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Policy 1     Governance, Ethical Conduct, and Organizational Values

 

Section 1.1     Mission and Vision

The University of North Georgia Foundation, Inc. (UNG Foundation or Foundation) supports the mission of the University of North Georgia by promoting philanthropy from all constituents, managing and investing its assets responsibly, providing financial assistance for students, faculty and staff, and serving in an advisory role to the President of the University.

The Vision is to be recognized and respected as a premier foundation that supports, creates, and enhances educational and other opportunities at the University of North Georgia, which, otherwise would not be possible through tuition and state funding alone.

Section 1.2     Board of Trustees

The By-Laws of the UNG Foundation establish the Board of Trustees and the Executive, Investment, Finance and Audit, Trusteeship, and Development Committees for the purpose of governing the Foundation. 

The Chief Executive Officer (CEO) and Chief Operating Officer (COO) regulate the day-to-day operations of the Foundation and the staff.  The CEO and COO are vested with full executive and administrative power to negotiate and sign leases, contracts, and other agreements on behalf of the Foundation for the performance of Foundation business as authorized by the Board of Trustees, or the Executive Committee.

BOARD AUTHORITY

The Foundation shall have the following powers, discretion and authority, which may be exercised in a fiduciary capacity, as the Board of Trustees shall deem advisable, and such powers, authority and discretion shall be in addition to, and not in limitation of, any power and authority exercisable by the Foundation by virtue of any provision of law:

  • To solicit contributions and to accept gifts and grants in money and property, both real and personal, and other things of value for use in its purpose, and to take and hold title to all such; and it shall have the power and authority to disburse any and all funds and to dispose of such property for the purposes herein proposed.
  • To hold, manage, and retain all, or any part of, the assets of the Foundation in the form in which the same may be at the time of the receipts thereof as long as the Board of Trustees may deem advisable, to collect and receive rents, issues, profits and income therefrom, to enter into trust agreements and to invest and reinvest any funds in the Foundation or in any trust in any property, real or personal, or any kind or nature, including, without limitation, stocks, bonds, mutual funds, common trust funds, secured or unsecured obligations, mortgages, and option transactions, other securities, and any interests in any of the foregoing, or in any other type property, without being limited or restricted to investments prescribed or authorized for trustees by the law of the State of Georgia, or any other jurisdiction, and regardless of the lack of diversification thereof.
  • To sell, exchange, partition, redeem, or otherwise dispose of any property, real or personal, which may at any time form part of the property of the Foundation, at public or private sale, and without the requirements of any court order, upon such terms, including sales on credit, with or without security, in such manner, on such terms and conditions, and at such prices, as the Board of Trustees may determine; and in connection therewith, to enter into contracts or agreements, grants, options, and execute and deliver all requisite instruments.
  • To assign, transfer and convey all, or any part of, the Foundation’s property, real or personal, in the name of a nominee, with or without disclosure of any fiduciary relationship; but accurate records shall be maintained showing that such property is a Foundation asset.
  • To mortgage any real property which may at any time form part of the Foundation’s assets in such amount, and on such terms as the Board of Trustees may deem advisable; to lease any such property for such term or terms, and upon such conditions and rentals, and in such manner, as the Board of Trustees may deem advisable, and to renew or modify any such leases; to make repairs, replacements and improvements, structural or otherwise, of any such property, and to charge the expense thereof as the Board of Trustees may deem proper.
  • To borrow money for any purpose in connection with the administration of the Foundation, or for any other purpose, which the Board of Trustees may deem necessary or desirable, or otherwise; to execute promissory notes or other obligations for amounts so borrowed, and to secure the payment of any amounts so borrowed by mortgage or pledge of any real or personal property, which may at any time form part of the trust, including, without limitation, the pledge of any such property; without the requirement of a court order, on such terms and conditions as the Board of Trustees may deem best.
  • To renew, or extend, the time of payment of any obligation, secured, or unsecured, or of any installment of principal or interest thereon, payable to the Foundation for as long a period or periods of time, and on such terms, as the Board of Trustees may determine; to hold any such obligation after maturity as past due; to consent to the modification of the terms thereof, including the date of interest; to waive defaults in the performance of the terms thereof; to foreclose any mortgage held by the Foundation, and take thereof, affected by said mortgages, either temporarily or permanently, and in partial or complete satisfaction of any claim thereunder; to protect such property against, or redeem it from, forfeiture for nonpayment of taxes, assessments or other liens; to insure, protect maintain and repair such property, and generally to exercise, with respect to such property, all such rights and powers as may be exercised by a person owning similar property in his/her own right; and to adjust, settle, compromise, and arbitrate any claim or demand of any nature in favor of, or against, the trust upon such terms as the Board of Trustees may deem advisable.
  • In respect of any stocks or securities forming part of the assets of the Foundation, to vote upon any proposition or election at any meeting, and to grant proxies or consents, discretionary, or otherwise; to vote at any such meeting; to join in, or become a party to, any reorganization, readjustment, recapitalization, merger, voting trust, exchange, consolidation, dissolution, liquidation or similar plan; to consent to any such plan, and any action thereunder, and to any contract, lease mortgage, purchase, sale, or other action, by any Foundation; to deposit any stocks, or securities forming part of the Foundation’s assets with any committee, depositary, trustee, or otherwise, and delegate discretionary powers thereto, and to pay out any fees, expenses and assessments incurred in connection therewith, and to charge the amount the Board of Trustees may see fit; to exercise conversion, subscription, or other rights, or to sell or abandon such rights; to receive, and hold, any new stock, or securities, issued as a result of any reorganization, readjustment, recapitalization, merger, voting trust, exchange, consolidation, dissolution, liquidation, or exercise of conversion, subscription or other rights, whether or not the property so acquired is of the character prescribed or authorized for said Foundation by the laws of the State of Georgia, or any other jurisdiction; and generally to take all action in respect of any such stock, or securities, as the Board of Trustees may deem proper.
  • To apportion extraordinary and stock dividends, and all rights to subscribe to new, or additional stock or securities, between corpus and income, provided that all liquidating dividends shall be deemed to be corpus.
  • In connection with making investments, to determine whether or not to amortize premiums in whole, or in part.
  • To adjust, settle, compromise and arbitrate any claim or demand of any nature in favor of, or against the Foundation.
  • To cause any and all stocks, or securities, held as part of the assets of the Foundation to be transferred to, in the name of a nominee to be selected by the Board of Trustees for that purpose, without liability for any loss resulting from any action or inaction by such nominee contrary to the discretion of the Board of Trustees; to hold bonds in bearer name.
  • For the purpose of convenience and the better investment thereof, to hold the principal of the Foundation’s separate trust, for which the Foundation may be responsible, in one or more consolidated funds; and to invest the same in solido, provided that the Foundation shall maintain adequate records showing the pro-rata interest of all funds in the commingled assets.
  • To employ agents, auditors, attorneys, consultants, investment counselors and/or real estate brokers and to pay them reasonable compensation.
  • To determine the manner in which it shall assist University of North Georgia and University of North Georgia Alumni Association with funds of the Foundation, and the amounts of such funds it will provide.
  • And in general, to invest and reinvest funds of the Foundation, within their discretion and irrespective of any law with regard to the investment of trust funds, and to hold said funds in such deposit accounts or in such other assets as they may desire, without any order of any court; and they shall not be personally liable for any losses which may be sustained of such funds and assets by reason of their making any investment of, making any deposit, or holding any assets in any form or manner they may desire.

