1. PURPOSE

The primary objective of this policy is to safeguard the assets of the Australian Charity for Burundi (ACB) and ensure that all donations are utilised exclusively for their designated projects in accordance with the charitable purposes defined in the ACB Constitution. This policy is established to:

• Mitigate risks related to theft, loss, and financial opacity.
• Ensure full compliance with Australian financial regulations, specifically Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) requirements.

2. SCOPE

This policy is binding for all ACB board members, employees, volunteers, and overseas partners involved in any capacity with the management, transfer, or distribution of charitable funds.

3. POLICY STATEMENT

ACB operates under a strict “No Cash Distribution” model. The core pillars of this model are:

• Prohibition of Direct Cash: ACB does not distribute physical cash to individual beneficiaries or households in either Burundi or Australia.
• Electronic Transaction Mandate: All payments to partners, suppliers, and service providers must be executed via traceable electronic banking methods, such as wire transfers through reputable international channels or secure platforms like MyCause.
• Direct Procurement Model: Assistance is delivered through the direct purchase and provision of essential goods or services (e.g., agricultural seeds, educational supplies, construction materials, and medical equipment) instead of cash grants.

4. OPERATIONAL PROCEDURES

4.1 International Fund Transfers

• Institutional Accounts Only: Any donated funds transferred from Australia to the project in Burundi must be deposited into a registered institutional bank account held by the local partner organisation.
• Personal Account Ban: The transfer of charitable funds to any personal bank account is strictly prohibited.

4.2 Local Procurement in Burundi

• Direct Vendor Payment: ACB or its authorised partners must pay vendors directly for goods and services.
• Traceable Methods: Payments should be made via bank transfer or mobile money accounts, provided they are standard in the region and fully traceable.
• Compulsory Documentation: Every transaction requires a legitimate invoice and a signed receipt of delivery to be valid.

4.3 Petty Cash Management

• Usage Limitation: Limited petty cash is permitted solely for minor administrative office expenses, such as postage or local transport.
• Defined Cap: A strict maximum limit of $ 100 applies to petty cash holdings.
• Strict Restrictions: Petty cash must never be used for high-value purchases or program distributions.

5. COMPLIANCE & MONITORING

• Financial Audits: ACB will perform periodic financial reviews of project expenditures to verify that no unauthorised cash distributions have taken place.
• Partner Reporting: Local partners are required to submit monthly financial reports, accompanied by bank statements and copies of all invoices.
• Consequences of Breach: Failure to comply with this policy may result in disciplinary action for personnel or the immediate termination of partnerships.

6. EMERGENCY EXEMPTIONS

• Criteria: A one-time exemption may be considered only in extreme humanitarian emergencies where electronic banking infrastructure has collapsed.
• Authorisation: Any exemption must be granted formally by the ACB Board of Directors.
• Documentation: All exemptions must be documented in writing, specifying the nature of the emergency, the amount involved, and the verification measures implemented.