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12/2/2017 12:00 AM

Awarding grants directly to individuals and families impacted by disasters is permitted so long as proper procedures are followed, experts say.

Following the back-to-back hurricanes that struck first Texas and then Florida and Puerto Rico in late August and September, many grantmakers were left scrambling to identify which disaster relief agencies to support first. With so much destruction and so many people impacted, the situation, for many foundations, called for extraordinary measures, including expanding their usual grant programs to include aid directly to those hit hardest by the storms—a move that can, in theory, speed up the process by bypassing the “middleman” relief agency.

While uncommon, it is possible and perfectly legal to grant funding directly to individuals and families directly impacted by disaster events. But, experts say, there are some rules and best practices that must be followed to stay on the right side of the law.

Corporate Philanthropy Report recently spoke with Jeff Haskell, chief legal officer at Foundation Source, a consulting firm that provides administrative and other support services for private foundations, about the intricacies of this type of grantmaking.

Q: Under what circumstances would a foundation give directly to an individual or family, as opposed to a nonprofit serving them?

A: Many foundations are interested in having a direct impact with their philanthropy and maintaining control over how their charitable funds are applied. Having the ability to select and make grants to individuals who are suffering a financial hardship or were the victim of an emergency addresses both of these priorities. In some cases, such as in the wake of a major natural disaster, there may not be a nonprofit serving all of the impacted individuals. Even if there is a nonprofit serving all of the impacted individuals, a foundation may be able to provide assistance more quickly than another type of nonprofit organization. Finally, even if another nonprofit organization is serving impacted individuals, where hundreds or thousands of individuals are impacted by a disaster, the nonprofit organization may be stretched too thin and be unable to provide the full extent of assistance needed; in that case, a foundation may be able to pitch in and fill gaps.

Q: What special considerations are involved when giving directly to individuals/families?

A: An important consideration, generally, is establishing a way to identify those in need. IRS rules require that grant recipients be selected from a “broad charitable class” of individuals. Many foundations call upon one or more unrelated third parties to act as referral sources, such as members of the clergy, local charities or social workers, to name a few.

Additionally, foundations must be mindful of the importance of retaining the documentation associated with such grants, and must take care when reviewing the applications and assessing the need of each applicant. Special considerations apply to corporate foundations that wish to provide disaster relief to employees of the for-profit donor company.

Q: What specific steps/actions are required by law to do so?

A: Although advance IRS approval is not required for hardship and emergency grants to individuals, there are certain IRS requirements that must be followed, as well as some guidelines that are considered best practice. IRS rules require that grant recipients be selected from an open-ended group of individuals known as a “broad charitable class.” This group must be large or indefinite enough to ensure that the number of members comprising the class is not fixed. For example, while the exact number of victims in a specific community impacted by a single current disaster can be determined with certainty, the exact number of victims who will be impacted by this and future disasters would be indefinite, which should constitute a broad charitable class.

Additionally, as mentioned earlier, the foundation must make a specific assessment of need for each recipient of aid. It is an established rule that charitable funds cannot be distributed to individuals merely because they are victims of a disaster; rather, the foundation must make a specific assessment that the recipient of aid is financially or otherwise in need. Individuals need not be totally destitute to be eligible to receive emergency or disaster relief; rather, they may merely lack the resources to obtain basic necessities.

Foundations are required to maintain certain records with respect to emergency and hardship grants to individuals, including the objective criteria applied to assess need, basic information about the grant and the recipient, and the selection process utilized by the foundation, among other things. Notably, foundations are not required to track how the grant funds are ultimately spent by the recipient.

Lastly, it is recommended that the foundation’s board formally adopt its hardship or emergency assistance grant program and memorialize the board action (e.g., with minutes).

Q: What other factors might apply to such giving by corporations/corporate foundations?

A: One of the most important considerations for employer-sponsored foundations in particular is whether the recipients of aid will be employees of the for-profit donor company. If that is the case, as addressed by IRS Publication 3833, the foundation will not be permitted to make hardship grants to such individuals and will need to abide by certain rules in making disaster relief grants to employees.

Specifically, an employer-sponsored foundation may only make grants for relief in connection with a “qualified disaster.” Qualified disasters include those that result from terrorist or military actions, those that result from an accident involving a common carrier, a presidentially declared disaster or an event that the secretary of the Treasury determines is catastrophic.

Additionally, selection of recipients of aid must be made by an independent selection committee. A selection committee is considered independent if a majority of the members are not in a position to exercise substantial influence over the affairs of the employer.

The foundation should ensure that any disaster relief payments it may make will not relieve the for-profit donor company of any liability it otherwise would have had to its employees.

For more information, Jeff Haskell can be reached at (800) 839-0054 or visit

11/24/2017 12:00 AM

The Norfolk Southern Foundation supports education, arts and culture, human services and environmental groups in the communities it serves.


