Annual Reports Policy

1Purpose

Shepherds Only Foundation (“SOF” or “the Foundation”) is committed to faithful stewardship, transparency, accountability and responsible administration of all resources entrusted to it.

The purpose of this Annual Reports Policy is to establish the principles, responsibilities, minimum reporting standards, approval procedures and publication requirements governing the Foundation’s annual reporting.

The Foundation shall use its annual report as a principal instrument of accountability to its beneficiaries, donors, partners, regulators, churches, ministers, stakeholders and the wider public.

Annual reporting shall provide a fair, balanced and understandable account of the Foundation’s activities, governance, financial stewardship, achievements, challenges and use of resources during the relevant reporting period.

The Foundation shall not use an annual report merely as a promotional publication. It shall be an accountability document intended to provide meaningful information concerning what the Foundation received, what it did, how resources were applied, what outcomes were achieved and how the organisation was governed.

3Scope

This Policy applies to Shepherds Only Foundation and, to the extent applicable, its:

• Board of Directors or Trustees;
• officers;
• employees;
• volunteers;
• committees;
• programmes;
• projects;
• funds;
• endowment arrangements;
• branches or offices;
• controlled entities; and
• persons responsible for preparing, reviewing, approving or supplying information for annual reports.

Where the Foundation establishes legally distinct trusts, endowment vehicles, subsidiaries, affiliates or other entities, the reporting obligations applicable to those entities shall be determined by their governing documents and applicable law.

The Foundation may nevertheless include appropriate consolidated or supplementary information concerning such entities where necessary to provide stakeholders with a fair understanding of the Foundation’s overall activities and stewardship.

4Legal and Regulatory Compliance

The Foundation shall prepare, approve, submit and publish reports in accordance with all applicable laws, regulations, regulatory directives, accounting standards, its Constitution and other governing instruments.

Where applicable, this includes compliance with requirements imposed by the:

• Office of the Registrar of Companies;
• Non-Profit Organisation Secretariat;
• Ghana Revenue Authority;
• applicable accounting and auditing standards;
• contractual requirements of institutional donors and grant-makers; and
• any other competent regulatory authority.

Nothing in this Policy shall reduce, replace or override a reporting obligation imposed by law, regulation, contract, grant agreement, governing instrument or regulatory authority.

Where a legal or regulatory requirement imposes a higher reporting standard than this Policy, the higher standard shall prevail.

5Reporting Period

The Foundation shall prepare an annual report for each financial year.

The annual report shall clearly identify:

• the reporting period;
• the date of publication;
• the entity or entities covered by the report; and
• where relevant, any material change in the Foundation’s financial year or reporting basis.

The Board shall establish an annual reporting timetable that provides sufficient time for year-end financial close, programme reporting, audit or independent review where applicable, Board review, approval, regulatory submission and public publication.

6Annual Reporting Principles

The preparation of every annual report shall be governed by the following principles.

7Minimum Content of the Annual Report

Subject to applicable legal requirements and proportionality, the Foundation’s annual report should ordinarily contain the following sections.

7.1  Identity and Mission

The report should state:

• the Foundation’s legal name;
• relevant registration information;
• registered or principal office;
• mission;
• charitable objects;
• principal areas of operation; and
• reporting period.

7.2  Leadership Statement

The annual report may contain a statement from the Chairperson, Executive Director, President or other authorised leader addressing significant developments during the reporting period.

Such statements remain subject to the accuracy and integrity requirements of this Policy.

7.3  Governance

The report should provide appropriate information concerning the Foundation’s governance structure, including where applicable:

• Board composition;
• appointment or departure of Board members;
• principal Board committees;
• governance responsibilities;
• material governance changes;
• Board oversight arrangements; and
• significant governance developments during the year.

7.4  Activities and Programmes

The report should describe the Foundation’s principal activities during the reporting period, including programmes undertaken to advance its charitable purposes.

This may include support provided to persons called into Christian ministry, including those serving within the five-fold ministry, and other activities falling within the Foundation’s lawful charitable objects.

7.5  Beneficiary Support

Where appropriate, the Foundation should report aggregate information concerning assistance provided, including:

• number of beneficiaries supported;
• categories of support;
• geographical distribution;
• duration or frequency of assistance;
• amounts disbursed;
• programme reach; and
• other relevant indicators.

Beneficiary reporting shall remain subject to the privacy, dignity and safeguarding provisions of this Policy.

7.6  Financial Information

The annual report should provide a meaningful account of the Foundation’s financial stewardship.

Depending upon the applicable reporting requirements, this may include:

• total income;
• donations and grants received;
• investment income;
• programme expenditure;
• administrative expenditure;
• fundraising expenditure;
• support disbursements;
• assets;
• liabilities;
• reserves;
• restricted funds;
• designated funds;
• endowment assets;
• investment holdings;
• material commitments; and
• other significant financial information.

