HP Global Charitable Contributions Policy

HP0003-01 30-Apr-2020

Internal use only

Owner

Michele Malejki

Responsible Group

Sustainability and Product Compliance

Sponsor

Matt Buckley

Document Identifier

HP0003-01

Revision date

10-May-2023

Last Re-validation date

10-May-2023

This is an uncontrolled copy when in printed form.

Introduction

HP has a long history of charitable giving and community involvement. This policy has been established to reflect

company-wide considerations, processes and controls that are to be employed to ensure charitable actions are carried

out with fairness and due diligence and are reflective of HP's core values and business interests.

Scope

This policy establishes principles and requirements for making charitable contributions and applies to all HP employees

and business units worldwide. The term "charitable contributions," as used in this policy, refers to monetary or in-kind

donations, including grants, donated to a charitable organization, academic institution, or library.

As used in this policy, the term charitable contributions does not include donations made in exchange for a benefit

(e.g., meals, memberships, event participation, marketing rights). "Sponsorship" refers to any arrangement whereby

HP provides financial support, products, services, or anything of value to a third party (including charitable

organizations), in exchange for the acquisition of rights that allows HP to associate its brand with another brand in a

broad, publicly visible way. The term "sponsorship" will include anything defined as such in HP's Sponsorship Policy. For

example, the purchase of tables at charitable events or participation in a charity golf tournament are examples of

sponsorships and are not charitable contributions. Any sponsorship must comply with the HP's Sponsorship Policy and

AntiCorruption Policy.

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Philosophy

HP is a recognized multi-national corporation with a global workforce and facilities in communities worldwide.

We seek to reflect our corporate values and sustainability objectives in all locales with a profound respect of all

cultures and the unique social needs found country to country.

Our strategic giving programs (described in greater detail below) are defined by the Digital Equity and Social Impact

Team and engineered to have relevance in the countries and markets in which we are present and competing. We

proactively partner with employees and organizations that can help ensure responsible engagements with those

schools and organizations receiving a charitable contribution from HP.

We recognize the diversity of people, culture, and social needs. We seek to align our giving to be reflective of our brand

values and to be helpful in resolving a social need and advancing our HP business and market interests.

HP organizations are encouraged to extend HP's sustainability values. This may be manifested, with the approval of

requisite leadership, by locally coordinated volunteerism and giving initiatives where access and leverage of

centralized funding or administrative capability does not exist.

Policy

HP seeks to address social needs through strategic philanthropic investments that build brand equity and support HP

business priorities. We align our philanthropic priorities with our business and brand objectives by investing in

educational institutions and nonprofit organizations around the world that promotes learning and enrich lives.

Charitable contributions and all HP business-driven giving initiatives are to be executed within a controlled framework

that mitigates risk, ensures fairness in the consideration of prospective beneficiaries, complies with applicable laws, and

reflects HP values, business and social interests and the behaviors of exemplary corporate sustainability.

HP supports strategic charitable contributions, with emphasis in the areas of Education, Healthcare and Economic

opportunity, and also encourages and supports programs to facilitate employee giving. These strategic giving

programs are administered through the HP Digital Equity and Social Impact.

Giving Practices

The HP Corporate Giving Team administers the company's charitable contributions protocols. Our charitable giving

activities are reflective of the assets that HP can bring to organizations in need: specifically, monetary donations and

equivalents such as HP products.

• Product giving is highly encouraged. HP products are typically procured from within the company at "cost," to

allow HP the opportunity to deploy technology in the context of good sustainability and develop brand

awareness in diverse nonprofit and academic settings.

• Monetary donations remain an element of HP's giving strategy and may supplement strategic product donation

transactions. Occasional charitable contributions that are exclusively monetary are permitted.

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• Charitable contributions must be documented in writing, including the intended recipient, eligibility criteria,

and payment terms.

• Charitable giving transactions must be executed and recorded according to the (1) written agreement with the

recipient, and (2) financial policy reflected in Section 6590 of HP's Accounting and Finance Manual (AFM).

Where possible, funds intended to purchase equipment or provide services should be paid directly to the

vendor.

