Fundraising Due Diligence Policy

This policy is relevant to any business, corporation or corporate foundation that wishes to make a donation to or establish a partnership with SAS.

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Surfers Against Sewage (SAS) is a nationwide marine conservation and campaigning charity that has been protecting the UK’s inland and coastal waters and the people who rely on them for livelihood creation, recreation, excitement and solace for over 33 years.

We believe that we can best serve our mission and values when we have a diverse funding base, which includes support from appropriate businesses and corporate organisations. It is, therefore, important to have a robust and transparent decision-making process for accepting donations.

The Fundraising (FR) Due Diligence Process aims to identify any potential risks to our objectives, programmes, reputation, or brand associated with accepting a donation. This will also ensure that potential partnerships add value and complement our work in protecting the UK’s marine environment whilst aligning with our mission and values.

We are realistic and understand that businesses are at various stages in their journey with sustainability. We welcome partners committed to working together towards a healthier ocean, even if they’re only just starting out.

This policy sets the standards for SAS’s commitment to due diligence in line with charity law, the Fundraising Regulator Code of Fundraising Practice, and our organisational values.

Responsibility for the Policy 

The SAS Board of Trustees (Board) has the overall responsibility to ensure that decisions are made in the best interest of the charity and our beneficiaries and are in line with this policy.

The Board delegates the day-to-day implementation of this policy to the Director of Fundraising and Philanthropy & Partnerships Manager. The Philanthropy & Partnerships Team is responsible for bringing relevant potential support and the appropriate level of research forward to their attention using FR Due Diligence Process summarised below.

The Director of Fundraising and Philanthropy & Partnerships Manager are responsible for the approval of higher-risk donations and support the practice of referring the highest-risk cases either to the Senior Leadership Team or to the Board for final approval.

Private Sector Donations Acceptance and Refusal

This policy is relevant to any business, corporation, corporate foundation or other type of organisation that wishes to make a donation to SAS. Donation is defined as financial including sponsorship, as well as gifts in kind and pro bono support.

SAS can and will only accept lawful donations. We cannot accept a donation where it is known that the donation comprises the proceeds of crime, including suspicion of money laundering.

When considering whether to accept or reject a gift or engagement, SAS will assess if the contribution will benefit our work without compromising or causing direct harm to the environment (specifically water quality, plastic pollution, climate change and/or marine protected areas) and our wider mission, values, independence, reputation and credibility.

We reserve the right to return or refuse donations in addition to terminating partnerships where the activities of the organisation directly conflict with the mission and/or purposes of  SAS, as set out in our Articles of Association.

Sectors that SAS will not engage with

We will not accept any donation linked to activities that are inconsistent with our charitable aims. Our “Exclusion List” consists of sectors we deem harmful to the environment and society. This includes:

  • Airlines
  • Arms Trade
  • The Dirty Dozen as per the latest SAS Brand Audit Report
  • Extractive Industries including mining and fossil fuels
  • Fast Fashion Industry
  • Industrial Fishing
  • Intensive Agricultural farming
  • Intensive Animal Farming
  • Meat Production
  • Pornography
  • Tobacco including vaping
  • Water Companies

SAS recognises the inherent complexity of certain industries and will, therefore, make reasonable checks to understand any potential areas of nuance before reaching a well-informed decision regarding donation acceptance. Definitions of each of these sectors are provided as part of the process below.

Process for following this Policy

SAS has developed a standardised FR Due Diligence Process to assess potential partners or donations, considering both risks and their alignment with our mission relative to the proposed value the partnership will bring. A risk-based tiered approach to due diligence allows us to allocate resources efficiently while proportionately tailoring the procedures to each assessed organisation and the proposed engagement.

All organisations will be initially assessed via Tier 1: Basic Screening and will be escalated through the subsequent due diligence tiers as necessary. These tiers are summarised as follows:

Tier 1: Basic Screening – The aim of Basic Screening is to quickly confirm that the organisation’s sector or main business activities are not listed on the Exclusion List, that there is no reason to believe that accepting this donation would be unlawful or that there are no other major concerns.

Tier 2: Risk Categorisation – Risk Categorisation aims to quickly identify the level of potential risk associated with the proposed engagement in order to understand if further investigation is required with what level of authoritative approval. To do this, a Risk Categorisation Checklist and Engagement Matrix are used.

Tier 3: CRA – Comprehensive Risk Assessment (CRA) includes the use of the Due Diligence Risk Assessment Form to provide a comprehensive understanding of the key areas of risk with decision-making approved at the appropriate level as determined through the Engagement Matrix.

Depending on the scale of due diligence necessary, research will cover organisational, environmental, reputational, political, legal and financial topics to inform decision-making.

Due diligence will be conducted at the outset of the development of the relationship with the organisation. For cases requiring Tier 3 Due Diligence, the resulting decision will be communicated back to the organisation within 10 working days.

As with all corporate engagement, SAS will maintain its right to an independent advocacy stance. This will be made clear to all companies at the start of any partnership.

This policy will be reviewed regularly and is subject to change without notice.

Privacy Policy

Any information collected as part of the FR Due Diligence Process is securely managed and stored in line with SAS’ Privacy Policy.

More information

If you would like any more information on this policy and SAS’ commitments to due diligence, please get in contact with Tabitha at [email protected].