Financial Controls, Anti-fraud, Anti-bribery and Conflicts of Interest Policy

Draft v1 — published temporarily while this policy is pending Board adoption.

How Upsurge Youth Network looks after its money, prevents fraud and bribery, and handles conflicts of interest, so that funders, members and the public can trust how funds are used.

Document Control

Status	Draft v1 — pending Board adoption (target: 30 November 2026)
Adopted / Adapted / UYN’s own	UYN’s own.
Review period	Annually, and whenever income, spending or the structure of the organisation changes materially
Responsible lead	Finance, Risk & Compliance Committee (a named trustee as Treasurer — to be confirmed); CEO (day-to-day); Board of Trustees (owner)
Statutory	Legal duties apply (Companies Act 2006; Bribery Act 2010; Fraud Act 2006; Proceeds of Crime Act 2002). A written policy is good practice and is expected by funders
Required on website	Summary only (section 1 and the conflicts declaration)
Ratified by Board on	[date — to be completed on adoption]
Review due	[date — to be completed on adoption]
Chair of Trustees’ signature	[signature — to be added on adoption]

Change History

Version	Date	Amendment or no change
1	October 2026	First draft. New policy created to complete UYN’s governance and compliance suite.

Website History

Version	Date on website	Notes
—	[not yet published]	[to be completed if a summary is published on darksalmon-gnu-318413.hostingersite.com]

Contents

1. Purpose and principles 2. Roles and responsibilities 3. Budgeting and reporting 4. Banking and handling money 5. Spending and approval limits (proposed) 6. Income: membership, grants, sponsorship and donations 7. Fraud prevention and response

8. Bribery, gifts and hospitality 9. Conflicts of interest 10. Training, whistleblowing and monitoring Appendix A. Conflicts of interest register (template) Appendix B. Gifts and hospitality register (template) Appendix C. Declaration of interests (for trustees, advisors, staff and key volunteers)

1. Purpose and principles

Upsurge Youth Network (UYN) is a not-for-profit company limited by guarantee. Its money, whether from membership, grants, sponsorship, donations, events or the shop, must be used to further its purposes and for nothing else. As a company limited by guarantee it cannot issue shares or pay dividends, and trustees cannot take a profit from UYN. This policy explains how UYN controls its money, deters and responds to fraud and bribery, and manages conflicts of interest.

• Stewardship. Funds are spent only on UYN’s purposes and in line with the budget and any funder conditions.
• Separation of duties. No one person can start, approve and pay for the same transaction, and no one approves their own claims.
• Transparency. Records are accurate, complete and available to trustees, auditors and funders.
• Integrity. We follow the Seven Principles of Public Life (the Nolan Principles): selflessness, integrity, objectivity, accountability, openness, honesty and leadership.
• Proportion. The controls are suitable for a small, volunteer-led organisation and will be strengthened as UYN grows.

2. Roles and responsibilities

Role	Responsibility
Board of Trustees	Approves the annual budget, accounts and this policy; sets financial limits; ensures UYN keeps within its Articles and the law; reviews the risk register.
Finance, Risk & Compliance Committee	Reviews management accounts at least quarterly; reviews controls and the conflicts register; oversees fraud risk; reports to the Board.
Treasurer (a trustee)	Leads on financial oversight; checks bank reconciliations and approves payments above the limit set in section 5.
CEO	Day-to-day financial management within the budget; ensures records are kept; reports spend against budget monthly.
Programme Manager	Manages the programme budget lines, raises purchase requests, and keeps records for events and time logs.
Everyone	Follows this policy, declares conflicts and gifts, and reports concerns straight away.

3. Budgeting and reporting

• The Board approves an annual budget before the year starts. The budget separates restricted funds (money given for a specific purpose) from unrestricted funds.
• Management accounts, showing income, spending against budget and cash, are produced monthly and reviewed by the Finance, Risk & Compliance Committee at least quarterly and by the Board at each meeting.
• The Board reviews the cost per member, forecast income and the gap to be raised against the Year 1 plan after each cohort.
• UYN keeps proper accounting records, files annual accounts and the confirmation statement with Companies House, and prepares funder reports when due. The Board will confirm whether an independent examination or an audit is required or advisable.
• UYN keeps the finance workbook and the time log up to date as the record of spending and volunteer and staff time.

