1. Introduction
The Amaefule and Astudillo Empowerment Foundation (T.A.A.E Foundation) is a non-profit organisation registered in Nigeria as an Incorporated Trustee under Part F of the Companies and Allied Matters Act (CAMA) 2020. The Foundation is committed to empowering children and adults with disabilities and delivering community development programmes across Nigeria.
Sound financial management is the bedrock of organisational credibility, donor confidence, and long-term sustainability. This policy establishes the financial management framework within which the Foundation operates. It defines how funds are received, recorded, approved, spent, reported, and audited, and sets out the responsibilities of every person who handles or oversees Foundation finances.
This policy is consistent with the requirements of CAMA 2020, the Nigeria Not-For-Profit Governance Code (NFPGC) 2023, the Federal Inland Revenue Service (FIRS) requirements for non-profit organisations, and the Special Control Unit Against Money Laundering (SCUML) reporting obligations applicable to civil society organisations in Nigeria.
2. Purpose of This Policy
The purpose of this policy is to:
- Establish transparent, consistent, and accountable financial management practices across the Foundation
- Protect the integrity and reputation of the Foundation and its trustees
- Ensure that all funds are used solely for the Foundation's stated charitable objectives
- Prevent fraud, misappropriation, and financial misconduct
- Provide a clear framework that builds confidence with donors, grant funders, and partner organisations
- Ensure compliance with Nigerian legal and regulatory requirements for non-profit organisations
- Support the preparation of accurate financial records and annual returns
3. Scope of This Policy
This policy applies to all persons who manage, handle, authorise, or have oversight of Foundation finances, including:
- Board of Trustees and the designated Board Treasurer
- The Chief Executive Officer
- Programme Coordinators and Executives responsible for programme expenditure
- Volunteers who are entrusted with funds for specific activities
- Any contractor, partner, or individual acting on behalf of the Foundation in a financial capacity
This policy covers all financial activity including income from founders and trustees, voluntary contributions, donations, grants, and any other source of funds, as well as all expenditure on programmes, logistics, medications and medical supplies, administration, and any other operational cost.
4. Core Financial Principles
Non-Profit Principle
Consistent with Section 838 of CAMA 2020, all income and assets of the Foundation must be applied solely toward the Foundation's stated charitable objectives. No portion of Foundation funds may be paid to, or benefit, any trustee, staff member, or volunteer as personal profit.
Transparency
Financial records shall be maintained in a manner that is accurate, complete, and accessible to authorised persons. The Foundation shall not maintain undisclosed accounts or conduct financial transactions outside its official records.
Accountability
Every person who receives, handles, approves, or spends Foundation funds is personally accountable for those funds. Accountability is not delegated away, it remains with the individual and the Board at all times.
Segregation of Duties
Where possible, the responsibilities of authorising, receiving, and recording financial transactions shall be separated among different individuals. No single person shall have sole control over any complete financial transaction from approval through to payment and recording.
Value for Money
All expenditure must represent genuine value for money. Funds must be spent economically, efficiently, and in a manner that maximises impact for the beneficiaries the Foundation serves.
Sustainability
The Foundation shall manage its finances in a manner that supports long-term organisational sustainability. Expenditure shall not routinely exceed income, and the Foundation shall maintain awareness of its financial position at all times.
5. Sources of Funding
T.A.A.E Foundation currently operates on a self-funded model. All programme costs to date have been met through the personal contributions of the founders, trustees, and board members, with occasional voluntary financial support from unpaid volunteers. The Foundation is actively developing the capacity to receive external grants, donations, and institutional funding.
All accepted sources of funding must be consistent with the Foundation's values and charitable objectives. The Foundation will not knowingly accept funds from sources that are implicated in exploitation, human rights abuses, or activities that contradict the Foundation's mission.
Categories of accepted funding include:
- Personal contributions from founders and trustees
- Voluntary financial contributions from volunteers
- Individual donations from members of the public
- Institutional grants from registered grant-making bodies
- Corporate donations and sponsorships
- Proceeds from Foundation-organised fundraising events
All incoming funds, regardless of source or amount, must be received into the Foundation's official bank account held with UNITED BANK FOR AFRICA, No Foundation funds shall be received into, or disbursed from, a personal account.
