Greenwich Peninsula Islamic Centre: Donation Acceptance Policy

Policy Date: 20 June 2025

Next Review Date: 19 June 2026

1. Purpose

This policy ensures that all donations to the Greenwich Peninsula Islamic Centre (hereafter "the Centre") are received, processed, and applied in a manner that is transparent, legally compliant, accountable, and consistent with the Centre's charitable objects.

This policy exists to:

  • Protect the Centre from financial fraud, reputational damage, and conflicts of interest.

  • Ensure compliance with UK law, including the Charities Act, Data Protection Act 2018 (GDPR), and the Money Laundering Regulations 2017.

  • Uphold the trust (Amanah) placed in the Centre by its donors and community.

  • Maintain the authority and integrity of the Board of Trustees in managing the Centre’s finances.

2. Scope

This policy applies to all trustees, staff, volunteers, and agents of the Centre, and covers all forms of donation, including (but not limited to) cash, bank transfers, online payments, card payments, in-kind gifts, and pledges.

3. Core Principles

  • Trust (Amanah): All donations are accepted as a trust to be used for the benefit of the community and in accordance with our charitable objects.

  • Integrity: The Centre will not knowingly accept donations from sources that are illegal or haram (forbidden).

  • Transparency: All donation handling will be open, honest, and accountable.

  • Trustee Duty: The Board of Trustees has the ultimate responsibility for all donations and must act in the best interests of the Centre, independent of any external influence.

4. Roles and Responsibilities

  • Board of Trustees: Holds the ultimate responsibility for this policy. The Board has the final decision to accept or refuse any donation.

  • Treasurer: Responsible for overseeing the donation process, ensuring accurate records, conducting due diligence, and reporting to the Board.

  • All Trustees, Staff & Volunteers: Must not accept donations personally. They must immediately direct donors to the Centre’s official donation channels and inform the Treasurer of any donation offers or irregularities.

5. Donation Acceptance Procedures

5.1. Official Donation Channels

To ensure security and proper recording, donations must be made through one of the following official channels:

  • The Centre's official bank account via transfer.

  • The official online donation page (e-form) on the Centre's website.

  • The official contactless card donation terminal(s) located on the Centre's premises.

  • Sealed and secured donation boxes located on the Centre's premises.

5.2. Personal Acceptance of Donations (Prohibition)

No trustee, staff member, or volunteer may accept a donation (especially cash) directly by hand. Any donor attempting to give cash directly must be politely redirected to an official channel. If a donor insists on handing over a donation, the individual must:

  1. Not accept the donation for personal keeping.

  2. Immediately escort the donor to the Treasurer or another senior trustee to log the donation.

  3. Ensure the donor completes the Donor Information E-Form immediately, as a condition of receipt.

5.3. Donor Information (Mandatory)

All non-anonymous donations require the completion of the Centre's Donor Information E-Form.

  • This form is mandatory for compliance, financial recording, and Gift Aid.

  • No donation will be formally processed or allocated to the Centre's funds until this form is fully completed and received. The funds will be held securely in suspense.

5.4. Unrestricted vs. Restricted Donations (Default Policy)

  • To ensure the Centre can meet its most critical needs, all donations received will be treated as unrestricted (Sadaqah/Lillah) by default. These funds will be used for the Centre's general charitable purposes at the discretion of the Board of Trustees.

  • The Centre will not accept donations restricted to a specific project, activity, or individual unless it is part of a formal, Board-approved fundraising appeal.

  • The Board reserves the right to decline any restricted donation that is not aligned with the Centre's priorities, creates a conflict of interest, or undermines the Board's authority.

6. Due Diligence and Money Laundering

6.1. "Know Your Donor" (KYD)

The Centre will take reasonable steps to verify the identity of donors. This is a legal requirement to prevent money laundering and protect the Centre's reputation.

6.2. Cash Donations

  • Cash donations are strongly discouraged, except via the official, sealed donation boxes.

  • For any cash donation received outside a donation box (in exceptional circumstances and only via the Treasurer), the Donor Information E-Form is mandatory, regardless of the amount.

  • For cash donations exceeding £10,000 (or cumulative donations from one source exceeding this amount in 12 months), the Centre is legally required by the Money Laundering Regulations 2017 to conduct enhanced due diligence, including verifying the donor's identity (e.g., via photo ID) and the source of the funds.

6.3. Anonymous Donations

  • Small, anonymous cash donations are accepted via the sealed donation boxes. The Centre cannot issue receipts for these donations.

  • Small, anonymous donations are accepted via the contactless card terminals.

  • The Centre will not accept large anonymous donations (e.g., over £100) outside of these official, secure channels.

7. Specific Islamic Donations

  • Zakat: Zakat donations are accepted and welcomed. These funds will be strictly segregated from all other funds (Sadaqah/Lillah) in a separate Zakat bank account. Zakat funds will be distributed strictly in accordance with Shari'ah principles to eligible recipients.

  • Sadaqah & Lillah: These will be treated as unrestricted funds for the general purposes of the Centre, unless given to a specific, Board-approved appeal (e.g., "Ramadan Food Drive").

8. Refusal and Return of Donations

The Board of Trustees reserves the right to refuse or return a donation at its discretion.

Mandatory grounds for refusal include:

  • The donation is from an illegal or haram (e.g., from proceeds of crime, gambling, alcohol) source.

  • The donation is suspected to be an act of money laundering.

Discretionary grounds for refusal include:

  • Accepting the donation would damage the Centre's reputation or put off other donors.

  • Accepting the donation would create a conflict of interest or be seen to undermine the authority of the Board of Trustees.

  • The donor's conditions are incompatible with the Centre's charitable objects.

  • The donor refuses to complete the mandatory Donor Information E-Form (for non-anonymous donations).

9. Data Protection

All information collected from donors will be held securely and processed in full compliance with the UK Data Protection Act 2018 (GDPR) and the Centre's Privacy Policy.

10. Policy Review

This policy will be reviewed annually by the Board of Trustees, or sooner if required by changes in legislation or best practice.