MARKETING, COMMUNICATIONS AND FUNDRAISING POLICY
Policy Statement
The purpose of Global Talent Pathway’s marketing, communication and fundraising activities is to empower passionate people, including Global Talent Pathway’s supporters and potential supporters, to give, fundraise and take action to fulfil Global Talent Pathway’s purpose. These important contributions can take the form of financial gifts, fundraising, volunteering, campaigning, and advocacy activities, and provide the funds Global Talent Pathway requires to carry out its work and fulfil its mission.
Currently, Global Talent Pathway does not undertake any fundraising activities and is not a registered charity. If in the future, Global Talent Pathway is required and is authorised to undertake fundraising activities, this policy shall govern those activities.
Global Talent Pathway recognises that:
Supporter and institutional donor relationships build over time. Most support given to charities is not one-off, and the relationship between a charity and a supporter must be carefully nurtured and managed to maximise the support given to the charity over time.
These relationships are based on trust. Ethical and sustainable fundraising, as well as being core to Global Talent Pathway’s values, is essential in order to enter ongoing relationships of trust, confidence and mutual respect between Global Talent Pathway and its institutional donors, supporters, volunteers, and beneficiaries.
Fundraising costs money. Collecting stories, producing effective communications, reaching people, and building relationships requires an investment of time, energy, and money. When the return on investment from a fundraising activity is positive, the more that is invested in fundraising, the more money that is available for program work.
Fundraising takes time. Because supporter and institutional donor relationships build over time, an investment in fundraising in one year may not deliver a positive return on investment for several years. Therefore, the ‘fundraising ratio’ of fundraising income vs expenditure in any given year is not a good indicator of the total return on investment of a fundraising activity. Lifetime value, or the fundraising income after costs over the entire time the supporter gives to the charity, is a more effective measure of return on investment.
Maximising the net fundraising contribution to programs, not minimising the cost of fundraising, will most effectively help Global Talent Pathway fulfil its purpose, its obligations to beneficiaries and its promise to donors. As an agency that is accountable to its donors, beneficiaries and other relevant stakeholders, Global Talent Pathway must ensure that it maximises its net contribution to programs within a fundraising ratio that is acceptable to stakeholders.
Fundraising activities must be relevant and appropriate to the needs of those Global Talent Pathway seeks to assist. Accordingly, fundraising strategies must be aligned to Global Talent Pathway’s Strategic Plan and current or future Business or Operational Plans. Fundraising objectives and strategies, including the planned mix of earmarked and non-earmarked funding, must align supporter and institutional donor needs with the funding requirements of Global Talent Pathway’s humanitarian, protection, advocacy, and development programs.
Global Talent Pathway seeks to ensure our supporters, donors and those who engage with us in fundraising and campaigning are treated ethically, with the highest level of respect and within the obligations we have accepted as a charitable organisation registered in Australia.
Compliance with this policy is essential to ensure Global Talent Pathway can continue to generate and sustain the funding it requires for its work, protect its beneficiaries, supporters, staff, and volunteers, and manage organisational risk. It is also essential in order to enter ongoing relationships of trust, confidence, mutual respect and accountability between Global Talent Pathway and its institutional donors, supporters, volunteers, and beneficiaries.
Objective
The objective of this policy is to provide guidance to ensure Global Talent Pathway staff, representatives and volunteers carry out marketing, communication and fundraising activities ethically, effectively, in line with Global Talent Pathway’s mission, vision, purpose and values, in compliance with all relevant Global Talent Pathway policies, and meeting our obligations under Commonwealth, State and Territory legislation.
Principles and standards
Global Talent Pathway is committed to meeting and exceeding the standards set out in the ACFID Code of Conduct and ACFID Fundraising Charter. Global Talent Pathway will, on an annual basis, conduct the required self-assessment of its work against the Code and report on its compliance with the ACFID Fundraising Charter to its Board.
