AMABHUNGANE CENTRE FOR INVESTIGATIVE JOURNALISM NPC
FUNDING POLICY – ADOPTED BY BOARD JULY 31 2019
Purpose

1. This policy is intended to:a. protect our editorial independence from compromise at the hand of our funding;b. shield us and our funders from public perceptions of the same;c. promote transparency; andd. stimulate the development of funding policies applicable to the non-profit journalism sector ingeneral.
Definitions

2. “Corporate funding” means funding from any juristic person with a profit motive or its proxy, the latterincluding a natural person, but does not include funding from bona fide charities/non-profits or simple
holding structures for the assets of natural persons. A “corporate” has the corresponding meaning.
3. A “donation” means funding with the characteristics below. “Crowd funding” means the same, while“donor” and “crowd funder” have corresponding meanings.
a. The funding, or invitation to apply for funding, is at the instance of the funder (although it may
be in response to a general appeal by us initially or in response to a specific request by us forrepeat funding);b. The purpose of the funding is not restricted (other than as to our stated objectives overall orstatutory limitations that apply generally between similar funders and funded organisations);c. The period within which we may use the funding is not restricted;
d. We are not obliged to report to the funder (other than information that we do or would readily
report to the public); ande. The aggregate from the funder within our financial year does not exceed the amounts inparagraph 20.
4. “Government funding” means funding from any government department, agency, entity, enterprise orproxy, the latter including a natural person, locally and abroad. A “government” has the corresponding
meaning.
5. A “grant” means funding that tends to have the characteristics below, while “grant funder” has thecorresponding meaning. We deem any funding that is not “government funding”, “corporate funding”, a“donation” or a “legacy” to be a grant.
a. We apply for the funding;b. The funding may be restricted to specific purposes;c. The period within which we may use the funding is restricted, after which any surplus may be
repayable to the funder; andd. We are obliged to report to the funder on predetermined indicators regarding the use of thefunding, our work and/or our organisational status.
6. A “legacy” is a bequest specifically to amaBhungane in a will.
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Application

7. This policy applies to donations, grants and legacies to amaBhungane itself. It does not apply to:a. commercial discounts, tax breaks or similar benefits provided they are also available to nonprofits, companies or the public generally;b. benefits such as sponsorships, hospitality and gifts to individual staff, provided that theiracceptance is regulated by policy or practice broadly consistent with this policy; andc. direct contributions by media organisations to shared costs of joint stories or by partnerorganisations to shared costs of joint non-story projects.
8. This policy prevails in case of a conflict between it and any earlier amaBhungane policy or code.
General conditions

9. We shall not accept funding for specific stories or story areas, or that has conditions regarding our
editorial decisions such as which stories we do and what they say.
10. We shall not accept funding where there is a material risk that its provenance will conflict us, orreasonably be seen by the public to conflict us, with regard to a story or stories that we might want to doin the foreseeable future. Unless aggravating circumstances apply, we shall consider risk to beimmaterial where the aggregate from a funder within our financial year is R10 000 or less.1
11. We shall not accept funding unless we may and do publicly disclose the identity of the funder and theamount where the aggregate within our financial year is material, i.e. exceeds the amount in paragraph
10 above.
12. Where funding reaches us before we are able to determine if it is acceptable under this policy, we shallreturn any amount that is not acceptable. Where we are unable to return funding despite ourreasonable efforts, we shall transfer it to a charitable cause of our choosing.
13. We consider the provenance of funding/the identity of a funder to be the juristic or natural person who
made the decision to fund us, and not any funder they had in turn who did not contribute to thatdecision.
14. Where ostensibly distinct funders are within our knowledge materially connected, we shall count themas one for the purpose of all limits in this policy.
Government and corporate funding

15. The risk that government or corporate funding will compromise us is high given our enduring journalistic
interest in government and corporate malfeasance; and the serious consequences should a perception
arise that our editorial decisions are influenced by state or corporate actors.
16. To this end:a. We shall not solicit government or corporate funding.
b. We shall not accept government or corporate funding.2

1

The executive directors will amend this amount from time to time to be a rounded figure roughly
equivalent to 0.1% of our budget.
2This is subject to us being or becoming aware that the funding is from such a source.
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Grant funding

17. Grant funding risks include the real or perceived links that may exist between grant funders andgovernments or corporates; the conditions that may attach to grant funding; the possibility that grant
funders may want to influence editorial decisions; and the materiality of some grants when measured
against the size of grantee budgets.
18. To this end:a. We may accept grant funding only from reputable grant-making organisations with a credible
track record of funding media or social justice causes and that are clearly not government or
corporate funders or their proxies;
b. We shall perform a due diligence on any new grant funder to satisfy ourselves that accepting
grants from it will not contravene this policy; in particular its provisions in the subparagraphimmediately above and on conflicts with regard to a story or stories that we might want to do in
the foreseeable future;c. We shall consider any new grant agreement diligently to satisfy ourselves that it does notcontravene this policy and in particular does not contain conditions regarding our editorial
decisions; andd. We shall limit our exposure to any particular grant funder to 20% of our budget, although ourboard may waive this limit in exceptional circumstances subject to conditions regarding theextent and duration of the breach.
Donations/crowd funding

19. Donations come without material conditions and tend to be in smaller amounts, which mitigates theirrisk. However, there may be real risks relating to who donors are and what other interests they have,
which may give rise to real or perceived conflicts regarding our stories.
20. To this end:a. We may accept donations from a natural person, or a juristic person that is a simple holding
structure for the assets of a natural person, to a maximum aggregate within our financial year of
R100 000;3
b. We may accept donations from a juristic person that is a bona fide charity/non-profit to amaximum aggregate within our financial year of R250 000,4 except that where the funder is little
more than an extension of a natural person, the limit in respect of natural persons applies;c. We shall perform a due diligence on any donor when their aggregate within our financial year
becomes material, i.e. exceeds the amount in paragraph 10 above, to satisfy ourselves that
accepting donations from them will not contravene this policy; in particular its provisions in thetwo paragraphs immediately above and on conflicts with regard to a story or stories that wemight want to do in the foreseeable future; and3The executive directors will amend this amount from time to time to be a rounded figure roughly
equivalent to 1% of our budget.
4
The executive directors will amend this amount from time to time to be a rounded figure roughly
equivalent to 2.5% of our budget.
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