Introduction

Section 109 of the Gambling Act 2003 requires a corporate society that operates mainly to distribute net proceeds of class 4 gambling to the community to, at least annually, review the
criteria, methods, systems and policies it uses for consideration of applications for the distribution of net proceeds.

Distribution of Proceeds

The Redwood Trust will distribute 100% of the proceeds raised locally to the Marlborough regional community.

Grant Application Forms

Applications for grants will only be considered if they are submitted on the prescribed forms
provided by the Trust. Forms will be made available to the public upon request or via the Trust website.
Contact details for the Trust will be advertised by the following means:

• On grant application forms
• On notices displayed at each venue where gaming machines are operated
• On the internet website "www.redwoodtrust.org.nz."
• On posters and/or in letters made available to community organisations upon request

Application forms will contain criteria and guidelines to assist the applicants in completing the
form. The criteria and guidelines will contain, but not be limited to:

• Terms and Conditions
• Details of the Trusts authorised purposes
• Details of eligibility for funding (criteria)
• Check list

Grant Applications

The following documentation will be required for each application:

• A completed application form (including the organisations GST number if applicable), signed by two representatives of the organisation (confirming content of application and authorisation to audit.)
• Two quotes (unless a satisfactory explanation is supplied - specialised equipment, limited suppliers in the area.)
• A copy of the minutes resolution signed by the secretary of the organisation.
• A printed bank deposit slip or bank verified deposit slip.
• Evidence of affiliation to national body (where applicable - sports groups, brass bands,
  dancing, kindergartens and pre-schools (Ministry of Education.))

Grant applications will be accepted before the 15th of each month.

Attached Conditions

The Trust and key persons of the Trust will not knowingly receive or seek any benefit (financial or otherwise), advantage, privilege or gift from any grant recipient or potential grant recipient, if receipt of the benefit, advantage, privilege or gift is conditional upon the positive determination of a grant application.
For the purposes of this section, a key person includes any trustee or other officer of the Trust, or any person who performs that function and all persons in management positions.

Influencing Grants

No key person associated to a venue for which the Trust holds a current venue licence will:

• Provide application forms to prospective grant applicants.
• Be involved in decisions about, or in managing, grants applications received by the Trust.

For the purposes of this section, a key person includes all venue personnel, including the manager, operator and any person contracted to service gambling equipment at a venue. In cases where the venue operator is a company a key person also includes any director, chief executive, senior manager or other person who has significant interest in the management, ownership or operation of that company.

Processing

Trust Management will process grant applications and will ensure funding has been used appropriately and supporting documentation has been provided.

Screening

Each grant application will be screened to determine whether the application form has been completed correctly and that all supporting documentation has been provided. Checks to ensure that accountability for any previous grants made to the applicant will also be conducted. Where the application form is completed incorrectly (for example those that have not been signed) will be returned to the applicant with a covering letter describing what remedial action should be taken before the application is resubmitted. Where the application form is completed correctly but all supporting documentation has not been included, the application will be returned to the applicant.

Grants that do not meet AP or are outside the Marlborough area will be declined during the screening process. A standard preformatted letter explaining the reason for the decision will be forwarded to the applicant, together with all documentation accompanying the application. A copy of the letter of decline will be retained and filed.

Verification

Once all applications received for a grant period have been screened, the Trust Management will begin working through the applications, verifying that they are entirely correct, complete, and meet the relevant criteria and also checking for validity. All applications that are not entirely correct, complete, valid, and meet all relevant criteria will be declined unless corrective action can be taken by the applicant. If anomalies regarding completeness are discovered at this point, remedial action will be taken as required e.g. applications returned for completion, or further documentation requested. Each application will be checked to verify the described purposes of the grant meets all relevant criteria. Checks will be conducted to ascertain whether the grant will provide any personal or commercial benefit to the applicant or anyone closely associated to them e.g. a quote provided by a committee member or other member of the applicant organisation.

More applications will be declined during this stage of processing. A standard preformatted letter explaining the reason the decision will be forwarded to the applicant, together with all documentation accompanying the application.

A copy of the letter of decline will be retained and filed.

Some applications will be withdrawn from processing, either at the applicant's request or because the applicant has failed to provide all required documentation. Withdrawn applications will be treated as declined applications.

Grant applicants may amend details of submitted applications, e.g. providing revised quotes etc. All alterations must be supported by appropriate documentation. The purpose of the application can only be altered if the revised purpose falls within the realms of the purpose stated in the associated meeting minutes, unless a copy of minutes from a subsequent meeting is provided, which stipulate the revised purpose.

