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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Social Fund Management and Distribution Policy

1. Purpose

The purpose of this policy is to ensure the proper management, distribution and oversight of the Social Fund at {{org_field_name}}, so that money donated or raised specifically for the collective benefit of residents is managed safely, transparently and only for the purposes for which it was donated or raised.

The Social Fund exists to enhance residents’ wellbeing, social participation and quality of life by supporting activities, entertainment, communal events, outings and other appropriate opportunities or items for the collective benefit of residents.

This policy supports compliance with the Regulation and Inspection of Social Care (Wales) Act 2016 and the Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017, as amended, including the requirements relating to safeguarding and supporting individuals to manage their money.

Money belonging to an individual resident is not Social Fund money merely because it is held, administered or safeguarded by {{org_field_name}}. Any money belonging to an individual resident that is managed or held by the service must be dealt with in accordance with the Managing Service User Finances Policy and Regulation 28 of the Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017, as amended.

This policy must be applied alongside the service’s safeguarding arrangements so that residents are protected from financial abuse, coercion, theft, fraud, misuse of money or property and inappropriate pressure concerning money.

2. Scope

This policy applies to the management and use of the Social Fund at {{org_field_name}} and to all staff, residents, representatives, family members, volunteers and other persons involved in contributing to, raising, administering, authorising or spending Social Fund money.

The Social Fund consists only of money that has been voluntarily donated, raised or granted specifically for the collective benefit of residents. This may include voluntary donations, fundraising proceeds and grants whose terms permit their use for the purposes described in this policy.

A resident’s personal money must not be transferred into or treated as part of the Social Fund unless the resident has made a valid and voluntary decision to donate that money and the requirements set out in section 3.3 of this policy have been satisfied.

Money that remains the property of an individual resident must not be pooled with the Social Fund. Where {{org_field_name}} holds or manages money belonging to an individual, it must be held in the individual’s name or within arrangements that clearly identify and separate that individual’s money and must be managed in accordance with the Managing Service User Finances Policy.

The Social Fund must not be used:

• for the routine operating expenditure of {{org_field_name}};
• to meet costs that the service provider is required to meet as part of providing the regulated service;
• as a substitute for a resident’s personal money;
• to make loans to staff, residents or other persons;
• to pay staff salaries, bonuses, gifts or benefits;
• for expenditure that does not benefit residents or is inconsistent with the stated purpose of the fund; or
• in any manner that amounts to, facilitates or creates a risk of financial abuse.

Where financial assistance is proposed for an individual resident rather than for the collective benefit of residents, the matter must not be dealt with through the Social Fund unless the money has lawfully been donated or raised for that specific charitable or benevolent purpose and its use is consistent with any conditions attached to the donation or fundraising activity. A resident’s own money must instead be managed under the Managing Service User Finances Policy.

3. Principles of Social Fund Management

3.1 Purpose of the Social Fund

The Social Fund is used solely for initiatives that contribute to residents’ quality of life, including organising social activities such as live entertainment, exercise classes, and cultural events, funding outings such as day trips, restaurant visits, and excursions, purchasing communal items such as books, games, gardening supplies, or decorations that enhance communal areas, and supporting special celebrations such as birthdays, religious or cultural festivities.

The Social Fund cannot be used for routine operational expenses of the care home, items or activities that only benefit individual residents unless pre-approved, staff salaries or bonuses, or any expenditure that does not align with the social and recreational needs of residents. All spending decisions must align with the principles of fairness, inclusivity, and resident choice.

3.2 Transparency and Governance

To ensure proper governance, the Social Fund is managed with strict financial controls. A dedicated fund account is maintained separately from operational finances to ensure clear accountability. All transactions must be documented with supporting receipts and a clear audit trail, with quarterly financial reports reviewed by management and made available for residents and family scrutiny.

An annual independent audit is conducted to ensure compliance with financial regulations. This audit process ensures that all funds are used as intended and that there are no irregularities in fund distribution or management.

The Registered Manager is responsible for ensuring compliance with financial regulations, approving all fund expenditures, and reporting financial updates to CIW as part of quality assurance reviews​. The manager must also ensure that residents and their representatives are informed of how the Social Fund is used and have an opportunity to contribute to decision-making.

3.3 Contribution to the Social Fund

The Social Fund may receive money from voluntary donations, fundraising activities, grants or other lawful sources where the money is intended for the collective benefit of residents.

All contributions must be genuinely voluntary. A resident, family member or other person must not be pressured, encouraged through coercion, given the impression that a contribution is expected, or treated differently because they choose not to contribute.

Payment into the Social Fund must never be made a condition of admission, continued residence, access to care or support, participation in activities, or receipt of any service that {{org_field_name}} is otherwise required or has agreed to provide.

