Appendix 1 FUNDRAISING POLICY

Appendix 1 FUNDRAISING POLICY

Policy Title: FUNDRAISING POLICY Executive Summary: This policy aims to give a general overview of how fundraising for East Cheshire NHS Trust s charity ECHO (East Cheshire Hospitals and Community Healthcare Charity) operates and help all trust staff understand their general duties and legal responsibilities in relation to any fundraising activities undertaken. It also provides guidance in relation to fundraising involving partner organisations and third parties. Fundraising Policy V3 Scheduled update Supersedes: Description of Amendment(s): This policy will impact on: All trust staff Supporters of trust fundraising Partner organisations involved with fundraising Financial Implications: Income for trust Charitable funds Policy Area: Trust-wide Document Reference: Version Number: Issued By: Author: APPROVAL RECORD ECT002788 3.0 Effective Date: June 2017 Julie Green, Director of Corporate Affairs and Governance Fiona Doorey, Head of Communications, Engagement and Marketing Review Date: February 2020 Impact Assessment Date: December 2017 Committees / Group Date Consultation: Corporate Affairs and May 2017 Governance Managers Financial Accountant Deputy Director of Corporate Affairs and Governance Charitable Funds Committee Approved by Director: Director of Corporate Affairs and June 2017 (digitally) Governance Ratified by: Director of Corporate Affairs and Governance June 2017 Received for All trust staff June 2017 information:

Table of Contents 1.Introduction 2. Purpose 3. Roles and Responsibilities 4. Processes and Procedures 5. Monitoring Compliance with the Document 6. References 7. Communication Page 11 Page 12 Appendices

1. Introduction While the trust will always ensure its services are safe and meet relevant clinical and quality standards, financing of additional equipment and services from funds outside normal revenue budgets is an important option for NHS organisations. Such funds are normally known as charitable funds. The majority of these funds come from voluntary donations, fundraising initiatives or sponsorship. Fundraising is a legitimate means to enable the purchase of goods, equipment or services which are not currently available within capital or revenue budgets. For the public, donating cash or equipment or actively raising funds is seen as a positive way of supporting local NHS services and often as a way of expressing gratitude for treatment received, or as a way of remembering a loved one who was cared for by the organisation in question. The trustees of ECHO, who manage the charity in line with statutory and regulatory requirements, welcome the contribution that the charity makes to the delivery of services and the welfare of patients, and recognise and value the work of individuals and groups that participate in fundraising events and donate to ECHO. Governance arrangements Charities are governed by a range of legislation and staff are required to adhere to the principles below when organising and carrying out fundraising activities for East Cheshire NHS Trust. This includes but is not limited to: Data protection Charity Commission guidelines The Institute of Fundraising s Code of Fundraising Practice The Consumer Protection from Unfair Trading Regulations 2008 Street collection regulations/laws Regulations/laws relating to lotteries, raffles and sweepstakes If you have any queries, please contact ECHO on 01625 661871. ECHO East Cheshire Hospitals and Community Healthcare Charity (Charitable Funds) Charitable funds consists of: Money donated to the trust in appreciation; Money left in a legacy for the benefit of the trust Money which has been raised through fundraising events; and Money which has been donated as a result of a fundraising appeal. East Cheshire NHS Trust Charitable Funds is a registered charity (1059228) whose principle objective is: ANY CHARITABLE PURPOSE RELATING TO THE NATIONAL HEALTH SERVICE WHOLLY OR MAINLY FOR THE SERVICES PROVIDED BY EAST CHESHIRE NHS TRUST.

