Gift Acceptance Policy
Document status: Live
Version number: 2.0
Effective date: November 2025
Purpose and Scope
This document seeks to layout a Gift Acceptance Policy for Green Templeton College’s Development and Alumni Relations Office (“Development Office”). Fundraising is a key element in furthering and supporting the life and work of Green Templeton College (“GTC”).
The University’s policy on Gifts and Hospitality can be found online
GTC recognises that fundraising, and philanthropic activities are the main function and purpose of the Development Office. This document outlines the principles to define standard procedures for the solicitation and acceptance of philanthropic gifts to support GTC and shall apply to all gifts offered to, and received by, the College.
Definitions
Donations are understood to refer to money, gifts in kind (goods or services), stocks and shares, property or offers of help for introductions. The Development and Alumni Relations System (DARS) provides a common source of data on all alumni, donors, students, staff and friends of the collegiate University.
Legal Basis
Green Templeton College is a Registered Charity. As a registered charity, the College must observe the requirements of charity law and other relevant legislation in relation to the receipt and expenditure of funds. As a registered charity this includes the ability to recover tax deducted from deeds of covenant and receipts under Gift Aid, exemption from Inheritance Tax for Donors to the institution, and exemption from Capital Gains Tax.
Statement of Principles
The objective of the Gift Acceptance Policy is to ensure that GTC accepts gifts that are in line with its charitable purposes and are not in conflict with its principles. Steps in the College’s Due Diligence Policy should be followed to provide an initial screening report on the individual or organisation for approval at the appropriate level in college.
In general terms the College will not accept significant gifts from anonymous individuals or from individuals or organisations that lead to a perceived or actual endorsement of illegal activities or involve unlawful discrimination or would lead to reputational damage to the College.
Principles
- GTC will be transparent about the sources and purposes of gifts received.
- GTC will only accept donations from students, or family members of current students, if there is no inappropriate personal or academic gain, or perceived gain, for the student from making such a donation.
- GTC will only accept donations from a donor who has the mental capacity to decide to make the donation.
- GTC will not accept donations:
- That are inconsistent with the College’s charitable purposes or if any conditions attached to accepting the gift outweigh its value to the College.
- That impose conditions that require the return of all or part of the original donation.
- From anonymous sources, however, anonymity will be respected provided the name of the donor is known to the Director of Development, Principal and the Governing Body.
- If the proposed donation arises in whole or in part from any illegal activities or from activities that would lead to damage to the reputation of the College. Dependent upon the size of the donation, decisions concerning whether to accept will be made with reference to Table 1.
- If accepting the proposed donation will require any illegal action on the part of GTC.
- If accepting will restrict academic freedom or limit freedom of enquiry.
- If accepting will create a conflict of interest, that cannot be managed, with a college member or the University.
- If accepting will cause harm to the reputation of the College or to the name of the University.
- If accepting will damage the College’s relationship with other beneficiaries, students, benefactors, partners, staff, collegiate community, the university or other stakeholders.
Gift Acceptance Approval Process
The College will have due regard to the University policy relating to the University of Oxford Committee to Review Donations and Research Funding (CRDRF). If significant concerns are raised about a new Donor or proposed donation, the College may seek guidance from the CRDRF on whether the donation should be accepted. Any donation which, in the opinion of the Governing Body (following referral by the Director of Development and the Principal), has the potential to have harmful reputational implications to the College or the University should be referred to CRDRF for review.
It is not mandatory for the College to refer any potential donors for review by the CRDRF, however it is suggested for donations of £1 million or above, or if there are significant concerns regarding the donor.
The potential donor details should be referred in the first instance to the CRDRF via the University Prospect Research Team – research@devoff.ox.ac.uk. It may be that the donor already has approval from the CRDRF, in which case the University Development Office (via the email address above) will inform the College straight away.
The CRDRF meet ten times during the year and require a 5-7 week lead time for considering any donations. It is possible that the donor has already been approved by CRDRF, in which case the Prospect Research Team will inform straight away.
All donations should be referred to the appropriate level in college for approval, with reference to Table 1, prior to acceptance.
