Group solicitations require the approval of the Director of Institutional Advancement.

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1 Charitable Giving Policy Section A: Soliciting/Accepting Gifts and Donations Carmel Catholic High School welcomes expressions of interest and financial support, solicited or unsolicited, regardless of size or form, from any individual, family, business, corporation, foundation or similar source. The Office of Institutional Advancement staff and volunteers are available to meet with any prospective donor(s) and their financial advisors, without obligation, to discuss areas of interest, the plans of Carmel Catholic High School, types of gift commitments, options for payment, estate planning, and tax planning consequences of a possible gift or gift commitment so as to provide every possible assistance to a prospective donor. Although representatives of Carmel Catholic High School will provide all appropriate assistance, the ultimate responsibility regarding asset evaluations, tax deductibility, and/or similar federal, state and/or local legal compliance rests with the donors(s) and/or with such financial advisors as the donor(s) shall secure. No volunteer or member of the faculty, staff or volunteer acting in the name of Carmel Catholic High School will contact a prospective donor or solicit a gift or service without the expressed permission of the Director of Advancement, or in his/her absence, the President. The Director of Institutional Advancement, the President, and other volunteer, faculty, or staff solicitors, will meet regularly to discuss solicitation and stewardship plans for major donors. Group solicitations require the approval of the Director of Institutional Advancement. Requests for mailing lists to alumni, parents or other donors require the approval of the Director of Institutional Advancement. All special events, outside of the normal schedule of school events, which raise funds for the benefit of Carmel Catholic High School require prior approval by the Director of Institutional Advancement.

2 Printed materials for special events such as tickets or entry blanks will comport with current state and federal regulations. Some vendor contracts may contain a gift element. To protect the vendor s tax deductions and allow for proper coordination, clearance, acknowledgement and stewardship, vendor contracts containing a gift element require consultation with the Office of Institutional Advancement and the Finance Department before the contract can be officially accepted and signed by Carmel Catholic High School. Solicited gifts to Carmel Catholic High School may take the form of one, or a combination, of the following: Cash Matching gifts Multi-year pledges Marketable securities Closely held stock and non-marketable securities Real Estate and other Tangible Personal Property Paid-in-full insurance policies with cash values Corporate Gifts Gifts-in-kind Gifts of Services Deferred or planned gifts including: o Trusts o Annuities o Insurance policies o Gifts of residence, with or without a retained life interest o Charitable Remainder Unitrust o Charitable Remainder Annuity Trust o Bequests Section B: Reviewing and Accepting Gifts Gifts will be accepted by Carmel Catholic High School, provided they are considered consistent with Carmel s mission, goals and objectives. All proposed gifts, gifts-in-kind (equipment, art objects, real estate, etc.) and restricted gifts will be reviewed by the appropriate personnel in the Office of Institutional Advancement, Administration and Finance Office prior to acceptance. Carmel Catholic High School s legal counsel may also be consulted when deemed necessary. A gift may be deemed unacceptable if it: Is not conducive to the best interest of Carmel Catholic High School Is clearly a commercial endeavor with no educational value Is hampered by restrictions to the extent that usefulness and desirability are affected Would obligate Carmel to undertake responsibilities, financial or otherwise, which it feels are inappropriate or onerous Carmel Catholic High School reserves the right to refuse such gifts or to counsel the donor to remove or modify the restrictions or terms and conditions of the gift. Section C: Definition of a Gift

