Sandton MEals on Wheels
Organizational Admin
In order to run our branch smoothly, ensure compliance and reduce risk, this page contains the links to the administrative documents needed to help us achieve these goals
MUST DO’S
Every NPO (Non-Profit Organisation) and PBO (Public Benefit Organisation) in South Africa is required to maintain sound governance through well-defined policies, procedures, and statutory documentation. These should be aligned with key legislative and regulatory frameworks, including the Basic Conditions of Employment Act (BCEA), Labour Relations Act (LRA), the NPO Act, SARS requirements for PBOs, and the principles of King IV.
MEALS ON WHEELS SANDTON
GOVERNANCE & COMPLIANCE MANUAL (SA NPO/PBO COMPLIANT)
COMPLIANCE FRAMEWORK
This organisation operates within the following regulatory framework:
- South African Department of Social Development – Nonprofit Organisations Act, 1997 (as amended)
- South African Revenue Service – Income Tax Act (Public Benefit Organisation provisions, Section 30)
- Companies Act principles (where applicable governance overlap exists)
- Common law fiduciary duties of Board members
0.0. Core Compliance Obligations
The organisation must:
- Maintain NPO registration with DSD
- Submit annual narrative and financial reports to DSD
- Maintain valid PBO status with SARS
- Ensure funds are used solely for approved public benefit activities
- Maintain proper accounting records (minimum 5 years recommended baseline)
- Ensure governance structures reflect registered Constitution
0.1 BOARD GOVERNANCE POLICY
Compliance Additions:
- Board must ensure compliance with:
- NPO Act reporting requirements
- SARS PBO conditions
- Board must ensure at least annual submission of:
- Financial statements (DSD)
- Narrative report (DSD)
- Board members are fiduciaries under common law and must act in good faith, care, and skill
0.2 FINANCIAL MANAGEMENT POLICY
SARS & DSD Alignment Requirements:
The organisation must maintain financial records sufficient to:
- Support SARS PBO public benefit activity compliance
- Support DSD annual financial reporting
Mandatory Additions:
- Annual financial statements must be:
- Prepared in accordance with GRAP or IFRS for SMEs (as applicable)
- Independently reviewed or audited where required by funders or scale of operations
- All expenditure must align with approved Public Benefit Activities (PBAs) under SARS legislation
- No funds may be used for:
- Private benefit
- Personal enrichment of Board members or staff
0.3. CONFLICT OF INTEREST POLICY
SARS-Specific Requirement:
- All conflicts must be disclosed to ensure compliance with:
- SARS PBO prohibition on private benefit distribution
Additional Requirement:
- Related-party transactions must be:
- Fully disclosed
- Fair market value tested where applicable
- Recorded in minutes
0.4 CODE OF CONDUCT & ETHICS
Includes explicit alignment with:
- Fiduciary duties under common law
- Ethical governance expectations under NPO Act principles
- Transparency expectations from DSD reporting framework
0.5 DELEGATION OF AUTHORITY POLICY
Critical Compliance Additions:
- Delegation must not override:
- Constitution
- SARS PBO compliance requirements
- Board fiduciary duties
- All delegated authority must ensure:
- Funds remain applied to approved public benefit objectives
- Proper audit trail exists for DSD/SARS review
0.6 FRAUD PREVENTION & WHISTLEBLOWING
Legal Alignment:
- Protected disclosures aligned with South African whistleblower protections
- Fraud reporting must support audit requirements for:
- SARS compliance reviews
- Independent audit verification (if required)
0.7 HUMAN RESOURCES POLICY
Must comply with:
- Basic Conditions of Employment Act
- Labour Relations Act
- Employment Equity principles (where applicable)
Includes:
- Fair disciplinary procedures
- Proper written employment contracts
- Documented grievance procedures
0.8 VOLUNTEER POLICY
Important SA additions:
- Volunteers must not be treated as employees under labour law
- Clear distinction must be maintained between:
- Volunteer reimbursement vs salary
- Volunteers involved in beneficiary care must comply with safeguarding expectations aligned with social development norms
0.9. POPIA & DATA PROTECTION POLICY
Aligned with:
- Protection of Personal Information Act (POPIA)
Mandatory provisions:
- Lawful processing of donor and beneficiary data
- Explicit purpose limitation (fundraising, service delivery)
- Secure storage and restricted access
- Breach reporting procedures
0.10 DOCUMENT RETENTION POLICY (SA COMPLIANCE MINIMUMS)
Retention aligned with:
- SARS audit expectations
- NPO Act reporting obligations
Minimum retention guidelines:
- Financial records: 5 years minimum
- Board minutes: permanent
- Donor records: 5 years minimum
- HR records: as required by labour law
0.11 HEALTH, SAFETY & OPERATIONAL RISK (SA CONTEXT)
Includes:
- Occupational Health and Safety Act alignment (where applicable)
- Food safety handling compliance
- Transport and delivery safety controls
0.12 SAFEGUARDING VULNERABLE PERSONS POLICY (CRITICAL FOR DSD ALIGNMENT)
Aligned with Department of Social Development expectations for service organisations.