Determination

Only trustees can make a determination regarding the outcome of a complete and valid grant application. Grant applications that do not meet the listed criteria (other than being an unauthorised, or retrospective, purpose) may be approved, but only by a quorum of the Board of Trustees. The Trust Management will review all applications forwarded for a determination to be made and verify the applications have been fully processed. The persons verifying any grant will satisfy themselves that the purpose of the funding falls within a category of the societies authorised purposes.

Grants cannot be granted in relation to expenses that have already been incurred (retrospective.)

Grant applications can only be approved on the basis that the required net proceeds are available at the time the application is considered. Grants must not be "promissory." A commitment cannot be made to provide funding for a purpose on the assumption that commitment will be satisfied by net proceeds received at a future time.

Grants for large amounts of funding may be provided by way of installment for the purpose of maintaining control regarding the appropriate use of the funds. In such cases the recipient will be required to supply satisfactory evidence that previous funding installments have been used appropriately, before further funding will be provided.

Grants cannot be directly beneficial to any employee or Trustee of the society, any site operator, gaming machine contractor or representative or any person closely associated to those persons.

Payment

Funding for all approved grant applications will be provided by way of direct credit, deposited
directly into the recipient's nominated bank account.

The schedule of payments and accompanying reports will be retained and filed. The Trust Management will conduct random audits of the reports to ensure the funds have been distributed appropriately.

Audit

An audit of all grants will be undertaken to ensure funds have been used appropriately. The following matters will be satisfied:

• The expenditure was consistent with the purpose stated in the original application.
• Payment was made directly to the suppliers of goods and services as per quotes accompanying the application form. (This requirement ensures a clear audit trail.)

The return of funds will be requested in the following instances:

• The funds have not been used, or partly used (as above) within 6 months of receipt.
• A surplus of funds exists after the expenses relating to the grant purpose, have been met.
• The funds have been used for an unauthorised purpose, or a purpose other than that specified in the original application.
• The funds have been used to reimburse money spent prior to the grant being approved.
• Funds have been provided from more than one source for the same purpose and no disclosure was made regarding the other application/s.
• The recipient has failed to provide adequate evidence of how the funds were used.
• The funds have been obtained or used in breach or any rule or regulation, or contrary to this policy.

A suite of preformatted letters will be used to communicate with grant recipients. The letter informing applicants that their grant has been approved will include a request for the recipient to provide documentary evidence (original receipts etc.) that the funds are used in accordance with the purpose stated in the grant application. If evidence confirming the funds were used appropriately, is not received within the seventh month of the funds being deposited into the recipients bank account, and no explanation has been provided for the lack of response, a second letter will be sent to the recipient reminding them that the information is required.

If no response to the second letter is received from the recipient within the following month, a
third letter will be sent requesting the funds to be returned. If the funds are not received within 14 days a further letter will be sent to the recipient advising that action will be initiated to recover the funds.

Errors/Omissions

If an applicant fails to disclose the fact they have submitted grant applications to other societies for the same purpose, the application will be declined and no further applications will be accepted from the requesting organisation for a period of six months. Where appropriate, the Department of Internal Affairs will be advised of the matter.

If a grant recipient fails to provide adequate proof that funds were applied in accordance with the grant application, no further grant applications will be considered from that recipient unless the funds have been repaid to the Trust.

Internal Conflict of Interest

Where any staff member of the Trust has an association with a grant applicant they must notify the Trust Management of that association in writing. A copy of the notification will be retained on file. Where any conflict of interest exists, the staff member concerned will not have any involvement in the processing or determination of the application.

Publishing

• The Trust Management will arrange to publish the following information in a national newspaper at intervals no greater than 3 months:
• The availability of net proceeds for authorised purposes.
• Details of where to obtain a funding application form.
• The criteria against which applications will be considered (as listed above).
• The names of persons who hold office in the Trust and a brief summary of their background.
• The process followed by the Trust in dealing with complaints regarding grant applications.
• Details of all grant applications received including whether each was accepted or declined.
• The amount of funds granted, if any, in each case.
• The results of the Trusts annual review of the criteria, methods, systems and policies it uses for considering the distribution of funds. (With the exception of the notice published immediately following the annual review of this policy, this will be a standard clause stating that no changes have been made to the policy.)

The newspaper in which the publication will be made will meet any criteria prescribed by regulation made under section 114 of the Act.

Complaints

Complaints will only be accepted in written format. All complaints received will be forwarded to the Trust Management.

The Trust Management will investigate the complaint and make a determination regarding the validity of the complaint. The complainant will be notified of the determination and if applicable any action that has or will be taken to rectify the matter. The complainant will also be advised of their right to refer the complaint to the Department of Internal Affairs if they are not satisfied with the action taken or the result of any investigation conducted by the Trust.

Annual Review

This policy will be reviewed at least annually.
As at the last annual review there were no changes required to the Grant Policy.