3 A gift is defined as a voluntary transfer of items of value from a person or organization where no material amount of goods or services are expected, implied or provided to the donor. Gifts normally take the form of cash, checks, securities, real property or personal property and may be restricted or unrestricted to a general area of use that benefits Carmel Catholic High School. A gift will generally exhibit the following criteria: A gift is motivated by charitable intent. Gifts are irrevocable, and Carmel Catholic High School is not expected to return all or part of the gift. In the event Carmel Catholic High School is unable to comply with donor intent, or if the gift was directed to Carmel in error, a return of the gift may be issued at Carmel s discretion. Approvals for such returns are made by the Director of Institutional Advancement, in consultation with the Director of Finance and the President. Gifts generally do not have contractual obligations imposed, although objectives may be stated and funds restricted to a specific purpose in an agreement. A period of performance is not specified or required. It may specify funding periods. Formal financial accounting is not required. 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 memorial or scholarship gifts. Section D: Disqualifying Factors Regarding Gifts A sponsored contract, sometimes called a grant or a contract, is not a gift. It is a payment to Carmel Catholic High School for a specific project that binds the school to a specific scope or area of work. There is always a signed, legally enforceable document involved. If the document includes the following attributes, it is probably a contract and not a gift: The source of the payment is a government agency A required item must be provided, such as a technical report of data collected, or the specific results of a project, a curriculum or training program Primary benefits are to the sponsor Patent rights or copyrights belong to the sponsor Punitive damages can be assessed A requirement for record retention or a provision for an audit is included Specific start and end dates for the funded project A detailed project description or discussion of the scope of the work to be performed is included There is a limitation on the use or publication of project data beyond the donor simply wanting recognition for the gift A requirement for disposition of property, whether tangible or intangible that may result from the project (equipment, inventions, copyrights, etc.) Authority over the project resides with the sponsor rather than with Carmel Catholic High School Unused funds must be returned A provision for reimbursement of indirect costs is included Questionable items should be reviewed by the Director of Institutional Advancement, the Finance Director and the President. Section E: School Representatives Who May Accept Gifts

4 The President, the Director of Institutional Advancement or their designees may accept gifts on behalf of Carmel Catholic High School. Formal recognition of a received gift is completed with the presentation of a receipt or formal acknowledgement. Gifts not processed according to these procedures should not be construed as accepted by Carmel Catholic High School. Section F: Gifts Which Are Not Accepted Carmel Catholic High School reserves the right to decline accepting a gift. Gifts are not accepted if any of the following conditions are present: The gift is in contravention of applicable Federal or State laws; or Board of Corporators, Board of Directors, or School policies. The gift would obligate Carmel Catholic High School to undertake duties, financial or otherwise, which it may not be fully capable of meeting for a period required by the terms and conditions of the gift. The gift constitutes a request to Carmel Catholic High School to operate a commercial endeavor for the sole benefit of the donor. The gift cannot be properly administered within the school s normal budget or resources (for example, in the case of the requirement for matching funds or resources). The gift presents an unreasonable or unacceptable degree of risk due to environmental or health/safety issues. The gift is subject to restrictions that are inappropriate or are contrary to Carmel Catholic High School s mission and values. Section G: Gifts of Cash Gifts of cash are accepted. Checks should be made payable to Carmel Catholic High School. Section H: Matching Gifts Matching gifts received from corporations, businesses, or other organizations of cash or securities will be receipted and acknowledged as a gift from the entity from which the gift was given. Matching gifts will follow the designation of the gift of the individual for whom the gift is being matched unless directed otherwise by the matching gift organization. Should Carmel Catholic High School wish to credit matching gifts to the individual for the purpose of donor recognition, it may do so as long as gifts are not counted twice for financial accounting purposes. Campaign pledges made by individuals are considered a personal obligation and should not include the anticipated matching gift amount. Section I: Multi-Year Pledges Pledges must be documented in writing by the donor either in the form of a pledge card or other written correspondence from the donor. No verbal pledges will be counted toward fundraising goals. For pledges to be counted in full, they must be made within the pre-established campaign period. Payments on pledges will not extend beyond five years or as otherwise determined by Carmel Catholic at the outset of a campaign. All pledges which are voided by donors will be deducted from campaign totals. Section J: Gifts of Marketable or Publicly Traded Securities

