Donor Acceptance Policy

Date of last review: 7th April 2026
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1. Purpose
Happy Doggo is a UK-registered charity and 501(c)3 whose mission is to fund humane dog population management programmes across South East Asia. The trustees recognise that not all donations are equally compatible with that mission. This policy sets out the criteria by which Happy Doggo will accept, condition, decline, or return donations, and the process by which decisions are made.The policy supports Happy Doggo's obligations under the Charities Act 2011, the guidance of the Charity Commission for England and Wales, the regulations of the US Internal Revenue Service (IRS), and the charity's own risk management framework.
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2. Scope
This policy applies to all donations received by Happy Doggo regardless of source, form, or value. This includes:

- One-off monetary donations received online, by post, or in person
- Regular giving and direct debits (including US ACH transfers)
- Corporate donations and sponsorships
- Legacies and gifts in wills (and US bequests)
- Gifts in kind
- Grants received from other charitable foundations
- Fundraised income collected by third parties on behalf of Happy Doggo.

3. Approved programmes  ‍
Happy Doggo maintains a defined list of active programmes to which restricted donations may be designated. As of the date of last review, the approved programmes are:
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Tina's Hospital - current: capital and construction costs; future: veterinary surgical and medical care operating costs
‍Alba’s Kitchen - daily food production and delivery
‍Happy Doggo Land - sanctuary and long-term care programme providing rehabilitation and adoption services.
‍CNVR - Catch, Neuter, Vaccinate, Return population management programme facilitated via Happy Doggo and grant partners

This list will be reviewed by the trustees at least annually and updated as programmes are created, closed, or renamed. Any changes to the approved programme list must be formally approved by the Board of Trustees and reflected in an updated version of this policy. In accordance with US tax law and accounting standards, the Board retains variance power to redirect funds if a restricted purpose becomes unnecessary, incapable of fulfillment, or inconsistent with the charitable needs of the organization.

4. General acceptance criteria‍
Happy Doggo will ordinarily accept a donation where all of the following conditions are met:
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- The donation does not come with conditions that conflict with the charity's objects or values.
- The source of the funds has been considered and does not present a material reputational, legal, or ethical risk.
- The donation does not require Happy Doggo to act outside its charitable objectives.
- The donation complies with US IRS "Public Support" tests to maintain 501(c)3 status.
- If restricted, the donation is designated to one of the approved programmes listed in Section 3.

5. Due dilligence thresholds
5.1 Standard donations (donations below £25,000/$25,000): Donations below £25,000 / $25,000 will be processed under standard administrative procedures. Anonymous donations below £25,000 / $25,000 may be accepted at the discretion of the Chief Executive or a designated trustee.

5.2 Significant donations (£25,000/$25,000 and above): Any donation of £25,000 / $25,000 or above will be reviewed and accepted on a case-by-case basis by the executive management team before the funds are accepted or applied.
The enhanced due diligence process for significant donations will include, as a minimum:

- Verification of the donor's identity and, where applicable, the identity of the ultimate beneficial owner of the funds.
- For US-based or USD donations, screening against the OFAC (Office of Foreign Assets Control) Specially Designated Nationals list.
- A review of publicly available information about the donor's activities, reputation, and any associations with causes or organisations that may conflict with Happy Doggo's values.
- Consideration of any conditions or designations attached to the gift and their compatibility with this policy.

‍6. Restricted donations and programme designation
6.1 Accepted restrictions: Happy Doggo welcomes donations designated to any of the approved programmes listed in Section 3. Where a donor specifies an approved programme, the funds will be held in the relevant restricted fund and applied in accordance with the donor's stated wishes and the programme's objectives. Happy Doggo will provide contemporaneous written acknowledgment for all US donations over $250 as required by the IRS.  

