Date of Board Resolution: October 5th, 2022
This policy establishes investment objectives, policies, guidelines and eligible securities related to all assets held by Endaoment.org, and/or any of our subsidiary corporations, primarily for investment purposes. (‘institutional funds”) In doing so the policy:
- Clarifies the delegation of duties and responsibilities concerning the management of institutional funds.
- Identifies the criteria against which the investment performance of the organization’s investments will be measured.
- Communicates the objectives to the Board, staff, investment managers, brokers, donors and funding sources that may have involvement.
- Confirms policies and procedures relative to the expenditure of institutional funds.
- Serves as a review document to guide the ongoing oversight of the management of the organizations’ investments.
The Board of Directors has a direct oversight role regarding all decisions that impact Endaoment.org’s institutional funds. The Board has delegated supervisory responsibility for the management of our institutional funds to the Investment Committee. The Investment Committee will be composed of subject-matter experts with knowledge of investment, finance, non-profit management, and other relevant expertise. The Investment Committee will meet quarterly to review current investment policies and procedures to ensure Endaoment.org is engaging in prudent investment management. Specific responsibilities of the various bodies and individuals responsible for the management of our institutional funds are set forth below:
The Board shall ensure that its fiduciary responsibilities concerning the proper management of Endaoment.org’s institutional funds are fulfilled through appropriate investment structure, internal and external management, and portfolio performance consistent with all policies and procedures. Based on the advice and recommendations of the Investment Committee, the Board shall:
- Select, appoint and remove members of the Committee.
- Approve investment policies and objectives that reflect the long-term investment-risk orientation of the Endaoment.org endowment.
Members of the Investment Committee are not held accountable for less than desirable outcomes, rather for adherence to procedural prudence, or the process by which decisions are made in respect to invested assets. In consideration of the foregoing, the Committee is responsible for the development, recommendation, implementation and maintenance of all policies relative to Endaoment.org’s institutional funds and shall:
- Develop and/or propose policy recommendations to the Board with regard to the management of all institutional funds.
- Recommend long-term and short-term investment policies and objectives for our institutional funds, including the study and selection of asset classes, determining asset allocation ranges, and setting performance objectives.
- Determine that institutional funds are lawfully, prudently, and effectively managed with the assistance of management and any necessary investment consultants and/or other outside professionals, if any.
- Monitor and evaluate the performance of all those responsible for the management of institutional funds.
- Recommend the retention and/or dismissal of investment consultants and/or other outside professionals.
- Receive and review reports from management, investment consultants and/or other outside professionals, if any.
- Periodically meet with management, investment consultants and/or other outside professionals management, investment consultants and/or other outside professionals.
- Convene regularly to evaluate whether this policy, investment activities, risk management controls and processes continue to be consistent with meeting the goals and objectives set for the management of institutional funds.
Management shall be responsible for the day-to-day administration and implementation of policies established by the Board and/or the Investment Committee concerning the management of institutional funds. Management shall also be the primary liaison between any investment consultants and/or other outside professionals that may be retained to assist in the management of such funds. Specifically, management shall:
- Oversee the day-to-day operational investment activities of all institutional funds subject to policies established by the Board and/or the Investment Committee.
- Contract with any necessary outside service providers, such as: investment consultants, investment managers, banks, and/or trust companies and/or any other necessary outside professionals.
- Ensure that the service providers adhere to the terms and conditions of their contracts; have no material conflicts of interests with the interests of Endaoment.org; and, performance monitoring systems are sufficient to provide the Investment Committee with timely, accurate and useful information.
- Meet with any outside service providers as needed to evaluate and assess compliance with investment guidelines, performance, outlook and investment strategies; monitor asset allocation and rebalance assets, as directed by the Investment Committee and in accordance with approved asset allocation policies, among asset classes and investment styles; and, tend to all other matters deemed to be consistent with due diligence with respect to prudent management of institutional funds.
- Comply with applicable laws and official accounting and auditing guidelines regarding due diligence and ongoing monitoring of investments, especially alternative investments. Prepare and issue periodic status reports to the Board and the Investment Committee.
