Run: Charitable Donation and Sponsorship Policy

This policy establishes a consistent process for charitable donations, sponsorships, and matching gift requests. It is intended to: - Support community engagement and responsible corporate giving. - Ensure requests are reviewed using objective, documented criteria. - Reduce conflicts of interest and protect the organization’s reputation. - Promote equity in access to giving opportunities across employees, departments, and locations. - Support compliance with applicable employment and anti-discrimination laws, including **Title VII of the Civil Rights Act of 1964** and EEOC guidance. This policy is not intended to create an entitlement to funding or sponsorship.

This policy applies to all employees, managers, executives, HR, Finance, Legal, and any other person authorized to request, approve, administer, or report charitable donations, sponsorships, or matching gifts on behalf of the organization. It applies to: - Corporate charitable donations. - Event, program, and cause sponsorships. - Employee matching gift programs. - In-kind donations of goods or services. - Requests submitted by employees, business units, or external organizations. **California employees:** any local approval, payroll, or leave-related implications must be reviewed for compliance with California wage-and-hour and anti-retaliation requirements, as applicable. **All jurisdictions:** where local law provides greater protection or imposes additional requirements, the organization will follow the law that is most protective or otherwise applicable.

- **Charitable donation:** A monetary or in-kind contribution made to a qualified nonprofit or charitable organization. - **Sponsorship:** A contribution made in exchange for recognition, branding, event placement, or similar promotional value. - **Matching gift:** An employer contribution that matches an eligible employee’s personal donation, subject to program rules. - **In-kind donation:** A non-cash contribution such as products, services, equipment, or volunteer support. - **Qualified organization:** An organization that meets the eligibility criteria in this policy and any applicable legal or tax requirements. - **Conflict of interest:** A situation in which a personal, financial, family, or business relationship could influence, or appear to influence, a giving decision. - **Documented warning:** A written notice that a policy requirement was not met and that corrective action may be taken if the issue continues. - **PIP:** A performance improvement plan; for purposes of this policy, a PIP does not guarantee approval of any request and must not be used as a condition for charitable giving decisions. - **Reasonable accommodation:** A workplace adjustment required under the ADA; charitable giving decisions must not be used to reward or penalize employees for requesting or using a reasonable accommodation. - **Interactive process:** The good-faith dialogue used to evaluate a reasonable accommodation request under the ADA.

The organization may support charitable causes and sponsorships when the request aligns with business values, community impact goals, budget availability, legal requirements, and this policy. The organization will make giving decisions using objective criteria and documented review. Decisions must not be based on an employee’s protected characteristic, protected activity, union activity, request for leave, request for accommodation, or any other factor prohibited by law. The organization will not approve donations or sponsorships that: - Create an actual or apparent conflict of interest. - Violate law, tax rules, sanctions, anti-bribery rules, or internal controls. - Are intended to influence a government official or business decision improperly. - Discriminate against a protected class under **Title VII**, the **ADA**, the **ADEA**, or other applicable law. - Interfere with employee rights under the **NLRA Section 7**, including protected concerted activity. Matching gifts, if offered, are discretionary and subject to separate program rules, funding limits, and verification requirements.

Requests will be evaluated against the following criteria: 1. **Organizational alignment** — The request supports the company’s mission, community priorities, or brand values. 2. **Qualified recipient** — The recipient is a legitimate organization and, where required, can provide tax or registration documentation. 3. **Purpose and use of funds** — The request clearly states how funds, goods, or services will be used. 4. **Budget availability** — Funding is available within the approved annual budget or departmental allocation. 5. **Risk review** — Legal, compliance, sanctions, reputational, and anti-corruption risks have been assessed. 6. **Equity review** — The request is evaluated using the same standards regardless of location, department, manager, or employee status. 7. **No prohibited purpose** — The request is not tied to political contributions, personal benefit, retaliation, or any unlawful purpose. Approval authority: - Requests up to the department threshold may be approved by the department head and Finance. - Requests above the threshold, high-visibility sponsorships, or requests with elevated risk require Legal and Executive Leadership approval. - Any exception to this policy must be documented and approved in writing by Legal or the designated policy holder. **Good-faith review** is required for every request. Approval decisions must be documented with the reason for approval or denial.