Financial information included in the annual report shall be reconciled, where appropriate, with the Foundation’s approved financial statements.

7.7  Endowment and Investment Stewardship

Where the Foundation maintains an endowment or material investment portfolio, the annual report should provide appropriate information regarding its stewardship.

This may include:

• opening value;
• contributions;
• investment income;
• realised and unrealised gains or losses where appropriate;
• withdrawals or distributions;
• closing value;
• broad asset allocation;
• investment objectives;
• applicable spending policy; and
• material developments affecting the fund.

The Foundation shall not describe investment performance in a misleading manner or selectively present information designed to obscure losses, volatility or material risks.

7.8  Restricted and Designated Funds

Where donations or grants are subject to donor restrictions or Board designations, the annual report should provide sufficient information to demonstrate responsible stewardship of those funds.

Restricted funds shall not knowingly be represented as unrestricted resources.

7.9  Impact and Outcomes

The Foundation should report not only activities undertaken but, where reasonably measurable, the results or outcomes associated with those activities.

Impact claims shall be proportionate to the available evidence.

The Foundation shall distinguish appropriately between:

• activities;
• outputs;
• outcomes;
• longer-term impact; and
• aspirations or projections.

Correlation shall not knowingly be represented as causation where the available evidence does not reasonably support such a conclusion.

7.10  Risks and Challenges

Where appropriate, the annual report should acknowledge material risks or challenges affecting the Foundation, its beneficiaries, programmes, financial sustainability or operations.

The disclosure of risks shall be balanced against legitimate confidentiality, security, safeguarding and legal considerations.

7.11  Future Priorities

The Foundation may describe priorities for the next reporting period.

Forward-looking statements shall be identified appropriately and shall not constitute guarantees of future results.

8Audited Financial Statements

Where required by applicable law, regulation, the Foundation’s governing documents, donor conditions or Board policy, the Foundation shall obtain an independent audit of its annual financial statements.

The annual report shall accurately state whether the financial statements have been audited.

The Foundation shall never describe accounts as “audited” unless an audit has actually been completed by a properly qualified and independent auditor in accordance with applicable professional requirements.

Where audited financial statements are published separately from the annual report, the annual report may provide an appropriate reference to them.

Nothing in a narrative annual report shall supersede, amend or replace the Foundation’s statutory financial statements or independent auditor’s report.

9Donations and Funding

The Foundation shall report donations and funding in a manner that promotes transparency while respecting lawful confidentiality.

Aggregate reporting may distinguish between:

• individual donations;
• institutional donations;
• grants;
• corporate support;
• church or ministry contributions;
• investment income;
• endowment contributions;
• gifts in kind; and
• other material sources of income.

The identity of an individual donor shall not automatically be publicly disclosed.

Donor identities may be disclosed where:

• the donor has consented;
• disclosure is required by law;
• disclosure is required by a regulator or competent authority;
• disclosure is required under the terms of a grant or agreement; or
• the Board determines that disclosure is lawful and appropriate.

Anonymous donations shall be handled in accordance with applicable law, anti-money laundering requirements, the Foundation’s internal policies and appropriate due diligence procedures.

10Beneficiary Privacy and Dignity

The Foundation’s commitment to transparency shall not override the dignity, safety or legitimate privacy interests of beneficiaries.

The Foundation shall exercise particular care when publishing information about ministers, families, children, vulnerable persons, persons experiencing financial hardship, illness or other sensitive circumstances.

Except where lawful and appropriately authorised, annual reports should use aggregated or anonymised information where individual identification is unnecessary.

A beneficiary’s photograph, testimony, name, personal history or identifiable case study shall not be published merely because that person received assistance.

Appropriate consent shall be obtained where required.

Consent shall, as far as reasonably practicable, be informed and voluntary and shall not be made an improper condition of receiving charitable assistance.

The Foundation shall not exploit hardship, vulnerability, illness, bereavement, poverty or personal circumstances for publicity or fundraising.

11Testimonials and Beneficiary Stories

Beneficiary stories may be included where they advance legitimate accountability, educational or communication purposes.

Such stories must:

• be substantially accurate;
• respect the dignity of the individual concerned;
• not materially exaggerate the Foundation’s role;
• not fabricate quotations or experiences;
• comply with applicable consent requirements;
• protect children and vulnerable persons; and
• avoid unnecessary disclosure of sensitive personal information.

Names may be changed, identifying details withheld or stories anonymised where appropriate. Where material facts have been altered to protect identity, the Foundation should not present the altered details as literal facts where doing so would materially mislead readers.

