Date: 12/8/97 9:49 AM Subject: s7-26-97 Thank you for the opportunity to provide public comment to the proposed bills relating to corporate philanthropy, H.R. 944 and 945. I am commenting from the perspective of a Regional Association of Grantmakers serving the Commonwealth of Massachusetts. Our organization provides extensive public philanthropic information services to nonprofits, corporate, private, community foundation and other grantmakers, and the general public interested in philanthropy. We are well aware of the importance and value of clear, current, public information about philanthropy. Indeed the 100 grantmaking member organizations of this Regional Association of Grantmakers, roughly 43% of whom are Corporate Grantmakers, actively support the extensive, free, very accessible public information resources that we, Assocated Grantmakers of Massachusetts, provide to thousands of users via hardcopy and online resources. Many corporations clearly see the value of clear, effective, public guidelines for their philanthropic engagement, and turn such philanthropic activity into a strong business and community asset. I do not think that regulation needs to impose what market forces and positive, community-building corporate values logically create. My thoughts about the two proposed bills are as follows: Public information about philanthropic activity certainly benefits multiple constituencies (among them, employees, communities, nonprofits, shareholders) and does generally assume a baseline of well-thought out, rationally directed philanthropic activity. Indeed we see the prevailing trend among corporate grantmakers in our region as being pro-active and public in nature, given that there is careful integration of philanthropic activity into the overall business strategy and plans. Corporate grantmakers usually take their philanthropic responsibility to invest in their communities quite seriously, and they do so in ways that add value to nonprofits of extraordinary diversity, focus and scope; to corporate employees, and, to the general health and profitability of their corporations. I do not support specific, directive, legislation of the nature outlined in H. R. 944 and 945. Corporate philanthropy is a key business decision and as such I cannot agree with the apparent interest to break this particular function out from other business functions for shareholder review and direction. Effective philanthropy adds value in my opinion to corporations, thus benefitting shareholders directly, as one of many critical management responsibilities and functions. Indeed, corporate philanthropy would likely be strengthened by more shareholders sending the message that they value management focus on and allocation of resources to effective philanthropic activity that benefits corporate health. However, this is not best achieved by the proposals in this legislation. Other respondents have commented well on the potential management problems from opening up shareholder participation in corporate philanthropy given the global nature of shareholders locations and interests. There is potential conflict between multiple shareholder personal philanthropic interests and focused, well thought out corporate philanthropy seeking to make a focused, accountable impact. Corporate staff do bring substantial expertise relating to the depth of issues in a given community or issue area, and can direct philanthropic resources to effective nonprofits with missions concurrent with corporate philanthropic interests. I have a concern about the potential deleterious effect that such regulation could have on new or emerging corporate givers, particularly small and mid-sized companies who are interested in philanthropy, but concerned with developing effective giving programs. They benefit from having a range of choices and incentives for engaging in philanthropic giving, not from regulation that could render the process cumbersome and not of direct benefit to customers, communities, employees. Effective philanthropy is often not simple, from-the-heart activity, given the range of issues, needs and possible options for directing philanthropic resources within American society. We all have increased challenges around broadening, not dampening, sources of philanthropic resources. I see many potential complicating and deleterious effects of the proposed legislation on corporate philanthropy, which is after all voluntary. I do not think the legislation takes into account either the complex, strategic realities of corporate philanthropy today, or the range of public and proactive ways that corporations engage in effective philanthropic giving. Sally Peabody President Associated Grantmakers of MA 294 Washington Street Boston, MA 02108 speabody@agmconnect.org