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Governance and trustees

Trustee Code of Conduct

This Code of Conduct sets out the standards of behaviour expected from every trustee of Al-Waris Foundation.

Current version 2.0

1. Purpose

This Code of Conduct sets out the standards of behaviour expected from every trustee of Al-Waris Foundation.

Trustees hold ultimate legal responsibility for the charity and must act in a way that protects:

  • the charity's purposes;
  • its beneficiaries;
  • its assets and reputation;
  • public and donor confidence;
  • the integrity of its governance.

This Code supplements the charity's Constitution and other governance policies.

It does not replace trustees' legal duties.

Where this Code conflicts with the Constitution or applicable law, the Constitution and applicable law take precedence.

2. Commitment to the Charity

Trustees must:

  • support Al-Waris Foundation's charitable purposes;
  • act in the charity's best interests;
  • understand the charity's activities;
  • contribute appropriately to governance;
  • devote sufficient time to their trustee responsibilities;
  • act with reasonable care and skill;
  • protect the charity's independence;
  • support responsible and lawful decision-making.

Trustees must not use Al-Waris Foundation primarily to advance personal, family, commercial, political or other interests unrelated to its charitable purposes.

3. Trustee Duties

Trustees must have regard to their legal duties, including the duties to:

  • ensure the charity carries out its purposes for the public benefit;
  • comply with the Constitution and the law;
  • act in the charity's best interests;
  • manage the charity's resources responsibly;
  • act with reasonable care and skill;
  • ensure the charity remains accountable.

Trustees are collectively responsible for the charity even where operational responsibilities are delegated.

Delegation does not remove trustee accountability.

4. Collective Responsibility

The Board acts collectively.

Trustees should:

  • participate constructively in decisions;
  • consider relevant information;
  • challenge appropriately;
  • exercise independent judgement;
  • respect properly made Board decisions.

A trustee may disagree with a proposal and should be free to express that disagreement during proper discussion.

Once a lawful decision has been properly made, trustees should respect the collective decision unless there is a legitimate reason for the matter to be reconsidered.

Serious concerns about unlawful or improper conduct must not be concealed in the name of collective responsibility.

5. Independent Judgement

Every trustee must exercise their own judgement.

A trustee must not simply follow the instructions of:

  • the Chair;
  • another trustee;
  • a donor;
  • a family member;
  • a partner organisation;
  • a contractor;
  • a religious or community figure;
  • another organisation.

Trustees should listen to relevant advice while reaching their own informed view of what is in Al-Waris Foundation's best interests.

6. Role of the Chair

The Chair may provide leadership, coordinate governance and undertake operational responsibilities where appropriately authorised.

However, the Chair does not replace the Board's collective legal responsibility.

Trustees must not assume that:

  • a decision is automatically valid because the Chair supports it;
  • they are relieved of responsibility because the Chair manages day-to-day matters;
  • they do not need to understand significant decisions.

The Board should provide appropriate oversight while avoiding unnecessary interference with properly delegated day-to-day administration.

7. Operational Delegation

Al-Waris Foundation may delegate operational functions to:

  • the Chair;
  • authorised officers;
  • staff;
  • volunteers;
  • contractors;
  • committees;
  • other appropriately appointed persons.

Trustees are not required to have routine operational or administrative access merely because they are trustees.

Where functions are delegated, the Board must retain sufficient oversight to satisfy itself that:

  • activities remain within the charity's purposes;
  • resources are properly controlled;
  • significant risks are managed;
  • legal and regulatory requirements are addressed;
  • material issues are escalated appropriately.

Trustees must respect properly established operational boundaries.

8. Attendance and Participation

Trustees should make reasonable efforts to:

  • attend Board meetings;
  • prepare appropriately;
  • review relevant papers;
  • contribute to discussion;
  • complete agreed governance actions;
  • notify the appropriate person when unable to attend.

Repeated unexplained absence may be addressed in accordance with the Constitution and governance procedures.

9. Preparation for Meetings

Trustees should read relevant information before meetings where reasonably practicable.

A trustee should ask questions where:

  • information is unclear;
  • evidence appears incomplete;
  • financial information requires explanation;
  • risks have not been addressed;
  • a proposal may fall outside the charity's purposes;
  • a legal or regulatory issue may arise.

Trustees should not approve significant decisions without sufficient information merely for convenience.

10. Behaviour at Meetings

Trustees must behave professionally.

