Gift Acceptance Policy

Purpose of Gift Acceptance Policy

The Volia Fund ("Volia") is proud that donors choose it as their route for philanthropy. The purpose of this policy is to set out for donors the guidelines that Volia follows for accepting gifts and utilizing those gifts effectively. All gifts shall be considered for acceptance in accordance with the policies set forth herein.

Volia:

• Provides effective stewardship of its assets.
• Ensures that all funds are expended in compliance with government regulations, donor priorities and instructions.
• Develops and implements effective procedures for coordinating allocation of funds and reporting funding impact to donors.

Introduction

Volia is a registered charity (EIN # 88-3424647). It is governed by a board of directors that oversee the acceptance and allocation of funds that protect the people of Ukraine and boost their well-being.

Use of Legal Counsel

Use of legal counsel by both the donor and Volia is advantageous to all parties. Volia cannot serve as both the donor's advisor and beneficiary of the donor's gifts. Therefore, potential donors should be advised that legal counsel for Volia does not represent their interest and are advised to consult independent tax and/or legal counsel before making gifts to Volia.

Advice to Donors

Volia engages donors living, working, or interested in its areas of benefit. It recognizes that donors have a range of interests and want them to make informed choices about their giving. However, its main purpose is to support the people of Ukraine.

Volia always respects the wishes of potential donors and never pressures them into a course of action. It will disclose the key issues that could be reasonably expected to influence a donor's decision to make a gift.

It will be made clear that all donations other than deferred gifts (and those outlined in section 7) are irrevocable, and that items such as market value and investment return can vary.

Volia also recommends that prospective donors obtain independent legal and/or financial advice regarding any proposed gift.

Gift Definition

A gift is defined as a voluntary transfer of assets from a person or an organization to Volia. Gifts usually take the form of cash, securities, real estate or personal property. Volia may accept or decline any gift. The following criteria generally identify a gift:

• A gift is motivated by charitable intent.
• Gifts are irrevocable transfers of assets.
• Gifts are not generally subject to an exchange of consideration or other contractual duties between Volia and the donor, although objectives may be stated, and funds may be restricted to a specific purpose.
• Donors are not provided formal financial accountings. A general report to the donor stating the utilization or impact of the gift is appropriate, and may be desirable, especially in the case of named gifts to the Restricted fund, Volia's endowment.
• Generally, funds received from individuals, closely held corporations, and family to Volia will be classified as gifts. Funds received from corporations and corporate partnerships will be classified as gifts unless the grant requires performance or other consideration.
• All gifts are completed when they have been accepted by Volia in writing, or in the case of securities, bonds, or mutual funds, when deposited into Volia's account.

Gift Designation

When received, without donor instructions, gifts will be treated as unrestricted.

Types of Acceptable Gifts

Directed Gifts

A directed gift involves the donor's voluntary and intentional transfer of money or property to the fund, without expectation of receiving a benefit equal to the value of the transfer. Volia reserves the right to accept or decline directed gifts after review of the donor's restrictions.

Although the donor may place restrictions on the use of the property, the donor may not retain control over the money or property transferred to the charity to qualify as a current gift. Examples of directed gifts include cash, securities, tangible personal property and some real estate gifts.

Checks

Checks will be accepted for donations up to $10,000. Larger donations will only be accepted electronically. The value of any cash or check gift is its face value. Checks must be made payable to the Volia Fund and sent to:

100 N. Howard Street, Suite W
Spokane, WA 99201

Securities

Securities, as defined herein, may be accepted as gifts by Volia, according to the policies described below. Securities given to Volia will typically be sold as soon as possible.

DonateStock is the preferred and default method that Volia will accept securities. Donors can access this platform at Volia.Fund. Tax receipts are provided to donors for all donations made via this platform.

10. Publicly Traded Securities

The value of a gift of securities is the mean (average) of the high and low of the stock(s) or bond(s) on the day the securities are received by Volia and takes ownership. The value of less actively traded securities, rarely traded securities or a security that does not trade on the gift date should be determined according to IRS rules as found in IRS Publication 561.