Global Talent Pathway is committed to high standards of ethical conduct in its fundraising and will adhere to the Fundraising Institute Australia (FIA) Code. The Code is a voluntary, self-regulatory code of conduct, informed by the International Statement of Ethical Principles in Fundraising, that aims to raise standards of fundraising in Australia. Global Talent Pathway will ensure that those engaged in fundraising activities have completed FIA Code training within six months of their appointment. A Global Talent Pathway board member or its CEO will sign off annually on Global Talent Pathway's adherence to the Code.
Global Talent Pathway is committed to complying with the Australian Government Department of Foreign Affairs and Trade (DFAT) Child Safeguarding Policy and meeting its acknowledgement and publicity obligations under our DFAT Agreement and ANCP Grant Agreement, and other institutional donor requirements as confirmed in Agreements and associated policies. Compliance includes but is not limited to financial controls, dedicated use of funds, safeguarding, counterterrorism, and other core compliance measures.
Global Talent Pathway will also comply with all Federal, State and Municipal laws and regulations applicable to Fundraising; the Australian Privacy Principles; and Payment Card Industry Data Security Standards.
This policy should be read in conjunction with Global Talent Pathway’s Value for Money Policy, Code of Conduct, Code of Good Practice, Child Safeguarding Policy, Risk Management Policy, Advocacy Policy, Counter-terrorism and Complaints Policy, as well as relevant Global Talent Pathway operations manuals and procedures.
Scope
This policy applies to the production of all marketing, communications and fundraising materials, and any associated activities, undertaken by Global Talent Pathway staff, representatives, suppliers, and volunteers whether in printed, electronic, or verbal form. Where specified, some sections of this policy also apply to Global Talent Pathway’s partners.
Policy in Action
Global Talent Pathway will ensure that all marketing, communications, and fundraising activities have clear objectives that align with its strategic goals, are effectively planned, and implemented to a high standard. Global Talent Pathway will regularly monitor, evaluate, and learn from the progress of these activities, and adapt its approach to maximise their effectiveness.
Global Talent Pathway’s marketing, communications and fundraising strategies will be informed by evidence and best practice and benchmarked against past performance and the sector. Global Talent Pathway will aim to maintain a balanced fundraising portfolio with a range of income streams and a diverse supporter and institutional donor base that balances risk and return.
Strategies for raising funds with institutional donors will be informed by research into institutional donor policy and funding preferences.
Strategies will aim to maximise the lifetime value of Global Talent Pathway’s supporter and institutional donor base at an acceptable return on investment, rather than minimising the cost of fundraising. Global Talent Pathway will strive to obtain an optimum balance between high productivity, effective outcomes, low cost, equitable distribution, and ethical practice.
Global Talent Pathway’s overall investment in marketing, communications, and fundraising, and therefore its fundraising ratio, will be approved by the Global Talent Pathway Board during each strategic planning and budgeting cycle and reviewed annually by the Board as part of the budget approval process.
Global Talent Pathway will put in place adequate procedures and record keeping to ensure it demonstrates compliance with this policy. These procedures will include compliance checklists that must be completed prior to the approval and distribution of marketing, communications, and fundraising content/material.
Communications and Marketing activities
Global Talent Pathway’s marketing, communications and fundraising activities will reflect its vision, purpose and values and adhere to the highest standards of ethics, transparency, accuracy, truthfulness, and integrity. Global Talent Pathway will act openly, honestly, with respect for professional Fundraising and with regard to its responsibility for public trust. It will act with respect towards Donors and Beneficiaries, placing a high value on their privacy and confidentiality. Global Talent Pathway will conduct itself in a manner that encourages others to aspire to the same high standards.
Transparency
Global Talent Pathway will operate transparently with and be accountable to all stakeholders. It will be open about the work it does, including how funds are raised, managed, and disbursed. It will proactively share accurate, timely and accessible information about the organisation and its work, making this available to all stakeholders – its Australian constituency, overseas partners, and others (including primary stakeholders, partners, and donors). It also commits to seeking stakeholder input and feedback.
