This policy applies to trustees, staff, volunteers, supporters, partners and fundraisers acting for, or on behalf of, SSAFA.

It should be read alongside the following SSAFA policies:

• Data Protection Policy
• Complaints Policy

This policy draws on relevant sector guidance, including the Institute of Fundraising’s guide, Creating a Donations Acceptance and Refusal Policy, and Charity Commission guidance for trustees, particularly CC3, CC7 and CC20.

This policy is written in accordance with charity law in England and Wales. Different provisions may apply in Scotland, including in relation to ex-gratia payments and the return of donations, and additional advice should be sought where required.

All fundraising, marketing and supporter communications must comply with applicable data protection legislation and regulatory guidance, including:

• UK GDPR and Data Protection Act
• Data (Use and Access) Act 2025
• Fundraising Regulator guidance

SSAFA will ensure that:

• there is a lawful basis for all supporter communications, whether through consent or legitimate interest;
• supporter preferences are captured clearly, including channel-specific preferences where applicable;
• data is aligned across relevant systems, including CRM platforms; and
• an auditable record of consent and communication preferences is maintained.

Where permitted by law, SSAFA may use a ‘soft opt-in’ approach for communications with individuals who have previously engaged with the charity, provided that:

• communications are relevant and proportionate; and
• a clear and simple opt-out mechanism is provided.

SSAFA’s Council of Trustees is responsible for ensuring that fundraising, marketing and partnership activity is consistent with charity law, the Code of Fundraising Practice and relevant regulatory guidance. Council delegates day-to-day operational authority to the Director of Fundraising, Marketing & Communications and the FMC Directorate, which applies this policy through due diligence, approval and escalation processes.

SSAFA will comply with relevant legislation and guidance, including requirements relating to data protection, money laundering, bribery and corruption, terrorism, political activity and charity governance. Assurance will be provided through appropriate reporting to the Executive Board, Fundraising & Marketing Committee, Enterprises Board and Council.

In exceptional circumstances, or where a matter is considered to represent a financial, regulatory or reputational risk to SSAFA, decisions will be referred to Council for approval.  Examples may include: -

• The donation or partnership is of significant value;
• The opportunity is high-profile or brand sensitive
• there is potential reputational, ethical or regulatory risk; or

the decision is novel, contentious or precedent setting.

SSAFA will generally accept donations and partnership income where acceptance supports its charitable objects, protects its independence, maintains public trust and does not compromise its values, reputation or future fundraising opportunities.

It does this by reporting through the Executive Board, Fundraising & Marketing Committee and Enterprises Board.

SSAFA will generally accept financial support from, and work in partnership with, third parties (companies and individuals) on the understanding:

• that the outcomes of fundraising will be used to support SSAFA’s charitable objects;
• that fundraising activities will not bring adverse publicity either to SSAFA itself or to the Armed Forces, Ministry of Defence or Government;
• that no attempt is made by any company or individual to link a donation with an attempt to influence the policy or activities of SSAFA;
• that SSAFA’s independence is not compromised by its fundraising activities.

The Council (or its delegated representatives) will accept any donation offered to SSAFA (save as described below in section Refusal Criteria).

The law allows practical and ethical factors to be considered where they are relevant to SSAFA’s objects, notwithstanding:

• trustees are required to accept charitable donations unless the acceptance of the donation would not be in the best interests of SSAFA (i.e. to relieve the need, suffering and distress of our armed forces, veterans and their families);
• trustees have a duty of care to consider whether SSAFA’s interests will be better served by acceptance or refusal of donations;
• in exercising this power, trustees must not allow personal views or prejudices to affect their conduct and decisions;
• trustees must be able to demonstrate that they have acted in the best interests of SSAFA, irrespective of their personal views and interests, in all cases.
• In exercising this duty of care and in representing the best interests of SSAFA, trustees have delegated the day-to-day (or, ‘operational’) decision-making authority to the senior management team’s Management Board broadly, and to the Director of Fundraising, Marketing & Communications in matters of specific relevance to fundraising activities and partnerships.