Trustees should:

  • allow others to speak;
  • challenge ideas rather than attack individuals;
  • avoid intimidation;
  • avoid discriminatory or abusive language;
  • disclose conflicts;
  • maintain confidentiality;
  • respect the Chair's reasonable management of meetings;
  • remain focused on the charity's interests.

Disagreement is acceptable.

Bullying, harassment, threats and personal abuse are not.

11. Decisions

Trustees should make decisions based on relevant factors including:

  • charitable purposes;
  • public benefit;
  • beneficiary needs;
  • available evidence;
  • financial implications;
  • safeguarding;
  • risks;
  • legal obligations;
  • conflicts of interest;
  • long-term sustainability.

Trustees should not knowingly allow irrelevant personal considerations to determine charity decisions.

12. Conflicts of Interest

Trustees must identify and declare actual, potential and perceived conflicts of interest.

A trustee must comply with the Conflict of Interest Policy and Constitution.

Where required, a conflicted trustee must:

  • withdraw from discussion;
  • not vote;
  • not receive restricted information;
  • avoid influencing the decision outside the meeting.

Trustees must update their declarations when circumstances change.

13. Personal and Family Interests

Trustees must be particularly careful where decisions involve:

  • themselves;
  • relatives;
  • close friends;
  • business associates;
  • organisations with which they are connected.

A personal connection does not automatically prohibit a transaction or appointment.

However, it must not be concealed and must be managed properly.

No trustee should use their position to obtain improper preferential treatment for themselves or another person.

14. Trustee Benefits

Trustees must not receive unauthorised personal benefit from the charity.

This includes inappropriate:

  • payments;
  • remuneration;
  • contracts;
  • loans;
  • property benefits;
  • gifts;
  • services;
  • preferential arrangements.

Any proposed trustee or connected-person benefit must comply with the Constitution and applicable charity law.

Properly incurred trustee expenses should be handled under the Expenses Policy.

15. Charity Property and Resources

Trustees must protect charity resources.

They must not knowingly misuse:

  • money;
  • equipment;
  • premises;
  • vehicles;
  • data;
  • intellectual property;
  • donor information;
  • beneficiary information;
  • charity accounts;
  • payment systems;
  • websites;
  • social-media accounts;
  • other assets.

Charity resources must be used for legitimate charitable or administrative purposes.

16. Financial Responsibility

Trustees share responsibility for ensuring the charity's finances are appropriately managed.

Trustees should understand, at a level proportionate to their role:

  • the charity's financial position;
  • significant income sources;
  • significant expenditure;
  • restricted funds;
  • financial risks;
  • reserves;
  • material liabilities;
  • significant transactions.

Trustees should ask for clarification where financial information is not understood.

17. Restricted Funds and Donor Intentions

Trustees must respect legally binding restrictions attached to charitable funds.

Where donors select a specific appeal, cause or project and the circumstances create a restricted fund, those funds must be applied accordingly.

Trustees must not knowingly redirect restricted funds merely because another purpose is considered more convenient.

The charity should communicate donation designations accurately and avoid creating restrictions unintentionally through misleading fundraising language.

18. Expenses

Trustees should not be personally disadvantaged by reasonable expenses necessarily incurred in carrying out authorised charity duties.

Claims must:

  • be genuine;
  • relate to charity activity;
  • be reasonable;
  • follow the Expenses Policy;
  • include appropriate evidence where available.

Trustees must not disguise remuneration or personal expenditure as expenses.

19. Fundraising Conduct

Trustees must support responsible fundraising.

They must not knowingly permit:

  • misleading appeals;
  • fabricated donation totals;
  • fabricated beneficiaries;
  • fabricated project outcomes;
  • false urgency;
  • misleading photographs;
  • deceptive fundraising claims;
  • inappropriate pressure on donors.

Public statements about how donations will be used should be accurate.

20. Beneficiary Dignity

Trustees must promote treatment of beneficiaries with dignity and respect.

Beneficiaries must not be treated as:

  • marketing props;
  • sources of personal content;
  • opportunities for personal status;
  • people required to demonstrate gratitude.

Charitable assistance should be based on legitimate charitable considerations.

A person's dignity should not be sacrificed to make fundraising content more emotionally powerful.

21. Safeguarding

Trustees must take safeguarding seriously.