The operation of said Foundation, as well as its organization, shall be exclusively for the purpose herein stated; and no part of the assets of the Foundation shall inure to the personal benefit of or be distributable to its members, trustees, officers, or other private persons.  No part of the activities of the Foundation shall be the carrying on of propaganda, or otherwise attempting to influence legislation, and the Foundation shall not participate in or intervene in (including the publishing or distribution of statements) any political campaign on behalf of any candidate for public office.  Notwithstanding any other provision of this policy, this Foundation shall not engage in any activities or exercise any powers that are not in furtherance of the purposes of this Foundation.

FISCAL RESPONSIBILITY

The CEO/COO shall keep and maintain on a fiscal year basis, beginning July 1 and ending June 30, the books and records of the Foundation, which shall be subject to examination by a committee appointed for such purpose.  An annual audit of all financial records will be conducted by a certified public accountant, and copies of the audit report shall be sent to each member of the Board of Trustees, and to the University of North Georgia, as required by Cooperative Organizations.

The treasurer in coordination with the CEO/COO shall provide three times per year to the Board of Trustees of the Foundation an analysis comparing actual disbursements to the budget.  Each year’s budget presentation will compare the next year’s allocation to the current year.

All funds of the Foundation shall be kept in the name of the Foundation in such depositories and such investments as the Board of Trustees shall authorize from time to time, and shall be kept under the custody of the CEO/COO.  All requests for disbursements of funds held by the Foundation along with the appropriate supporting documentation shall be made in writing and be approved by the CEO/COO.  Request for disbursements exceeding $10,000 shall also require written approval of the Chairman or other officer of the Foundation.  Written approval may take the form of a facsimile, overnight letter, electronic transfer or other means of providing written confirmation.  The funds of the Foundation shall be paid when authorized by the Board of Trustees on checks, wire transfers, electronic transfers, drafts and other commonly accepted means of transacting business in the name of the Foundation by the CEO/COO.  When those transactions exceed $10,000, those transfer documents will require a co-signature by one of the officers of the Foundation.

Section 1.3     Conflict of Interest

The purpose of the conflict of interest policy is to protect the UNG Foundation by identifying and properly managing all conflicts of interest and appearances of a conflict of interest.  This policy is intended to supplement, but not replace, any applicable state and federal laws governing conflict of interest applicable to nonprofit and charitable organizations.

DEFINITIONS

Interested Person – Any trustee, principal officer, or member of a committee with governing board-delegated powers, who has a direct or indirect financial interest, as defined below, is an interested person.

Financial Interest – A person has a financial interest if the person has, directly or indirectly, through business, investment, or family:

  • An ownership or investment interest in any entity with which the Foundation has a transaction or arrangement.
  • A compensation arrangement with the Foundation or with any entity or individual with which the Foundation has a transaction or arrangement, or
  •  A potential ownership or investment interest in, or compensation arrangement with, any entity or individual with which the Foundation is negotiating a transaction or arrangement.

Compensation includes direct and indirect remuneration as well as gifts or favors that are not insubstantial.

A financial interest is not necessarily a conflict of interest.  A person who has a financial interest may have a conflict of interest only if the Executive Committee decides that a conflict of interest exists, in accordance with this policy.

PROCEDURES

Duty to Disclose – In connection with any actual or possible conflict of interest, an interested person must disclose the existence of the financial interest and be given the opportunity to disclose all material facts to the Executive Committee.

Recusal of Self – Any trustee, principal officer, or member of a committee with governing board delegated powers, may recuse him or herself at any time from involvement in any decision or discussion in which the individual believes he or she has or may have a conflict of interest, without going through the process for determining whether a conflict of interest exists.

Determining Whether a Conflict of Interest Exists – After the interested person discloses the potential conflict of interest and all related material facts and after any discussion, the interested person shall leave the board or committee meeting (if applicable) while the determination of a conflict of interest is discussed and voted upon.  The Executive Committee members shall decide if a conflict of interests exists.

Procedures for addressing the Conflict of Interest -

  1. An interested person may make a presentation at the Board or Committee meeting, but after the presentation, he/she shall leave the meeting during the discussion of and the vote on the transaction or arrangement involving the possible conflict of interest.
  2. The Chairman of the Board of Trustees shall, if appropriate, appoint a disinterested person or committee to investigate alternatives to the proposed transaction or arrangement.
  3. After exercising due diligence, the Executive Committee shall determine whether the Foundation can obtain with reasonable efforts a more advantageous transaction or arrangement from a person or entity that would not give rise to a conflict of interest.
  4. If a more advantageous transaction or arrangement is not reasonably possible under circumstances not producing a conflict of interest, the Executive Committee shall determine whether the transaction or arrangement is in the Foundation’s best interest and benefit, and whether it is fair and reasonable.  In conformity with the above determination, the Executive Committee shall make its decision as to whether to enter into the transaction or arrangement.

Violations of the Conflicts of Interest Policy

If the Executive Committee has reasonable cause to believe a member has failed to disclose actual or possible conflicts of interest, it shall inform the interested person of the basis for such belief and afford the individual an opportunity to explain the alleged failure to disclose.

