1. Policy and Purposes
This Donor and Gift Acceptance Policy (this “Policy”) governs the solicitation and acceptance of gifts,
grants, contributions, donations and similar funding (collectively “Gifts”) by Sentinel Bio Inc. (“Sentinel”). The purpose of this Policy is to provide guidance for Sentinel’s board of directors (the “Board”), officers and staff with respect to their responsibilities concerning Gifts to Sentinel. The provisions of this Policy apply to all Gifts received by Sentinel Bio. The Board reserves the right to revise or revoke this Policy at any time, and to make exceptions to this Policy.
2. About Sentinel Bio
Sentinel Bio is a new nonprofit organization focused on eliminating pandemics within our lifetimes.
Sentinel Bio will help find, fund, and scale solutions to prevent biosecurity risks and respond to
pandemics, reducing threats to health and economic stability around the world.
3. General Policy Regarding Gifts
3.1 General Policy; Factors
The primary consideration for the solicitation or acceptance of Gifts will be the impact of the Gift on
Sentinel Bio and its mission, values and objectives. When considering whether to solicit or accept a Gift,
Sentinel Bio should evaluate the following factors:
(a) Mission and Core Values. Whether the acceptance of the Gift is consistent with or compromises
the mission or any of the core values of Sentinel Bio;
(b) Compatibility between Sentinel Bio and the Donor. Whether there is compatibility between the
intent of the donor with this gift and Sentinel’s use of the Gift;
(c) Reputation and Public Relationships. Whether acceptance of the Gift could support or damage
the reputation of Sentinel Bio;
(d) Relationships with Artificial Intelligence, Synthetic Biology, or other Pharmaceutical Companies.
Whether the donor has any current (i) employment, advisory, fiduciary or other working
relationship with, (ii) ownership, investment, equity interest or other financial interest in, or (iii)
compensation arrangement or other financial relationship with, any for-profit company whose
business includes the development of artificial intelligence technology, synthetic biology, or
pharmaceuticals and whether those interests could present a conflict of interest with Sentinel’s
mission, values and objectives;
(e) Primary Benefit of the Gift. Whether the primary benefit of the Gift is to Sentinel Bio or the
donor;
(f) Consistency and Prior Practice. Whether acceptance of the Gift is consistent with prior practice;
(g) Form of Gift. Whether the Gift is offered in a form that Sentinel can use without incurring
substantial expense, risk or difficulty; and
(h) Effect on Future Giving. Whether the Gift will encourage or discourage future Gifts from other
donors.
3.2 Grounds for Refusing Gifts
Sentinel Bio will not accept Gifts that:
(a) Violate the terms of Sentinel’s organizational documents or policies;
(b) Would jeopardize Sentinel Bio’s status as a 501(c)(3) tax-exempt organization under federal and
state law;
(c) Are too difficult, risky or expensive to administer;
(d) Are inconsistent with or contrary to Sentinel Bio’s mission or core objectives or are for purposes
that do not further Sentinel’s objectives;
(e) Could damage the reputation of Sentinel Bio; or
(f) Are associated with any illegal activity.
3.3 Review and Approval of Gifts
All final decisions on the acceptance or refusal of a Gift will be made by Sentinel Bio in accordance with
the requirements and guidelines set forth in this Policy. The Board may delegate the authority and
responsibility for reviewing and approving Gifts to any committee, officer, staff or team within Sentinel
Bio, and such authority may be general or may be confined to specific instances.
3.4 Gift and Pledge Agreements
Sentinel Bio may enter into grant, gift, pledge and similar agreements with donors for particular Gifts,
provided that the terms of such agreements are consistent with the requirements and guidelines
described in this Policy. Sentinel Bio should strive to include provisions in gift agreements that give
Sentinel Bio the right to terminate a particular gift agreement and/or return a particular Gift to a donor if
such action is necessary or appropriate to protect the mission or reputation of Sentinel Bio.
No donor will be allowed to exercise control or influence over Sentinel’s use of a Gift.
