GREEN GRANITE ROWING INC.

A 501(c)(3) Tax-Exempt Organization

Gift Acceptance Policy

Version 1.0 – Adopted: August 26, 2026

1.  Background

1.1  Purpose

Green Granite Rowing Inc. (“Green Granite Rowing,” or “GGR") is a tax-exempt nonprofit organization under Section 501(c)(3) of the Internal Revenue Code. This Gift Acceptance Policy establishes the guidelines and procedures by which GGR accepts, processes, and acknowledges charitable contributions. The purpose of this policy is to:

  • Protect the interests of donors and GGR

  • Ensure that all gifts are consistent with GGR's mission and values

  • Provide clear guidance to directors, officers, employees, and volunteers

  • Ensure legal and regulatory compliance

  • Facilitate responsible stewardship of all contributed assets

1.2  Relationship to Dartmouth Men’s Lightweight Rowing Program

A primary purpose of GGR is to raise charitable funds and to grant or otherwise transfer such funds to support the Dartmouth Men’s Lightweight Rowing Program (“D150”) at Dartmouth College. GGR is not a department, agent, or affiliate of Dartmouth College, and Dartmouth College is not responsible for GGR’s activities, governance, or obligations.

In addition to its funding activities, GGR conducts operational activities in furtherance of its charitable purposes, which currently include maintaining a donor database, building and supporting the D150 alumni rowing community, and engaging in related communications and fundraising operations. GGR may, in the future and at the discretion of its Board of Directors, undertake additional activities that further its charitable mission, including (without limitation) operating one or more rowing programs or clubs, employing or engaging coaches, supporting youth or community rowing in the geographic areas where it operates, or undertaking other initiatives consistent with GGR’s purposes. This Gift Acceptance Policy is intended to apply to gifts in support of all such activities, present and future.

2.  Scope and Authority

This policy applies to all gifts and pledges received by GGR, including contributions from individuals, corporations, foundations, estates, and other entities. The Board of Directors has ultimate authority over gift acceptance decisions, including the authority to accept, decline, return, or refund any gift or pledge. Specific acceptance policies applicable to each category of gift and type of pledge are set forth in the body of this Policy.  

GGR does not provide tax, legal, or financial advice. Donors and prospective donors are urged to consult their own tax, legal, and financial advisors regarding the implications of any contemplated gift.

3.  Types of Gifts Accepted

3.1  Cash and Cash Equivalents

GGR accepts outright gifts of cash and cash equivalents, whether in the form of checks, money orders, wire transfers, ACH transfers, credit or debit card payments or transfers of certificates of deposit or other similar cash equivalent items. Checks should be made payable to Green Granite Rowing, Inc. and not to any individual employee, officer, director, volunteer, program participant, or beneficiary. Electronic transfers will be accepted through approved payment platforms designated by GGR.

No prior review or approval by the Board or any officer is required for acceptance of any gift of any cash or cash equivalent item.

3.2  Securities

Subject to certain exceptions (listed below), GGR accepts gifts of marketable securities, which generally do not require Board approval.  “Marketable securities” include stocks listed on a recognized national securities exchange, bonds for which there is an active market or readily determinable value, treasury bills, money market instruments, mutual funds, and exchange-traded funds (ETFs) that are listed on a recognized national securities exchange. Securities will be received via electronic transfer (DTC transfer) to GGR's designated brokerage account. Donors should contact GGR to obtain the DTC participant number and account number prior to initiating a transfer.

It is the policy of GGR to sell all donated securities promptly upon receipt, generally within three (3) business days, unless the Board authorizes a longer holding period or GGR’s investment advisor or similar service provider indicates that a longer holding period would be more appropriate to obtain the best price for such securities upon disposition thereof. GGR does not generally retain donated securities as investments. This sell-immediately policy protects GGR from market risk and is consistent with GGR's fiduciary duty.

The value of a donated security for gift acknowledgment purposes is determined by the donor and reported by the donor on IRS Form 8283 (if applicable). GGR will not assign a dollar value in its gift acknowledgment letter.