6.2 Donations designated to an unapproved programme: Where a donor designates a donation to a programme, project, or purpose that is not included in the approved programme list, Happy Doggo will not automatically accept the donation as restricted. Instead, the following process will be followed:

Step 1 — Contact the donor: A representative of Happy Doggo will contact the donor promptly to explain that the specified programme does not currently exist or is not active, and to explore one of the three outcomes set out below.
‍Step 2 — Agree one of the following outcomes:
- Redirect to an approved programme. The donor agrees to redesignate the gift to one of the four approved programmes. This outcome is preferred where the donor's intended purpose is closely aligned with an existing programme.
- Make the donation unrestricted. The donor agrees to remove the programme restriction, allowing Happy Doggo to apply the funds wherever they are most needed in furtherance of the charity's objects. This outcome is appropriate where no existing programme closely matches the donor's intent.
- Return the donation. If the donor is unwilling to adjust the designation and the donation cannot be accepted in an unrestricted form, Happy Doggo will return the funds in full. A return of funds will be authorised by a trustee and documented.
‍Step 3 — Document the outcome: The outcome of the conversation with the donor, including the basis for any decision to redirect, release, or return the donation, will be recorded by the Chief Executive or a designated staff member and retained in accordance with Happy Doggo's data retention policy.

7. Anonymous donations
Happy Doggo recognises that some donors wish to give anonymously. Anonymous donations will be accepted subject to the following conditions:
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- Anonymous donations below £25,000 / $25,000 may be accepted at the discretion of the Chief Executive, subject to standard sanctions screening where any donor information is available.
- Anonymous donations of £25,000 / $25,000 or above will require a trustee decision. The trustees will consider whether it is possible to conduct adequate due diligence and whether acceptance is consistent with the Charity Commission's guidance on anonymous donations.
- While a donor’s identity may be kept anonymous from the public, Happy Doggo must collect the donor's name and address for internal records to comply with IRS Schedule B (Form 990) and UK anti-money laundering (AML) expectations.
- Where the source of an anonymous donation cannot be adequately assessed and acceptance would present a reputational or legal risk, the trustees may decline the donation.


8. Declining and returning donations
Happy Doggo reserves the right to decline or return a donation at any stage where:
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- Due diligence reveals a material risk that could not be identified at the time of receipt.
- The donor attaches conditions that are incompatible with the charity's objects, values, or independence.
- The donation is designated to a programme outside the approved list and no resolution under Section 6.2 can be reached.
- Acceptance would place the charity in breach of UK law, charity law, US Federal law (including the Patriot Act), or sanctions regulations.
- The donation results in impermissible private inurement or private benefit to a disqualified person under IRS rules.
- The trustees determine, in their reasonable judgement, that acceptance would damage the charity's reputation or undermine public trust.

Where a donation is returned, the return will be documented, authorised by a trustee, and reflected in the charity's financial records. Returned funds will not be recorded as income in the charity's accounts.

9. Gifts in kind
Non-monetary donations will be assessed for compatibility with Happy Doggo's operational needs and values. The trustees or Chief Executive will consider whether a gift in kind can be used directly by the charity or its grantees, converted to cash, or must be declined. The same programme designation principles in Section 6 apply where a donor attaches a specific purpose to a gift in kind. For US donors, Happy Doggo will acknowledge receipt of property but, in accordance with IRS rules for Form 8283, will not provide a dollar valuation of the gift on the tax receipt.

10. Record-keeping
Happy Doggo will maintain records of:
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- All significant donations (£25,000 / $25,000 and above) and the due diligence conducted.
- All donations that were declined or returned, and the reasons.
- All restricted donations, the programme to which they are designated, and how they were applied.
- All US donor acknowledgments and tax-related filings.

‍Records will be retained for a minimum of seven years in accordance with HMRC requirements, the Charity Commission's guidance on financial records, and US IRS record-keeping standards.

11. Review and governance
This policy will be reviewed by the Board of Trustees at least once every 12 months or sooner in the event of a material change in the charity's programmes, a significant donation decision that reveals a gap in the policy, or updated Charity Commission, HMRC, or IRS guidance.

Any trustee or member of staff may propose a revision to this policy. Proposed changes must be approved by a majority of the Board of Trustees and recorded in the Board minutes before taking effect.