Norfolk Southern is one of the nation’s leading transportation companies. Its Norfolk Southern Railway subsidiary operates approximately 19,500 route miles in 22 states and the District of Columbia, serving every major container port in the eastern United States. The company also offers an extensive intermodal services network that utilizes road and rail transport to various destinations. Norfolk Southern is a major transporter of coal, automotive and industrial products, as well as general merchandise. In 2016, the company reported about $9.8 billion in sales and employed about 28,000 workers.


Norfolk Southern conducts its philanthropy mainly through the Norfolk Southern Foundation, which was established in 1983. The foundation offers a variety of grant and sponsorship programs, with the goal to enhance the quality of life for Norfolk Southern employees and the livability of the communities it serves.

The foundation’s core giving areas include:

  • Educational programs, including business and engineering programs at the collegiate level, early childhood education and childhood literacy.
  • Arts and culture.
  • Environmental programs, especially those in line with the company’s broader sustainability initiatives that focus on efficient energy and fuel consumption and reducing carbon emissions.
  • Human services, with a focus on serving families with children.

The foundation awards grants of up to $10,000 for specific projects or programs, including capital projects, serving its territory communities.

The foundation also offers limited sponsorships for certain events in its territory that benefit or promote Norfolk Southern’s business and social interests. Factors considered in sponsorship requests include relationships with charitable organizations, community impact, appropriateness of funding level and timing of requests.

And through its Local Discretion Grant Program, the foundation awards smaller grants of up to $3,000 for programs that promote community goodwill, diversity and safety awareness at the local level in each of Norfolk Southern’s 11 operating divisions. This program enables Norfolk Southern to enhance relationships with the communities in which its employees work and live and allows local railroad facilities and employees to share in corporate citizenship.

In addition, the foundation administers a Matching Gifts Program to encourage employees and retirees to support their communities. Donations from employees are matched dollar for dollar up to $20,000 each year, and up to $10,000 for retirees.

Visit the company’s website for more information.

11/15/2017 12:00 AM

CDW’s charitable giving is directed to children’s health and well-being, education, health and human services, and veterans’ services.


CDW is a leading provider of technology products for business, government, education and health care organizations in the United States, Canada and the United Kingdom. Founded in 1984 as Computer Discount Warehouse, the company offers over 100,000 information technology products for sale, including desktop computers, printers, servers, storage devices, networking equipment, software and accessories from more than 1,000 brands, including big names like Adobe, Apple, Cisco, Hewlett-Packard and Microsoft. For 2017, the company reported sales of nearly $15 billion and employed about 8,800 workers worldwide.


CDW’s charitable giving is directed primarily to nonprofit organizations that are located and/or operating in a community where it has business operations. The company provides a combination of cash grants and employee volunteers, with most of its giving devoted to the following focus areas:

  • Children’s well-being. The company supports various groups and programs that serve children’s well-being, with priority areas including:
    • Providing conditions for children to learn and develop.
    • Fostering a positive view of themselves and an identity that is respected.
    • Having enough of the basic human necessities like food and clothing.
    • Promoting positive relationships with family and friends.
    • Having a safe and suitable home environment and local community.
    • Having an opportunity to take part in positive activities to thrive.
  • Education and literacy. CDW supports schools and organizations focusing on improving K–12 student academic achievement with a heavy focus in the area of science, technology, engineering and math. It also supports literacy programs with an eye toward ensuring more potential job candidates who know how to use reading, writing, listening and viewing, speaking and presenting, and critical thinking skills to benefit the business.
  • Health and human services. The company strives to improve the quality and access to affordable health care through support of innovative and technology-based programs.
  • Military veterans. The company honors veterans, wounded warriors, active-duty service members and their families by providing technology and support to help military and their families while deployed and after they return home.

Some of the programs and organizations CDW supports include:

  • The Center for Enriched Living. The CEL enhances and enriches the lives of people with developmental disabilities, including Down syndrome, autism and Fragile X syndrome.
  • The Greater Chicago Food Depository. This is one of the largest nonprofit food distribution centers in the United States, feeding more than 310,000 hungry children and adults annually.
  • Children’s Miracle Network Hospitals. Every July, CDW’s employees embark on a monthlong grassroots fundraising campaign called the CDW Fun Drive for Children’s Miracle Network Hospitals.
  • Operation Homefront. The company supports this group, which provides emergency assistance and morale to U.S. troops, the families they leave behind and wounded warriors when they return home.
  • YWCA TechGYRLS. CDW supports this program designed to reduce the widening gender gap and increase exposure to and interest in technology for girls, ages 9–14. Designed to broaden girls’ knowledge of and interest in math, science and technology, the program helps girls gain confidence using technology tools in whatever profession they pursue.