5 Gifts of publicly traded securities shall be valued at the average of the high and low market prices of the security on the day of receipt into Carmel Catholic s ownership, in accordance with IRS regulations. The securities shall be forwarded to the Finance Department for deposit to Carmel Catholic High School s account for disposition by its asset manager based on the school s policy for the management of securities. Section K: Gifts of Closely Held Stock and Non-marketable Securities 1 Securities not traded on an exchange or over-the-counter may be accepted only if the valuation can be substantiated through comparable sales price or by qualified appraisal. It will be the responsibility of the donor to conduct and pay for appraisals of such securities and provide written documentation to Carmel Catholic High School. No prior written agreements on the disposal of such gifts will be made, in accordance with IRS regulations on such gifts. All gifts of closely held stock and non-marketable securities will be held until liquidated at which time the funds will be used consistent with the intention of the donor and the established policies of Carmel Catholic High School. Section L: Gifts of Real Estate or Other Tangible Personal Property 2 Outright gifts of real estate or other tangible personal property are required to be reviewed by the Director of Institutional Advancement, the Director of Finance, and the President. Gifts of tangible personal property are at all times subject to acceptance per the conditions of Section B. When gifts of real estate or tangible personal property are given to Carmel Catholic High School with the intent of the donor receiving a tax deduction, it shall be the responsibility of the donor to obtain an appraisal, in accordance with IRS regulations governing such gifts. It is in the donor s best interest that Carmel Catholic High School neither provides directly nor be responsible for securing the service of appraisers in connection with gifts to the school. All gifts of real estate will be reviewed by Carmel Catholic s legal counsel before such gifts are accepted and finalized. Appropriate site assessments and additional independent appraisals may be required to satisfy Carmel Catholic s legal counsel s review. Gifts of real estate with a retained life interest may be accepted, in which case the donor will be expected to bear the expenses of maintenance and real estate taxes during his or her lifetime. 1 The Internal Revenue Service requires that all gifts of appreciated property in excess of $5,000 (non-publiclytraded securities, real property, and personal property) must be accompanied and substantiated by a qualified donor-obtained appraisal of market value to be used for income tax deduction purposes. The subsequent sale of such items by Carmel Catholic High School within three years (previously two years) after the date of the gift must be reported to the IRS and may cause a reduction in the value of the charitable gift to the donor if appreciated property is sold for less than the appraised value. Donors should obtain their own appraisal of gifts for income tax purposes. Should any gifts exceed an estimated value of $5,000, the value should be verified through the use of an expert appraiser. Any appraiser s report should contain: 1) the appraiser s qualifications; 2) statement of value and appraiser s definition of value; 3) complete description of the property; 4) factors used in making the appraisal (e.g., restriction on use of the property); 5) data on which the property was evaluated; and 6) appraiser s signature and date. For the donor s protection, Carmel Catholic High School cannot establish the value of such gift nor can it pay to have an independent appraisal made for a donor or the donor s own gift. The appraisal must also be current under IRS guidelines (typically 90 days). 2 See note 1.

6 Gifts of real estate with restriction on the eventual sale must be reviewed and approved by the Director of Finance, the President, the Board of Directors, and the Board of Corporators prior to accepting such a gift. Gifts of real estate which have a mortgage or liens on the property must be reviewed and approved by the Director of Finance, the President, the Board of Directors, and the Board of Corporators prior to accepting such a gift. Unless otherwise authorized by the Board of Directors, Carmel Catholic High School will seek to liquidate such assets in order to secure the cash needed to fund its program or facilities priorities. Any recommendation to the Board of Directors to hold or invest real estate or tangible personal property is contingent on the following general guidelines or considerations: Generally, the school s decision to hold such gifts cannot involve significant additional expense for their present or future use, insurance, maintenance or administration. Generally, no burdensome financial or other obligations can be incurred, directly or indirectly, by Carmel Catholic High School as a result of the holding such gifts. All gifts of tangible personal property (such as books, works of art, etc.), if such gifts are to be made on the condition, understanding or expectation that the gifted items will be loaned to the donor or to persons designated by the donor for life or an extended period of time, shall be reviewed by the President and assigned to appropriate committees for review. Section M: Gifts of Insurance An actual gift must take place in which Carmel Catholic High School becomes the owner and beneficiary of a new or existing policy. The cash value of such policies will be counted toward fundraising goals when realized. The face value of the insurance gift, minus the cash value, will be counted toward the future value of the gift only if the campaign includes a goal for deferred gift expectancies. Section N: Corporate Gifts Corporate gifts will be accepted and may take the form of outright gifts, sponsorships, or underwriting. Gifts from corporations will be handled according to the provisions for the form of their gift, as stated within this or other policies of Carmel Catholic High School. Section O: Life Income Plans Only irrevocable life-income gifts (with the charitable remainder earmarked for purposes acceptable by Carmel Catholic) made via the following instruments will be accepted: Charitable remainder unitrusts Charitable remainder annuity trusts Charitable gift annuities Pooled income fund Remainder interests in real estate All such life-income gifts will be recognized in an amount equal to the allowable Federal Income Tax charitable deduction. Gifts of remainder interest in real estate will be treated the same as life income gifts.

