy is intended to ensure that:

grants further the charity's purposes;
funds reach legitimate recipients;
funds are used as intended;
safeguarding risks are considered;
fraud and diversion risks are controlled;
decisions are fair and appropriately documented;
monitoring is proportionate to risk.

3. Relationship With the Constitution

All grants must further the charitable purposes set out in the Al-Waris Foundation Constitution.

This policy does not expand the charity's legal objects.

Where a proposed grant does not fall within the charity's purposes, the grant must not be made merely because the proposed work is socially beneficial.

Where there is uncertainty about whether a grant is within the objects, appropriate advice should be obtained before approval.

4. Current Charitable Priorities

Al-Waris Foundation may make grants in support of activities consistent with its charitable purposes, including areas such as:

relief of poverty;
relief of financial hardship;
health;
education;
assistance to people in need;
humanitarian relief;
assistance following natural disasters;
other activities falling properly within the Constitution.

Operational priorities may change over time.

Any change in grant-making priorities must remain within the charity's legal objects.

5. Trustee Responsibility

The Board of Trustees retains ultimate responsibility for grant-making.

The Board may delegate parts of:

application administration;
due diligence;
project assessment;
monitoring;
record keeping;
payment administration;

to authorised persons.

However, the Board remains responsible for ensuring that an appropriate grant-making framework exists.

Significant grants or higher-risk grants may be reserved for direct Board approval.

6. Delegated Grant Authority

The Board may establish delegated authority for grant decisions.

A delegated-authority framework may specify:

approval limits;
risk limits;
geographical limits;
permitted grant categories;
escalation requirements.

No person may approve a grant outside their delegated authority.

A delegated approver with a conflict of interest must not make the relevant decision.

7. Eligibility

A proposed recipient must be eligible to receive funds for purposes consistent with Al-Waris Foundation's objects.

Eligible recipients may include:

individuals experiencing qualifying need;
families experiencing qualifying need;
registered charities;
charitable organisations;
non-profit organisations;
community groups;
overseas NGOs;
project delivery partners.

Eligibility does not create an entitlement to funding.

8. Grants to Individuals

Where grants or financial assistance are provided directly to individuals, Al-Waris Foundation should establish proportionate evidence of:

identity where appropriate;
need;
eligibility;
intended use;
relationship to the charity's purposes.

The nature of evidence required should reflect:

value of assistance;
urgency;
vulnerability;
location;
practical availability of documents.

The charity must avoid unnecessarily intrusive evidence requirements.

9. Beneficiary Selection

Beneficiary selection must be based on legitimate charitable criteria.

Selection must not be improperly influenced by:

family relationships;
personal friendship;
donor pressure;
social status;
political affiliation;
personal benefit to charity representatives.

Where a trustee, volunteer or representative has a close relationship with a proposed beneficiary, the conflict must be declared and managed.

10. Applications

Where appropriate, grant applicants may be required to provide:

name and contact information;
legal status;
organisational details;
project description;
funding requested;
intended outcomes;
location;
project timetable;
budget;
evidence of need;
other funding sources;
relevant safeguarding arrangements;
financial information;
supporting documentation.

The level of information requested must be proportionate to the grant.

11. Emergency Grants

Humanitarian emergencies may require faster decision-making.

Urgency may justify:

simplified application requirements;
accelerated due diligence;
staged approval;
initial emergency payments.

However, urgency does not remove the trustees' duty to:

establish charitable purpose;
identify the recipient;
assess significant risks;
monitor use of funds.

Any checks deferred because of genuine urgency should be completed as soon as reasonably practicable.

12. Assessment Criteria

Applications may be assessed according to factors including:

alignment with charitable purposes;
demonstrated need;
expected charitable benefit;
value for money;
feasibility;
delivery capacity;
safeguarding arrangements;
financial controls;
risks;
sustainability where relevant;
monitoring capability;
evidence available.

Not every factor will apply equally to every grant.

13. Due Diligence

Al-Waris Foundation will carry out due diligence proportionate to:

value of the grant;
nature of the recipient;
geographical location;
safeguarding risk;
fraud risk;
terrorism-financing risk;
sanctions risk;
length of relationship;
complexity of the project;
payment mechanism;
local operating environment.

Higher-risk grants require stronger checks.

14. Know Your Recipient

Due diligence should establish, where proportionate:

who the recipient is;
legal or organisational status;
address;
key responsible persons;
bank-account ownership;
organisational purpose;
relevant track record;
ability to deliver the proposed work;
whether material adverse information exists.

