Donor ethics at L4T
This Charter sets out how contributions to Luxembourg for Transparency are managed, protected and used in support of our mission.
Date of Adoption
31 December 2025
Applicable to
All individual donors, corporate sponsors and grant-making institutions.
Contact
compliance [at] l4t [dot] lu
1. Preamble
Luxembourg for Transparency, abbreviated as "L4T", is an ASBL governed by the Law of 7 August 2023. As a nonprofit organisation dedicated to promoting transparency, we hold ourselves to the highest standards of integrity. This Charter outlines our pledge to our donors regarding how their contributions are managed, protected and utilised.
2. Financial Stewardship & Allocation
Purpose
100% of donations are applied directly to L4T's mission, including operational costs necessary to sustain it.
Accounting
L4T maintains rigorous accounting records in accordance with the Luxembourg Plan Comptable Normalisé (PCN).
Efficiency
We are committed to keeping administrative costs reasonable and consistent with typical costs in Luxembourg, ensuring only necessary costs are covered while maximising the impact of our advocacy and research.
3. Independence
To maintain the credibility of our advocacy work, L4T applies the following safeguards:
- No Pay-to-Play: Donations, regardless of size, strictly do not grant donors influence over L4T's strategy, editorial content, investigations or governance decisions. Donations do not imply any endorsement of a donating party's policies or record. Corporate donors may be requested to sign a commitment to integrity before any donation from that company is accepted.
- The Firewall: There is a strict functional separation between our fundraising team and our research and advocacy team.
- Right of Refusal: L4T reserves the right to refuse any donation from a source whose values or business practices are fundamentally incompatible with our mission, including entities involved in corruption, money laundering or human rights abuses. Any donor accused of involvement in corrupt or unethical financial or non-financial misconduct can expect no protection from L4T.
4. Anonymity vs. Transparency
Public Listing
With the donor's explicit consent, L4T will publicly acknowledge contributions exceeding €1,000 in our Annual Report, thereby demonstrating broad-based support.
Anonymity
We respect donors' right to remain anonymous to the public. However, L4T maintains internal records of all donor identities to comply with Luxembourgish Anti-Money Laundering (AML) regulations. We do not accept anonymous cash donations exceeding €100 to prevent illicit financing.
5. Data Protection (GDPR)
In compliance with the Commission Nationale pour la Protection des Données (CNPD) and the GDPR, L4T applies the following principles:
- Donor data is stored securely and never sold, rented or traded to third parties.
- Donors have the right to access, rectify or erase their data from our active marketing lists upon request to compliance [at] l4t [dot] lu.
6. Reporting & Accountability
Annual Report
We publish a full activity and financial report annually following our General Assembly (AGM). This includes a clear breakdown of income sources, including memberships, donations and grants.
RCS Filing
Our annual accounts are filed with the Registre de Commerce et des Sociétés (LBR) and are publicly accessible.
7. Tax Deductibility Disclaimer
As a newly established organisation, L4T is not yet recognised as a non-profit of public utility (Reconnaissance d'Utilité Publique); therefore, donations made by Luxembourg tax residents are not tax-deductible within the limits of Articles 109 and 112 of the L.I.R. (Luxembourg law), unless specific project approval has been granted.