6. Banking and Cash Management
Official Bank Account
The Foundation maintains an official bank account registered in the Foundation's name. All funds received by the Foundation must be deposited into this account. No financial activity shall be conducted outside this account without prior written approval from the Board.
Authorised Signatories
The Foundation's bank account shall require a minimum of two authorised signatories for any transaction above a defined threshold. Authorised signatories shall be designated by the Board of Trustees and shall include at least one trustee. The list of authorised signatories shall be reviewed annually and updated whenever there is a change in board or leadership composition.
Cash Handling
The Foundation shall minimise the use of physical cash wherever possible. Where cash transactions are necessary, particularly for field operations, the following controls apply:
- Cash shall only be advanced for a specific approved purpose and activity
- The person receiving the cash advance must sign a receipt acknowledging the amount received
- All cash must be accounted for with receipts, invoices, or written records of expenditure
- Any unspent cash must be returned to the designated financial officer within 48 hours of the activity
- Cash advances shall not be issued to a person who has an outstanding unretired advance
Mobile and Electronic Payments
Where payments are made or received through mobile money platforms or electronic transfers, a record of the transaction reference, amount, sender or recipient, and purpose must be maintained and filed with the Foundation's financial records.
7. Financial Record Keeping
TAAE Foundation is committed to maintaining accurate, complete, and up-to-date financial records at all times. Financial records serve as the primary evidence of how funds and resources entrusted to the Foundation have been managed and utilized, and are essential for accountability to donors, beneficiaries, partners, regulators, and other stakeholders.
The Foundation shall maintain appropriate financial records, including but not limited to:
- - Records of income received, including donations, grants, sponsorships, and other sources of funding.
- - Records of expenditures and payments made in support of Foundation activities and operations.
- - Supporting documentation such as receipts, invoices, contracts, and payment vouchers.
- - Banking records and reconciliations for Foundation accounts.
- - Donor and funding records where applicable.
- - Financial reports, budgets, and audit documentation.
- - Other records required to demonstrate compliance with applicable laws, regulations, and donor requirements.
All financial records shall be maintained in a secure and organized manner, with access restricted to authorized personnel only.
The Foundation shall retain financial records for a minimum period of seven (7) years, or for such longer period as may be required by applicable laws, regulatory requirements, donor agreements, or organizational needs.
TAAE Foundation is committed to protecting the confidentiality, integrity, and availability of financial information while ensuring transparency, accountability, and responsible stewardship of all resources entrusted to the organization.
8. Budgeting and Financial Planning
The Foundation shall prepare an annual budget that projects expected income and planned expenditure for each financial year. The budget shall be prepared by the CEO, reviewed by the Board Treasurer, and approved by the full Board of Trustees before the commencement of each financial year.
For each specific programme, outreach, or project, a programme budget shall be prepared in advance setting out the expected costs across all expenditure categories. Expenditure shall not substantially exceed the approved programme budget without prior authorisation.
The Board shall receive a financial report comparing actual income and expenditure against the approved budget at least every six months. Significant variances shall be explained and, where necessary, the Board shall approve a revised budget.
9. Financial Reporting
Internal Reporting
The CEO shall present a financial summary to the Board of Trustees at every board meeting. This summary shall include total income received to date, total expenditure to date, current bank balance, any outstanding advances or liabilities, and any financial concerns or anomalies.
Annual Financial Report
At the close of each financial year, the Foundation shall prepare an annual financial report covering all income and expenditure for the year. This report shall be reviewed and approved by the Board before submission to the Corporate Affairs Commission as part of the Foundation's annual returns, as required by Section 845 of CAMA 2020.
SCUML Reporting
As a civil society organisation, the Foundation is required to register with and report to the Special Control Unit Against Money Laundering (SCUML). Cash transaction reports shall be filed every six months as required. The CEO is responsible for ensuring SCUML compliance is maintained.
Donor and Funder Reporting
Where the Foundation receives external grants or restricted donations, financial reports shall be prepared and submitted to the relevant donor or funder in accordance with the agreed reporting schedule and format. Restricted funds must be tracked separately and used only for the purposes for which they were given.
10. Audit and Financial Review
The Foundation is committed to independent financial oversight as a mark of accountability and transparency.
An internal financial review shall be conducted at least annually by a trustee or designated person who has no day-to-day involvement in financial transactions. This review shall assess whether financial records are accurate and complete, whether the approval processes have been followed, and whether there are any irregularities requiring further investigation.