CDW supports its employees’ efforts to give back to their communities by offering one paid Community Service Day off per year. Some examples of groups and projects supported by employee volunteers include:

  • Habitat for Humanity. Hundreds of CDW employees volunteer each year to help support this group’s goal of providing adequate housing for those who need it.
  • The American Cancer Society. Each year, CDW and its employees participate in the Relay for Life event to celebrate survivorship and raise money for research and programs.
  • Chicago Cares. CDW employees volunteer in the Chicago Cares Serve-a-thon to transform schools into beautiful, energetic places to help create a better environment for children to learn and grow.
  • Big Brothers Big Sisters. CDW provides financial support to this organization, while numerous CDW workers volunteer their time by mentoring children.
  • Junior Achievement. CDW also provides financial support to this group, which is supported by numerous employee volunteers who mentor students.
  • The American Red Cross. CDW’s employees have been trained for the ARC’s local disaster response volunteer program, Ready When the Time Comes.

Visit the company’s website for more information.

News Briefs
12/15/2017 12:00 AM

JPMorgan Chase & Co. has announced a $10 million investment to help drive inclusive economic growth in underserved Washington, D.C., neighborhoods.

JPMorgan Chase & Co. has announced a $10 million, three-year investment to help drive inclusive economic growth in underserved Washington, D.C., neighborhoods, most notably in Wards 7 and 8. The commitment will leverage the firm’s business expertise and collaboration with local business and community leaders to invest in four key drivers of inclusive growth: jobs and skills, minority-owned small business expansion, neighborhood revitalization and financial health. This is the third such initiative announced over the last couple years. Previous efforts focused on Detroit and, most recently, Chicago, to which the company has pledged a total of $40 million in resources over the next three years. In all three cities, the company aims to equip workers with critical skills, help minority small-business owners by providing them with the capital and expertise they need to grow, revitalize underserved neighborhoods by investing in affordable housing and locally driven solutions and help individuals get the tools needed to build strong financial futures.

News Briefs
12/11/2017 12:00 AM

Boeing has awarded a $5 million, multiyear donation to help expand the United Service Organizations’ Pathfinder program that helps transitioning troops.

Boeing has awarded a $5 million, multiyear donation to help expand United Service Organizations’ Pathfinder transition services, a comprehensive global program for transitioning service members. The USO Pathfinder program provides transition services to those exiting the military, their spouses and families 12–18 months before their transition and up to 12 months beyond the service member’s date of separation. USO employees work one-on-one with transitioning service members and military family members at transition centers located at military installations across the United States. The scouts help transitioning service members identify personal and professional goals while connecting them to the resources necessary for a successful transition into the civilian workforce. Boeing said its contribution will support more than 210,000 transitioning service members over the three-year grant period. The funds will target the launch of eight new support centers across the country, with a planned nationwide expansion to 25 centers by 2020, enabling the USO to reach 80 percent of all active-duty transitions each year.

News Briefs
12/8/2017 12:00 AM

Duke Energy has awarded over $300,000 in grants to 10 nonprofit groups working to revitalize Cincinnati’s urban core.

Duke Energy has awarded over $300,000 in grants to 10 nonprofit groups working to revitalize Cincinnati’s urban core. The grants, totaling $307,352, will fund transformational redevelopment projects that will stimulate growth, job creation and further investments in the city. Since 2011, Duke Energy has provided $1.88 million in urban revitalization funding to 58 projects in Southwest Ohio and Northern Kentucky. Projects include Braxton Brewing Company, Madcap Puppet Theater, Carabello Coffee, Cincinnati State’s Middletown campus and Gateway Community & Technical College’s Urban Metro campus. The new round of funding will go to the Community Improvement Corporation of Silverton, Downtown Middletown Inc., the Hamilton County Development Corp., Keep Cincinnati Beautiful, the Walnut Hills Redevelopment Foundation Inc., the Westwood Community Urban Redevelopment Corp. and the Catalytic Fund. Projects to be supported include the redevelopment of a local firehouse, the construction of a craft brewery, the launching of a community kitchen and an initiative to revamp vacant lots, among others.


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  • Meet the Editor

    Nicholas King

    Nicholas King has served as editor of Corporate Philanthropy Report since 2007, and he continues to be impressed with the philanthropic efforts of the nation’s business sector.

    Drawing on an educational background in English and environmental policy, Nicholas began his journalism career in 2000 when he was brought on as editor of Environmental Laboratory Washington Report, a niche-market subscription-based newsletter serving the environmental testing industry. After seven years of honing his craft, Nicholas expanded his writing/editing portfolio to an entirely new field of interest - corporate philanthropy. As editor of Corporate Philanthropy Report, he stays abreast of the latest developments affecting corporate giving—and the charitable/nonprofit sector more broadly—providing his readers the “need to know” information vital for making the best use of their limited charitable dollars.

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