Global Talent Pathway will regularly and proactively report back on its projects and activities, and the results of these activities and lessons learned. Information will be shared through its website, newsletters, promotional material, and the distribution of its Annual Report.
Its Annual Report will be produced in line with ACFID requirements and include ACFID Code-compliant financial statements and other detailed financial reports, including its overall expenditure on fundraising, and will be available to the public on its website. Global Talent Pathway will lodge a copy of its audited annual report and a copy of its annual full financial statements (if not included in the annual report) with ACFID within the required reporting period. Global Talent Pathway will also ensure that in any references to financial performance, stakeholders are made aware of their right to access Global Talent Pathway’s full financial reports. Global Talent Pathway’s website will also include publicly available information about the agency and its work, including its strategic plan, its governing Board and relevant policies and processes. Global Talent Pathway will ensure its stakeholders are able to hold Global Talent Pathway to account through maintaining key accountability documents on its website, including its Code of Conduct, Code of Good Practice, Whistleblower and Complaints Policy and procedures.
Global Talent Pathway is committed to sharing any other information about its projects and activities (with the exception of confidential and commercially sensitive information) upon request, including:
its objects and how it intends to use Donated funds.
its capacity to use Donations effectively for their intended purposes.
whether funds are being raised by volunteers, employees, or Suppliers.
Accuracy
Global Talent Pathway’s public materials will be truthful, accurately describe the organisation and its work, and not seek to deceive or mislead the general public.
Its marketing, communications and fundraising content will be obtained and used according to ethical principles, consistent with Global Talent Pathway’s purpose and values, and accurately describe the nature and scope of Global Talent Pathway’s work, acknowledging the role of partners.
Images and messages will accurately represent the context, situation, proposed solutions and intended meaning of information provided by affected people. They will avoid material omissions, exaggerations, or misleading visual portrayals. They will directly relate to the country, place, context, and activities being supported; and be an honest representation of the work being undertaken.
However, names and other information which could lead to the identification of, or location of vulnerable people featured in communications, or otherwise put their safety at risk, will be altered to ensure adequate protection.
Facts or statements will be checked for accuracy before publication.
When communicating about the work of coalitions or networks of which Global Talent Pathway is a member, promotional materials will clearly distinguish between Global Talent Pathway’s work and that of the alliance/network, where they are different. The material will not lead the public to believe that Global Talent Pathway is undertaking work that is really being done by other parts of its international network. Fundraising communications will clearly state if there is a specific purpose of each donation, not over- state the need or what the donor’s response may achieve, and not claim or imply that professional fundraising activities are carried out at no cost.
Global Talent Pathway’s financial statements will fully and accurately disclose administration costs and costs of any public fundraising. They will not inaccurately claim zero expenses or otherwise understate the amount spent on public fundraising and administration and/or overseas development expenditure.
When reporting financial ratios, Global Talent Pathway will apply ACFID’s Financial Definitions in its calculations and accompany any use of ratios with a note explaining how these have been determined.
Integrity and ethics
Global Talent Pathway’s marketing, communications and fundraising activities will be conducted with integrity, to the highest ethical standards. Global Talent Pathway will not engage in activities that bring Fundraising into disrepute.
Images and messages in communications will:
Promote partners and beneficiaries as active agents, and not as passive recipients of aid.
Portray people (including children) in a manner that respects their dignity, values, history, religion, language, and culture.
Be authentic to the context, person and terms of consent given.
Protects the safety and rights of those depicted.
Be respectful of other NGOs.
Images and messages in communications will not:
Be discriminatory (e.g., on the basis of ethnicity, faith, sexuality, or socio-economic status).
Sensationalise the challenges faced in developing countries.
Be used if they may endanger the people they are portraying.
Be used without the free, prior, and informed consent of the person/s portrayed, including children, their parents, or guardians.
Present people in a dehumanised manner, or contain depictions that are demeaning, discriminatory, pornographic, or unduly violent towards a person or group.
