Handbook of Procedures Manuale delle procedure
PG SPONS Procedure for sponsorships and donations 1. Purpose of the procedure 2. Definitions 3. Scope of the procedure 4. Operating methods for the management of sponsorships 5. Operating methods for the management of donations 6. Filing 1. Purpose of the procedure The purpose of this procedure is to regulate the management process for sponsorships and donations granted by Fondazione Fiera Milano to third parties, in line with the selected strategic approaches. 2. Definitions The term (cause-related) sponsorship refers to any payment made to financially support an event, an activity or an organization in exchange for displaying the business name / official logo / trademark of Fondazione Fiera Milano through the media in specific advertising spaces and/or using various communication supports. 2
This means that sponsoring does not include individual contributions granted as gifts, without any contractual undertaking to display Fondazione s official logo. By donations reference is made to cash, goods and/or services granted in favor of specific beneficiaries with a view to supporting projects which are considered worthy in terms of social, cultural, economic and environmental development and consistent with the business purpose, values and principles of Fondazione. 3. Scope of the procedure Sponsorships and donations shall be granted to authorities/associations/foundations which can prove to be qualified and reliable, after stipulating the relevant agreements and checking the beneficiary s good professional standing; no sponsorships or donations should be granted to counterparts even just suspected of organized crime connections, or if there is any legal action underway to ascertain their responsibility pursuant to Lgs. D- 231/01. When managing this procedure, Fondazione is required to pay specific attention to possible conflicts of personal or corporate interest, in full compliance with the rules listed below. Below is a list of entities which are expressly excluded from sponsoring and donations by FFM: authorities and organizations which have not been officially incorporated by means of a duly registered official document; parties and political organizations; trade unions or aid offices; 3
entities which directly or indirectly conduct political propaganda activities that are aimed at influencing the law-making process or electoral campaigns; entities whose purpose is to limit the freedom and dignity of citizens or to promote any form of discrimination; private individuals; wherever there appears to be a conflict of interest with the work done by FFM or with members of statutory bodies at FFM. Any request for sponsorship and donations in favor of public authorities and entities whose organization or company structure includes persons related to Public Administration offices needs to be assessed and approved by the Executive Committee and then promptly notified to the Supervisory Body (SB). In view of its statutory purposes, priority shall be given by FFM to all those actions whose objectives can be traced back to promoting cultural, scientific, training, community and trade fair exchanges within the region of Lombardy, with specific reference to the Greater Milan area, as well as at domestic and international level. All of the sponsoring activities carried out have be consistent with Article 1 in Fondazione s Articles of Association, for the purpose of enhancing and consolidating the image and good standing of FFM. When managing sponsorship activities it will be possible to start specific partnerships also with other foundations. Having regard to the management of donations - by means of example and including, but not limited to - the latter shall be granted in favor of initiatives aimed at economic, social, cultural and scientific development or requalification of the area, by means of donations as stipulated according to the subsidiarity principle referred to in Section 1, paragraph 4, of Fondazione s Articles of Association. 4
Generally speaking, the sponsorship and donation initiatives shall never involve behaviors which clearly suggest any intention to receive or give unfair advantages, or which create assumptions or factors of illegality or immorality, or which might jeopardize the integrity or good name of one of the parties and affect the beneficiary s independent judgement. 4. Operating methods for the management of sponsorships The ceiling/plafond for sponsorship proposals needs to be specifically included in the budget for the Communication and External and Institutional Relations Area (REI), as part of the objectives set in the relevant three-year Budget Plan and Report for the fiscal year in question. More specifically, the overall amount of sponsorship allocations is established by the Executive Committee when drafting the budget, taking into account the total funds that can be made available by Fondazione Fiera Milano. The requests for sponsoring or donations taken into account include the following: sponsoring as Lead Partner of events and projects with a high cultural, artistic and social prestige; sponsoring of organizations that are involved in scientific research, support and assistance to the community and environmental protection activities. Any person or corporate Area at Fondazione receiving a request for sponsorship from a third party is required to notify the Chairman and the General Manager. The general Management shall then submit any proposals it has received to the in-house board which is known as Sponsorship and Donations Committee (hereinafter also COSEL). 5
