Effective Date: 25/12/2025
Last Updated: 25/12/2025

1. Introduction

KUPATE BG – Roma Public Council Foundation (“the Foundation”, “we”, “our”) is a non-profit organisation dedicated to improving the quality of life, social inclusion, and economic opportunities of vulnerable communities across Bulgaria, the Balkans, and beyond.

The Foundation operates with a mission to address systemic inequalities, providing targeted interventions in housing, education, youth development, environmental protection, and social welfare. Our work is guided by principles of transparency, accountability, and ethical stewardship of donor funds.

This Transparency & Compliance Statement is intended to provide comprehensive information on how the Foundation ensures responsible governance, legal compliance, ethical fundraising, financial integrity, and robust project monitoring. It serves to reinforce confidence for donors, partners, beneficiaries, regulators, and the wider public.

2. Legal and Regulatory Compliance

2.1 Bulgarian Legal Framework

The Foundation operates under the laws of the Republic of Bulgaria, including but not limited to:

• The Non-Profit Legal Entities Act

• The Civil and Commercial Code

• Taxation laws applicable to charitable organisations

All activities, from fundraising to project implementation, comply strictly with these statutes.

2.2 European Union Compliance

As the Foundation receives support and engages with donors and partners within the EU, it adheres to relevant European Union regulations:

• General Data Protection Regulation (GDPR, EU 2016/679): Ensuring lawful processing, storage, and protection of personal data for donors, partners, staff, and beneficiaries.

• ePrivacy Directive (2002/58/EC) and amendments: Governing digital communications, cookies, and online consent mechanisms.

• EU Anti-Fraud and Anti-Corruption Directives: Safeguarding EU funds when utilised for projects or grants.

2.3 United Kingdom Compliance

For UK-based donors and partners, the Foundation complies with relevant UK legislation, including:

• UK GDPR and Data Protection Act 2018

• Charity Commission guidance for registered charities (if applicable)

• Anti-Money Laundering (AML) regulations

3. Governance and Organisational Structure

3.1 Board of Trustees

The Foundation is governed by a Board of Trustees responsible for strategic oversight, compliance, and accountability.

Responsibilities include:

• Approval of annual budgets

• Oversight of financial audits

• Monitoring risk management frameworks

• Ensuring adherence to legal and ethical standards

Trustees are selected for their expertise in finance, law, social development, and governance. Conflicts of interest are actively managed through written policies.

3.2 Executive Management

The day-to-day operations are managed by an Executive Director and a team of managers responsible for:

• Programme design and implementation

• Human resources management

• Financial planning and reporting

• Donor and stakeholder engagement

3.3 Advisory Committees

The Foundation maintains advisory committees comprising subject-matter experts, external auditors, and community representatives. These committees provide:

• Strategic guidance on programme priorities

• Independent reviews of projects and budgets

• Ethical oversight and compliance recommendations

4. Financial Transparency

4.1 Budgeting Process

All financial resources are allocated through a formal budgeting process, which involves:

• Programme needs assessment

• Cost-benefit and impact analysis

• Approval by the Board of Trustees

Budgets are reviewed quarterly to ensure alignment with operational and strategic priorities.

4.2 Auditing and Reporting

The Foundation commissions annual external audits by independent certified accountants. Audit reports are made available to:

• Donors and funding partners

• Regulatory authorities

• Members of the public, upon request

Internal controls include:

• Segregation of duties in finance

• Automated accounting systems

• Monthly financial reconciliations

4.3 Publication of Annual Reports

Transparency is reinforced through public annual reports, which detail:

• Financial statements and balance sheets

• Fundraising outcomes and donor contributions

• Project implementation metrics and impact assessments

5. Fundraising Practices

5.1 Ethical Fundraising

All fundraising is conducted in accordance with ethical principles, including:

• Honesty and integrity in communications

• Respect for donor privacy and autonomy

• Compliance with applicable fundraising laws

5.2 Corporate and Institutional Donations

The Foundation welcomes donations from corporate entities, foundations, and institutions, subject to:

• Due diligence to prevent conflict of interest

• Verification of legal and ethical standing

• Written agreements outlining the purpose and use of funds

5.3 Individual Donors

Individuals may contribute through:

• Online donations via secure platforms

• Bank transfers

• Fundraising campaigns

All donations are acknowledged promptly, and receipts may be issued for tax-deductible purposes, where applicable.