4. Banking and handling money

• UYN has its own bank account in its own name. No UYN money is paid into, or mixed with, a personal account or the account of any other business.
• Payments out require two people: one to prepare or request and one to approve. Bank mandate signatories are agreed by the Board and reviewed annually. No one may authorise a payment to themselves or to a person connected to them.
• Online banking and card details are protected with strong authentication. Cards are not shared. Any card is issued to a named person with a limit set by the Board.
• Cash is avoided. If cash is received at an event or sale, it is counted by two people, recorded on a receipt sheet and banked promptly.
• Bank reconciliations are prepared monthly and checked by a person other than the preparer.
• Records are kept for at least 6 years from the end of the financial year [period to be confirmed with an accountant].

5. Spending and approval limits (proposed)

The Board will set the limits below before the first spending. The amounts shown are proposals only.

Spend (single item or related items)	Who may approve	Evidence
Up to [£100]	Programme Manager within budget line	Receipt or invoice
[£100] – [£500]	CEO	Receipt or invoice; purchase request
[£500] – [£2,000]	CEO plus the Treasurer or Chair	Two quotes (where practical); written approval
Over [£2,000] or outside the budget	The Board (or Committee, with delegated authority)	Three quotes or a written justification; minuted decision
Any contract over 12 months or with an automatic renewal	The Board	Written terms checked before signing

• Value for money is considered for every purchase, and orders are placed in writing. A purchase from a person or business connected with a trustee, the CEO or any member of staff needs approval by the Board under section 9.
• Staff and volunteer expenses are paid only against receipts and a signed claim, within an agreed expenses list, and are approved by someone other than the person claiming. Mentors and volunteers are unpaid and are reimbursed only for agreed out-of-pocket costs.
• When UYN employs staff, payroll, PAYE, National Insurance, pension auto-enrolment and the National Minimum Wage will be handled through a payroll provider or accountant, and pay changes are approved by the Board.

6. Income: membership, grants, sponsorship and donations

• Membership income (Trailblazer, Achiever and any free access) is recorded against the member register so that every payment can be matched to a member.
• Grants. Each award is recorded with its conditions. Restricted funds are held and spent only for the stated purpose, and the Board approves the acceptance of any grant that carries conditions. Grants are not counted as income in the budget until confirmed in writing.
• Sponsorship and donations. The Board decides whether to accept a gift that is unusually large, anonymous, conditional, from an overseas source, or from a source that could damage UYN’s reputation or independence. A sponsor’s support never gives it influence over who is accepted as a member, the content of the programme or UYN’s decisions.
• UYN does not describe itself as a registered charity, quote a charity number or claim Gift Aid unless and until charity registration is confirmed.
• Receipts are issued for donations on request, and donors’ personal data are handled under the Privacy Policy.
• Shop and online income follows the E-commerce Terms and Conditions and is reconciled to the payment provider’s statements each month.

7. Fraud prevention and response

Fraud includes false representation, failing to disclose information, and abuse of position to make a gain for yourself or another, or to cause loss to UYN (Fraud Act 2006). Examples include false expense claims, diverting income, inflating invoices, creating fictitious members or outcomes to meet a funder target, misusing a card, and falsifying records.

• Prevention. Separation of duties, bank reconciliations, approval limits, member register checks, regular reporting and a culture in which people can raise concerns.
• Reporting. Anyone who suspects fraud or financial irregularity must tell the CEO, the Treasurer or the Chair, or if the concern involves them, another trustee or (as a whistleblowing concern) as set out in the Staff Policies Pack. Do not investigate yourself or confront the person.
• Response. The Chair (or, if the concern is about the Chair, another trustee) convenes the Finance, Risk & Compliance Committee within 5 working days. The Committee secures records and access, decides who will investigate, and, where there is evidence of a crime, reports it to the police and Action Fraud.
• Wider reporting. UYN will tell the bank, insurers and any funder whose money is involved, as their terms require. If UYN becomes a registered charity, serious incidents, including significant fraud, will be reported to the Charity Commission.
• Outcome. The Board reviews what failed and strengthens the controls. Anyone who commits fraud may be dismissed or removed from their role, and UYN will pursue recovery where appropriate.

8. Bribery, gifts and hospitality

UYN does not pay or accept bribes. Under the Bribery Act 2010 it is an offence to offer, promise or give a bribe, to request or accept one, and to bribe a foreign public official. A commercial organisation can also commit an offence if it fails to prevent bribery by people who perform services for it, unless it has adequate procedures. UYN’s procedures are proportionate to its size and risk and are based on the Ministry of Justice’s six principles: proportionate procedures, top-level commitment, risk assessment, due diligence, communication and training, and monitoring and review.