COSEL consists of Chairman, General Manager, Governance and Communication Area Manager, Study and Research Area Manager, Finance and Control Administration Area Manager (AFC), Legal Area Manager and Technical Area Manager. The proposal requires a simple majority of participants for approval (regardless of how many are attending); minutes shall be kept for each COSEL session. All approved proposals are forwarded to the REI-Communication Area which evaluates them jointly with the Legal and Corporate Area Manager and the AFC Area depending on their respective competences. Before a sponsorship agreement is signed, the REI-Communication Area notifies the Legal and Corporate Area which runs checks on the potential beneficiary according to the procedure in the register of suppliers (PA AF). The decision regarding sponsorship selections needs to be taken within no more than 60 working calendar days starting from the date on which approval has been given by COSEL. In order to be admissible for evaluation, projects need to meet the following requirements: all documents certifying the reasons for the sponsorship and their compliance with the criteria stipulated in the Scope of application for this procedure must be attached; the request shall be submitted at least 90 in advance of the starting date scheduled for the event and/or project; consistency with the aims pursued by FFM needs to be proved; generic non-targeted projects shall be specifically excluded; co-funding by the proposing entity shall cover no less than 70% of the total estimated expenditure. 6
Admissibility of requests in the assessment phase, moreover, needs to be verified on the basis of the following conditions: during one calendar year FFM is not allowed to finance the same project more than once; during one calendar year FFM is not allowed to finance the same entity more than once; no sponsorship may be granted unless the potential beneficiary has submitted a comprehensive report as to any projects completed using funds previously provided by FFM. In addition to the provisions in the paragraph above, if the sponsorship concerns specific research projects (for example in the area of physics and/or medicinescience) the financial commitment shall be for no more than three years and cofunded projects are admissible. The beneficiary of sponsoring from FFM agrees to mention the financial support provided by the latter in the relevant official documents. The REI-Communication Area is expected to contact the sponsored third party to coordinate all the work necessary to promote the project, as well as to make sure that FFM is given adequate visibility, in terms of its own logo and of its media exposure. The REI-Communication Area shall draft and send to the Supervisory Body every six months, through its Legal Department, a report summarizing the sponsorships granted by FFM in the course of the fiscal year, detailing the following specific elements: applying entity / beneficiary of the sponsorship; 7
counterpart within the applying entity / beneficiary, specifying any employment relationship with Public Administration offices; nature/type of event being sponsored; aims/purpose; amount/value paid out in total; date of the event; date on which the sponsorship is paid; entity possibly promoting the initiative; checking, also on a temporary basis of the correct allocation of funds and compliance with the agreement by the beneficiary. The sponsorship fee which is paid to the sponsored entity includes all or part of the amounts required for the event being sponsored; this will be done only after a specific agreement to that extent has been signed. The sponsored entity, once the relevant payment has been cashed, shall issue invoices or fiscal receipts according to the sponsorship agreement. More specifically, after the sponsored initiative has been completed, the beneficiary shall send to the REI-Communication Area at Fondazione, for the appropriate checks, a detailed report in writing and fully documented regarding the correct allocation of everything it has received, detailing the amounts used and the projects completed. If the sponsored entity fails to promptly send to the Communication Area the said documentation, the latter shall immediately report to COSEL and to the SB. The REI-Communication Area shall: 8