If, after hearing the interested person’s response and after making further investigation as warranted by the circumstances, the Executive Committee determines the individual has failed to disclose an actual or possible conflict of interest, it shall take appropriate corrective action.

RECORDS OF PROCEEDINGS

The meeting minutes of the Board of Trustees and all Committees with board-delegated powers shall contain:

  • The names of the persons who disclosed or otherwise were found to have a financial interest in connection with an actual or possible conflict of interest, the nature of the financial interest, any action taken to determine whether a conflict of interest was present, and the Executive Committee’s decision as to whether a conflict of interest in fact existed.
  • The names of the persons who were present for discussions and votes relating to the transaction or arrangement, the content of the discussion, including any alternatives to the proposed transaction or arrangement, and a record of any votes taken in connection with the proceedings.

COMPENSATION

A voting member of the Board of Trustees who receives compensation, directly or indirectly, from the Foundation for services is precluded from voting on matters pertaining to that member’s compensation.

A voting member of any committee whose jurisdiction includes compensation matters and who receives compensation, directly or indirectly, from the Foundation for services is precluded from voting on matters pertaining to that member’s compensation.

No voting member of the Board of Trustees or any committee whose jurisdiction includes compensation matters and who receives compensation, directly or indirectly, from the Foundation, either individually or collectively, is prohibited from providing information to any committee regarding compensation.

ANNUAL DISCLOSURE STATEMENTS

Each trustee, principal officer and member of a committee with board delegated powers shall annually sign a Conflict of Interest Disclosure Form (see Appendix) which affirms such person:

  • Has received a copy of the conflict of interest policy,
  • Has read and understands the policy,
  • Has agreed to comply with the policy, and
  • Has an understanding that the Foundation is a charitable organization which, in order to maintain its federal tax exemption, must engage primarily in activities, which accomplish one or more of its tax-exempt purposes.

If at any time during the year, the information in the annual statement changes materially, the individual shall disclose such changes and revise their annual conflict of interest disclosure form.

The Executive Committee shall regularly and consistently monitor and enforce compliance with this policy by reviewing annual disclosure forms and taking such other actions as are necessary for effective oversight.

PERIODIC REVIEWS

To ensure the UNG Foundation operates in a manner consistent with charitable purposes and does not engage in activities that could jeopardize its tax-exempt status, periodic reviews shall be conducted.  The periodic reviews shall, at a minimum, include the following subjects:

  • Whether compensation arrangements and benefits (if any), meet the IRS Rebuttable Presumption requirements:
    • The compensation arrangement must be approved in advance by an authorized body of the applicable tax-exempt organization, which is composed of individuals who do not have a conflict of interest concerning the transaction,
    • Prior to making its determination, the authorized body obtained and relied upon appropriate data as to comparability, and
    • The authorized body adequately and timely documented the basis for its determination concurrently with making that determination.
  • Whether partnerships, joint ventures, and arrangements with management organizations (if any), conform to the Foundation’s written policies, are properly recorded, reflect reasonable investment or payments for goods and services, further charitable purposes and do not result in inurement or impermissible private benefit or in an excess benefit transaction.

When conducting the periodic reviews, the UNG Foundation may, but need not, use outside advisors.  If outside experts are used, their use shall not relieve the Board of Trustees of its responsibility for ensuring periodic reviews are conducted. 

This policy is based on the IRS model conflict of interest policy, which is an attachment to Form 1023.

Section 1.4     Whistleblower Protection

The UNG Foundation requires trustees, officers and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities.  This Whistleblower Protection policy is intended to encourage and enable employees and others to raise serious concerns internally so that the Foundation can address and correct inappropriate conduct and actions.  

Representatives of the Foundation must practice honesty and integrity in fulfilling responsibilities and complying with all applicable laws and regulations.  It is the responsibility of all board members, officers, employees and volunteers to report concerns about violations of law or regulations that govern the Foundation’s operations.

NO RETALIATION

It is contrary to the values of the UNG Foundation for anyone to retaliate against any trustee, officer, employee, or volunteer who in good faith reports an ethics violation, or a suspected violation of law, such as a complaint of discrimination, or suspected fraud, or suspected violation of any regulation governing the operations of the Foundation.  An employee or trustee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment or board membership.

REPORTING PROCEDURES

The Foundation has an open door policy and suggests that trustees, officers, employees, and volunteers should report questions, concerns, suggestions or complaints with someone who can address them properly.  In most cases, reports should be made to the Foundation CEO.  Alternatively, reports can be made to the Chairman or Executive Committee if the person is not comfortable speaking with the CEO, or if they are unsatisfied with the initial response.  Contact information may be found on the following website: https://unggive.org/foundation

All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.  The CEO will notify the person submitting a complaint and acknowledge receipt of the reported violation or suspected violation within two weeks of receiving the complaint.  The CEO is responsible for ensuring that all complaints about unethical or illegal conduct are investigated and resolved.  The CEO will advise the Chairman, and/or Board of Trustees of all complaints and their resolution.

ACTING IN GOOD FAITH

Anyone filing a written complaint concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation.  Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.

CONFIDENTIALITY

Upon the request of the complainant, violations or suspected violations may be submitted on a confidential basis or may be submitted anonymously.  Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.
This policy is adopted from the National Council of Nonprofits, Whistleblower Protection Policy, Copyright 2010, www.councilofnonprofits.org.

Section 1.5     Records Management and Retention

The purpose of the Records Management and Retention policy is to assist the UNG Foundation in properly protecting and managing the records it needs to maintain, while eliminating the records that are no longer legally or operationally required.  This will help to ensure that the Foundation is following all applicable laws and regulations governing the management, retention and destruction of the Foundation’s legal, historical, business, and administrative records.

A “record” is any recorded information in any format (paper or electronic) that has been created by, received by, or for the Foundation in connection with its business transactions.

The following schedule outlines the minimum time periods specific types of records must be maintained:

 
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The COO is responsible for identifying the records to be retained and making arrangements for the proper storage of the records, and handling the disposal of records whose retention period has expired.

 Section 1.6          Purpose and Responsibility of the Policy Manual

The purpose of the Policies and Procedures Manual is to establish internal control and best business practices to operate the UNG Foundation and the programs it supports.  It is designed primarily for use by UNG Foundation administrative officers and staff, and UNG campus fund administrators.

