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Climate Action Funding Opportunity: Action Fund

We are delighted to announce an incredible opportunity to develop and deploy highly visible and replicable projects that demonstrate community-led, data-driven, and lasting innovation in local climate action through the Action Fund!

Made possible through funding from Google.org, ICLEI Local Governments for Sustainability USA, Inc. (ICLEI USA) is accepting expressions of interest (EOI) from nonprofit and civil society organizations or consortiums of organizations (located in the US or US territories) that have a plan to accelerate the implementation of a city climate action plan while addressing inequality.

Each of the two awardees or consortiums will receive $1,000,000 to fund activities identified by the awardee and ICLEI USA and supported by local government leadership.

ICLEI USA is now accepting EOI until April 11th, 2022 (Submit here). A round of finalists will be advised by May 11, 2022, of the opportunity to provide a full proposal.

Read more about the Action Fund EOI requirements, timeline, information session, General FAQ, and Answered Questions from Information Session.

Expressions of Interest Requirements 

Applicants will propose activities that support, leverage, or align with:

  • A city-wide greenhouse gas (GHG) inventory and related science-based target 
  • Political will to advance climate action, climate equity, and just energy transitions
  • A climate action plan that includes goals related to at least one of the following: sustainable mobility, buildings, solar energy development, air quality management, or urban tree canopy
  • The city’s ability to qualify for or implement public or private funding to multiply the impact of the Google.org award (e.g., federal or foundation grants)
  • A city that has not received a donation or grant funding or been the beneficiary of funding of $1,000,000 or more in the past 2 years (via American Cities Climate Challenge or other climate or energy-related program)

ICLEI USA will review expressions of interest and invite full proposals from applicants meeting the above criteria. In addition, ICLEI USA will provide technical assistance during the proposal development and project deployment phases and support communication efforts to share results and lessons learned from selected projects.

Learn more about the Action Fund and the expressions of interest requirements here.

Timeline 

  • April 11th, 2022 Expressions of interest due (Submit EOI here)
  • May 11th, 2022 Invitations to apply announced at the ICLEI World Congress 
  • July 15th, 2022 Full proposals due 
  • September 16th, 2022 Awards announced
  • December 16th, 2022 Complete due diligence and execute contracts 
  • January 15th, 2024 Activities completed and funds spent

Action Fund Information Session

We are hosting an information session about the Action Fund on March 16th from 1 PM – 1:30 PM EST. Join us to learn more about the Action Fund, outline how to apply, and answer participants’ questions. Register today!

General FAQs

Q: Does the city need to be an ICLEI member to apply? 

A: No, but the city must meet the prerequisite requirements: GHG inventory, Science-based target, and high-impact action summary, all of which are available to ICLEI members. Contact us if you have questions. 

Q: Can the funds be granted to the city for regranting to non-profits? 

A: No, funds must flow directly from ICLEi USA to a nonprofit or civil society organization

Q: We would like to support a contiguous group of cities (e.g. the Denver region). Is this acceptable? 

A: Yes, but you will need the expressed support of the highest-level elected official from each city if you are invited to submit a full proposal.

Q: I represent a regional council of governments. Can I apply and propose actions to support my region?

A: Assuming your regional council of governments is a nonprofit entity, yes you may apply. The activities you propose can benefit the entire regional boundary. You will need to demonstrate support of the regional organization by providing a declaration or other notice of agreement from the governing body of the Regional Council. We assume that these board members will be representatives of local governments within the region.

Q: We are a national nonprofit organization serving cities and counties across the United States. Can we apply and serve many of our constituents?

A: As a nonprofit organization you can apply. You can suggest a set of activities that supports one and only one city or county within your network. You can suggest activities that support more than one city or county, but only if those two local governments are contiguous to one another and share a geographic boundary.

Q: Can the funding be used to support cities and counties outside of the United States?

A: No.  

Q: I represent a nonprofit organization working with a number of cities across the US who would like to have a new software tool developed. Can the funds be used to develop this tool?

A: The action fund is designed to support the implementation of a local climate action plan. It is not intended for assessments or planning processes. Applications will need to demonstrate that the activity or activities proposed will result in tangible and quantifiable greenhouse gas reductions and they support a climate action plan of a single city, county or contiguous group of local governments.

Q: Is there a page limit to the expressions of interest?