file and keep suitable documentation to prove that the sponsorship has been granted according to the terms approved; check that the sponsorship corresponds to the agreements undertaken; request, if possible a feedback report in qualitative and quantitative terms about the outcome of the sponsorship. If the REI Communication Area should notice that the sponsorship actually granted does not correspond to the agreements which were undertaken with the sponsored entity, it shall immediately report this to COSEL and to the Supervisory Body. The Administration office pays the invoices in accordance with the Procurement procedures. Moreover, no later than the annual deadline and while the budget is being drafted, COSEL is expected to arrange a meeting to review the work done during the year in question and make the relevant planning decisions for the following year. 5. Operating methods for the management of donations FFM shall subsidize selected initiatives organized by third parties based on their similarity and consistence with the objectives set in the three-year RPP Budget Plan and Report in force. The main operating instruments are: patronage, paid or free of charge, in support of cultural and training events or performances; co-funding of projects or actions with ongoing purposes. 9
The person at Fondazione who receives a request for a donation from a third party shall inform the Chairman and General Manager. The general Management then submits any proposals received to COSEL: The proposals received are assessed on a regular basis by COSEL. The ones that are approved are forwarded to the REI-Communication Area which reviews them in coordination with the Manager of the Legal Area and of the AFC Area depending on their respective competences. Before the agreement becomes official, the Communication Area shall notify the Legal and Corporate Area which checks the beneficiary for compliance with the register of supplier procedures (PA AF). The ceiling/plafond for donations needs to be specifically included in the budget for Institutional Relations activities, as part of the objectives that are set in the Budget Plan and Report in force for the fiscal year to which the donation refers. The total amount of donations requires prior approval by the Executive Committee as part of the budget, taking into account the overall funds available to Fondazione Fiera Milano. The REI-Communication Area, with the support of the FFM bodies in charge, shall then: file and keep suitable documentation aimed at proving that the donation has been made according to the terms agreed; monitor and benchmark the actions based on the following criteria: transparency as regards the methods and timing for delivery of the funding granted; progress reporting on the projects which have been subsidized; review of the results achieved; compliance with privacy regulations. The subsidy requests taken into consideration shall include: 10
co-funding of highly relevant events and projects from a cultural and social perspective; membership of well-established cultural associations, foundations and authorities with an outstanding reputation; support to organizations involved in scientific research, help and assistance to the community and environmental protection. In order to be admissible for assessment, the projects need to meet the following requirements: all documents certifying the reasons for the donation and their compliance with the criteria stipulated in the Scope of application for this procedure must be attached; consistency with the aims pursued by FFM; the donation may not be used for the purpose of covering previous debts; generic non-targeted projects shall be specifically excluded; Admissibility of the applications to the evaluation phase, moreover, needs to be assessed based on the following conditions: during one calendar year FFM is not allowed to grant more than one donation for the same project; during one calendar year FFM is not allowed to grant more than one donation to the same entity; no donation may be granted unless the potential beneficiary has submitted a comprehensive report as to any projects completed using funds previously provided by FFM. The beneficiary of a donation from Fondazione shall mention this in the relevant official documents. The beneficiary is also required to send to the REI-Communication 11
Area at Fondazione, within the next 30 working days, a written report showing that the funding received has been properly allocated. In the event that the beneficiary should fail to issue the aforesaid documentation or that the projects completed should appear not to be compliant with the required criteria, the REI-Communication Area shall immediately notify the Chairman, the General Manager, the Sponsorship and Donations Committee and the Supervisory Body. Finally, the REI-Communication Area shall file and keep all the documentation aimed at proving that the donation has been actually granted in accordance with the terms agreed. The REI-Communication Area shall draft and send within the annual deadline to the Supervisory Body a summary report of the donations granted by Fondazione in the course of the fiscal year, including the following details: applying entity / beneficiary of the donation; counterpart within the applying entity / beneficiary, specifying any employment relationship with Public Administration offices; nature/type of the event in respect of which the donation is granted; aims/purpose; amount/value paid out in total; date of the event; date of the donation; entity possibly promoting the initiative. 12
6. Filing All of the relevant documents pertaining to the activities referred to in this procedure must be kept by the REI-Communication Area for a period of ten years or for any other length of time which may be stipulated depending on specific regulatory provisions. 13