In general, Sentinel Bio will seek to solicit and accept Gifts from donors that are unrestricted in nature. If,
however, a donor wishes to make a restricted Gift to Sentinel Bio, Sentinel Bio will review the terms of
the Gift and the nature of the proposed restrictions to ensure they are consistent with Sentinel Bio’s
mission, values and objectives and are otherwise consistent with the requirements and guidelines of this
Policy. While Sentinel Bio may agree to appropriate restrictions on a particular Gift, such as using a Gift
for a particular purpose or program or reporting to a donor on Sentinel’s use of a Gift, Sentinel will not
allow donors to direct, control or influence how Sentinel Bio applies and uses a particular Gift. All such
restrictions on a particular Gift must be consistent with Sentinel Bio’s charitable mission and should be
described in a written gift agreement between Sentinel and the relevant donor.
3.5 Attestation by Donors
Sentinel Bio may ask donors to attest that they do not have any relationships, interests or activities that
are inconsistent with or in violation of Sentinel’s mission, values or core objectives or any requirements
of Sentinel’s policies, including this Policy. For example, Sentinel Bio may ask donors to certify that they
do not have any relationships with or financial interests in any frontier artificial intelligence, synthetic
biology, or pharmaceutical companies that would be inconsistent with Sentinel Bio’s mission or core
objectives, or any other relationships, interests or activities that would violate or be inconsistent with
this Policy.
4. Procedures for Vetting Donors
4.1 Review of Donors
Sentinel Bio may ask donors to attest that they do not have any relationships, interests or activities that
are inconsistent with or in violation of Sentinel’s mission, values or core objectives or any
requirements of Sentinel Bio’s policies, including this Policy. For example, Sentinel Bio may ask donors to
certify that they do not have any relationships with or financial interests in any for-profit artificial
intelligence companies, synthetic biology companies, or pharmaceutical companies that would be
inconsistent with Sentinel’s mission or core objectives, or any other relationships, interests or activities
that would violate or be inconsistent with this Policy.
4.2 Factors to Consider
In reviewing prospective donors and Gifts, Sentinel Bio should look for any information that raises a
concern about Sentinel Bio accepting the Gift. Review of prospective Gifts should include, but is not
limited to, the following:
(a) Whether the conduct, activities, statements or business of the donor, or companies and
organizations associated with the donor, are in conflict with Sentinel Bio’s mission, purposes,
values or objectives;
(b) Whether the donor, or companies or organizations associated with the donor, have been
associated with any controversy that could damage the reputation of Sentinel Bio;
(c) Whether the Gift, by virtue of the donor’s relationship to Sentinel Bio or the terms of the Gift,
may provide a substantial benefit to the donor, present a potential conflict of interest, and/or
violate any other Sentinel policies;
(d) Whether the donor, or any companies or organizations associated with the donor, have engaged,
or are alleged to have engaged, in any illegal or unethical activities, including any investigations,
inquiries, subpoenas, lawsuits, or criminal prosecutions relating to any such activities;
(e) Whether the donor, or any companies or organizations associated with the donor, are listed on
any sanctions list maintained by the U.S. Government or any foreign government;
(f) Any possibility that the Gift is or is alleged to be associated with any illegal activities by the
donor or anyone else, including fraud, theft, kickbacks, bribery, money laundering, terrorist
financing or sanctions; and
(g) What is the source of the donor’s Gift, and are there any legal, reputational or ethical risks
associated with such source.
4.3 Scope of Review
If appropriate, Sentinel Bio may perform a review of individuals, companies and/or organizations
associated with the donor. If the donor is a company or organization, Sentinel Bio may review the
company’s or organization’s founders, board of directors and executive staff. If the donor is an individual,
Sentinel Bio may review immediate family members of the donor, as well as businesses, companies,
nonprofit organizations and other entities controlled by or associated with the donor. It is important for
Sentinel Bio to consider whether the donor, and individuals, companies, organizations and entities
associated with the donor, are aligned with Sentinel’s mission to help find, fund, and scale solutions to
prevent biosecurity risks and respond to pandemics, reducing threats to health and economic stability
around the world.
4.4 Sources for Review
Sentinel Bio may use any appropriate and reliable sources to perform its review of the prospective donor
and Gift. These sources may include, but are not limited to, the following:
(a) Internet searches and use of news databases;
(b) Publications, annual reports, statements and other materials issued by a donor;
(c) Documents and information made available through litigation involving a donor or companies,
organizations or entities associated with a donor;
(d) Reports issued by government agencies, watchdog groups, academic institutions and other
reputable organizations;
(e) Filings, reports or returns that are filed with local, state or federal regulators. For nonprofit
organizations, this may include tax returns filed with the Internal Revenue Service and reports
filed with state nonprofit regulators. For publicly traded companies, this may include filings with
the Securities and Exchange Commission;
(f) Sanctions lists maintained by the U.S. Government or foreign governments, including the OFAC
Specially Designated Nationals And Blocked Persons List and the ITA Consolidated Screening List;
and
(g) Consultations with Sentinel Bio’s networks and trusted advisors, supporters, collaborators and
partners.
