Donations Policy

Application of this policy

It applies to one-off and recurring donations of money and, where SBSI has agreed to accept them, donations of property or other assets. It does not apply to:

• membership fees;
• event tickets or registrations;
• purchases of goods or services;
• sponsorship, advertising or naming arrangements;
• commissioned research;
• grants involving contractual deliverables;
• loans, investments or deposits; or
• payments made under another written agreement with SBSI.

Those payments are governed by their applicable terms.

A person who makes a donation through a form, payment facility or appeal that refers to this policy acknowledges that the donation will be accepted and administered on the basis set out here. A separate written gift agreement signed by an authorised representative of SBSI prevails to the extent of any inconsistency with this policy.

Donations are gifts

A donation is a voluntary transfer of money or property to SBSI for which the donor does not receive a material benefit, consideration or compensation.

A genuine gift ordinarily involves a voluntary transfer of money or property, an intention to benefit the recipient and no material benefit being received by the donor in return.

Subject to this policy, once a donation has been:

• received and cleared;
• accepted by SBSI; and
• not refunded, reversed or dishonoured,

the money or property becomes the property of SBSI. The donor gives up any legal or beneficial ownership of, or control over, the donation.

A donation does not create a trust, agency, fiduciary relationship, partnership, joint venture or other special legal relationship between SBSI and the donor unless SBSI expressly agrees otherwise in a written instrument signed by an authorised representative.

A receipt, acknowledgement, thank-you letter, public acknowledgement or other expression of appreciation does not constitute consideration for the donation and does not create an obligation to provide anything in return.

No entitlement to influence, access or benefit

Acceptance of a donation does not oblige SBSI to take any action for the donor or any other person.

A donation does not give the donor any right to:

• direct or control SBSI’s research, publications, advocacy, public statements, events, expenditure or operations;
• require SBSI to adopt, change, withdraw or refrain from adopting a policy position;
• approve, veto, edit, delay or suppress any publication or communication;
• choose or remove directors, officers, staff, contractors, researchers, authors, speakers or event participants;
• obtain employment, a contract, a procurement opportunity, a grant, an appointment or any other commercial advantage;
• receive private access to directors, staff, speakers, public officials or other persons associated with SBSI;
• attend an event, meeting, briefing or function;
• obtain confidential, privileged, commercially sensitive or unpublished information;
• receive publicity, endorsement, naming rights, advertising or use of SBSI’s name, logo or intellectual property;
• receive donor-specific reports, accounts or audits beyond those expressly agreed in writing or required by law; or
• require SBSI to return the donation because the donor later disagrees with SBSI’s work, decisions, personnel or public positions.

Donors may express their views, but those views are not instructions to SBSI. The Board and its authorised delegates retain control over SBSI’s decisions and activities.

Any sponsorship, commissioned work, naming arrangement, commercial benefit or other reciprocal arrangement must be documented separately. A payment made under such an arrangement may not be a donation.

Unrestricted donations

Unless SBSI expressly agrees otherwise in writing before accepting a donation, every donation is an unrestricted donation.

SBSI may apply an unrestricted donation, at the discretion of the Board or an authorised delegate, to any lawful purpose within SBSI’s objects. This may include:

• research, publications and public-policy work;
• public education and issue-based advocacy;
• events, communications and community engagement;
• staff, contractors and professional advisers;
• technology, premises and administration;
• governance, accounting, legal and regulatory compliance;
• fundraising costs;
• the acquisition, maintenance or replacement of assets;
• reserves and provision for future expenditure; and
• any other cost reasonably connected with SBSI’s purposes or operations.

SBSI may pool an unrestricted donation with other money, hold it in a general account, invest it where lawful and use it when SBSI considers appropriate. SBSI is not required to maintain a separate account, trace the expenditure of an individual unrestricted donation or spend it within a particular period.

A donor is not entitled to an individual account of how an unrestricted donation was applied.

References to projects, programs and appeals

A reference in an appeal or communication to a project, program, event, publication, campaign or area of work ordinarily describes SBSI’s intended use of the funds at the time of the appeal. It does not create a binding restriction unless:

• the appeal expressly states that donations are restricted to that purpose; or
• SBSI enters into a written gift agreement accepting the restriction.