No prior review or approval by the Board or any officer is required for acceptance of any gift of any marketable securities unless: (i) such securities are subject to any restrictions on transfer or sale imposed by law or contract or are not otherwise readily convertible to cash; or (ii) the total value of marketable securities gifted by any donor in any fiscal year exceeds $250,000. 

3.3  Real Property

Gifts of real estate, including residential, commercial, or undeveloped land, may be accepted at the discretion of the Board of Directors. Prior to acceptance, GGR will conduct appropriate due diligence, which may include:

  • An independent appraisal

  • An environmental assessment

  • A title search

  • A review of carrying costs, liens, and encumbrances

GGR will not accept real property that presents unacceptable legal, financial, or reputational risk, including any material environmental exposure, debt, litigation risk or other material liability. If a member of the Board holds any pecuniary interest in any real estate, such Board member shall recuse themselves from any vote of the Board relating to the approval of any gift of such real estate.

3.4  In-Kind Gifts (Non-Cash Goods and Services)

GGR may accept gifts of goods and services (in-kind contributions) that directly support its programs and operations so long as the aggregate value of such gifts from any one donor do not exceed $5,000 in any particular fiscal year. By way of example and without limitation, in-kind contributions that may be accepted include software licenses or platform access, database and donor-management services, communications and design services, professional services, and similar contributions that reduce GGR’s operating costs or expand its operational capacity. In-kind gifts will be accepted only when they are consistent with GGR's mission and when the cost of acceptance does not exceed the benefit. GGR will acknowledge in-kind gifts but will not assign a value in the acknowledgment letter; valuation is the donor's responsibility.

For the avoidance of doubt, GGR does not, as of the date of adoption of this Policy, operate a rowing program or own rowing equipment. GGR therefore does not currently intend to accept in-kind contributions of rowing shells, oars, ergometers, launches, trailers, or similar equipment. Donors wishing to contribute such equipment in support of the Dartmouth Men’s Lightweight Rowing Program are encouraged to contact Dartmouth College’s development office or the program’s coaching staff directly. GGR may, in its discretion and with appropriate coordination, facilitate introductions between such donors and Dartmouth College.

3.5  Planned Gifts and Bequests

GGR welcomes planned gifts, including bequests through a donor's will or trust, beneficiary designations on retirement accounts or life insurance policies, and designations of GGR as a beneficiary of a charitable remainder trust or other split-interest trust. Donors considering a planned gift are encouraged to consult their own legal and financial advisors. GGR will work with donors and their advisors to facilitate planned giving arrangements.

GGR does not, as of the date of adoption of this Policy, offer charitable gift annuities. The administration of charitable gift annuities is subject to state-by-state registration requirements, reserve and reporting obligations, and actuarial administration that GGR is not presently equipped to undertake. The Board of Directors may revisit this determination in the future. GGR may, with appropriate professional advice, accept gifts that require GGR to act solely as a passive beneficiary, including designation as the remainder beneficiary of a charitable remainder trust administered by a third-party trustee.

3.6  Gifts Not Accepted

GGR reserves the right to decline or return any gift. The following gifts will generally not be accepted:

·       Gifts that are illegal or that impose obligations inconsistent with GGR's mission

·       Gifts that would jeopardize GGR’s 501(c)(3) status (or equivalent status under state or local law);

·       Gifts of non-marketable securities without prior Board approval. If a member of the Board holds any pecuniary interest in a company or other entity, such Board member shall recuse themselves from any vote of the Board relating to the approval of any gift of non-marketable securities issued by such entity. 

·       Gifts of marketable securities that are subject to any restrictions on transfer or sale imposed by law or contract or are not otherwise readily convertible to cash, absent Board approval. The Board shall consider such factors as it deems appropriate, including determining the expected holding period for such gift and whether holding such gift creates unacceptable reputational, legal, tax, operational or other burdens. 

·       Gifts of marketable securities by a donor where the total value of marketable securities gifted by such donor in any fiscal year exceeds $250,000, absent Board approval. The Board shall consider such factors as it deems appropriate, including determining whether holding such gift creates any unacceptable reputational, legal, tax, operational or other burdens.

