Grant-Making Policy

Adopted by the charity trustees on 12 May 2026  |  Version 1.0  |  Review date: May 2027

1. Purpose and status

This policy is adopted by the charity trustees of The Association for Clinical Artificial Intelligence (‘AfCAI’, ‘the Charity’) to govern all grant-making activity. It is written to comply with Charity Commission guidance, in particular: Grant funding from a charity; Internal financial controls for charities (CC8); Conflicts of interest: a guide for charity trustees (CC29); the Compliance Toolkit (Chapter 2: Due diligence, monitoring and verifying the end use of charitable funds); and Equality Act guidance for charities.

Grant-making is a means by which the Charity carries out its charitable objects; it is not itself a charitable purpose. Every grant must directly further at least one of the Charity’s objects and produce identifiable public benefit. No grant may confer more than incidental personal benefit on any trustee, member, employee, founder or connected person.

This policy applies to all grants and grant-equivalent financial support, including educational bursaries and prizes, research grants, project grants, and capacity-building grants, made to either individuals or organisations.

2. Charitable objects

Grants must be capable of being mapped to one or more of the following objects (clause 3 of the constitution):

• Object 1: to protect, preserve and advance the health of patients and to save lives, for the public benefit, in particular by promoting the safe, ethical, equitable and effective development, evaluation, regulation and clinical application of clinical artificial intelligence;
• Object 2: to advance the education of the public, for the public benefit, in the subject of clinical artificial intelligence;
• Object 3: to advance science, for the public benefit, by promoting and supporting research into clinical artificial intelligence, by disseminating the useful results of such research, and by developing and publishing standards, evidence and good practice.

The Grants Sub-Committee shall record, on every grant award, the object(s) furthered and a brief explanation of the expected public benefit.

3. Funding categories and indicative budgets

In its first three years the Charity will operate the following grant streams. Trustees shall confirm a budget envelope for each stream at the start of each financial year, having regard to the reserves policy and forecast income.

All values are indicative. Trustees may set or amend specific funding envelopes by resolution.

4. Eligibility

4.1 Eligible recipients

Grants may be made to:

• individuals (including clinicians, students, allied health professionals, researchers, patients and carers) aged 18 or over, eligible to receive funding under UK and applicable law;
• UK-registered charities;
• UK higher-education institutions and NHS bodies;
• not-for-profit organisations and incorporated bodies whose proposed activity is itself charitable in nature; and
• for-profit organisations only exceptionally, where trustees are satisfied that (a) the funded activity is exclusively charitable, (b) funding is restricted by a written grant agreement, and (c) appropriate due diligence has been completed.

Grants to non-charitable organisations will be made strictly in accordance with Charity Commission guidance Grant funding an organisation that isn’t a charity, including a written grant agreement, restricted use of funds, and post-grant monitoring and reporting.

4.2 Ineligible recipients and uses

The Charity will not make grants:

• to any organisation or individual not meeting the eligibility criteria;
• for activity not exclusively for charitable purposes within the Charity’s objects;
• for political campaigning, party-political activity, or activity incompatible with Commission guidance CC9;
• for retrospective funding of activity already completed, except where expressly approved by trustees with written reasons recorded in the minutes;
• to any trustee, founder, employee or connected person, save where (i) such person is a beneficiary of an open call on the same terms as the public, (ii) a majority of trustees do not benefit, and (iii) the conflicts procedure in section 9 has been followed; or
• where due-diligence checks (section 8) have not been satisfactorily completed.

5. Application process

5.1 How applications are invited

Calls for applications are published on the Charity’s website and are open to the public. The Charity will normally run timed funding rounds with published opening and closing dates, eligibility criteria, application form, scoring rubric and word limits. The Grants Sub-Committee may also operate a rolling-application stream for small bursaries.

All calls will state plainly: who is eligible; the maximum grant size; what will and will not be funded; the assessment criteria; the timeline; the conflicts-of-interest rules; and the data-protection treatment of applications.

5.2 What an application must contain

Every grant application shall contain at minimum:

• the applicant’s identity and contact details (and, for organisations, registration details, governing document, accounts where available, and details of senior officers);
• a clear statement of the proposed activity and how it furthers each relevant object;
• a clear statement of the public benefit expected, the intended beneficiaries, and how dissemination will reach them;
• a budget showing how the grant will be used, with separate identification of staff time, consumables, dissemination, overheads (capped at 10% of direct costs save with trustee resolution) and any co-funding;
• a delivery plan with key milestones and outputs;
• a statement of any actual or potential conflict of interest (see section 9);
• a statement of any safeguarding considerations (see section 11);
• a declaration that the applicant is not subject to disqualification, sanctions, or other matters the trustees ought reasonably to know; and
• for individuals, evidence of identity and (where applicable) right to work or study in the UK.

