Foundation Policies and Procedures Manual


MISSION STATEMENT

The Grand Island Public Schools Foundation will enhance student educational opportunities through its support of the Grand Island Public Schools by seeking, securing, and managing resources for scholarships, projects, and programs.

Administrative Fees Policy

Conflict of Interest Policy

Contracts for Services Policy

Credit Card Policies and Procedures

Document Retention and Destruction Policy

Donor Bill of Rights

Donor Privacy Policy

Gift Acceptance Policy

Investment Policy

Small Lottery and Raffle Policy

Scholarship and Grants to Individuals Policy

Whistleblower Policy

 

Grand Island Public Schools Foundation Administrative Fees Policy


Endowed Accounts

1. Endowed accounts that are restricted in nature (ie scholarships/other) will be subject to an annual administrative fee determined in November each year by the Foundation Board of Directors (currently 1.5% of total value).

One of the following criteria must be met to assess said fee:
a. Restricted Account value is greater than $10,000 or
b. The account has been in existence for 5 years or more

2. Incubation Period - Funds that have not met the $10,000 benchmark will
be considered "incubating" and will not be assessed an annual administrative fee until the fund reaches the $10,000 benchmark or it has been in existence for 5 years. After which time the "incubating" fund will be assessed an administrative fee as determined by the Foundation Board of Directors.

Note: Although exceptions may arise, funds that are considered "incubating" will not pay out scholarships or other program needs until they reach $10,000 in value.

3. Graduated Fees - Funds that have reached a value of $500,000 will be charged a 1% administrative fee.

Annual Restricted Pass-through Scholarships
1. All pass-through scholarships will be charged a $50 fee regardless of value. This amount may be paid in addition to the scholarship or subtracted from the amount of the scholarship.

2. Pass-through scholarships that are from school related organizations, including booster clubs, PTA's, Coaches Association, and others will be charged a $25 fee to process each scholarship.

3. The Foundation Board encourages donors to consider a $500 minimum
value when determining scholarship awards.

4. Scholarships may be combined by donors/organizations that are like-minded in order to meet the $500 level.

5. Donors wishing to give annual scholarship dollars that are not subject to a pass-through fee may give directly to the Foundation's Academic Aristocrat General Fund. This fund provides annual scholarships to students who graduate in the top 15% of their class at Grand Island Senior High.

Umbrella Accounts
1. Accounts that are maintained by the Foundation for separate organizations such as booster clubs, the Grand Island Literacy Coalition, and the Grand Island Multi-cultural Coalition will be subject to an annual administrative fee based upon the organization's income.

2. Said fee will be charged against all income, fundraising, and other, except student paid fees for trips etc.

3. The annual fee will be assessed by the Foundation Board of Directors each year after the Foundation's audited financials are accepted (usually in December or after). Fees will be assessed in arrears from the previous fiscal year's audit. The Foundation Board of Directors has determined the current rate of the fee to be 2.5% of annual income or $2,000 – whichever is less. The minimum administrative fee charged to member organizations will be $250. This rate is subject to change by a two-thirds majority vote of the Board.

4. If an organization does not generate income in a given year, but has assets of $10,000 or more, said organization will be assessed a minimum annual administrative fee of $250.

5. The annual fee will be payable to the Foundation within 30 days of billing each year.

6. The Foundation will provide the following services to umbrella organizations:

1. Annual Audit
2. Directors' and Officers' Insurance
3. Fidelity Bond
4. Non-profit tax exempt status
5. Administrative Time
6. Institutional Trust and/or Banking Services
7. Check writing and Financial Tracking (note: The Foundation expects umbrella organizations to also maintain financial records and will not account for student fees individually. The Foundation records will be an aggregate capture of data.)

7. The Foundation Finance Committee will meet with the booster club chairs and treasurers, and the chairs/treasurers of other umbrella groups semi-annually to share information.

8. All umbrella organization accounts shall be operated through the
Foundation's designated depository or the Foundation's internal operating account based on the size and goals of the affiliated organization.

9. Procedures – Leadership of each organization operating under the
Foundation's umbrella will sign the Foundation's "Umbrella Organization Practices and Procedures" document annually in order to function as part of the Foundation.

 

Grand Island Public Schools Foundation
Conflict of Interest Policy


Article I

Purpose

The purpose of the conflict of interest policy is to protect the interest of the Grand Island Public Schools Foundation (Organization) when it is contemplating entering into a transaction or arrangement that might benefit the private interest of an officer or director of the Foundation or might result in a possible excess benefit transaction. This policy is intended to supplement but not replace any applicable state and federal laws governing conflict of interest applicable to nonprofit and charitable organizations.

Article II
Definitions

1. Interested Person
Any director, principal officer, or member of a committee with governing board delegated powers, who has a direct or indirect financial interest, as defined below, is an interested person.

2. Financial Interest
A person has a financial interest if the person has, directly or indirectly, through business, investment, or family:
a. An ownership or investment interest in any entity with which the Organization has a transaction or arrangement,
b. A compensation arrangement with the Organization or with any entity or individual with which the Organization has a transaction or arrangement, or
c. A potential ownership or investment interest in, or compensation arrangement with, any entity or individual with which the Organization is negotiating a transaction or arrangement.

Compensation includes direct and indirect remuneration as well as gifts of favors that are not insubstantial.

A financial interest is not necessarily a conflict of interest. Under Article III, Section 2, a person who has a financial interest may have a conflict of interest only if the appropriate governing board or committee decides that a conflict of interest exists.

