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COMPLAINTS POLICY POLICY STATEMENT The Malthus Trust Committee (TMT) aims to carry out all of its activities in a professional and open way, which will minimise complaints from those with whom we come into contact. Where complaints are received, TMT Trustees will treat them with respect, endeavour to resolve them to the satisfaction of all parties and instigate any actions necessary to prevent the recurrence of the issue causing complaint. AIMS In all its activities TMT will aim to: • Operate in a professional and efficient manner, which will please all users and minimise cause for complaint. • Handle any complaints promptly and efficiently in an approved manner. • Seek resolutions that are acceptable to all parties. • Learn from complaints and their resolution to improve TMT’s operating procedures. • Encourage feedback from those we deal with on how TMT meets the requirements of the community. • Achieve constant improvement in operating processes and procedures to ensure that TMT is a pleasure to deal with. PRINCIPLES TMT will strive to: •Encourage its trustees to take responsibility for resolving complaints promptly in accordance with the published complaints procedure. •Treat all applicants and others who contact the Trust in a fair and equitable manner and in accordance with the Trust’s equal opportunities policy. •Maintain suitable operating procedures, so that applicants know what is expected of them. •Ensure that all applicants are made aware of these procedures and adhere to their requirements. •Avoid cause for complaint of non-compliance by meeting all relevant legislation and regulations. •Undertake a process of constant improvement in operating procedures and standard of facilities available. •Occasionally seek user opinion on the standard of service offered by TMT and use this information in the improvement process. •Learn from any complaints that arise and the actions necessary to resolve them. COMPLAINTS PROCEDURE Stage One: Informal Complaints •Informal complaints should be raised with or directed to the Chairperson. •Complainants who remain dissatisfied at this stage will be informed that they have the opportunity to make a formal complaint. Stage Two: Formal Complaints •Formal complaints should be made in writing and will normally be investigated by the Chairperson in the first instance. •If the complaint directly concerns the Chairperson, complainants should be advised to contact any other Trustee who will then consult with the rest of the Trustees. •A written response will be given by the Chairperson, or suitable alternative, to all formal complaints. Response •TMT will take every complaint seriously and will treat everyone who complains with respect and courtesy. •TMT believes that most complaints can be resolved satisfactorily by informal discussion either over the telephone or through a meeting of the key people involved. •TMT aims to acknowledge complaints within five working days and give a full response to complainants within two weeks. If the complaint is judged to involve complex issues, complainants will be informed within two weeks when they can expect a full response. The main aim throughout the process is to resolve the matter as quickly and effectively as possible, to everybody’s satisfaction. Monitoring, Evaluation and Review •Where a complaint has specific implications for TMT operating procedures, these will be reviewed at the earliest opportunity and any changes that are deemed necessary approved at the next Trustees meeting. •All complaints received will be logged by the Chairperson and “complaints” will be a regular agenda item at Trustee meetings. •TMT will conduct an annual review of the outcome of all complaints prior to the annual general meeting as part of its policy of continued process improvement.

