As a registered charity and company limited by guarantee we are required to maintain accounting records and controls to satisfy the requirements of the Companies Act 2006 and Charities Act 2011.
The trustees of the charity, who are also directors of the company, have a legal duty to safeguard its assets and apply them exclusively to the furtherance of its declared charitable aims and objectives.
These requirements are expanded by the key principles listed in section 2.
Within this Purpose the Policy may, in exceptional circumstances, be overridden by the Chief Executive Officer (CEO) by prior agreement with the Chair or Treasurer as an emergency decision between Board Meetings. Any such override will be immediately reported by the CEO to the Board.
The CEO is responsible for ensuring that the Policy is adhered to, in conjunction with, and subject to the overall legal responsibility of, the board of trustees.
The key principles underlying this Policy are that:
- Legal obligations to keep adequate records to be able to prepare, publish and file statutory accounts are satisfied
- Assets are safeguarded from undue loss, and from misuse, damage or fraud
- Assets are applied to further our Objects in the most effective and efficient way
- Finances and assets are administered in a way that identifies and manages risk
- Controls in place are proportionate to the risks
- The highest standard of record keeping and financial reporting is maintained
- Financial reporting is clearly expressed, comprehensive and transparent
- Duties are sufficiently segregated to satisfy the demands of charity governance
Effective financial controls rely on the personal integrity of all the people involved - including those making payments, claiming for reimbursement, authorising, monitoring or controlling budgets.
- We will apply Charity Commission guidance regarding checks on trustees and members of the senior management team prior to appointment.
- Where issues are revealed or disclosed, these will be treated sensitively and discreetly, having due regard for the privacy of the individual but ensuring that chapters' assets are not put at undue risk.
- Compliance with the Conflict of Interest policy will be monitored at least annually.
Accounts, accounting records and internal controls
Accounting records and internal controls shall be maintained to allow the timely production of quarterly financial management reports and statutory accounts that satisfy external auditors or independent examiners, and any conditions imposed by any grantor that have been accepted by the Board.
Accounts shall be prepared annually and audited by registered auditors appointed by the company at the previous Annual General Meeting. Where allowed by charity law the Board may, at its discretion, opt for the statutory accounts to be independently examined instead of audit and references to audited accounts in this policy shall be read to include that option. The Board shall consider the reasonable requirements of major donors or grantors when exercising this option.
The Board shall agree an annual budget, where possible before the start of the financial year to which it relates to give effect to the operational plan agreed for the year. Information shall be collected as is necessary to prepare a budget on a direct costs and an absorbed costs basis by the start of each financial year.
The annual budget shall include a projection of income and the reserves position at the end of the forthcoming financial year. The annual budget and projection of income shall be reviewed by the Audit and Risk Committee (ARC) before presentation to the Board for their agreement.
The agreed annual budget shall be reforecast if in the opinion of the Chief Executive there is a material change that warrants it and in that event the reforecast budget shall be reviewed and approved by ARC and the Board at their next scheduled meetings.
Income and Expenditure
Detailed regulations on the procedures around the acceptance and recording of income and the incurring of expenditure shall be maintained and agreed by ARC. The following principles shall be followed:
Acceptance of non-immaterial donations subject to donor restrictions of any kind shall be subject to Board agreement in accordance with the Donations and Grants Acceptance Policy
All payments from any source must be from budgeted expenditure or otherwise approved in accordance with the Procurement Policy and the Scheme of Delegation.
No commitment to expenditure shall be made without the prior knowledge and agreement of the relevant budget holder.
Creditors shall be paid promptly in accordance with terms agreed.
- All bank accounts will be held in the name of Wikimedia UK
- No account will be opened or closed in the name of the charity without Board authorisation (except that an account that is in the view of ARC redundant may be closed and noted at the next Board meeting).
- Signatories on all bank accounts and electronic banking powers shall be decided by Board resolution.
- Bank payments or other written instructions require at least two signatories except as described in paragraphs 5 to 8.
- Electronic banking payments will be set-up online and authorised in accordance with the Scheme of Delegation concerning small or recurring payments.
- The Treasurer shall act as the administrator of the electronic banking system.
- The CEO will be a main mandate signatory and can be a signatory to current and deposit accounts
- No signatory or authoriser may authorise payments to themselves as a sole authoriser.
- The credit rating, charges and interest of all banks used shall be reviewed at least annually.
- Bank reconciliations are to be prepared monthly for all accounts including credit, debit or any other type of payment card. These shall be reviewed by the Chief Executive, who may delegate this task to the Director of Finance and Operations.
- All transactions shall be recorded in accordance with standard accountancy practice using software approved by ARC that allows accounts to be produced readily that comply with the requirements of the Charities Statement of Recommended Practice: SORP(FRS102)
- If so specified by a grantor and agreed by the Board income shall be treated as a discrete (restricted) fund and expenditure shall record the fund from which it is made.
- Money held with any single financial institution or group should be no more than the current Government guarantee limit unless specifically authorised.
- Choice of deposit accounts will take account of credit worthiness, qualification for the government guarantee scheme (ie UK banks only) and interest rates.
- Adequate training (in house or otherwise) is to be provided to all involved in online financial transactions.
- A Register of Fixed Assets shall be maintained listing all assets at or above a value determined from time to time by ARC.
- All physical assets shall be physically verified at least once a year or more frequently where the Chief Executive considers it appropriate.
- All assets shall be appropriately safeguarded from loss or damage
- Adequate insurance cover shall be maintained to protect against any substantial loss.
Wages and Salaries
- Full records of all payroll payments and deductions shall be maintained and returns and payments made to satisfy audit and HM Revenue & Customs regulations.
- Payroll may be outsourced to a reputable bureau.
- Where payroll services are outsourced the performance of the bureau shall be reviewed annually.
- Payroll and HMRC payments shall be made directly by the charity.
- Monthly payroll reports are reviewed by the Director of Finance and Operations (DFO) or the Chief Executive.
- Statutory returns and payment of deductions shall be made to HMRC by due dates.
Reporting (internally and externally)
- A Quarterly Financial Management Report (QFMR) approved by ARC shall be presented at each Board meeting held more than one month after a quarter end (April, July, October, January).
- Audited annual accounts shall be filed with the Charity Commission, Companies House, the Wikimedia Foundation and published to members as required.
Authorisation of expenditure
Clear and public authority levels are agreed as set out in the scheme of delegation.
All expenditure from any source shall be pre-authorised by a budget holder.
Secure procedures will be agreed for any payment working within the bank's system procedures to ensure separation of duties, and authorisation at the appropriate levels.
All payments shall be by electronic transfer unless agreed by the CEO
Staff or trustees may be provided a credit or debit card if a clear need can be demonstrated, after approval by ARC
- Provision of a card can be withdrawn by the Board, ARC or by the CEO at any time
- Individuals receiving a Wikimedia UK card shall agree to a deduction from their salary or other amounts owed to them in the event of improper use of the card/expenditure.
- If a card user ceases in their role with the chapter, their cards will be cancelled and destroyed
- All statements will be sent directly to the offices of Wikimedia UK
- All expenses incurred using a card must be authorised by a budget holder
- All card use must be supported by appropriate receipts etc.
- There will be an annual review of card use to ensure proper practice.
- A small cash float up to a maximum determined by ARC may be held in the office safe.
- Transactions from the cash float shall be recorded in the accounting system.