# Nkwenkwezi Foundation
## Draft Organisational Policy Framework
Version 1.0 | 29 September 2026

Status: Draft for governing-body review. Not yet formally adopted.

Before implementation, confirm named responsible people, alignment with the founding document and applicable requirements, approval resolution, effective date, procedures and training.


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# Nkwenkwezi Foundation
## Governance, ethics & conflicts of interest

Document: NKF-POL-01 | Version 1.0 | 29 September 2026
Status: Draft for governing-body review; not yet adopted.
Proposed approval authority: the Foundation’s governing body.
Effective date: to be recorded following formal adoption.
Review: annually and after material changes.

### 1. Purpose and scope

This draft applies to the governing body, office-bearers, staff, volunteers, advisers and anyone authorised to represent Nkwenkwezi Foundation. It is intended to support the founding document and applicable duties; it does not replace them.

### 2. Governing authority

The governing body should approve strategy, annual budgets, material commitments and delegated authority. Management should implement approved work and report against the agreed plan. Before adoption, confirm the Foundation’s legal form, governing-body composition, quorum, meeting schedule and reserved decisions against its founding document.

### 3. Decision-making and records

Keep an accurate register of office-bearers, a decision and resolution register, meeting minutes and a delegation schedule. Record who approved a decision, the information considered, any conditions and the person responsible for follow-up. Review programme, financial, safeguarding and reputational risks at scheduled meetings.

### 4. Conflicts of interest

Declare actual, potential or perceived conflicts when joining and whenever circumstances change. Record relevant financial, family and organisational relationships. A conflicted person should withdraw from the affected decision; the remaining authorised decision-makers should record how the conflict was handled. Gifts and hospitality must not influence selection, funding or procurement decisions.

### 5. Integrity and representation

Do not claim credentials, partnerships, tax benefits, outcomes or endorsements without current evidence and permission where necessary. Only authorised people may sign agreements or speak on behalf of the Foundation. No representative may use the Foundation’s position for private gain or party-political campaigning.

### 6. Oversight, review and adoption

The governing body should designate a policy custodian and review this policy annually, after a serious incident or after a material change. Adoption requires a recorded resolution, an effective date, confirmed delegations, an interests register and induction for affected people.

### Reference framework

Department of Social Development, Codes of Good Practice for South African NPOs: https://www.dsd.gov.za/index.php/documents?catid=78&id=395&m=0&task=download.send
Information Regulator, POPIA resources: https://inforegulator.org.za/popia/

This is a proposed organisational framework. It must be checked against the Foundation’s circumstances before adoption; it is not legal certification.


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# Nkwenkwezi Foundation
## Finance, fundraising & donor stewardship

Document: NKF-POL-02 | Version 1.0 | 29 September 2026
Status: Draft for governing-body review; not yet adopted.
Proposed approval authority: the Foundation’s governing body.
Effective date: to be recorded following formal adoption.
Review: annually and after material changes.

### 1. Purpose and scope

This draft applies to donations, grants, sponsorships, event income, fundraising campaigns and related expenditure. Its aim is to protect the Foundation, donors and communities through appropriate approvals and reliable records.

### 2. Official channels and approvals

Use only Foundation-controlled banking and payment channels approved by the governing body. Do not collect funds into personal accounts. New gateways, public campaigns, third-party collectors and fundraising agreements require documented approval before launch. Verify a proposed partner’s identity, reputation, terms and handling of personal information.

### 3. Donor care and honest claims

Explain the purpose of an appeal, the intended use of funds and any material restriction. Do not promise a tax-deductible receipt unless current eligibility and the relevant donation have been verified. Acknowledge contributions, record communication preferences and respect donor anonymity. Proposed service standards should be approved only when staff capacity can support them.

### 4. Restricted funds and financial records

Record donor restrictions separately, using a unique grant or campaign reference. Reconcile income to bank records and acknowledgements, investigate differences and retain supporting evidence. Do not redirect restricted funds without the necessary documented permission. Record in-kind contributions and their intended use without inventing valuations.

### 5. Expenditure and reconciliation

Operate against an approved budget and written delegation limits. Separate requesting, authorising, paying and reconciling where possible; use documented independent review where a small team cannot fully separate roles. Reconcile bank accounts regularly and report unexplained items, overdue reports and cash-flow risks to the governing body.

### 6. Exceptions, refunds and reporting

Document refunds, disputed payments, cash handling and losses through an authorised process. Maintain a donor and grant register, restricted-funds register, payment approval record and reporting calendar. The governing body must approve thresholds, signatories, reporting frequency and the finance owner before this policy takes effect. Suspected misuse should be escalated through the complaints and whistleblowing process.

