This seems quite burdensome. In order to accept a $10k donation from a ‘high-risk’ PopVax employee (listed on 80k’s job board!) you’d have to:
Involve a wide range of senior people in your org:
A wide range of functions and units across CC are part of the process to decide on Donations and Partnerships. The process will typically include input from CC’s:
Development Team
Relevant program or project team
Legal Team
CEO
Development Council
Members of the Board of Directors, where relevant expertise is needed
Pay for a wealth screening database:
current and prospective Donors that meet the criteria for screening described above will be screened using a wealth screening database
Write a written report that is reviewed by many senior people:
the Development Team will provide a written report to the CEO, the Legal Team, any relevant program / project teams, the Development Council and board members selected by it and the Development Team for review and approval during the Qualification Stage of the fundraising pipeline.
be very diligent:
Decisions are taken after thorough examination of such Donation [emphasis added]
Review each year:
CC reviews Donors and their fundamentals every year at the renewal or annual anniversary of a multi-year relationship
Regularly stalk them on social media:
regularly monitors the media for developments linked to Donors. The monitoring is carried out by the Development Team with support from staff and relevant project teams as reasonably requested.
Communicate frequently with donors with feedback about their business practices:
CC aims to maintain a frequent, transparent and constructive engagement with Donors. This enables the CC to be a critical friend where appropriate.
… and a $10k donation from a Palantir employee would simply be totally prohibited.
Overall it seems plausible to me that actually following this for a $10k donation would eat up most of the donation in due diligence overhead. My guess is that CC does not actually follow the letter of this policy in practice.
I just posted the CC policy as an example of a donor screening policy, and by posting it I don’t necessarily endorse its exact contents. As you helpfully pointed out, the terms of this policy could be overbroad and burdensome, and would have to be adapted to the different context in which EA orgs operate.
“a $10k donation from a Palantir employee would simply be totally prohibited”
First, many EAs donate a lot more money ($1-10k/year) than the average non-EA donor, so $10k would likely be on the high end for a gift to CC but typical for an EA org. So I think the threshold for an EA org to scrutinize a donor should be much higher than CC’s threshold - $50-100k might be appropriate.
Second, by “totally prohibited” I think you are referring to the section on exclusionary criteria. The most relevant criteria for your Palantir example might be these ones:
the Donor’s involvement in:
The manufacture or sale of arms, including any direct or indirect involvement in the manufacture or sale of illegal or controversial weapons;
International crimes; this encompasses International crimes as defined in treaty and customary law, which include violations of International Humanitarian Law (IHL) and violations of International Human Rights Law (IHRL), such as crimes against humanity, genocide, torture; as well as other international crimes such as piracy, transnational organized crime, human trafficking, financing of terrorism, amongst others;
Even if taken literally, this would only apply to Palantir employees who work directly on weapons systems or any software that is being used to commit violations of international law (such as war crimes). Palantir has branches that work with the private sector, and most employees there would likely be exempt.
That said, if it applied to literally all employees who worked on a particular project at Palantir, it’s probably too broad. Taking money from rank-and-file employees of Palantir (or any large tech company) is unlikely to bring CC into disrepute, but taking money from a senior executive might. (That said, there is a group trying to disparage the events startup Partiful based on its founding employees’ connections to Palantir, though it’s hard to say how much influence they will have.)
Decisions are taken after thorough examination of such Donation [emphasis added]
As @huw suggested in another comment, this could be outsourced to an organization or team that can do centralized donor vetting and risk scoring for the whole EA community. Impact Ops comes to mind (and in fact does this).
by posting it I don’t necessarily endorse its exact contents.
Well you did suggest people could “emulate” and “copy-paste”
Even if taken literally, this would only apply to Palantir employees who work directly on weapons systems or any software that is being used to commit violations of international law (such as war crimes).
No, any employee who is ‘involved’ in arms, including totally unobjectionable sales to the US Government, would be involved. The language is quite clear that, while it includes illegal weapons, there is nothing to suggest it is limited to them. As far as I can see even accountants would be ‘involved’ - you can’t make weapons without accounting!
Larks, I’ve noticed that your comments on this post focus on criticizing the specific rules in the CC donor policy document that I shared as an example for other EA organizations to consider. You rightly point out that some of these rules might be impractical for EA orgs to follow. However, I feel frustrated because I think your responses have missed the point of my original post, which was to highlight the value of having a written donor screening policy, and to offer the CC document as a resource that other orgs can legally copy and adapt to their own needs (under the CC-BY license), rather than to recommend that others adopt the policy verbatim.
I would appreciate it if we could keep the conversation focused on discussing the broader idea of implementing donor screening policies or processes for EA orgs, rather than getting bogged down in the specifics of this document tearing down this specific policy without suggesting alternatives. By focusing on the bigger picture, we can ensure that EA organizations develop systems that promote transparency and trust, especially in light of past controversies such as FTX. I think this approach would help build more confidence in the community, while still allowing for flexibility in implementation.
If you have thoughts on how these policies or processes could be better adapted to fit the needs of EA organizations, I’d be glad to discuss them here. I hope we can continue this conversation in a collaborative and constructive way.
