1. PRI Identification
2. The Actively-Conducted Program This PRI Supports
Describe the Foundation-run program the PRI sits inside, its charitable objective, and how the PRI advances it (not merely that funds were granted).
3. The Foundation’s Substantial Body of Expertise
The significant-involvement test asks whether the Foundation brings genuine expertise and conducts the program itself. The following is generally true for the Foundation; tailor as needed.
The Foundation’s co-founders and personnel bring directly relevant expertise: Charles Eesley is a Professor of Management Science & Engineering at Stanford whose research examines how institutional environments shape entrepreneurship and technology commercialization, and who has taught entrepreneurship to more than 200,000 students; Lijie Zhou leads the Foundation’s programs and brings engineering and education-program experience. The Foundation has conducted entrepreneurship and CS/AI education programs across multiple communities (including Molokai, Malaysia, Vietnam, Tanzania, Taiwan, and Uganda) and has made mission-related and program-related investments since 2021. This expertise enables the Foundation to design, supervise, and actively conduct — not merely fund — the program this PRI supports.
4. Significant Involvement by Foundation Personnel
Describe the specific, continuing, hands-on involvement by the Foundation’s own people — e.g., regular advising of the recipient’s leadership, recruiting directors, fundraising introductions, curriculum or technical assistance, monitoring. Token involvement does not qualify; substance and continuity do.
Involvement time log:
| Date | Person | Activity (advising, recruiting, intros, monitoring) | Hours |
|---|---|---|---|
5. Self-Dealing / Disqualified-Person Screen
| Confirmation | Confirmed |
|---|---|
| No disqualified person (Founder, director, officer, family) holds or seeks a personal financial interest in the recipient | ☐ |
| The Foundation is not co-investing alongside any disqualified person’s personal holdings in the recipient | ☐ |
| All mentorship/assistance is rendered solely in the Foundation’s charitable capacity | ☐ |
| No Founder/director/officer has taken or will take compensation, equity, advisory shares, carried interest, or a board seat from the recipient for this assistance | ☐ |
6. Institutional (University) Conflict Screen
If the deal flow or program connects to a Founder’s university role (e.g., a Stanford program, accelerator, or research project), record the relationship and the clearance obtained under the applicable institutional COI process.
7. Expenditure Responsibility Status
Required whenever the recipient is not a U.S. public charity (including foreign nonprofits and for-profits). Note: a foreign nonprofit such as Challenges Uganda is generally NOT a U.S. public charity, so expenditure responsibility applies.
8. Direct-Conduct Characterization
Based on the program, expertise, and significant involvement documented above, the Foundation treats this PRI as support within a program it actively conducts and, accordingly, as a qualifying distribution made directly for the active conduct of its exempt activities for purposes of the operating-foundation income and endowment tests. The Foundation acknowledges this characterization is fact-intensive and subject to confirmation by counsel.
9. Board Determination and Annual Review
This memorandum is an internal governance record, not legal advice. Confirm the significant-involvement characterization and expenditure-responsibility status with qualified counsel.