Exhibit F
SHAREALEDGER, NFP
GIFT ACCEPTANCE POLICY
Last Revised April 30, 2021
This is the Gift Acceptance Policy of SHAREALEDGER, NFP, an Arizona nonprofit corporation (the “Corporation”) adopted by the Board of Directors of the Corporation on April 30, 2021.
The purpose of this gift acceptance policy is to give guidance and counsel to those individuals within the Corporation concerned with the planning, promotion, solicitation, receipt, acceptance, management, reporting, use, and disposition of private sector gifts.
These policies must be viewed as flexible and realistic in order to accommodate unpredictable situations as well as donor expectations, as long as such situations and expectations are consistent with the Corporation’s mission and policies. Flexibility must be maintained since some gift situations will be complex, and proper decisions can be made only after careful consideration of all related factors. These policies may, therefore, require that the merits of a particular gift be considered by the appropriate staff and/or committee of the board along with legal counsel and members of the Board of Directors if necessary.
All fundraising activities and gift acceptance policies, and their day-to-day implementation, are designed and managed by the President in conjunction with the appropriate staff, and are subject to approval by the Board of Directors.
The Board of Directors, through the President, is responsible for implementing this gift acceptance policy. This responsibility cannot be delegated or waived. These policies and authorizations shall be reviewed by the finance committee on an annual basis or as circumstances warrant.
Gift Acceptance Policy
The Corporation may actively solicit gifts and grants to further the mission of the organization. There is a potential that the acceptance of certain gifts could compromise the ability of the organization to accomplish its goals or could jeopardize its tax-exempt status. Therefore, the following gift acceptance policy applies:
The President of Corporation and the Board of Directors have the authority to solicit and/or accept gifts on behalf of Corporation. The Corporation’s responsibility is to productively pursue gifts that will further the organization’s mission, goals, and objectives. The primary consideration in the pursuit of gifts is how they can benefit the organization in the most ethical and unencumbered manner. To that end, the following caveats must be considered:
• Core Values. Is the gift one that is consistent with the organization’s standards, principles, and core values?
• Compatibility of Cause. Will the gift unnecessarily challenge the organization’s ability to further its mission, goals, or objectives?
• Public Relations. Does the acceptance of the gift present the organization in an unfavorable light? Does it appear that there may exist a conflict of interest between the donor and the organization?
• Motivation. Is there clear charitable intent and a commitment to the organization?
• Consistency. Will the acceptance of the gift be compatible and in agreement with other fundraising activities or gifts of the organization?
• Credibility. Are the circumstances surrounding the donor and the gift believable?
• Organizational Stability. If controversy develops, will it be significant enough to weaken the structure of the organization?
• Form of Gift. Will the nature of the in-kind contribution create problems, such as in advertising or sponsorship?
• Source of Gift. Who is the donor? Is the gift from an individual or a corporation? Does the donor represent a perceived conflict of interest, or might the donor’s objectives not fit with the mission of the organization?
Unrestricted, outright gifts of cash, check, credit card, and publicly traded securities do not require approval. Routine gifts are accepted and administered through the Secretary of the Corporation, with final authority to accept routine gifts lying with the President.
Gifts will only be accepted where there is charitable intent on the part of the donor. The Corporation is unable to accept gifts that are overly restrictive in purpose. The most desirable gifts are those with the least restrictions, as unrestricted funds allow the organization to address its most pressing needs. Unless the Board of Directors grants a specific exception, the Corporation will not accept any gifts that:
• Contain a condition that requires any action on the part of the organization that is unacceptable to the President or the Board of Directors
• Contain a condition that the proceeds will be spent by the organization for the personal benefit of a named individual or individuals
• Require the organization to employ a specified person now or at a future date
• Inhibit the organization from seeking gifts from other donors
• Expose the organization to adverse publicity, litigation, or other liabilities
• Require undue expenditures, or involve the organization in unexpected responsibilities because of their source, conditions, or purpose
• Involve unlawful discrimination based upon race, religion, gender, sexual orientation, age, national origin, color, disability, or any other basis prohibited by federal, state, and local laws
Noncash gifts will be accepted only when it is reasonably expected they can be converted into cash within a reasonable period of time or when the Corporation can utilize the property in its operations. Generally, six months to one year shall be considered reasonable for conversion to cash. All noncash gifts to the Corporation will be sold at the discretion of the President, whose express policy will be to convert the property to cash at the earliest opportunity, keeping in mind current market conditions and the potential use of the property in the accomplishment of the mission of the Corporation.