·       If the aggregate value of in-kind gifts from any one donor exceed $5,000 in any particular fiscal year,[1] the Board shall consider such factors as it deems appropriate, including whether GGR can use, sell, invest, or dispose of the gift, whether the gift creates debt, liability, unrelated business taxable income, tax reporting obligations, environmental risk, insurance costs, storage costs, or maintenance costs, whether the gift requires professional appraisal, environmental review, title review, investment review, or legal review, whether the gift raises conflict of interest, related-party, private benefit, or private inurement concerns, whether the gift is marketable or usable within a reasonable period, and whether the net benefit of the gift justifies the cost and risk of acceptance. If a member of the Board holds any pecuniary interest in such in-kind gift, such Board member shall recuse themselves from any vote of the Board relating to the approval of any gift of such in-kind gift.

  • Gifts of tangible personal property that are difficult to liquidate or that impose significant carrying costs, including storage, transportation, insurance, maintenance, authenticity and sale costs.

  • Gifts accompanied by conditions that are so narrowly restrictive that GGR cannot reasonably administer it or that would compromise GGR's independence.

  • Gifts from donors whose activities conflict with GGR's values or that could expose GGR to unacceptable reputational risk.

  • Gifts that require GGR to make financial guarantees or investment commitments.

  • Gifts that require GGR to endorse a product, service, candidate, political party, or private business in a manner inconsistent with law or policy.

  • Gifts that conflict with the GGR’s conflict of interest, whistleblower, investment, document retention or other relevant governance policies.

  • Gifts that may generate unrelated business taxable income or other adverse tax consequences (as determined in consultation with GGR’s tax advisor).

  • Cryptocurrency and other digital assets, unless and until the Board of Directors determines that GGR has the capacity to evaluate, accept, custody, and liquidate such gifts and adopts written procedures for doing so.

GGR has no obligation to (and does not) conduct pre-acceptance investigations of individual donors. GGR relies on standard payment processing for ordinary-course cash and electronic gifts and does not require donors to submit information beyond what is needed to process the gift and provide an acknowledgment. Nothing in this Section 3.6 is intended to create or imply a duty on the part of GGR to investigate any donor prior to acceptance of a gift.

Notwithstanding the foregoing, if at any time after acceptance the Board of Directors determines, in its reasonable judgment, that (i) a gift was wrongfully obtained by the donor, (ii) retention of the gift would materially harm GGR’s reputation or its relationship with Dartmouth College, the Dartmouth Men’s Lightweight Rowing Program, or the broader rowing community GGR serves, or (iii) continued public recognition of the donor would be inconsistent with GGR’s values, the Board may, in its discretion: (a) return all or a portion of the gift to the donor or to an alternative charitable recipient consistent with applicable law; (b) decline to provide, or rescind, any public recognition of the donor, including donor listings, naming opportunities, or similar acknowledgments; and (c) take such other actions as the Board deems appropriate.

As an aspirational matter, and recognizing that GGR’s charitable purposes are closely aligned with those of Dartmouth College, GGR endeavors not to knowingly accept gifts from sources that Dartmouth College would itself decline. This sentence states an aspiration and a guiding principle only; it is not intended to create a binding compliance standard, a duty to inquire of Dartmouth College in advance of accepting any particular gift, or a basis on which GGR would be deemed to have violated its own policy.

3.7  Pledges

A pledge is a written promise by a donor to make a future contribution to GGR. GGR distinguishes between unconditional pledges (promises that depend only on the passage of time or on the donor’s own future payment) and conditional pledges (promises that depend on a future and uncertain event outside the donor’s control).  The recording and recognition of pledges — including the timing of revenue recognition, the treatment of conditional pledges and matching or challenge gifts, the valuation of multi-year pledges, and the establishment of allowances for uncollectible pledges — will be determined by GGR in consultation with its accountant or auditor and in accordance with applicable accounting standards and relevant law. As a matter of governance, GGR will not rely on conditional pledges (including matching pledges and challenge gifts) for budgeting, planning, or fundraising representations until the underlying conditions have been substantially met (as determined in consultation with GGR’s accountant or auditor and in accordance with applicable accounting standards).

