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Gift Acceptance Policy

Purpose

The Greater Victoria Police Foundation (“GVPF” or “Foundation”) is a non‐profit, charitable organization registered under Canadian law. GVPF welcomes donations to fulfil its mandate to raise funds for crime prevention and community engagement initiatives that are above and beyond the operating budget of the Greater Victoria municipal police agencies (“Police Agencies”).

The Gift Acceptance Policy ensures that donations made to the GVPF further the mission of the GVPF and include appropriate consideration of donor interests and objectives.

The Gift Acceptance Policy also provides clarification of roles, responsibilities and expectations of both the GVPF and its donors and ensures that gifts to the GVPF are made in accordance with legal and ethical regulations and guidelines to protect the GVPF from potential liability related to gifts that may have a negative impact.

The GVPF reserves the right to refuse any donation or gift. All donations over an amount determined by the GVPF Board of Directors will be subject to an approval process.

The GVPF abides by the Association of Fundraising Professionals (“AFP”) Code of Ethical Principles and Standards and the Donor Bill of Rights.

Policy Objective

The purpose of GVPF’s Ethical Gift Acceptance Policy is to provide guidance to the board of directors and staff on which gifts can be accepted and how they should be handled. The policy also serves as a source of information for potential donors who are interested in supporting GVPF’s activities.

Details

Acceptable Gifts

The GVPF accepts gifts, donations, grants and funds from individuals, foundations, organizations, associations, employee groups, corporations and other donors. According to the Canada Revenue Agency, a gift is “a voluntary transfer of property without consideration.” The following types of gifts are deemed eligible for acceptance by GVPF:

  • Outright gifts of cash, cheques and cash equivalents;
  • Cash and in-kind sponsorship of events/programs
  • Publicly traded securities (including stocks, mutual funds and bonds);
  • Gifts of property (including real estate, art, computer equipment, jewelry); and
  • Bequests, life insurance policies, gifts of residual interest, charitable remainder trusts and annuities.

Other gifts not listed above may be acceptable but require review by the GVPF before the gift is accepted. In reviewing these gifts, consideration will be given to the size of the gift, financial liability, and risks to the GVPF.

In the case of publicly traded securities, gifts of property and other asset types, GVPF’s practice is to sell immediately upon receipt and convert to cash. A charitable tax receipt will be issued for the fair market value at the date of transfer. Gifts of property should be evaluated prior to donation; minimum values may apply. GVPF may hold onto gifts in kind that are deemed to be of future use to the organization. GVPF recognizes that donors may occasionally wish to give property that is not readily marketable. GVPF will evaluate such gifts to determine whether there are costs or risks associated with acceptance.

The GVPF retains the right to decline any type of gift or source of gift from an individual or organization with objectives that do not align with those of the GVPF.

Unacceptable Gifts

All donations over an amount determined by the GVPF Board of Directors will be subject to an approval process. Any gifts not accepted will be returned to the donor and no explanation will be provided.

Gifts of cryptocurrency will not be accepted by the Foundation.

Donations in the amount of $30,000 or less per year may be accepted with the Donor attesting as to the donor’s alignment of the Foundation’s guidelines for gift acceptance. Donations in excess of $30,000 per year may trigger a request for the donor to consent to limited background review to ensure the gift aligns with the Foundation’s guidelines for gift acceptance.

Designated Gifts

The GVPF will accept gifts designated (“Restricted Contribution”) to a specific project or fund provided the Foundation or the police agencies can reasonably utilize the gift. The Foundation applies a five per cent fee to all designated donations. This fee provides the Foundation with increased capacity to raise and distribute charitable funds for the police agencies and to cover GVPF administrative costs, including donor stewardship, granting, reporting, financial audits and other regulatory compliance.

Each restricted contribution will be used as designated, with the understanding that when the need for such a program or project has been met, or the program or project cannot be completed for any reason determined by the board, and neither the donors, nor their representatives, are living or able to consent to an amendment, the remaining restricted contributions will be used for another purpose consistent with the intent of the original gift.

