“Internal financial controls are essential checks and procedures that help charity trustees: meet their legal duties to safeguard the charity’s assets; administer the charity’s finances and assets in a way that identifies and manages risk; and ensure the quality of financial reporting, by keeping adequate accounting records and preparing timely and relevant financial information.
If a charity is to achieve its aims then the trustees need to ensure that assets are properly used, that its funds are spent effectively and its financial affairs are well managed.” Charity Commission – Internal financial controls for Charities 2011 Financial Controls A key feature of internal financial controls is to ensure that no single individual will have sole responsibility for any single transaction from authorisation to completion and review. As a general rule, any financial transaction will be approved by at least two people, one of which is a trustee.
These will include: Writing cheques from the charity bank account Withdrawing cash from the charity bank account Using a credit or debit card on the charity’s account Setting up direct debits or standing orders on the charity’s behalf Using electronic banking facilities Transactions will be promptly recorded in the accounts. Access to the charity bank account is limited to named persons and all records, cards, chequebooks, pins and passwords are kept secure. Expenditure will be approved by at least one trustee. Orders placed should be within an agreed budget and invoices will be checked confirming the price paid and the receipt of the goods or services ordered. Cash transactions will be kept to a minimum. A cash float can be used for very small expenditures and its use is recorded in a petty cash book. Income in the post will be recorded and banked immediately. Ideally, the post will be opened in the presence of an unrelated person. Collection boxes are numbered sealed, regularly opened and a record of their location and takings made. Cash received is banked as soon as possible without deduction of expenses. Fundraising events will be conducted by the relevant legislative framework, as outlined in The Charity Commission’s guidance Charities and Fundraising (CC20)
The current scale of the charity means an external auditor is unnecessary, but instead financial activities will be regularly reported and monitored by the trustees. The effectiveness of the charity’s internal financial controls will be reviewed at least annually. This will include an assessment of whether the controls are relevant to, and appropriate for, the charity and not too onerous or disproportionate. Expenses
Expense claims will be authorised by someone other than the claimant and checked for accuracy before payment. Expense claims should contain a self-declaration that the claim is accurate and incurred in connection with the business of the charity. Reimbursement will be made by cheque.
The charity does receive restricted donations which can be spent at the discretion of the trustees in furtherance of some particular aspect of the objects of the charity. Restricted funds are recorded in the accounts and a record is kept of how they are spent. Donations may be refused where conditions attached are unduly restrictive or are intended to exercise undue influence over the trustees or where the acceptance of the donation would be detrimental to the charity’s reputation. Financial Reporting The charity needs access to accurate and up-to-date financial information to make proper decisions. This can include the latest internal accounts or bank statements. At the beginning of each year, a budget will be prepared outlining planned income and expenditure for the period. The trustees will review this regularly and the reasons for any changes explained.
We are also legally required to produce annual accounts for the Charity Commission. These will be based on internal records of income and expenditure and will be reconciled against the bank statements and copies of invoices or receipts. Someone other than the person who made the accounting entries will undertake the reconciliation.
We keep a list of the charity’s fixed assets which will be regularly updated. The assets will also be checked to ensure they are in good repair and of use to the charity. The Trustees’ meetings will be used to communicate information concerning the finances and approve the accounts. All decisions by the trustees will normally be taken collectively and significant decisions and action points noted in writing.
Wherever possible donations will be used for Gift Aid. Secure records will be kept of amounts reclaimed and the donor’s authorisation and personal details as required by HMRC http://www.hmrc.gov.uk/charities/gift_aid/reclaim.htm
We have a legal requirement to identify tainted donations. These occur when a donor gets relief from tax only for the capital or a benefit from the donation to end up back in the hands of the donor. Although the regime is intended to affect the tax position of the donor, should the charity have claimed a repayment of tax on the gift, an income tax charge will arise on that repayment. The charity itself may be liable for this charge if the charity was a party to, or aware that, the main purpose or one of the main purposes of the arrangements was to provide financial advantage to the donor.
Financial Crime The incidence of reported financial crime affecting charities is relatively small. However, when it does happen the impact can be great. Financial crimes such as fraud, theft, and money laundering, or the loss of electronic data can result not only in significant loss of charitable funds but also in damage to the public trust and confidence in charities more generally.
The Charity Commission’s Compliance Toolkit:
Protecting Charities from Harm – Fraud and financial crime identify 13 areas of risk relating to fraud and financial crime to which charities may be susceptible: Income-related fraud Expenditure fraud Property and investment fraud Procurement fraud Fraudulent fundraising in the charity’s name Fraudulent invoicing and grant applications Identity fraud/theft Banking fraud E-Crime (including ‘phishing’) Gift aid fraud Share purchase and investment fraud (boiler room fraud) Mass Market fraud (letter or e-mail) Section ‘419’ (payment in advance for promises of wealth) frauds Trustees, employees and volunteers will all need to consider the risk of financial crime and report any suspicions. If trustees know or suspect an individual is misusing the charity for their purposes or misappropriating charitable funds they should take immediate and appropriate action to resolve the issue.
If it is known or suspected that a charity is a victim of financial crime then this should always be reported to the police and as a matter of best practice to the Charity Commission immediately under the Serious Incident Reporting regime. Data Protection
Through our fundraising and charitable work we have access to personal data including addresses. This data is very valuable and its loss could expose the charity and others to the risk of theft, fraud, identity theft and loss. Data is stored in locked filing cabinets or electronically. The charity PC is password protected and access to that password is limited. We use antivirus firewalls and spyware software. We do not share data with third parties without permission. We have a separate policy on bribery and a separate policy on reserves and investments.