In accordance with Endaoment.org’s understanding of California's Uniform Prudent Management of Institutional Funds Act, the Investment Committee must consider the purposes of both Endaoment.org and our assets in managing and investing institutional funds. All individuals responsible for managing and investing Endaoment.org’s institutional funds must do so in good faith and with the care that an ordinarily prudent person in a like position would exercise under similar circumstances. In making any decision relative to the management and investment of institutional funds, each of the following factors must be considered, and properly documented, in the minutes or other records of the applicable decision-making body:
- 1.General economic conditions;
- 2.Protocol security,
- 3.Possible effect of inflation or deflation;
- 4.Expected tax consequences, if any, of investment decisions or strategies;
- 5.The role that each investment or course of action plays within the overall investment portfolio of the fund;
- 6.Expected total return from the income and appreciation of investments;
- 7.Other resources of the organization;
- 8.The needs of the organization and the fund to make distributions and preserve capital; and,
- 9.An asset’s special relationship or special value, if any, to the organization’s purposes.
These guidelines are meant to inform the way that donated capital owned by Endaoment.org smart contracts ecosystem is invested. The investment goal is to achieve a stable return, while the optionality for donors to recommend investment into the digital asset industry over time. The following guidelines apply to all investment asset classes:
Crypto Allowable Range: Minimum 0% - Maximum 25% of total platform assets, per the following maximum macro asset allocations:
- 25% ETH, or wrapped derivatives thereof, where the derivative is non-algorithmic and backed with a 1:1 ratio of native token reserves held in escrow.
Endaoment.org may hold any amount of USDC, or other USD pegged, non-algorithmic stable coins backed with a 1:1 ratio of fiat reserves held in escrow. Any amount of those USD-backed funds may also be deployed into money-market interest bearing USD pegged stable coins from yield protocols that meet the Board's published Protocol Evaluation Criteria.
Endaoment.org will create Deposit Caps for each portfolio that effectively restrict its size on the platform in order to maintain conformity with the aforementioned guidelines. A Deposit Cap can be set at any level at or below what is permitted in accordance with the Crypto Allowable Range by the Endaoment.org staff, and are subject at any time without prior notice. All Deposit Caps will be publicly visible in the Endaoment.org UI.
Normal and expected market conditions can lead to investments falling outside of the Crypto Allowable Range (e.g. in the case of extreme growth of a portfolio's underlying asset). In the case that any portfolio's value leads to an investment falling outside of the Crypto Allowable Range the Board shall discuss remedies at their next quarterly Board meeting. Remedies may include but are not limited to adjusting the Crypto Allowable Range or force exiting any portion of any portfolio allocation.
Only well-audited and tested crypto assets will be utilized for any Endaoment.org portfolio with the objective to seek stable growth consistent with current market conditions. While crypto assets don’t have ratings in the way traditional investment assets do, the Investment Committee and Management team are responsible for determining the quality of both the asset(s) themselves as well as the underlying protocol(s). Assets will only be considered for investment if their underlying protocol is a minimum of 6 months old, the underlying code is publicly accessible, and has undergone a security audit. All assets must be classified under the macro allocation allowances above per the asset’s character or type else they shall not be considered for use in portfolios.
In addition, all potential assets must be evaluated and scored by either the Crypto Ratings Council (CRC) and/or the Investment Committee per the CRC’s Securities Law Framework, and score a 2 or lower. A PDF of the framework can be found here: https://assets.website-files.com/5d766f847039d787f8a99a02/609998f89636a3f99c8429c6_CRC%20Securities%20Law%20Framework.pdf
No assets considered by Endaoment.org may utilize any form of leverage in order to achieve return or otherwise as part of its protocol. No leverage of any kind can be used for any crypto investment, either within or outside of portfolios.
In all instances, donor intent shall be respected when decisions are rendered concerning the investment of donor restricted funds when possible and not in conflict with internal policies. Endaoment.org retains full control of the funds and can, without notice to the donor, evacuate any investment position if it deems it to be unsafe, risky, or undesirable for any reason; provided, however, that if Endaoment.org accepts a particular gift subject to a lawful restriction on investments, it will comply with such restrictions.
Endaoment.org retains the right to effectively change or convert any investment or holding within any fund or organization smart contract at any time, as a response to fluctuating market conditions.
Regardless of how well any particular asset is audited, vetted, researched, etc. there always remains an inherent risk in using any form of cryptocurrency. Stable coins can de-peg, on-chain investments can become insolvent, derivatives backed with native token reserves held in escrow may fall below their ideal 1:1 ratio. With this basis of understanding, Endaoment.org will act swiftly in response to any such event or threat thereof. These actions may include but are not limited to evacuating any portfolio position on behalf of any fund or organization or removing any portfolio from access, migrating assets to different or newly deployed smart contracts, changing the base token of the platform, temporarily suspending activity via the UI, temporarily moving assets off-chain to to another chain, and other blockchain and fiat transactions meant to ensure the security of the platform and value of assets.