12Related-Party Transactions and Conflicts of Interest

Material related-party transactions shall be accounted for and disclosed to the extent required by applicable law, accounting standards or the Foundation’s governance policies.

Annual reporting shall not be structured to conceal a material financial relationship between the Foundation and a director, trustee, officer, senior employee, substantial donor, connected person or related entity.

All such matters remain subject to the Foundation’s Conflict of Interest Policy and applicable law.

13Grants and Support Disbursements

The Foundation shall maintain adequate records supporting grants, assistance and other programme disbursements.

Annual reporting may aggregate disbursements according to:

• programme;
• beneficiary category;
• purpose;
• geographic location;
• funding source;
• restricted fund; or
• other appropriate classification.

Publication of aggregate information does not remove the Foundation’s obligation to maintain sufficiently detailed internal records supporting individual transactions.

14Fundraising Costs and Administrative Expenditure

The Foundation shall not manipulate expenditure classifications for the purpose of artificially reducing reported administrative or fundraising costs.

Costs shall be classified according to applicable accounting principles and the Foundation’s approved accounting policies.

Where expenditure serves more than one function, allocation methodologies should be reasonable, consistently applied and capable of explanation.

15Preparation of the Annual Report

Management shall coordinate preparation of the annual report under the supervision of the Board or an authorised Board committee.

Relevant departments and responsible persons shall provide accurate information within the established reporting timetable.

The Finance function shall verify financial information.

Programme personnel shall verify programme statistics and impact information.

The Company Secretary or appropriate governance officer shall verify material governance information.

Management shall establish appropriate internal review procedures before presenting the report to the Board.

16Board Oversight and Approval

Ultimate responsibility for oversight of the Foundation’s annual reporting rests with the Board.

Before approving the annual report, the Board should satisfy itself, to the extent reasonably practicable, that the report:

• fairly represents the Foundation’s activities;
• is consistent with approved financial information;
• contains no known material misstatement;
• appropriately addresses material matters;
• complies with applicable reporting requirements; and
• protects information that should lawfully remain confidential.

The annual report shall not be represented as an approved report of Shepherds Only Foundation until the required approval has been obtained.

Board approval shall be documented in the minutes or resolutions of the Board.

17Independence of the Auditor

Where an external auditor is appointed, the Foundation shall seek to preserve the auditor’s independence and professional judgment.

No director, trustee, officer, employee, donor or other person shall improperly pressure an auditor to:

• alter an audit conclusion;
• suppress a material finding;
• disregard evidence;
• mischaracterise a transaction; or
• issue an opinion inconsistent with the auditor’s professional judgment.

Any attempt to improperly influence an audit shall be treated as a serious governance matter.

18Publication

Following approval and completion of applicable regulatory requirements, the Foundation should make its annual report reasonably accessible to the public.

Publication may include:

• the Foundation’s official website;
• a downloadable digital report;
• an annual reports archive; or
• another appropriate public medium.

Where feasible, previous annual reports should remain accessible so that stakeholders can evaluate the Foundation’s activities and stewardship over time.

Publication shall be subject to lawful confidentiality, privacy, security and safeguarding considerations.

19Regulatory Submission

Public publication does not replace statutory or regulatory filing.

The Foundation shall separately ensure that annual reports, annual returns, financial statements, audited accounts, tax documents, beneficial ownership information and other required filings are submitted to the relevant authorities within applicable deadlines.

Responsibility for maintaining a regulatory compliance calendar shall be assigned by the Board or management.

20Material Errors and Corrections

The Foundation recognises that transparency includes correcting material errors.

Where a material error is discovered after publication, management shall promptly assess:

• the nature of the error;
• its financial or operational significance;
• whether regulators, auditors, donors or other parties must be informed;
• whether the published report should be corrected or replaced; and
• whether additional internal controls are required.

Material corrections shall be authorised at an appropriate level.

Where a corrected report is published, it should clearly identify that it is a corrected or revised version and state the date of revision.

The Foundation shall not silently alter material historical information in a manner that could mislead readers.

21Fraud, Misrepresentation and Concealment

No person involved in the Foundation’s annual reporting shall knowingly:

• falsify financial or programme information;
• fabricate beneficiaries or activities;
• inflate beneficiary numbers;
• duplicate programme outcomes;
• conceal material expenditure;
• misstate restricted funds;
• alter supporting documentation improperly;
• conceal material related-party transactions;
• provide false information to auditors;
• suppress material audit findings;
• fabricate testimonials; or
• knowingly cause the Foundation to publish materially misleading information.

Suspected misconduct shall be addressed under the Foundation’s Whistleblower Policy, Code of Ethics, fraud-control procedures and other applicable policies.

