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CeloHT Donation Policy

Version: 1.0 Last Updated: August 2026 Status: Active

Purpose

This document defines what donations CeloHT accepts, how restricted and unrestricted donations are handled, when a donation may be refused, and what donors can expect regarding transparency and privacy. It exists to give prospective donors a clear, accurate basis for deciding whether and how to contribute.

Scope

This policy applies to all monetary and in-kind donations offered to CeloHT, regardless of amount, source, or form (fiat, USDm, or other assets), and to every individual involved in soliciting, accepting, or processing a donation on CeloHT's behalf.

Responsibilities

Role Donation Policy Responsibility
Treasury Committee Reviews and processes donations per this policy
Finance Working Group Records and reports donation activity
Governance Council Approves acceptance of donations above the threshold defined in Section 1 and any donation raising a refusal question under Section 3

Review Schedule

Reviewed annually per GOVERNANCE.md Section 21, and immediately following any donation-related incident or dispute.

1. Accepted Donations

CeloHT accepts donations that:

  • Are consistent with CeloHT's mission as described in LEGAL_STATUS.md Section 2.
  • Do not require CeloHT to misrepresent its legal status (LEGAL_STATUS.md Section 3) or compromise its non-token, non-investment identity (NO_TOKEN_POLICY.md).
  • Are made in a form CeloHT can practically receive, record, and report on (fiat via available channels, or USDm via CeloHT's treasury infrastructure per TREASURY.md).

Donations above $1,000 USD-equivalent from an undisclosed or anonymous source require additional Treasury Committee review before acceptance, consistent with LEGAL_STATUS.md Section 8, to guard against misuse.

CeloHT does not currently issue tax receipts for donations, because it does not hold tax-exempt or charitable registration in any jurisdiction (LEGAL_STATUS.md Section 3). Donors should evaluate the tax treatment of any contribution with their own advisors.

2. Restricted vs. Unrestricted Donations

Type Definition Handling
Unrestricted donation Given without a specified use, available for allocation per FUND_ALLOCATION_FRAMEWORK.md Recorded and reported as general treasury inflow
Restricted donation Given with a specified use (e.g., "for reforestation only") Recorded separately, tracked against its designated category, and reported as such in the applicable Treasury Summary

CeloHT accepts restricted donations only where the designated purpose is genuinely achievable within CeloHT's current activity and capacity. Where a proposed restriction cannot realistically be honored, CeloHT declines the restriction and, where appropriate, offers the donor the option of an unrestricted donation instead.

3. Donation Refusal Policy

CeloHT reserves the right to decline a donation where:

  • Acceptance would create a conflict of interest not resolvable under CONFLICT_OF_INTEREST_FINANCE.md.
  • The donation's source cannot be adequately identified or reviewed under Section 1.
  • The donor attaches conditions inconsistent with CeloHT's mission, governance independence (LEGAL_STATUS.md Section 19), or non-token identity (NO_TOKEN_POLICY.md).
  • Accepting the donation would expose CeloHT to legal or reputational risk identified through the Legal Working Group's review.

Refusal decisions above routine Treasury Committee discretion are escalated to the Governance Council and logged, consistent with the Risk Management principles in GOVERNANCE.md Section 20.

4. Ethical Fundraising

  • CeloHT does not use high-pressure, misleading, or exaggerated claims in fundraising communications, consistent with the "avoid marketing language" and "avoid exaggerated claims" principles applied throughout CeloHT's documentation.
  • Fundraising materials accurately reflect CeloHT's current legal status, financial position, and programmatic track record, without implying results, registrations, or guarantees that do not exist.
  • CeloHT does not solicit donations by suggesting or implying any financial return, consistent with LEGAL_STATUS.md Section 4 and NO_TOKEN_POLICY.md.

5. Transparency Commitments

  • Donations are recorded and reported per FINANCIAL_TRANSPARENCY.md and FINANCIAL_REPORTS.md, subject to the privacy protections in Section 6 below.
  • Aggregate donation activity (total received, by category and reporting period) is published in the Quarterly and Annual Reports.
  • Named recognition of a donor occurs only with the donor's explicit consent.

6. Donor Privacy

  • CeloHT collects only the information necessary to process, record, and (where legally relevant) report a donation.
  • Donor identity is not published without the donor's consent; aggregate reporting (Section 5) does not require disclosing individual donor identities.
  • Donor personal data is handled consistently with the data protection commitments in LEGAL_STATUS.md Section 16 and is not sold, shared, or used for purposes unrelated to donation processing and reporting.
  • A donor may request anonymity, subject to the review requirements in Section 1 for donations above the stated threshold.

This document is maintained alongside GOVERNANCE.md, LEGAL_STATUS.md, FUNDING_POLICY.md, NO_TOKEN_POLICY.md, FINANCIAL_TRANSPARENCY.md, TREASURY.md, and CONFLICT_OF_INTEREST_FINANCE.md in the CeloHT governance repository.