Fundraising with trust and integrity.

1. Purpose and status of this policy

This policy sets the minimum standards that Kashmir Welfare Foundation (“KWF”, “we”, “us” or “our”) expects in all fundraising carried out in its name or for its benefit.

It is intended to help trustees, employees, volunteers, agencies, professional fundraisers, commercial participators, online platforms and other partners make lawful, proportionate and well-documented decisions.

This policy does not replace the law, the Code of Fundraising Practice, Charity Commission guidance, licence conditions, data-protection rules, gambling requirements, safeguarding duties or professional advice. Where another requirement sets a higher standard, the higher standard must be followed.

2. Our commitment to the Fundraising Regulator

KWF is registered with the Fundraising Regulator and is committed to meeting the Code of Fundraising Practice and is committed to meeting the Code of Fundraising Practice. We may display the Fundraising Badge on appropriate fundraising materials while our registration and permission to use it remain current.

The Code applies to charitable fundraising in the UK, whether or not an organisation is registered with the Fundraising Regulator. KWF will work constructively with the Fundraising Regulator, and with the Scottish Fundraising Adjudication Panel where relevant, in relation to complaints, monitoring and investigations.

We recognise that the Code is principles-based. Words such as “appropriate”, “reasonable” and “proportionate” require judgement. We will document significant decisions so that we can explain how our actions met the principle, taking account of risk, scale, method, audience and circumstances.

3. Scope

This policy applies to fundraising carried out:

• by KWF trustees, employees and volunteers;
• through our website, donor portal, checkout and online campaigns;
• by supporters running fundraising pages or community appeals;
• at mosques, schools, businesses, community venues and events;
• through cash, card, cheque, bank transfer, direct debit and digital payments;
• through telephone, email, post, social media, messaging or advertising;
• through professional fundraisers, commercial participators, agencies and suppliers;
• through challenge events, collections, grants, payroll giving and legacies;
• in the UK and, where relevant, activity overseas carried out in KWF’s name.

Personal fundraising for a person’s own private cause is outside the Code unless it is represented as KWF fundraising or uses a KWF-approved platform or appeal.

4. Core fundraising values

These values apply at every stage: planning, approval, public communication, collection, payment processing, delivery, reporting, complaints and review.

5. Trustee and senior-management responsibilities

The Board of Trustees retains overall responsibility for KWF’s fundraising. Delegating activity does not remove trustee accountability.

The trustees will take reasonable steps to:

• set and review fundraising strategy, risk appetite and ethical standards;
• ensure fundraising serves KWF’s charitable purposes and best interests;
• approve material campaigns, partnerships and unusual fundraising methods;
• maintain effective financial, safeguarding and data-protection controls;
• ensure complaints are handled fairly and lessons are implemented;
• monitor fundraising performance without creating incentives for poor behaviour;
• review serious incidents, significant donations and regulatory concerns;
• ensure the annual report contains legally required fundraising statements;
• provide appropriate resources, training and supervision.

Day-to-day responsibility may be delegated to named staff or officers. Delegations, financial limits and approval routes should be recorded.

6. Risk assessment, decision-making and records

Fundraising activity must be planned in proportion to its scale and risk. Before a material campaign or activity begins, KWF should consider:

• legal and regulatory requirements;
• financial controls and fraud risk;
• safeguarding and vulnerability;
• reputation, donor trust and beneficiary dignity;
• health, safety, insurance and venue requirements;
• data protection, consent and marketing rules;
• partner capability, conflicts and due diligence;
• restricted-fund wording and what happens if the appeal succeeds, fails or raises excess funds;
• how the activity will be monitored and evaluated.

Significant decisions must be recorded at a level proportionate to the risk. Records may include an approval form, risk assessment, due-diligence note, trustee minute, contract, campaign brief, safeguarding plan or complaints log.

7. Behaviour when fundraising

Everyone fundraising for KWF must act professionally and in a way that reflects positively on charitable fundraising.

Fundraisers must not:

• put undue pressure on anyone to donate;
• use unreasonably persistent approaches;
• continue after a person asks to end the interaction;
• unreasonably intrude on privacy;
• use threatening, manipulative, humiliating or discriminatory language;
• obstruct access, follow people or cause unreasonable nuisance;
• exploit faith, grief, guilt, fear, illness or vulnerability;
• misrepresent their identity, authority, payment or the purpose of an appeal;
• criticise or pressure a person for choosing not to donate.