GGR will accept pledges subject to the following requirements:

  • Pledges must be documented in writing and signed by the donor and GGR. The pledge documentation must specify the total amount, the payment schedule, any donor-imposed restrictions, any conditions that must be satisfied prior to, or after, receipt of the pledged amount, whether the pledge is conditional, recognition terms, if any, consequences of nonpayment, if any, and a donor acknowledgment that the donor has had the opportunity to consult with independent advisors. The terms of each conditional pledge agreement (i.e., any pledge that contains any donor-imposed restrictions or conditions) must be reviewed for compliance with the restrictions set forth in Section 4 prior to the execution thereof. A commitment communicated only verbally is not a pledge under this Policy unless and until it is reduced to a writing satisfying the criteria above and signed by the donor.

  • The payment period for a pledge will generally not exceed five (5) years from the date the pledge is made. Longer payment periods require Board approval.

  • Multi-year unconditional pledges will be recorded in accordance with applicable accounting standards, in consultation with GGR’s accountant or auditor.

  • GGR’s treasurer (or their designee) will review outstanding pledges at least annually and will establish an allowance for uncollectible pledges based on GGR’s collection experience and the specific facts and circumstances of each pledge.

  • GGR will provide reasonable reminders to donors in accordance with the agreed payment schedule. If a donor becomes unable to fulfill a pledge, GGR will work with the donor in good faith to modify, extend, or release the pledge. GGR will not pursue legal action to enforce an unpaid pledge except in extraordinary circumstances and only with prior approval of the Board of Directors.

  • Where a pledge is the basis for a naming opportunity or other public recognition, the underlying pledge agreement will specify the consequences of non-payment, including any modification or removal of the recognition.

A pledge itself is not a tax-deductible contribution. The donor may claim a charitable deduction only when, and to the extent that, payment against the pledge is actually made.

3.8  Matching Gifts and Challenge Gifts

GGR welcomes matching gifts. This Section 3.8 addresses two distinct arrangements: (a) employer and similar matching gift programs, and (b) matching pledges and challenge gifts in which a lead donor commits to contribute on the condition that GGR raise qualifying gifts from other donors.

Employer and Similar Matching Gift Programs. GGR will cooperate with employer matching gift programs and similar third-party matching programs by furnishing the documentation reasonably required to verify the underlying gift, including GGR’s 501(c)(3) determination and Employer Identification Number. The matched portion is treated as a separate contribution from the matching entity, not from the original donor, for IRS substantiation and acknowledgment purposes. The donor’s acknowledgment letter will reflect only the donor’s personal contribution; the matching entity will receive its own acknowledgment when its gift is received. The matched portion is recognized as revenue when received from the matching entity. For internal donor recognition purposes (such as recognition tiers and giving societies), the donor may receive soft credit for the matched amount at the discretion of GGR.

Matching Pledges and Challenge Gifts. A matching pledge or challenge gift is a commitment by a lead donor to contribute a specified amount on the condition that GGR raise qualifying gifts from other donors. Because such a commitment depends on a future and uncertain event, it is treated as a conditional pledge under Section 3.7 and is recognized as revenue only when the match conditions are substantially met (as determined in consultation with GGR’s accountant or auditor and in accordance with applicable accounting standards). Each matching pledge or challenge gift agreement must be documented in writing and must specify, at minimum:

  • The total amount of the match and the match ratio (e.g., one-to-one, two-to-one);

  • The criteria for qualifying gifts (for example, gifts received within a specified date range, gifts above a stated minimum, gifts from new donors, or pledges in addition to outright gifts);

  • The deadline by which qualifying gifts must be received and/or the criteria must be met;

  • The treatment of a partial match (whether the lead donor will contribute pro rata if the full match is not achieved, or whether the commitment lapses entirely); and

  • Any restrictions imposed by the lead donor on the use of the matched funds.

Fundraising communications referencing a match (for example, “your gift will be matched”) must accurately describe the match terms, including the match ratio, any cap, any qualifying-gift criteria, and any deadline. The directors, officers, employees, and volunteers responsible for the campaign shall each be responsible for ensuring that public communications conform to the underlying match agreement(s), and for communicating this requirement to any other person involved in the campaign.