22Confidential and Legally Privileged Information

Transparency does not require publication of every record held by the Foundation.

Information may appropriately be withheld or redacted where disclosure would:

• breach applicable law;
• violate legitimate privacy rights;
• compromise safeguarding;
• expose a beneficiary to danger;
• breach lawful donor confidentiality;
• reveal protected personal data;
• prejudice legal proceedings;
• disclose legally privileged communications;
• compromise cybersecurity or physical security;
• disclose confidential employment matters; or
• otherwise materially prejudice the legitimate interests of the Foundation or persons it serves.

The Foundation shall not misuse confidentiality as a means of concealing wrongdoing, conflicts of interest or information that it is legally required to disclose.

23Record Retention

The Foundation shall maintain appropriate supporting records for its annual reports in accordance with applicable law and its Records Retention Policy.

Supporting records may include:

• financial ledgers;
• bank and investment records;
• receipts and invoices;
• grant records;
• beneficiary-support records;
• monitoring and evaluation records;
• Board resolutions and minutes;
• contracts;
• audit documentation;
• donor records;
• consent records;
• programme reports; and
• source data supporting material statistics.

Records shall be retained securely and made available to authorised auditors, regulators or other persons where legally required.

24Accessibility

The Foundation shall seek to make public annual reports reasonably accessible.

Where resources permit, reports should:

• be mobile accessible;
• use readable formatting;
• be downloadable;
• use understandable language;
• include appropriate descriptions for charts and material visual information; and
• avoid unnecessary technical complexity.

Financial transparency should be presented in a manner that assists rather than obstructs public understanding.

25Comparability and Historical Reporting

Where reasonably practicable, annual reports should include comparative information from prior periods for significant financial and programme indicators.

The Foundation shall not change definitions or measurement methods merely to produce more favourable reported results.

Where material definitions, accounting treatments or measurement methodologies change, the report should explain the change where necessary to avoid misleading comparisons.

26Reporting of Significant Events

Where a significant event occurring after the end of the reporting period materially affects the interpretation of the annual report, the Foundation shall consider whether disclosure is required by applicable accounting standards, law or good governance practice.

Material events may include significant changes in governance, major commitments, litigation, loss of material funding, significant asset impairment, fraud investigations or events materially affecting the Foundation’s ability to continue its programmes.

Disclosure shall be determined with appropriate professional advice where necessary.

27Responsibility Matrix

Responsibility for annual reporting shall ordinarily be allocated as follows:

28No Retaliation for Good-Faith Reporting

No director, trustee, officer, employee, volunteer or other person acting for the Foundation shall suffer retaliation for raising, in good faith, a legitimate concern about the accuracy, completeness or integrity of an annual report.

Concerns may be raised under the Foundation’s Whistleblower Policy or other applicable reporting mechanism.

Knowingly false or malicious allegations are not protected as good-faith reporting.

29Relationship With Other Foundation Policies

This Policy should be read together with the Foundation’s:

• Constitution and governing instruments;
• Code of Ethics;
• Conflict of Interest Policy;
• Whistleblower Policy;
• Non-Discrimination Policy;
• Safeguarding Policy;
• Financial Management Policy;
• Investment Policy;
• Donation Acceptance Policy;
• Data Protection and Privacy Policy;
• Records Retention Policy;
• Anti-Fraud and Anti-Corruption Policy; and
• other applicable governance policies.

Where policies appear inconsistent, the Board shall determine the appropriate interpretation subject always to applicable law.

30Non-Compliance

Failure to comply with this Policy may expose the Foundation to regulatory, financial, legal and reputational consequences.

A director, officer, employee, volunteer or other person who deliberately falsifies, conceals or materially misrepresents information used in an annual report may be subject to appropriate disciplinary or governance action, without prejudice to any reporting obligation or liability arising under applicable law.

31Policy Review

The Board shall review this Policy periodically and whenever there is a material change in:

• applicable law;
• regulatory requirements;
• accounting or auditing standards;
• the Foundation’s organisational structure;
• its financial or investment arrangements; or
• recognised governance practice.

Amendments require approval by the Board unless authority has lawfully been delegated.

32Interpretation

For purposes of this Policy, “Board” means the governing body legally responsible for Shepherds Only Foundation, whether described in the Foundation’s final legal structure as the Board of Directors, Board of Trustees, Executive Council or another legally recognised governing body.

“Annual Report” means the Foundation’s annual narrative, operational, governance and financial accountability report and does not, unless expressly stated, replace any statutory annual return, audited financial statement, directors’ report, auditor’s report or regulatory filing.

“Foundation” means Shepherds Only Foundation and, where the context requires, any organisational unit falling within the scope of this Policy.