A: Please be concise in your response. We are looking for 1 to 2 paragraph responses to each of the three questions. A group of applicants will move to a second round where a full proposal will allow applicants to provide much more detail about the proposed activities.

Q: Our non-profit was very interested in applying for this funding. Though our city has conducted a Green House Gas Inventory and City Council has passed a Carbon Neutral Resolution, the Climate Action Plan is still being developed. So, we cannot qualify for this year’s grants. Will there be another funding opportunity like this next year?

A: We certainly hope so, however, we have no commitment for future funding at this time. Thank you for your interest and congratulations on getting to this point in the journey.  Let us know how ICLEI can continue to support the CAP development.

Answered Questions from Information Session

If you submitted questions during the March 16th, 2022 Action Fund Info Session, please refer to the following sections to read answers: Eligibility Questions, Role of Cities and Counties with Action Fund, Requirements for Climate Action Plan, Expressions of Interest Application (General), Demonstration of Community Need, and Information about Google.org Grant Funds.

Is your question not answered? Submit your question(s) about the Action Fund here (open until March 28th)!

Eligibility Questions

Q: Who can apply to the Action Fund?

  • Are local county governments eligible to apply for these funds? 
  • Is this funding only available to cities?
  • Is this funding only available to cities, or are other science-based organizations eligible?
  • Are unincorporated counties eligible to apply?
  • Can a community without non-profit status apply?
  • May the funds be used by Territories?
  • Are expressions of interest from Universities eligible?
  • Could grant funding me used as seed funding for 501(c)(3) nonprofit yet to be created (such as a local green bank)? The nonprofit would be in place at the time of grant receipt, just not at this time.
  • Can a 501(c)4 organization receive grant funding
  • Could a community foundation – that would then distribute funding to non-profits and combine funds with other resources – be an eligible lead applicant?
  • Would an organization funded by a federal entity that works regionally but wants to focus on one city be eligible?
  • Can the partner NGO pass funds on to a city, or does the NGO need to spend the money directly?
  • My organization has two legal entities, a 501 c4 and a 501c3.  Should we apply as the 501c3, or do you have a preference?
  • Can an organization that partners with a municipality apply? 
  • Is a Sustainability Commission that worked on the Sustainability Action Plan a valid organization to apply to be included in the Consortium of groups involved?
  • Are U.S. Territories allowed to apply?
  • Are universities eligible to be the lead institution in applying for the Action Fund?

A: Only established organizations recognized by the Internal Revenue Service as 501(c)3 are eligible to apply, lead a consortium, and receive funding.  The IRS written determination of status must be in place by April 11, 2022.  Grant funds cannot be passed from the nonprofit awardee to a city or county.

Q) Does it matter if the County/City government serves as the main applicant or do you prefer that a nonprofit partner serve as the main applicant / submitter ? Is it correct that all funding must be used by nonprofit (501(c)3 partners?

A: Only established organizations recognized by the Internal Revenue Service as 501(c)3 are eligible to apply, lead a consortium, and receive funding.  The IRS written determination of status must be in place by April 11, 2022.  Grant funds cannot be passed from the nonprofit awardee to a city or county.

Q: Can the application come from a consortium of nonprofits, with one in the lead?  For example, a state-based or national NGO in the lead, partnering with one or more community-based nonprofits in the city?  

A: Yes, provided that the state based or national NGO and partners are all 501(c)3 organizations.

Role of Cities and Counties with Action Fund

Q: Explain the role of cities and counties with regard to this grant funding

The purpose of the Google.org grant funding is to provide financial support to a nonprofit or consortium of nonprofits to implement strategies documented in a local climate action plan.

Q: What qualifies as a “local” climate action plan?

A:  A climate action plan is a written plan to mitigate greenhouse gas emissions occurring within the political boundary of a city or county. The climate action plan must be published on the local government’s website by April 11, 2022 in order to be considered adopted for the purposes of this grant.  A draft plan is permissible, provided that the plan meets the requirements in the previous sentence, is actionable, and is a document used by local political leaders to inform decision making. ICLEI maintains a map of published climate action plans for your reference. This is not an exclusive list. Please contact us if you would like to suggest the addition of a published plan.

Q: Can an application from a nonprofit or consortium of nonprofits support more than one city or one county climate action plan?

