Individual Gift Acceptance Policy

Purpose

Conservation International Foundation (CI) is a U.S. non-profit, tax-exempt charitable organization (tax identification number 52-1497470) under Section 501(c)(3) of the Internal Revenue Code. The Board of Directors of CI, its affiliates, subsidiaries, and its staff solicit current and deferred gifts from individuals, corporations, and foundations to help fulfill its mission. This policy governs the solicitation, acceptance, receipt, management, reporting, and use of charitable gifts from individuals to CI and its affiliates and subsidiaries. The purpose of this gift acceptance policy ensures the uniform treatment of donors and their gifts and provides guidelines for the acceptance and stewardship of gifts. This policy provides general guidance on the acceptance of gifts of cash, assets, securities, and property, and the restrictions on those gifts to ensure the integrity of the organization's programs, core values, and fiscal position. In some instances, the merits of accepting a particular gift must be reviewed by CI's Gift Acceptance Committee.

Scope

This Policy applies to all CI employees, interns, fellows, volunteers, and representatives (jointly, "CI Staff") and donors.

Our principles and actions

CI is committed to the highest ethical standards governing donor engagement and gift acceptance. Transparency and accountability are critical for responsible stewardship of gifts and ensuring that we receive and utilize them in the best interest of CI and our mission.

• Legal Review: CI urges all prospective donors to seek the assistance of personal legal and financial advisors in matters relating to their gifts, including the resulting tax and estate planning consequences. Further, to avoid conflicts of interest or the appearance of improper influence, CI shall not pay donors' legal or other fees. Where necessary, CI will seek the advice of its legal counsel in matters relating to the acceptance of gifts. Such review is required for:
  • Gifts of securities that are subject to restrictions or buy-sell agreements.
  • Documents naming CI as trustee or requiring CI to act in any fiduciary capacity.
  • Gifts requiring CI to assume financial or other obligations.
  • Transactions with potential conflicts of interest.
  • Gifts of real property that may be subject to environmental or other regulatory restrictions.
  • Gifts intended for donor-designated recipients.
  • Gifts of movable private property (example: fine art, jewelry, antiquities, cars)
  • Any gift that would require a CI or CI affiliate board action.
• Donor Confidentiality: CI endorses the Donor Bill of Rights and sets the minimum standards for interacting with donors and guiding fundraising activities. All information obtained from or about donors or prospective donors shall be processed in accordance with CI's Donor Privacy Commitment and Privacy Notice. Requests for donor anonymity will be honored. Files, records, and mailing lists regarding all donors and donor prospects are maintained and controlled by CI. Written reports of interviews and solicitations will be maintained in the donor or prospect records. This information is classified and treated as restricted and/or confidential information.
• Donor Consideration: CI conducts due diligence on the identity of donors and source of donations in accordance with principles and objectives laid out in CI's Anti-Money Laundering/Counter-Terrorism Financing Policy.
• Donor Acknowledgement + Recognition: Gift agreements will fully reflect each donor's wishes and financial instructions consistent with CI's policies and applicable law. All donors who have provided contact information are furnished gift acknowledgment letters as soon as possible after the receipt of a gift. Acknowledgment for all gifts over $250 and gifts of $75 or more for which a benefit was offered by CI to the donor will include required language related to the value of goods and services received. In accordance with their privacy choices, donors contributing $1,000 or more will be recognized in the Annual Report. Donors contributing planned gifts or those who have indicated that will leave a deferred gift to CI, and have given permission to be recognized, will be listed as Future of Life members in the Annual Report.
• Ban on Commission-Based Fundraising: Following the Association of Fundraising Professionals' Code of Ethical Principles & Standards of Professional Practice, no fundraiser is compensated based on a percentage of funds raised or on a contingent basis. Non-exempt or hourly fundraisers in the employment of CI are compensated based on the number of hours worked. Exempt or salaried fundraisers in the employment of CI are salaried staff compensated on a fixed annualized rate. Independent contractors and consultants are compensated on a project basis.
• Gift Agreements: CI expects that all donor pledges are made in good faith and will be honorably fulfilled by each donor within the agreed-upon timeline. Multi-year pledges OR restricted gifts of $50,000+ will be documented in writing with pledge payment timelines detailed on the pledge commitment or within gift agreements. CI will expend every effort to fulfill its obligations to provide reminders, appropriate reporting and recognition, and honor commitments to its donors.  CI's practice is not to pursue any unfulfilled written pledge commitments but reserves the right to do so in specific circumstances.
• Gift Restrictions: CI records each gift according to the restriction indicated by the donor. If the donor provides specific restrictions and CI cannot follow such restrictions, CI will not accept the gift. To restrict a gift to a current CI program, a donor must indicate so in writing.  CI reserves the right to refuse any gift that is not consistent with its mission. Decisions on the restrictive nature of a gift, and its acceptance or refusal, shall be made by the Gift Acceptance Committee.  In addition, and without limiting the generality of, the following gifts will not be accepted by CI:
  • Gifts that violate any federal, state, or local statute or ordinance;
  • Gifts that would result in CI violating its Corporate Engagement Policy
  • Gifts that would result in CI losing its status as an IRC § 501(c)(3) not-for-profit organization
  • Gifts that contain unreasonable conditions (e.g., a lien or other encumbrance) or gifts of a partial interest in a property;
  • Gifts that are too difficult or too expensive to administer in relation to their value;
  • Gifts that are made with the condition that proceeds will be spent by CI for the private benefit of a designated party;
  • Gifts that could expose CI to liability or result in unacceptable reputational consequences.