• No one acting for UYN may offer or accept a gift, hospitality or favour intended to influence, or that could be seen as influencing, a decision.
• Gifts or hospitality valued at more than [£25] must be declared on the gifts and hospitality register (Appendix B) within 7 days, and anything above [£50] needs prior approval from the CEO or Chair and is usually declined. Cash or cash equivalents are never accepted.
• Offers made to a trustee or the CEO are reported to the Chair or Treasurer. Offers made to the Chair are reported to the Treasurer.
• Employers, sponsors and training providers who offer opportunities to members must not give or receive payments in return for placing a member. UYN does not charge members or employers to be paired for an opportunity, and the Board will approve any change.
• Facilitation payments are prohibited. Agents, suppliers and partners are told about this policy, and the Board is told of any suspicion.
• UYN will carry out reasonable due diligence on new significant donors, sponsors and suppliers (identity, ownership and reputation) and will not accept money from sources that it believes are linked to criminal conduct or sanctions. Concerns about money laundering are reported to the Treasurer, who will take advice and consider a report to the National Crime Agency.

9. Conflicts of interest

A conflict of interest exists where a person’s personal, family, business or other duties could, or could appear to, affect their judgement in a UYN decision. Conflicts are normal and are not wrong in themselves; the failure to declare and manage them is the problem.

• Declare. Trustees, advisors, the CEO, staff, mentors and volunteers declare interests when appointed, and update them within 28 days of a change. Interests are entered on the register (Appendix A).
• Agenda item. Declarations of interest are the first item at every Board and committee meeting.
• Manage. The Chair decides whether the person leaves the room, does not take part in the discussion or vote, or takes part with safeguards. The decision is minuted, and a decision tainted by an undeclared conflict can be set aside.
• Payments and benefits. A trustee may not be paid for being a trustee, and any payment to a trustee or a person connected with one for goods or services (or any other benefit) needs the express authority of the Articles and Board approval, with the person excluded from the decision. [To be checked against the Articles of Association.]
• Connected organisations. UYN is separate from any other business that a trustee, the CEO or the founder owns or is involved in, including Upsurge Global Limited. Any proposed transaction, contract, loan, shared cost or use of premises, staff, brand or data between UYN and such an organisation must be declared, priced at arm’s length, approved by the Board without the connected person, and recorded in writing. UYN does not rely on, or claim the track record of, any other organisation.
• Opportunity pairing. A mentor, trustee or member of staff must not match a member to an employer or provider in which they have a personal or financial interest without declaring it, and the Programme Manager reviews the matching.
• Funders and sponsors. A person with a financial relationship with a funder, sponsor or supplier declares it before that body is approached or a decision is made.

10. Training, whistleblowing and monitoring

• Trustees, the CEO and the Programme Manager receive a briefing on this policy at induction and annually. Mentors and volunteers are told the key rules about gifts, expenses, conflicts and fraud.
• Anyone can raise a concern in good faith without fear of retaliation, under the whistleblowing arrangements in the Staff Policies Pack (Part D) and the Safeguarding Policy.
• The Finance, Risk & Compliance Committee reviews the registers, any breaches and the control checks each year and reports to the Board. UYN will consider whether an independent review of controls is needed as income grows.

Appendix A. Conflicts of interest register (template)

Name and role	Interest declared	Date declared / updated	Decision and safeguard	Reviewed by / date

Appendix B. Gifts and hospitality register (template)

Date	Offered by / to	Description and estimated value	Accepted? (Y/N)	Reason / approver	Entered by

Appendix C. Declaration of interests (for trustees, advisors, staff and key volunteers)

Item	To be completed
Name and role
Other directorships, trusteeships and business interests (including shares)
Close family members or partners who work for, supply, or are funded by UYN or a funder or partner
Connection with any organisation that could do business with UYN (supplier, sponsor, employer, training provider)
Any other interest or loyalty that could affect your judgement
I confirm this is accurate and I will update it within 28 days of any change. Signature and date

Upsurge Youth Network · Financial Controls, Anti-fraud, Anti-bribery and Conflicts of Interest Policy · Draft pending Board adoption  ·  Page