The CEO and COO of the UNG Foundation is ultimately responsible for the preparation and maintenance of this policies and procedures manual.  All policies and procedures are subject to approval by the Executive Committee and Board of Trustees of the UNG Foundation.  The manual’s accuracy will be examined annually and necessary revisions will be made.

The website https://unggive.org/foundation/policies will be the primary source for distributing the Policy and Procedure Manual.

 

 

Policy 2     Gift Acceptance

Section 2.1          Gift Acceptance General Provision

The fundraising program of the University of North Georgia encompasses all gift solicitations on behalf

of the University and its colleges, units or affiliated entities.  All fundraising on behalf of the University will be coordinated by the University of North Georgia Foundation (UNGF) and conducted in accordance with the UNGF Code of Ethics and these policies.

Gifts of cash (or checks made payable to UNGF, not the University) and negotiable securities may be accepted by UNGF staff.  All gifts in other forms will be reviewed by the UNGF CEO or COO, in accordance with the policies below, and accepted, rejected or presented to the Executive Committee of the UNGF Board of Directors for final determination.  When timing is a critical factor, a gift may be accepted by the CEO or COO, conditional on subsequent approval by the Executive Committee.

The UNGF will record all gifts, deposit gifts into the appropriate funds and promptly issue gift receipts to donors.

The administration and investment of all gifts for the benefit of the University is the responsibility of UNGF.  The UNGF Finance Committee oversees fund management and financial policies.  All gifts will be invested in accordance with UNGF investment policies, established by the UNGF Investment Committee.  Donors may not control the investment of specific gifts.

The University President retains the right to approve or disapprove of any naming or to return a gift to a donor, in the best interests of the University, and in accordance with the University Naming Policy:  https://policy.ung.edu/pages/view/184.

Section 2.2          Fund Agreements

All endowment gifts shall be documented in a written fund agreement (or other written form) that outlines the program to be supported and the schedule of contributions.  All non-endowed gifts should be documented in pledge forms, fund agreements or other written forms. 

To maximize efficiency of operations, separate named funds and accounts must meet established minimum initial or annual donation amounts, and/or maintain prescribed minimum fund balances, as specified in the Section 3 Gift Accounting policy.  These minimums will be updated periodically in consideration of changing economic conditions, with the approval of the Foundation Board.

Section 2.3          Donor Restrictions on Gifts

All gifts solicited and accepted on behalf of the University must further the mission and strategic initiatives of the University.  The terms of each gift should be as flexible as possible to permit the most productive use of the funds, while accomplishing the donor’s goals.

No restrictions shall be accepted if in violation of local, state, or federal law or noncompliance with the Internal Revenue Code or IRS Regulations.

In accordance with federal and state law, provisions that restrict gifts on the basis of race, national origin, color, religion or nationality are prohibited.  Provisions that discriminate on the basis of age, marital status, disability or gender are discouraged, or if disallowed by law, prohibited.

IRS conditions for a qualifying gift, and principals of academic freedom, mandate that:

  • Preferences for relatives, descendants or friends of the donor in awarding scholarships or fellowships are not permitted.
  • A gift from any donor made on the condition or with the understanding that the award will be made to a student or faculty member of the donor’s choice will not be accepted.   
  • Any gift that includes a commitment of future employment of the recipient may not be accepted.
  • A donor may not serve on a committee that selects or evaluates the recipient beneficiary of the gift.

Section 2.4          Altering Donor Restrictions

It is a paramount obligation of UNGF that a donor’s gift be used for the purposes given.  The use of a donor’s gift for any purpose other than that stipulated by the donor is prohibited.

If the use stipulated by the donor becomes impossible, illegal or impracticable, consent for using the funds in a different manner will be sought from the donor, if possible.  If the donor is deceased or incapacitated, or cannot be located, then consent may be sought from the donor’s family members, estate representatives, or other legal agents.

If consent cannot be obtained, the use may be altered in accordance with the terms of the original written document, or as provided by Georgia law, which may include seeking court approval.

If the donor wishes to amend or alter the terms of his or her gift, the UNGF and University must first agree to those alterations and the alterations must be documented in writing.

Section 2.5          Gifts of Cash and Negotiable Securities

Gifts of cash and negotiable securities may be accepted by UNGF.  Checks must be payable to UNGF, not the University.  Gifts of cash are considered to be made on the date postmarked, accepted by a UNGF staff member, or delivered to the Foundation office.  Credit card gifts are considered to be made on the date they are processed, regardless of postmark dates. 

Securities that are traded on the New York and American Stock Exchanges, as well as other major U.S. and foreign exchanges and the NASDAQ, corporate bonds, government issues and agency securities may be accepted as gifts.  In general, such securities shall be sold as soon as possible after their receipt. 

The value of a gift of securities is determined by averaging the highest and lowest selling prices quoted for the security on the day the transfer is completed by the donor to the Foundation, in compliance with IRS regulations. 

Donors should notify the Foundation of the securities being gifted, the number of shares, the intended gift date, and the intended use of the gift.  Securities may be wired to a designated Foundation brokerage account, see Appendix for Stock Transfer Authorization Form.

Section 2.6          Gifts of Partnership Interests, Non-Publicly Traded Securities, Closely Held Business Interests or other Business Interests

A gift of an interest in a limited or general partnership, or of stock in a corporation that is not publicly traded, or of restricted stock of a publicly traded corporation may be accepted on behalf of the University, but only after appropriate due diligence by UNGF staff (including such matters as possible liability, the assets of the entity, the liquidity of the interest, the partners’ or shareholders’ agreement, etc.), then subsequent approval by the CEO or COO of the Foundation and recommendation to and approval by the Executive Committee.

Section 2.7          Gifts of Tangible Personal Property

Gifts of tangible personal property, including but not limited to art, antiques, collections, manuscripts, books, and vehicles, may be accepted only after review and approval by the Foundation CEO or COO, and in some instances the University.

A gift of tangible personal property may be accepted only when:

  • Such a gift is consistent with the mission of the University, or may be liquidated and the proceeds used by the University; and
  • No financial or other burdensome obligation or expense is or will be directly or indirectly incurred by the UNGF because of the gift, unless approved by the Executive Committee.

Consistent with the donor’s intent for the gift, which must be documented in writing, UNGF may retain the gift of such property for University use, transfer the asset to the University, or liquidate it for the benefit of the University. 

