Global Giving Policy

For non U.S.-based Charitable Organizations

I. Criteria

WDC requires that non-profit organizations and non-government organizations (NGO’s) seeking support from WDC or any of its subsidiaries, meet specific criteria to be considered for support.  Such organizations must:

  • Be previously designated a tax-exempt non-profit organization or otherwise designated as a bona fide charitable organization under the local laws or customs of the respective country
  • Show program capability, sound fiscal policies, responsible management, and evidence of long-range planning and effective use of volunteers
  • Have a competent, active board of directors or similar governing body providing sound policies and guidance to the organization and its members
  • Produce a budget, financial statements and a plan for funding beyond the period covered by the proposed contribution
  • Show a method of evaluating the results of the proposed project

In addition, we require:

  • There are no deals that are contingent (either in fact or in appearance) upon the granting of the charitable aid
  • Normal due diligence has been conducted to verify that the charity is legitimate and reputable, and financially stable
  • The charity’s mission is consistent with the philanthropic priorities of Western Digital Corporation (Education, Basic Human Needs, Civic and Environment)

The Western Digital Foundation and the Foundations reserve the right to make funding and contribution decisions within their sole and absolute discretion and may alter these criteria without notice at any time.

II. Limitations and Exclusions

Western Digital’s charitable contributions are not automatically renewing in nature.  If an organization receiving current or previous support from Western Digital desires additional funding, it must submit a new grant request. Such request will be evaluated in relation to other submitted requests and budgetary considerations at the time of the new request, and may or may not be approved.

The Foundations will not provide grants or other charitable contributions under circumstances that are not permitted by or conflict with the policies of Western Digital Corporation or the Western Digital Foundation or applicable law.

The Foundation will not provide grants to:

  • Individuals
  • Customers, distributors, suppliers or other business partners
  • Organizations that discriminate on the basis of race, color, creed, religion, gender, sexual preference, disability, age, or national origin
  • Grant-making foundations
  • Political organizations
  • Organizations failing to meet Western Digital’s corporate standards for ethical operation and social value
  • Fund raising events such as galas, golf tournaments, etc.  Any exceptions must be approved by the Western Digital Foundation Board of Directors in advance

III. Compliance with Anti-Bribery and Corruption Laws

Company donations are part of Western Digital Corporation’s commitment to society and a way of contributing to worthy causes. They reflect our identity as a responsible corporate citizen. Unfortunately, even legitimate donations sometimes have the risk of creating the appearance of corruption.  For example, funding charitable organizations that would benefit a third party (such as a government official) in some way may create an appearance of corruption.

The corruption risk can also be more direct like funding non-existent or illegitimate charitable organizations to conceal corrupt payments.

To avoid improper use of charitable donations, Western Digital requires that:

  • Donations may not be offered, promised or given if they are intended to influence official action or secure an improper advantage
  • Donations may not be made to individuals, to for-profit organizations, to organizations that do not have tax-exempt status or whose goals are not compatible with the principles in the Global Code of Conduct
  • Donations must be transparent
  • Donations should be tax-deductible
  • Payments to private accounts or in cash are not permitted
  • Duplicate donations are to be avoided
  • It must be possible at all times for the person initiating the donation to justify the reasons for a donation and to be accountable.

All applicants for contribution or support must disclose if a Public Official has any connection to or will benefit in any way from a charitable donation.  The term “Public Official” includes any officers or employees of a government, or any department or agency of a government, at any level (e.g., local, regional or national) or branch (e.g., legislative, executive, judicial or military), political parties, party officials, any candidate for political office, and officers and directors of wholly or partially state-owned, controlled or operated enterprises (e.g., state-owned hospital, bank, utility, oil company, airport).  A Public Official does not have to be a high-ranking government official; even low-level administrative or clerical personnel are included.  By way of example, Public Officials include: firefighters, police, politicians, military personnel, customs agents, immigration clerks, and employees of state-owned enterprises.

Any contribution or support involving a Public Official, government agency or government institution requires the advance approval of the Western Digital Legal Department.

Western Digital’s Anti-Bribery and Corruption Policy, available by request, provides further guidance concerning compliance with anti-bribery and corruption laws.

IV. Application Procedures

Non U.S.-based charitable organizations meeting the requirements listed above are asked to email a letter of inquiry to one of the appropriate individual below.  Please include information about your organization and the specifics of your request including the project or program for which you are seeking funds.

Inquiries will be reviewed by volunteers and staff of the Foundations for initial recommendation of denial or approval. Those accepted will be invited to apply for a Western Digital Foundation grant. The Western Digital Foundation makes the final recommendation.  The Company reserves the right to make funding and contribution decisions within its sole and absolute discretion.

Global contacts:

Thamanoon Songsana
Chairperson, Western Digital Foundation Thailand

Wan Zailena Mohd Noordin
Chairperson, Western Digital Foundation Malaysia

Rosemary Krupp
Director, Western Digital Foundation &
Global Community Relations