Unless an appeal expressly states otherwise, donations made in response to an appeal may be used for the direct and indirect costs of the relevant work. This includes administration, staffing, communications, fundraising, professional services and other reasonable operating costs.

If an appeal raises more money than is required, SBSI may use the surplus for related work or, where the appeal so provides, for SBSI’s general purposes.

Restricted donations

A donor may propose that a donation be used for a specified purpose. SBSI is not bound by the proposed restriction unless it is accepted in writing by the Board or an authorised delegate.

A restriction written in a bank reference, payment description, donation form, letter or email does not bind SBSI merely because SBSI received the payment. Acceptance of the money does not constitute acceptance of a condition unless SBSI confirms that acceptance in writing.

SBSI may refuse a proposed restriction where it considers that the restriction:

• is inconsistent with SBSI’s objects, independence or priorities;
• is unlawful or may create electoral, fundraising, taxation or other regulatory obligations that SBSI is unwilling or unable to assume;
• would give the donor an unacceptable degree of control or influence;
• would create disproportionate administrative, reporting or financial obligations;
• is impracticable, uncertain or incapable of being properly administered;
• would require SBSI to act contrary to its interests;
• may damage SBSI’s reputation or relationships; or
• may expose SBSI or its personnel to material risk.

A restricted donation may be used for the reasonable direct and indirect costs of carrying out the agreed purpose unless the written terms provide otherwise.

If an accepted purpose becomes unlawful, impossible, impracticable, obsolete or materially inconsistent with SBSI’s objects, SBSI may, subject to the written agreement and applicable law:

• consult the donor where reasonably practicable;
• apply the unspent balance to a substantially similar purpose;
• seek to vary the restriction; or
• return all or part of the unspent balance.

A donor cannot impose or alter a restriction after the donation has been made unless SBSI agrees in writing.

Acceptance, refusal and return of donations

SBSI may conduct any review it considers appropriate before or after receiving a proposed donation.

A payment confirmation generated by a bank or payment provider confirms that a transaction was submitted or processed. It does not prevent SBSI from declining or returning the donation and does not constitute acceptance of any donor condition.

Subject to law, SBSI may decline, suspend, return or refuse to process a donation where SBSI considers that:

• the donation or its source may be unlawful;
• the donor has not provided information reasonably requested by SBSI;
• the donor’s identity, authority, beneficial ownership or source of funds cannot be verified;
• the donation may involve fraud, theft, corruption, money laundering, sanctions evasion or other misconduct;
• the donor is acting for an undisclosed person;
• the donor does not have legal capacity or authority to make the donation;
• there is a reasonable concern that the donor is vulnerable, under pressure or unable to provide informed consent;
• the donor expects an improper advantage, influence or reciprocal benefit;
• a condition attached to the donation is unacceptable;
• the donation may compromise SBSI’s independence;
• the donation may create an actual, potential or perceived conflict of interest;
• accepting the donation may be inconsistent with SBSI’s objects or interests;
• the donation may expose SBSI to disproportionate cost, liability or regulatory work;
• the donation may be subject to electoral funding, foreign donation, fundraising, sanctions or other restrictions;
• the donation consists of property SBSI is unwilling or unable to hold or administer;
• the donor has previously engaged in fraud, abuse, harassment or dishonest dealings with SBSI; or
• acceptance would otherwise be inappropriate.

SBSI may decline a donation without providing detailed reasons, particularly where doing so may disclose confidential information, compromise an investigation or prejudice SBSI’s legal interests.

Where lawful and practicable, a donation declined or returned by SBSI will be returned to the person or account from which it was received. SBSI will not redirect returned funds to another person or an unrelated account merely at the donor’s request.

A returned donation does not carry interest. Unavoidable bank charges, payment-processing fees or foreign-exchange losses may be deducted from a discretionary return, except where SBSI is required by law to provide a full refund.

SBSI may refuse future donations from a person whose donations have previously been reversed, disputed or connected with misconduct.