If the organization offers matching gifts or sponsorship support, the following rules apply: - Matching gifts are available only to eligible employees and only for eligible organizations and donation types. - The organization may set annual, per-employee, per-organization, or per-campaign limits. - Matching is not available for donations that are reimbursed, required by employment, or made in exchange for personal benefit. - Sponsorships must have a documented business or community purpose and may include recognition, event attendance, or brand placement only if approved in advance. - The organization will monitor participation to identify disparities by location, department, or employee group and may adjust outreach or process steps to improve equitable access. - Managers must not favor requests from favored employees, high-performing employees, or employees who are not on a PIP over similarly situated employees. - Requests must not be approved or denied based on race, color, religion, sex, pregnancy, sexual orientation, gender identity, national origin, age, disability, genetic information, veteran status, or any other protected characteristic. **Equity considerations:** The organization will provide the same application path, review standards, and documentation requirements to all eligible requestors. If a department has historically received more support than others, Finance or HR may implement allocation controls or outreach measures to improve fairness.

1. **Submit request** — The requester completes the donation, sponsorship, or matching gift form with the recipient name, purpose, amount, dates, and supporting documentation. 2. **Initial screening** — HR, Finance, or the designated policy holder confirms completeness, eligibility, and budget availability. 3. **Conflict check** — The reviewer identifies any personal, family, vendor, or business relationship that could create a conflict of interest. 4. **Legal/compliance review** — Required for higher-value, high-risk, cross-border, government-adjacent, or unusual requests. 5. **Approval or denial** — The decision is recorded in writing, including any conditions, limits, or rationale. 6. **Payment or fulfillment** — Approved donations are processed through Finance or the approved vendor workflow. 7. **Recordkeeping** — Supporting documents, approvals, receipts, and recipient confirmations are retained according to the records schedule. 8. **Post-event reporting** — Sponsorships and major donations are reviewed after completion to confirm deliverables, recognition, and budget use. Requests that are incomplete, outside budget, or inconsistent with this policy may be denied without further review.

- **Policy holder:** Owns the policy, approves exceptions, and ensures annual review. - **HR:** Supports equity review, employee communications, and policy acknowledgements. - **Finance:** Confirms budget, processes payments, and maintains financial controls. - **Legal/Compliance:** Reviews legal risk, conflicts, sanctions, tax, and anti-bribery issues. - **Managers:** Submit or endorse requests only when there is a legitimate business or community purpose and no conflict of interest. - **Employees:** Provide accurate information and disclose any relationship that could affect review. - **Executive Leadership:** Approves high-value, strategic, or sensitive requests. Managers and reviewers must act in good faith and must not retaliate against any employee for submitting, questioning, or declining to support a request.

The organization will maintain records of requests, approvals, denials, payments, receipts, and post-event reports in accordance with its retention schedule and any applicable tax or audit requirements. Records must be accurate, complete, and accessible only to authorized personnel. Any personal data collected for this policy must be handled in accordance with privacy requirements, including applicable **GDPR** or **CCPA** obligations where relevant. Violations of this policy may result in corrective action up to and including a documented warning, removal of approval authority, repayment or reversal of an improper transaction where permitted by law, and further disciplinary action up to termination. Nothing in this policy limits rights protected by law, including the right to engage in protected concerted activity under the **NLRA** or to request a reasonable accommodation under the **ADA**.

This policy will be reviewed at least annually and updated as needed to reflect changes in law, tax guidance, business priorities, budget controls, or equity findings. The policy holder will document revisions, effective dates, and any jurisdiction-specific changes. **California employees:** any revisions affecting payroll deductions, reimbursements, or employee-facing program terms must be reviewed for California-specific compliance before implementation. Employees will be notified of material changes and may be required to re-acknowledge the policy.