Gifts In Kind will be acknowledged by the item(s) listed with no value.  The Foundation will give the donor credit for recognition of total giving.  A Gift In Kind Contribution Form (see Appendix) must be completed and approved by the Foundation office prior to any gifts of tangible personal property being accepted from a donor. 

Section 2.8          Gifts of Real Property

Gifts of real property, or interests in real property, may be accepted on behalf of the University by UNGF, after approval by the CEO and the UNGF Executive Committee.  Due to the expenses associated with gifts of real property, only gifts valued in excess of $100,000 will generally be considered.  Most property gifts are actively and promptly marketed and the proceeds used for the charitable purpose designated by the donor.  Some property may be received and held for use by the University.

However, no interest in real property, whether outright, in trust, by bequest, as a secured interest, or otherwise, will be accepted by UNGF without first complying with all due diligence requirements as set by the Foundation Board.  Each such gifts requires at a minimum:

  • A title insurance commitment showing marketable title in the donor, free and clear, issued by a reputable title insurance company;
  • An appraisal by a qualified appraiser (not older than 60 days and paid for by the donor);
  • A Phase I environmental audit by a qualified environmental engineer, indicating that ownership will not expose the Foundation to environmental liability;
  • A market feasibility study for purposes of liquidation;
  • An on-site evaluation by the Foundation CEO or COO, or their designee; and
  • A listing of all carrying costs, including but not limited to taxes, insurance, association dues, membership fees, and transfer charges.

Moreover, unless waived by the Foundation CEO or COO, the donor shall be responsible for all costs related to the environmental impact study, title search, market feasibility study, and any other related study.

Gifts of mortgaged property raise significant tax issues for the donor and the Foundation, and may require additional review.  Gifts of time shares, ground rents, and burial lots will not be accepted.

The execution and delivery of a deed of gift (preferably in the form of a warranty deed or trustees’ deed) shall complete the gift.  The donor shall pay the costs associated with the conveyance and delivery of the gift.

Gifts of real property shall be valued at their fair market value on the date of the transfer as set forth in a “qualified appraisal” prepared in accordance with IRS regulations. 

Section 2.9          Planned or Deferred Gifts

Various types of planned or deferred gifts are encouraged and may be accepted.

  • Bequest Expectancies: are encouraged but do not count as current gifts.  Generally, the Foundation will not serve as a trustee or co-trustee of a trust or as executor of an estate, exceptions, where appropriate, may be made with prior approval of the Foundation CEO or COO, and approval by the UNGF Board. 
  • Gifts of Charitable Trusts:  UNGF may serve as trustee if UNGF is 100% charitable remainder beneficiary of such trust.  UNGF will not serve as trustee of a charitable lead trust.
  • Gifts of Charitable Gift Annuities.
  • UNGF may consider other forms of planned or deferred gifts, including gifts of insurance, retained interests in personal residences or farms or pooled income gifts.  Appropriate due diligence and approval by the Executive Committee is required.

Neither the University nor UNGF provides legal or tax advice.  All prospective donors shall be strongly urged to seek the assistance of personal legal and financial advisors in matters relating to their deferred gifts and other tax and estate planning. 

General provisions for planned or deferred gifts:

  • Such gifts will normally be funded with cash, marketable securities or marketable real property.
  • The minimum amount required for funding a life income plan in which UNGF is to serve as a trustee is $100,000.
  • Payouts from life income arrangements will be set in accordance with IRS rules and those recommended by the American Council of Gifts Annuities.
  • The Foundation reserves the right to charge reasonable management fees to offset estimated costs to be incurred during the development and management of various planned gifts.  Fees charged by the Foundation or third parties providing administration for deferred giving instruments will be absorbed by the individual instrument. 

A companion Fund Agreement should be executed by the parties outlining the purposes of the donor’s gift, when realized by UNGF.

Section 2.10       Gifts to Support Scholarly Activities of Faculty

Funds may not be contributed to UNGF to benefit a particular individual.  All gifts are deemed made irrevocably to the institution, and will not be transferred to another organization or institution in the event a particular faculty member leaves the University.

Section 2.11        Gift in lieu of Honoraria

A payor may make a gift to UNGF, in lieu of paying an honorarium, if accompanied by a letter from the payor identifying the payment as a charitable contribution.  If a University employee wishes to make a gift of an honorarium which has been sent to him or her directly, he or she must first deposit the honorarium personally and then make a separate private gift to the Foundation.

Section 2.12        Gifts of Other Property

Gifts of other property such as copyrights, or royalties, are generally not accepted by the Foundation. These gifts may be considered only with the approval of the Foundation CEO or COO, and subsequent approval of the Executive Committee.

Individuals may accept royalty payments directly, and then make a private gift to the Foundation.   

 

 

Policy 5     Expenditure Control

Section 5.1          Expenditure Introduction

The University of North Georgia Foundation, Inc. (UNGF) exists in order to support the University of North Georgia and its mission.  Private philanthropic support depends, in part; upon the confidence donors have in the UNGF’s commitment to sound fiduciary management of funds, to include expenses.

All expenditures of donor gift monies from the UNGF shall be spent mindfully and with respect for the donor’s wishes and intents. 

Generally, all expenditures must:

  1. Be reasonable and benefit the University;
  2. Be consistent with the donor’s intent for the gift;
  3. Not jeopardize UNGF’s tax-exempt status;
  4. Comply with all applicable statutes and regulations.

All disbursements must have written justification detailing the business purpose suitable for auditing purposes and must not be:

  1. For political or charitable contributions, fines or penalties;
  2. For the personal benefit of the payee;
  3. For lavish or excessive entertainment.

A Fund Administrator is responsible for approving expenditures from each fund to ensure the authenticity and appropriateness of the expenditure, compliance with the donor fund agreement, and adherence to Foundation policies. 

Fund Administrators include the President, Vice Presidents, Deans, or Directors of a particular unit.  Fund Administrators may request to delegate his/her signature authority to another employee in that unit, when appropriate (i.e. business manager).  A Signature Authority Form (see Appendix) must be completed and approved by the Foundation office in order to delegate signature authority.

If a Fund Administrator is requesting reimbursement for him/herself, the request should be forwarded to the next level of authority for approval.  As example, Deans should forward reimbursements to the Provost for approval and Vice Presidents should forward reimbursements to the President for approval.  Direct reimbursements to the President of the University shall be approved by the Foundation Chair and/or Vice Chairman.