Fundraisers must be courteous, identifiable where required, appropriately dressed for the activity and able to explain how to verify KWF and raise a concern.

8. Informing donors and treating people fairly

Donors must be given enough accurate information to make an informed choice. The information required will depend on the method and context, but should normally include:

• the name of Kashmir Welfare Foundation;
• the charitable purpose or campaign being supported;
• whether the donation is one-off or recurring;
• the amount and any optional additional contribution;
• how to stop an interaction, opt out or cancel recurring giving;
• the fundraiser’s status where a solicitation statement is required;
• material restrictions, costs, conditions or use of proceeds;
• how to make a complaint.

We will take care not to create a misleading impression through headlines, images, comparisons, omissions, urgency, countdowns, statistics or case studies.

Beneficiary stories must be presented with dignity and context. Images should not imply that a named person will receive a donor’s exact gift unless that is accurate.

9. Accepting, refusing and returning donations

The starting point is that charities should normally accept lawful donations that further their purposes. However, trustees must act in KWF’s best interests and may need to refuse, delay, investigate or return a donation.

Concerns may arise where a donation:

• is suspected to involve crime, sanctions, money laundering or stolen funds;
• comes with conditions inconsistent with KWF’s purposes or independence;
• could cause disproportionate harm to beneficiaries, staff, reputation or public trust;
• creates costs, liabilities or obligations that outweigh the benefit;
• appears to be a mistake, duplicate or unauthorised transaction;
• is in an unusual form requiring additional expertise or controls;
• cannot legally be accepted or used.

Due diligence must be appropriate and proportionate to the size, nature, source and risk of the gift. Unexpected large donations, complex overseas arrangements, cryptoassets, loans, property, high-risk jurisdictions or unusual restrictions require enhanced consideration.

KWF will not refuse or return a donation merely because of personal dislike or external pressure. The decision must be lawful, properly reasoned, documented and taken by someone with authority. Legal or regulatory advice should be obtained where necessary.

10. Using donations and restricted funds

Donations must be applied for the purpose for which they were given. Campaign teams must decide before launch whether an appeal creates a specific legal restriction or supports a broader charitable programme.

Appeal wording should be clear about the primary purpose and, where appropriate, include a suitable secondary purpose explaining what KWF may do if:

• more is raised than required;
• the original project cannot proceed;
• circumstances or needs change;
• a named beneficiary no longer requires or can receive support;
• funds remain after completion.

Restricted funds must be separately identifiable in accounting records. They must not be redirected merely for convenience. Where an appeal fails or raises surplus funds without an adequate secondary purpose, KWF will follow charity law and any required Charity Commission process.

Fundraising costs and allocations must not be described in a misleading way. The statement “100% donations” must be supported by KWF’s actual funding model and explained consistently where necessary so donors understand how administration and payment costs are met.

11. Fundraising complaints and concerns

KWF will maintain an accessible complaints procedure and respond constructively to concerns. Complaints should be acknowledged promptly, investigated fairly and answered within the published timescale.

The complaints process should:

• be easy to find and use;
• allow complaints by reasonable channels;
• identify an impartial reviewer where appropriate;
• keep relevant evidence and correspondence;
• explain findings and any corrective action;
• provide information about escalation to the Fundraising Regulator;
• identify trends, training needs and systemic weaknesses.

Complainants should normally raise the issue with KWF first. If unresolved, they may refer an eligible complaint to the Fundraising Regulator. KWF will cooperate with requests for information and implement agreed or required action.

12. Paying and incentivising fundraisers

Remuneration must be lawful, reasonable, transparent and designed so that it does not encourage pressure, misleading statements or inappropriate targeting.

KWF will not use commission-only arrangements where they create an unacceptable risk. Performance measures should include quality, compliance, complaints, donor care and safeguarding—not only income.

Trustees must consider value for money, market rates, conflicts of interest and the effect on public trust. Payments to trustees or connected persons require a clear legal authority, proper approval and conflict management.

13. Solicitation statements

Paid employees, officers, trustees, professional fundraisers and commercial participators must make any solicitation statement required by law.

The statement must be clear, timely and audible or visible. Depending on the fundraiser’s status, it may need to identify:

• the charitable institution benefiting;
• whether the fundraiser is paid;
• how remuneration is calculated or the expected amount;
• the proportion or amount expected to reach KWF;
• the name of a commercial participator and the nature of the promotion.

The exact wording must be checked against current law and the applicable fundraising method.

