Last updated 16 March 2026
1. Our Fundraising Principles
The People’s Strategy Project exists to serve the long-term public good by strengthening democratic, educational, and research capability, public trust and collective agency. Our approach to fundraising reflects this purpose. We seek to build a broad base of support that enables independence, legitimacy and shared ownership of the work. We believe that how funds are raised matters as much as how they are used. Fundraising is therefore conducted in a way that:
- Enables participation from individuals and organisations of all means;
- Safeguards independence from political, commercial or other external influence;
- Is transparent about purpose, use of funds and decision-making; and
- Strengthens public trust in the project and its public purposes more broadly.
2. Our Aim
We see fundraising not only as a means of resourcing our work, but as an opportunity to model values of openness, shared responsibility and civic contribution that underpin the project itself.
Our promise to the general public and our supporters is that our fundraising, in all its forms, is legal, open, honest and respectful. We will be honest about how donations are used to fulfil our mission, open about the methods we use to raise funds, respectful to the wishes, preferences, personal information and circumstances of the people we interact with and we will take all steps necessary to comply with the law and sector fundraising practice standards.
Nobody directly or indirectly employed by or volunteering for PSP shall accept commissions for fundraising activities. No general solicitations shall be undertaken by telephone or door-to-door to the public. If those involved in fundraising identify signs of vulnerability in an existing or prospect donor, they will respond appropriately and according to the principles, stated above, of being legal, open, honest and respectful. Furthermore, we will always strive to respect the wishes and preferences of the donor. We will not discriminate against any group or individual.
3. What are the Fundraising Activities Covered by this Policy?
It is generally intended that monies will be raised by direct appeal or application to high net worth individuals, companies and other organisations, other charities and trustees whose objectives or aims align with the PSP objects.
In addition, in rare occasions fundraising might take place through:
- a fundraising appeal
- events at which fund raising occurs
- legacies left for the benefit of PSP
On a case-by-case basis, PSP may consider accepting tangible personal property (gifts-in-kind) where PSP Trustees determine that it would be in the best interest of PSP to accept so long as any potential conflict of interests are declared and carefully considered before acceptance.
This policy applies to all such fundraising activities.
In all cases Anti Bribery & Corruption, and Anti Money Laundering laws and regulations will be complied with.
4. Who is Authorised to Fundraise?
Fund raising may only be carried our PSP Trustees, PSP staff so authorised by the Board of Trustees and any professional fund raisers appointed by the Board provided that they have agreed to abide by the policies herein.
5. Regulation
PSP will comply with regulations as set out by the Charity Commission[1]. PSP will also adhere to the Fundraising Code and standards as laid out by the Fundraising Regulator.
5.1 The Acceptance of Donations:
Except as below, we will only accept donations from UK bank accounts; the robust systems in place for monitoring accounts and detecting potentially fraudulent transactions and instructions throughout the UK banking sector, as directed by the Financial Conduct Authority (FCA) are sufficient to mitigate the risk of a donation coming from an illegal source of funds.
We are committed to transparency in its funding. While we may respect a donor’s wish to remain anonymous publicly, the Trustees must be satisfied as to the donor’s identity, the source of funds and the motivation for the donation.
We will not accept:
- Donations with conditions attached
- Donations from political parties or their affiliates
- Donations from individuals or organisations on the consolidated lists of financial sanctions targets and proscribed organisations
- Donations that seek to influence PSP’s governance, leadership, agenda-setting, deliberative processes or outputs, whether explicitly or implicitly or
- Donations which, in the opinion of the Trustees, are likely to prejudice the independence of PSP.
Donations will not be accepted where the Trustees judge that the donor’s motivation, expectations or associations could reasonably be perceived as compromising the independence, integrity or public trust of the Project.
At the discretion of PSP, donations by cheque may be accepted but will still be subject to the due diligence screening thresholds.
5.2 Donations via Overseas Bank Accounts
Any don ations accepted through overseas banks must be authorised by the Board of Trustees in advance. In addition to complying with requirements of this policy on due diligence, such donations will only be accepted if they are:
- Remitted directly from the overseas bank to PSP’s own bank account
- The overseas bank is in a jurisdiction which have anti-money laundering regulations equivalent to, or stronger than, those in the UK; the current list of such jurisdictions is given in Appendix 1 and will be reviewed and updated as necessary by the Board of Trustees
- The overseas bank is regulated by the appropriate banking authority in the country concerned.
5.3 Due Diligence on Donations
One-off donation of up to (and including) £10,000
- No screening
- Minimum donation of £10
In respect of donations over £10,000: donors must be
- Known to and vouched for by a Trustee or
- A recognised charity or fund or
- An individual where we have established their identity and have a UK address [or a permanent residential address in a country listed in Appendix 1] or
- A company with a registered address in the UK which has been trading for at least 12 months and filed financial statements [ or which is resident in and listed on a recognised stock exchange in a country listed in Appendix 1].