Infringe child safeguarding policies and in particular show children in a naked and/or sexualised manner.
Comment unnecessarily or negatively on the impairment, dependency, or disability of a Beneficiary.
Use language which suggests that the Beneficiary is to be pitied or feared.
Use children to raise funds for adult causes, giving the impression that the Beneficiaries are childlike.
Feature dead bodies or dying people.
Disparage others.
Infringe on the intellectual property rights of others.
Denigrate other agencies, make statements about other NGOs with the intention of creating a reputation or other advantage for itself.
Supporters
Global Talent Pathway will not exploit relationships with Supporters.
Global Talent Pathway will promptly and courteously comply with a Supporter’s:
refusal to make a Donation.
request not to receive any future solicitations.
request to be contacted at a more convenient time or by a different method; and
request to limit the number, type, or frequency of solicitations.
Global Talent Pathway will, if asked:
assist Supporters to stop receiving solicitations.
provide information about how the Supporter’s contact details were obtained; and
provide information about how to make a complaint or the name and contact details of the person who is responsible for handling complaints.
Global Talent Pathway will:
not subject Supporters to undue influence, or any harassment, intimidation, or coercion.
maintain an appropriate professional relationship with the Supporter in connection with any Donation or Bequest.
not prevent or discourage a Supporter from seeking independent legal advice in relation to a Donation.
not prevent or discourage a Supporter from having a family member or other trusted advisor present when considering a Donation.
not, after obtaining a Donation, change the conditions of the Donation without first communicating with the Supporter any changes and gaining their consent for the change.
Knowingly send communications to anyone under the age of 18.
Ensure a Supporter has given consent prior to any public recognition of their Donation.
Branding and Visual Identity
A strong brand is an essential pre-requisite for attracting and maintaining public support for Global Talent Pathway’s work, and Global Talent Pathway will achieve the greatest impact when all its communications build on and reinforce each other. All Global Talent Pathway communications must follow the Global Talent Pathway Visual Identity Guidelines to ensure all its communications convey a consistent brand personality and are instantly identifiable as coming from Global Talent Pathway.
All Global Talent Pathway communications must use the common visual identity system and feature the Global Talent Pathway logo. In very limited circumstances, where space does not allow for the effective use of all branding elements (such as social media icons or certain coalition publications), the Global Talent Pathway logo may be used in isolation.
All Global Talent Pathway products must be instantly recognisable as run by Global Talent Pathway, and the best interest of the brand must always take priority over what works best visually for an individual product or piece of communication.
Published URLs should always incorporate ‘globaltalentpathway’ where possible (e.g. www.globaltalentpathway.org.au/productname or productname.globaltalentpathway.org.au). Where possible, all new products must be called, and referred to in marketing materials, as ‘the Global Talent Pathway Product Name’ (e.g., the Global Talent Pathway Ration Challenge) rather than given a stand-alone name.
Mandatories
Global Talent Pathway’s logo (which includes a statement relating to our purpose), mailing address, free call number, email address, website URL and ABN must be included on all Global Talent Pathway communications (except in very limited circumstances, where space does not allow for the effective use of all mandatories above, such as videos, where the ABN and website URL only can be used).
Acknowledgement and Attribution
Global Talent Pathway commits to acknowledging and attributing the support of institutional donors, both in Australia and overseas.
Global Talent Pathway will follow the branding requirements we agree to in our contracts with institutional donors to ensure they receive appropriate recognition, and to ensure our supporters and partners are aware of this contribution.
Correct and consistent branding maximises recognition of the development role played by the Australian Government. It is a key mechanism for enhancing the visibility of the Australian Government’s international activities and initiatives.
Privacy and Data Security
Privacy is very important to Global Talent Pathway and it is committed to collecting, storing, and using personal, sensitive and credit card information responsibly.
All Global Talent Pathway marketing, communication and fundraising activities must comply with Global Talent Pathway’s Privacy Policy and data handling procedures (which are guided by the Australian Privacy Principles) and PCI legislation.