Volia should be notified in advance of the securities being transferred, the number of shares, the intended gift date and the intended designation of the gift (for example Unrestricted Fund, Restricted Fund or a specific program fund). Volia will sell such securities as soon as possible after the securities have been received.

Donation of Securities via Wire Transfer: Contact Alex Balkan, Board Treasurer for instructions.

Donation of Securities via Mail: If the donor has physical custody of stock certificates, they should be mailed, unsigned. The signed stock/bond power forms must be sent and received separately from the stock/bond certificates. The signature on the stock/bond power must exactly match the name(s) on the certificates.

11. Mutual Fund Shares

Volia may accept mutual fund shares. In most cases, Volia must open an account to accept gifts of mutual fund shares. Aspects of this process are beyond Volia's control and can take several weeks before the transaction is complete. Therefore, donors are advised to allow sufficient time (two to three weeks) to complete such transactions.

To initiate a gift of mutual fund shares, Volia must be notified of the mutual fund shares being gifted, the name of the institution at which the shares are held (brokerage firm, financial institution or the mutual fund company itself), the number of shares, the intended gift date, and the intended use of the gift (for example the Unrestricted Fund, Restricted Fund or specific program fund). If the shares are held at the mutual fund company, the donor and Volia must follow the necessary steps required by that company for transfer of ownership of the shares. If the shares are held at a brokerage firm or financial institution, Volia will contact the institution and establish an account there if none is currently open. When the account is open, that institution will transfer the shares into Volia's account. In all cases the shares will be sold as soon as possible after successful transfer into Volia's account.

The fair market value of mutual fund shares will be determined by the public redemption price of the shares on the date of the gift to Volia's account. If such a price is not readily available, then the value shall be determined as if the shares were non-publicly traded securities in accordance with IRS Publication 561.

12. Tangible Personal Property (accepted with intent to sell)

Tangible personal property is an asset that can be touched, handled, or moved by an individual (as opposed to intangible assets such as ownership in a company). The most common tangible personal property assets include art, coin and stamp collections, jewelry, furniture, or any similarly unique asset or collectible owned by a donor.

Volia, upon review and approval of the Finance Committee, may accept gifts of tangible personal property. However, gifts of automobiles, boats, airplanes and motorcycles are not usually accepted by Volia. Volia will sell gifts of tangible personal property and invest the proceeds as soon as practical.

Acceptance Criteria

Generally, gifts of tangible personal property may be accepted if they:

• Meet Volia's minimum gift value requirements
• Are readily marketable, and
• Are free and clear of encumbrances.

Gifts of tangible personal property must be of sufficient value to cover holding, maintenance, sale and administrative costs. The Finance Committee, assuming all other guidelines are also met, will consider gifts of jewelry, artwork, and collectibles. However, the minimum estimated value to secure an appraisal and generate a tax receipt is $5,000.

Documentation Required

Donors who intend to give tangible personal property to Volia must submit their gift proposal in writing. The proposal must include a description of the gift, proof of ownership, the donor's cost basis, date of acquisition, and a qualified appraisal performed within 60 days of the gift proposal date. Criteria for acceptance of the proposed gifts of tangible personal property shall include the following:

• Whether the property is readily marketable and what additional costs may be involved with the sale of the property;
• Whether the donor has requested any restrictions on the use, display or sale of the property;
• Whether the donor is aware of Volia's policy of selling such gifts as soon as possible after receipt;
• Whether the donor is willing and able to finance the packing, shipping and in-transit security, insurance and other associated costs in transferring the gift to Volia.

The donor is responsible for any packing, shipping, in-transit security and insurance costs or gifts of tangible personal property. The item(s) must be insured at the donor's expense until delivered safely to Volia, and transfer of ownership is complete.

Tax Considerations: Donors must complete IRS Form 8283. If Volia sells a gift of tangible personal property within two years of receipt, the sale will be reported to the IRS with submission of Form 8282. A copy of Form 8282 will be provided to donors to whom this applies. In considering gifts of tangible personal property, donors are advised to consult with a professional advisor regarding the related use rules that apply to such gifts and their tax deductibility.