Implementation

CI accepts gifts in the form of outright gifts, pledges, planned gifts, and endowment gifts.

Outright gifts accepted. CI regularly conducts due diligence on donor relationships and gifts to reduce legal, reputational, and other risks to the organization. The following types of gifts are typically not subject to additional review.

• Cash: Any amount can be given and may be designated to support CI's mission and operations or to a current program of the donor's choosing. Cash gifts are acceptable in any form, including by check, wire transfer, ACH transfer, credit card, or online (including PayPal and Apple Pay).
• Marketable Securities: Marketable securities may be transferred electronically to an account maintained at one or more brokerage firms or delivered physically with the transferor's endorsement or signed stock power (with appropriate signature guarantees) attached. All marketable securities will be sold promptly upon receipt. In some cases, marketable securities may be restricted, for example, by applicable securities laws or the terms of the proposed gift; in such instances, the decision whether to accept the restricted securities shall be made by the Gift Acceptance Committee. Gifts of publicly traded marketable securities will be credited (in conformity with IRS guidelines) as the mean value between the 'high' and 'low' market prices on the date of the gift. If the security was not traded on its exchange on that date, the date of the most recent prior sale will be used. The minimum accepted gift amount of marketable securities is USD $100.
• Donor Advised Funds: Donors who wish to give to CI through their Donor Advised Fund (DAF) must contact their sponsoring financial or community institution to recommend a grant to CI. The U.S. Pension Protection Act of 2006 establishes certain restrictions applying to DAFs. Donors need to be aware of these restrictions to ensure that the gift matches their needs and charitable intent. Any amount can be given.
  • Pledges — When a DAF is established, the donor may recommend but not legally direct future charitable grants. As the donor has given up legal ownership of the funds, they are prohibited from making a legally binding pledge from their DAF to the charity they want to support. In addition, donors may not fulfill existing pledges through their DAF.
  • Donor Benefits — Because a full tax deduction is received at the time of establishing the DAF, donors may only receive "incidental" benefits, or benefits which do not carry a fair market value, in relation to gifts from DAFs.
• Bequests: Donors and supporters of CI are encouraged to make bequests to CI within their wills and trusts. Such gifts will not be recorded as gifts to CI until such time as the gift is irrevocable. When the gift is irrevocable, but is not due until a future date, the present value of that gift may be recorded and recognized at the time the gift becomes irrevocable. Any amount can be given.
• Retirement Plan Beneficiary Designations: Donors and supporters of CI are encouraged to name CI as a beneficiary of their retirement plans. Retirement plan beneficiary designations are acceptable without prior review. However, such designations will not be recorded as gifts to CI until the gift is received. When the gift is irrevocable, but is not due until a future date, the present value of that gift may be recorded and recognized at the time the gift becomes irrevocable. Any amount can be given.
• Life Insurance Beneficiary Designation: CI will accept gifts of life insurance where CI is named as both beneficiary and irrevocable owner of the insurance policy. The donor must agree to pay, before due, any future premium payments owing on the policy. Any amount can be given.
• Charitable Gift Annuities:  CI does not currently offer gift annuities but will accept designation as an annuitant's beneficiary. Any amount can be given.
• Matching gifts: CI honors other organizations' matching gift policies while optimizing matching opportunities as fully as possible. Cash gifts received from organizations or corporations to match gifts or volunteer time from individuals who are associated with that entity will be credited to the entity, with soft credit to the individual donor's record. Unless explicitly prohibited by the matching entity, these funds will be allocated to the same purpose as the individual donor's gift. Any amount can be given.
• Memorial, honorary, and "on behalf of" gifts: Memorial and honorary gifts are encouraged by CI as generous and thoughtful ways to recognize people's lives and accomplishments. Any amount can be given.
• Workplace giving: Many employers offer gift matching and CI participates in several workplace giving campaigns. Please check your employer's workplace giving policies to see how you can give at work. For active or retired federal employees and members of our military, CI's Combined Federal Campaign (CFC) number is 11430. Any amount can be given.