2. Purpose The fundraising policy aims to help all staff involved in fundraising to understand the legal responsibilities around fundraising, how the trust fundraises, how to register your fundraising activity to avoid conflicting with a similar activity being held at the same time, your responsibilities and who to contact for guidance. The policy highlights all fundraising activities undertaken by the trust to ensure that they meet all legal requirements. The wide range and scope of fundraising activities makes it difficult to incorporate specific advice on every event undertaken. Instead, the full policy which follows is designed to provide best practice-based guidance on the basic principles and acceptable practices of fundraising on behalf of ECHO. 3. Responsibilities Trustees The Trustees of ECHO have ultimate accountability for fundraising. The Trustees delegate this accountability to the Director of Corporate Affairs and Governance. The Trustees are responsible for ensuring that: Fundraising is carried out legitimately; Expenditure is properly validated; All funds raised are accurately accounted for; and The money is expended in accordance with the objectives of the charity. Director of Corporate Affairs and Governance The Director of Corporate Affairs and Governance has delegated accountability for leading on fundraising and ensuring that robust arrangements are in place to support the charitable funds in line with statutory requirements. Deputy Director of Corporate Affairs and Governance The Deputy Director of Corporate Affairs and Governance is responsible for leading the implementation of appropriate systems and processes that support fundraising and for the line management of the Head of Communications, Engagement and Marketing who has operational responsibility for this function. Finance Director of the Trust The Finance Director of the trust is responsible for overseeing the income for ECHO, and for the implementation of appropriate systems and processes to accurately record income and expenditure and monitor financial controls for the charity. The Corporate Trustee and Financial Accountant Charitable funds have to be accounted for in a different way from other mainstream funding and are subject to a different set of rules and guidance. The control and management of charitable

funds is the responsibility of the Corporate Trustee, managed by the Trust Board executive and non-executive members with authority to spend up to 5k per request delegated to heads of directorate to spend monies on items beneficial to their service area. Head of Communications, Engagement and Marketing The Head of Communications, Engagement and Marketing has operational management responsibility for the management of fundraising activity, ensuring that the systems and processes are implemented and that controls and assurances are in place for any identified risks in relation to this policy. The Head of Communications, Engagement and Marketing is also responsible for monitoring compliance as outlined in Section 5. Associate directors Associate Directors have operational responsibility for approving expenditure within their directorates. Line managers Line managers must ensure that they and their staff members: Adhere to this policy Operate any fundraising in accordance with this policy and Submit any requests for expenditure in line with the process detailed in Appendix 4. All trust staff, volunteers and contractors All trust staff, volunteers and contractors must adhere to this policy and operate any fundraising on trust premises or for trust charity ECHO in accordance with this policy. 4. Processes and Procedures Implementation This policy will be recommended by the Director of Corporate Affairs and Governance and approved by the Charitable Funds Committee of Trustees. Advice and support on the policy will be provided by the ECHO fundraising team. 4.1 Working principles Contact ECHO on 01625 661871 prior to undertaking any fundraising for the charity so we can provide advice, guidance and support promoting your fundraising activity. We can also advise regarding donation routes so that the monies are spent as intended. Fundraising linked to a sponsored activity (eg running a marathon, skydiving, swimming) and/or linked to fundraising for a specific project or piece of equipment is usually much more effective than a general appeal for donations. It is also important to highlight if you are fundraising because of a personal link to trust/general NHS services as potential donors are likely to respond to this.

It is vital to note that absolutely no funds can be claimed from ECHO to cover expenses (eg accommodation costs) incurred as part of fundraising activities for the charity without prior approval. Similarly, funds donated to ECHO via JustGiving and potentially other online donation methods can not normally be recovered or claimed back to cover expenses or share with other charities once transferred. Every care must be taken to set up pages appropriately. Where individual staff members are fundraising for the trust but the event is to be held offsite, prior notification must be given to ECHO on 01625 661871 so members of the team can assist and support your event. We have resources including collection tins and buckets and can support you with press coverage, photography and certificates of thanks. Please also note that while we are grateful to all staff members who carry out fundraising activities for ECHO, activities off trust premises would never normally be covered by insurance held by ECHO or the trust so staff must ensure they source their own insurance as appropriate and adhere to relevant health and safety considerations. 4.2 Fundraising for ECHO, partner organisations and relevant causes Fundraising on trust premises should primarily be focused on ECHO but it is understood that we work closely with partner organisations and therefore fundraising on their behalf is permitted if all relevant rules are followed. Fundraising for the following organisations is permitted on trust premises: ECHO. This is the official trust charity and as such staff fundraising on trust premises should be primarily focussed around it. National and local health-related awareness campaigns, especially those which are linked to trust services and strategies. Examples include but are not limited to: Lung Cancer Awareness Month, Breast Cancer Awareness Month, National No Smoking Day, Movember and Dry January. Fundraising for these events should be shared as deemed appropriate between ECHO and the joint fundraising partner organisation. Where the funds will be split this should be made clear to donors. National charity events may be participated in by trust staff on trust premises but fundraising for these events should be shared as deemed appropriate between ECHO and the joint fundraising partner organisation. Where the funds will be split this should be made clear to donors. Funds received via this route will be directed to general funds. Examples of national charity events include but are not limited to: Red Nose Day, Children in Need, Sports Relief, Genes for Jeans Day, the Poppy Appeal. Charitable or non-profit making organisations which support or work closely with the trust and its services, including the Royal Voluntary Service, Macmillan Cancer Support, CVS Cheshire East and League of Friends of the Macclesfield and Congleton Hospitals. Fundraising for charities or appeals which do not fall into the categories listed above will not normally be permitted on trust premises, however in exceptional circumstances this may take place with the permission of a member of the trust s executive team. Please contact the fundraising team on 01625 661871 to discuss. Please undertake fundraising activities that are aligned with general trust and NHS values, aims and objectives.