Global Talent Pathway will ensure that appropriate security measures (including encryption of internet transactions in accordance with industry standards) are in place to ensure that donations and supporter’s information is secure at all times.
Global Talent Pathway’s Privacy Collection Notice must be clearly printed near to the point of data capture in all printed communications where data is collected and read out when data is collected over the phone. A link to Global Talent Pathway’s Privacy Policy must be displayed near to the point of data capture where data is collected online and in all direct-marketing emails from Global Talent Pathway.
As stated in Global Talent Pathway’s Privacy Policy, supporters have the right to have their names deleted or suppressed from Global Talent Pathway’s mailing lists, and any mailing lists that it has shared. Supporters are also be permitted to refuse to make a donation; limit to a certain amount, the frequency of communications (including fundraising solicitations); not be communicated with via mail, phone, or other technology; or not receive printed material concerning Global Talent Pathway. Any such requests must be processed promptly by Global Talent Pathway.
Each time a prospective supporter is contacted by Global Talent Pathway, information must be provided about how the supporter can opt out of receiving any further solicitations from Global Talent Pathway. Prospective supporters are to be distinguished from existing supporters.
Supporter’s personal information about their identity, their donations, and the organisations to whom they donate are protected and must not be disclosed to a third party without the consent of the supporter.
Media Releases, Media Advisories and Public Statements
Global Talent Pathway engages with the media in order to raise awareness and inspire action on issues and activities relating to our purpose.
All media releases, media advisories and public statements that include an Global Talent Pathway policy position must be approved by the Global Talent Pathway Chief Executive Officer or delegate. Once the policy position is approved, the CEO may delegate approval of related releases, advisories and statements to the Chie Fundraising and Marketing Officer and or Snr Policy and Advocacy Advisor or another delegate.
Media releases or public statements relating to institutional donor funded initiatives, including DFAT funded initiatives will acknowledge the donor’s support. Media releases, articles or other formal statements prepared by Global Talent Pathway relating to DFAT funded initiatives which expressly or impliedly comment adversely on DFAT's role in the initiative will be strictly subject to the prior written consent of DFAT. Global Talent Pathway shall not associate the Commonwealth or DFAT in any way with any adverse comment it may make about governments in recipient countries; and as far as practical Global Talent Pathway will keep DFAT, and the relevant Australian diplomatic mission advised of matters relating to public and media relations associated with DFAT funded initiatives.
Social Media
Social media networks are important two-way channels of communication between Global Talent Pathway and its supporters, other stakeholders, and the general public. The interactive nature of these channels should be reflected in Global Talent Pathway’s social media communication strategies, and they should not be used exclusively as one-way or broadcast channels.
Global Talent Pathway will appoint a person to review and moderate its social media channels/pages and ensure compliance with this policy, Global Talent Pathway’s Safeguarding Policies (including Child Safeguarding), Global Talent Pathway’s Privacy Policy, and other relevant Global Talent Pathway policies.
Any new Global Talent Pathway social media pages/accounts must be approved by the Global Talent Pathway Chief Fundraising and Marketing Officer before being set up.
Information on Global Talent Pathway’s social media pages must be regularly updated, reviewed for accuracy and timeliness, and incorrect or outdated information removed.
Comments and posts by users should be moderated. Publicly posted feedback, queries, questions, or suggestions - positive and negative - should be responded to promptly. Moderation should be transparent, and negative feedback should only be removed if it is offensive or malicious. Offensive comments, links to offensive material or any post or comment that would endanger Global Talent Pathway’s staff, supporters, partners, or beneficiaries should be promptly removed. Complaints received via social media should be handled in accordance with Global Talent Pathway’s complaints handling procedures.
Advertising on social media channels must not be knowingly targeted at people under the age of 18, comply with Global Talent Pathway’s Privacy Policy, Safeguarding policies, Code of Conduct, and all relevant legislation, including privacy legislation.