GGR is not obligated to return or refund prior contributions to other donors solely on the basis of a lead matching donor's failure to fulfill the underlying match commitment, provided GGR has not made a contrary representation in its fundraising communications.

3.9  Donor-Advised Funds and Qualified Charitable Distributions

GGR accepts grants from donor-advised funds (“DAFs”) sponsored by community foundations, financial institutions, and other qualified sponsoring organizations. The acknowledgment of a DAF grant will be addressed to the sponsoring organization and will reference the donor-advisor where provided. Because DAF grants are made from funds owned by the sponsoring organization rather than by the donor-advisor, the donor-advisor is not entitled to a charitable contribution acknowledgment from GGR for the DAF grant itself.

Under applicable U.S. tax law, a DAF grant may not be used to satisfy a legally binding personal pledge of the donor-advisor or to provide more than an incidental benefit to the donor-advisor. GGR’s pledges (as described in Section 3.7) are intended as non-binding statements of charitable intent and are not legally enforceable obligations of the donor. Accordingly, GGR will generally accept DAF grants in satisfaction of a donor-advisor’s pledge to GGR, provided that no more-than-incidental benefit (such as event tickets, auction items, preferred seating, or memberships with quantifiable value) flows back to the donor-advisor in connection with the grant. Donors who wish to satisfy a pledge through a DAF grant are encouraged to consult their DAF sponsor and their own tax advisor.

GGR also accepts Qualified Charitable Distributions (“QCDs”) made directly from a donor’s individual retirement account (“IRA”) by the IRA custodian, in accordance with Section 408(d)(8) of the Internal Revenue Code. GGR will provide the donor with a written acknowledgment confirming receipt of the distribution and stating that no goods or services were provided in exchange. As with DAF grants, no more-than-incidental benefit may be provided to the donor in connection with a QCD.

4.  Donor-Imposed Restrictions

GGR is currently operated primarily by volunteers and has limited administrative capacity to track and report against complex donor-imposed restrictions, whether applied to current gifts or future conditional pledges of gifts. For this reason, GGR generally does not accept donor-imposed restrictions on the use of gifts (including any gifts made under a conditional pledge) beyond the permitted purposes set forth below. In general, GGR may accept restricted gifts only if the restriction is charitable, consistent with GGR’s mission, lawful, clear and administratively feasible, financially prudent, and not inconsistent with GGR’s governing documents or policies. GGR will not accept a restricted gift that gives the donor control over GGR’s operations, staffing, vendors, grant recipients, investment decisions, program decisions, or charitable assets.

Permitted purposes. Subject to the right of any officer of GGR to decline or refer a particular gift or pledge to the Board for review, gifts (including any gifts made under a conditional pledge) designated for any of the following permitted purposes may be accepted without further Board approval:

  • General support of GGR’s mission;

  • General operating support of GGR, including (without limitation) administrative, technology, communications, accounting, legal, insurance, and fundraising expenses;

  • Any specific giving program or fundraising campaign that the Board of Directors has authorized (for example, an annual giving program, a matching or challenge campaign, or a campaign to support a particular initiative);

  • Any Board-designated reserve fund, which may include funds established to provide for the long-term financial stability of GGR and/or the sustained support of its charitable purposes.

For the avoidance of doubt, “general support of GGR’s mission” may include the funding of GGR’s operating expenses or other activities, and does not require immediate or full pass-through of any gift to Dartmouth College or to any other person or entity.

Other restrictions. Any donor-imposed restriction outside the permitted purposes listed above—including (without limitation) restrictions designating a gift for a specific individual, a specific season or year, a specific piece of equipment, a specific coach, or any other purpose not listed above—requires prior approval of the Board of Directors. Before accepting any such gift requiring prior approval, the Board shall consider such factors as it deems appropriate, including whether any donor restriction is clear, lawful, feasible, and administratively reasonable and whether the gift raises conflict of interest, related-party, private benefit, or private inurement concerns.

Prospective donors are encouraged to discuss any proposed restriction with GGR before making the gift or conditional pledge to confirm that the restriction can be accommodated.

