Wiltshire Community Foundation will monitor the effectiveness of this policy regularly to ensure its suitability, adequacy, and effectiveness. Any improvements identified will be made as soon as possible.

1. Introduction

1.1 Wiltshire Community Foundation is a registered charity and limited company with broad charitable purposes to benefit communities in Wiltshire and Swindon. Our vision is to see more people thriving across Wiltshire. Our mission is to maximise the impact of charitable activity in our local communities by connecting people, information, and resources.

1.2 Wiltshire Community Foundation recognises that everyone has a unique contribution to make to the life of our communities. We welcome the involvement of all people and commit to treat everyone with equal respect. Among the principles underpinning our work are advocating for disadvantaged people and less well supported causes and reflecting and involving our area’s diverse communities. We are committed to a working environment in which all individuals can make best use of their skills, free from discrimination or harassment, and in which all decisions are based on merit.

2. Purpose and Scope

2.1 The purpose of this policy is to show how Wiltshire Community Foundation complies with relevant laws and guidance on discrimination and equality, and how we work towards best practice in celebrating diversity and promoting equal opportunities. In adopting the policy, the Board has taken legal advice and account of the Charity Commission guidance on the Equality Act 2010, in particular that grant-making is service provision within the meaning of the Act.

2.2 The policy covers our five workstreams and the overarching area of governance. It applies to all employees and Board members of Wiltshire Community Foundation and to volunteers. 

3. Meaning of Terms

3.1 Protected characteristics: as defined in the Equality Act 2010 they are age, disability, gender reassignment, marital or civil partner status, pregnancy or maternity, race, colour, nationality, ethnic or national origin, religion or belief, sex, or sexual orientation.

3.2 Positive Action: proportionate measures to help people who share a protected characteristic to have the same chances as everyone else. This may include providing additional or bespoke services or targeted support to help them address their specific needs, to overcome disadvantage linked to their protected characteristic or to increase their participation where there is disproportionate underrepresentation.

3.3 Charitable instrument: a formal document setting out the purposes for which funds have to be applied. For Wiltshire Community Foundation, this is normally the fund/philanthropy agreement, a will or a trust deed or other governing document.

3.4 Legitimate aim is one which can be objectively justified as effective on social policy grounds or is consistent with Wiltshire Community Foundation’s operational purpose for the public benefit. 

4. Philanthropy and Giving

4.1 Donors may wish to establish funds at Wiltshire Community Foundation with benefits restricted to people with a particular protected characteristic. Such restrictions may be accepted where the donor’s intention is to tackle greater needs or disadvantages linked to that protected characteristic. In such cases, the donor’s wishes will be clearly set out in the relevant charitable instrument.

4.2 Donors may also seek restrictions on who may benefit from a fund that do not relate to a protected characteristic. For example, a fund may legitimately be restricted to a particular locality or type of activity without excluding people with any protected characteristics.

4.3 Wiltshire Community Foundation staff will advise potential donors on how this policy may apply to named funds they establish. However, the Board reserves the right not to accept a gift if restrictions regarding any protected characteristic cannot be justified on the grounds of need or disadvantage or would otherwise be unlawful. 

5. Funding and Support

5.1 It is Wiltshire Community Foundation’s aim to make grants to a wide range of organisations supporting diverse communities and, in certain circumstances, to individuals. We consider all requests for grants and other support fairly on their merits.

5.2 If a fund has been established with restricted purposes as described above, Wiltshire Community Foundation may make grants or offer other forms of support restricted to people with the protected characteristic(s) in question when doing so is a fair, balanced and reasonable way of meeting a legitimate aim.

5.3 Alternatively, Wiltshire Community Foundation may make grants or offer other forms of support restricted to people with a particular protected characteristic(s) where doing so is an objectively justifiable means of achieving positive action.

5.4 We will take particular needs into account when dealing with requests for grants or other support. In particular, Wiltshire Community Foundation will take reasonable steps to make information available in a variety of accessible formats. Wiltshire Community Foundation may also take positive action to encourage and enable applications from groups representing or helping people with other protected characteristics where they are disproportionately underrepresented across our grant-making and other support.

5.5 Wiltshire Community Foundation welcomes applications from faith groups but we will not normally support religious activity which is not for wider public benefit.

5.6 The Board reserves the right not to approve any application for funding if the resulting grant-making would conflict with our policies or damage our reputation  

6. Knowledge and Leadership

6.1 As well as providing funding, advice and support, where appropriate Wiltshire Community Foundation also carries out advocacy, research and development which is linked to the needs analysis conducted with support from OCSI. This can mean investing in policy work, initiatives and collaborations or making targeted grants to address gaps and leverage funding. It can also involve providing thinking, convening and brokerage around our areas of expertise. In carrying out such activities, we may take positive action where it is justified to address particular needs, disadvantages, or lower levels of participation for groups sharing one or more protected characteristics.

7. Governance and Operations

7.1 Wiltshire Community Foundation seeks the involvement of a wide range of people and organisations and will treat everyone with equal respect. Our Board is continuously striving for representation which reflects the diversity of our county and the communities we serve. We will take positive action where justifiable to encourage and enable the participation of under-represented groups in our governance.

7.2 Wiltshire Community Foundation’s staff handbook includes our policy on equality and diversity in employment which applies to all aspects of our relationship with staff and relations between staff members. The handbook also covers harassment and bullying.

7.3 The principles of non-discrimination and equality of opportunity apply to the way in which Wiltshire Community Foundation staff will treat visitors, patrons, trustees, volunteers, grantees, donors, potential donors, suppliers. and former staff members. 

8 Responsibilities and Review

8.1 Ultimate responsibility for this policy rests with the Board of Trustees and the Operational Effectiveness Committee. The Board delegates responsibility for implementation to the Joint Chief Executives. However, everyone who works for the organisation, whether paid or unpaid, has an individual responsibility to comply with the policy and contribute to its application.

8.2 Where it appears that there may be a breach of the policy, the Joint Chief Executives will investigate and take appropriate action. Complaints may be made externally through Wiltshire Community Foundation’s complaints procedure, or internally through the procedures set out in the staff handbook.

8.3 The Board will receive a report on Diversity, Equity and Inclusion annually, including appropriate statistics on application of the policy in relation to services, governance, and operations. The Board will review the policy itself every three years.

Date Last reviewed and approved:	05.07.2024
Date for next review:	July 2025