Gift acceptance policy
Southbank Centre’s Development Committee has delegated responsibility from the Southbank Centre Board for capital refurbishment project Gift Acceptance Policy within the following guidelines.
Southbank Centre should carry out due diligence, proportionate to the scale of the relationship, before accepting donations from individuals and sponsorship from corporate partners.
Southbank Centre should take all reasonable steps to ensure that they are aware of the source of funding for each donation /sponsorship and have processes in place to satisfy them that the funds did not derive from activity that was or is illegal.
Individual and trust donations
In the case of donations from individuals personally or via a charitable trust Southbank Centre will use the basic Know Your Customer standards. KYC controls typically include the below:
- Collection and analysis of basic identity information.
- Name-matching against lists of known parties (such as politically exposed persons).
- Determination of the donor’s risk in terms of propensity to commit money laundering or other illegal activities.
The legal and reputational rights of the potential donors should also be considered as part of any due diligence undertaken in assessing the acceptability of donations and a distinction drawn between speculation and confirmed fact or legal finding. Southbank Centre may however consider reputational risk that could be incurred through public perception of a particular donor.
Should Southbank Centre be particularly concerned about whether to refuse a particular donation, they may seek the views of the Charity Commission under Section 110 Charities Act 2011 (power to give advice). This might relate to circumstances where there are very large sums of money involved, it is not clear what ‘the best interests of the charity’ are in relation to the donation or the decision taken might be challenged in the courts and the authority of the Charity Commission’s advice might mitigate against the threat of negative publicity.
For both individual and corporate support the Development Committee must determine
- There are no conflicts of interest or potential conflicts of interest relating to the donation /sponsorship.
- The donation does not carry the potential for long term reputational damage
In addition Southbank Centre must ensure that there are written agreements in place with the donor/ sponsor which include lists of benefits and payment terms. These are spot-checked on an annual basis by our external auditors.