Collection, Storage and Use of Stories, Photos, and Video
Global Talent Pathway’s story gathering guidelines must be followed when collecting, storing, and using stories, photos and videos of Global Talent Pathway beneficiaries or supporters. This policy is designed to ensure Global Talent Pathway always respects the dignity, values, history, religion, and culture of the people portrayed; ensure that the people portrayed, especially children, are protected and not endangered in any way; and ensure that our communications are factually accurate, truthful, and not likely to deceive or mislead any person.
Anyone photographing or filming a child or using children’s images for Global Talent Pathway-related purposes, must comply with Global Talent Pathway’s Child Safeguarding Policy and Child-Safe Code of Conduct, which describes Global Talent Pathway obligations in full and mandatory requirements for staff.
Consent given by subjects to Global Talent Pathway to use their images or stories must be free, prior, and informed and obtained in a way that is culturally appropriate and contextually sensitive. Key figures in images will be provided with information regarding how the image will be used and their permission obtained. They will have the right to deny either the taking of or use of their image without negative repercussions. The collection of information, images and stories must not harm people or the environment.
The origins of any images used will be known and any necessary permissions, including copyright releases, be held. Care will be taken to ensure that the identification of or use of images of local people will not endanger the people they portray.
These policy requirements apply to all information, stories and images collected for research, evaluation, and donor and supporter purposes.
Collection
A detailed story gathering brief, which includes Global Talent Pathway’s story gathering guidelines and permission requirements, must be prepared before each trip to the field and shared with the partner who is hosting the trip and arranging interviews with case studies. All people (staff, contractors, or volunteers) who undertake the collection of stories, photographs or video of Global Talent Pathway beneficiaries are required to abide by local customs, observances, and traditions.
Key figures in images (and the child ‘and’ parent or guardian if the figure is a child) must provide ‘informed consent’ for the use of the image before images are captured. Details must be given as to how and where their image may be used. Evidence of this permission must be recorded in line with Global Talent Pathway procedures, filed with the image(s) and kept on record until the image is destroyed.
Storage
All Global Talent Pathway images should be securely digitally stored (e.g., using a secure online image library) for use by Global Talent Pathway staff in communications. Only images which are compliant with Global Talent Pathway’s image and child safeguarding guidelines must be uploaded, names of children and vulnerable adults (and anyone else on request) changed and any identifying information of children and vulnerable adults (and anyone else on request) including their location must be removed before being uploaded.
Use
Images and video can only be used in accordance with Global Talent Pathway’s image and child safeguarding guidelines. Images should always be accompanied by a photo credit, and where possible, a descriptive caption. Editing checklists are used to ensure compliance with the guidelines.
Fundraising
All Fundraising Communications
Global Talent Pathway is committed to adhering to best practice standards in fundraising and will comply with the ACFID Fundraising Charter and FIA Code. Specific fundraising activities will be guided by the relevant FIA Code Practice Notes, where applicable.
Global Talent Pathway will abide by all applicable fundraising legislation, including the relevant provisions of the Competition and Consumer Act 2010 (Cth) and State or Territory equivalent legislation, (in particular those sections relating to misleading and deceptive conduct and false and misleading representations).
Use of funds
Supporters will be informed about the purposes for which funds are being raised and be able to access information on programs supported by their donation.
Global Talent Pathway’s fundraising solicitations will clearly state if there is a specific purpose for the donations. In public fundraising for a specific purpose, Global Talent Pathway will have a plan for handling any excess funds and make this known through the use of notifications presented near the point of donation.
Funds contributed by institutional donors will be used for the purpose set out in the signed agreement with the donor.
Global Talent Pathway will maintain financial records that enable substantiation of application of supporter funds and will provide this on request.
After obtaining a donation, Global Talent Pathway will not change the conditions of the donation without first communicating with the supporter any changes to the donation.
If a supporter requests their donation to be used for a specific purpose other than a current, approved fundraising appeal, the decision will be handled in line with the policy on Acceptance and Refusal of Donations.