14. Processing donations: general controls

All donations must be recorded accurately, protected against loss or misuse and transferred to KWF promptly. Duties should be separated where proportionate so that one person does not control collection, counting, recording and reconciliation without review.

Core controls include:

• unique references for collection containers, events or online transactions;
• two-person counting for material cash collections;
• signed count sheets and prompt banking;
• reconciliation to payment-provider, bank and accounting records;
• investigation of discrepancies;
• secure storage and restricted access;
• receipts or acknowledgements where appropriate;
• clear handling of restricted funds and Gift Aid information.

15. Cash, tills, floats and collection containers

Cash

Cash must be kept secure, counted in a controlled environment and banked as soon as reasonably practicable. Personal money and KWF funds must not be mixed.

Collection containers

Sealed buckets, tins and boxes should be numbered or otherwise controlled. Seals must be checked, and issue and return records maintained. Unstaffed containers require permission, clear ownership details, secure placement and a documented servicing schedule.

Tills and floats

Floats must be authorised, recorded at issue and reconciled at return. Till access should be restricted. Variances must be recorded and reviewed.

Cash must never be left unattended in a vehicle, public area or unsecured private address unless an approved risk assessment and control makes this unavoidable.

16. Cheques, vouchers, card and online transactions

Cheques and charity vouchers

Cheques should be payable to Kashmir Welfare Foundation rather than an individual. They should be logged, securely stored and banked promptly. Charity vouchers and similar instruments must be processed according to the issuer’s conditions.

Card payments

Card details must be handled through approved payment systems. Full card numbers and security codes must not be written down, emailed, stored in ordinary documents or entered into an unapproved system.

Online donations

Online pages must clearly show the charity, donation amount, frequency, selected cause, optional contribution and total before confirmation. Recurring payments must be clearly identified and capable of cancellation.

Refunds, duplicate payments, chargebacks and payment failures must be logged and reconciled. Access to payment-provider accounts must use strong authentication and role controls.

17. Volunteers

Volunteers are central to KWF’s work. They must receive information, instruction and supervision proportionate to the activity and risk.

KWF will, where appropriate:

• define the volunteer’s role and authority;
• check suitability, identity and safeguarding requirements;
• provide approved messages and materials;
• train volunteers in conduct, cash security, data protection and complaints;
• provide identification or written authority;
• ensure reasonable welfare, safety and support;
• monitor activity and withdraw authority when necessary.

“On-behalf-of” volunteers who organise their own activity must not bind KWF to contracts, change campaign wording, collect personal data, use lotteries or appoint sub-agents without approval.

18. Children and people in vulnerable circumstances

Children involved in fundraising

KWF must consider age, supervision, consent, safety, hours, location, money handling, photography and the nature of the activity. Required licences or permissions must be obtained. A child must not be given inappropriate financial responsibility or placed in an unsafe or exploitative situation.

People in vulnerable circumstances

Fundraisers must respond to signs that a person may not understand the request, may lack capacity for the decision, or may be experiencing distress, confusion, bereavement, financial difficulty, illness, cognitive impairment or undue influence.

Fundraisers must:

• slow down, explain clearly and check understanding;
• avoid pressure, urgency or repeated requests;
• end the interaction where informed choice is doubtful;
• not accept a donation where the person cannot make an informed decision;
• raise safeguarding concerns through the proper route;
• record and review concerning interactions proportionately.

Vulnerability must not be inferred simply from age, disability or appearance. People should be treated as individuals with dignity and autonomy.

19. Fundraising partnerships and third parties

Before entering a material fundraising partnership, KWF will carry out proportionate due diligence on the organisation, ownership, reputation, finances, capability, legal status, safeguarding, data handling, sanctions exposure and conflicts.

Written agreements must be used where required and should cover:

• roles, purpose, term and termination;
• fundraising methods and territories;
• payment, fees, expenses and financial reporting;
• required solicitation statements;
• brand and content approval;
• data protection and marketing responsibilities;
• safeguarding and complaints;
• monitoring, audit access and corrective action;
• ownership and return of funds and data;
• subcontracting and conflicts of interest.

KWF will monitor partners proportionately rather than relying only on the contract. Serious or repeated non-compliance may lead to suspension or termination.

20. Public fundraising

Street, private-site and door-to-door fundraising must be specifically approved and carried out with all required licences, permissions, agreements and identification.