They should:

  • understand the charity's safeguarding framework;
  • ensure appropriate safeguarding arrangements exist;
  • respond appropriately to significant concerns;
  • support a culture in which concerns can be raised;
  • avoid interfering improperly with safeguarding referrals;
  • consider regulatory reporting where required.

Safeguarding concerns must not be concealed to protect the charity's reputation.

22. Confidentiality

Trustees may receive confidential information concerning:

  • beneficiaries;
  • donors;
  • volunteers;
  • complaints;
  • safeguarding;
  • finances;
  • contracts;
  • disputes;
  • personnel;
  • security;
  • other trustees.

Such information must not be disclosed without proper authority or lawful justification.

The duty of confidentiality continues after a person ceases to be a trustee where the information remains confidential.

23. Data Protection

Trustees must handle personal data in accordance with the Data Protection and UK GDPR Policy.

Trustees must not:

  • access personal data without legitimate need;
  • retain unnecessary copies;
  • share personal data casually;
  • use donor or beneficiary information for personal purposes;
  • disclose authentication credentials;
  • transfer sensitive charity information to unauthorised systems.

Trustee status does not automatically create a need for unrestricted access to operational personal data.

24. Information Security

Trustees must take reasonable steps to protect charity information.

This includes:

  • protecting passwords;
  • using multi-factor authentication where required;
  • reporting compromised accounts;
  • keeping devices reasonably secure;
  • avoiding suspicious links or attachments;
  • not sharing credentials;
  • reporting loss of sensitive information.

Cybersecurity concerns should be reported promptly.

25. Social Media

Trustees must recognise that their public conduct may affect the charity's reputation.

When using personal social-media accounts, trustees should avoid creating a misleading impression that personal statements are official Al-Waris Foundation statements.

Trustees must not:

  • disclose confidential information;
  • publish beneficiary information improperly;
  • harass others;
  • make knowingly false statements about the charity;
  • misuse charity branding;
  • present fabricated project evidence as genuine.

Trustees remain free to hold and express personal views, subject to their legal and governance responsibilities.

26. Speaking on Behalf of the Charity

Only appropriately authorised persons should make official statements on behalf of Al-Waris Foundation.

Trustees must distinguish between:

  • personal views;
  • trustee discussions;
  • official charity positions.

A trustee should not claim that the Board has approved a position where it has not.

27. Political Activity

Al-Waris Foundation must remain independent of party politics.

Trustees may have personal political views and may participate in political activity in a personal capacity, subject to applicable law.

However, trustees must not use Al-Waris Foundation's:

  • name;
  • resources;
  • funds;
  • beneficiaries;
  • communications;
  • premises;

to support a political party or candidate.

Any campaigning by the charity itself must further its charitable purposes and comply with charity law.

28. Religious Identity and Conduct

Al-Waris Foundation may operate within a charitable context informed by its identity, values and charitable purposes.

Trustees must nevertheless ensure that:

  • charitable resources are used within the charity's purposes;
  • beneficiaries are treated with dignity;
  • unlawful discrimination does not occur;
  • aid is not improperly conditional on participation in religious activity;
  • donor representations remain accurate;
  • public benefit remains central to decision-making.

Personal religious authority must not replace trustees' legal responsibilities.

29. Equality, Diversity and Inclusion

Trustees must treat people fairly and with dignity.

Unlawful discrimination, harassment and victimisation are unacceptable.

Trustees should support reasonable inclusion and accessibility in:

  • governance;
  • volunteering;
  • beneficiary services;
  • communications;
  • recruitment;
  • events.

See the Equality, Diversity and Inclusion Policy.

30. Bullying and Harassment

Trustees must not engage in:

  • bullying;
  • harassment;
  • intimidation;
  • threats;
  • humiliating conduct;
  • discriminatory abuse;
  • retaliation against someone raising a genuine concern.

Position or seniority must not be used to silence legitimate challenge.

31. Gifts and Hospitality

Trustees must not accept gifts or hospitality that could improperly influence, or reasonably appear to influence, their judgement.

Relevant gifts or hospitality should be declared and recorded in accordance with the Gifts and Hospitality Policy.

Cash or cash-equivalent personal gifts connected to a charity decision should not normally be accepted.

32. Fraud, Bribery and Corruption

Trustees must not participate in, authorise or conceal:

  • fraud;
  • bribery;
  • corruption;
  • kickbacks;
  • false accounting;
  • misappropriation;
  • deliberate misuse of charitable funds.