6. Decision-making

6.1 Who decides

Grant decisions are reserved to the charity trustees. The trustees have established a Grants Sub-Committee (‘Sub-Committee’) to which they have delegated the assessment of applications and recommendations on award. The Sub-Committee must include at least one charity trustee, and may include external assessors selected for their independence and subject-matter expertise.

Recommendations are presented to the full trustees, who take the decision to award (or not). Decisions — including the scoring, public-benefit rationale, any conflicts declared and managed, and any conditions attached — are recorded in the minutes.

6.2 Assessment criteria and scoring

All applications are scored using the Charity’s published scoring rubric, which is appended to every call. The rubric scores each application on three domains on a 1–5 scale (total 3–15):

Domain	Description	Score
Alignment with Charitable Objectives	Relevance to healthcare improvement, alignment with charitable priorities, ethical and societal implications	1–5
Demonstrable Public Benefit	Clarity and scale of anticipated benefit, target populations, feasibility of implementation, dissemination plans	1–5
Contribution to New Knowledge	Novelty, methodological rigour, contribution beyond existing literature, potential to inform practice or policy	1–5

The recommended threshold for funding is 11/15. Priority is given to applications scoring 13+ or addressing health inequalities. Every recommendation must also address: feasibility of delivery; value for money; safeguarding; equality, diversity and inclusion; and conflicts of interest.

Trustees retain discretion to award, decline, or partially fund any application, and to attach conditions. Where trustees depart from the Sub-Committee’s recommendation, written reasons shall be recorded in the minutes.

6.3 Confidentiality and feedback

Application material is treated as confidential and processed in accordance with UK data protection law. Unsuccessful applicants will be told the outcome and offered a brief summary of reasons. The Charity does not operate a formal appeals mechanism but will reconsider a decision on written request where the applicant identifies a procedural error.

7. Grant agreements and payment

Every successful grant is documented in writing. For individual bursaries and prizes, a signed award letter is sufficient. For project and research grants, a written grant agreement is required. Both forms must include:

• the amount, payment schedule and method (BACS only; no cash payments);
• the specific charitable purpose for which funds may be used, and an express prohibition on any other use;
• the period of the grant;
• reporting requirements (see section 10) including a final report;
• a duty to notify the Charity promptly of any material change of circumstance, safeguarding incident, fraud or reputational matter;
• acknowledgement of AfCAI’s funding in any output;
• data-protection, intellectual property and (where relevant) open-access obligations;
• the consequences of misuse, including suspension, withdrawal and clawback;
• a duty to comply with all applicable law including safeguarding and equalities obligations; and
• the governing law and forum (England and Wales).

Payments are made only against signed agreements and only to the recipient’s verified bank account. For larger grants, payments are tranched against milestones. All payments require dual authorisation by an authorised trustee and the Treasurer in accordance with CC8.

8. Due diligence

Before any grant is awarded, the Charity carries out due diligence proportionate to the size and risk of the grant.

8.1 All recipients

• verification of identity (photo ID and proof of address for individuals; Companies House / Charity Register entry for organisations);
• confirmation that the proposed activity is consistent with the Charity’s objects and produces identifiable public benefit;
• checks against the UK Sanctions List, the Charity Commission Register of Removed Trustees, and relevant disqualification registers;
• a Google / open-source check for adverse media or reputational risk;
• confirmation that the recipient is not connected with any trustee or staff member, or that the conflicts procedure has been followed where there is a connection;
• confirmation that the recipient understands and accepts the grant agreement terms.

8.2 Organisations — additional checks

• most recent annual report and accounts;
• governing document or articles of association;
• safeguarding policy (where work involves children or adults at risk);
• evidence of proportionate insurance;
• track record of similar work, including referees where appropriate.

8.3 Higher-risk grants

Higher-risk grants — including grants over £10,000, grants to newly-formed organisations, grants to non-charities, grants involving vulnerable beneficiaries, or grants with any cross-border element — attract enhanced due diligence. Records of all due-diligence steps and outcomes are retained for at least six years.

9. Conflicts of interest and loyalty

The Charity follows the CC29 five-step approach: identify, declare, remove, manage, record.