Board-designated funds. The Board of Directors may, by resolution, designate all or any portion of GGR's funds for a particular purpose, including the establishment of a long-term reserve fund intended to provide for GGR's sustained financial stability and the ongoing support of its charitable purposes over multiple years. Unlike donor-imposed restrictions, Board-designated funds may be modified, redesignated, or undesignated by subsequent action of the Board, subject to GGR’s bylaws and other governing documents, as applicable. GGR may adopt one or more separate policies (including an investment policy) governing the management of any Board-designated long-term funds.

Variance. If a donor-imposed restriction or condition becomes, in the judgment of the Board of Directors, impractical, unnecessary, incapable of fulfillment, impracticable, unlawful, wasteful, impossible, or no longer consistent with GGR’s charitable purposes, the Board may either: (i) seek to modify the restriction in a manner consistent with the donor’s charitable intent and applicable law; or (ii) apply the affected gift to a related purpose that, in its judgment, most closely approximates the donor’s original charitable intent and applicable law. 

Where reasonably practicable, GGR will first consult with the donor or the donor’s authorized representative. Where the donor is deceased, the donor’s estate has been closed, or such consultation is otherwise not reasonably practicable, the Board may exercise its judgment under this paragraph without such consultation. The Board may delegate any determination under this paragraph to a committee thereof.

Each agreement containing a donor-imposed restricted shall include provisions setting forth the foregoing principles.

Unrestricted gifts are preferred, as they allow GGR the greatest flexibility in deploying resources strategically.

5.  Valuation of Gifts

For gift acknowledgment purposes:

  • Cash gifts are acknowledged at face value.

  • Pledges (whether unconditional or conditional, including matching pledges and challenge gifts) are recorded and recognized in accordance with applicable accounting standards, as determined by GGR in consultation with its accountant or auditor.

  • Marketable securities are acknowledged by the number of shares/units and the name of the security; GGR does not assign or state a dollar value.

  • Non-cash gifts valued over $500 require the donor to complete IRS Form 8283. Gifts over $5,000 (other than marketable securities) generally require a qualified appraisal by the donor.

  • GGR will provide a qualified appraisal for charitable deduction purposes only when required by law and authorized by the Board.

6.  Gift Acknowledgment

GGR will provide a written acknowledgment to every donor for all contributions in a timely manner, and no later than January 31 of the year following the year of the gift. Acknowledgment letters will include:

  • The name of GGR

  • The date the gift was received

  • A description of the gift (e.g., number of shares and name of security; description of in-kind item)

  • For cash gifts, the dollar amount received

  • A statement that no goods or services were provided in exchange for the contribution (or a description and good-faith estimate of value of any goods or services provided)

Acknowledgment letters will NOT include a dollar valuation for non-cash gifts. It is the donor's responsibility to determine and report the fair market value for tax purposes.

A written acknowledgment is required by the IRS for any single contribution of $250 or more in order for the donor to claim a charitable deduction.

Acknowledgment of pledges and matching gifts is governed by the following additional rules. GGR will provide a written confirmation of each pledge upon receipt of signed pledge documentation; this confirmation is not a tax-deduction acknowledgment. GGR will endeavor to acknowledge each payment received against a pledge in a manner that, where reasonably practicable, references the underlying pledge. GGR's failure to reference a particular pledge in an acknowledgment does not affect the donor's right to claim a charitable deduction for the payment, which is governed by the donor's records and applicable IRS rules. For matching gifts, the donor receives an acknowledgment only for the donor’s own gift, and the matching entity receives a separate acknowledgment for its matching contribution when received.

For the avoidance of doubt, written acknowledgments of gifts or pledges may be delivered by letter, email, or other electronic means.

7.  Conflicts of Interest

Directors, officers, employees and volunteers involved in gift acceptance decisions must disclose any personal, financial, or other interest in a proposed gift transaction. Any individual with a conflict of interest shall recuse themselves from the relevant discussion and vote, in accordance with GGR’s Conflict of Interest and Related Party Transaction Policy (as such policy may be amended, amended and restated, or otherwise modified from time to time).