13. Gifts in Kind (retained for Volia use)

Furniture, equipment, medical supplies, computer hardware and software and Ukraine-related memorabilia are examples of gifts in kind that may be considered for acceptance by Volia. The Finance Committee will consider such gifts on a case-by-case basis.

Acceptance Criteria

Depending on the nature of the gift, there may be maintenance, storage, shipping and insurance costs associated with it. Generally, the Finance Committee will use the following criteria to determine whether a gift in kind will be accepted by Volia:

• Whether the property furthers the mission or enhances the history of Volia
• Whether the donor has requested any restrictions on the use or display of the property
• Whether the donor is willing and able to finance the packing, shipping and in-transit security, insurance (until safe delivery of items to Volia and transfer of ownership is complete) and other associated costs in transferring the gift to Volia.

Documentation Required

Donors who intend to give gifts in kind to Volia must submit their gift proposal in writing. The proposal must include a description of the gift, proof of ownership, the donor's cost basis, date of acquisition, and a qualified appraisal performed within 60 days of the gift proposal date. In addition, the donor must provide a written document clearly identifying the property (describing the item(s) in detail) and stating the donor's clear intent to transfer all rights of ownership to Volia.

Tax Considerations

In considering such gifts, donors are advised to consult with a tax/financial professional regarding the related use rules that apply to such gifts. Unless it can be determined that the item being donated will be used by Volia to further its mission, Volia's recognition of the donation value will be limited to the lesser of his/her cost and the fair market value of the property.

14. Split Interest Gifts

Charitable Lead Trusts

A charitable lead trust is a trust in which the income, or lead interest, is paid to Volia, and the remainder interest is given to one or more non-charitable individuals. The amount paid to Volia may be either a fixed sum (an annuity trust interest) or a percentage of the trust assets as valued each year (a unitrust interest). At the conclusion of the payment period, the trust assets are returned either to the donor or to someone designated by the donor.

Donors are advised to consult with Volia regarding how to designate the gift and any restriction that is being considered. Volia shall not serve as trustee of a charitable lead trust.

Charitable Remainder Trusts

A charitable remainder trust is an irrevocable trust that provides for a specified distribution to the donor or other individuals named by the donor for a term of years or lives. Upon termination, all remaining trust assets pass to one or more qualified charities.

A charitable remainder annuity trust pays a fixed annual amount to the income beneficiary(ies), which must be at least 5% of the fair market value of the assets initially contributed to the trust. No additional gifts may be made to the annuity trust after its creation.

A charitable remainder unitrust pays the income beneficiary(ies) a fixed percentage (at least 5%) of the fair market value of trust assets, as valued annually. Because the value of assets will change from year to year, the unitrust payment will vary in amount each year. Additional cash contributions may be made to the trust after it is established if the trust agreement so provides.

Donors are advised to consult with Volia regarding how to designate the gift and any restriction that is being considered. Volia shall not serve as trustee of a charitable remainder trust.

15. Deferred Gifts

Deferred gifts that are put in place during life and are effective at death. Any deferred gift agreement that requires execution by Volia should first be reviewed and approved as to form and substance by Volia. Donors are advised to consult with Volia regarding how to designate the gift and to discuss any restriction that is being considered.

16. Bequests

A bequest to Volia is a gift made in the donor's will. Gifts made in a donor's revocable trust that are effective at the donor's death are treated the same as bequests. The donor can designate a specific amount, a percentage, or the remainder of an estate to Volia. Direct, unencumbered bequests shall be accepted by Volia if the underlying assets are in conformity with the guidelines set forth in Section 7 of this Policy entitled "Directed Gifts". Volia reserves the right to not accept gifts from the estates or trusts of deceased donors that are not in conformity with the terms of this Policy. Donors should be encouraged to notify Volia when considering a bequest to ensure that the assets left to Volia meet the criteria set forth in this policy.