Suspected misconduct must be handled under the appropriate policies and reported externally where required.

33. Procurement and Contractors

Trustees involved in procurement must act fairly and in the charity's interests.

They must not:

  • secretly favour connected suppliers;
  • receive undisclosed commissions;
  • manipulate quotations;
  • bypass controls for personal reasons;
  • direct contracts to relatives without appropriate conflict management and due diligence.

Value for money, quality, safeguarding and delivery risk should be considered.

34. Overseas Activities

Trustees must ensure appropriate oversight of overseas charitable activities.

Trustees should recognise risks including:

  • safeguarding;
  • fraud;
  • bribery;
  • diversion of aid;
  • unreliable contractors;
  • weak documentation;
  • security;
  • local legal requirements;
  • conflicts of interest.

Overseas work should have evidence proportionate to the nature and value of the activity.

35. Project Evidence

Trustees should support reliable records demonstrating that charitable projects have been carried out.

Depending on the project, appropriate evidence may include:

  • project reference;
  • location;
  • dates;
  • specifications;
  • invoices;
  • receipts;
  • photographs;
  • video;
  • contractor information;
  • completion evidence;
  • monitoring information.

Evidence must not be fabricated or manipulated to create a false impression of impact.

36. Artificial Intelligence and Generated Content

Where AI-generated or illustrative content is used, trustees must ensure it is not presented deceptively as:

  • a real beneficiary;
  • genuine documentary photography;
  • evidence of a completed project;
  • evidence of an actual distribution;
  • a genuine quotation from a beneficiary;
  • proof of impact.

AI tools must not be provided with confidential or sensitive charity information unless their use has been appropriately assessed and authorised.

37. Complaints

Trustees must respect the charity's complaints process.

Trustees must not:

  • suppress legitimate complaints;
  • retaliate against complainants;
  • alter records improperly;
  • interfere with an investigation because its outcome may be inconvenient.

Where a trustee is personally involved in a complaint, the conflict should be managed appropriately.

38. Whistleblowing

Trustees must support an environment in which genuine concerns about wrongdoing can be raised.

A trustee must not retaliate against a person for raising a genuine concern in good faith.

Concerns involving serious wrongdoing should be addressed under the Whistleblowing Policy.

39. Serious Incidents

Trustees must support appropriate identification and reporting of serious incidents.

Potential serious incidents may include:

  • significant financial loss;
  • fraud;
  • serious safeguarding incidents;
  • significant data breaches;
  • serious governance failures;
  • significant reputational incidents;
  • terrorism or sanctions-related concerns;
  • other matters meeting current Charity Commission criteria.

Trustees must not deliberately conceal a reportable incident.

40. Relations With Regulators

Trustees must cooperate appropriately with lawful regulatory requirements.

Information supplied to:

  • the Charity Commission;
  • HMRC;
  • Information Commissioner's Office;
  • other competent authorities;

must not knowingly be false or misleading.

Trustees must not destroy or conceal relevant records to obstruct regulatory scrutiny.

41. Record Keeping

Trustees must support accurate organisational records.

Records should appropriately document:

  • significant decisions;
  • conflicts;
  • financial approvals;
  • governance actions;
  • serious incidents;
  • significant risks.

Trustees must not knowingly falsify or improperly alter charity records.

42. Public Statements and Transparency

Information published by Al-Waris Foundation should be accurate and supportable.

Trustees should not knowingly authorise false claims concerning:

  • donation totals;
  • beneficiary numbers;
  • project completion;
  • expenditure;
  • impact;
  • partnerships;
  • registrations;
  • endorsements.

Where figures are estimates, they should be described appropriately.

43. Reputation

Trustees should take reasonable care not to damage the charity through serious misconduct.

This does not mean trustees must avoid all disagreement or criticism.

Protecting reputation must never be used as a justification for:

  • concealing wrongdoing;
  • suppressing safeguarding concerns;
  • misleading donors;
  • preventing lawful whistleblowing.

44. Personal Conduct

Trustees should conduct themselves in a manner compatible with the responsibilities of charity trusteeship when acting for or representing Al-Waris Foundation.

Private conduct should only become a governance concern where it has a genuine and material connection to:

  • trustee suitability;
  • legal eligibility;
  • safeguarding;
  • the charity's operations;
  • serious reputational risk;
  • ability to fulfil trustee duties.