For organisations, verification may include reviewing:

regulator records;
registration documents;
governing documents;
public information;
financial records;
policies;
references.

15. Overseas Organisations

Where a recipient operates overseas, checks should consider:

legal existence;
local registration where applicable;
management structure;
reputation;
financial controls;
safeguarding arrangements;
ability to provide project evidence;
local security conditions;
sanctions and terrorism-financing risk;
banking arrangements;
previous relationship with Al-Waris Foundation.

International work should generally receive greater scrutiny where the operating environment is higher risk.

The Charity Commission expects due diligence and monitoring to be proportionate to factors including the amount involved, location, partner and associated risks. :contentReference[oaicite:3]{index=3}

16. Sanctions Screening

Where appropriate to the level and nature of risk, Al-Waris Foundation should screen relevant parties against applicable UK sanctions information.

Screening may include:

recipient organisations;
significant controllers;
key delivery partners;
financial intermediaries.

Where a potential sanctions match is identified, funds must not be transferred until the matter has been appropriately resolved.

See the Sanctions and Terrorist Financing Policy.

17. Terrorist Financing

Charitable funds must never knowingly be:

provided to;
diverted to;
controlled by;
used for the benefit of;

a terrorist organisation, proscribed organisation or person where prohibited by law.

Particular care must be taken where work takes place in:

conflict zones;
areas controlled by armed groups;
high-risk jurisdictions;
areas with limited banking infrastructure.

Appropriate advice should be sought where necessary.

18. Anti-Fraud and Anti-Bribery

Grant arrangements must be designed to reduce the risk of:

fraud;
theft;
bribery;
kickbacks;
false invoices;
fabricated beneficiaries;
duplicate claims;
diversion of aid.

No trustee, volunteer, contractor, intermediary or recipient may request or accept improper payment in exchange for:

grant approval;
beneficiary selection;
access to aid;
contract award.

See the Anti-Fraud, Bribery and Corruption Policy.

19. Safeguarding Due Diligence

Where grant-funded work involves:

children;
adults at risk;
vulnerable communities;

the charity should assess the recipient's safeguarding arrangements.

Depending on the project, this may include:

safeguarding policy;
safeguarding lead;
safer recruitment;
reporting process;
staff or volunteer training;
photography practices;
beneficiary complaints arrangements.

Serious safeguarding weaknesses may make an organisation unsuitable to receive funds.

20. Financial Due Diligence

Financial checks should be proportionate to risk.

They may include:

bank account verification;
budget review;
financial statements;
accounts;
quotations;
previous grant records;
financial controls;
segregation of duties.

Payments should normally be made to an account held in the recipient organisation's name.

Payments to personal accounts on behalf of organisations should be avoided unless there is a clear, documented and risk-assessed reason.

21. Bank Account Verification

Before making a material grant payment, Al-Waris Foundation should take reasonable steps to verify:

account holder;
account details;
relationship between the account and recipient.

Changes to bank details should be independently verified before payment where practicable.

Email alone should not automatically be relied upon for unexpected bank-detail changes.

22. Cash Payments

Cash should generally be avoided for material grants where safer traceable methods are reasonably available.

Where cash is necessary due to:

emergency conditions;
local infrastructure;
lack of accessible banking;

the charity should implement enhanced controls.

These may include:

documented approval;
signed receipts;
payment logs;
segregation of duties;
beneficiary confirmation;
reconciliations;
photographic or other evidence where appropriate.

23. Informal Value Transfer and Money Service Businesses

Where conventional banking cannot reasonably be used, the charity must assess the risks before using:

money service businesses;
informal transfer systems;
other financial intermediaries.

The arrangement must comply with applicable law.

The charity should maintain an audit trail sufficient to demonstrate:

origin of funds;
intermediary;
destination;
recipient;
amount.

24. Conflicts of Interest

All conflicts relating to grants must be declared.

This includes situations where a trustee or decision-maker:

is related to an applicant;
controls an applicant organisation;
works for an applicant;
has a financial interest;
has another duty of loyalty.

Conflicted persons must not improperly participate in grant decisions.

See the Conflict of Interest Policy.

25. Connected-Person Grants

Particular care must be taken where assistance may benefit:

a trustee;
connected person;
family member;
organisation controlled by a trustee.

The charity must confirm:

the grant is within its purposes;
private benefit is legally permissible and incidental where applicable;
relevant authority exists;
conflicts are properly managed.

Professional advice should be obtained where necessary.

26. Grant Decision

The grant decision should be recorded.