17. Life Insurance Policies

Volia may accept ownership of life insurance policies that meet the following criteria:

When/if the policy to be gifted is fully paid-up as of the date of the gift:

• Policy must have a minimum face value of $1,000;
• The life expectancy of the insured must be less than 15 years on an actuarially determined basis;
• Volia may liquidate the policy for cash value net of any policy loans or other charges.

When/if the policy to be gifted is not fully paid-up as of the date of the gift, and the donor requests that Volia make premium payments on their behalf:

• Policy must have a minimum face value of $5,000;
• The life expectancy of the insured must be less than 15 years on an actuarially determined basis;
• Volia may liquidate the policy for cash value, net of any policy loans or other charges;
• Donor agrees to forward contributions to Volia in amounts equal to the cost of corresponding periodic premium payments;
• The amount of the periodic premium must be greater than $200.

When/if the policy to be gifted is not fully paid-up and the donor will pay future owed premiums directly to the insurance company until policy is fully paid-up:

• Policy must have a minimum face value of $1,000;
• The life expectancy of the insured must be less than 15 years on an actuarially determined basis;
• Volia may liquidate the policy for cash value net of any policy loans or other charges.

Only individual gifts of life insurance shall be accepted; individual insurance policies purchased by a group of individuals will not be accepted. Volia will not accept ownership of term life insurance policies.

18. Designating Volia as Beneficiary

Volia will accept any proceeds that it receives as a designated beneficiary (or an alternate beneficiary) of a life insurance policy, a deferred annuity contract, an IRA, a defined benefit plan, a 401(k) plan, a defined contribution (profit sharing) plan or other qualified plan, unless the designation imposes restrictions or a trust arrangement, in which case, prior review and approval by Volia is required.

Volia will accept beneficial interest in an insurance policy without minimum but reserves the right to decline to pursue receipt of funds offered under such interest if it proves administratively burdensome.

19. Gift Pledges

Volia may accept unconditional promises to give (pledges) with payment terms three years or less and valued at $1,500 or more.

A pledge meeting these criteria will be considered active upon receipt of the first payment, which shall represent a proportional share of the total pledge amount. Pledge terms must be provided to Volia in writing by the donor.

20. Gift Acknowledgment

Volia will acknowledge the receipt of all gifts in writing and in a manner which satisfies the IRS's substantiation requirements set forth in IRC Section 170(f) for the deduction of charitable gifts by individual donors.

21. Finance Committee

The purpose of the Finance Committee is to advise the Volia Board concerning acceptance of gifts to Volia; to make recommendations concerning Board policy regarding acceptance or declination of such gifts; and to develop effective practices and procedures for acceptance and management of gifts to Volia.

Meetings of the Finance Committee will be called on an as-needed basis to review gifts of real estate, tangible personal property, privately held stock and gifts which fall outside of current gift acceptance practices or guidelines, and to review updates in practices due to changes in legal or financial requirements, or as requested by the Volia Board President.

22. Overly Restrictive Gifts

Volia will not accept gifts deemed to be overly restrictive by the Finance Committee. Overly restrictive gifts that place undue burdens on Volia as well as gifts that violate the terms of Volia formation or governance documents.

23. Authorization for Reallocation

Every effort will be made to honor the intent of the donor or the estate gift. In the case that Volia cannot adhere to the intent of the gift, then Volia will attempt to contact the donor and/or the legal counsel representing the estate by mail and email at least 3 times within a calendar year to seek authorization to distribute the resources with proposed alternatives. After 3 documented attempts, if no contact is made then the remaining assets will be transferred to Volia's unrestricted or discretionary funds at the Board's discretion.

24. Policy Amendment and Review

Responsibility for review of and recommended amendments to the Policy shall be that of the Volia Finance Committee. This policy will be reviewed annually. To amend the Policy, a written amendment shall be prepared and submitted to the Volia Board for review and approval.

This policy shall be construed to be consistent with the Internal Revenue Code of 1986, as amended, the regulations promulgated thereunder, or other applicable state or federal laws as of the effective date of the legal change.