A clear record must be maintained of money received into the Social Fund, including, where appropriate:

• the date received;
• the amount;
• the source of the money;
• the purpose or any restrictions attached to the donation, grant or fundraising proceeds;
• the person recording receipt of the money; and
• any supporting documentation required to maintain an appropriate audit trail.

Where money is raised for a stated or restricted purpose, it must be used consistently with that purpose. Money donated or collected specifically for the benefit of residents must not be used to meet the routine operating expenditure of the service.

Before accepting a contribution directly from a resident, staff must be satisfied that the resident is making the contribution freely and understands that the money is being donated to the Social Fund and will no longer be retained as part of their personal funds.

Where there is reason to doubt a resident’s capacity to decide whether to donate money, staff must not obtain or accept the contribution on the basis of consent from the resident until the question of capacity has been addressed in accordance with the Mental Capacity Act 2005.

A member of staff, an advocate, the Social Fund Committee or another person must not authorise the donation of a resident’s money merely because the resident lacks capacity. Where another person is legally authorised to manage the resident’s financial affairs, any proposed use of the resident’s money must fall within that person’s lawful authority and comply with the Mental Capacity Act 2005 and any other applicable legal requirements.

Staff must report any concern that a resident has been pressured, coerced, exploited or improperly influenced to contribute to the Social Fund as a safeguarding concern in accordance with section 3.6 of this policy.

3.4 Decision-Making Process for Fund Distribution

A Social Fund Committee oversees fund allocation and ensures fair distribution. The committee consists of resident representatives (where possible), a designated staff member responsible for fund administration, the Registered Manager or Deputy to ensure compliance with regulations, and a family representative where applicable.

The committee meets quarterly to review fund balances and approve upcoming expenditures, discuss new activity proposals from residents and families, and ensure fair and inclusive use of funds for all residents. All decisions are minuted and available for inspection by CIW. In cases where a resident is unable to participate in decision-making, their key worker or advocate will represent their interests.

Transparency in decision-making is a priority. All residents must be informed of committee decisions and have an opportunity to suggest activities or raise concerns about fund use. No decisions should be made without consultation, and all residents should benefit from the fund.

3.5 Resident Involvement and Choice

Residents must be given meaningful opportunities to express their wishes, preferences and views about how Social Fund money should be used for their collective benefit.

Information about proposals for use of the Social Fund must be communicated in a manner appropriate to residents’ individual communication needs. Reasonable support must be provided to enable residents to participate, including residents who have cognitive impairment, sensory impairment, communication difficulties or other support needs.

Residents may be invited to suggest activities, outings, events or communal purchases and may participate in residents’ meetings, surveys, voting or other appropriate consultation arrangements. The method used must not unfairly exclude residents who cannot participate in a conventional meeting or vote.

A resident must not automatically be excluded from consultation because they lack capacity to make a particular decision. Staff must take practicable steps to support the resident to participate and must consider the resident’s known wishes, feelings, preferences, values and interests.

Where a decision concerns a resident’s own personal money rather than money that has already been validly donated to the Social Fund, the decision must not be made by the Social Fund Committee. The resident’s own money must be managed in accordance with the Managing Service User Finances Policy and the Mental Capacity Act 2005 where applicable.

Where a resident lacks capacity to make a specific decision about their own finances, any decision made on their behalf must be made by a person with lawful authority or otherwise in accordance with the Mental Capacity Act 2005. An advocate does not acquire authority to make financial decisions merely by acting as an advocate, and the Social Fund Committee does not have authority to dispose of a resident’s personal money.

The Social Fund must be administered fairly and inclusively. Decisions concerning expenditure must have regard to the different needs, abilities, communication requirements, cultures, religions and protected characteristics of residents and must not unlawfully discriminate against any resident or group of residents.

3.6 Safeguarding Against Financial Misuse

{{org_field_name}} will maintain effective controls to protect residents and Social Fund money from theft, fraud, financial abuse, coercion, misappropriation, unauthorised expenditure or other misuse.

No person may use Social Fund money for their own personal benefit or use their position within the service to obtain an improper financial advantage.

Appropriate financial controls must be maintained, including separation of the Social Fund from the service’s routine operating finances, accurate transaction records, supporting receipts or equivalent evidence for expenditure, and arrangements that provide an appropriate audit trail.

Access to and authorisation of Social Fund transactions must be restricted to persons authorised by {{org_field_name}}. No person may circumvent the financial controls established by the service.

Any discrepancy, missing money, unexplained transaction, suspected theft, fraud, coercion, misuse of funds or other indication of possible financial abuse must be reported immediately to the Registered Manager or other designated senior person in accordance with the service’s safeguarding procedures.

