Gift Acceptance Policy

ATTORNEY REVIEW REQUIRED: This policy should be reviewed by legal counsel, particularly Sections IV and V regarding restricted gifts and planned giving vehicles.

I. Purpose

This policy establishes guidelines for the solicitation and acceptance of gifts by PROVENIQ Foundation, Inc. to protect the Corporation, its donors, and its tax-exempt status.

II. General Policy

The Corporation shall solicit and accept gifts that are consistent with its mission and that do not create unacceptable financial, legal, ethical, or reputational risk. All gifts are subject to the ultimate discretion of the Board or its designee.

III. Gifts Generally Accepted Without Review

The following gifts may be accepted without Board review: cash and checks, credit card and electronic fund transfers, publicly traded securities, bequests and beneficiary designations (subject to legal review of conditions), and matching gifts from employers.

IV. Gifts Requiring Review

The following gifts require review by the CEO and, where appropriate, the Finance, Audit & Risk Committee or legal counsel before acceptance: real property, closely held securities, tangible personal property, in-kind services valued above $5,000, gifts with donor-imposed restrictions, cryptocurrency or digital assets, gifts involving naming rights, sponsorships with conditions, and gifts from foreign sources.

V. Gifts the Corporation Will Not Accept

The Corporation shall not accept gifts that violate any federal, state, or local law, that would jeopardize the Corporation’s tax-exempt status, that are inconsistent with the Corporation’s mission or values, that create an unacceptable financial or legal burden, that require the Corporation to take actions contrary to its governance policies, or that involve illegal activity.

VI. Donor Intent and Restrictions

The Corporation shall honor donor intent to the extent possible and consistent with its mission. Restricted gifts shall be tracked and reported separately. If the Corporation determines it cannot honor a restriction, it shall consult with the donor and, if necessary, seek legal modification of the restriction consistent with WV law (cy pres doctrine).

VII. Gift Acknowledgment

The Corporation shall provide written acknowledgment of all gifts as required by IRS regulations, including the donor’s name, date and amount of gift, description of non-cash gifts, and a statement that no goods or services were provided in exchange (or a description and good-faith estimate of value if they were).

VIII. Donor Privacy

The Corporation shall protect donor privacy and shall not sell, trade, or share donor information with third parties without donor consent, except as required by law. Anonymous gifts shall be accepted and honored.

IX. Fundraising Ethics

All fundraising activities shall be conducted ethically and in compliance with applicable law. The Corporation shall not use high-pressure solicitation tactics, shall provide accurate information about programs and use of funds, and shall honor donor requests to be removed from solicitation lists.

X. Administration

The CEO shall oversee the administration of this policy. The Development & Strategic Partnerships Committee shall review this policy annually.