A: The proposed activities may support more than one city or county – provided that the cities or counties share a geographic border and that each city or county in which the proposed interventions occur meets the other eligibility criteria, namely each and every city or county must have a science-based target and published climate action plan.

Q: Are County governments eligible or only in partnership with cities?

A: A nonprofit or consortium of nonprofits can submit an application to support a county government.

Q: Are non-profits able to apply for a water district?

A: The grant funds must support the implementation of a city or county-wide climate action plan. Support for a water district is not an eligible activity on its own. However, if the city or county in which the water district is located includes strategies and goals related to the water district operations, the nonprofit could propose implementation of those activities.

Q; Could we be a regional organization that is facilitating a small group of contiguous cities, such as a group of environmental justice communities within our region?

A: Yes, provided that each of the cities meets the eligibility requirements.

Q: I’m interested in proposing a regional collaboration.  Does each participating city or county need to have these targets, or can I use our state-wide goals?  Several of our proposed cities have adopted climate action plans with SBT’s, should we focus on those?

A: The purpose of the grant funding is to implement local climate action plans. State-wide goals, while supportive, are not the focus of this grant funding. Applications should propose actions in cities that have adopted climate action plans with SBTs.

Q: If a city-wide GHG inventory is required for the applicant, and multiple cities are joining together to apply with a non-profit, which city inventory is used?

A: Cities are ineligible to apply or receive funding. A nonprofit can support multiple contiguous cities, provided that each city supported has published a climate action plan and adopts science-based target.

Q: What about the American Cities Climate Challenge cities?

A: The purpose of the Google.org grant funds is to implement climate action in communities who are poised and ready for action and have not received philanthropic implementation support in the past two years (2020, 2021). Therefore, the cities who received support from Bloomberg Philanthropies via the American Cities Climate Challenge cannot be supported by this grant. 

Q: If the city received American Cities funds prior to 2020 & 2021, is that ok?

A: No

Q: What if your collaborative group of locals are neighboring to American Climate Cities grantees?

A: This is acceptable, provided that each and every city supported meets the climate action plan and science-based target requirements.

Q: I see that regional governments are eligible to apply.  What if one or more city within the regional government footprint has been or is an American Climate Cities recipient?  Is the regional government still eligible?  Some of the activities could benefit those core center cities that are ACCC.  

A: The regional government, provided it is a 501C3, can apply. The regional government should suggest activities that benefit non-ACCC communities only.

Q: In the Q&A, a response says, “…(F)unds must flow directly from ICLEI USA to a nonprofit…”  Once a nonprofit obtains the funds, how is it allowed to use them?  To pay contractors and providers directly?  As rebates to participants in a community solar buy-in program?  What are the guidelines?

A: This response was intended to communicate that only nonprofit organizations can receive grant funding. Cities and counties are not eligible to apply for or receive funds. Yes, all of the uses you’ve listed: contractors, providers, rebates etc. would be allowable use of funds.

Requirements for Climate Action Plan

Q: What are the requirements for the climate action plan? Please define “adopted”…can this be a mayoral commitment or do we need a Council action? If a draft version of a Climate Action Plan is available, but still in process to be adopted – does that meet the requirements?

A: A climate action plan is a written plan to mitigate greenhouse gas emissions occurring within the political boundary of a city or county. The climate action plan must be published on the local government’s website – as a final (not draft) document by April 11, 2022 in order to be considered adopted for the purposes of this grant.

ICLEI maintains a map of published climate action plans for your reference. This is not an exclusive list. Please contact us if you would like to suggest the addition of a published plan.

Q: Does the community’s climate action plan need to be science-based? Meaning do the climate action goals need to be per capita goals?

A: The climate action plan does not need to be science-based or contain per capita goals. If the climate action plan includes a community wide GHG reduction target that is less ambitious than a per capita science-based target, the community will need to adopt a science-based target by July 31, 2022.  

Q: What are the requirements for the science-based target?

  • If we don’t have a science-based target now, but do have aggressive GHG reduction targets and plan to convert to science-based targets in 2023, will that qualify for applying? 
  • By what date do we need to have a Science Based Target approved?
  • What does it mean to have adopted a science-based target? 
  • We have received science-based targets from ICLEI, but our sustainability plan set goals of 50% reduction of CO2 by 2025 and carbon neutral by 2040. Is a resolution from our Governing Body required to be eligible for the grant?