Public fundraisers must:

• respect access, safety, privacy and local communities;
• not obstruct, follow, surround or intimidate people;
• leave when asked and not return contrary to a request;
• comply with site, local-authority and permit conditions;
• carry appropriate identification and authority;
• protect cash, devices and personal information;
• follow agreed locations, times and spacing rules.

Door-to-door activity must account for additional risks involving private homes, lone working, children and vulnerable residents. KWF may decide not to use a method where it cannot provide sufficient supervision and control.

Convenience giving and unstaffed collections

QR codes, contactless devices, donation kiosks, collection boxes and clothing banks must identify KWF, explain the donation where necessary, remain secure and be inspected at a documented frequency. Broken, misleading or unauthorised units must be removed promptly.

21. Fundraising communications and advertising

Fundraising communications must be accurate, clear, responsible and capable of substantiation. Material information must not be hidden in small print or omitted where it would change a reasonable donor’s understanding.

Communications should clearly identify:

• Kashmir Welfare Foundation and its registered status where legally required;
• the purpose of the appeal;
• how to donate and any recurring nature;
• the role of a commercial participator or professional fundraiser where relevant;
• significant conditions, costs or secondary purposes;
• how to opt out or complain.

Statistics, quotations and impact claims must have a reasonable evidence base. Testimonials and case studies must not be fabricated or materially altered. AI-generated or stock images must not be presented as a real beneficiary where that would mislead.

Emergency language, limited-time claims and targets must be genuine. We must not create false scarcity or imply that a donation is compulsory.

22. Fundraising calls, direct marketing, consent and opt-outs

Telephone, email, text, direct message and postal fundraising must comply with data protection law, PECR, the Code and applicable preference services.

KWF will:

• use a valid lawful basis for personal-data processing;
• obtain electronic-marketing consent where required;
• keep evidence of consent and communication preferences;
• screen telephone activity against applicable preference and suppression lists;
• identify KWF and the purpose of the communication;
• provide a clear and simple opt-out;
• honour direct-marketing objections promptly;
• retain a minimal suppression record to prevent re-contact;
• avoid excessive frequency or intrusive timing.

Transactional receipts, account notices and service messages must not be used to bypass a marketing opt-out by inserting substantial promotional content.

23. Online fundraising platforms

Where KWF operates an online platform or allows supporters to create fundraising pages, it will provide clear information about:

• who operates the platform and who receives donations;
• fees, optional tips and deductions;
• when and how funds reach KWF;
• refunds, failed appeals and chargebacks;
• fundraiser verification and moderation;
• personal-data use and public visibility;
• complaints and reporting unlawful or misleading content.

User-created pages must be reviewed or monitored proportionately. KWF may reject, edit, pause or remove pages that are misleading, unlawful, unsafe or inconsistent with our purposes.

Platform features must not make optional tips or recurring donations appear compulsory. The full amount and frequency must be shown before confirmation.

24. Fundraising events

Events must be planned with proportionate attention to safety, safeguarding, insurance, accessibility, venue terms, licences, food hygiene, first aid, weather, cancellations, financial controls and data protection.

Promotional materials must distinguish clearly between a donation, registration fee, sponsorship target and participant costs. Any minimum sponsorship requirement or non-refundable charge must be explained before registration.

Participants must receive clear instructions about collecting, recording and transferring funds. They must not deduct expenses from donations unless KWF has expressly authorised a lawful arrangement and donors are not misled.

Cancellation and postponement terms must explain the treatment of fees, donations and sponsorship. Donations already given to KWF may remain charitable funds even if a participant cannot attend, subject to appeal wording and law.

25. Prize competitions and free draws

Prize competitions, free draws and lotteries are legally distinct. No such activity may be launched in KWF’s name without written approval and confirmation of the legal structure.

The organiser must check Gambling Commission requirements, licence or registration needs, age restrictions, territorial limits, advertising rules, free-entry routes, prize terms, closing dates and selection procedures.

Rules must be available before entry and the draw or judging process must be fair, documented and capable of verification. Winners must be contacted and announced only in a way consistent with privacy and the published terms.

26. Applications to grant-making bodies

Grant applications must be truthful, properly authorised and based on reasonable budgets, outputs and evidence. KWF must not knowingly submit duplicate or incompatible claims for the same cost.

Restricted grant conditions, reporting deadlines, procurement rules, safeguarding duties and evaluation requirements must be recorded and assigned to responsible staff.

Material changes, underspends, delays, conflicts or inability to deliver must be disclosed to the funder where required. Reports must not exaggerate beneficiary numbers or outcomes.