### Reference framework

Department of Social Development, Codes of Good Practice for South African NPOs: https://www.dsd.gov.za/index.php/documents?catid=78&id=395&m=0&task=download.send
Information Regulator, POPIA resources: https://inforegulator.org.za/popia/

This is a proposed organisational framework. It must be checked against the Foundation’s circumstances before adoption; it is not legal certification.


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# Nkwenkwezi Foundation
## Safeguarding children & vulnerable participants

Document: NKF-POL-03 | Version 1.0 | 29 September 2026
Status: Draft for governing-body review; not yet adopted.
Proposed approval authority: the Foundation’s governing body.
Effective date: to be recorded following formal adoption.
Review: annually and after material changes.

### 1. Purpose and scope

This draft covers all Foundation activities, events, visits, digital engagement and partner-delivered work involving children or people at increased risk of harm. Safety takes priority over organisational reputation, fundraising or programme targets.

### 2. Preparation before an activity

Designate a trained safeguarding lead and an alternate, complete an activity risk assessment and confirm appropriate supervision and reporting routes. Check suitability and any legally required screening before assigning roles. Explain participation arrangements to caregivers and participants in language they can understand. Participation or media consent must not be coerced by a promise of assistance.

### 3. Expected conduct

Treat participants respectfully. Prohibit abuse, exploitation, harassment, humiliating punishment, sexual misconduct and exchanges of assistance for personal favours. Avoid isolated, unobservable contact with children; use approved supervision and communication arrangements. Do not publish identifying information or photographs without the required permission and a risk assessment.

### 4. Receiving a concern

Listen without leading questions, record essential facts accurately and do not promise absolute secrecy. Take immediate steps to reduce danger and seek appropriate emergency assistance when required. Escalate promptly to the designated lead or alternate. Do not attempt an unqualified investigation or confront an alleged perpetrator in a way that increases risk.

### 5. Referral and confidentiality

Identify applicable reporting duties and appropriate statutory referral routes without delay; an internal process must not obstruct a required external report. Share information only with people who need it to protect participants or fulfil a duty. Keep records securely, restrict access and arrange appropriate support. Protect good-faith reporters from retaliation.

### 6. Implementation and review

Before adoption, confirm the named lead and alternate, emergency and statutory contacts, screening requirements, event and transport procedures, consent templates and secure records. Train staff and volunteers, include safeguards in partner agreements and review incidents for learning. Until these arrangements are confirmed, this document is a draft framework, not a claim that all safeguards are operational.

### Reference framework

Department of Social Development, Codes of Good Practice for South African NPOs: https://www.dsd.gov.za/index.php/documents?catid=78&id=395&m=0&task=download.send
Information Regulator, POPIA resources: https://inforegulator.org.za/popia/

This is a proposed organisational framework. It must be checked against the Foundation’s circumstances before adoption; it is not legal certification.


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# Nkwenkwezi Foundation
## Personal information, privacy & records

Document: NKF-POL-04 | Version 1.0 | 29 September 2026
Status: Draft for governing-body review; not yet adopted.
Proposed approval authority: the Foundation’s governing body.
Effective date: to be recorded following formal adoption.
Review: annually and after material changes.

### 1. Purpose and scope

This draft addresses personal information handled in programme administration, fundraising, employment, volunteering, events and communications. The website privacy page separately describes how the current website works. This framework must be aligned with the Foundation’s actual systems and applicable South African requirements before adoption.

### 2. Accountability and lawful purpose

Confirm the responsible party, the relevant Information Officer arrangements and the people authorised to handle records. Maintain an inventory of information collected, why it is needed, where it is held, who can access it and how long it is retained. Identify an appropriate lawful basis for each activity rather than assuming consent is always the only basis.

### 3. Minimal collection and clear notices

Collect only what is necessary for the defined purpose. Explain the use of information in plain language, including relevant sharing and contact routes. Do not request identity documents, medical details or sensitive case records through the general website enquiry form. Consider additional requirements before processing children’s or other specially protected information.

### 4. Security and service providers

Use role-based access, strong authentication, secure storage, reliable backups and prompt removal of access when a role ends. Keep paper records in controlled storage. Assess service providers and document their security and confidentiality responsibilities. Review cross-border processing before using an external service.

### 5. Retention, requests and incidents

Approve a retention schedule that accounts for legal, funding and operational needs, then securely dispose of information when no longer required. Record access, correction and objection requests and route them to the responsible person. Contain suspected security incidents, preserve relevant evidence, assess notification duties and follow the Information Regulator’s applicable process.

### 6. Adoption requirements

Appoint accountable roles, approve notices and retention rules, document approved systems and providers, train users and test the incident process. Do not claim POPIA compliance merely because this draft exists. Review the framework at least annually and after a material change or incident.