Includes:
- Protection of elderly beneficiaries
- Mandatory reporting of abuse or neglect
- Boundaries for volunteers entering private homes
- Zero tolerance for exploitation or neglect
0.13 BOARD MEETING POLICY
Aligned with good governance expectations under NPO Act principles:
Includes:
- Proper notice of meetings
- Quorum requirements per Constitution
- Accurate minutes retained for audit trail
- Clear distinction between Board vs operational authority
0.14 RISK MANAGEMENT POLICY
Supports:
- DSD governance expectations
- SARS audit readiness
Includes:
- Risk register maintained annually
- Financial risk monitoring
- Reputational risk management
- Operational risk (food, transport, volunteers)
0.15 MEDIA & COMMUNICATIONS POLICY
Governance risk control:
- Only authorised spokespersons may speak on behalf of organisation
- Messaging must not contradict NPO/PBO objectives
- Crisis communication delegated to Chairperson or designated official
0.16 FUNDRAISING & DONATIONS POLICY
Aligned with:
- SARS PBO requirements for public benefit use of funds
Includes:
- Donor funds must be applied to stated purpose
- Restricted funds must be tracked separately
- Ethical fundraising standards
- No misrepresentation to donors or funders
0.17 GOVERNING DOCUMENTS HIERARCHY
Order of precedence:
- Constitution (highest authority)
- Applicable law (NPO Act, SARS legislation, labour law)
- Affiliation agreements / MOUs (if legally binding)
- Board policies (this manual)
- Operational procedures
0.0
Statuatory Compliance
☐NPO Registration Certificate (Department of Social Development)
☐ Founding Document (Constitution / Trust Deed / MOI)
☐ PBO Approval Letter from SARS (Section 18A status, if applicable)
☐ SARS Income Tax Exemption confirmation
☐ Registered for PAYE, UIF, SDL (if employing staff)
☐ Valid Tax Clearance Status (TCS PIN)
☐ Compliance with NPO Act, BCEA, LRA, and relevant legislation
- Maintain NPO registration with DSD
- Submit annual narrative and financial reports to DSD
- Maintain valid PBO status with SARS
- Ensure funds are used solely for approved public benefit activities
- Maintain proper accounting records (minimum 5 years recommended baseline)
- Ensure governance structures reflect registered Constitution
0.1
Governance Structure
☐ Active and independent Board / Management Committee
☐ Board Charter outlining roles, responsibilities, and authority
☐ Clearly defined organisational structure
☐ Documented delegation of authority framework
☐ Regular Board and Committee meetings (with minutes recorded)
☐ Conflict of Interest Policy and annual declarations
Compliance Additions:
- Board must ensure compliance with:
- NPO Act reporting requirements
- SARS PBO conditions
- Board must ensure at least annual submission of:
- Financial statements (DSD)
- Narrative report (DSD)
- Board members are fiduciaries under common law and must act in good faith, care, and skill
Financial Management & Controls
☐ Approved annual budget
☐ Financial policies (including procurement and expenditure controls)
☐ Segregation of duties (e.g., approvals, payments, reconciliations)
☐ Dual authorisation for payments (especially large transactions)
☐ Monthly financial reporting to management/Board
☐ Annual Financial Statements (audited or independently reviewed)
☐ Asset register maintained and reviewed
☐ Petty cash controls and limits clearly defined
☐ Banking controls (including restricted access and oversight)
Statuatory Compliance
