The purpose of this policy is to advance educational opportunities by supporting the education of employees of Blue Mound Golf and Country Club (“the Club”) and their children and dependents. This policy establishes procedures and eligibility criteria for the award of scholarships by Blue Mound Golf & Country Club Foundation, Inc. (the “Foundation”), a Wisconsin nonstock corporation organized and operated for tax-exempt purposes under Section 501(c)(3) of the Internal Revenue Code (the “Code”). It ensures that the scholarship program is administered in accordance with applicable federal tax laws, including IRS guidelines for company-sponsored scholarship foundations, while maintaining the Foundation’s charitable and educational mission.

The Foundation’s Board of Directors shall be responsible for reviewing applications and approving scholarship recipients. All decisions regarding scholarship awards shall be made by the Board in accordance with the eligibility and selection criteria set forth in this policy. The Board shall apply these criteria objectively and consistently to ensure compliance with applicable IRS guidelines and to maintain the integrity of the Foundation’s charitable mission.

To be eligible, a recipient must be a current Club employee who has worked for the Club for at least 2 seasons, or a child or dependent of such an employee. Recipients must have graduated from high school or earned a GED.

Recipients must be admitted to, or current students of, a college, university, trade school, or similar institution or registered for a professional certification program.

In accordance with IRS rules and to avoid prohibited self-dealing under IRC § 4941, the following individuals are not eligible for scholarships:

1. Children or dependents of officers, directors, or trustees of the Foundation;
2. Children or dependents of substantial contributors to the Foundation;
3. Children or dependents of members of the Board of Directors of the Foundation;
4. Children or dependents of individuals who exercise substantial influence over the Foundation.

In compliance with applicable IRS restrictions, the Foundation’s scholarship program shall be:

1. Objective and nondiscriminatory;
2. Primarily for the benefit of the general public or a charitable class;

The Board of Directors must award scholarships on an objective and nondiscriminatory basis using one or more of the following criteria:

1. Academic achievement;
2. Financial need;
3. Demonstrated leadership or community service; and
4. Special talents or interests;

Selection criteria shall be published in the application materials and applied consistently to all applicants.

1. Applications will be made available to all eligible participants and widely publicized.
2. Each applicant must complete and submit an application form, along with supporting documentation.
3. The Board of Directors will evaluate applications based on published criteria.
4. Whenever possible, awards will be given to the educational institution on behalf of the recipient. Alternatively, awards may be made to the recipient or the recipient’s sponsor as a reimbursement upon presentation of documentation that the eligible expenses have been paid by the recipient or his or her sponsor.
5. The Foundation will verify enrollment before disbursing any funds.

Scholarship awards may be one-time or renewable, subject to the recipient maintaining eligibility. The Foundation will monitor recipients’ academic progress and confirm continued enrollment. If a recipient becomes ineligible, remaining scholarship funds will be forfeited or redirected.

To ensure compliance with IRS regulations under Section 4945 of the Code and Rev. Proc. 76-47, the Foundation’s scholarship program shall meet the following standards:

1. The number of scholarships awarded to children of employees must not exceed either:
   1. 25% of the number of employees’ children who were eligible, who applied for scholarships, and who were considered by the Committee; or
   2. 10% of the total number of employees’ children who were eligible, regardless of whether they applied.
2. If it is impossible for the program to meet the percentage tests describe above, the Committee shall ensure that the program satisfies all of the following criteria:
   1. The program is not used to recruit or retain employees.
   2. The Board of Directors operates independently of the Club.
   3. Eligibility is based on objective criteria.
   4. Selection is based on academic merit, financial need, or other objective standards.
   5. Scholarships are not contingent on continued employment of the parent.
   6. The program is widely publicized to Club employees.
   7. The course of study is not limited to those benefiting the Club or Foundation.
   8. The program’s primary purpose is to educate recipients, not to compensate employees.

The Foundation will maintain documentation supporting compliance with these criteria and seek advance IRS approval of its grant-making procedures as required.

The Foundation will maintain records of:

1. All applicants and recipients;
2. Selection criteria and procedures;
3. Minutes of board meetings related to scholarship decisions;
4. Amount and purpose of each scholarship;
5. Follow-up and academic performance data.

These records will be retained for at least seven years and made available for IRS examination if requested.

This policy shall be reviewed annually by the Board of Directors and updated as necessary to reflect changes in applicable laws or IRS guidance.