6. Donor Data Protection and Privacy

6.1 GDPR Compliance

The Foundation ensures all personal data is processed in accordance with GDPR principles, including:

• Lawfulness, fairness, and transparency

• Purpose limitation

• Data minimisation

• Accuracy

• Storage limitation

• Integrity and confidentiality

6.2 Data Collection and Retention

Personal information collected from donors includes:

• Name, address, and contact details

• Payment information

• Communication preferences

Data is stored securely, with retention periods aligned with legal requirements and organisational policies.

6.3 Donor Rights

Donors retain rights to:

• Access their personal data

• Rectify inaccuracies

• Withdraw consent

• Request data erasure where lawful

7. Project Transparency

7.1 Project Selection

Projects are selected based on:

• Identified community needs

• Alignment with the Foundation’s mission

• Feasibility and sustainability

7.2 Monitoring and Evaluation

All projects are subject to:

• Continuous monitoring of outcomes and deliverables

• Quarterly progress reports

• Independent evaluations were required by donors

7.3 Public Reporting

Project outcomes, case studies, and impact data are shared publicly to ensure transparency, including:

• Website updates

• Donor newsletters

• Annual reports

8. Anti-Fraud and Ethical Standards

8.1 Whistleblowing

The Foundation maintains a confidential whistleblowing mechanism for staff, donors, or beneficiaries to report:

• Fraud

• Corruption

• Unethical practices

8.2 Conflict of Interest

All trustees, staff, and contractors must disclose conflicts of interest. Policies include:

• Recusal from decision-making

• Written documentation

• Board oversight

8.3 Risk Management

Comprehensive risk assessments cover:

• Financial mismanagement

• Operational inefficiencies

• Reputational risk

9. Partnerships and Third-Party Compliance

9.1 Partner Due Diligence

All partners, subcontractors, and implementing organisations undergo:

• Legal verification

• Financial and operational assessment

• Ethical and human rights compliance checks

9.2 Grant Compliance

For EU and UK grants, the Foundation ensures:

• Use of funds according to agreements

• Timely reporting and financial accountability

• Compliance with donor-specific regulations

10. Reporting and Accountability Mechanisms

10.1 Internal Reporting

Staff report through:

• Monthly operational meetings

• Financial reconciliations

• Project monitoring tools

10.2 External Reporting

Donors and the public are provided:

• Quarterly newsletters

• Annual financial statements

• Impact assessment reports

10.3 Complaint Handling

The Foundation provides clear procedures for handling:

• Donor complaints

• Beneficiary concerns

• Stakeholder feedback

11. Tax and Fiscal Compliance

11.1 Tax-Exempt Status

The Foundation maintains its charitable status under Bulgarian law, ensuring:

• Proper accounting of donations

• Submission of statutory returns

• Eligibility for tax exemptions

11.2 Cross-Border Donations

For international donors:

• Donations are processed in compliance with home country laws

• Tax-deductibility is subject to local regulations

• Certificates may be issued for donor records

12. Sustainability and Ethical Commitments

12.1 Environmental Responsibility

The Foundation implements policies to:

• Minimise carbon footprint

• Use sustainable materials

• Promote recycling and environmental education

12.2 Social Inclusion

Programmes actively include:

• Marginalised communities

• Women and youth

• Individuals with disabilities

12.3 Long-Term Planning

Strategic planning ensures sustainable impact beyond immediate projects.

13. Continuous Improvement and Review

• Policies are reviewed annually

• Staff receive regular training on compliance, ethics, and governance

• Feedback mechanisms are integrated into organisational learning

14. Contact Information

For queries regarding transparency, compliance, or donations, contact:

KUPATE BG – Roma Public Council Foundation
📍 Bulgaria, Sofia (1517), Slatina district, 31 514th Street
📞 +359 88 955 2668
📧 kupate.bg2021@gmail.com

15. Governing Law

This Transparency & Compliance Statement is governed by the laws of the Republic of Bulgaria, in accordance with applicable EU and UK regulations.