Fundraising for Emergencies
Global Talent Pathway will follow Global Talent Pathway’s Emergency Response Procedures when deciding whether or not to launch a fundraising appeal for a specific emergency and the scale of that appeal. Funding appeals may be aimed at supporters, the public and institutional donors.
Global Talent Pathway will follow Global Talent Pathway’s emergency fundraising guidelines when fundraising for emergency situations, which ensure we meet ACFID requirements for fundraising during emergencies.
A realistic fundraising target should be set, taking into account the needs of the program. Once the target is reached, Global Talent Pathway must stop soliciting funds until the situation has been further assessed by the Global Talent Pathway Emergency Response Management Team.
Acceptance and Refusal of Donations
The purpose of the policy on Acceptance and Refusal of Donations is to give Global Talent Pathway clear guidelines to make consistent decisions regarding the acceptance and refusal of a donation from a supporter or organisation. This policy clause does not apply to grants awarded by institutional donors for which Global Talent Pathway has lodged an application. Global Talent Pathway must ensure that decisions to accept or reject a donation support Global Talent Pathway’s purpose and are in line with our Code of Good Practice.
The decision on whether to accept or refuse a donation must be taken by the Global Talent Pathway Board, unless authority has been delegated as prescribed below:
Donations between $50,000 and $500,000 where (a) conditions are attached, e.g., the supporter has requested the donation is used for a specific purpose other than a current program or, approved fundraising activity; or (b) the donation is from a company, institution, organisation, or highprofile individual will require the approval of the Global Talent Pathway CEO.
Donations below $50,000 where conditions are attached, e.g., the supporter has requested the donation is used for a specific purpose other than a current program or, approved fundraising activity will require the approval of the Global Talent Pathway Head of Programs and Partnerships.
On the basis of the evidence available to them, the authorised decision maker must consider whether Global Talent Pathway’s purpose will be best met by accepting or refusing the donation and decide accordingly. They must take into account Global Talent Pathway’s legal obligations, any reputational risks to the agency and any potential adverse reaction from existing or potential supporters.
The authorised decision maker may accept a donation for a specific activity conducted by Global Talent Pathway provided that that specific activity is:
directly related to Global Talent Pathway’s purpose; and
is practically achievable by Global Talent Pathway or its partners.
The authorised decision maker may refuse a donation where it is clear that:
the activities of the supporter are directly opposed to Global Talent Pathway’s purpose, policies (including policies prohibiting money laundering and the funding of terrorism) or against the best interest of Global Talent Pathway’s beneficiaries; or
the activities of the supporter are incompatible with Global Talent Pathway’s purpose; or
the cost (whether a direct, indirect or opportunity cost) to Global Talent Pathway of accepting the donation will be greater than the value of the donation itself; or
acceptance of the donation will directly lead to a net decline in the asset base of Global Talent Pathway; or
the offer of a donation is dependent upon the fulfilment of certain conditions by Global Talent Pathway, where the conditions are: (i) contrary to the taxation status of Global Talent Pathway regarding receipt of a donation (if any); (ii) in itself, contrary to Global Talent Pathway’s purpose; (iii) in itself, contrary to the current policies or work priorities of Global Talent Pathway; or requires Global Talent Pathway to first spend its own money or resources.
The authorised decision maker must refuse a donation where there is a reasonable belief that the supporter is in vulnerable circumstances or lacks capacity to make a decision to donate.
The authorised decision maker must demonstrate that the evidence they used to form their decision to accept or refuse the donation relates to Global Talent Pathway’s purpose and adheres to Global Talent Pathway’s Code of Good Practice. Evidence must be provided where: a) it is not immediately clear what purpose the proposed donation would be used for; b) large sums of money or property are involved; c) there is reason to believe that the decision taken may expose Global Talent Pathway to litigation; or d) there is the threat of negative publicity to Global Talent Pathway by the refusal of a donation.
The authorised decision maker must not allow personal interests to affect their decision to accept or refuse a donation, and they must derive no personal material benefit from a donation to a cause for which they are working.