Property encumbered by a mortgage or other indebtedness cannot normally be accepted as a gift unless the donor agrees to assume all carrying costs until the property is liquidated. Exceptions to this guideline can be made when the value of the property exceeds the anticipated exposure, or will produce income, or will be used by the Corporation in its programs.
Associated expenses of a gift made to the Corporation are to be borne by the donor.
Donors of property gifts of over $5,000, except for gifts of publicly traded stock, must obtain an appraisal by an independent third-party appraiser in accordance with current tax law requirements. The Corporation retains the right to obtain its own qualified appraisals of real property or tangible or intangible personal property being offered as a gift at its own expense.
To avoid conflicts of interest, the unauthorized practice of law, the rendering of investment advice, or the dissemination of income or estate tax advice, all donors of noncash gifts must acknowledge that the Corporation is not acting as a professional advisor, rendering opinions on the gift. All information concerning gift planning from the Corporation is to be for illustrative purposes only and is not to be relied upon in individual circumstances. The Corporation may require a letter of understanding from a donor of a property gift, along with proof of outside advice being rendered, before such a gift will be accepted.
All gifts of life insurance must comply with applicable state insurance regulations, including insurable interest clauses.
The Corporation does not accept any gifts requiring annuity payments that will be guaranteed by the organization.
All gifts and gift consideration must meet all applicable local, state, and federal laws and regulations.
The Corporation will not pay commissions or finder’s fees as consideration for directing a gift to Corporation.
The Corporation will acknowledge receipt of gifts of tangible personal or real property in accordance with the federal tax law and will sign any IRS form or other documents necessary for the donor to obtain a tax deduction for such gifts, so long as such acknowledgment does not entail valuing the gift.
The Corporation reserves the right to decline any financial commitment, gift, or bequest, as well as the right to determine how a gift will be credited and/or recognized.
Confidentiality
All information about donors and prospective donors, including but not limited to their names, the names of their beneficiaries, the nature and amounts of their gifts, and the sizes of their estates will be kept confidential by the Corporation and its representatives, unless the donor grants permission to release such information. All requests by donors for anonymity will be honored, except to the extent that Corporation is required by law to disclose the identity of donors.
Professional Advice
Prospective donors shall be strongly encouraged in all cases to consult with their own independent legal and/or tax advisors about proposed gifts, including tax and estate planning implications of the gifts. No representative of the Corporation shall provide legal or tax advice to any donor or prospective donor.
Upon request, representatives of Corporation may provide to the donor sample bequest language for restricted and unrestricted gifts to ensure that a bequest is properly designated. The Corporation may also provide, upon request, IRS-approved prototype trust agreements for review and consideration by the donor and his or her advisors. The sample nature of such language or agreements shall be clearly stated on all documents given to donors, and donors shall be advised that consultation with their own legal advisors is essential prior to use of such standard language or specimen agreements.
Authority
The Chairman of the Board of Directors or his or her designee is authorized to enter into planned gift agreements on behalf of the Corporation and to sign any and all documents necessary or appropriate to consummate such agreements. Any exceptions to these gift acceptance policies may be made only in exceptional circumstances, on an individual basis, and shall require the approval of the Board of Directors.
SECRETARY’S CERTIFICATE
I, the undersigned officer of SHAREALEDGER, NFP, an Arizona nonprofit corporation (the “Corporation”), do hereby certify that the foregoing Gift Acceptance Policy is a true and correct copy of the Gift Acceptance Policy of the Corporation adopted by the affirmative vote of the Directors of the Corporation on April 30, 2021.
IN WITNESS WHEREOF, I have hereunto set my hand on April 30, 2021. [Signed] Kip M. Twitchell
Kip Mack Twitchell, Secretary