Using a very simple cntrl-f methodology, I estimated that over 95% of this post is the CC Guidelines. In contrast you spend less than one sentence arguing for having such a policy, and zero words whatsoever considering tradeoffs. If you want engagement on something you need to provide some material to engage with, and if you thought the CC Guidelines were inappropriate for EA orgs and require significant modification you should say so in the post! I don’t think you can share a lengthy post and then declare, post hoc, that almost the entire post is off-limits, running the risk that orgs might copy-paste it without understanding the issues, and that comments should be restricted to a topic which was barely mentioned in the post.
Indeed, as far as I can see even you agree with this, since one paragraph after chastising me for getting “bogged down in the specifics of the document” you ask for advice on how to adapt these policies, which necessarily involves engagement with the specifics.
This seems quite burdensome. In order to accept a $10k donation from a ‘high-risk’ PopVax employee (listed on 80k’s job board!) you’d have to:
Involve a wide range of senior people in your org:
Pay for a wealth screening database:
Write a written report that is reviewed by many senior people:
be very diligent:
Review each year:
Regularly stalk them on social media:
Communicate frequently with donors with feedback about their business practices:
… and a $10k donation from a Palantir employee would simply be totally prohibited.
Overall it seems plausible to me that actually following this for a $10k donation would eat up most of the donation in due diligence overhead. My guess is that CC does not actually follow the letter of this policy in practice.
I just posted the CC policy as an example of a donor screening policy, and by posting it I don’t necessarily endorse its exact contents. As you helpfully pointed out, the terms of this policy could be overbroad and burdensome, and would have to be adapted to the different context in which EA orgs operate.
First, many EAs donate a lot more money ($1-10k/year) than the average non-EA donor, so $10k would likely be on the high end for a gift to CC but typical for an EA org. So I think the threshold for an EA org to scrutinize a donor should be much higher than CC’s threshold - $50-100k might be appropriate.
Second, by “totally prohibited” I think you are referring to the section on exclusionary criteria. The most relevant criteria for your Palantir example might be these ones:
Even if taken literally, this would only apply to Palantir employees who work directly on weapons systems or any software that is being used to commit violations of international law (such as war crimes). Palantir has branches that work with the private sector, and most employees there would likely be exempt.
That said, if it applied to literally all employees who worked on a particular project at Palantir, it’s probably too broad. Taking money from rank-and-file employees of Palantir (or any large tech company) is unlikely to bring CC into disrepute, but taking money from a senior executive might. (That said, there is a group trying to disparage the events startup Partiful based on its founding employees’ connections to Palantir, though it’s hard to say how much influence they will have.)
As @huw suggested in another comment, this could be outsourced to an organization or team that can do centralized donor vetting and risk scoring for the whole EA community. Impact Ops comes to mind (and in fact does this).
Well you did suggest people could “emulate” and “copy-paste”
No, any employee who is ‘involved’ in arms, including totally unobjectionable sales to the US Government, would be involved. The language is quite clear that, while it includes illegal weapons, there is nothing to suggest it is limited to them. As far as I can see even accountants would be ‘involved’ - you can’t make weapons without accounting!
Larks, I’ve noticed that your comments on this post focus on criticizing the specific rules in the CC donor policy document that I shared as an example for other EA organizations to consider. You rightly point out that some of these rules might be impractical for EA orgs to follow. However, I feel frustrated because I think your responses have missed the point of my original post, which was to highlight the value of having a written donor screening policy, and to offer the CC document as a resource that other orgs can legally copy and adapt to their own needs (under the CC-BY license), rather than to recommend that others adopt the policy verbatim.
I would appreciate it if we could keep the conversation focused on discussing the broader idea of implementing donor screening policies or processes for EA orgs, rather than
getting bogged down in the specifics of this documenttearing down this specific policy without suggesting alternatives. By focusing on the bigger picture, we can ensure that EA organizations develop systems that promote transparency and trust, especially in light of past controversies such as FTX. I think this approach would help build more confidence in the community, while still allowing for flexibility in implementation.If you have thoughts on how these policies or processes could be better adapted to fit the needs of EA organizations, I’d be glad to discuss them here. I hope we can continue this conversation in a collaborative and constructive way.
Using a very simple cntrl-f methodology, I estimated that over 95% of this post is the CC Guidelines. In contrast you spend less than one sentence arguing for having such a policy, and zero words whatsoever considering tradeoffs. If you want engagement on something you need to provide some material to engage with, and if you thought the CC Guidelines were inappropriate for EA orgs and require significant modification you should say so in the post! I don’t think you can share a lengthy post and then declare, post hoc, that almost the entire post is off-limits, running the risk that orgs might copy-paste it without understanding the issues, and that comments should be restricted to a topic which was barely mentioned in the post.
Indeed, as far as I can see even you agree with this, since one paragraph after chastising me for getting “bogged down in the specifics of the document” you ask for advice on how to adapt these policies, which necessarily involves engagement with the specifics.
Also, what makes PopVax “high-risk” according to CC’s criteria, in your opinion?
PopVax is an Indian biotechnology company. Biotech is a type of pharma company.