Police Agency Status

Acceptance and or recognition through GVPF channels of a donation does not imply endorsement by the Foundation or the police agencies of any product, service or philosophy of the donor. Making a donation, of any amount, does not confer special status or preferential treatment on the donor by the police agencies.

Charitable Tax Receipting

GVPF issues charitable tax receipts for all eligible donations, in accordance with Canada Revenue Agency regulations. The GVPF has established a minimum donation amount of $20 for the automatic issuance of approved receipts. However, smaller donations will be receipted upon request by the donor. Donors of eligible gifts‐in‐kind are entitled to receive an official receipt that reflects the fair market value of the gift, according to Canada Revenue Agency guidelines. Eligibility for official receipts for non‐monetary (in‐kind) gifts is to be determined prior to the acceptance of the gift.

Fair Market Value (FMV) / Appraisals

If the Foundation has agreed to accept an in-kind donation and the value of the gift is under $1,000, the Foundation may use an in-house expert who is qualified to appraise the donation, to ascertain FMV for tax receipt purposes. If the Foundation has agreed to accept an in-kind donation and the value of the gift is over $1,000, the Foundation will obtain at least two appraisals from a qualified expert, one of whom must be arm’s length. The average of the two appraisals will constitute the FMV of the donation. The cost of obtaining the appraisal(s) will be discussed in advance between Foundation staff and the donor(s).

Administration Fee

The Foundation incurs expenses to process donations, particularly larger and more complicated gifts. In order to cover a small portion of these costs, the Foundation charges a 5% administration fee on all gifts of $5,000 or more. The decision to apply this fee, or not apply this fee, is at the discretion of the Foundation’s Executive Director.

Guidelines for Gift Acceptance

  • Gifts shall support GVPF’s mandate, vision and long-term direction.
  • GVPF shall not accept gifts from individuals, groups or organizations that may:
    • Encroach on the organization’s integrity;
    • Restrict its liberty of action;
    • Cause damage to its reputation;
    • Be inconsistent with the ethical values of the Foundation or police agencies;
    • Place additional costs or burdens on the organization; and
    • Expose it to uncertain risk or possible liability.

Transparency & Reporting

  • Gifts shall be accounted for in a manner that allows donors and the public to develop a fair picture of how the GVPF conducts its activities.
  • GVPF will respect donors’ presumption of anonymity and will consult with donors to obtain their permission before public disclosure of their giving.
  • GVPF will conduct itself in accordance with all Canada Revenue Agency or any other applicable government, Ministry or agency regulation(s).
  • GVPF urges prospective donors to seek the assistance of personal legal and financial advisers in matters relating to their gifts and the resulting tax and estate-planning consequences and to inform or include their family members in their philanthropy and gift making.
  • A Chief Constable or Deputy Chief Constable from one of the police agencies shall serve as an ex-officio, non-voting member of the GVPF Board of Directors.
  • The finance team of one of the police agencies may, at their sole discretion, administer the financial affairs of the collective police agencies in terms the spending and accounting for funds allocated by the GVPF.
  • The finance team administering funds allocated by the Foundation will demonstrate that all net funds are distributed in support of the identified police agency programs as approved in the granting process or through another approved channel, as well as directed gifts to a specific fund or unit.

Authority to Accept & to Sign Gift Agreements

The authority to accept most types of gifts on behalf of the GVPF is delegated by the Board of Directors to the Board Chair, Finance Committee Chair or Executive Director, who are able to accept the gift and sign a subsequent gift agreement. The Executive Director, Board Chair or Finance Committee Chair will consult with other appropriate Committee Chairs before deciding on gift acceptance. The exception to this authority is for gifts of shares in privately owned companies whose acceptance must be reviewed by the GVPF Finance & Audit Committee.

Monitoring & Compliance

The Executive Director is responsible for leading the monitoring of the application and compliance of this policy direction in conjunction with other members of the Foundation staff. The Executive Director will work with appropriate staff to ensure compliance and seek guidance from the GVPF Directors for gifts that fall outside of this policy.