The charity should not unnecessarily regulate trustees' private lives.

45. Use of Position

A trustee must not misuse their title or relationship with Al-Waris Foundation to:

  • obtain personal discounts;
  • secure private business;
  • pressure others;
  • obtain preferential treatment;
  • imply charity endorsement of a private venture;
  • access information for personal purposes;
  • obtain personal financial advantage.

46. Trustee Access to Systems

Operational access should be provided according to role and legitimate need.

Being a trustee does not automatically require access to:

  • donor accounts;
  • beneficiary databases;
  • payment systems;
  • CMS administration;
  • website infrastructure;
  • email administration;
  • authentication systems;
  • confidential case files.

The Board should receive sufficient information to exercise oversight without creating unnecessary security or data-protection risks.

47. Leaving Office

When a trustee leaves office, they must:

  • return charity property;
  • cease using trustee authority;
  • return or securely dispose of confidential records as directed;
  • stop accessing systems for which authority has ended;
  • continue respecting confidential information.

Access credentials should be revoked promptly.

48. Breaches of This Code

A suspected breach should be considered fairly and proportionately.

Depending on seriousness, action may include:

  • informal discussion;
  • guidance;
  • additional training;
  • formal warning or governance action;
  • removal of delegated responsibilities;
  • restriction of access;
  • investigation;
  • consideration of removal from office where permitted by the Constitution and law;
  • referral to a regulator;
  • referral to safeguarding authorities;
  • referral to police.

Not every minor error requires formal action.

Deliberate dishonesty, safeguarding misconduct, serious financial misconduct and intentional concealment will be treated seriously.

49. Concerns About Another Trustee

A trustee who has a genuine concern about another trustee should raise it through an appropriate governance route.

Depending on the circumstances, this may include:

  • the Chair;
  • another unconflicted trustee;
  • the Designated Safeguarding Lead;
  • the Whistleblowing procedure;
  • an appropriate external authority.

Where the concern involves the Chair, it should be raised with another unconflicted trustee.

50. No Retaliation

No trustee should suffer retaliation merely for:

  • asking reasonable governance questions;
  • challenging a proposal;
  • declaring a conflict;
  • reporting a safeguarding concern;
  • reporting suspected wrongdoing;
  • refusing to participate in unlawful conduct.

This protection does not prevent appropriate action where a person knowingly makes malicious or deliberately false allegations.

51. Acceptance of the Code

Each trustee should confirm that they:

  • have received this Code;
  • have read and understood it;
  • agree to comply with it;
  • understand that it forms part of Al-Waris Foundation's governance framework;
  • understand their continuing duty to disclose conflicts and relevant changes in circumstances.

A trustee's legal duties apply regardless of whether a signed acknowledgement has been completed.

52. Trustee Declaration

Trustees may use the following declaration:

I confirm that I have read and understood the Al-Waris Foundation Trustee Code of Conduct. I agree to act in accordance with the charity's Constitution, applicable law and the governance standards set out in this Code. I understand my responsibility to act in the best interests of Al-Waris Foundation and to declare relevant conflicts of interest.

Trustee name:

Signature:

Date:

53. Related Al-Waris Foundation Policies

This Code should be read alongside:

  • Constitution;
  • Trustee Terms of Reference;
  • Conflict of Interest Policy;
  • Safeguarding Children Policy;
  • Safeguarding Adults at Risk Policy;
  • Safer Recruitment Policy;
  • Data Protection and UK GDPR Policy;
  • Confidentiality Policy;
  • Equality, Diversity and Inclusion Policy;
  • Complaints Policy;
  • Whistleblowing Policy;
  • Serious Incident Reporting Policy;
  • Risk Management Policy;
  • Financial Controls and Reserves Policy;
  • Expenses Policy;
  • Gifts and Hospitality Policy;
  • Anti-Fraud, Bribery and Corruption Policy;
  • Procurement and Purchasing Policy;
  • Overseas Operations and Partner Due Diligence Policy;
  • Social Media and Digital Communications Policy;
  • Photography, Video and Beneficiary Consent Policy;
  • Information Security and Cybersecurity Policy.

54. Review

This Code will be reviewed:

  • at least annually;
  • following a significant governance failure;
  • following serious trustee misconduct;
  • following material changes to the charity's governance arrangements;
  • following relevant changes in law or Charity Commission guidance.

55. Approval

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

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