Recipient Eligibility Criteria

ALL RECIPIENTS of HP charitable contributions must meet the following criteria

• All giving must be to either a 501(c)(3) organization (in the United States) or equivalent (outside of the United

States), or a certified academic institution;

• The organization's primary mission is non-sectarian, non-religious, non-denominational, non- discriminatory,

and non-political; and

• The organization's policies and practices are consistent with HP's non-discrimination policies and practices. HP

will not make contributions, matching gift donations or product donations to organizations that discriminate on

the basis of race, color, ethnicity, creed, religion, gender, gender identity and expression, national origin, sexual

orientation, age, pregnancy, disability, veteran status, protected genetic information, or political affiliation.

Restrictions on Charitable Contributions

HP cannot provide charitable contributions to:

• Individuals;

• Organizations whose primary purpose is to promote political views, influence legislation, or support candidates

for public office;

• Organizations located in countries where US Trade Embargo is in place or on HP's Restricted Parties List;

• Churches, houses of worship, religious or sectarian programs for religious purposes, or religious training

programs including but not limited to seminaries, theology schools, or yeshivas;

• Fraternal organizations; or

  
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•  Non-profits not currently holding a 501(c)(3) exempt status or international equivalent. No charitable giving is 
to be made in a manner that would:  
•  Be or create the appearance of a bribe, kickback or other corrupt practice.  
  
•  Directly procure HP future business or otherwise be made with the intent to obtain or retain business, 
secure an improper advantage, or induce anyone to act improperly. 
 
•  Circumvent existing HP rules relating to giving business amenities highlighted in the Global  Business 
Amenities Policy. 
 
•  Be inconsistent with applicable law and HP's policies, including its Anti-Corruption and Conflicts of  Interest 
policies. Disclosure of board seats and involvement with organizations, including indirectly through a close 
relative or friend, that may be petitioning HP for a charitable contribution or product donation is essential to 
protect HP, the employee or executive, and the organization. See the HP policy Service by HP Employees as a 
Director or Officer of a non-HP Company.  
Additional Approvals for Public Sector Transactions  
•  The HP Public Sector Compliance team (PSGiftRuleCompliance@HP.com) must approve all charitable 
contributions to a U.S. public sector institution or agency, including a business owned or operated by the U.S. 
public sector or a  U.S. public or private school or library, to ensure adherence with HP's Public Sector "Code of 
Conduct".  
•  You must consult the Anti-Corruption Office before agreeing to donate to a charitable organization, public or 
private school, or a public sector institution or agency, in connection with any public sector sales promotion, 
tender, or bid scenario.  
•  The Anti-Corruption Office must also approve all charitable contributions, if a government official has, or may 
have, an interest, directly or indirectly, in the organization.  
Charitable Contributions Valued at $10,000 or Greater  
In addition to the requirements above, charitable contributions valued at $10,000 USD or greater, regardless of HP 
funding source, must be approved by the HP Corporate Giving Team to ensure proper recipient engagement, legal 
vetting, and tax documentation are adequately developed and completed.  
•  Corporate Giving procedures require due diligence of a potential grantee or recipient be completed PRIOR to 
announcing an intention to give.  
•  At least a L2 executive must complete and submit an Anti-Corruption Checklist Certification to the Corporate 
Giving program manager.  

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See HP Corporate Giving for additional information regarding the due diligence and approval procedures. If a corporate

giving proposal is being made valued at $10,000 or greater, that proposal must include:

• A proposal from a grantee with clear goals and success measurement criteria.

• Signed HP Terms and Conditions for the donation or contribution.

• A confirmation of receipt once goods or monetary donations are received.

• Written acknowledgment on file from the recipient organization to be claimed as a tax deduction in the United

States.

• All appropriate detail associated with a grantee or recipient organization: names, address, tax identification

status confirmation, and other information.

Charitable Contributions Valued Less Than $10,000 USD

Charitable cash contributions with values less than $10,000 USD may be made by any HP organization and do not

require the completion of a corporate giving application as mandatory.

Such charitable contributions, however, must be consistent with the principles contained within this Policy. HP

Corporate Giving Team will still take part of the process to ensure all our policy requirements are met. HP Corporate

Giving Team may request additional information, tax and legal documentation in order to provide approval.

For all US product donations that have a FMV (Fair Market Value) of equal to or greater than $5,000 must follow our

Corporate Giving Process.