A: The local government must accept the science-based target by July 31, 2022 – the full proposal deadline.  Acceptance can be in writing by a person or governing body who has the authority to make public commitments to achieve climate targets on behalf of a local government. 

Q: Can ICLEI staff review targets to confirm if they are science-based?

A: Yes, ICLEI can review targets and will do so based upon the guidance document developed and published by ICLEI USA in 2021.

Q) We would like clarification on the Science Based Target to ensure we meet it. The specifics are below. Does the City meet the requirements?

* The City just adopted a CAP this year based on a 2017 inventory and projected forecasts for population growth. The inventory was developed by our local regional planning agency who sits on the ICLEI working group for updating inventory approaches.

* This CAAP sets a legal target and an aspirational goal. We believe both meet the Science Based Target standard as they exceed 50% reduction by 2030:

” Legal Target. The CAAP sets in motion a suite of programs that are designed to reduce the community’s greenhouse gas (GHG) emissions to 80% lower than levels in 1990 over the next ten years, meeting a State-mandated legal target.

” Climate Safe California Goal. On July 6, 2021, the City Council voted unanimously to support the Climate-Safe California Campaign* goal of net-negative emissions by 2030, setting an aspirational goal for the community to remove more GHGs than it emits by 2030. The Council and staff acknowledge that meeting this goal will be challenging. However, bold leadership is necessary to address the existential threat of climate change, and this goal sends a message to the State that its current goals and funding are insufficient to meet the demands of climate change, and must be accelerated. “

A: Yes – this city has adopted a science-based target.

Q: If we are looking to do activities countywide, would every city within the county need to have adopted science-based targets by the time the proposal is due?

A: That depends on the proposed activities. If your proposal is to implement a strategy listed in the county climate action plan, only the county need have a science-based target. If your proposal is to implement strategies listed in multiple city climate action plans then each of those cities must have a science-based target.

Q: Will there also be potential funding to align or update cities w/ existing climate action plan to science-based targets, if they were not considered science based, before?

A: No

Expressions of Interest Application (General)

Q: How many pages would you prefer the Expression of Interest submittals to be?

A: We prefer narrative answers to be no more than two paragraphs each.

Q: In the Expression of Interest, Applicant Organization question, would it be just the lead organization or more than one organization involved that would benefit?

A: Please list the lead organization and the lead organization’s contact. If you feel it is important for the evaluation of your expression of interest, please include the names of other nonprofit consortium partners in your narrative answer. 

Qs: 

  • Are you collaborating, or can we show leverage w/ say CDP’s sustainable financing cohort?
  • Is match required?  If so, is in-kind match allowed? Do you have to have a commitment for additional funding or is the city being eligible sufficient?

A: No matching funds are required.  However, successful proposals will strongly demonstrate the potential to leverage Google.org grant funding to attract additional investment in the community.  

Q: Can a nonprofit contract with a private company to conduct some of the work for a project?

A: The purpose of this grant funding is to build nonprofit capacity and demonstrate that nonprofits are key implementation partners for a local climate action.  You may contract to private sector companies however this will not score as well as a project delivered exclusively by nonprofits.

Q: Can the proposal include close cooperation with a municipality?

A: in order to be successful, close collaboration between the nonprofit and municipality is essential. Your expression of interest should indicate your potential in this regard. 

Q: Can I submit multiple expressions of interest?

A: Yes

Q: How many applicants will be selected to submit full proposals?

A: We expect approximately 20 expressions of interest to advance.

Q: What metrics will you use to evaluate the replicability of a project?

A: Projects that demonstrate they will deploy data, technology, and policy in innovative and impactful ways that would be applicable and of interest to most any community across U.S. Within the grant timeline 2023 through 2024.

Q: Are carbon sequestration projects allowed and competitive, like tree plantings, or do you prefer projects are strictly focused on reducing emissions at the source?

A: The proposed projects should reduce local greenhouse gas emissions. Either mitigation or sequestration could meet this requirement. Recall that you will need to suggest actions related to at least one of the following: sustainable mobility, buildings, solar energy development, air quality management, or urban tree canopy.

Q: What criteria will you use to select those invited to submit a full proposal? Are you prioritizing proposals with one central focus or would it be of interest to fund a city with an aggressive climate action plan and a portfolio of 3 – 5 priority projects that are all implementable?

