Overseas Operations and Partner Due Diligence Policy

Al-Waris Foundation may carry out charitable work outside the United Kingdom directly or through contractors, community organisations, charities, NGOs, local representatives and other delivery partners.

Overseas work may present additional risks relating to:

Al-Waris Foundation will therefore use proportionate due diligence, written arrangements, monitoring and evidence requirements before and during material overseas work.

The level of control applied will reflect the actual risk of the project, partner, location and payment arrangement.

This policy establishes the framework for:

This policy applies to overseas activity involving:

It applies whether the charity:

The Board of Trustees retains ultimate responsibility for overseas activity.

Trustees must ensure that:

Operational project management may be delegated.

Due diligence should reflect factors including:

A low-value, low-risk purchase from an established supplier may require fewer checks than a large grant to a new organisation in a higher-risk environment.

Before significant overseas work, Al-Waris Foundation should consider the operating environment.

Relevant factors may include:

Risk should be assessed at the relevant local level where possible rather than treating an entire country as having one uniform risk profile.

Every overseas project must further Al-Waris Foundation's charitable purposes.

A project must not proceed solely because:

unless the activity is also within the charity's legal objects.

Overseas assistance must be provided for public benefit.

Private benefit should be:

to achieving the charitable purpose.

The charity must not use charitable resources primarily to benefit:

without proper legal justification.

Overseas delivery may involve:

The appropriate due diligence depends on the role the party performs.

For material partner organisations, checks may include:

For significant contractors, checks may include:

Where an individual acts as an Al-Waris Foundation representative overseas, the charity should establish:

An informal local connection should not automatically be given unrestricted authority over charity funds or beneficiaries.

Anyone involved in selecting a partner or contractor must declare relevant interests.

Examples include:

The existence of a local relationship does not necessarily prevent engagement.

However, the relationship must be declared and properly managed.

See the Conflict of Interest Policy.

Where a trustee or connected person has a financial or personal interest in an overseas supplier, contractor or partner, enhanced scrutiny is required.

The charity must establish:

The conflicted trustee must not control the decision.

Material contractor work should normally be supported by written quotations.

Quotes should clearly identify, where applicable:

For repeat work, the charity should consider bulk pricing where appropriate.

New contractors undertaking repeatable project work should normally begin with a limited pilot where reasonably practicable.

The pilot should assess:

Larger batches should only be considered after satisfactory performance.

Before a material partnership begins, the charity should record:

Material partnerships should normally be supported by written terms.

These may cover:

Contractor arrangements should specify, where relevant:

Overseas payments should follow the Financial Controls and Reserves Policy.

The charity should record:

Unexpected changes to payment details should be verified independently.

Material organisational payments should normally be made to an account associated with the recipient organisation or contractor.

Payment to an unrelated personal account should require:

Cash should be avoided where a safer, traceable payment method is reasonably available.

Where cash is necessary, controls may include:

Foreign currency transactions should record sufficient information to reconcile:

Before material higher-risk overseas payments, sanctions checks should be considered.

The charity must not knowingly make prohibited funds or economic resources available to a designated person or organisation.

See the Sanctions and Terrorist Financing Policy.

Overseas charitable activity must be structured to reduce the risk of funds being diverted for terrorist purposes.

Controls may include:

Overseas operations may carry increased risks of:

See the Anti-Fraud, Bribery and Corruption Policy.

Safeguarding requirements apply to overseas work.

Before projects involving children or adults at risk, the charity should consider:

See the relevant safeguarding policies.

Where local safeguarding systems are weak or unavailable, Al-Waris Foundation should determine alternative procedures.

This may include:

Beneficiaries must be treated with dignity.

Receiving assistance must not be made conditional upon:

Selection should be based on legitimate charitable criteria.

Where local partners select beneficiaries, Al-Waris Foundation should understand:

Photography and video may support monitoring and donor accountability.

However, project partners must follow appropriate requirements relating to:

See the Photography, Video and Beneficiary Consent Policy.

Evidence should be proportionate to the nature and value of the project.

Examples may include:

Evidence should not automatically be accepted without review.

For higher-risk projects, the charity may:

AI-generated or materially manipulated content must not be knowingly submitted as genuine project evidence.

Project partners and contractors must not use fabricated:

to demonstrate work that did not occur.

Water projects require project-specific controls.

Before installation, the charity should consider:

The appropriate installation should be determined by actual site conditions rather than applying one solution universally.

