Wikimedia Foundation Investment Policy

Purpose

The purpose of the Wikimedia Foundation ("the Foundation") is to be the home of free-knowledge projects like Wikipedia. In order to serve this mission, the Foundation's investment portfolio is intended to provide both short-term and long-term financial support to the Foundation's current operations as well as its growth over time.

For the purposes of providing for sufficient liquidity, managing investment risk, and optimizing investment returns within acceptable risk parameters, the following funds shall be created and held as separate investment pools:

Operating Fund
Short-term Reserve Fund
Long-term Reserve Fund

Roles and Responsibilities

Audit Committee

The Board of a non-profit organization is ultimately responsible for its investments. The Wikimedia Foundation Board of Trustees ("the Board") has delegated to the Audit Committee ("the Committee") the fiduciary responsibility to oversee the Foundation's investment activities.

The Committee shall monitor investment performance semi-annually.
The Committee shall review the Investment Policy Statement ("the Policy") periodically to ensure it is consistent with the mission of the Foundation and accurately reflects current financial conditions.
The Committee shall approve any changes in the Policy and notify the Board of those changes.

Treasurer

The Committee authorizes the Foundation's Treasurer to implement the Policy, including executing investment transactions directly or via professional investment managers consistent with the "Delegations of Financial and Spending Authority" approved July 11, 2012 by the Board of Trustees which is incorporated into this Policy by reference.

It is anticipated that the services of investment managers and/or advisors may be sought to manage portions of the funds. The Treasurer is authorized to hire, fire, or replace investment managers and/or advisors with notification to the Chair of the Audit Committee. The Treasurer must approve allocation to securitized assets like mortgage-backed, commercial loan obligations, asset-backed securities, etc.

Performance Monitoring

The Treasurer shall monitor and evaluate investment performance quarterly. The Treasurer shall report investment performance and provide a copy of the investment statement(s) to the Committee on a semi-annual basis. The Treasurer shall report annually to the Committee on the overall Environmental, Social, & Governance ("ESG") profile of the portfolio using publicly available ESG ratings, as appropriate.

Spending Policy

The Foundation will use funds in the Operating Fund to meet the day-to-day financial obligations of the Foundation. The Foundation may withdraw funds from the Short-term Reserve Fund or the Long-term Reserve Fund, in line with approved spending in our annual plan and in line with maintaining the working capital ratio established by the Board of Trustees. The objectives of the spending policy are to grow the purchasing power of the funds and to achieve a predictable distribution of funds to aid budgeting.

Any material withdrawal of funds from the Short-Term Reserve Fund or the Long-term Reserve Fund outside of approved spending in the annual plan or the normal expectations of adequate working capital ratio must be communicated to the Board prior to withdrawal and material use of funds.

Operating Fund

Investment Objectives

The purpose of the Operating Fund is to provide sufficient cash to meet the day-to-day financial obligations of the Foundation in a timely manner. The Operating Fund shall prioritize preservation of capital and access to immediate liquidity in order to minimize risk to operational financial needs of the Foundation.

Investment Guidelines

Time Horizon	Less than 3 months.
Return Objective	Target short-term Treasury market rates.
Risk Tolerance	The volatility of the Operating Fund should be similar to its benchmark.
Liquidity Needs	The Operating Fund should maintain high liquidity (short to ultra-short/weekly to monthly range) in order to support the Foundation's day-to-day operations.
Spend	The Operating Fund shall aim to reserve four-to-six months of expenses on a rolling quarterly basis. Due to the timing of cash flows, the Foundation may – at times – either lag or exceed this level of liquidity in its Operating Fund.

Asset Class Mix

Cash & Cash Equivalents	This allocation may be held in US Treasuries, savings accounts, interest-bearing money market accounts, or certificates of deposit at FDIC-insured commercial banking institutions.
Money Market Indexed Funds	These securities must be comprised of US Treasury-equivalent holdings. Underlying repurchase agreement ("repo" or "repos") exposure collateralized by US Treasuries is also permissible, where applicable.
Public Fixed Income	This Fixed Income allocation shall be comprised of direct obligations of the US Government, its agencies, and instrumentalities. Repos collateralized by US Treasuries are also permissible.
Benchmark - to be based on asset mix and investment objectives	Bloomberg US T-bill 1-3 Month fixed income index.

Short-term Reserve Fund

Investment Objectives

The purpose of the Short-term Reserve Fund is to improve the return on the funds held for expenditure beyond twelve months. The Short-term Reserve Fund shall prioritize preservation of capital and also aim to generate current income in line with its benchmark.

Investment Guidelines

Time Horizon	2.5 to 3.5 years.
Return Objective	Target 2.5- to 3.5-year Treasury market rates and target total return (net of fees) in line with its benchmark.
Risk Tolerance	The volatility of the Short-term Reserve Fund should be similar to its benchmark. This Fund is anticipated to be the least volatile segment of the consolidated Foundation portfolio.
Liquidity Needs	The Short-term Reserve Fund should maintain intermediate-term liquidity, in line with the time horizon mandate.
Spend	The current portion of the Short-term Reserve Fund may contribute to the Foundation's ongoing Operating Fund needs.