### Reference framework

Department of Social Development, Codes of Good Practice for South African NPOs: https://www.dsd.gov.za/index.php/documents?catid=78&id=395&m=0&task=download.send
Information Regulator, POPIA resources: https://inforegulator.org.za/popia/

This is a proposed organisational framework. It must be checked against the Foundation’s circumstances before adoption; it is not legal certification.


---

# Nkwenkwezi Foundation
## People, volunteering & code of conduct

Document: NKF-POL-05 | Version 1.0 | 29 September 2026
Status: Draft for governing-body review; not yet adopted.
Proposed approval authority: the Foundation’s governing body.
Effective date: to be recorded following formal adoption.
Review: annually and after material changes.

### 1. Purpose and scope

This draft applies to employees, volunteers, interns, mentors, event contributors and other authorised representatives. It sets a common conduct framework without replacing employment agreements, volunteer agreements or applicable labour requirements.

### 2. Recruitment and role clarity

Define the purpose, duties, supervisor, location, time commitment, suitability requirements and any expense arrangements before a person starts. Select fairly and document necessary screening. Clarify whether a role is paid, unpaid or reimbursed; do not suggest that volunteering guarantees employment or financial assistance.

### 3. Induction and support

Provide induction on the Foundation’s purpose, safeguarding, privacy, conflicts of interest, approved communications and how to raise a concern. Allocate a supervisor and agree practical boundaries. People must work within their competence and should seek guidance when a situation falls outside their role.

### 4. Respectful conduct

Prohibit discrimination, bullying, harassment, exploitation and abuse. Respect cultural difference and people’s dignity. Protect confidential information and Foundation property. Do not solicit personal benefits from participants, make unauthorised promises or use the Foundation’s name for private collections.

### 5. Children, media and digital contact

Roles involving children require suitable safeguards and supervision. Use approved channels for participant communication. Photographs, testimonials, social posts and media statements require appropriate permission and review. Never publish sensitive participant details or portray people in a degrading manner.

### 6. Concerns, exit and adoption

Address concerns through a fair, documented process with an opportunity to respond and proportionate interim protections. Return property, revoke access and hand over records when a role ends. Before adoption, approve the role templates, screening process, supervision arrangements, expense rules and grievance route.

### Reference framework

Department of Social Development, Codes of Good Practice for South African NPOs: https://www.dsd.gov.za/index.php/documents?catid=78&id=395&m=0&task=download.send
Information Regulator, POPIA resources: https://inforegulator.org.za/popia/

This is a proposed organisational framework. It must be checked against the Foundation’s circumstances before adoption; it is not legal certification.


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# Nkwenkwezi Foundation
## Complaints, whistleblowing & protection from retaliation

Document: NKF-POL-06 | Version 1.0 | 29 September 2026
Status: Draft for governing-body review; not yet adopted.
Proposed approval authority: the Foundation’s governing body.
Effective date: to be recorded following formal adoption.
Review: annually and after material changes.

### 1. Purpose and scope

This draft covers concerns from participants, caregivers, donors, volunteers, staff, partners and members of the public. It includes service complaints, misconduct, suspected fraud, conflicts of interest and safeguarding concerns. Urgent safety matters require immediate protective action and appropriate external assistance.

### 2. Accessible reporting

Provide clear contact routes, a designated handler and an alternate who can receive concerns about the handler or leadership. Accept a first report without demanding unnecessary personal information. Permit a reporter to request a private follow-up. An anonymous report should be assessed on the information available, while recognising that follow-up may be limited.

### 3. Triage and acknowledgement

Record the concern securely and assess urgency, safety, conflicts and any legal reporting duty. Acknowledge receipt and explain the next step where a safe contact route is available. Agree realistic response targets before adopting this policy; do not promise an outcome before the facts are assessed.

### 4. Fair handling and confidentiality

Assign a sufficiently independent person to assess the matter. Give affected people a fair opportunity to respond, preserve evidence and limit access to those who need it. Share information lawfully and explain that confidentiality may have limits where safety or reporting duties apply. Do not retaliate against good-faith reporting.

### 5. Outcome, review and learning

Record the findings, action taken and reasons. Communicate an appropriate outcome to the reporter without exposing another person’s confidential information. Provide a review route to a non-conflicted governing-body member or suitable independent person. Track recurring themes and corrective actions.

### 6. Before adoption

Confirm named reporting and escalation contacts, the alternate route, secure registers, response targets, investigation support and external referral contacts. Staff and volunteers should know how to use the process. A public general-contact address alone is not an independent whistleblowing service.

