Gift Acceptance Policy

Independent Ukrainian Fund (the “IUF”) is a Delaware non-stock, not-for-profit corporation organized exclusively for charitable purposes including, for such purposes, the making of distributions to organizations that qualify as exempt organizations under section 501(c)(3) of the Internal Revenue Code (“Code”), or the corresponding section of any future federal tax code.

The Board of Directors of the IUF ( “Board”) has adopted the following Gift Acceptance Policy ( “Policy”), effective as of the date written below.

I. Purpose of the Policy.

The purpose of the Policy is to govern the acceptance of charitable contributions by the IUF. The policy also serves as a source of information for potential donors who are interested in supporting the IUF’s activities.

According to the IRS, “A charitable contribution is a donation or gift to, or for the use of, a qualified organization. It is voluntary and is made without getting, or expecting to get, anything of equal value.”

The Policy will apply to all charitable contributions (“Gifts”) received by the IUF for any of its activities that are consistent with its mission to fund projects directed to help the Ukrainian people, with the purpose to Defend, Rebuild, Develop and Prosper.

II. Authority.

The Board retains the ultimate decision-making authority with respect to whether or not a Gift should be accepted. The Board may delegate authority to the President to evaluate, negotiate and decline Gifts, and create and execute contribution agreements with prospective donors in keeping with this policy.

III. Use of Advisors.

The IUF may seek the assistance of legal counsel and/or other advisors in matters relating to the acceptance of Gifts.

The IUF 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. It is the donor’s responsibility to retain the appropriate advisors to represent the donor’s interests.

IV. Types of Gifts.

In the course of its regular fundraising activities, IUF will accept the following Gifts:

  • Outright gifts of cash, cheques and cash equivalents;

  • Cryptocurrency gifts;

  • Gifts of property (including but not limited to real estate, art, computer equipment, jewelry);

  • Publicly traded securities (including stocks, mutual funds and bonds);

  • Bequests, life insurance policies, gifts of residual interest and annuities.

Gifts will be generally accepted from individuals, partnerships, corporations, foundations, government agencies, or other entities.

In the case of publicly traded securities and gifts of property, IUF’s practice is to sell them and convert to cash. A charitable tax receipt will be issued for the amount gained through sale. Gifts of property may be evaluated prior to donation; minimum values may apply. IUF may hold onto Gifts in kind that are deemed to be of immediate or future use to the organization. IUF recognizes that donors may occasionally wish to give property that is not readily marketable. IUF will evaluate such gifts to determine whether there are costs or risks associated with acceptance.

The IUF will consider the following non-exclusive list of factors in deciding whether or not to accept gifts of assets other than cash: (i) the expense involved in owning the asset; (ii) the expense involved in selling the asset; (iii) staff and volunteer time required to manage or sell the asset; (iv) whether owning or selling the asset will expose the IUF to liability; and (v) the marketability of the asset and the cash flow it can be expected to generate.

All decisions to solicit and/or accept potentially controversial Gifts will be made by the Executive Committee of the Board in consultation with the President. The primary consideration will be the impact of the Gift on the IUF.

V. Restrictions on Gifts.

The IUF will not accept Gifts from any donor that:

  • Encroaches on IUF’s integrity;

  • Restricts its liberty of action;

  • Causes damage to its reputation;

  • Places additional costs or burdens on the IUF;

  • Exposes it to uncertain risk or possible liability.

The IUF will not accept Gifts that (a) would result in IUF violating its corporate charter, (b) would result in IUF losing its status as an IRC § 501(c)(3) not-for-profit organization, (c) are too difficult or too expensive to administer in relation to their value, (d) would result in any unacceptable consequences for IUF, or (e) are for purposes outside IUF mission. Decisions on the restrictive nature of a Gift, and its acceptance or refusal, shall be made by the Board of Directors, in consultation with the President.

The IUF reserves the right to refuse or return Gifts to donors at its discretion. Gifts containing restrictions that are inconsistent with, or restrict the IUF ability to carry out the IUF’s mission may be refused or returned.

VI. Conflict of Interest.

Any gift to the IUF that may reasonably be perceived as creating a conflict of interest must be brought to the attention of the Chairman of the Board and President. Under no circumstances may Gifts provide an improper financial or personal benefit to the donor, or to any employee, officer or director of the IUF.

VII. Miscellaneous Provisions.

A. Appraisals. It is the responsibility of the donor to secure and cover the cost of an appraisal whenever an appraisal of a gift is necessary.

B. Gift Acknowledgement. The IUF will acknowledge the receipt of all gifts in writing and in a manner which satisfies the substantiation requirements for the deduction of charitable gifts by individual and corporate donors as set forth in the Code, as applicable.

C. Donor’s Anonymity. The IUF will respect donors’ wishes for anonymity and consult with donors to obtain their permission before public disclosure of their giving.

D. Cost Allocation. Unless otherwise agreed by the parties, the donor and the IUF will each bear their respective costs associated with making or accepting the gift.

XII. Changes to Policy. The Board may amend this Policy from time to time.

This Policy is effective as of April 13, 2022.