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1.1 SMEEF will seek philanthropic support in the form of one-off or, multiyear contributions, from anyone with an interest in the health of the Scottish marine and coastal environment, including from individuals, trusts, foundations, and corporate bodies in the UK and abroad.

1.2 We have a clear and rigorous contributions acceptance process which requires assessment by the SMEEF Ethical Contributions Board and agreement by the SMEEF Steering Group. We report to contributors regularly including via the Contributors’ Forum and through the annual Impact Report.

1.3 It is vital that contributions to SMEEF do not create influence (real or perceived) upon SMEEF Steering Group members and their organisations (NatureScot, Scottish Government and Crown Estate Scotland), their processes or standards, including upon the outcomes and advice given relating to licences/marine applications etc.

1.4 In order to limit the risk associated with accepting contributions from third parties, SMEEF will take all reasonable measures to:

• Ensure it is aware of the source of funding for proposed contributions;
• Undertake due diligence to ensure that contributions are for purposes consistent with SMEEF’s mission and that no legal or reputational issues are raised by their acceptance;
• Be cognisant of SMEEF’s and NatureScot’s responsibilities under anti-money laundering, anti-terrorist financing legislation and international sanctions legislation; such as the Criminal Finances Act 2017; the Proceeds of Crime Act 2002; the Terrorism Act 2000; the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017; and the Bribery Act 2010;
• Ensure the timing of a contribution could not be construed as influencing or having influenced (for example) a licencing or application outcome, or a procurement process.

1.5 SMEEF will maintain an appropriate and auditable record of all contributions and contributors.

1.6 Contributors can expect to receive appropriate acknowledgement, including being listed on the SMEEF website.

1.7 Funds will not be transferred out of SMEEF and will only be used for the purposes agreed. An agreed percentage of contributions will be used to cover overheads and any dedicated resources needed for delivery. 

2.1 The SMEEF Contributions Acceptance Policy requires us to undertake suitable levels of due diligence on proposed contributors to the fund. Our tests, summarised below, align to Scottish Government’s policies and standards regarding responsible investment and route to net zero/just transition, and also include consideration of reputational risk. The tests fall into three categories, Standard, Enhanced and Extended Due Diligence.

• Standard Due Diligence (SDD) – all prospective contributors are subject to standard due diligence. SDD will generally examine only the previous 5 years of publicly available information relating to the prospective contributor.
• Enhanced Due Diligence – applies to prospective contributors from industries regarded as ‘medium risk’, or where the Ethical Contributions Board has requested further information. This will mean that checks will extend beyond the standard 5 years.
• Extended Due Diligence – applies to all potential contributors from organisations in a high-risk category, and includes any parties with a controlling interest in, or beneficial ownership of, the potential contributor.

2.2 Examples of higher risk industry sectors:

• Fossil fuel extraction
• Energy generation from fossil fuel
• Energy generation from nuclear power
• Animal testing for cosmetic or other non-medical products

2.3 All due diligence assessments are undertaken by SMEEF staff using publicly available information, including use of the Dow Jones Risk and Compliance tool, before submission of a report to the SMEEF Ethical Contributions Board and ultimately, the SMEEF Steering Group.

3.1 Contributions will be used by SMEEF to fund grants in the following topic areas:

Targeted funding – A dynamic funding pot which reacts strategically to issues.

Seabed enhancement – encompassing seagrass, native oysters and other seabed species and habitats,

Coastal enhancement – to encompass saltmarsh, sand dunes and other coastal species and habitats,

Wider Seas – to encompass all mobile species and deeper seas work,

Seabirds – all work aiming to benefit seabirds.

The SMEEF Ethical Contributions Board retains the right to recommend restrictions to the SMEEF Steering Group on how contributions may be used and/or recognised. Our independently chaired SMEEF Grants Panel makes recommendations on which projects are awarded grant funds. Final decisions are taken by the SMEEF Steering Group.

4.1 Contributions may be returned in line with the Return of Contributions Policy. This includes situations where SMEEF can no longer deliver the agreed activities; where there is a change in circumstances which could lead to reputational damage; or where the contribution was paid by a banking error, in which case notification must be received in writing within 30 days.

5.1 In addition to undergoing assessment by the Ethical Contributions Board, businesses contributing to SMEEF will sign an agreement, which includes a declaration that they agree and undertake to SMEEF and NatureScot that they:

• Have never denied that climate change is caused by anthropogenic forcing, or if they have they have issued a correction or apology.
• Have taken measurable steps in reducing their carbon emissions and are actively seeking a net zero future for their business.
• Have only used carbon offsetting as a last resort to reducing emissions.
• Have taken measurable steps to reduce their impact on the marine environment.
• Have made public their environment policy and their progress against its objectives.
• Follow a evidence-based approach to managing their environmental impact/are compliant with an appropriate action framework such as the Science Based Targets Initiative or similar.
• Have an appropriate Fair Work and Anti-Modern Slavery policy and have policies or mechanisms in place that address human rights obligations. Have taken steps to improve its record and/or provide redress for any prior human rights issues.
• Are aligned with/actively support appropriate campaigns and frameworks such as Drink Aware and Gamble Aware.
• Has not provided SMEEF with any information that is inaccurate, misleading, incorrect or fraudulent.
• Has not committed a Prohibited Act, including:

1. 1.  offering, giving or agreeing to give to any employee or officer of SMEEF or NatureScot any gift or consideration of any kind as an inducement or reward for: (i) doing or not doing (or for having done or not having done) any act in relation to the obtaining or performance of this Agreement or any other contract with SMEEF of NatureScot; or (ii) showing or not showing favour or disfavour to any person in relation to this Agreement or any other contract with SMEEF of NatureScot;
   2. entering into this Agreement or any other contract with SMEEF or NatureScot where a commission has been paid or has been agreed to be paid by the Contributor or on its behalf, or to its knowledge, unless before the relevant contract is entered into particulars of any such commission and of the terms and conditions of any such contract for the payment thereof have been disclosed in writing to SMEEF;
   3. committing any offence: under the Bribery Act 2010; under legislation creating offences in respect of fraudulent acts; or at common law in respect of fraudulent acts in relation to this Agreement or any other contract with SMEEF or NatureScot; or
   4. defrauding or attempting to defraud or conspiring to defraud SMEEF or NatureScot.