4.3 Further general guidance While raising money for general ECHO funds is welcomed, fundraising activities where money is raised for a trust ward, team or department should ideally be linked to a specific requirement, for example the purchase of a piece of equipment which will directly benefit patients or provide enhancements to trust services as donors/sponsors are more likely to respond to fundraising for a specific purpose. Money should be paid into the directorate of the ward or department. Please note - all monies raised for a specific purpose will be allocated accordingly however the trust reserves the right to redirect any surplus funding to general funds for expenditure in other areas of the trust where this may be deemed most needed if required. No collection tins should be displayed within the ward or department without prior permission from the Communications and Engagement Department. Refer enquiries from potential fundraisers who wish to raise funds directly for the trust or your ward or department to ECHO on 01625 661871. Please state clearly in promotional materials such as posters and web pages who will benefit from the fundraising activity and what will be purchased with the money raised or where the money will go to (this must be a registered charity). Do also ensure that ECHO approves all the literature naming the trust as the beneficiary as failure to do this correctly may result in the illegitimate collection of funds. As a registered charity with a total income of more than 10,000 per year, every written or printed communication encouraging people to give to ECHO must state that the organisation is a registered charity and quote its charity number 1059228. Do ensure you comply with the data protection regulations. Read more in Appendix 2. Do inform anyone intending on making a donation to ECHO East Cheshire Hospitals and Community Healthcare Charity that the money should be paid into the Cash Office or donated via the ECHO page on JustGiving: https://www.justgiving.com/echeshirenhscharitablefund Alternatively cheques only (cash should not be posted) should be posted to: ECHO East Cheshire Hospitals and Community Healthcare Charity Cash Office Macclesfield District General Hospital Victoria Road Macclesfield SK10 3BL * Please make clear which directorate, ward or department the money is intended for. 4.4 Items and assets donated by third parties Items and equipment which may be funded by other organisations/charities (e.g. League of Friends) should ordinarily be purchased using the usual trust charitable funds procurement systems, with written confirmation from the other organisation that they are willing to reimburse the agreed cost. In this way ECHO is able to utilise the national NHS procurement contracts to obtain best value for money and ensure the purchases meet trust standards. If an organisation or individual wants to donate assets, before accepting them please ensure they adhere to trust standards by contacting the relevant department (e.g.risk management, fire safety etc.) Also, do ensure the Finance Department are aware of all potential donated assets (equipment, furnishings) by contacting them via on 01625 661591.