4.5 Assessment of Risk
After performing its review, Sentinel Bio will determine if the risk to Sentinel Bio in accepting the Gift is
low, medium or high. If Sentinel determines that the risk is medium or high, Sentinel Bio should consult
with the Board prior to deciding whether to accept the Gift. If Sentinel determines that the risk is low,
Sentinel may accept the Gift without first consulting with the Board.
4.6 Confidentiality of Donors; Gifts from Anonymous Sources
Sentinel Bio will consider on a case-by-case basis a donor’s request to treat the identity of a donor
and/or the terms of a donor’s Gift as confidential. Sentinel Bio will weigh such a request against other
important factors, including the importance of transparency in Sentinel Bio’s operations. If Sentinel Bio
agrees to such a request, any donor that requests anonymity for a particular Gift will not be publicly
identified in Sentinel Bio’s materials, communications, programs or events, to the extent permitted by
law. However, Sentinel Bio requires that all donors identify themselves when making a Gift to Sentinel,
and Sentinel will not accept Gifts from anonymous sources. Sentinel Bio will provide information about
its donors and Gifts to the Internal Revenue Service and other government authorities as required by
law.
4.7. Gifts from Foreign Sources
Sentinel Bio may accept Gifts from sources outside the United States, subject to the requirements and
vetting described in this Policy.
5. Donor Recognition for Gifts
Sentinel Bio recognizes that providing donors with recognition and naming opportunities at Sentinel Bio
can be an important part of encouraging Gifts to Sentinel Bio and thanking donors for their generosity. At
the same time, Sentinel Bio recognizes that donor recognition and naming opportunities at Sentinel
must be implemented in a manner that best supports the mission and protects the reputation of
Sentinel.
Sentinel Bio should consider the following guiding principles in its review of proposed Gifts to Sentinel
and associated donor recognition and naming opportunities at Sentinel:
(a) Mission and Reputation of Sentinel Bio. Sentinel Bio should consider the potential impact of a
particular Gift or donor recognition or naming opportunity on the mission and reputation of
Sentinel Bio. Sentinel Bio should not accept any Gift and should not agree to any donor
recognition or naming opportunity that is likely to generate significant controversy or negatively
impact Sentinel’s mission or reputation.
(b) Size and Nature of the Gift. The donor recognition or naming opportunity for a particular Gift
should be commensurate with the size and nature of the donor’s Gift. Sentinel should strive to
implement donor recognition and naming opportunities that are reasonably consistent across
Gifts of a similar size or nature.
(c) No Endorsement of Particular Companies, Products, or Services. Sentinel Bio may accept Gifts
from and provide donor recognition and naming opportunities for companies that manufacture
commercial products or provide commercial services, including Gifts from their affiliated entities
such as corporate foundations, subject to the requirements described in this Policy. However, no
donor naming or recognition opportunity will be approved that implies endorsement by Sentinel
Bio of a particular company or its products or services.
(d) No Endorsement of Partisan Political Positions. No donor naming or recognition opportunity will
be approved that implies endorsement by Sentinel Bio of a partisan political position.
(e) Duration of Donor Recognition or Naming Commitments. Sentinel Bio will consider on a
case-by-case basis a donor’s request that Sentinel provide donor recognition or naming
commitments for a particular or minimum period of time. If Sentinel Bio approves such a
request, Sentinel Bio should strive to include an option that gives Sentinel the right to terminate
a Gift or a donor recognition or naming commitment if such action is necessary or appropriate to
protect the mission or reputation of Sentinel Bio.
Sentinel Bio may approve donor recognition and naming opportunities for particular donors and Gifts to
Sentinel provided that such donor recognition is consistent with the requirements and guidelines
described in this Policy.
6. Administration of this Policy
This Policy has been reviewed and accepted by the Board, which has the sole authority to update,
modify or revoke this Policy. The Board or its designee must approve in writing any exceptions to this
Policy for a particular Gift.
VERSION HISTORY
Adopted: 25-06-2024