7 Section P: Charitable Lead Trusts Gift income from Lead Trusts will be recognized upon receipt of the income by Carmel Catholic. Section Q: Bequests and Other Deferred Gifts All bequests or deferred gifts that will, or may, require expenditure of funds either at the time of the gift or at some future date (e.g., non-performing assets gifted to fund a charitable trust or charitable gift annuity, bargain sales, or outright gifts such as real estate) that impose present obligations on Carmel Catholic High School shall require the approval of the Board of Directors. The proceeds of bequests and other estate gifts will be recognized when they are actually received, or where the amount of assured future estate distribution is confirmed by the executors, the full amount of the bequest will be counted toward current gifts and pledges as long as such gifts have not been counted in previous campaigns. Newly established or newly confirmed bequest provisions may be counted toward a campaign goal. All properly documented bequest provisions for campaign purposes shall be credited to the campaign s deferred giving goal in accordance with the deferred giving guidelines of the campaign. Proper documentation must be secured before any future planned gifts can be counted to the campaign. Proper documentation will be constituted by formal and specific letters of intent or actual copies of bequest clauses, and wills supported by accompanying statements that stipulate the bequest s estimated amount and purpose. Carmel Catholic High School will provide the donor a standard form for verification and certification of bequests upon request. Section R: Restricted Gifts Acceptance of a restricted gift, such as a scholarship, imposes a legal obligation to comply with the terms established by the donor; therefore, it is necessary that the nature and extent of this obligation be clearly understood. For this reason, the terms of each restricted gift will be reviewed by the Director of Institutional Advancement and President before acceptance to assure that it does not hamper the usefulness and desirability of the gift to Carmel Catholic High School. In so far as possible, the designated purposes for gifts should be described in as broad and flexible terms as possible. Very narrow restriction should be avoided. If a restricted gift is deemed unacceptable because of the restriction the donor has placed on its use, the donor will be counseled to remove or modify the restrictions. The President decides when a gift will be refused or returned; when a gift is inappropriate or not conducive to the best interest of the school; or when it would obligate the school to undertake responsibilities, financial or otherwise, which it may not be capable of meeting. The language used in creating such a restricted gift or fund should contain provisions which would allow for the Board of Directors to apply the gift to some other related purpose, if and when the designated purpose is no longer feasible, practical, necessary, or possible of performance. This should be discussed with and agreed to by the donor. The following standard language may be used to provide this latitude:

8 In the event the Carmel Catholic High School Board of Directors, in its sole discretion, determines that the use of [the income from] this fund for the above stated purposes is no longer appropriate, necessary, practical, or possible of performance, or for other good and lawful reason said purpose should be changed, the Board of Directors may use [the income from] this fund for such other closely related purpose as the Board of Directors, in its sole discretion, determines will best promote and support the mission of Carmel Catholic High School. Should Carmel Catholic High School cease to exist, this fund, like other Carmel assets, would then be split between the BVM and the Carmelite religious communities. Section S: Notification Any approved gift or service received (valued at more than $100) by a member of faculty, staff or volunteer acting in the name of Carmel Catholic High School must be reported to the Office of Institutional Advancement. When a gift or service is received, it should be reported to the Office of Institutional Advancement in writing or via within 24 hours of receipt or on the next business day (whichever occurs first). This information should include the donor s name, address and phone number as well as a detailed description of the gifts and services received.