4.5 Staff must not: Fundraise for other charitable organisations which do not meet the definitions outlined in 4.3 onsite. Staff members may wish to raise funds for charities linked to their own personal, political and/or religious beliefs off-site and in their own time, however any fundraising undertaken by staff on trust premises must be linked to the objectives of the trust and wider NHS/partner organisations. Undertake inappropriate fundraising activities which attract adverse publicity for the trust, potentially damaging its reputation and undermining public/patient confidence in our services. Please call ECHO via 01625 661871 if you are at all unsure. Impose participation in fundraising activities on any individual. Carry out fundraising activities which interfere with your scheduled hours of work without the express permission of your line manager. Display any collection tins within wards or departments which are for charities other than ECHO East Cheshire Hospitals and Community Healthcare Charity. (this may be permissible on a short-term basis during joint fundraising activities). 4.6 Requesting funds Please see the form and guidance in appendix 3 for details of how to request funds from ECHO. 4.7 Fundraising offsite for other charities or organisations Employees participating in fundraising for other charities or organisations must do so in their own time and offsite. For your own safety we recommend you should check that the organisers of any such activities have carried out a suitable risk assessment and carry the requisite insurance. Such fundraising activities may be highlighted via the trust s staff newsletter and other communication channels but this must be at the discretion of the Communications Team and should avoid direct appeals for donations. Please call the Media and Communications Manager on 01625 663935 for further guidance. Please see the appendices at the end of this policy for further information and guidance. 5. Monitoring Compliance with the Document 5.1 Measuring performance and audit Performance of fundraising activities at the trust will be monitored and reported to the Charitable Funds Committee on a quarterly basis. The key performance indicators include: Number of activities undertaken Amount of charitable funds raised Publicity, reputation and awareness creation - positive media coverage Cost of fundraising Website hit statistics Social media activity.

5.2 Review This policy will be reviewed on a three-yearly basis by the Head of Communications Engagement and Marketing. 6. References Further guidance and information Institute of Fundraising http://www.institute-of-fundraising.org.uk/home/ The Charity Commission http://www.charity-commission.gov.uk/ East Cheshire NHS Trust s Advertising and Sponsorship Policy: http://www.eastcheshire.nhs.uk/about-the- Trust/policies/A/Advertising%20and%20Sponsorship%20Policy%20ECT2199.pdf Information Commissioner s Office www.ico.gov.uk Appendices APPENDIX 1 - Data Protection Data protection legislation affects many areas of fundraising. Fundraisers need to ensure they comply with trust information governance policies available on the intranet. If staff are uncertain regarding information governance issues, they are advised to contact their line manager or the trust s Information Governance Department. The regulations may appear daunting at first but it is helpful to remember a few rules of thumb which are often centred on having the correct permissions for using the data ensure you have the necessary permissions to contact supporters; do not retain any information on a supporter or prospect that you would not be comfortable sharing with them; do not use information in a manner that the supporter would not wish; and do not share data in a manner that a supporter would not wish. Codes of Fundraising Practice The Institute for Fundraising s Code of Fundraising Practice identifies key regulatory and best practice standards.

APPENDIX 2 Security relating to donations Staff should inform anyone enquiring about making a donation to ECHO that the money should be paid into the Cash Office or given as a cheque if the donation is to be posted (cheques made payable to East Cheshire NHS Trust ) The donation should list the beneficiary department and be completed with the name and address of the donor where possible. Please note: Gift Aid should be indicated wherever possible as the donor pays no more but ECHO receives tax relief on the full amount of the donation. All staff receiving a donation or in receipt of money from fundraising should pay it in immediately to the cashier at the trust s Cash Office. Please use the donation envelopes available so that we can ensure the correct donations are allocated to the correct area, donors data can be collected for future use and so that we can thank them and Gift Aid can be claimed. This will then be receipted and banked. All charitable income either from donations or fundraising must be paid into official funds. Failure to do this is a disciplinary offence. Any collection tins and buckets will be provided with a specific security seal in place. This seal must be still in place and unbroken when the tin/bucket is returned to ECHO to show no monies have been removed. Receiving legacies Any member of staff receiving notification of a legacy that names East Cheshire NHS Trust as a beneficiary should contact the ECHO team on 01625 661871 who will then bring this to the attention of the Finance Department. APPENDIX 3 Methods of fundraising and legal requirements Please ensure that you contact the fundraising department to ensure any legal considerations are taken into account before fundraising as there are many attached to charity law. Please do not let this put you off as the ECHO team will be able to assist. Monies can only be refunded in very specific circumstances once a fundraising initiative has been launched, such as cancellation of the event. Auctions Auctions, often held at one-off fundraising events, can be a great way to increase revenue. Unlike raffles and lotteries, auctions have the benefit of not falling under gambling law. However, you still need to be aware of consumer legislation such as those for unfair commercial practices. Find out more about the Consumer Protection from Unfair Trading Regulations. Auctions also come under the Trade Descriptions Act 1968 so make sure that you describe any items accurately Establishing terms and conditions in advance are important to help avoid problems later. Some of the issues to consider will be highlighted during a risk assessment of the activity.