Table 1. Gift thresholds with required approval levels
Level of Gift | Lead | Gift Agreement | Approving person or body |
>=£1m | Principal | Drawn up by the legal team of the donor or the college. | Governing Body on recommendation of Risk and Scrutiny Committee |
>=£100k to <£1m | Director of Development | Gift Agreement drawn up by the Development Office. | Principal |
>=£5k to <£100k | Head of Development | Gift Agreement drawn up by the Development Office if required by the donor or the Director of Development. | Director of Development |
<£5k | n/a | Not required unless requested by the Director of Development. | Head of Development Operations |
The Development Office, in conjunction with the Principal of the college and the Governing Body is responsible for reviewing all matters or instances where a proposed gift may not be acceptable within the meaning of this policy, or otherwise not in the best interests of the College. When considering any proposed donation or gift, the Development Office will, alongside the Principal of the college, operating in line with this policy, pay due regard to the College’s charitable status and the duties and responsibilities of the Trustees of the College. They will also need to consider the duty to act in the College’s best interests and the duty to act with reasonable care and skill.
For significant gifts (any that fall within the definitions in Table 1) a Gift Agreement summarising the donor’s name, and contact details, the amount and date of the gift, purpose, payment schedule (if appropriate) and duration of spend (as a minimum) should ideally be produced by the Development Office and acknowledged by the Donor.
A record will be kept of donations and gifts received by the College or Development Office in DARS. The donation will also be discussed with the Finance office to ensure that funds are correctly allocated in the College accounting system.
Returning a Donation
Guidance concerning provisions in charity governance documents that would allow GTC to legally return a donation are provided by the Charity Commission at Accepting, refusing and returning donations to your charity.
It may well be necessary to seek legal guidance before attempting to return a donation
It should be confirmed that the GTC governance documents provide a general power to return donations, this will be something along the lines of:
- The power to do anything which is calculated to further your charity’s purposes or is conducive or incidental to doing so.
- The power to do any lawful thing that is necessary or desirable for the achievement of the objects.
As brief guidance, these are some of the reasons GTC may consider returning a donation:
- Donation was for activities outside the purposes of the charity.
- There is a risk of a legal claim.
- There is a risk to the independence of GTC,
- The donation has unacceptable burdens linked with it.
- The donation comes with a private benefit to the donor.
- There is a reputational risk to GTC or the University.
Ethical Fundraising Practices
All philanthropic fundraising individuals who solicit or receive funds on behalf of GTC will:
- Adhere to the provisions of applicable law: the General Data Protection Regulation ((EU) 2016/679), the Data Protection Act (2018), Freedom of Information Act (2000), Bribery Act (2010) and Charities Act (2011), and professional codes of ethics and standards of practice such as the Charity Commission guidelines (https://www.gov.uk/guidance/fundraising-legally-and-responsibly and https://www.gov.uk/government/publications/charities-and-fundraising-cc20) and the Fundraising Code of the Fundraising Regulator.
- Adhere to the principles laid out in this policy.
- Act with fairness and integrity and take all reasonable steps to treat a donor fairly.
- All philanthropic donations will be used as agreed with the Donor, except as otherwise permitted by law. As appropriate, a Gift Agreement or Statement of Donor Wishes will be produced, setting out the purpose, direction, and terms of the gift as agreed between the Donor and the College.
- Where funds can no longer be used for a purpose within the original designation of the donation, the College may seek to repurpose the restricted funds, which will be done according to the processes required in charity law. In such cases the College will seek to discuss the proposed change of purpose with the Donor or Donor’s legal designate(s).
- Provide truthful information about fundraising activity.
- Immediately cease solicitation of a prospective Donor on request.
- Not accept philanthropic donations for purposes that are inconsistent with the College’s mission.
- Report immediately to the Director of Development, Principal, Bursar and/or Governing Body any philanthropic donations which they consider to be a cause for concern and any actual or apparent conflict of interest, that cannot be managed, as a result of the College accepting a donation.
- Comply with the Charity Commission’s guidance on serious incident reporting in relation to suspicious donations.