27. Payroll Giving and post-tax salary donations

Payroll Giving arrangements must be operated through authorised employers, agencies and HMRC-approved mechanisms where applicable.

Employees must receive clear information about the amount, frequency, tax treatment, deductions, fees, cancellation and the organisation receiving the donation. No employer, manager or fundraiser may pressure an employee to participate.

Post-tax salary donations must not be described as Payroll Giving where that would mislead people about tax relief or processing.

28. Gifts in wills and legacy fundraising

Legacy fundraising must respect a person’s freedom, privacy, family relationships and right to obtain independent legal advice.

Fundraisers must not:

• provide legal advice unless professionally qualified and authorised;
• pressure a person to make or change a will;
• be present during will instructions unless appropriately requested and safe;
• draft or witness a will where a conflict or legal restriction arises;
• seek to know or control the contents of a will unnecessarily;
• take advantage of illness, grief, dependence or vulnerability.

Where KWF pays for or promotes a will-writing service, the relationship, limits, costs and independence of the provider must be clear. KWF staff should not act as executors or receive personal benefits without specific approval and conflict safeguards.

29. Due diligence, financial crime and unusual donations

KWF will apply a risk-based approach. The greater the risk, value, complexity or unusual nature of a donation or relationship, the more KWF must do to understand and mitigate it.

Checks may include:

• identity and source of funds or wealth;
• ownership and control of an organisation;
• sanctions, adverse media and regulatory history;
• connection to high-risk jurisdictions or politically exposed persons;
• conditions, intermediaries and intended influence;
• cryptoasset, property, loan or non-cash valuation and custody;
• conflicts with trustees, staff, beneficiaries or suppliers.

Small routine cash donations will not normally require formal donor checks unless other risk indicators exist. Unexpected large or complex gifts must be escalated.

Suspicious activity must not be concealed or “tipped off”. KWF will seek specialist advice and report to an appropriate authority where legally required.

30. Data protection and donor privacy

Personal information used for fundraising must be handled in accordance with KWF’s Privacy Policy, Cookie Policy, data-protection procedures and applicable law.

Fundraising data must be relevant, accurate, secure and limited to what is needed. It must not be copied to personal devices, private accounts or unapproved spreadsheets without authority and suitable controls.

Sensitive beneficiary data must not be shared with donors merely to prove impact. Reporting should use anonymisation, consent, redaction and minimum necessary information.

Lists must not be sold. Sharing with fundraising partners requires a lawful basis, transparency and an appropriate agreement.

31. Training, supervision and monitoring

Anyone undertaking material fundraising duties must receive training proportionate to their role. Training may cover:

• the Code and this policy;
• conduct, pressure and vulnerability;
• campaign accuracy and restricted funds;
• cash and payment security;
• data protection and direct marketing;
• safeguarding and complaints;
• fraud, conflicts and due diligence;
• method-specific licences and procedures.

Monitoring may include observation, call review, complaint analysis, mystery shopping, reconciliation, audits, page review, partner reporting and sample checks. Monitoring must itself respect privacy and employment law.

32. Breaches, concerns and regulatory reporting

Suspected breaches must be reported promptly to the relevant manager, trustee or designated lead. No person should be penalised for raising a genuine concern in good faith.

KWF will assess:

• harm or risk to donors, beneficiaries and the public;
• whether activity should be paused;
• refund, correction or apology requirements;
• safeguarding or personal-data breach duties;
• fraud, criminal or regulatory reporting;
• whether the matter is a serious incident for Charity Commission reporting;
• disciplinary, contractual or training action;
• changes needed to prevent recurrence.

KWF will cooperate constructively with the Fundraising Regulator and other competent bodies. Findings and corrective action should be recorded.

33. Policy approval and review

The operational lead should monitor Code updates and supporting guidance. Minor procedural updates may be approved under delegated authority; material changes should return to the trustees.

34. Contact and complaints

Questions, concerns or complaints about KWF fundraising may be sent to:

Kashmir Welfare Foundation
UK registered charity
Registered charity number: 1206824
Address: Kashmir Welfare Foundation UK, Ikhlas Community Centre, 127–129 Clarence Road, Derby, DE23 6LS
Phone: 020 3900 3790
Email: hello@kashmirwelfare.org.uk
Finance enquiries: finance@kashmirwelfare.org.uk
Website: www.kashmirwelfare.org.uk