Asset Class Mix

Cash & Cash Equivalents	This allocation may be held in US Treasuries, savings accounts, interest-bearing money market accounts, or certificates of deposit at FDIC-insured commercial banking institutions.
Money Market Indexed Funds	These securities must be comprised of US Treasury-equivalent holdings. Underlying repurchase agreement ("repo") exposure collateralized by US Treasuries is also permissible, where applicable.
Public Fixed Income	The Fixed Income portfolio will consist mainly of investments in investment-grade marketable bonds (USD-denominated). Permissible securities may be issued by US Treasury, domestic US organizations, non-US corporations, non-US governments ("sovereign" bonds), and multinational organizations ("supranationals" like World Bank), municipalities ("munis"), commercial paper, and repos collateralized by US Treasuries.
Benchmark - to be based on asset mix and investment objectives	Bloomberg 1-3-year Government Credit fixed income index.

Other Guidelines

Prior approval by the Foundation's Treasurer is required before allocation to securitized assets like mortgage-backed, commercial loan obligations, asset-backed securities, etc.
With the exception of U.S. Government and agency securities, fixed income issues of a single issuer and its affiliates (ownership stake of 20% or more) shall at time of purchase constitute no more than 5% of the market value of the Short-term Reserve Fund portfolio.
Maturity (using preferred metric of expected maturity) of any individual holding shall not exceed six years. Weighted average duration of the portfolio shall be aligned with the Time Horizon of the Short-term Reserve Fund.

Long-term Reserve Fund

Investment Objectives

The purpose of the Long-term Reserve Fund is to aid growth of invested assets and maintain the portfolio's inflation-adjusted purchasing power over a long-term. The Long-term Reserve Fund shall prioritize long-term growth while avoiding excessive risk. This Fund shall also aim to achieve returns in excess of the rate of inflation plus spending over a long-term (greater than 7-10 years).

Investment Guidelines

Time Horizon	Up to 4.5 years for fixed income while greater than 7 years for equities.
Return Objective	Target total return (net of fees) in line with its blended benchmark.
Risk Tolerance	The volatility of the Long-term Reserve Fund should be similar to its benchmark. This Fund is anticipated to be the most volatile segment of the consolidated Foundation portfolio.
Liquidity Needs	The Long-term Reserve Fund shall be comprised of highly liquid assets while also aiming to minimize asset turnover (i.e. holding assets over a long term to promote investment growth and return).
Spend	The current portion of the Long-term Reserve Fund may contribute to the Foundation's ongoing Operating Fund needs.

Asset Class Mix

Cash & Cash Equivalents	This allocation may be held in US Treasuries, savings accounts, interest-bearing money market accounts, or certificates of deposit at FDIC-insured commercial banking institutions.
Money Market Indexed Funds	These securities must be comprised of US Treasury-equivalent holdings. Underlying repurchase agreement ("repo") exposure collateralized by US Treasuries is also permissible, where applicable.
Public Fixed Income	The Fixed Income portfolio will consist mainly of investments in investment-grade marketable bonds (USD-denominated). Permissible securities may be issued by US Treasury, domestic US organizations, non-US corporations, non-US governments ("sovereign" bonds), and multinational organizations ("supranationals" like World Bank), municipalities ("munis"), commercial paper, and repos collateralized by US Treasuries.
Public Equities	The Equities portfolio will consist mainly of investments in public equities. Designed to be the principal contributor toward achieving the growth target, the Equities portfolio is likely to be the most volatile asset class and may include areas like Emerging Markets.
Alternatives	The Alternatives portfolio will consist mainly of hybrid real estate investments, via publicly traded REITs. This allocation may be a source of heightened volatility, but such volatility may not exceed that of the Equities portfolio.
Blended Benchmark - to be based on asset mix and investment objectives	35% Bloomberg 1-5-year Government Credit fixed income index. 65% S&P 1500 equity index.

Other Guidelines

Prior approval by the Foundation's Treasurer is required before allocation to securitized assets like mortgage-backed, commercial loan obligations, asset-backed securities, etc.
With the exception of U.S. Government and agency securities, fixed income issues of a single issuer and its affiliates (ownership stake of 20% or more)) shall at time of purchase constitute no more than 5% of the market value of the Long-term Reserve Fund portfolio.
Maturity (using preferred metric of expected maturity) of any individual holding shall not exceed eleven years. Weighted average duration of the portfolio shall be aligned with the Time Horizon of the Long-term Reserve Fund.

ESG Investments

The Foundation shall first prioritize its risk/return requirements and operational obligations. ESG factors, in addition to many other factors, may have an impact on investment performance over the long term. The Foundation may consider ESG ratings when analyzing and selecting investments, and the Treasurer shall report annually to the Audit Committee on the overall ESG profile of the portfolio using publicly available ESG ratings, as appropriate.

Approve: February 27, 2024