A: Is the applicant an eligible applicant supporting an eligible community? Does the proposed project meet the criteria regarding climate action plan and demonstrate the potential for adoption of a science-based target by July 31; demonstration of potential impact (GHG reductions) replicability and ability to leverage grant funding; demonstration of collaboration between the nonprofit and selected community; clear benefit to well defined underserved communities; perception of successful outcomes.

Q: Do you have a preference for the scale of the project?  Large cities vs smaller cities?

A: No preference

Q) Our approach to implement the Action Fund may include a combined activity that both pilots an implementation on a small population (Building electrification direct installation) and then completes an inventory/lead generation that is city-wide (identifies future needs/costs/implementation approach). The goals would be to test and then direct local/private funding immediately while also becoming implementation-grant-ready. Would both of these steps qualify as eligible activities or only the first?

A) Our statement that the funds cannot be used for “assessment and planning,” refers to an assessment of community-wide GHG emissions and development of a science-based target and development of a climate action plan. If your pilot, then assessment approach is related to the implementation of a mitigation strategy contained in the city’s climate action plan, then both activities qualify for the Google.org action fund grant.

Demonstration of Community Need

A city that has not received a donation or grant funding or been the beneficiary of funding of $1,000,000 or more in the past 2 years (via American Cities Climate Challenge or other climate or energy-related program).

Qs

  • Are you looking at single grant sources over $1M or cumulative funding over $1M
  • Do you mean a city that has received over $1 million in ANY sources of grants over the past 2 years is ineligible?
  • Do grants that have funded infrastructure (bike and walk improvements) count in terms of the grant funding you are considering?
  • In Q&A please provide more distinction on which grant funding sources you are considering “Climate and energy” so we can determine if our cities have received those. For example there are significant CalTrans grants in the state of California that may fund bike and pedestrian infrastructure that exceed $1M but are not directly funding CAP implementation (though obviously enabling increased biking and walking at a future date).
  • If city/counties who have received $1M in similar funding are ineligible – does this mean just the government entity themselves, or the nonprofit as well?
  • Would public funding to supplement the ICLEI Google Action Fund grant that comes from state funding not yet distributed but soon to be distributed qualify for item 4 in the list of qualifying characteristics.

A: The purpose of the Google.org grant funds is to implement climate action in communities who are poised and ready for action and have not received significant support to do so. Successful applicants will propose activities in communities that have been underserved in this regard. 

Here are questions to ask the communities you seek to support:

  • Has the city or county received one or more donations; charitable gifts, or grants from a private donor(s) or philanthropic organization(s) totaling $1,000,000 since January 1, 2020? Grant funds from public sources do not count towards this threshold. 
  • If the answer is NO, Google.org grants can support this community.
  • If the answer is YES:
  • What is the total amount of funds received that are for the specific purpose of climate action plan implementation?  
  • If the answer is less than $1,000,000, Google.org grants can support this community.
  • If the answer is $1,000,000 or more, Google.org grants cannot support this community.

Q) Can you please verify that ABC County, the City of DEF, and the City of XYZ are able to partner on this project? None have received American Cities Climate Challenge funding but the guidance document stated $1 million or more for “other climate or energy related program.” Does this mean all in one lump sum from one source, or could it also be funding from different sources that adds up to $1 million for all three jurisdictions?

Here are questions to ask the communities you seek to support:

Which climate action plan would the grant funds support?  If actions identified in the county CAP, then the prior charitable giving limit of $1,000,000 applies only to the county.  If the grant funds are intended to support actions stated in the county + city (or cities) CAPS, then we’d look at all three jurisdictions

Has the city or county received one or more donations; charitable gifts, or grants from a private donor(s) or philanthropic organization(s) totaling $1,000,000 since January 1, 2020? Grant funds from public sources do not count towards this threshold.

If the answer is NO, Google.org grants can support this community.

If the answer is YES:

What is the total amount of funds received that are for the specific purpose of climate action plan implementation? 

If the answer is less than $1,000,000, Google.org grants can support this community.

If the answer is $1,000,000 or more, Google.org grants cannot support this community.

Q: We would like clarification on the requirement: “A city that has not received a donation or grant funding or been the beneficiary of funding of $1,000,000 or more in the past 2 years (via American Cities Climate Challenge or other climate or energy-related program)”. We have four questions on this:

Q1: Is there a list of the types of grants and funding sources that are considered “climate and energy grants”?

