91¶¶Òõ

1. 91¶¶Òõ was founded on , and to advance the College’s mission and strategic objectives we will seek philanthropic support or sponsorship which is aligned with our values, strategic goals and financial needs, as a legitimate, sustained and vital component of our income.  Such support may be sought and accepted from alumnae, friends, organisations, companies and charitable trusts and foundations.  The acceptance of benefactions can give rise to ethical considerations.
2. The College is registered with (FR) which sets out a Code of Practice for fundraising, including standards on accepting, refusing and returning donations. The FR, the and the Chartered Institute of Fundraising all highlight the importance of registered charities establishing clear policies and the requirement of trustees to act in the best interests of the charity (). The Council for Advancement and Support of Education () provides guidelines and principles for UK universities to consider when developing policies and procedures with regard to the criteria that determine whether any particular benefaction should be accepted from any particular benefactor (). Reflecting on all the guidelines provided this paper outlines the set of ethical principles under which the College will or will not pursue potential benefactions, and establishes procedures in the case of potentially controversial gifts or donors.
3. The following questions will be considered by Development Office staff in the context of all benefactions proposed or received:

• Is the proposed gift or sponsorship consistent with the College’s mission, strategic plan and values, as determined by the College Council?
• Is the proposed gift or sponsorship in support of or for a current or agreed/approved College activity or project?
• If there are stipulations attached to the proposed gift or sponsorship, have the implications of accepting these been assessed (e.g., time and resources required for delivering the stipulations) and considered appropriate?
• By accepting the proposed gift or sponsorship is there a possibility that it will expose or put any College staff or Fellows, students, visitors or other members of the public at serious risk (for example, from protests)?
• Has the gift or sponsorship or a previous gift or sponsorship from this donor or organisation previously been refused by the College or University for any reason?
• Is there published or other credible evidence that the benefaction will be or has been made from a source that arises in whole or in part from an activity that:
  • Evaded taxation or involved fraud?
  • Violated international conventions that bear on human rights?
  • Suppressed or falsified academic research?
  • Was linked in any way to bribery of a member of the College or any other person?
  • Is there evidence that the proposed gift or sponsorship, or any of its terms will:
  • Require action that is illegal or non-compliant with Charity Commission guidance?
  • Limit freedom of enquiry?
  • Limit independence or freedom of decision making for the College?
  • Suppress or falsify academic research?
  • Seriously damage the reputation of the College or the University of Cambridge?
  • Create unacceptable conflicts of interest for the College or the University of Cambridge?
  • Led to an undue and inappropriate third-party influence, or impression of such influence, on institutional decisions of the College?
  • Harm the College relationship with other benefactors, partners, potential students or research supporters?
• Is there any question that the identity of the ultimate donor is undisclosed or that the apparent donor is an agent of an undisclosed principal?
• In line with the policy of the University, the College will not accept funding from sources where to do so would be incompatible with its commitment to address climate change through a transition to a zero carbon world. The guidelines agreed by the University Committee on Benefactions and External and Legal Affairs (CBELA) will apply. 

Procedure

For all gifts with a value of over £10,000, and any company/corporate donations or sponsorships, the Director of Development will undertake necessary research and due diligence.  The Director of Development is authorised to make an acceptance decision on any gifts where there are no concerns up to the value of £100,000.  If any prospective gift should give rise to potential concerns over its acceptance the procedure to determine a decision is as follows: 

1. If s/he has any concerns regarding gifts at any level, the Director of Development will, at an early stage in discussions, seek advice from the College Officers.
2. All gifts at the level of above £100,000 will be tabled for discussion by the College Officers. If there are no concerns, then the College Officers are authorised to make an acceptance decision. 
3. Where there are concerns and the gift is above £100,000 the Director of Development will convene a Gift Acceptance Meeting comprised of the President, Bursar and at least two other Fellows from the Gift Acceptance Group.  The Gift Acceptance Group consisting of six Fellows will be appointed by Council for a three-year term. Fellows appointed to the group may be called upon at any point in the year. A decision on gift acceptance may be made at the Gift Acceptance Meeting or can be referred for further discussion within a meeting of the College Council. 
4. The Gift Acceptance Group may decide to consult an external body for their advice and information which will then be reviewed by the College Council.
5. The final decision on gift acceptance where there may be a concern lies with the College Council.