Each completed Al-Waris Foundation water installation should normally have an appropriate project record containing:

Where appropriate, completed installations should include an Al-Waris Foundation branded plaque or other project identification.

The identification should normally contain the project number.

It should not reveal beneficiary information unnecessarily.

Where appropriate, contractors should provide information concerning:

The charity should recognise that drilling costs may still arise even where the expected result is not achieved, depending on the agreed contractual terms.

Where a project provides drinking water, the charity should consider whether water-quality assessment is appropriate based on:

The charity must not claim water is verified safe to drink unless there is an adequate basis for doing so.

Food projects should maintain proportionate records concerning:

Food safety and suitable storage should be considered.

Where a standard food package is advertised, published contents and prices should be presented accurately.

Where prices are estimates, they should be described as estimates.

A target package cost should not be represented as an exact verified cost where supplier prices remain variable.

Distribution evidence may include:

The charity should avoid collecting excessive beneficiary personal data solely for donor reporting.

Al-Waris Foundation may conduct site visits to:

Visits should be appropriately planned and risk assessed.

Where site visits are impractical, monitoring may use:

No single technique guarantees authenticity.

Monitoring should reflect risk.

Low-risk established partners may require less frequent checks.

New, higher-value or higher-risk partners should receive more intensive monitoring.

Partner performance should be assessed against matters including:

Material failures should affect decisions about future funding.

Contractors may be assessed on:

The charity should maintain a record of material performance concerns.

Where repeat projects are planned, Al-Waris Foundation may negotiate bulk pricing after contractor capability has been established.

Bulk procurement must not reduce:

Material changes should be approved before implementation where reasonably practicable.

Examples include changes to:

Emergency adjustments may be made where necessary but should be documented.

Partners or contractors should not materially subcontract work without appropriate visibility where subcontracting increases risk.

The charity may require approval of significant subcontractors.

Overseas activity may involve security risks to:

Travel or site visits should consider current local conditions.

No person should be required to enter an unreasonably dangerous environment merely to obtain photographs or monitoring evidence.

Where volunteers or representatives travel overseas for charity work, planning should consider:

Personal expenses must be distinguished from charity project expenditure.

Authorised travel or project expenses may be reimbursed according to the Expenses Policy.

Local procurement may provide:

However, local purchases remain subject to appropriate:

Where overseas activities involve:

the charity should seek appropriate information.

Unofficial payments should not be disguised as official charges.

Al-Waris Foundation will seek to comply with applicable local law where operating overseas.

Where local requirements conflict with UK legal or regulatory obligations, appropriate professional advice should be obtained.

Overseas work may involve international transfers of personal data.

The charity must consider:

See the Data Protection and UK GDPR Policy.

Only beneficiary information reasonably required for:

should be collected.

Large beneficiary databases should not be created merely because they may be useful in future.

Partners and project teams should provide a practical means for significant concerns to reach Al-Waris Foundation where appropriate.

Complaints involving safeguarding or serious misconduct must be escalated through the relevant process.

Partners and project representatives should be able to report concerns about:

See the Whistleblowing Policy.

Partners should promptly notify Al-Waris Foundation of significant incidents affecting:

Serious matters may require Charity Commission reporting.

Potential serious incidents must be considered under the Serious Incident Reporting Policy.

The fact that an incident occurred overseas does not remove the trustees' reporting responsibilities.

Where misuse is suspected, Al-Waris Foundation may:

A project that does not achieve the planned result is not automatically evidence of fraud or misconduct.

The charity should distinguish between:

The reason should be documented.

Where funds have been misused, recovery action should be considered.

The charity should assess:

A partner may be suspended where significant unresolved concerns exist.

Examples include:

Suspension does not necessarily mean permanent termination.

The charity may terminate a relationship where:

Termination should be managed to minimise unnecessary harm to legitimate beneficiaries.

The charity should maintain proportionate records including:

Al-Waris Foundation may maintain a central partner and contractor register.

It may include:

Due diligence should be refreshed where:

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

Financial and safeguarding records may require longer retention than ordinary project communications.

Al-Waris Foundation should provide appropriate public information about overseas projects.

This may include:

Public transparency must not compromise:

Donor communications should distinguish clearly between:

Unverified work must not be presented as complete.

The Board should receive proportionate information about:

Trustees do not need routine access to every operational record where appropriate reporting exists.

This policy should be read alongside:

This policy will be reviewed:

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