Overview This policy seeks to reconcile the need for financial support with the values of the Florida Center for Investigative Reporting, the foremost of which is editorial independence. FCIR fails just as surely if it loses public confidence in its integrity as if it becomes unsustainable financially. The policy acknowledges, too, that individuals and organization invest in projects that further their own goals and values, directly or indirectly. Hence, the policy is organized around three categories of donor intentions – those who seek to support investigative journalism in general, those who seek to support investigations in particular areas of interest, and those who seek to support specific investigations. The FCIR Board of Directors retains full authority over the fundraising policy and fundraising efforts and may reject donors for any reason, to protect the best business interests of the organization. All donations are subject to compliance with the FCIR Policy on Financial Support, including provisions for transparency, the disclosure of donors’ identities, and the prohibition on donations from political parties, elected officials, or others whose contribution may affect public perception of FCIR’s independence. Gifts and grants to support investigative journalism in general FCIR will seek and accept gifts and grants from individuals or organizations in any amount for the general support of the center’s activities. Acceptance of these gifts or grants neither expresses nor implies any voice in editorial decisions beyond the broadly stated mission of investigative journalism. We expect that most gifts and grants of this type will come from foundations, organizations, and individuals concerned about the future of journalism in general and the future of investigative journalism in particular. Gifts and grants to support investigations in particular areas of interest FCIR will establish a limited number of funds to support investigations in specific areas of public importance, such as the environment, education, immigration or governmental integrity. To assure that donors respond to the priorities of FCIR rather than FCIR responding to the agenda of others, each fund will be approved by the board of directors before any gifts are solicited and accepted. The initial list of approved funds is: Government Integrity, Economy (includes Consumer, Immigration, Poverty), Education, Environment, Health & Welfare, Justice & Public Safety. The activation of such funds shall be contingent upon development of an efficient and reliable system for tracking the receipt and expenditure of these donations. We expect most gifts or grants of this type to come from individuals interested in the subject area. FCIR will also accept contributions from organizations if they agree to the following conditions, which also apply to gifts from individuals: 1. Gifts and grants are tied to a subject area defined by FCIR but not to a particular project or investigation. 2. All donations of $5,000 or more will be announced at the time the gift or grant, and publicly acknowledged throughout the years they are being expended. Gifts and grants to support specific investigations FCIR will consider gifts or grants to support particular investigative projects. All project-specific grants require approval from the FCIR board of directors and will conform to the following conditions: 1. FCIR exercises editorial control of any project. The donor specifically cedes any right to review editorial content or to restrict its distribution. 2. All funds are transferred to the FCIR prior to the start of the investigation and are not refundable. 3. Financial contributions to specific projects are totally transparent and public, with a disclaimer specifying the nature of the relationship. Procedures 1. Fundraising is the work of the board, management and designated staff, consultants or volunteers. Only those who are identified by FCIR’s management and approved by the board will be authorized to fundraise on behalf of FCIR. All fundraising efforts by the board, management, staff or volunteers will strictly adhere to this policy. 2. In the spirit of transparency, FCIR will compile a complete list of donors each fiscal year or more frequently, and make the list available for public inspection through the FCIR website and other reports. FCIR will not accept gifts from anonymous sources. FCIR will not accept gifts from political parties, elected officials, or others whose contribution may affect public perception of FCIR’s independence. Gifts may be in cash, in-kind services or tangible goods. If not in cash, a value will be attached to the gift. The list of donors will be published at least semi-annually, but may be published more frequently as directed by the board. FCIR will never share donors’ personal information for the sake of advertising or other direct-mail efforts, unless the donor consents in advance. 3. All checks or credit card transactions deposited to FCIR must be intended by the donor to be given as a gift, meeting the criteria above. Checks, debit or credit transactions should be made payable to Florida Center for Investigative Reporting Corp. Instructions provided to donors for gifts to FCIR should instruct the donor to make the check payable to Florida Center for Investigative Reporting Corp. A FCIR Gift Deposit Form should be completed for each check, debit or credit card transaction sent to FCIR. Where correspondence with the donor will be useful in documenting the intent to give the gift, it will accompany the Gift Deposit Form. In accordance with good donor stewardship practices and with all IRS regulations, all gifts will receive an acknowledgment in writing or by e-mail, which will be archived. 4. As technology develops, methods may be implemented to accept very small donations (“micropayments”) through online transactions. These contributions ranging from pennies to $20 might be associated general support, subject specific funds, or specific projects. 5. Good internal control procedures must be followed. These include: Restrictively endorsing checks “for deposit only” immediately upon receipt. Depositing checks within five days of receipt. Storing undeposited funds in a locked desk or safe overnight. Reconciling deposits with gift deposit form. Where credit card payments are accepted, FCIR will obliterate the credit card number from any copies of source documents after deposit. 6. Gifts of stock, real estate or other non-cash gifts not covered elsewhere may only be accepted following specific approval by the FCIR board. 7. FCIR fund development practices and accounting for gifts will fulfill all Internal Revenue Service, state of Florida and other relevant regulations at the state and federal level.