A Check and Reimbursement Request Form (see Appendix) must be completed for all Foundation payments.  Original invoices and receipts must be promptly submitted as supporting documentation.  The Foundation processes checks once a week.  Requests received by 5:00pm every Tuesday will be processed within the same week, provided all documentation is submitted.  All requests will be approved by a UNGF Officer (CEO or COO) prior to being processed.

Section 5.2          Travel

All University employee and student travel expenses must be processed through the University Business Office in accordance with University and Board of Regents policy.  Please refer to the UNG Comptroller Office for additional information: https://ung.edu/comptroller/ .

Under certain circumstances, the Foundation may reimburse for an employee’s spouse travel, if it can be shown that the spouse’s presence has a bona fide business purpose.  The request must be clearly substantiated in writing, and approved in advance of the travel by the Foundation CEO or COO.  No personal or social purpose reimbursements will be allowed, which would result in a fringe benefit to an employee. 

The UNGF may reimburse the Board Chairman, or designee, for required travel on behalf of the Foundation and/or University of North Georgia when asked to represent UNG or the UNG Foundation.

Section 5.3          Entertainment

Foundation funds may be used for payment to vendors or reimbursement to individuals for expenses related to entertainment incurred while conducting official University business.  An Entertainment Form (see Appendix) must be completed and submitted with each separate entertainment request.

Fund Administrators are responsible for determining whether expenses are appropriate, moderate, and in support of furthering institutional goals and programs. 

The following instances are applicable for entertainment reimbursements:

  • ·         Business meals that include a donor, prospect, or other business related non-employee are reimbursed as entertainment.  Business meals consumed while not away from home are not normally considered reimbursable by the IRS, with the following exceptions:
    • Faculty/staff has a meal with a prospective donor or job candidate.
    • Faculty/staff has a meal with a representative of an external business-related organization to discuss matters of benefit to the University.
    • Faculty/staff has a meeting scheduled for the purpose of conducting business related to University matters, or as an official function of the University. 
  • Original itemized receipts must be submitted with all reimbursement requests.
  • Business meals should include tips with a reasonable amount, generally, not more than 20%.
  • Solo (individual employee) meals will not be approved through the Foundation.  Individual meals should only be reimbursed if on official University business with the employee’s state travel reimbursement.  Meals reimbursed through state travel should not be submitted as a reimbursement request to the Foundation.
  • All requests for entertainment expenditures must include an explanation of the business purpose, list of attendees, and relationship of those attending, plus date and location.  If a University employee’s spouse attends, an explanation of the necessity of his/her attendance should be attached.  The required Entertainment Form will document this information accordingly.   
  • Reimbursement may be made for the judicious use of alcohol while entertaining and must comply with the University’s alcohol policy.  Alcohol must not be served to underage individuals:  https://ung.edu/police/campus-safety-information/alcoholic-beverages.php

Section 5.4          Dues and Memberships

The Foundation may pay for dues and or memberships for key employees at the University on case-by case basis, as approved by the Office of the President.  This includes civic organizations, leadership programs, and chamber memberships.  No private club memberships or memberships resulting in fringe benefits to an employee will be paid by the Foundation. 

The Foundation must receive approval from the President’s office prior to processing payments. 

Section 5.5          Gifts to Employees

  • Employee cash awards, cash gifts, and gift certificates are always considered taxable income when paid by the employer, per IRS.  Therefore they may not be given by or paid with Foundation funds.  Such payments must be processed via University payroll.
  • Foundation funds may not be spent for recognition of personal events or achievements, such as birthdays, wedding, baby showers, nor may they be spent for charitable donations in lieu of gifts.
  • Sympathy gifts for a death or serious illness or injury of an employee are allowable only with pre-approval of the President or appropriate Vice President.    
  • Gifts of flowers to employees are not reimbursable as business expenses except as noted above, with specific pre-approval of the President or appropriate Vice President. 
  • Individual non-cash gifts to University employees must be items of de minimis value, i.e. $50.00 or less.  The value of non-cash gifts includes sales tax, delivery fees, and other service charges.
  • Gifts for retirement or employee achievement awards after five years of service are exempt from the limitation above, per IRC 274(j)(4) and are restricted to a value of $400 or less.  Retirement and employee achievement awards are allowable only by the Office of Human Resources, as part of a meaningful presentation emphasizing the employee’s achievement.  Service awards cannot be made to part-time employees.  Exceptions may be made with Executive Committee or Presidential approval.

Section 5.6          Endowed Chair/Professorship

The Foundation may invest funds for an Endowed Chair/Professorship.  Until the fund is fully endowed, the position cannot be awarded.  During that period, spendable income may only be spent on recruitment for the position.

Examples of acceptable expenditures once the position is filled include:

  • Salary and benefits.
  • Salaries of support staff, including graduate students, working exclusively on the professor’s scholarly work.
  • Travel for the professor related to scholarly work.
  • Technology support for the professor including computers, software and data.
  • Subscriptions to journals and/or journal application fees.
  • Renovation of facility, laboratory, etc. for professor.

The above expenditures must be processed through the University Business Office.  The Business Office will bill the Foundation accordingly for all expenses.  All Endowed Chair positions are subject to approval by the University System of Georgia Board of Regents.

Section 5.7          General Policy Regarding Expenditures

The following general policies apply in considering the appropriateness of Foundation expenditures:

  • The Foundation does not allow cash advances.
  • Gift cards and gift certificates are unallowable, as the IRS considers them as cash equivalent. 
  • Donations or payments to other non-profit entities are unallowable, unless it supports the philanthropic mission of the UNG Foundation. 
  • All student awards and scholarships must be disbursed through Student Financial Aid.  The Foundation cannot disburse award and scholarship checks directly to students because of tax reporting purposes.
  • Foundation funds may not be used to purchase raffle items.
  • For equipment purchases of $5,000 or less, Foundation funds may be used.  For purchases in excess of $5,000, purchases of equipment must be made through the University Business Office in accordance with its rules and procedures.  Transfer of funds may be made from the Foundation to the University for such purchases.  State bidding rules must be followed.
  • The Foundation is not exempt from state sales/use taxes.  All invoices and receipts must show that such taxes have been paid.
  • Receipts must be submitted promptly for reimbursement, generally within 45 days.
  • No contracts, purchase orders, or other documents may be signed on behalf of UNGF except by a UNGF officer (CEO or COO).
  • An IRS Form W-9 must be submitted for each new vendor before payments may be processed.
  • The Foundation’s expenditure policy allows expenses that have a supportable business purpose and do not result in the personal benefit to any individual or UNG employee.  If it is determined that a UNG employee has derived personal benefit from an expenditure of the Foundation, that information will be reported to the UNG Payroll Department and may be included in the employee’s taxable income reported on their W-2.
 