1. A standing agenda item at every Sub-Committee and trustee meeting is the declaration of any actual or potential conflict of interest or loyalty with respect to any item being considered.
2. Each trustee and external assessor maintains a register of interests, reviewed annually and updated immediately on any change.
3. Where a trustee or assessor declares a conflict in respect of an application, they must withdraw from any discussion of and decision on that application, are not counted in the quorum, and will not be given access to the application material.
4. In no circumstances may a trustee, founder, employee, or connected person receive a grant other than as a beneficiary of an open call on the same terms as the public, with the conflicts procedure followed and a majority of trustees not benefiting.
5. Every conflict declared, how it was managed, and the outcome are recorded in the minutes.

10. Monitoring and impact reporting

10.1 During the grant

• for grants of £5,000 or more, an interim progress report is required at the mid-point of the grant period;
• for all grants, the recipient must notify the Charity within 14 days of any material change of circumstance, safeguarding incident, fraud, or reputational matter;
• the Charity may request additional information at any time, and may carry out a site visit or independent review for higher-value or higher-risk grants;
• payment of subsequent tranches is conditional on trustees being satisfied with progress.

10.2 End of grant

Within three months of the end of the grant period, every recipient must submit a final report setting out:

• the activity actually undertaken, with reference to the original plan;
• the outputs and beneficiaries reached;
• a financial reconciliation showing how the grant was spent (with receipts or invoices available on request);
• a statement of the public benefit produced, with evidence;
• any unspent funds, which must be returned to the Charity unless trustees agree in writing that they may be retained for an in-scope purpose;
• any safeguarding incidents, complaints or significant variations from plan; and
• any learning the Charity may share with future applicants.

10.3 Aggregate impact reporting

Trustees shall include in the Charity’s Trustees’ Annual Report a section on grant-making, summarising the number, value and types of grants made; the public benefit produced; lessons learned; and any matters that should be brought to the Commission’s attention as a serious incident.

11. Equality, safeguarding and other duties

11.1 Equality and inclusion

Grant-making is treated as the provision of a service for the purposes of the Equality Act 2010. Eligibility criteria, scoring rubrics and decision processes are reviewed annually for risk of indirect discrimination, with deliberate steps taken to address known barriers to participation in clinical AI for under-represented groups.

11.2 Safeguarding

Where any grant involves work with children or adults at risk, the Charity will require the recipient to have and follow a written safeguarding policy proportionate to the activity, ensure relevant staff have appropriate vetting (including DBS where required), and report any safeguarding concern to the Charity at the earliest opportunity. Trustees will report serious incidents to the Charity Commission.

11.3 Data protection

All personal data submitted in or relating to a grant application is processed in accordance with UK GDPR and the Data Protection Act 2018. Application material is retained only for as long as necessary for assessment, monitoring and audit, and in any event for not less than six years from the end of the grant.

11.4 Fraud, financial crime and counter-terrorism

The Charity follows CC8 internal financial controls. All payments are by BACS to a verified account; cash and cryptoasset payments are prohibited. Recipients are screened against the UK Sanctions List before payment. Any suspicion of fraud, terrorist financing or other financial crime is reported to the National Crime Agency and to the Charity Commission as required.

12. Misuse, suspension, withdrawal and clawback

If the trustees have reasonable grounds to believe that a grant has been or is likely to be misused, that material information was withheld at application, that the recipient has materially breached the grant agreement, or that continuing payment would not be in the best interests of the Charity, the trustees may:

• suspend further payments and require an explanation;
• vary the terms of the grant;
• withdraw the grant; and/or
• require repayment of any sum not properly applied to the agreed charitable purpose.

The grant agreement contains an express right of clawback for these purposes. Where appropriate, trustees will report a serious incident to the Charity Commission.

13. Records and review

Records of every grant — including the application, scoring, due-diligence checks, signed agreement, payments made, monitoring reports and final evaluation — are retained for at least six years from the end of the grant. Trustees review this policy at least annually, and on any material change in Charity Commission guidance or in the Charity’s circumstances.

Appendix A — Scoring Rubric

The scoring rubric is published as a separate document and incorporated by reference. It scores each application across three domains, each on a 1–5 scale (total 3–15). The recommended funding threshold is 11/15; priority funding is available for applications scoring 13–15, particularly those addressing health inequalities or with strong implementation potential.

Appendix B — Conflicts of Interest Declaration (template)

To be completed by every trustee, Sub-Committee member, external assessor and applicant in respect of every funding round:

• Name; role; date.
• Do you have any actual or potential personal, financial, professional, employment or institutional connection with the applicant or any co-applicant? If yes, describe.
• Do you have any other interest, however apparently remote, that a reasonable observer might consider could influence your judgement on this application? If yes, describe.
• Signature; date.

This policy was adopted by resolution of the charity trustees of The Association for Clinical Artificial Intelligence on 12 May 2026. It will be reviewed not later than 12 months from that date.  |  Version 1.0