Gift acceptance policy
Translated from the Czech version of the Order’s policy (2021). The authoritative text is issued by the Grand Magistry.
Introduction
The Sovereign Military Hospitaller Order of St. John of Jerusalem of Rhodes and of Malta (“the Order”) raises funds from its members and from private and public donations. Sources of funding vary between countries, entities of the Order, types of project and circumstances. This policy sets out the main rules governing the Order’s approach to accepting gifts. It describes the steps expected to ensure that the Order is not exposed to undue reputational or compliance risk.
Scope
This policy applies to all entities of the Order of Malta and to volunteers acting on behalf of the Order, and to all other entities directly or indirectly controlled by the Order. It should be applied in accordance with local legal and regulatory requirements. Where a requirement of this policy is less strict than local law, entities should adopt the stricter local requirement.
Main rules
- Entities of the Order should not accept gifts from donors where this would risk damaging the reputation of the Order or would otherwise harm its work.
- In fundraising, entities of the Order should comply with all local laws and established good practice in the jurisdictions where they are registered or operate.
- Entities of the Order should be very careful when allowing donors to publicise their connection with the Order, bearing in mind the donor’s possible motives for making that connection visible.
Expectations of entities
In the light of the rules above, all entities of the Order that raise funds are expected to follow a local gift acceptance policy. It should name the person or committee responsible for overseeing the acceptance of gifts (usually the board or the equivalent body of the entity) and, where appropriate, the delegation of decisions to executive management.
Local gift acceptance policies and procedures should:
- Reflect the core values of the Order. Although every donor relationship should be assessed on its own merits, entities should not work with those whose funds come from sectors likely to conflict with Catholic teaching, such as arms or pornography.
- Comply with local laws governing fundraising. All relevant staff should be familiar with these laws. Attention should also be paid to anti-money-laundering requirements and to the Order’s anti-money-laundering policy.
- Set out a procedure for screening donors. It should be based both on an assessment of risk and on the value of the proposed gift, taking into account the cumulative effect of gifts from the same donor.
- Require due diligence on donors proportionate to the value of the gift and the perceived risk. This may include, among other things, searching publicly available information, referring the matter to the Grand Magistry or using specialist research firms. Thresholds at which different procedures apply can help in choosing the most suitable approach.
- Ensure that records are kept of prospective donors who have been screened. These records must be kept in accordance with the GDPR (or equivalent local law) and should document the reasons for the conclusion reached.
- Set out a policy on anonymous gifts. Such gifts are prohibited or regulated (including maximum amounts) in some jurisdictions. Anonymous gifts should in any case be treated with particular caution and accepted only when the entity is satisfied that the gift comes from a lawful and acceptable source.