8.  Donor Confidentiality

GGR respects donor privacy. Donor information will be used by GGR for organizational purposes, including the acknowledgment, stewardship, and recognition of gifts, the administration of fundraising programs, the preparation of required tax and regulatory filings, and the coordination of charitable activities in support of the Dartmouth Men’s Lightweight Rowing Program. Donor information will not be sold or traded. Subject to a donor’s right to request anonymity as described below, donor information (including the donor’s name, contact information, and giving history) may be shared with Dartmouth College and with the Dartmouth Men’s Lightweight Rowing Program for the purposes of donor recognition and the coordination of charitable activities supporting the program.

Public recognition is the default. Unless a donor has requested anonymous treatment in accordance with this Policy, GGR may publicly recognize donors for their contributions, including in donor lists, on GGR’s website, in communications with the D150 community, in printed or electronic materials provided to Dartmouth College, and in similar customary forms of donor acknowledgment. Prospective donors should assume that gifts will be publicly recognized in these and similar ways unless the donor expressly opts for anonymous treatment.

Anonymity at the donor’s request. A donor may request that a particular gift, or the donor’s giving generally, be treated as anonymous. An anonymous-treatment request will be recorded in GGR’s donor-management system, and GGR will use reasonable efforts to honor the request, including (where applicable): (i) omitting the donor’s name from published donor lists and recognition materials; (ii) declining to share the donor’s name with Dartmouth College or the D150 program for recognition purposes; and (iii) limiting internal references to the donor to those reasonably necessary for stewardship, accounting, and compliance.

Limits of anonymity. GGR cannot guarantee anonymity in all circumstances. In particular: (i) GGR is required by the Internal Revenue Service to maintain identifying information for substantial donors and may be required to report such information on Schedule B of Form 990; (ii) GGR must provide written acknowledgments to donors for charitable deduction purposes; (iii) GGR may be required to disclose donor information in response to subpoenas, court orders, audits, or other lawful process; and (iv) GGR’s commitment to anonymity does not extend to internal record-keeping reasonably necessary for legal, governance, accounting, and audit purposes. 

9.  Fees and Costs

All costs associated with the evaluation, acceptance, and liquidation of a gift (e.g., appraisal fees, legal fees, brokerage commissions, title insurance, environmental assessments) will generally be borne by GGR unless otherwise negotiated with the donor prior to acceptance. GGR reserves the right to decline a gift if associated costs are deemed excessive relative to the benefit.

10.  Amendment and Review

This Gift Acceptance Policy shall be reviewed by the Board of Directors at least once every three (3) years, and at such other times as the Board determines circumstances warrant. Circumstances likely to warrant review include, by way of example and without limitation: (i) a material change in GGR's operations, mission, or scope of activities; (ii) the launch of a new or materially expanded fundraising program or campaign — provided that the continuation, on substantially the same terms, of a recurring program (such as an annual giving campaign) does not by itself require review; (iii) the receipt of, or a credible offer of, a material non-routine gift not clearly contemplated by this Policy; or (iv) a change in applicable federal or state law or accounting standards that affects gift acceptance, valuation, or acknowledgment. This Policy may be amended by the Board at any duly called meeting or by unanimous written consent of the Board.

11. Recordkeeping and Internal Controls

GGR shall maintain accurate records of all gifts in accordance with its document retention policy, accounting procedures, donor records procedures, and applicable law. Gift records should include, as applicable:

  1. donor name and contact information; 

  2. date of gift; 

  3. gift amount or description; 

  4. restrictions;

  5. gift agreement; 

  6. acknowledgment letter; 

  7. appraisal, Form 8283, or Form 8282 records, if applicable; 

  8. Board or committee approvals; 

  9. correspondence with the donor; 

  10. disposition records for noncash gifts; and 

  11. stewardship or reporting obligations. 

Cash handling shall follow appropriate internal controls, including segregation of duties, timely deposits, reconciliation, and review.

[1] For the avoidance of doubt, this restriction applies only to in-kind gifts for which a donor intends to obtain a tax benefit and does not apply to other donated services, volunteer work, or other in-kind contributions for which no tax benefit is applicable.

Give Now