Depending on the significance of the award, records may include:

recipient;
purpose;
amount;
decision-maker;
due diligence completed;
risk rating;
conditions;
monitoring requirements;
conflicts.

27. Reasons for Decisions

For material grants, records should provide a sufficient explanation of why trustees or authorised decision-makers considered the grant:

charitable;
appropriate;
proportionate;
in the charity's best interests.

A short but meaningful record is usually preferable to no documented rationale.

28. Grant Agreements

Material organisational grants should normally be supported by written terms.

Terms may address:

amount;
charitable purpose;
permitted expenditure;
payment schedule;
project period;
reporting;
evidence;
safeguarding;
data protection;
use of branding;
changes to project;
unused funds;
suspension;
repayment;
fraud;
sanctions;
monitoring access.

The level of contractual formality should reflect the value and risk.

29. Restricted Use

Recipients must use the grant only for the agreed charitable purpose.

Material changes should require prior approval where appropriate.

The recipient must not knowingly use funds for:

private profit outside permitted charitable arrangements;
unlawful activity;
terrorism;
bribery;
corruption;
political-party support;
purposes outside the agreed grant.

30. Payment in Instalments

Higher-value or higher-risk grants may be paid in stages.

Later instalments may depend on:

progress;
financial reporting;
evidence;
milestones;
continued eligibility.

Staged funding may reduce financial risk.

31. Project Monitoring

Monitoring should be proportionate to risk.

It should seek to establish:

work occurred;
funds reached the intended recipient;
funds were used for the agreed purpose;
significant problems were identified;
outcomes were reasonably consistent with the proposal.

The Charity Commission specifically expects trustees to monitor end use of funds and maintain an audit trail, including supporting records such as receipts and invoices where appropriate. :contentReference[oaicite:4]{index=4}

32. Monitoring Methods

Monitoring may include:

written reports;
photographs;
video;
invoices;
receipts;
bank records;
project logs;
location information;
beneficiary feedback;
site visits;
telephone/video calls;
independent verification;
milestone reports.

No single form of evidence should automatically be considered sufficient in every case.

33. Evidence Integrity

The charity should recognise that documentary evidence can be:

inaccurate;
duplicated;
manipulated;
fabricated.

For higher-risk grants, monitoring should go beyond simply receiving paperwork where reasonably practicable.

Evidence may be cross-checked against:

project specifications;
payment records;
photographs;
timestamps;
location;
independent observations.

34. Photographs and Video

Photographs and video may be useful evidence.

However:

beneficiary dignity must be respected;
appropriate consent or lawful basis should be considered;
children and adults at risk require additional safeguards;
beneficiaries must not be pressured into publicity to receive assistance.

See the Photography, Video and Beneficiary Consent Policy.

35. Site Visits

Site visits may be used where appropriate.

A visit may check:

progress;
existence of project;
quality;
use of funds;
beneficiary access.

Site visits must themselves be risk assessed, particularly in overseas or unstable environments.

36. Water Projects and Physical Infrastructure

For physical infrastructure such as water installations, monitoring records should be proportionate to the project and may include:

Al-Waris Foundation project number;
project location;
GPS/location details where safe and appropriate;
installation specification;
depth or technical details where relevant;
completion date;
contractor information;
invoice/cost;
photographs/video;
completion evidence;
maintenance or warranty information.

This evidence supports accountability and future monitoring.

37. Food and Aid Distributions

Where grants fund distributions, monitoring may include:

number or quantity of packages;
unit cost;
distribution date;
location;
supplier documentation;
receipts;
distribution records;
appropriate photographic evidence;
beneficiary-selection method.

Care must be taken not to create unnecessary personal-data or safeguarding risks.

38. Financial Reporting

Recipients may be required to provide:

expenditure statement;
invoices;
receipts;
bank evidence;
explanation of material variances.

Requirements should be proportionate.

Small emergency grants should not automatically be subjected to the same reporting burden as major organisational awards.

39. Unspent Funds

Grant terms should normally address unspent funds.

Depending on the circumstances, the charity may:

approve revised charitable use;
extend the project period;
require repayment.

Recipients must not assume they may use remaining funds for unrelated purposes.

40. Misuse of Funds

Where misuse is suspected, Al-Waris Foundation may:

suspend payments;
request additional records;
conduct further enquiries;
conduct a site visit;
seek repayment;
terminate the grant;
notify police;
notify regulators;
make safeguarding referrals;
make a serious incident report.

Action should reflect the seriousness of the concern.

41. Recovery of Funds

The charity should seek recovery where:

funds were obtained fraudulently;
grant terms were materially breached;
funds were clearly misapplied;
the grant was not used.