PRIVACY & DATA PROTECTION POLICY POLICY STATEMENT The Malthus Trust (TMT) is committed to a policy of protecting the rights and privacy of individuals. TMT needs to collect and use certain types of data in order to carry out its objectives of financially assisting those individuals who are covered by the Trust Deed The Data Protection Act 1998 (DPA) and General Data Protection Regulations (GDPR) govern the use of information about people (personal data). Personal data can be held on computers, laptops and mobile devices, or in a manual file, and includes email and minutes of meetings. This personal information must be collected and handled securely. TMT will remain the data controller for the information held. The trustees of TMT are personally responsible for processing and using personal information in accordance with the Data Protection Act and GDPR. If you would like to find out more about how we use your personal data or want to see a copy of information about you that we hold, please contact the Chairman of TMT by emailing Malthustrustchair1@gmail.com. AIMS The purpose of this policy is to set out TMT’s commitment to and procedures for protecting personal data. TMT regards the lawful and correct treatment of personal information as very important to successful working, and to maintaining the confidence of those who apply to the Trusts for financial assistance. OPERATION The Data Protection Act contains 8 principles for processing personal data with which we will comply. Personal data: 1.Shall be processed fairly and lawfully and, in particular, shall not be processed unless specific conditions are met, 2.Shall be obtained only for one or more of the purposes specified in the Act, and shall not be processed in any manner incompatible with that purpose or those purposes, 3.Shall be adequate, relevant and not excessive in relation to those purpose(s), 4.Shall be accurate and, where necessary, kept up to date, 5.Shall not be kept for longer than is necessary, 6.Shall be processed in accordance with the rights of data subjects under the Act, 7.Shall be kept secure by the Data Controller who takes appropriate technical and other measures to prevent unauthorised or unlawful processing or accidental loss or destruction of, or damage to, personal information, 8.Shall not be used by or transferred to anyone other than the trustees for the time being of TMT. The TMT will let people know why we are collecting their data, which is purely for the purpose of agreeing financial assistance. It is our responsibility to ensure the data is only used for this purpose. Consent to use personal data will be included with all Grant Application forms handed out. Access to personal information will be limited to trustees of TMT. Data may be retained for up to 7 years for accounts purposes and for longer where required by TMT insurers. Information regarding any future employees will be kept indefinitely. If something occurs years later it might be necessary to refer back to a job application or other document to check what was disclosed earlier, in order that trustees comply with their obligations e.g. regarding (should it ever apply) employment law or insurance. Individuals have a right to make a Subject Access Request (SAR) to find out whether the charity holds their personal data, where, what it is used for and to have data corrected if it is wrong. Any SAR will be dealt with within 30 days, as is required, and steps will be taken to confirm the identity of the individual making the request. We may occasionally need to share data with other agencies such as the local authority, funding bodies and other voluntary agencies in circumstances which are not in furtherance of the management of the charity. The circumstances where the law allows the charity to disclose data (including sensitive data) without the data subject’s consent are: •Carrying out a legal duty or as authorised by the Secretary of State protecting vital interests of a Data Subject or other person e.g. child protection. •The Data Subject has already made the information public. •Conducting any legal proceedings, obtaining legal advice or defending any legal rights. •Monitoring for equal opportunities purposes – i.e. race, disability or religion. •We regard the lawful and correct treatment of personal information as very important to successful working, and to maintaining the confidence of those with whom we deal. We intend to ensure that personal information is treated lawfully and correctly. SPECIFIC ACTIONS The TMT has a duty to ensure that appropriate technical and procedural measures are taken to prevent breaches of data security. These measures will include: •Physical files containing personal data will be kept in a locked cabinet, or secure area. •Personal data stored electronically will be password protected, with a strong password. •Computers and devices used to access and process the data will have up to date internet security software installed and operational. •Only the trustees of TMT will have access to personal information held by the charity and then only on a need-to-know basis and having given written assurance that appropriate data security measures are in place and procedures observed. •No personal data will be given over the phone unless there is no doubt as to the caller’s identity and right to access the information. •Information to meet a SAR request will only be released if evidence of identity is provided. •Consent to retain personal information will be recorded and updated as necessary. •Email correspondence on behalf of TMT will use a dedicated email account, not personal emails. Emails containing personal information will be saved into appropriate secure folders and deleted from email in-boxes and deleted files folders. •Personal data will be stored for only as long as it is needed, or required by statute and will be disposed of appropriately. •Data security will be included as a regular Agenda item at TMT meetings.