Receipts
Receipting and recording of donations
Mail opening and payment receipt procedures should follow good internal control practices.
Payments received through the mail should be recorded in a remittance advice register.
Payments received electronically should be recorded in individual donor/grant management and ledger systems and reconciled on an appropriate basis, that is, daily, weekly, or monthly.
Commonwealth funds provided by DFAT should be properly receipted and banked promptly.
An appropriate audit trail of all receipts, including for donations, should be maintained.
A receipt should be sent to all supporters informing them of the details of their donation (unless the donation is anonymous, or the supporter’s contact details are missing). The receipt can be sent by email or mail and should include:
the date of the donation.
the amount of the donation.
the supporter’s name and contact details.
Global Talent Pathway’s Australian Business Number
the frequency of the donation.
the payment method agreed by the supporter; and
sequential numbering.
The receipt should be sent to the supporter as promptly as possible after the donation is received by Global Talent Pathway.
Payment Card Industry Data Security Standards
The Payment Card Industry (PCI) Data Security Standard (DSS) is a set of requirements designed to ensure that organisations that process, store or transmit credit card information maintain a secure environment in order to reduce credit card fraud. The requirements cover procedures, policies, networks, software design, architecture, and other security protective measures.
Global Talent Pathway will maintain robust procedures to ensure compliance with the PCIDSS. Global Talent Pathway will provide adequate training on these procedures for all relevant staff, contractors, and others where necessary, and enforce adherence to these procedures.
Outsourcing
Global Talent Pathway will have written contracts with all relevant parties in its Supply Chain that clearly specify the responsibilities of all parties and meet the requirements of applicable laws and regulations.
Quotations should be obtained and documented for significant purchases where possible, and value-for-money principles should be followed.
Global Talent Pathway will ensure that all relevant parties in their Supply Chain are aware of Global Talent Pathway’s obligations under the FIA Code and do not act in ways that could result in Global Talent Pathway being in breach of the Code. Contractors will clearly identify themselves when communicating with donors or prospective donors, and Global Talent Pathway is identified as the beneficiary of the funds.
Contractors will sign relevant compliance documentation, including but not limited to the Global Talent Pathway Child Safeguarding Code of Conduct, Privacy Policy, and Confidentiality Agreement.
Global Talent Pathway will ensure that Supplier costs incurred in fundraising are proportionate to the funds raised and represent fair market value for services provided.
Advocacy and Campaigns
In addition to the requirements detailed in this policy, any Advocacy or campaigning-related marketing and communications activities undertaken by Global Talent Pathway will comply with Global Talent Pathway’s Advocacy policy.
Compliance with this Policy
Compliance with Global Talent Pathway's Marketing, Communications and Fundraising policy, and other policies relating to the accuracy, timeliness, and accessibility of information, will be enforced through:
Staff and volunteer inductions, training and the mandatory signing of Global Talent Pathway's Code of Conduct, and Child Safeguarding and Privacy Policy.
Marketing & Communications checklists, which must be completed before communications are published.
Performance management / disciplinary action taken against staff and volunteers should they fail to comply.
Compliance with Global Talent Pathway's policies, including our Code of Conduct, is a requirement. Any staff or volunteers found to have breached these policies will be subject to appropriate performance management or disciplinary procedures, including suspension and dismissal.
Annex 1. Resource and Reference List
Fundraising Institute Australia - https://fia.org.au/fiacode/ & https://fia.org.au/fia-code-course-practice-notes/
Australian Council for International Development - https://acfid.asn.au/content/read-code
The Australian Charities and Not-for-profits Commission (ACNC) - http://www.acnc.gov.au/
Australian Competition & Consumer Commission - https://www.accc.gov.au/
The PCI Security Standards Council - https://www.pcisecuritystandards.org/
The Office of the Australian Information Commissioner (OAIC) - https://www.oaic.gov.au/
Federal, State and Territory Resources and References - https://fia.org.au/fiacode/government-links/