SSAFA may refuse a donation, partnership or fundraising opportunity where acceptance would not be in the charity’s best interests, including where one or more of the following considerations apply.

Legal, regulatory or policy risk

The donation or opportunity arises from criminal activity, money laundering, bribery, corruption, or other activity that would breach relevant legislation, government guidance or SSAFA policy.

The opportunity conflicts with the Counter Fraud, Bribery and Corruption Policy, fundraising regulation, data protection requirements or other applicable regulatory obligations.

The donation or opportunity is associated with a political party or political activity, except where expressly permitted by law and consistent with SSAFA’s charitable objects.

The proceeds derive from gambling activity arranged outside the UK which, if arranged in the UK, would require registration with the Gambling Commission, unless the activity is appropriately licensed, regulated and permitted to advertise in the UK.

Acceptance would be inconsistent with government policy or Charity Commission guidance.

Values, mission or beneficiary impact

The donor’s activities conflict with SSAFA’s charitable objects, values, policies or duty to beneficiaries.

The donation, partnership or associated activity could be directly or indirectly harmful to SSAFA’s beneficiaries, supporters, partners or stakeholders.

Reputational or ethical risk

Acceptance could adversely affect SSAFA’s reputation, independence, public confidence or longer-term fundraising prospects.

The opportunity could bring SSAFA into disrepute or involve the charity in controversy likely to damage its reputation or standing.

Financial or practical proportionality

The financial, administrative or reputational cost of accepting the donation or opportunity is likely to outweigh its value to SSAFA.

To ensure that cause-related promotional and marketing efforts properly reflect the values of the charity, any initiative that is deemed potentially contentious must first be approved by the Executive team and, if necessary, the Council.

Any partnership with a commercial organisation that involves the sale of a product or service to raise money for SSAFA and uses the organisation’s logo must be covered by a commercial participation agreement in line with the Code of Fundraising Practice.

This includes, but is not limited to:

• Digital fundraising platforms
• Third-party online fundraising tools
• Retail, e-commerce and product partnerships
• Affiliate or branded commercial arrangements

Once a donation has been accepted, then generally it can only be returned:

• if the terms and conditions of the gift provide for it to be returned in particular circumstances; or
• where the law specifically provides for the gift to be returned in particular circumstances; or
• by way of an ‘ex-gratia payment’ (a payment made as a result of a compelling moral, but not legal, obligation). This type of donation return is only permissible where SSAFA has received an order from the Charity Commission for England and Wales.
• In Scotland, different rules cover the provision of ‘ex-gratia payments’.

SSAFA will not knowingly purchase goods and/or services produced and delivered under conditions which involve any form of abuse or exploitation by/of third parties.

Examples (not definitive) of such abuse and exploitation include:

• the employment of child labour;
• the failure to pay employees a living wage; and
• evidence of any form of inhuman, unreasonable or discriminatory treatment of employees.

All fundraising and partnership activity is subject to SSAFA’s Complaints Policy.

SSAFA recognises the right of individuals to escalate concerns to the appropriate external body, including:

• The Fundraising Regulator
• The Charity Commission
• The Information Commissioner’s Office (ICO)

All colleagues and representatives are responsible for applying this policy in practice and escalating concerns where appropriate.

The FMC Directorate is responsible for:

• the operational application of this policy;
• ensuring compliance with fundraising standards; and
• advising on high-risk or complex decisions.

Before accepting or refusing a donation, partnership or fundraising opportunity, decision-makers should use the following checklist alongside the refusal criteria above:

• Does the opportunity align with SSAFA’s values and charitable objectives?
• Does it present a reputational, ethical or regulatory risk?
• Is the proposed use of data and supporter communication compliant?
• Are the associated costs proportionate to the likely benefit?
• Does the matter require escalation?