Purpose

This policy sets out the Bermuda Foundation’s (BF) ethical standards and governance principles in all fundraising activity. It is informed by the UK Code of Fundraising Practice and reflects best practice for community foundations under UKCF accreditation expectations. It ensures that fundraising conducted in Bermuda is legal, open, honest, respectful, and trusted by donors and the public.

Scope

This Code applies to all BF staff, trustees, volunteers, contractors, external fundraisers, and affiliates involved in fundraising for the Foundation. It governs planning, solicitation, acceptance, acknowledgment, stewardship, and reporting.

Core Values

BF will ensure that all fundraising is:

• • Legal – Fully compliant with applicable local Bermudian and UK fundraising law and regulation, as applicable.
  • Open – Transparent about BF’s identity, purpose, use of funds, costs, and methods.
  • Honest – Neither misleading donors nor misrepresenting BF’s mission, activities, or outcomes.
  • Respectful – Treats donors, prospects, and the broader public with courtesy and sensitivity, especially individuals in vulnerable circumstances.

Trustee Accountability and Governance

• • Trustee Oversight: The BF Board reserves ultimate responsibility for the integrity of fundraising programmes and compliance with this Code.
  • Risk Assessment: BF will conduct documented risk assessments before approving new fundraising methods or third-party partnerships.
  • Gift Acceptance: The Board retains the authority to accept or decline gifts, following the existing Gift Acceptance Policy, ensuring no reputational or ethical conflict.

Standards in Fundraising Practice

Behaviour When Fundraising
All interactions shall be polite and professional. Fundraisers will not apply undue pressure or coercion. Criticism of other organisations or solicitation tactics intended to shift support from another charity are not permitted.

Informed Consent and Transparency
Appeals must clearly identify BF, its charitable purpose, and what the funds will achieve. Donors should receive accurate information on the management fee structure, expected impact, and reporting procedures.

Vulnerable Donors
Extra care is taken with individuals who may be vulnerable. Fundraisers must apply principles from Treating Donors Fairly guidance to assess the capacity and suitability of solicitation.

By using our website and services, you agree to the collection and use of personal information as outlined in our Privacy Policy. We implement security measures to protect your personal data but cannot guarantee absolute security.

Working with Others

Volunteers
All BF volunteers engaged in fundraising must receive training on this Code and must act in accordance with its standards at all times.

Third-Party Fundraisers
Any professional or commercial fundraisers must be vetted, contracted with explicit obligations to uphold the Code, and monitored regularly for compliance.
Agreements must include a solicitation statement, fee structures, training requirements, and performance monitoring protocols.

Fundraising Methods and Events

Digital, Communications, and Media
All communications (mail, online, SMS, social media) must meet the transparency, consent, and data protection standards (in compliance with BF’s PIPA policy).

Public Events and Collections
External events must undergo risk and legal review, including insurance, licensing, venue safety, and liability clauses. Third-party events must be governed by written agreements clarifying responsibilities and branding usage.

Donor-Generated Fundraising
Donor-initiated fundraising (e.g. peer-to-peer campaigns) is discouraged unless specifically approved in writing by the Board or CEO. Any such activity must comply with BF branding guidelines and contractual oversight.

Data Protection & Donor Privacy

• • All donor data collection, storage, and use shall comply with BF Privacy Policies and applicable data protection regulations.
  • Donor opt-out requests shall be respected immediately.
  • Anonymity requests must be processed in accordance with BF’s Privacy and Gift Acceptance policies.

Complaints and Non-Compliance

• • Complaints Mechanism: BF will maintain accessible reporting channels for donors or the public to raise concerns about fundraising practices.
  • Investigation and Response: BF commits to prompt, impartial investigation of complaints, remediation of breaches, and documentation of outcomes.
  • Whistleblower Protection: Individuals reporting issues will be protected in line with BF policies.

Documentation and Record-Keeping

BF will maintain detailed records of fundraising strategies, decisions, risk assessments, agreements, and donor preferences. Performance monitoring—particularly for third-party fundraisers—will include reporting, mystery shopping, or site visits where appropriate.

Review and Revision

This Code will be reviewed ad hoc, responding to emerging fundraising risks, new methods, changes in law, or changes in BF strategy. UKCF accreditation or regulatory developments (e.g. the new Code effective 1 November 2025) will prompt a formal review.

Related Policies & References

This Code supplements and should be read alongside:

• • Bermuda Foundation Gift Acceptance Policy (2025)
  • Bermuda Foundation Privacy Policies (2025)
  • Bermuda Foundation Donor Ethics Policy (2025)
  • UK Code of Fundraising Practice (Fundraising Regulator)
  • Fundraising Regulator’s Treating Donors Fairly and Code Advice Service resources