Wellesley College Gift Acceptance Policy

Introduction

The mission of Wellesley College is to provide an excellent liberal arts education for women who will make a difference in the world. In furtherance of this mission, the College welcomes the support of its alumnae and friends who share their time, talent and financial resources. The College is firmly committed to the principles set forth in this policy regarding charitable giving to the College. The College encourages the cultivation, solicitation and stewardship of charitable gifts in accordance with all applicable laws and policies.

This policy shall apply to all gifts to the College and is intended to offer a high-level governing policy and set of guiding principles. This policy shall be implemented and overseen by the Gift Review Committee, as set forth in further detail below. This policy shall be reviewed periodically by the Board of Trustees in consultation with the General Counsel for the College and may be amended by the Board of Trustees at any time and from time to time.

Guiding Principles of Gift Acceptance

Gifts to the College will be determined to be acceptable based on the following principles of gift acceptance (the “Principles of Gift Acceptance”):

• Support of Mission. All gifts must be in furtherance of the College’s mission to provide an excellent liberal arts education for women who will make a difference in the world. This Policy is designed to ensure that all gifts to or for the use of the College are structured to benefit the College while ensuring fidelity to donor intent.
• College Reputation and Core Values. The College will not accept a gift which may damage or compromise the College’s reputation, is not in the best interests of the College community, or is not consistent with the College’s core values. The College will not knowingly encourage any gifts that are inappropriate in light of the donor’s disclosed personal or financial situation.
• Academic Integrity. No gift may violate the College’s integrity and commitment to academic freedom.
• Burden on the College. No gift may impose an unreasonable or undue financial, legal or administrative burden on the College or its faculty, staff, students or other resources.
• Right to Refuse and Rescind Gifts. The College has the right to refuse any gift from any donor and the right to rescind its acceptance of a gift that does not adhere to these Principles of Gift Acceptance or does not meet the criteria set forth in this Policy or the Gift Acceptance Guidelines promulgated by the Gift Review Committee as set forth below.
• Advice to Donors. While College personnel may work with donors to further their charitable, financial and estate planning goals, donors are ultimately responsible for ensuring that the proposed gift furthers those goals. Donors will be encouraged to seek the advice of independent legal, tax and financial counsel in the gift planning process. It is not within the province of the College or its staff to give legal, accounting, tax or other advice to donors or prospective donors.
• Confidentiality. Information concerning all transactions between a donor and the College shall be held by the College in confidence and may be disclosed only with the permission of the donor or the donor’s designee or as required by law. To the fullest extent permitted by law, the College shall respect the wishes of any donor offering anonymous support and shall implement reasonable procedures to safeguard such donor’s identity.
• Gift Restrictions. All donor-imposed gift restrictions shall be documented in writing, shall be consistent with this Policy and the Principles of Gift Acceptance, and shall be subject to review as provided herein. The Vice President for Development and the Development Office shall be responsible for assuring compliance with all restrictions applicable to accepted gifts.

Responsibility for Cultivation and Acceptance of Gifts

The President and Board of Trustees of the College have overall responsibility for the acceptance of all gifts to the College and for assuring compliance with the requirements of this Policy and delegate that responsibility as set forth herein.

The President and the Board of Trustees delegate primary responsibility for the fundraising operations of the College to the College Development Office, under the leadership of the Vice President for Development. The Vice President for Development oversees all fundraising operations at the College and ensures that all departments engaged in fundraising are acting in accordance with institutional policies and guidelines and in furtherance of these Principles of Gift Acceptance. All College-based projects, programs, or initiatives that include fundraising solicitations of any organization or individuals must be approved by the Vice President for Development.

The President and Board of Trustees delegate primary responsibility for the review and acceptance of gifts and for assuring compliance with the requirements of this Policy to the Vice President for Development and the Gift Review Committee as set forth herein.

The following types of gift shall be subject to review by, and require the approval of, the Gift Review Committee:

• Gifts with a value in excess of $10 million;
• Gifts of assets other than cash or publicly traded securities with a value in excess of $100,000;
• Gifts that would be paid over a period of greater than five years;
• Gifts with significant donor restrictions, as determined by the Vice President for Development; Gifts that involve a naming opportunity or that would involve use of the College’s name;
• Gifts that require a financial commitment by the College (other than in the context of a charitable gift annuity, pooled income fund, charitable remainder trust or charitable lead trust);
• Gifts that could have reputational implications for the College or otherwise be considered to be inconsistent with the Principles of Gift Acceptance;
• Gifts that may have real or perceived conflicts of interest for the donor, the College, or any officer or Trustee of the College;
• Gifts from corporations of $500,000 or more;
• Any proposed redirection of a restricted gift or return of a gift to a donor due to circumstances that have made use of the gift for the intended purposes impractical or impossible to achieve;
• Gifts that require an exception to the Gift Acceptance Guidelines promulgated by the Gift Review Committee; and
• Gifts from international entities not already known to or affiliated with the College and gifts of $500,000 or more from any international sources, including alumnae and parents.

All other gifts shall be subject to review by, and may be accepted on behalf of the College by, the Vice President for Development.

Gift Review Committee

The Gift Review Committee shall have the responsibility for review and approval of gifts as set forth above, consistent with this Policy and the Principles of Gift Acceptance.

The gift review committee shall consist of the Chair of the Board of Trustees of the College, the Chair of the Development Committee of the Board of Trustees of the College, the President of the College, the Vice President for Development, the Provost, and Chief Financial Officer. The General Counsel of the College shall participate in meetings of the Committee but shall not be a voting member of the Committee.

Gifts that require a financial commitment by the College (other than in the context of a charitable gift annuity, pooled income fund, charitable remainder trust or charitable lead trust) shall require the consent of the Chief Financial Officer of the College in addition to approval by the Gift Review Committee.

In cases where a proposed gift would benefit a specific program, department or unit of the College, the Gift Review Committee is encouraged to consult with leadership of that program, department or unit in evaluating the proposed gift. In cases where a proposed gift would benefit from additional faculty input, the Gift Review Committee is encouraged to consult with the immediate past chair of the Budget Advisory Committee. The Gift Review Committee is also encouraged to consult with members of the College community who may have special expertise to offer with respect to any particular proposed gift.

The committee shall meet at least quarterly and shall hold special meetings as needed to review specific gifts. Any committee member having a conflict of interest with respect to a particular gift shall recuse herself or himself from voting with respect to that gift. Determinations to approve or decline gifts on behalf of the Committee must be made by a majority of the committee members who are eligible to vote. If a majority determination cannot be reached, the President of the College may, but shall not be required to, forward the proposed gift to the Board of Trustees for review and final determination.

Gift Acceptance Guidelines

The Gift Review Committee shall adopt guidelines regarding the acceptance of gifts by the College and the credit and recognition provided for such gifts (the “Gift Acceptance Guidelines”), which shall be consistent with the Principles of Gift Acceptance and shall apply to all gifts to the College. The Gift Acceptance Guidelines shall be reviewed periodically by the Gift Review Committee in consultation with the General Counsel for the College and may be amended by the Gift Review Committee at any time and from time to time.

No Third Party Rights

Nothing in this Policy or the Gift Acceptance Guidelines is intended to be construed, or shall be deemed to create, any right or remedy in any third party, including but not limited to any donor to the College or any individual affiliated with the College.