All charitable contributions made to a public sector entity require the corporate giving application completed

regardless of the amount.

Employees within the HP organization must retain the related documentation according to HP Record Retention policy

(HP Global Master Records and information Management Policy). All U.S. Corporate Donations of $250 or more are

required to have a written acknowledgment on file from the recipient organization to be claimed as a tax deduction in

the United States.

Strategic Giving Programs

HP's charitable contributions and Corporate Giving making activities within its strategic giving programs, as defined and

coordinated by Digital Equity and Social Impact Team to maximize the impact of our philanthropy by developing global

programs that showcase HP technology in a solutions-oriented context. These programs are developed in conjunction

with HP business organizations to align strategic giving initiatives with areas of market and technological interest.

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Strategic Corporate Giving initiatives are developed and announced annually, often with a Request for Proposal

message soliciting requests from schools and organizations related to a particular theme, such as advancing the

process of teaching, community engagement, and so forth.

All strategic giving programs are coordinated by the HP Digital Equity and Social Impact Team in collaboration with

Business Unit and or Global Function leadership.

U.S. Employee Giving Programs

HP provides resources to match employee giving. Each fiscal year a U.S. Employee Cash Giving program is funded by

the HP Company Foundation. This is a first come, first served model, coordinated through an external service provider

specializing in cash-based charitable transactions. The program is launched at the beginning of the fiscal year and is

available as long as funds are available.

Business Unit Used Equipment Donations

The HP Corporate Giving Team realizes that certain HP businesses may have access to used HP and non-HP equipment,

that is no longer of value to HP and could be of use to qualified recipient organizations. As such, despite HP not being

able to recognize the same tax and reporting benefits associated with donating new HP equipment, used HP and non-

HP equipment may be given in accordance with the requirements set in the Used HP Product and Used Non-HP

Product procedures (click here for the web page containing both procedures at the bottom).

Reporting

HP reports its global charitable and citizenship activities each year in the form of a HP Sustainable Impact

Report. The report is a critical element, leveraged worldwide, in the messaging of our sustainability and

giving profile. It reflects the company's total giving activity, which is derived from a centralized data and

corporate giving repository managed by the HP Digital Equity and Social Impact Organization. It is in HP's

best interest to have all giving activity captured centrally, to accurately and fully reflect the rate of

contributions activity and social goodwill that HP manifests annually.

Additionally, centrally capturing all charitable contributions information allows our HP sales, marketing and

executive teams to have access to information related to HP's activity in given regions, countries, cities and

organizations – and to what financial extent. Often this information is essential in developing new business

relationships, particularly in new market areas.

The HP Company Foundation

The HP Company Foundation is a distinct legal entity unto itself and is not a discretionary resource for HP's

philanthropic pursuits.

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References

Accounting and Finance Manual

Anti-Corruption Policy

Conflicts of Interest Policy

Sustainability Report

Sponsorship Policy

Service by HP Employees as a Director or Officer of a non-HP Company

Employee Volunteerism Policy

Human Resources website

Public Sector "Code of Conduct"

Global Business Amenities Policy

Revision History

Revision

Description of Change

06-Oct-2008

Initial Release

09-Apr-2010

Updated Organization, Sponsor and Contact

13-Feb-2012

Updated Organization, E-Rate, and Public Sector

15-Mar-2012

Updated reference to a referenced policy's name change.

06 Nov 2012

Revised to cover the donation/granting of used HP and non-HP products to qualified

non-profit organizations by HP business units.

19-Dec-2012

Revised to cover the donation/granting of used HP and non-HP products to qualified

non-profit organizations by HP business units.

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30-May-2014

Updated Organization and Restrictions on Contributions

26-June-2015

Revised to clarify definition of charitable contribution and add approval by the Anti-

Corruption Office.

01-Aug-2015

Cloned for HPI

16-Sep-2016

Update to the Policy with some language and some of the links that were pointing to

HPE still.

22-Jun-2017

Updated the Sponsor, Organization and owner details

29-Apr-2020

Updated hyperlinks and switched out HP Human Resources to Digital Equity and Social

Impact Team. Added our $5000 value US product donation process. Updated Grants

to Corporate Giving

06-Jun-2023

Provided greater clarity on charitable contributions valued less than $10K (wording

change)