A: We do not have a comprehensive list.  Climate and Energy grants and funding sources are those whose purpose is to reduce local greenhouse gas emissions.

Q2: The City has received numerous CalTrans Active Transportation Grants to fund bike and walk infrastructure projects. These exceed $1M. They would enable the active transportation activities in the CAAP but don’t directly fund incentives or education to get those behaviors to occur. They are not an energy or climate grant directly. Would these grants disqualify our application?

A: One of the stated goals (page 7) of the Active Transportation Program (ATP) is to “Advance the active transportation efforts of regional agencies to achieve greenhouse gas reduction goals as established pursuant to Senate Bill 375 (Chapter 728, Statutes of 2008) and Senate Bill 391 (Chapter 585, Statutes of 2009).
The ATP meets the definition of a grant aimed at addressing climate change through the reduction of GHG emissions.  However, the ATP is funded with federal and state (public) funds and not private donations or grant funds.  Therefore, receipt of ATP funds does not disqualify the city.

Q3: For Energy and Climate grants per the above definition, do these include local implementation of energy efficiency work or vehicle charging done by regional agencies or third party implementers? (example: CALeVIP charging investments, PG&E Public Goods Charge funded energy efficiency grants provided to nonprofits/consultants to work statewide both having some investment in our City).

A: The purpose of the Google.org grant funds is to implement climate action in communities who are poised and ready for action and have not received significant support to do so. Successful applicants will propose activities in communities that have been underserved in this regard.

Here are questions to ask the communities you seek to support:

  • Has the city or county received one or more donations; charitable gifts, or grants from a private donor(s) or philanthropic organization(s) totaling $1,000,000 since January 1, 2020? Grant funds from public sources do not count towards this threshold.
  • If the answer is NO, Google.org grants can support this community.
  • If the answer is YES:
  • What is the total amount of funds received that are for the specific purpose of climate action plan implementation? 
  • If the answer is less than $1,000,000, Google.org grants can support this community.
  • If the answer is $1,000,000 or more, Google.org grants cannot support this community.

Q4: For energy and climate grants received directly by the City or 100% for implementation in the City, would such a grant individually need to exceed $1M to disqualify the City or would a cumulative total of smaller grants also disqualify?

A: What is the total amount of funds received that are for the specific purpose of climate action plan implementation?

  • If the answer is less than $1,000,000, Google.org grants can support this community.
  • If the answer is $1,000,000 or more, Google.org grants cannot support this community.

Information about Google.org Grant Funds

Is there anything else our nonprofit should know about the use of Google.org grant funds?

Yes, if selected for one of the awards your organization will need to attest to the following:

Your organization must not use any of the grant funds to promote or engage in violence, terrorism or the destruction of property or to provide support or make payments to any person or entity that promotes or engages in such activities.

Your organization will not use any portion of this grant to make sub-grants or sub-contracts to individuals on a non-objective basis, or for any non-charitable or non-educational purpose. The Grant Funds do not represent the payment of a pledge or other financial obligation. No goods or services should be provided in return for the Grant Funds.

Your organization will not use any portion of the Grant Funds to engage in any political or lobbying activity, including carrying on propaganda or attempting to influence specific legislation either by direct or grassroots lobbying. For the sake of clarity, this clause does not prohibit your organization from engaging in legally permissible political or lobbying activities, provided your organization does not use the Grant Funds for such activities.

Your organization agrees that the Grant Funds will be designated for service programs open to all persons regardless of religion, and will not be used for religious instruction.

Your organization certifies that it does not discriminate against any person or group of people in either hiring or employment practices or in the administration of programs and services, including on the basis of sexual orientation or gender identity.

Your organization agrees to comply with all applicable export laws and trade sanctions programs. Your organization agrees to comply with all applicable laws, including all anti-bribery or anti-corruption laws. Your organization and officers, directors, employees, or agents have not and will not pay, offer or promise to pay, or authorize the payment directly or indirectly, of any money, gift or anything of value to any government official or employee or any political party or candidate for political office for the purpose of influencing any act or decision of such official or of the government to obtain or retain business, or direct business to your organization. Your organization certifies that the use of Grant Funds will comply with all applicable government ethics laws, including gift limits. Your organization certifies that it will not use the Grant Funds to honor any government officials.

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