 

Policy 6     Investment

Section 6.1          Investment Introduction

The mission of the University of North Georgia Foundation (the “Foundation”) is to support the University of North Georgia by promoting philanthropy from all constituents, managing and investing its assets responsibly, providing financial assistance for students, faculty and staff, and serving in an advisory role to the President of the University. 

The Investment Committee ("the committee") is charged with the following:

  1. maintain the assets of the foundation in perpetuity
  2. achieve acceptable investment returns compared to industry benchmarks
  3. keep sufficient liquidity for short term funding needs
  4. manage risk

General Principles

This Investment Policy Statement (together with its Appendices, the “Statement”) sets forth policies and procedures that shall guide the Board of Trustees (the “Trustees”) and any of its delegates in supervising, implementing, evaluating and monitoring the investable assets of the Foundation.  The following six general principles shall apply:

  1. Investments of the Foundation shall be diversified unless the Trustees, or their lawful delegates, after appropriate deliberation, reasonably determine that because of special circumstances the purposes of the Foundation are better served without diversification.
  2. The Foundation shall be managed in accordance with applicable standards of fiduciary duty and in compliance with applicable laws and regulations, including the Uniform Prudent Management of Institutional Funds Act (Ga. Code §44-15).
  3. Standards for return, asset allocation, and diversification shall be determined primarily from a strategic perspective and measured over both short and long time periods.
  4. Foundation funds are by definition perpetual pools of capital and as such a long-term view in setting investment policy and strategy should be taken.
  5. Taking into consideration the long-term nature of the Foundation assets, maintaining a bias towards risk assets, which have historically produced higher long-term returns, is appropriate.
  6. The Foundation is exempt from taxation.  It is the policy of the Foundation to treat all assets of the organization, including those funds that are legally unrestricted, for the purpose of accomplishing the organization’s tax-exempt mission.  As such, the policies described in this Statement are to be interpreted in light of that overall sense of stewardship.

Section 6.2          Delegation of Responsibilities

If the Board of Trustees elects to oversee investment matters directly, it shall undertake the roles and responsibilities of the Investment Committee (“Committee”) as outlined in this Statement.  Otherwise, the Committee shall implement the management process and monitor the Foundation in accordance with this Statement.  The Committee is the governing body responsible for (i) developing this Statement; (ii) monitoring compliance of the investment program with this Statement; (iii) overseeing the Foundation Staff in the discharge of their responsibilities as outlined below; (iv) retaining, monitoring and terminating Investment Managers, and Advisors  – collectively referred to as external investment partners (“Partners”) as appropriate; and (v) approving the terms upon which Partners manage the Foundation assets, including without limitation, the terms of investment management agreements, asset allocation guidelines, fees and compensation, and performance measurement benchmarks.  At least annually, the Committee shall review this Statement to ensure that the policies contained herein remain current and appropriate.

The Foundation Staff is responsible for communication with the Committee, acting as liaison with Partners, monitoring investments, and administration of the Foundation assets.

Subject to specific legal limitations or other restrictions in a gift instrument, the Committee may hire and prudently delegate to Partners the management of some or all of the Foundation’s assets.  The Committee will act in good faith, with the care that an ordinary prudent person in a like position would exercise under similar circumstances in:

  1. Selecting Partners.
  2. Establishing the scope and terms of the delegation, consistent with the purposes, goals, and mission of the Organization.
  3. Periodically reviewing the Partners’ actions in order to monitor the Partner’s performance and compliance with the scope and terms of any delegated activities.

In this regard, the Committee shall engage qualified external professional Partners that have demonstrated competence in their respective areas of expertise.  The duties and responsibilities delegated to Partners will be defined by specific contracts, applicable laws, and regulation.

Section 6.3          Investment Objective

The primary investment objective of the Foundation is to preserve and enhance the purchasing power of the Organization’s assets.

In furtherance of this objective, the Foundation will generally diversify the portfolio among various asset classes and securities with the goal of reducing the investment portfolio’s volatility and its non-systematic, single issuer, principal risk.

Section 6.4          Asset Allocation and Investment Policy

The single most important investment decision is the allocation of the Foundation’s funds to various asset classes.  The primary purpose of the Foundation’s asset allocation policy is to provide a strategic mix of asset classes which produces an acceptable investment return within a prudent risk framework that meets the long-term goals and objectives of the Foundation.  Each asset class should not be considered alone but in the context of the overall structure of the portfolio.  How the different asset classes relate and interact with each other is the key to making asset allocation decisions within the context of the required risk and return trade-offs.

As stated earlier, a core fundamental investment belief of the Foundation is that a bias toward investing in risk asset, which produce higher long-term returns, should be maintained.

GENERAL ASSET ALLOCATION STRUCTURE

The basic framework for developing the asset allocation mix for the Foundation is to consider the universe of investments fitting into two broad categories – risk assets and risk control assets.  Risk assets are generally the return drivers of the portfolio, provide portfolio diversification benefits during stable capital market conditions, but tend to see their diversification benefits diminish (as a result of rising correlations) during stressed capital market environments.  As a result of their lower and more stable correlations (even in stressed capital market conditions), especially in relation to risk assets, risk control assets provide a dependable diversification benefit during all market environments.  By optimizing and controlling the overall portfolio mix between risk assets and risk control assets, a more stable, risk managed portfolio results – especially during stressed capital market environments.  What follows is a review of the risk assets and risk control asset segments approved for use in portfolio construction.