☐NPO Registration Certificate (Department of Social Development)
☐ Founding Document (Constitution / Trust Deed / MOI)
☐ PBO Approval Letter from SARS (Section 18A status, if applicable)
☐ SARS Income Tax Exemption confirmation
☐ Registered for PAYE, UIF, SDL (if employing staff)
☐ Valid Tax Clearance Status (TCS PIN)
☐ Compliance with NPO Act, BCEA, LRA, and relevant legislation
Governance Structure
☐ Active and independent Board / Management Committee
☐ Board Charter outlining roles, responsibilities, and authority
☐ Clearly defined organisational structure
☐ Documented delegation of authority framework
☐ Regular Board and Committee meetings (with minutes recorded)
☐ Conflict of Interest Policy and annual declarations
Financial Management & Controls
☐ Approved annual budget
☐ Financial policies (including procurement and expenditure controls)
☐ Segregation of duties (e.g., approvals, payments, reconciliations)
☐ Dual authorisation for payments (especially large transactions)
☐ Monthly financial reporting to management/Board
☐ Annual Financial Statements (audited or independently reviewed)
☐ Asset register maintained and reviewed
☐ Petty cash controls and limits clearly defined
☐ Banking controls (including restricted access and oversight)
04
Human Resources & Labour Compliance
☐ Employment contracts aligned with BCEA
☐ HR policies (leave, discipline, grievance, performance management)
☐ Payroll compliance (PAYE, UIF submissions up to date)
☐ Job descriptions and performance management processes
☐ Training and development plans
☐ Health & Safety compliance (where applicable)
05
Policies & Procedures
☐ Code of Conduct / Ethics Policy
☐ Financial Management Policy
☐ Procurement / Supply Chain Policy
☐ Risk Management Policy
☐ Data Protection / POPIA Compliance Policy
☐ Whistleblowing Policy
☐ Fundraising & Donor Stewardship Policy
☐ Safeguarding Policy (especially where vulnerable groups are served)
06
Risk Management & Internal Controls
☐ Approved annual budget
☐ Financial policies (including procurement and expenditure controls)
☐ Segregation of duties (e.g., approvals, payments, reconciliations)
☐ Dual authorisation for payments (especially large transactions)
☐ Monthly financial reporting to management/Board
☐ Annual Financial Statements (audited or independently reviewed)
☐ Asset register maintained and reviewed
☐ Petty cash controls and limits clearly defined
☐ Banking controls (including restricted access and oversight)
07
Monitoring, Evaluation & Reporting
☐ Defined programmes and measurable objectives
☐ Monitoring & Evaluation (M&E) framework
☐ Impact measurement and reporting
☐ Annual report prepared and shared with stakeholders
☐ Donor reporting aligned to funding agreements
08
Fundraising & Donor Compliance
☐ Valid Section 18A certificates issued correctly (if applicable)
☐ Donor database maintained securely (POPIA compliant)
☐ Transparent use of funds and reporting
☐ Alignment with donor requirements and compliance standards
09
King IV Governance Principles (Applied)
☐ Ethical leadership demonstrated
☐ Accountability and transparency upheld
☐ Proper oversight of strategy and performance
☐ Responsible stewardship of resources
☐ Stakeholder-inclusive approach
10
Documentation & Record Keeping
☐ All statutory and governance documents securely stored
☐ Board minutes and resolutions properly recorded
☐ Financial records retained as required by law
☐ Contracts and agreements properly filed
11
TBC
☐ Valid
12
TBC
☐ Ethic