Ukraine humanitarian crisis: guidance for charities and trustees
Guidance for charities and trustees responding to the crisis in Ukraine.
Applies to England and Wales
The situation in Ukraine is changing rapidly. We recognise the complex challenge this poses for charities responding to the crisis at home or abroad. We have set out below our guidance on the most commonly asked questions and will be reviewing this guidance regularly.
For members of the public, please see advice on:
Fundraising and Ukraine appeals
Many charities are already raising funds and have launched appeals. Our guidance about emergency appeals explains how your charity can help when responding to an emergency. It includes advice about collaborating with other charities and managing risks when planning an appeal.
Setting up a new charity to help the people of Ukraine
We recognise that people want to take urgent action and help those in need.
Whilst we are prioritising applications to register charities with objects that relate to the crisis in Ukraine, we encourage those applying to first consider whether supporting an established registered charity with relevant experience may be more efficient: existing humanitarian charities know how to get help to those who need it and know how to operate safely on the ground.
For example, the Disasters Emergency Committee (DEC), a coalition of 15 leading UK charities, has launched its collective appeal for Ukraine and many other registered charities are also helping to provide vital services to those caught up in the conflict.
To find charities helping in relevant areas, you can search the public Register of charities.
Changing charitable objects to support the Ukraine crisis
Naturally, lots of charities are considering whether they can provide support at this time. You should first consider whether your charity’s existing charitable objects allow you to help. These are set out in your charity’s governing document.
If your existing objects do not allow you to help, you may be able to amend your governing document to change them. But consider first:
- whether there are other charities that may be better placed to respond than yours
- the wider and longer-term impact of changing your charity’s objects including on your existing beneficiaries
- whether it is in the best interests of your charity
Use the principles of trustee decision-making and take independent professional advice if appropriate.
If you decide it is in your charity’s best interests to change your charity’s objects, use our guidance on how to make changes to your charity’s governing document.
Dealing with a large increase in funding
If your charity receives a sudden, significant, increase in funding to help respond to the crisis in Ukraine, it is important that, as trustees, you carefully consider the practical implications for your charity. This is all the more important if you are a smaller charity and the proportionate increase in your funding is very large.
Extra funding should enable you to make a bigger difference for your beneficiaries, but it is important that you:
- review whether you need to change the way you work and how your charity operates, for example bringing in more expert staff in support areas such as financial management, as well as operational or ‘front line’ areas
- maintain clear records on decision-making, with supporting evidence, even during busy periods
- assess the risks of dealing with the extra income, for example checking whether your charity’s financial controls are still suitable
- think about whether your reporting requirements may change
Read our guidance on charities and risk management for further support with identifying, assessing and managing risks.
Safeguarding
Protecting people and safeguarding responsibilities are a fundamental part of operating as a charity for the public benefit.
Operating safely and effectively in a conflict zone is incredibly complex, as is providing support to those fleeing conflict zones, but it is critical that charities protect and safeguard their beneficiaries, volunteers and staff. We urge trustees to read:
- our Regulatory Alert on the increased risk of sexual exploitation and abuse and sexual harassment
- our safeguarding guidance for charity trustees, and take reasonable steps to protect from harm all those who come into contact with your charity
- our guidance on how to manage risks when working internationally, and ensure you are identifying and managing the risks to your charity
- the Foreign, Commonwealth and Development Office (FCDO) country advice and monitor and assess any updates to that advice
Organising or participating in aid convoys
Trustees of charities and charitable appeals providing humanitarian support should exercise significant caution before organising and/or participating in a convoy to Ukraine or its borders.
There are often inherent risks associated with convoys, including around safeguarding, terrorism and fraud and theft, which the Commission has, in other conflict zones, seen a number of charities fail to adequately manage.
Trustees should therefore consider whether they have the necessary expertise and understanding to ensure safe delivery, and if it is the most effective way to get aid to those in need. Supporting local economies by buying much needed goods close to the point of need is often a more practical and sustainable alternative.
In addition, the Foreign, Commonwealth and Development Office (FCDO) advises against all travel to Ukraine and no longer provides consular assistance in person due to the security situation.
Charities that appeal for or purchase medicines should also be aware of, and ensure they are compliant with, the relevant regulations. For more information, please see the Medicines and Healthcare products Regulatory Agency.
Complying with financial sanctions
All UK nationals and legal entities established under UK law, including charities, must comply with UK financial sanctions, wherever in the world their activities take place.
The Office of Financial Sanctions Implementation (OFSI) publishes a list of all those subject to financial sanctions in the UK and has produced guidance for charities on how to ensure compliance with financial sanctions.
It is your responsibility to check whether individuals or organisations you are dealing with (for example donors, partners, contractors or beneficiaries) are subject to financial sanctions and take appropriate action to ensure you are not breaching the regulations. It is of the upmost importance that charities monitor developments particularly in light of the increased number of sanctions imposed on individuals and organisations in response to the war in Ukraine.
Know your donor – key questions for trustees
Know your donors, and partners
All charities should know their donors and think carefully about whether or not to accept donations. Good due diligence will help you assess the risks to the charity of accepting a donation, including reputational risks.
There will be similar considerations for working with partners or contractors. You should ensure that the individuals or organisations that the charity funds, or uses to help deliver its work, are suitable and appropriate for the charity to associate with.
Whether you are considering new partners, or reviewing existing partnerships, ensure there is appropriate and proper due diligence to assess the risks. For more information on due diligence, please see the Commission’s Compliance Toolkit.
Updates to this page
Last updated 28 March 2022 + show all updates
-
New paragraph added on Dealing with a large increase in funding
-
First published.