Donor responsibilities and warranties

By making a donation, the donor represents and warrants that:

• the donor has legal capacity and authority to make the donation;
• where the donor acts for an organisation, trust or another person, the donor is properly authorised to do so;
• the donor is the beneficial owner of the funds or has disclosed the beneficial owner to SBSI;
• the donation is made from lawful funds;
• the money or property is not the proceeds of crime or unlawful conduct;
• the donation is not being made to obtain an improper personal, political, regulatory or commercial advantage;
• the donor has not relied on a representation that the donation is tax deductible;
• all information provided to SBSI is complete and accurate in all material respects;
• any payment card, account or payment method used by the donor is used with proper authority; and
• the donation is not subject to an undisclosed condition, trust, agency or obligation.

SBSI may require information about a donor’s identity, address, date of birth, organisation, beneficial ownership, citizenship or residency, source of funds, source of wealth, purpose of the donation or authority to act.

SBSI may hold a donation pending the completion of those checks. It may also disclose relevant information to banks, payment providers, insurers, auditors, professional advisers, regulators, law-enforcement bodies or other authorities where required or permitted by law.

To the extent permitted by law, a donor is responsible for reasonable loss or expense incurred by SBSI because the donor breached these warranties or made a donation without authority or good title.

Electoral and political purposes

SBSI’s general donation facilities are not intended to receive contributions earmarked for electoral expenditure or for the promotion or opposition of a political party or candidate.

A donor must not use a general donation to direct SBSI to:

• influence how electors vote;
• promote or oppose the election of a candidate;
• promote or oppose a political party;
• produce or distribute how-to-vote or other electoral material;
• reimburse electoral expenditure; or
• make a political donation to another person or organisation.

A donor proposing to fund activity that may be regulated by New South Wales or Commonwealth electoral law must contact SBSI before transferring funds.

SBSI may reject or return any donation that may constitute a political donation, foreign donation or contribution for regulated electoral expenditure. It may also require information needed to determine the donation’s legal character.

If SBSI undertakes regulated electoral activity, any appeal for that activity will be conducted through a separately identified and legally compliant arrangement. Separate eligibility, disclosure, accounting, payment and refund terms may apply.

Further information appears on SBSI’s About Donations page.

Tax treatment

SBSI is not endorsed as a deductible gift recipient. Its Australian Business Register entry states that it is not entitled to receive tax-deductible gifts.

A donation to SBSI is therefore not eligible for the ordinary income-tax deduction available for a gift to a deductible gift recipient. SBSI will not issue a deductible gift recipient receipt. The ATO states that a gift deduction is generally available only for eligible gifts made to an organisation with deductible gift recipient status.

Any receipt or acknowledgement issued by SBSI records that a payment was received. It must not be treated as a statement that the payment is tax deductible.

SBSI does not provide taxation, financial or legal advice and does not warrant that a donation will receive any particular taxation treatment. A donor should obtain advice about whether a payment may be deductible under another provision of taxation law.

Payments involving sponsorship, advertising, goods, services or other consideration may have different income-tax and GST consequences and must be dealt with separately.

Payment processing

A donation is not complete until the funds have cleared and are available to SBSI.

SBSI may use banks and third-party payment providers to process donations. Their terms, security procedures and processing times may also apply to a transaction.

Payment-processing, banking and foreign-exchange charges may reduce the amount ultimately available to SBSI. SBSI is not responsible for a bank’s or payment provider’s act, omission, delay, exchange rate or system failure to the extent permitted by law.

A dishonoured, reversed, cancelled or charged-back payment is not an effective donation. SBSI may cancel any acknowledgement or recognition associated with it.

SBSI may refuse cash, cryptocurrency, foreign currency or any payment made through an unapproved channel.

Recurring donations

A recurring donor authorises SBSI or its payment provider to process donations at the amount and frequency selected by the donor.

SBSI will not increase the amount or frequency of a recurring donation without the donor’s authority.

A donor may cancel future recurring donations by contacting SBSI at contact@sbsi.com.au. SBSI will action the request as soon as reasonably practicable. A debit already submitted to a bank or payment provider may still be processed.

Cancellation applies to future payments. It does not create an entitlement to a refund of donations processed before the cancellation took effect.

