1. Policy Statement 

1.1. This policy is a statement of principles outlining Mary’s Meals’ commitment to ensuring that money is received, held and transferred safely. The Mary’s Meals aspiration is that all network entities implement local policies and processes to achieve this in line with local laws, regulations and guidance. 

1.2. The Protection of Funds policy aligns with other global policies including Whistleblowing and Anti Bribery & Corruption. 

1.3. Mary’s Meals is committed to:

• the good stewardship of resources entrusted to us;
• safeguarding all money and assets transferred to us and acting prudently ensuring no funds or assets are put at undue risk;
• ensuring that all charity funds are managed effectively and appropriately;
• mitigating against the risks of funds being transferred to or from illegal activities such as terrorism or other forms of extremism;
• ensuring appropriate due diligence, monitoring and verification of funds flowing through the organisation;
• promoting the safe holding, moving and receiving of funds internationally. 

2. Purpose 

2.1. The purpose of this document is to:-

• Outline Mary’s Meals’ zero tolerance approach to unsafe and illegal transfers of funds.
• Provide guidance on the action that should be taken across the movement to ensure that funds are always protected and are not from illegal sources, such as terrorism.
• Set out our responsibilities, and of those working for and on our behalf, in observing and upholding our position on the protection of funds.
• Set out the requirement that all funds received, held and moved by all involved in the Mary’s Meals movement is done so safely without undue risk. 

3. Scope / Applicability 

3.1. This policy is applicable to MMI, National Affiliates and Programme Affiliates. It applies to all Mary’s Meals employees, Board Members and volunteers within all regions, areas and functions, wherever located. 

3.2. Mary’s Meals expects partners to adhere to the general principles of this policy and these expectations are set out in the Partner Agreement. 

4. Who is Responsible for this Policy 

4.1 The MMI Board and each Affiliate Board (subject to the terms of their Scheme of Delegation) have overall responsibility for ensuring this policy, and all local policies and procedures flowing from this, comply with all legal and ethical obligations, and that all those under the scope comply with it. 

4.2. Each Mary’s Meals entity should put in place suitable arrangements for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in protecting funds from undue risk. 

4.3. Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and any policies and procedures flowing from this. 

5. Source of Funds 

5.1. Each Mary’s Meals entity is responsible for understanding the source of any funds they receive. In particular, each entity must take care to ensure they understand the source of funds received from major donors or large institutions. 

5.2. Prior to accepting any donations or funds, entities should ensure they follow the relevant and proportionate due diligence procedures to obtain reasonable assurance that the money is not from an illegal source. 

6. Holding Funds 

6.1. Each Mary’s Meals entity is responsible for ensuring that any funds received are held securely with an appropriate financial institution. 

6.2. Each Mary’s Meals entity should keep appropriate records of funds being held and ensure accounts are accurate. 

7. Transfer of Funds 

7.1. When receiving, holding and moving funds, all Mary’s Meals entities will take proper care to ensure the charity's money is held safely, not placed at undue risk and reaches the destination for the purposes intended. 

7.2. All Mary’s Meals entities will take reasonable steps to ensure that the end use of funds is consistent with the purpose of our mission. 

7.3. When transferring funds, all Mary’s Meals entities must ensure that each transaction has been properly authorised and a positive confirmation of receipt is received. All transactions should be recorded and traceable in line with all relevant finance policies and procedures 

7.4. Subject to their own operational cost requirements, National Affiliates should transfer all funds raised to Mary’s Meals International as soon as possible so as to ensure that these funds can be used for our charitable purposes promptly. 

8. Due Diligence 

8.1. Mary’s Meals does not permit or condone the misuse of charitable funds, either through the activity of Mary’s Meals itself or through its Affiliates, Partners, Donors and Volunteers. 

8.2. All Mary’s Meals entities must ensure that they have systems, procedures and controls in place to ensure that they manage the risk of becoming involved in financing or supporting illegal activity and/or the misuse of funds. 

8.3. The main recommended system of control is to put in place a comprehensive due diligence process, requiring detailed checks to be carried out on those we intend to fund, or receive funds from (whether an individual or commercial entity) before the relationship commences. All such checks should be documented. 

8.4. Due diligence checks should be broad and thorough, including (but not limited to):- • lists of proscribed terrorist groups/persons; • financial sanctions lists; and • all other regulatory compliance lists that apply in the relevant jurisdiction 

8.5. These processes and controls should be reviewed and updated regularly to include new checks as they become available. 

8.6. If a member of staff or volunteer uncovers illegal activity such as terrorism, extremism or otherwise concerning as a result of a due diligence check, processes should be put in place to ensure that this can be promptly recorded, reported and acted upon. 

9. Reporting and Accountability 

9.1. All Mary’s Meals staff and volunteers across the Network have a duty to protect Mary’s Meals from the reputational and financial damage that could be caused by receiving money from or transferring money to third parties involved in illegal activities such as terrorism or other forms of extremism. 

9.2. If any Mary’s Meals entities become aware, whether through due diligence checks or otherwise, that a third party transferring to or receiving money from Mary’s Meals has any connection whatsoever to illegal activity concerning terrorism or misuse of funds, they shall promptly report the concerns in accordance with the relevant local reporting procedures. 

9.3. The Global Whistleblowing Statement should be referred to where concerns cannot be reported through the normal management channel. Any such concerns should be reported in line with the relevant whistleblowing procedure or other relevant local reporting process as soon as possible. 

9.4. Mary’s Meals is committed to ensuring that we meet our obligations to report suspected illegal activity to the relevant external authorities and all individuals should be encouraged to report as necessary.

9.5. All Mary’s Meals entities reserve the right to terminate their relationship with third parties if there has been a breach of this policy. 

9.6. Each Mary’s Meals entity should put in place appropriate procedures to deal with a discovery that money already received has come from an illegal source. Any such discovery should be dealt with promptly using the formal process and the entity should consider whether there is an obligation to report to the relevant local law enforcement authorities. 

10. Local policies and procedures 

10.1. All Mary’s Meals entities must ensure that this policy has been read, understood, and complied with, and commit to creating and implementing local policies and processes to support the principles outlined in this policy, which should be acknowledged by all. 

10.2. All Mary’s Meals entities are encouraged to provide training to all relevant staff or volunteers on local policies flowing from this, and to ensure a high level of understanding of the need for checks to prevent the unlawful transfer of funds. 

10.3. Breaches of this policy, or any local policies and procedures, should be taken seriously and dealt with appropriately by the relevant Mary’s Meals entity.