FINANCE POLICY POLICY STATEMENT The Trustees of The Malthus Trust, which comprises the above two registered charities, will ensure that the finances of both Trusts are managed in a prudent manner, on sound financial principles, which will comply with Charity Commission and HMRC requirements and which will enable The Malthus Trust to continue to provide funding to those individuals and organisations approved by the Trust Deed. AIMS The aim is to operate The Malthus Trust on a sustainable revenue basis and, where possible, to maintain and grow the Trusts’ capital assets. At no time shall annual expenditure exceed annual Income. The policy document lays down the principles of financial management that are employed. PRINCIPLES 1. The Trustees will manage the assets of the charity in accordance with the prevailing governing document and will appoint a Finance Officer responsible for the day-to-day management of the charity’s finances. 2. Suitable Insurance will be maintained to protect the Charity’s finances against all risks. 3. Financial records will be kept to ensure that The Malthus Trust meets its legal and other obligations under Charity Law, Revenue and Customs and common law. 4. The financial year will end on the last day of December and accounts for each financial year will be drawn up and approved by the Trustees at their March meeting 5. All funds will be held in accounts in the names of each Trust at such banks and on such terms as the Trustees shall decide. 6. All cheques shall require the signatures of two of the designated signatories. Where electronic payment methods are used, the payment will be set up by the Finance Officer and approved by at least one other Trustee 7. The Finance Officer will present a financial report to every Trustees’ meeting the format and content of the report to be decided by the Trustees. 8. All expenditure shall be properly authorised and documented; all income shall be paid into the bank without delay. 9. No committee member shall have a personal financial interest in the management of either charity. 10. Only in exceptional circumstances should payments exceeding £100 be made directly by a Trustee and then reclaimed from the Trust. Online banking should eventually ensure that such payments are never required. 10. No payments shall be made other than those specifically allowed for in the Trust Document. SPECIFIC FINANCIAL PROCEDURES A.Financial Records The following records shall be kept up to date by the Financial Officer: A computer-based Excel record analysing all the transactions in all of the Trusts’ bank accounts. This record will be compared to and reconciled to the various bank statements. A file containing all supporting documentation, maintained in the order that payments are made. B.Payment Procedures • All payments will be fully itemised in the accounts. • Payments will be made only by the Finance Officer following approval by a majority of Trustees. • The Finance Officer will be responsible for holding the various cheque books (unused and partly used cheque books) which should be kept under lock and key. • Blank cheques will never be signed. The relevant payee’s name will always be inserted on the cheque before signature and the cheque stub will always be properly completed. No cheques will be signed without original documentation (see below). It is hoped that Online banking will substantially reduce the number of cheques required. C.Income Procedures • All income not received electronically must be paid into the relevant bank account immediately and without deduction. • Any cash received for any reason is to be counted by the person collecting it and placed in a bag with a paying-in slip showing source, date, amount and signature of collector; the cash to be handed to the Finance Officer who will confirm the amount. D.Payment Documentation • Every payment made will be evidenced by an original invoice/pro-forma invoice, or expense receipt. • The cheque signatory should ensure that it is referenced with payment amount; cheque number; date drawn; signatory(s). • The only exceptions to cheques not being supported by an original independently produced invoice would be Grant Payments, where a fully completed Application Form, letter or email will be taken as adequate supporting documentation. . • Any Petty Cash will be held by the Finance Officer. Petty cash will be reconciled with receipts on a monthly basis by the Finance Officer. • The charities will pay reimbursement of expenditure paid for personally by committee members on behalf of the charity, providing that expenditure is evidenced by original receipts; car mileage is based on local authority scales; no cheque signatory signs for the payment of expenses to themselves. All reimbursements must be authorised by a majority of Trustees. E.Grant Award Methodolgy • The scope for awarding Grants is set out in the Trust Deed. • Grants will only be made to individuals or organisations that meet the criteria of the Trust deed. • Grants will only be paid after discussion at a Trustees Meeting where a majority of the Trustees vote in favour of the proposed Grant. • No Grant will be paid without either a completed Application form or a letter/email from an Organisation outlining the purpose to which the Grant will be put. • All Grant recipients must be asked to acknowledge receipt of Grants. Except in extenuating circumstances, the Trustees will reserve a minimum of 25% of annual Net Income (after deducting all Expenses) towards funding major repair work to the Trust’s main asset (the PreSchool Building). The remaining annual Net Income may be divisible amongst applicants at the discretion of the Trustees. The Trustees are not under any obligation to distribute all of the available funds. F.Reserves •Minimum Reserves held in cash should not be less than £25,000 •This sum shall be reviewed annually at the September meeting, taking into account the expected expenditure in following year. •Transfers to and from Reserves may be requested by any Trustee but will always need the approval of a majority of the Trustees. •Reserves may be either “Designated” (available only for a specific purpose) or “Undesignated” (available for any reason approved by the Trustees).

