How to Create a HR Policy for Your Employee Giving Program

In the first post in our series on How to Create Employee Giving Programs, 

How to Start an Employee Matching Gifts Program in 6 Easy Steps, we shared how to:

Step 1 – Act Like a Startup

Step 2 – Set a Budget for a Pilot or Test Program

Step 3 – Decide on the Employee Matching Gift Rate

Step 4 – Decide Eligibility Criteria

Step 5 – Choose a department, division, or sub-group to use as a pilot

Step 6 – Select Cloud Software as a Service tool to Manage your Program


That’s a great start, however, you may now be asking….

  • What kind of policy is needed to implement this employee giving program?
  • How do we protect our employees and also the reputation of our company?
  • What about Branding our Employee Giving Program?

How to Create a HR Policy for Your Employee Giving Program

In this segment, How to Create a HR Policy for Your Employee Giving Program, we answer those questions by looking more in depth at creating eligibility criteria for both employees participating in the employee matching gift program and also the eligibility of recipient organizations.

If your company is shying away from offering an Employee Giving Program due to fear of the potential risk of a publicity blunder, these recommendations will help mitigate those risks.

The Basics


First, we’ll start with the basics.  Let’s assume you just created the following Employee Matching Gifts Program:

Employee Matching Gift Program:

myCompanyGives Program Highlights:

  • myCompanyGives Employee Matching Gift Rate:  100%, dollar for dollar for monetary donations
  • myCompanyGives matches the tax deductible portion of the charitable contribution… (more on this later)
  • myCompanyGives will match up to $500 per employee per calendar year, beginning in 2016.
  • Minimum Donation Amount:  $10
  • For larger contributions, myCompanyGives will match the first $500.
  • Receipts stating the 501(c)(3) status of the organization and the tax deductible amount of the contribution must be attached to the request.

9 Steps to Create a HR Policy for Your Employee Giving Program

To create a HR policy supporting this Employee Giving Program, we are going to evaluate the following 9 steps.

These 9 steps will help you to:

Step 1 – Determine your Employee Eligibility Criteria

Step 2 – Determine eligible contributions

Step 3 – Research and Set Eligibility Criteria for recipient organizations

Step 4 – Identify ineligible organizations

Step 5 – Select a charitable partner who offers specific projects or funds International needs

Step 6 – Ensure Foreign Corrupt Practices Act Compliance

Step 7 – Tax Compliance – Audit Proof Your Employee Matching Gifts Program

Step 8 – Branding

Step 9 – Document & Share your Employee Giving Program Highlights and detailed policies.

Below, you will find recommendations and suggested policies for each item.


Step 1

Step 1 of HR Policy for Employee Giving Programs - Determine Employee Eligibility to Participate


If you hire contractors, include a statement regarding contractor eligibility or ineligibility to participate.


Large organizations often extend Employee Matching Gift Programs to their retirees, however, often at a reduced rate.  We recommend you include a statement regarding the eligibility of retirees.

Step 1 – Determine your Employee Eligibility Criteria 

Eligible Employees:

Most companies extend their CSR, Employee Matching Gift Program to all employees.

If you are not exceeding your budget, we encourage you to extend the program to all employees, including part-time employees.

If budgets are a concern, a phased in approach would extend the program to full-time employees the first year which allows time to assess the potential costs of extending the program to part-time employees.

Remember, the lean startup approach?   Act like a startup within your company.   That means begin with a minimum viable program, then iterate it over & over as you move forward adjusting the program as you gain more experience in its administration.

Restrictions, if any, on the employee’s eligibility to participate in the Employee Matching Gifts Program may include limiting participation to full-time employees  who have:

  • Completed their probationary period (if applicable);


  • The point in time when the employee is eligible for other company benefits.

Step 2

Step 2 – Determine eligible contributions

This post is focused on monetary contributions.  However, these policies apply equally well to Employee Dollars for Doers Programs.    

First, state what contributions are eligible for the Employer Match and include examples.   Next, we recommend you also state examples of ineligible contributions.  It’ll save you time answering the questions, as they will surely be posed.

Be sure to capture the portion of the gift that is tax deductible.  This should exclude any personal benefit the employee may have received, such as an event ticket or meal.

The following is an example:

Eligible Contributions:

–         Tax Deductible monetary donations including donations by cash, check or credit card.

Ineligible Contributions:

–         In-kind gifts (auction items, gift baskets, etc), volunteer service hours, other non-monetary items.

–         The portion of the donation that resulted in personal benefit, such as event tickets and the value of the meal at a charity event.

Step 2 of HR Policy for Employee Giving Programs - Determine Eligible - Ineligible Contributions

Step 3

Step 3 of HR Policy for Employee Giving Programs - Determine Charity Eligibility

Step 3 – Research and Set Eligibility Criteria for Recipient Organizations

To protect your company and its employees, we recommend the Employer Matches be restricted to 501C3 organizations, including organizations supporting schools that are “In Good Standing”.

Our recommendation is to vet and if you see any potential red flags, decline the match for that particular organization  Your “In Good Standing”  and the “right to decline at our sole discretion” clauses (below) have you covered.