If SBSI processes a recurring payment after the cancellation has taken effect, SBSI will refund that payment unless another lawful basis for retaining it exists.

Fundraisers must make clear whether a donation is one-off or recurring and explain how a recurring donation can be ended.

Refunds

13.1 General rule

Except where this policy or the law provides otherwise, donations are final and non-refundable.

A pure donation does not ordinarily involve the supply of goods or services and does not carry a general change-of-mind cooling-off right. Consumer law protections may still apply where fundraising conduct was misleading, deceptive, unconscionable or otherwise unlawful.

A donor is not entitled to a refund merely because:

• the donor changes their mind;
• the donor’s financial circumstances change;
• the donor later disagrees with SBSI;
• SBSI does not undertake a particular project;
• work takes longer than the donor expected;
• the donor expected access, influence, recognition or another benefit;
• a public acknowledgement is altered or withdrawn;
• the donor does not obtain an expected tax deduction;
• the donor did not read this policy;
• the donor no longer supports SBSI’s leadership, work or public positions; or
• the donation has already been committed, allocated or spent.

13.2 Donations made in error

SBSI will approve a refund of a one-off donation made in genuine error where all of the following requirements are met:

A genuine error may include:

• a duplicate payment;
• entry of the wrong donation amount;
• selection of SBSI when payment was intended for another recipient;
• use of a payment method without the account holder’s authority; or
• an identifiable technical or processing error.

A change of mind is not, by itself, a payment error.

An approved refund under this section will ordinarily be for the full amount of the mistaken donation. SBSI will initiate the refund promptly after completing any necessary verification.

The 24-hour period applies to the time within which the request must reach SBSI. SBSI cannot guarantee when a bank or payment provider will credit the refunded amount to the donor’s account.

13.3 Requests made after 24 hours

A refund request received more than 24 hours after the transaction will be considered only:

• where a refund is required by law; or
• at SBSI’s discretion.

In deciding whether to approve a discretionary refund, SBSI may consider:

• the reason for the delay;
• the evidence of mistake or lack of authority;
• whether the donation has been spent, committed or allocated;
• payment-processing costs;
• whether the request raises concerns about fraud, vulnerability or informed consent;
• the conduct of SBSI or a person acting on its behalf;
• any restriction attached to the donation;
• the period that has passed; and
• SBSI’s legal and financial obligations.

SBSI is not obliged to provide a discretionary refund merely because another donor received one in different circumstances.

SBSI may approve a partial refund where it considers that appropriate.

13.4 Refunds required by law

Nothing in this policy limits any right that cannot lawfully be excluded.

SBSI will provide a refund where required by law, including where an unauthorised payment or unlawful fundraising conduct gives rise to a refund obligation.

The ACCC’s fundraising guidance states that refunds should be given where misleading or unconscionable conduct led to a periodic donation, even though a donation itself does not ordinarily attract the unsolicited consumer agreement cooling-off provisions.

13.5 Refund method and verification

A refund will ordinarily be made:

• to the original payment method;
• to the account from which the donation was received; and
• in the original transaction currency where reasonably practicable.

SBSI will not refund a donation to an unrelated person, account or payment method merely at the donor’s request.

SBSI may require proof of identity, account ownership or authority before issuing a refund. It may delay a refund where reasonably necessary to prevent fraud, investigate a disputed transaction or comply with law.

SBSI will not issue both a refund and a payment chargeback for the same transaction. If a chargeback has been initiated, SBSI may suspend its internal refund process pending the outcome.

No interest is payable on a refunded donation.

For a discretionary refund requested after the 24-hour period, SBSI may deduct payment-processing fees, bank charges and foreign-exchange losses that SBSI cannot recover.

Anonymous donations and donor recognition

A donor may ask not to be publicly identified. SBSI will take reasonable steps to respect that request, but public anonymity does not prevent SBSI from:

• recording the donor’s identity;
• conducting due diligence;
• disclosing information to professional advisers, banks, auditors or insurers;
• complying with electoral, fundraising, taxation, court or regulatory obligations; or
• providing information to a regulator or law-enforcement body where required or permitted by law.