Recovery action should consider:

amount;
evidence;
cost of recovery;
safeguarding consequences;
legal position;
charity's best interests.

42. Failed Projects

A project that fails to achieve every intended outcome is not automatically evidence of misconduct.

The charity should distinguish between:

genuine project failure;
unforeseen circumstances;
poor performance;
negligence;
misuse of funds;
fraud.

Lessons should be documented.

43. Changes to Projects

Recipients should notify Al-Waris Foundation of material changes including:

purpose;
location;
timetable;
budget;
delivery partner;
safeguarding arrangements.

Material changes may require approval before funds continue to be used.

44. Partner Changes

Recipients should not transfer grant responsibility to another organisation without appropriate approval where this materially changes the risk.

New delivery partners may require additional due diligence.

45. Publicity

Recipients must not imply that Al-Waris Foundation:

endorses unrelated activities;
guarantees the organisation;
has verified impact beyond what has actually been checked.

Use of Al-Waris branding should be appropriately controlled.

46. Data Protection

Grant processes may involve personal data.

Information must be handled in accordance with:

Data Protection and UK GDPR Policy;
Confidentiality Policy;
Records Retention and Disposal Policy.

Beneficiary information should not be collected merely to create stronger publicity.

47. Grant Records

The charity should retain appropriate records including:

applications;
assessments;
due diligence;
approvals;
agreements;
payments;
monitoring;
evidence;
correspondence;
closure records.

Records should be retained according to the Records Retention and Disposal Policy.

48. Grant Closure

A grant may be closed when:

final reporting has been received;
material conditions have been satisfied;
outstanding issues are resolved;
unused funds are appropriately addressed.

Closure should be documented for material grants.

49. Repeat Grants

A previous successful grant does not automatically entitle a recipient to future funding.

Before repeat funding, the charity should consider:

previous performance;
reporting quality;
current due diligence;
ongoing need;
current risks.

Due diligence should be refreshed where necessary.

50. Risk Rating

Al-Waris Foundation may categorise grants as:

low risk;
medium risk;
high risk.

Factors may include:

amount;
country;
conflict environment;
recipient history;
cash use;
safeguarding;
sanctions;
banking arrangements;
project complexity.

The risk rating should determine the level of due diligence and monitoring.

51. High-Risk Grants

For high-risk grants, enhanced measures may include:

additional identity checks;
sanctions screening;
enhanced financial review;
multiple approvals;
staged payments;
stronger evidence requirements;
site visits;
independent verification;
more frequent reporting.

If risks cannot be reduced to an acceptable level, the grant should not proceed.

52. Complaints

Applicants and beneficiaries may raise concerns about grant-making under the Complaints Policy where appropriate.

A complaint does not automatically require a grant decision to be reversed.

53. No Guarantee of Funding

Submission of an application or completion of due diligence does not guarantee funding.

The charity may:

decline funding;
reduce an award;
defer a decision;
attach conditions.

Trustees must retain discretion to act in the charity's best interests.

54. Transparency

Al-Waris Foundation may publish information about grants where appropriate.

This may include:

recipient organisation;
amount;
purpose;
location;
project progress.

Public disclosure must respect:

safeguarding;
security;
confidentiality;
data protection.

Individual beneficiaries should not be unnecessarily identified.

55. Annual Reporting

Grant-making information should be included in statutory reporting where required.

The charity should ensure that descriptions of grant activity are accurate and not misleading.

56. Related Al-Waris Foundation Policies

This policy should be read alongside:

Constitution;
Overseas Operations and Partner Due Diligence Policy;
Sanctions and Terrorist Financing Policy;
Anti-Fraud, Bribery and Corruption Policy;
Financial Controls and Reserves Policy;
Procurement and Purchasing Policy;
Conflict of Interest Policy;
Safeguarding Children Policy;
Safeguarding Adults at Risk Policy;
Data Protection and UK GDPR Policy;
Photography, Video and Beneficiary Consent Policy;
Serious Incident Reporting Policy;
Risk Management Policy;
Records Retention and Disposal Policy.

57. Review

This policy will be reviewed:

at least annually;
following significant misuse of grant funds;
following a serious fraud or safeguarding incident;
following material expansion of overseas grant-making;
following significant changes to relevant law or Charity Commission guidance;
where monitoring identifies systemic weaknesses.

58. Approval

Version: 2.0 Status: Approved Approved by: Board of Trustees Approval date: 25/08/2026 Next scheduled review: 24/08/2027