As the Foundation grows and its income increases, the Board shall commission an independent external audit by a qualified auditor. Consistent with the NFPGC 2023, external audit firms shall not be retained for longer than ten years, and the Foundation shall ensure auditor independence at all times.
Audit findings and any management responses shall be presented to the full Board and retained on record.
11. Prevention and Response to Financial Misconduct
The Foundation operates a strict zero-tolerance position on fraud, theft, bribery, corruption, and any form of financial misconduct. Financial misconduct includes misappropriation of funds, falsification of records or receipts, unauthorised transactions, accepting or offering bribes, and deliberate circumvention of financial controls.
Upon receipt of a report of suspected financial misconduct, the Board shall:
- Immediately secure relevant financial records
- Appoint an independent person to investigate the concern
- Suspend the implicated individual from financial responsibilities pending the outcome of the investigation
- Take appropriate disciplinary action based on the findings, up to and including termination and referral to the Nigerian Police Force or the Economic and Financial Crimes Commission (EFCC)
No person who reports a financial concern in good faith shall face any adverse consequence as a result. Retaliation against a person who raises a financial concern is itself a disciplinary offence.
12. Financial Conflicts of Interest
A conflict of interest arises when a person involved in financial decisions has a personal, financial, or family interest in the outcome of that decision. All trustees, staff, and volunteers must declare any potential conflict of interest before participating in any financial decision or procurement process in which they have a personal interest.
A person with a declared conflict of interest shall withdraw from the relevant decision-making process. The conflict and the withdrawal shall be recorded in the minutes or financial records. This requirement applies equally to all levels of the Foundation, including the founders and trustees.
13. Restricted and Designated Funds
Where the Foundation receives funds that are given for a specific purpose, those funds are restricted and must be used only for that stated purpose. Restricted funds shall be tracked separately in the Foundation's financial records to ensure they are not mixed with general operational funds.
Where it becomes apparent that a restricted fund cannot be used for its original purpose, the Foundation shall notify the donor and seek written agreement before redirecting the funds. Restricted funds must never be used to cover general operating costs without explicit donor consent.
14. Financial Arrangements for Volunteers
T.A.A.E Foundation operates with a team of unpaid volunteers who give their time and skills freely. The Foundation deeply values this contribution. The following financial arrangements apply to volunteers:
- Volunteers are not entitled to payment or remuneration for their time
- Volunteers who incur genuine out-of-pocket expenses directly related to Foundation activities may submit an expense claim for reimbursement, subject to the approval process set out in Section 7 of this policy
- Volunteers who voluntarily contribute personal funds to support a Foundation activity shall have those contributions acknowledged and recorded as voluntary income
- No volunteer shall be placed in a position of financial obligation to the Foundation
- Where a volunteer is entrusted with Foundation funds for a specific activity, the same cash handling controls set out in Section 6 apply in full
15. Policy Review and Monitoring
The Amaefule and Astudillo Empowerment Foundation (TAAE Foundation) to ensure its continued effectiveness, relevance, and compliance with applicable laws, regulations, and best practices in nonprofit financial management.
Foundation's operations, funding structure, regulatory environment, strategic direction, or identified financial risks.
implemented, monitored, communicated, and periodically updated. The Foundation's leadership shall ensure that appropriate financial controls, accountability measures, and reporting systems are consistently maintained across all programs and operations.
maintaining the highest standards of financial integrity, transparency, accountability, and responsible stewardship of resources entrusted to the organization.
16. Declaration and Adoption
This Financial Management Policy has been formally adopted by the Board of Trustees of The Amaefule and Astudillo Empowerment Foundation (TAAE Foundation).
The policy reflects the Foundation's commitment to sound financial governance, transparency, accountability, ethical management of resources, and compliance with applicable laws and regulations.
TAAE Foundation recognizes that responsible financial management is essential to fulfilling its mission of empowering Persons with Disabilities, strengthening communities, and creating sustainable opportunities for inclusion, independence, and development.
By adopting this policy, the Foundation affirms its commitment to ensuring that all financial resources are managed prudently, utilized effectively, and directed toward advancing the Foundation's vision of an inclusive society where Persons with Disabilities can thrive and reach their full potential.
Approved by: Board of Trustees