RISK ASSETS:

  • U.S Capital
  • International Developed & Emerging Market Capital
  • High Yield Bonds
  • International Market Bonds
  • Real Estate & Infrastructure
  • Natural Resources & Commodities
  • Hedge Funds
  • Private Capital

RISK CONTROL ASSETS:

  • U.S. Investment Grade Bond
  • Inflation Protected Bonds (IPB)
  • Cash

ASSET ALLOCATION GUIDELINES:

The Committee will establish and approve a set of customized asset allocation guidelines for each discrete pool of investible capital being managed for the Foundation.  Each customized set of asset allocation guidelines will be aligned to support the underlying goals and objectives of each separate pool of investible capital.  The asset allocation guidelines will include a Policy Normal Level, representing the strategic asset allocation mix for the pool of  Foundation assets being managed.  The asset allocation guidelines will also include an approved target range that:  (i) recognizes various asset classes may be under- and over-weighted due to the trading, settlement, and timing delays associated with fully implementing an investment program; (ii) recognizes it may be prudent and necessary for its Partners to operate outside the Policy Normal Levels when the  financial markets are stressed and subject to extreme levels of volatility; and (iii) allows its Partners to deliberately over- and under-weight the investment program’s asset classes within prescribed target ranges as set out in the investment policy guidelines.  The approved asset allocation guidelines for all of the Partners, when considered together, will reflect the overall liquidity needs and risk tolerance of the Foundation and will, in the judgment of the Committee, represent the asset mix likely to satisfy the Foundation’s long-term investment objectives. 

Exhibit A to the Investment Policy Statement, which is also an integral part of each Partner’s Investment Services Agreement, provides the asset allocation guidelines currently in effect for the Foundation (See Appendix).

REBALANCING

Rebalancing is a critical element in controlling the long-term asset allocation of the Foundation. The portfolio rebalancing policy will be implemented in a systematic and disciplined fashion using policy guidelines.

In general, the Partners are expected to review the portfolios at least quarterly to determine if any rebalancing activities are required. The Foundation’s assets will be allocated in a manner consistent with the asset allocation guidelines, as determined by the Investment Committee and the Partners given prevailing market conditions, with variations around the expected long-term policy normal allocation levels permitted within the ranges set in the asset allocation guidelines.

INVESTMENT PERFORMANCE EXPECTATIONS:

The Committee will establish and approve investment performance expectations for the Partners.  Such expectations will vary by asset class and will be based on appropriate index returns, composites or other recognized industry performance standards deemed appropriate by the Committee.

PERFORMANCE REVIEW AND EVALUATION:

The Partner will review and evaluate investment performance periodically in the context of both the current investment environment and the long-term investment horizon of the Foundation.  Performance evaluation will be conducted for the total portfolio and for each asset and sub-asset class.  All performance results will be reported net of all fees and expenses.

The performance review at the asset class level will evaluate asset class performance versus the appropriate benchmarks as outlined in Exhibit A.

Section 6.5          Other Investment Considerations

USE OF DERIVATIVES:

Certain investment strategies employed will be permitted to use derivative investments.  Derivative investments are those securities whose value is related, or derived, from that of another security, index, or financial instrument.  Investments in derivatives include (but are not limited to) futures, forwards, options, warrants, swaps, etc.  No derivative positions can be established that have the effect of creating portfolio characteristics that would ordinarily be prohibited by the Statement.

Derivatives can be used in prudent ways including hedging market, currency, or interest rate risk, maintaining exposure to a desired asset class while making asset allocation changes, gaining exposure to an asset class when it is more cost-effective than the cash markets, and adjusting duration within a fixed income portfolio.  When using derivative investments, the investment manager responsible for the position needs to carefully monitor the creditworthiness of any third parties involved in the transaction.

Each investment manager using derivatives shall exhibit expertise and experience in utilizing such products; demonstrate that such usage is strategically integral to their security selection, risk management, or investment process; and demonstrate acceptable internal controls regarding these investments.

LIQUIDITY MANAGEMENT:

The Foundation may have liquidity needs for operational commitments, need cash to meet annual payout requirements or participant benefit payments, or for the management of its legal commitments to draw down funds for certain private investments.  Additionally, the portfolio needs to be able to respond to changing market conditions allowing the portfolio to be shifted modestly to take advantage of the relative or absolute attractiveness of certain asset classes over time.  To address all of these needs, care must be given to the level of liquid assets in the portfolio, the anticipated funding needs, and the level of future funding commitments while providing additional liquidity for unplanned or emergency needs.  In particular, there should be an awareness of how liquidity can change in periods of capital market stress.

Nevertheless, the permanent nature of the Foundation’s capital should enable it to accept lower levels of liquidity in instances where capital is likely to earn a sufficient return premium.

As a general test of overall portfolio liquidity, the value of illiquid assets (i.e., defined as investment positions which cannot be converted into cash within a six month holding period) plus any future unfunded commitments cannot exceed the total of all liquid assets held in the portfolio.  For this test, liquid assets are defined as those assets which can be converted into cash within thirty business days or less and have no limitations – no “gates” – imposed on their liquidity.  Note that in determining this calculation, some assets will not fit the above, strict definition of “liquid” or “illiquid” assets.  Those positions are considered semi-liquid and will be ignored for this basic liquidity test.  To the extent the Foundation’s investment portfolio meets or exceeds this basic liquidity test, there are no liquidity restrictions imposed on the management and operation of the portfolio.  To the extent the Foundation’s investment portfolio fails this basic liquidity test, a more sophisticated cash flow monitoring and liquidity plan must be developed, implemented, and monitored by the Investment Committee.

USE OF LEVERAGE:

While the Foundation may invest in investment funds and vehicles that utilize differing forms of leverage, the portfolio as a whole is to remain unlevered.  In terms of this section of the Statement, unlevered refers to the fact that the total notional exposure of the portfolio should not exceed 100% of the assets of the Foundation.

Subject to any legal or regulatory limitations, and requiring specific Trustee oversight and approval, the Committee may approve the creation of a line of credit to be utilized in unusual situations to address temporary liquidity needs in an amount not to exceed 10% of assets.

EXCEPTIONS TO POLICY:

The Committee may waive or modify any of the restrictions in this Statement given appropriate circumstances.  Any such waivers or modifications shall be made only after a thorough review of the situation.  Any such waiver or modification should be documented in writing and maintained as a permanent record.  All such waivers and modifications shall be reported to the Trustees at the meeting immediately following the granting of the waiver or modification.

Section 6.6          Documentation and Reporting

Statements will be provided monthly to the Foundation summarizing the prior period’s activity, market value, and asset allocation mix.  On a quarterly basis, the Foundation will be provided a performance report for the prior period and longer term trailing periods.  The performance report will contain industry standard benchmarks that are relevant for evaluating the performance of the portfolio and its sub components. 

 

 
 

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