### Reference framework

Department of Social Development, Codes of Good Practice for South African NPOs: https://www.dsd.gov.za/index.php/documents?catid=78&id=395&m=0&task=download.send
Information Regulator, POPIA resources: https://inforegulator.org.za/popia/

This is a proposed organisational framework. It must be checked against the Foundation’s circumstances before adoption; it is not legal certification.


---

# Nkwenkwezi Foundation
## Procurement, partnerships & anti-corruption

Document: NKF-POL-07 | Version 1.0 | 29 September 2026
Status: Draft for governing-body review; not yet adopted.
Proposed approval authority: the Foundation’s governing body.
Effective date: to be recorded following formal adoption.
Review: annually and after material changes.

### 1. Purpose and scope

This draft covers purchasing, contracting, in-kind arrangements, delivery partners and third-party fundraising. The process should be proportionate to value, complexity and risk while protecting the Foundation’s purpose and resources.

### 2. Planning and approval

Define the need, budget, specification and decision-maker before seeking a supplier or partner. Apply an approved delegation and procurement-threshold schedule. Do not split transactions to avoid approval limits. Keep written reasons for urgent or single-source exceptions and obtain independent review.

### 3. Fair selection

Use consistent criteria that consider suitability, total cost, delivery capacity, safety and relevant social value. Declare conflicts and exclude conflicted people from evaluation and approval. Do not accept bribes, kickbacks or gifts that could affect a decision. Related-party arrangements require explicit disclosure and appropriate independent approval.

### 4. Proportionate due diligence

Verify identity and relevant credentials, banking details, capacity and reputation. For participant-facing work, assess safeguarding and privacy arrangements. For fundraising partners, verify fee terms, fund flows, donor-data responsibilities and the use of the Foundation’s name. Do not describe a prospect as an established partner.

### 5. Contracting and performance

Record scope, deliverables, responsibilities, price, payment terms, ownership of materials and data, safeguarding requirements, complaints routes and exit arrangements. Confirm receipt or performance before payment. Track issues and do not extend a poor-performing arrangement without a documented review.

### 6. Adoption and review

Approve thresholds, authorisation levels, supplier checks, evaluation templates and a contracts register. Report suspected corruption through the complaints process and preserve relevant evidence. Review this policy annually and when material weaknesses are identified.

### Reference framework

Department of Social Development, Codes of Good Practice for South African NPOs: https://www.dsd.gov.za/index.php/documents?catid=78&id=395&m=0&task=download.send
Information Regulator, POPIA resources: https://inforegulator.org.za/popia/

This is a proposed organisational framework. It must be checked against the Foundation’s circumstances before adoption; it is not legal certification.


---

# Nkwenkwezi Foundation
## Programme evidence, reporting & ethical storytelling

Document: NKF-POL-08 | Version 1.0 | 29 September 2026
Status: Draft for governing-body review; not yet adopted.
Proposed approval authority: the Foundation’s governing body.
Effective date: to be recorded following formal adoption.
Review: annually and after material changes.

### 1. Purpose and scope

This draft covers programme planning, participant records, monitoring, evaluation, donor reporting, photographs, stories and public claims. Its purpose is to make learning useful and communication trustworthy.

### 2. Plan evidence before delivery

Each initiative should have a defined community need, intended participants, activities, intended outcomes and a proportionate evidence plan. Set indicators, sources, responsibilities and review points before launch. Distinguish attendance from unique participants, outputs from outcomes and aspirations from measured results.

### 3. Keep proportionate records

Collect only necessary information and explain its purpose. Use controlled participant or activity references where possible. Record reporting periods, definitions and limitations. Check for duplicate counts, missing evidence and inconsistent financial totals before publishing a result.

### 4. Learn with participants

Seek accessible feedback and include people’s views in programme improvement. Participation in feedback or publicity should not be a condition of receiving support. Consider whether reported change can reasonably be connected to the programme and avoid claiming sole causation without evidence.

### 5. Tell stories with dignity

Use appropriate, informed permission for identifiable images, quotations and case studies. Apply additional safeguards for children and sensitive situations. Do not invent testimonials, stage false beneficiary claims or import another organisation’s results. Verify partner names, logos, credentials and financial claims before publication.

### 6. Review, correction and adoption

Assign programme, finance and communications reviewers as appropriate. Keep a claims register and evidence reference for significant published results. Correct errors promptly and record material changes. Before adoption, approve indicator definitions, consent templates, review responsibilities, data access and the reporting calendar.

### Reference framework

Department of Social Development, Codes of Good Practice for South African NPOs: https://www.dsd.gov.za/index.php/documents?catid=78&id=395&m=0&task=download.send
Information Regulator, POPIA resources: https://inforegulator.org.za/popia/

This is a proposed organisational framework. It must be checked against the Foundation’s circumstances before adoption; it is not legal certification.