In respect of donations over £100,000:
- In addition to the above requirements, enquiries must be carried out and documented to assess the legitimacy of funds being donated to ensure that they are not derived from illegal activities. The adequacy of such checks must be reviewed by the Board of Trustees on a case-by-case basis before such donations are received.
5.4 The Review of Donations
If at any time any fundraising activity is recognised by the Board of Trustees as having the potential to be fraudulent, tax avoidance or part of suspected criminal proceeds, the matter will be reported to the relevant authorities: Action Fraud and The Charity Commission and/or HMRC as appropriate.
If at any time we have reasonable cause to suspect that a donation is related to terrorist financing, the matter will report the issue to the police as required by Counter-Terrorism Act. In the case of money laundering, reports should be made to the police, a customs officer (HMRC), or an officer of the National Crime Agency.
5.5 The Return of Donations
As a rule, charities are not permitted to refund any donations. However, there may be exceptional circumstances relating to Financial Fraud and/or Money Laundering; if either is suspected we will follow government guidance set out here:
PSP will also follow guidance set in The Code of Fundraising Practice which refers to guidance issued by the Institute of Fundraising which can be found here
This states:
“donations MUST only be refunded in line with any policies or in exceptional circumstances”.
It may not be lawful to return a donation and we may take advice from legal advisers or the Charity Commission before doing so.
In some situations we may have a legal obligation to refund a donation if certain conditions were attached to a gift. For example, where an appeal for a particular purpose fails to raise sufficient funds to achieve that purpose.
In other situations we may have a moral obligation to refund a gift, for instance:
- Legacies – If we receive a legacy but there is evidence that the person who died had changed their mind since making the will.
- Other gifts – An example might be where a person has made a gift but it later became clear that the donor’s generosity had reduced them to poverty, the Trustees might feel morally obliged to make an ex gratia payment by returning all or part of the gift
- People in vulnerable circumstances – guidance has been issued by the Fundraising Regulator and the Institute of Fundraising which may lead to donations needing to be refused or refunded.
6. Ethics
With the exception of the above scenarios, we will only refuse donations if we can maintain that the refusal of that donation is correct in terms of the Trustees’ duty towards fulfilling the charitable objective of PSP. More specifically, we would refuse any donation where in our considered opinion it would:
- compromise our status as a bastion of free speech;
- limit the matters on which PSP could hold debates or speaker meetings or impose any restriction on the subject or content of subjects raised at such debates or speaker meetings or on books and other material held in our libraries;
- contradict the aims and objects of the Trust;
- cause damage to the reputation of PSP.
Process: Any request for a refund should be made in writing to the Chair of PSP and the Company Secretary. This request will trigger a review of the circumstances of the request, including personal details of the donor, the intended purpose of the donation (if applicable), the method of donor payment and the reasons for the refund. Advice will be sought from the Charity Commission if we believe this is required. Refunds will be made using the original mode of payment as far as possible.
7. Donor Research and Data Protection
Data may be retained on donors and prospective donors for the purposes of fundraising and for accounting, legal or regulatory purposes.
PSP will comply with requirements of the Data Protection Act 2018, the General Data Protection Regulation and the Privacy and Electronic Communications (EC Directive) Regulations 2003 and such other data protection regulation as is in force from time to time.
Further details can be found in our Data protection and privacy policy. [to be drafted]
We will respect the privacy and contact preferences of all donors and will respond promptly to requests to amend or remove contact details except to the extent that we are required to retain them for accounting, legal or regulatory purposes.
8. Complaints Process
For public fund-raising, a clear process for raising a complaint will be published alongside any fundraising materials including but not limited to printed materials and online campaigns.
9. How PSP Communicates this Policy
This policy will be published on PSP’s website and made publicly available. PSP will also publish high-level information about its funding sources and funding model, in line with Charity Commission guidance, in order to support transparency and public confidence.
The policy will be communicated to all PSP Trustees, the Company Secretary and each employee of the Company on their joining and to any person working on PSP’s behalf on fundraising when they commence that work. This policy may be re-visited should the risk profile of PSP be deemed to change or for any other reason deemed necessary by PSP Trustees. This policy is subject to review and PSP reserves the right to amend the policy without prior notice.
ENDS
Agreed by the Board 16 March 2026
APPENDIX 1: ACCEPTABLE COUNTRIES
For the purposes of this policy, the following countries are deemed to have money laundering regulations equivalent to or better than those in the UK:
- European Union Countries which have implemented the EU Anti-Money Laundering Directives including 6AMLD
- United States of America
- Canada
- Australia
- New Zealand
- Singapore
- Hong Kong
- Japan
Last updated 16 March 2026
[1] At the date this policy was approved PSP has yet to apply for, or receive, approval from the Chairty Commission to be a registered Charity. Notwithstanding this, as far as possible, PSP will comply with Charity Commission regulations and guidelines. Once Charitable Status is obtained PSP undertakes to comply with all Charity Commission regulation and guidelines.