Outright gifts accepted with prior review – In addition to the regular due diligence process, certain types of gifts will be subject to review by the Gift Acceptance Committee before acceptance. Examples of types of gifts subject to prior review include, but are not limited to:

• Tangible Personal Property: CI shall review and determine whether to accept any gifts of tangible personal property in light of the following considerations:
  • Does the property further the organization's mission?
  • Is the property marketable?
  • Are there any unacceptable restrictions imposed on the property?
  • Are there any carrying costs for the property for which the organization may be responsible?
  • Is the title/provenance of the property clear?
  • If the property is liquidated, are there any restrictions on how CI utilizes the funds made from the sale?
  • The minimum gift amount is to be determined by the Gift Acceptance Committee as needed to cover the costs associated with any sale or fees associated with the acceptance of such a gift.
• Real Estate: All gifts of real estate are subject to review by the Gift Acceptance Committee and must receive approval from the General Counsel's Office and CFO. Before acceptance of any gift of real estate other than a personal residence, CI shall require an initial environmental review by a qualified environmental firm. If the initial review reveals a potential problem, CI may retain a qualified environmental firm to conduct an environmental audit. Criteria for acceptance of gifts of real estate include:
  • Is the property useful for the organization's purposes?
  • Is the property readily marketable?
  • Are there covenants, conditions, restrictions, reservations, easements, encumbrances, or other limitations associated with the property?
  • Are there carrying costs (including insurance, property taxes, mortgages, notes, or the like) or maintenance expenses associated with the property?
  • Does the environmental review or audit reflect that the property is damaged or otherwise requires remediation?
  • Is CI responsible for the contents?
  • If the real estate is liquidated, are there any restrictions on how CI utilizes the funds made from the sale?
  • The minimum gift amount is to be determined by the Gift Acceptance Committee as needed to cover the costs associated with any sale or fees associated with the acceptance of such a gift.
• Crypto Currency: CI does not currently accept direct donations of cryptocurrency. CI will accept donations of liquidated cryptocurrency following approval and due diligence by the Gift Acceptance Committee.

Deferred gifts accepted with prior review by the Gift Acceptance Committee: In addition to the regular due diligence process, the following types of gifts may be subject to review before acceptance. Examples of types of gifts subject to prior review include, but are not limited to:

• Bequests: Donors and supporters of CI are encouraged to make bequests to CI within their wills and trusts. Such gifts will not be recorded as gifts to CI until such time as the gift is irrevocable. When the gift is irrevocable, but is not due until a future date, the present value of that gift may be recorded and recognized at the time the gift becomes irrevocable. Any amount can be given.
• Retirement Plan Beneficiary Designations: Donors and supporters of CI are encouraged to name CI as a beneficiary of their retirement plans. Retirement plan beneficiary designations are acceptable without prior review. However, such designations will not be recorded as gifts to CI until the gift is received. When the gift is irrevocable, but is not due until a future date, the present value of that gift may be recorded and recognized at the time the gift becomes irrevocable. Any amount can be given.
• Life Insurance Beneficiary Designation: CI will accept gifts of life insurance where CI is named as both beneficiary and irrevocable owner of the insurance policy. The donor must agree to pay, before due, any future premium payments owing on the policy. Any amount can be given.
• Charitable Remainder/Lead Trusts: CI will accept designation as a remainder beneficiary of charitable remainder and charitable lead trusts. CI will not accept an appointment as a Trustee of a charitable remainder trust. The minimum gift amount is USD $50,000 (Unitrust) and $25,000 (Annuity Trust).
• Endowment Gifts: Endowment gifts contribute to the long-term financial health of CI and are deeply appreciated and encouraged. Gifts made to CI's Endowment Funds will be subject to review by the Gift Acceptance Committee and the Investment Committee if such gifts otherwise would be subject to review before acceptance in accordance with these policies. Gifts to CI's Endowment Funds are held in perpetuity, subject to the policies adopted from time to time by CI's Board. The minimum gift amount is USD $500,000 to create a new restricted endowment.
• Charitable Gift Annuities:  CI does not currently offer gift annuities but will accept designation as an annuitant's beneficiary. Any amount can be given.

Definitions

• Gift Acceptance Committee: CI internal committee including, at minimum, a member or members of the General Counsel's Office, Finance, and Vice President, Individual Giving, or other relevant Development representative.  The Committee manages this policy, related procedures, and exceptions; determining when an independent appraisal is required for a gift; and accepting gifts that are considered to be Tier 3 and 4 donations as per the AML /CTF procedures for donor due diligence.
• Bequest: Gift from a donor's estate that is made by including language in the donor's will or living trust indicating that the donor wishes to leave a portion of their estate to CI as a specific amount, a percentage of the estate, or for all or a portion of what is left after other bequests have been made.
• Endowment: Collection of funds the principal of which cannot be spent.
• Gift: Voluntary, non-reciprocal charitable donation of value for which nothing is promised, expected, implied, or forthcoming to the donor in return. The donor may make a restricted-use gift by designating a specific purpose.
• Planned Gift: Represents a donor's present decision to make a future gift, as evidenced through a written gift instrument.
• Pledge: A good faith commitment to make a gift payable over a period of time, as evidenced through a written gift instrument.
• Outright Gift: Irrevocable transfer of assets at the immediate disposal of CI and in which the donor retains no interest, nor makes a commitment to pledge payments. Outright gifts may be restricted or unrestricted in purpose.