SBSI may refuse a donation where the donor will not provide identity or other information reasonably required by SBSI.

A donation does not give the donor an automatic right to public recognition. Any acknowledgement, listing, description, title or other recognition is at SBSI’s discretion unless governed by a separate written agreement.

SBSI may alter or withdraw discretionary recognition where it considers this necessary, including because:

• information about the donor was inaccurate or incomplete;
• the donation was reversed or refunded;
• continued recognition may damage SBSI;
• the donor engaged in conduct inconsistent with SBSI’s interests;
• legal or regulatory concerns arise; or
• the relevant program, event, publication or asset changes or ceases.

No permanent naming right arises merely because SBSI acknowledged a donor.

A donor must not state or imply that SBSI endorses the donor, the donor’s organisation, products, services or views without SBSI’s prior written permission.

Privacy and records

SBSI collects and handles donor information in accordance with its Privacy Policy, including for payment processing, record keeping, communications, relationship management, fraud prevention, due diligence and legal compliance.

SBSI may retain donation and refund records for as long as reasonably required for accounting, taxation, audit, governance, insurance, electoral, fundraising, dispute-resolution and legal purposes.

A donor may opt out of fundraising and promotional communications. Transactional, administrative, legal and operational communications may still be sent where necessary.

SBSI does not store complete payment-card details where those details are handled directly by a payment provider.

Non-cash donations

A person must obtain SBSI’s written approval before transferring:

• real property;
• shares, securities or financial products;
• cryptocurrency or digital assets;
• valuable goods or collections;
• intellectual property;
• vehicles or equipment;
• interests in trusts, partnerships or companies;
• foreign assets;
• property subject to a mortgage, security interest or other encumbrance; or
• any other non-cash asset.

SBSI may require legal, taxation, valuation, environmental, title or other professional advice before accepting a non-cash donation. Unless SBSI agrees otherwise, the proposed donor is responsible for the cost of that advice and for all costs of transfer.

A donor of property warrants that the donor has good title to the property, has disclosed all encumbrances and liabilities, and has authority to transfer it.

Unless a written gift agreement provides otherwise, SBSI may retain, sell, realise, licence, invest, alter or dispose of donated property at any time and apply the proceeds as an unrestricted donation.

SBSI does not provide a valuation for the donor’s taxation or reporting purposes.

Complaints and enquiries

Donation, fundraising and refund enquiries may be sent to:

The contact details are those currently published by SBSI.

A complaint should include enough information for SBSI to identify the transaction, understand the concern and verify the complainant’s identity or authority.

SBSI will consider complaints within a reasonable period and may request further information. Making a complaint does not itself create a right to a refund or suspend SBSI’s use of an accepted donation.

Administration of this policy

The Board has ultimate responsibility for this policy. The Board may delegate the administration of donations, due diligence, acceptance decisions, refunds and donor communications.

Only a person acting within an SBSI delegation may:

• accept a restricted donation;
• enter into a gift agreement;
• promise naming or recognition rights;
• agree to donor reporting obligations;
• waive a requirement of this policy; or
• approve a discretionary refund.

A representation by a person without that authority does not bind SBSI.

Changes to this policy

SBSI may amend this policy by publishing an updated version on its website.

Unless the updated policy states otherwise:

• an amendment applies to donations made after publication;
• the version applying when a donation was made continues to govern that donation; and
• a written gift agreement remains governed by its own terms.

SBSI may apply an amendment to an existing donation where this is required by law or is necessary to address fraud, sanctions, electoral funding or another regulatory obligation.

Governing law

This policy is governed by the laws of New South Wales, Australia.

The courts of New South Wales and any courts competent to hear appeals from them have jurisdiction in relation to this policy and donations made to SBSI, subject to any applicable law that requires otherwise.

If any provision of this policy is invalid or unenforceable, it is to be read down to the extent necessary. If it cannot be read down, it is severed without affecting the remaining provisions.

Nothing in this policy excludes, restricts or modifies a right, guarantee, remedy or liability that cannot lawfully be excluded, restricted or modified.

Policy current as at 7 August 2026.

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