For example, what would you do if the auction prize was no longer available? What will you do if someone decides they no longer want to purchase the auction item? Event fundraising Organising events as a means of fundraising can be a great way to involve an array of different people and the community as a whole. It can raise awareness for your cause in a fun way, reaching new audiences and a wider potential new supporter base. Legal requirements: Venue - Must consider issues of equal access for all, even if an event is being targeted at a specific group of people. Must ensure the venue complies with all health and safety regulations. Literature You must ensure that materials adhere to copyright laws and that permission is obtained from the right holders for use of images, logos etc and are printed with all legally required information, for example, registered charity status or number, full company name and registered office and VAT number if applicable. Purpose If fundraising literature states that funds raised will be used for a particular purpose then funds must be used for that purpose and must be identified in the charity s accounts as restricted funds. Cancellation/postponement If the event is cancelled, or if it is postponed and a participant is then unable or chooses not to take part, or if they are unable to take part for any reason, the participant must contact donors and ask if they are still happy for monies to go the organisation and if not the donation must be refunded to them. Commercial partners - If the event is being staged by a person who is a commercial participator or professional fundraiser the charity and commercial participator must ensure compliance with section 59 of the Charities Act 1992 and the Charitable Institutions (Fund Raising) Regulations 1994. Data protection - Organisers must ensure compliance with data protection legislation. Disability discrimination - People with disabilities must not be unlawfully discriminated against in relation to the event. Unregistered charities - If the charity is a registered charity, that fact must be stated on all documents soliciting funds for the charity. ECHO is is a registered charity number 1059228) Fundraising for specific purposes/fundraising appeals All monies raised for a specific purpose/appeal will be allocated to the relevant department or directorate, however the ECHO trustees reserve the right to redirect surplus funding to other areas of the trust according to organisational priorities. If the funds raised for a specific purpose do not meet the target amount required (eg to fund the purchase of a specific piece of equipment) then the funds will be held with the intention

of reaching the target amount through further fundraising activities. However if the target amount is not reached or if organisational priorities change and the purpose of the appeal is no longer relevant, the ECHO trustees reserve the right to redirect surplus funding to other areas of the trust according to organisational priorities. Collecting for ECHO Fundraising collections are a common method of raising money for charity. The trust has a range of ECHO collection tins which all must be monitored and security sealed. Please contact us if you intend to use collection tins. There are many different forms of charitable collections, and all have different rules associated with them. Some of the most common are: Street collections - If you are holding a collection in the street, you will need to obtain a licence from your local authority. Private collections - If your collection is still open to the public, but being held on private property such as within a shopping centre or rail station, you must obtain permission from the landowner or manager. Static collection boxes - Boxes must be secure and tamper proof. You do not need a licence to place these in a shop or business, just permission from the business owner. House-to-house collections - Licences must be obtained from the relevant local authority. Please do not let these requirements deter you as the ECHO team will be able to assist. Raffles and lotteries Under the Gambling Act raffles and lotteries held to raise funds for charity need to fit into one of three categories in order to not require a licence. Which of the three categories should be used depends on whether you plan to sell tickets for the raffle/lottery to patients, staff or both groups, and whether tickets for the raffle/lottery will be sold on or off trust premises, at an event or over a longer period of time. The full guidance from the Gambling Commission can be found here: http://www.gamblingcommission.gov.uk/pdf/organising-small-lotteries.pdf Alternatively contact the ECHO team for advice. APPENDIX 4: CHARITABLE FUNDS REQUEST FORM AND STANDARD OPERATING PROCEDURE (links to form on trust intranet)