EQUALITY, DIVERSITY AND INCLUSION POLICY POLICY STATEMENT The Malthus Trust (TMT) acknowledges that the United Kingdom is diverse in culture, race beliefs and religion and believes that no individual or group of people should receive less favourable treatment on the grounds of gender, age, colour, race, nationality, racial or national origins, cultural heritage, disability, marital status, social background, sexual orientation or geographical location. The Trustees acknowledge that members of these groups are often under represented, exposed to prejudice and stereotyping, and suffer various disadvantages within our society. TMT is committed to providing equality of opportunity in all areas of its work. It aims to overcome discrimination on the grounds mentioned above within the provisions of the Trust Deed. The trustees recognise that positive steps need to be taken to ensure equality of provision in areas of representation, service provision, and access and will take action to make this policy effective. TMT is committed to the equal opportunities policy set out in this document and will work to develop, improve and monitor it. AIMS The purpose of this policy is to set out clearly and fully the positive action that TMT intends to take to combat direct and indirect discrimination in employment policy, executive management of the organisation, relationships with other bodies, and the services it provides to the community, community organisations and individuals. PRINCIPLES TMT acknowledges the definitions of various groups of people who are vulnerable to discrimination as set out in the relevant legislation. The Committee will support and implement the legislation and will work to ensure that no person protected by the legislation is discriminated against unlawfully, and that any positive obligations and duties are performed. Protected characteristics •age •disability •gender reassignment •marriage and civil partnership •pregnancy and maternity •race (including colour, nationality, and ethnic or national origin) •religion or belief •sex •sexual orientation TMT commits to: •Encouraging equality, diversity and inclusion as they are good practice and make business sense. •Creating an operating environment free of bullying, harassment, victimisation and unlawful discrimination, promoting dignity and respect for all, and where individual differences and the contributions of all staff are recognised and valued. This commitment includes training Trustees and all others associated with TMT about their rights and responsibilities under the equality, diversity and inclusion policy. Responsibilities include conducting themselves to help the organisation provide equal opportunities and prevent bullying, harassment, victimisation and unlawful discrimination. Everyone should understand that they can be held liable for acts of bullying, harassment, victimisation and unlawful discrimination, in the course of their tenure, against fellow Trustees, applicants and the public. •Take seriously any complaints of bullying, harassment, victimisation and unlawful discrimination by colleagues, customers, suppliers, visitors, the public and any others in the course of the organisation’s work activities. Such acts will be dealt with as misconduct under the organisation’s grievance or disciplinary procedures, and appropriate action will be taken. Particularly serious complaints could amount to gross misconduct and lead to termination of appointment. Further, sexual harassment may amount to a criminal matter, such as in sexual assault allegations. In addition, harassment under the Protection from Harassment Act 1997 – which is not limited to circumstances where harassment relates to a protected characteristic – is a criminal offence. •Make opportunities for training, development and progress available to all Trustees and TMT volunteers, who will be helped and encouraged to develop their full potential, so their talents and resources can be fully utilised to maximise the efficiency of the organisation. •.Review practices and procedures when necessary to ensure fairness, and also update them and the policy to take account of changes in the law.

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