Introduction

Our policy sets out the principles and procedures governing the acceptance of monetary donations by The Friends of Penlee House Gallery and Museum (“Charity”) in support of Penlee House Gallery & Museum (“PHG&M”), owned and operated by Penzance Council.

The Policy aims to ensure that all donations that are accepted by the Charity are ethical, transparent, and consistent with the Charity’s values and legal obligations.

Purpose and Regulatory Context: The Policy establishes clear guidelines for conducting due diligence on prospective donations and on donors, in order to safeguard the reputation and integrity of the Charity and of PHG&M.

The Policy further provides for the Trustees of the Charity to act in compliance with the Fundraising Agency’s Code of Fundraising Practice and the Charity Commission guidance CC3 (The Essential Trustee) thereby ensuring that they act in the Charity’s best interests, safeguard assets, and protect public trust.

Scope: The Policy applies to all monetary donations (excluding that from collecting boxes) received from individuals, corporations, foundations and other entities (“Donations”).

Risk-Based Approach: The Charity applies a proportionate, risk-based approach when offered Donations.

Donor Identification: All prospective donors will be subject to appropriate checks to confirm their identity.

Donation Assessment: Donations will be evaluated for potential reputational, ethical, or legal risks. This may include reviewing publicly available information about the donor.

The Charity will not accept Donations that appear to be derived from illegal activities, or which could compromise the integrity of the Charity or that of PHG&M.

Cash and Non-Cash Donations: Excluding those received through collecting boxes, cash donations shall be declined.

Conditional Donations: Conditions must be lawful, compatible with the Charity’s objects, and not compromise independence.

Conflict of Interest: Trustees must declare any personal or professional connections to donors. Where a potential conflict exists, this will be recorded. Examples of where potential conflict may arise include (but are not limited to) the following: close family relationships; close business relationships; close friendships; indebtedness by either Trustee or donor to one another.

Anonymous Donations: Donations offered anonymously via a third party will be accepted only after reasonable efforts have been made to ensure the source is both lawful and ethical.

Refusal or Return: Donations must be refused or returned if unlawful, linked to crime, sanctioned, or damaging to public trust.

Art and Artefact Donations: Donations of physical art and artefacts will not be accepted by the Charity, but will be referred, with the donor’s permission, directly to PHG&M. Where physical art and artefacts are bequeathed to the Charity, the Trustees will undertake proper consultation with all interested parties to see if the bequests can be accepted by PHG&M.  If this is not possible the Trustees will propose to the Executor/Administrator an alternative course of action, such as arranging for sale with the proceeds going to the Charity, or to offer the bequest to another suitable institution.

Confidentiality and Data Protection: Information will be handled lawfully and confidentially.

Compliance: The Charity will comply with all applicable laws, including anti-money laundering regulations, charity law, and guidance issued by the Charity Commission and other regulatory bodies.

Contact: For queries regarding the policy or the due diligence process, or for the full text of the Policy, please contact the Secretary.

Review: The Policy will be reviewed periodically.

Adopted by the Trustees of the Friends of Penlee House Gallery & Museum 28 January 2026.