Group Charitable Donations policy

Last updated 02/12/2024.

1. Purpose - why it matters 

Charitable donations – whether in the form of money or donations in-kind such as time, products or services – are an important part of our commitment to social responsibility. However, donations may cause reputational harm to Tesco if they are made to inappropriate causes. In extreme cases, a charitable donation that is made in order to obtain a benefit for Tesco may be considered a bribe.

2. Scope 

This policy applies to:

• all business units that are either majority-owned by Tesco or operated by Tesco management. For the purposes of this policy, business units includes all retail businesses, along with Booker, Tesco Insurance, Tesco International Sourcing Limited, Tesco Business Solutions and dunnhumby.
• charitable foundations or trusts that are run by, or on behalf of, Tesco.
• Third parties, including contractors and suppliers, who make charitable donations on behalf of Tesco.

Any joint ventures where Tesco owns 50% or more of the shares in the company are expected to put in place policies consistent with this policy.

3. Policy  

Each business unit is responsible for determining the charities that it supports, including the level of donations made. However, in addition to respecting local laws, the following guidance must be followed by all business units:

• Only make charitable donations with the appropriate authority: Section 6 of this policy sets out the delegation of authority (DOA) schedule for making charitable donations[1], which must be followed at all times.
• National Charity Partners: The policy supports the identification and selection by business units of a small number of strategic national charity partners, selected in accordance with Section 6 of this policy. The policy intention is to direct more of Tesco’s charitable giving to these partners. The Group Communications Director will maintain a log of all business units’ national charity partners.
• No bribery: Charitable donations must never be made with the expectation of receiving any improper benefit for Tesco. Donations to charities that are associated with specific public officials and their families represent a significant risk for bribery. Appropriate reputational due diligence (e.g. using existing anti- bribery due diligence tools) must be conducted before such donations are made.
• Tax status of charitable donations: Business units must maintain an understanding of the tax implications of donating money to charity. These rules differ by jurisdiction. In the UK, charitable donations should not include VAT. So-called "cause-related marketing” (CRM) agreements (where Tesco or the supplier donates to charity a percentage of a product’s retail price or profit) may give rise to certain tax implications. A written contract must therefore always be in place to support any CRM activity before the product is sold in stores.
• No use of expenses to process charitable donations: Cash donations to charity may not be made by a colleague on behalf of Tesco and reclaimed as personal expenses. Donations may only be processed through a business unit’s finance systems, using an appropriate account code.
• Declaration of donations: if you are making a donation of over £500 then please ensure it is logged via the Donations Portal here. For any corporate charity donation requests under £500, colleagues will need to follow the usual procedure of raising a payment request with their budget owner’s approval. 

4. Involving suppliers in charitable donations

It is a normal part of business life to ask suppliers and other partners to support our charitable initiatives. However, supplier participation is subject to compliance with the following principles:

• You must never put suppliers or other parties under pressure to donate money to charity, buy tickets for Tesco charity events or provide sponsorship for Tesco events.
• Where you are organising charity fundraising events, such as sporting events or charity dinners, the general rule is that the cost of running the event must be borne by Tesco. Where suppliers are invited to buy tickets for such events, the price of tickets must not be used to subsidise the cost of running the event, including the cost for Tesco colleagues to attend.
• Where suppliers co-sponsor a charitable initiative, their role as sponsor must be clearly and appropriately acknowledged by Tesco.
• Where Tesco is making a donation to charity, you may not take credit for contributions made by suppliers or other parties.
• Tesco colleagues should not ask suppliers to donate valuable products to charity, for example to raffles or as competition prizes.

If you are based in the UK and raising funds for GroceryAid, you must ensure your event or activity additionally follows GroceryAid’s Principles of Good Practice, Charitable Support in the Retail Sector, issued in November 2017.

5. Commercial sponsorship agreements

Commercial sponsorship agreements, for example of a sporting team or cultural event, which are negotiated on commercial terms and which are principally intended to promote the Tesco brand via association with that team or event, are not deemed to be charitable donations by Tesco for the purposes of this policy. However, the DOA for sponsorship agreements, which is set out at Section 6 below, must be followed at all times.

6. Delegation of Authority (DOA) 

The DOA for charitable donations and commercial sponsorship agreements is as set out in the table below. For the purposes of calculating the value of a donation, gifts in kind (such as colleague time or goods or services provided by Tesco) shall be included.

It should be noted 1) splitting a donation into two or more payments in order to avoid the appropriate DOA approval will be deemed a breach of the policy and 2) the DOA also applies where a business unit tops up or matches the amount raised by colleagues’ fundraising.

7. Reporting charitable donations to the Risk & Compliance Committee 

The Group Communications Director (or equivalent business unit role) will review both the donations submitted via the portal and the relevant donations cost centre, with the exception of donations by Tesco of less than £500.

The business unit Risk & Compliance Committee will review the log of charitable donations twice each year. Business units are required to provide colleague training and awareness about this policy as appropriate.

8. Reporting breaches

You have a duty to speak up if you believe the policy has been breached. Speak to your line manager in the first instance. If this is not possible, speak to your local Security or Legal contact, a member of your business unit leadership team or email business.conduct@tesco.com to report your concerns. If you wish to raise a concern on an anonymous basis, you may also contact Protector Line, a third-party service run on behalf of Tesco. You can find out how to contact Protector Line here.

We are committed to ensuring that colleagues who raise concerns are not victimised and do not tolerate retaliation in any form against individuals who raise concerns. If you raise a genuine concern in good faith, you will not face any adverse consequences for speaking up, even if you were mistaken about your concern. If you believe that you are being retaliated against, you should report it immediately.

Failure to comply with this policy may result in disciplinary action being taken against any colleagues concerned or the termination of contracts with third parties working for Tesco.

 

[1] At Tesco UK, a Community Interest Company (CIC) can also receive donations, but the CIC must have been established for at least two years.