Using cloud software products, like GivingTrax Cloud Software, makes the entire process of vetting fairly easy and straightforward.


For international needs, our recommendation is to restrict the Employee Matching Gift Program to US based 501C3 organizations that serve international needs.  A good example of one such organization is Global Impact.  Global Impact offers a series of project specific funds to support items such as Clean Water, Disaster Relief,  etc., a federation of vetted organizations with feet on the ground around the work, and the means to distribute funds to them efficiently.


Most schools have a 501C3 organization that helps to fund projects or programs.

For those that don’t, there are many ways employees can support schools without direct monetary contributions.

School backpack programs, shoes for the children programs are a great example.  You can learn more about these offerings at:  How to Engage Employees by Supporting Local Schools…. without Giving Money (coming soon).

Below is an example policy for eligibility criteria:

Eligible Organizations:

–         US 501(c)(3) organizations in good standing

–         US 501(c)(3) organizations serving international needs

Step 4

Step 4 – Identify Ineligible Organizations

“In Good Standing” gives you the flexibility to decline matching contributions even when the organization meets your general criteria.  Do your homework when vetting for the matching contribution.  

The following is a recommended policy statement on ineligible organizations:

Ineligible Organizations:

  • Political organizations
  • Churches, except for sub-entity that is a US 501(c)(3) charitable organization
  • Organizations deemed to have values or a mission not aligned with myCompany’s values, policies, and Code of Business, Code in Ethics.
  • myCompanyGives reserves the right to approve or deny matching requests at our sole discretion.
Step 1 of HR Policy for Employee Giving Programs - Identify Ineligible Organizations

Step 5

Step 5 – Select a charitable partner who offers specific projects or funds International needs

Step 5 of HR Policy for Employee Giving Programs - Select International Partner - 960x320

International Projects:

Beyond the basics, do you want to recommend organizations for specific causes?

Along with the Employee Giving Program, that is matching many smaller contributions by employees across a broad spectrum of charitable organizations, we recommend you adopt a couple of strategically aligned charitable organizations or areas of need, for making larger grants aligned.

This can be as easy as creating a higher matching rate for target recipient charitable organizations addressing specific areas of need.  Or, it could be encouraging support through employee volunteerism.    Encouraging employee volunteerism by adopting a cause (or causes) that needs both monetary support and more tangible items, such as school back-packs, are a great way to foster employee engagement and to bring awareness to your Employee Matching Gift Program.

Either way, along with matching, we encourage clients to consider larger investments in strategically aligned organizations.


Step 6


Step 6 – Ensure Foreign Corrupt Practices Act Compliance

Foreign Corrupt Practices Act

To ensure compliance with the Foreign Corrupt Practices Act, we recommend you restrict the matching contributions to U.S. 501C3 charitable organizations.

For companies using cloud software tools, like GivingTrax Cloud Software to manage their CSR Matching Gifts Program, it is also easier to ensure the company contributions are not made to organizations on the Terrorist Watch List.

If you are a multi-national organization with employees located elsewhere around the World, the Foreign Corrupt Practices Act compliance applies to your Employee Giving Program.  The Foreign Corrupt Practices compliance questions are available to GivingTrax Cloud Software members and clients.

Step 7

Step 7 – Tax Compliance – Audit Proof Your Employee Matching Gifts Program

Having been the subject of an IRS Audit of our Companies Tax Returns (and passing), we are well armed to make a few suggestions to help ensure you have the appropriate documents needed for compliance with IRS regulations.

First, always ensure you’ve have supporting documents for the recipient charitable organization.  These include:

  • A copy of the 501C3 certification letter:  One-Time
  • A signed W-9:     Yearly
  • IRS Database Screenshot of Current Status:  Every Donation at time of disbursement

The IRS publishes a database of IRS charities and also publishes organizations whose status has been revoked.

It’s also a good idea to obtain contact information for the organization, to that any required documentation that is not publically available can be obtained.


Step 8


Step 8 – Branding:

Now we are on to the creative aspects of your program.

Beyond these policies, in terms branding your program,  we recommend choosing a name  such as YourCompanyNameGives.

Combining your company name with the word Give is trending as a common approach to branding the Employee Giving Program.  If you are able, reach out to your marketing team and create a logo that represents your campaign.

Step 9

Step 9 – Document Your Employee Matching Gift Program Policy

An example of  a Employee Matching Gift program and the supporting HR Policy is available for you to use.  Just click the “chat” button, email us at [email protected] or call us at (206) 486-0185.



Act Like A Startup

Remember, Act Like a Startup.  Your Employee Giving Programs and supporting HR Policies do not need to be perfect, the first time.  Start small, learn and adjust as you gain more experience.

Most of all, enjoy…. You have a fantastic job that is making the world a better place.

We're Here to Help...

Congratulations on starting an Employee Giving Program.

We hope this helps simplify the process of creating your programs and underlying policies.

At first glance, this may seem daunting, however, using a cloud software solution, like GivingTrax,  for Employee Giving Programs makes the process easy.

We invite you to try out GivingTrax… all you need is an email id.  We’ll even set up a profile and create test accounts for you to explore how GivingTrax works. Best of all there is no fee to see how easy and intuitive GivingTrax really is for you and for your employees.