Where there is an allegation, evidence or reasonable concern of financial abuse, neglect or improper treatment, {{org_field_name}} must:

• take immediate and proportionate action to protect the resident or residents concerned;
• act in accordance with the service’s Safeguarding Policy and the Wales Safeguarding Procedures;
• preserve relevant financial records and other evidence;
• make appropriate referrals to the local authority safeguarding service and other relevant agencies;
• notify the police where a criminal offence is suspected or where otherwise appropriate;
• make any notification to Care Inspectorate Wales required by the Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017, as amended; and
• keep an accurate record of the concern or allegation, evidence obtained, decisions made, protective action taken, referrals made, notifications submitted and the outcome so far as known.

Where abuse or an allegation of abuse involves the service provider, a member of staff or a volunteer, the required notification to Care Inspectorate Wales must be made in accordance with the applicable statutory notification requirements.

Where an incident is reported to the police, any separate statutory requirement to notify Care Inspectorate Wales must also be followed.

Staff may additionally use the Whistleblowing (Speaking Up) Policy where appropriate. Whistleblowing does not replace the requirement to take safeguarding action or make statutory referrals and notifications.

Any concern involving a member of staff must also be considered under the service’s disciplinary procedures and, where applicable, whether referral to the Disclosure and Barring Service, Social Care Wales or another professional regulator is required.

Social Fund financial records must be retained securely and made available to Care Inspectorate Wales where lawfully required for regulatory purposes.

4. Responsibilities

4.1 Management Responsibilities

The Registered Manager is responsible for the day-to-day implementation of this policy and for ensuring that arrangements for receiving, recording, safeguarding, authorising and spending Social Fund money are operated consistently with this policy.

The Registered Manager must ensure that:

• appropriate financial records and supporting evidence are maintained;
• Social Fund money is used only for its intended purposes;
• residents’ personal money is not improperly pooled with or treated as Social Fund money;
• staff understand the distinction between Social Fund money and residents’ personal money;
• resident involvement in decisions concerning use of the Social Fund is facilitated appropriately;
• suspected financial abuse or misuse is addressed through safeguarding procedures;
• statutory referrals and notifications are escalated to the person responsible for making them; and
• any identified discrepancy or weakness in financial controls is investigated and remedial action is taken.

The Responsible Individual must maintain effective oversight of the service in accordance with their statutory responsibilities. This includes ensuring that suitable arrangements are in place for policies and procedures to be kept up to date and for required records and governance systems to be maintained effectively.

Significant concerns regarding misuse of the Social Fund, financial abuse, failures in financial controls or repeated non-compliance with this policy must be brought to the attention of the Responsible Individual and service provider without delay.

The Responsible Individual must ensure that relevant safeguarding matters, concerns, incidents and weaknesses identified through monitoring or audit are considered within the service’s wider governance and quality assurance arrangements where appropriate.

Nothing in this section removes or transfers any statutory responsibility placed directly upon the service provider, Responsible Individual or other person by legislation.

4.2 Staff Responsibilities

Staff members must facilitate resident engagement in fund-related decisions, ensure residents are informed about fund contributions and activities, support residents in expressing their preferences regarding fund use, and report any concerns about financial mismanagement or exclusion. Staff must also ensure that activities funded by the Social Fund align with residents’ needs and preferences.

4.3 Resident and Family Responsibilities

Residents and families may suggest activities and review fund records upon request. They are also responsible for ensuring that contributions to the fund are voluntary and made transparently. Families should encourage resident participation in decision-making and raise any concerns about fund use to management.

5. Related Policies

This policy should be read in conjunction with:

• Managing Service User Finances Policy​
• Whistleblowing (Speaking Up) Policy​
• Dignity and Respect Policy​
• Communication and Engagement with Service Users and Families Policy

6. Policy Review

This policy will be reviewed at least annually and sooner where required because of:

• a change in legislation, statutory guidance or applicable CIW requirements;
• a change to the service or its Statement of Purpose that affects the operation of this policy;
• a safeguarding concern, financial irregularity, complaint or incident indicating that the policy may not be effective;
• findings from monitoring, audit, inspection or quality assurance activity; or
• identified changes in residents’ needs or the operation of the Social Fund.

The Responsible Individual must ensure that suitable arrangements are in place for the service provider’s policies and procedures to be kept up to date, having regard to the Statement of Purpose and the requirements of the Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017, as amended.

The Registered Manager is responsible for supporting the operational review and implementation of this policy and for bringing any identified need for amendment to the attention of the Responsible Individual and service provider.

Where this policy is amended, relevant staff must be informed of the changes and provided with any instruction or training necessary for them to implement the revised requirements.

The service must operate in accordance with the current approved version of this policy.

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Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
Reviewed on: {{last_update_date}}
Next Review Date: {{next_review_date}}
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