Internal Financial Control Policy and Procedures for the Bujagali Trust
Effective Date: 20th February 2026
Review Date: Every three years
Approved By: The trustees
1.0 Policy Statement & Purpose
This policy establishes a framework of internal controls and procedures to ensure that:
• All financial transactions are properly authorised, recorded, and reported.
• The charity’s assets (funds, data) are safeguarded against loss, fraud, or misuse.
• Financial management complies with all legal and regulatory requirements, including those set by the Charity Commission.
• Financial reporting is accurate, timely, and provides a true and fair view of the charity’s financial position.
• Resources are used efficiently and effectively to further the charity’s charitable objectives.
2.0 Roles & Responsibilities
• The Trustees: Have ultimate responsibility for the charity’s financial health, governance, and compliance. They must approve the annual budget, annual report, and accounts, and ensure robust financial controls are in place.
• Treasurer: Leads the trustees’ oversight of financial matters and responsible for maintaining accounting records, processing transactions, producing management reports, banking, and implementing procedures.
3.0 Core Financial Controls
3.1
Segregation of Duties
The Bujagali Trust is a small charity with no employees so segregation of duties is not practicable. However, the following procedures are in place to minimise error and fraud risk:
1. An annual budget for the forthcoming year (the financial year runs from 1st January to 31st December) is prepared by the treasurer and reviewed and agreed by the trustees
2. A financial report is reviewed by the trustees at each quarterly meeting. This financial report includes a comparison of actual receipts and payments compared to budget, and a detailed analysis of new donor income and project costs since the last meeting’s report
3. An annual independent review by a qualified accountant to check the validity of transactions and to ensure that the closing bank balance shown in the accounts submitted to the Charity Commission reconcile to the bank statement on 31st December
4. The accounts are prepared on a “cash basis” rather than an “accruals basis” makes a bank reconciliation simpler and more transparent
3.2 Authorisation Limits
The treasurer is authorised to make all expenditure transactions provided the expenditure has been approved in the budget. All expenditure and any variation to budget should be explained by the treasurer to the trustees at each quarterly meeting.
3.3 Documented Procedures & Evidence
• Transactions require supporting documentation (e.g., invoice, receipt, grant award letter, gift aid receipt) other than ongoing regular donations from individuals to the charity.
• Documents must be retained for at least seven years, as required by law.
4.0 Specific Procedures
4.1
Donations & Income Processing
• Receipting: one-off donations should be acknowledged promptly.
• Recording: Transactions should be recorded in the Excel file producing the accounts or any accounting software subsequently adopted.
• Banking: All cash/cheques should be banked promptly.
• Gift Aid: Procedures must be in place to claim Gift Aid accurately and in compliance with HMRC rules.
4.2 Purchasing & Payment Procedures
• The Bujagali Trust is a grant making charity for schools operating in Uganda so no purchases are made other than for website hosting which is paid for by another trustee and reimbursed by the treasurer.
• Payments are made as stated in paragraph 3.2.
4.3 Expense Reimbursement
• The charity’s policy is that no expenses are paid to the trustees:
o Trustees personally bear the cost of any costs incurred (for example travel expenses to Uganda)
o The charity has no employees
• As the charity incurs no expenses for trustees or employees a claim procedure is not necessary.
• A small expense allowance (currently less than £600 per annum) is made annually to one of our ambassadors in Uganda. This allowance is adjusted each year to take account of inflation in Uganda and the exchange rate from sterling to Ugandan schillings. The allowance is the main item included under Operating Costs in the budget.
4.4
Payroll
• As the charity has no employees a payroll procedure is not necessary.
4.5 Bank & Cash Management
• Bank Accounts: all accounts are held in the charity’s name.
• Bank Reconciliations: checked annually by the independent auditor.
• Online Banking: the treasurer and the chair of trustees both have access to online banking and should use a strong password.
• Petty Cash: no petty cash is held.
4.6 Fixed Assets & Stock
• The charity has no fixed assets.
4.7 Investments & Reserves
• Whilst the policy of the charity is not to hold excessive cash reserves the trustees need to ensure that:
1. the money approved for educational projects in Uganda is spent cost effectively, and
2. sufficient funds are available to finance a project
• Any excess cash reserves held in the short term to build up sufficient project funds are transferred to a bank deposit account to gain interest. The charity does not tie up funds in longer term investments which are unlikely to be quickly converted into cash without significant penalties or loss of value.
• The policy of the charity is to have a minimum reserve of around £3 million. A minimal reserve is necessary to cover the risk of overspend on projects or to cover emergency requests from our schools, for example assistance during the Covid outbreak in 2020.
4.8 Financial Reporting & Audit
• Management Accounts: A financial report is produced quarterly by the treasurer for the trustees, detailing actual income and costs, and comparing actuals to budget.
• Annual Statutory Accounts: Prepared in accordance with the Charity Commission requirements and filed on time.
• Independent Examination/Audit: Accounts are subject to independent examination as required by the Charity Commission.
5.0 Review & Compliance
This policy will be reviewed every three years by the trustees.