Article III
Procedures

1. Duty to Disclose
In connection with any actual or possible conflict of interest, an interested person must disclose the existence of the financial interest and be given the opportunity to disclose all material facts to the directors and members of committees with the governing board delegated powers considering the proposed transaction or arrangement.

2. Determining Whether a Conflict of Interest Exists
After disclosure of the financial interest and all material facts, and after any discussion with the interested person, he/she shall leave the governing board or committee meeting while the determination of a conflict of interest is discussed and voted upon. The remaining board or committee members shall decide if a conflict of interest exists.

3. Procedures for Addressing the Conflict of Interest
a. An interested person may make a presentation at the governing board or committee meeting, but after the presentation, he/she shall leave the meeting during the discussion of, and the vote on, the transaction or arrangement involving the possible conflict of interest.
b. The chairperson of the governing board or committee shall, if appropriate, appoint a disinterested person or committee to investigate alternatives to the proposed transaction or arrangement.
c. After exercising due diligence, the governing board or committee shall determine whether the Organization can obtain with reasonable efforts a more advantageous transaction or arrangement from a person or entity that would not give rise to a conflict of interest.
d. If a more advantageous transaction or arrangement is not reasonably possible under circumstances not producing a conflict of interest, the governing board or committee shall determine by a majority vote of the disinterested directors whether the transaction or arrangement is in the Organization's best interest, for its own benefit, and whether it is fair and reasonable. In conformity with the above determination it shall make its decision as to whether to enter into the transaction or arrangement.

4. Violations of the Conflict of Interest Policy
a. If the governing board or committee has reasonable cause to believe a member has failed to disclose actual or possible conflicts of interest, it shall inform the member of the basis for such belief and afford the member and opportunity to explain the alleged failure to disclose.
b. If, after hearing the member's response and after making further investigation as warranted by the circumstances, the governing board or committee determines the member has failed to disclose an actual or possible conflict of interest, it shall take appropriate disciplinary and corrective action.

Article IV
Record of Proceedings

The minutes of the governing board and all committees with board delegated powers shall contain:
a. The names of the persons who disclosed or otherwise were found to have a financial interest in connection with an actual or possible conflict of interest, the nature of the financial interest, any action taken to determine whether a conflict of interest was present, and the governing board's or committee's decision as to whether a conflict of interest in fact existed.
b. The names of the persons who were present for discussions and votes relating to the transaction or arrangement, the content of the discussion, including any alternatives to the proposed transaction or arrangement, and a record of any votes taken in connection with the proceedings.

Article V
Compensation

a. A voting member of the governing board who receives compensation, directly or indirectly, from the Organization for services is precluded from voting on matters pertaining to that member's compensation.
b. A voting member of any committee whose jurisdiction includes compensation matters and who receives compensation, directly or indirectly, from the Organization, for services is precluded from voting on matters pertaining to that member's compensation.
c. No voting member of the governing board or any committee whose jurisdiction includes compensation matters and who receives compensation, directly or indirectly, from the Organization, either individually or collectively, is prohibited from providing information to any committee regarding compensation.

Article VI
Annual Statements

Each director, principal officer and member of a committee with governing board delegated powers shall annually sign a statement which affirms such person:
a. Has received a copy of the conflicts of interest policy,
b. Has read and understands the policy,
c. Has agreed to comply with the policy, and
d. Understands the Organization is charitable and in order to maintain its federal tax exemption it must engage primarily in activities which accomplish one or more of its tax-exempt purposes.
e. Discloses current employment, business interests and/or organizational affiliations, and amends as required.

Article VII
Periodic Reviews

To ensure the Organization operates in a manner consistent with charitable purposes and does not engage in activities that could jeopardize its tax-exempt status, periodic reviews shall be conducted. The periodic reviews shall, at a minimum, include the following subjects:
a. Whether compensation arrangements and benefits are reasonable, based on competent survey information, and the result of arm's length bargaining.
b. Whether partnerships, joint ventures, and arrangements with management organizations conform to the Organization's written policies, are properly recorded, reflect reasonable investment or payments for goods and services, further charitable purposes and do not result in inurnment, impermissible private benefit or in an excess benefit transaction.

Article VIII
Use of Outside Experts

When conducting the periodic reviews as provided for in Article VII, the Organization may, but need not, use outside advisors. If outside experts are used, their use shall not relieve the governing board of its responsibility for ensuring periodic reviews are conducted.

 

Grand Island Public Schools Foundation
Contracts for Services Policy


Objective:

1. To allow the Grand Island Public Schools Foundation and all of its member Umbrella Organizations to enter into contracts for services that are deemed necessary to enhance the educational experience for GIPS students.

Policies and Procedures:
1. All persons or businesses offering services for which payment shall be made, will be required to complete a W-9 tax form prior to receiving payment.
2. In January of each year, Foundation Staff will send 1099 tax returns to all persons or businesses who have provided services according to criteria as defined by the IRS.
3. Contracts with GIPS Staff Members – From time to time, it may be necessary for the Foundation or its Umbrella Organizations to enter into an agreement with a GIPS Employee for a specific service based on the talents and abilities of that employee. Examples include: hiring employees to play instruments in a pit orchestra for the Fall Musical; hiring an employee to organize a tournament or event; hiring an employee to coach a camp, etc.

When the Foundation or Umbrella Organization hires a GIPS employee, the contract payment shall be executed through the GIPS payroll process. As such the following will occur:

a.) Payment for the contract will be made to GIPS and the Payroll Department will be notified of the amount to attribute to the GIPS Employee's next scheduled check.
b). Payroll taxes will be automatically withdrawn
c.) The contracted payment will be subject to the Nebraska Public Employees Retirement System policies, procedures, and payments
d.) The Foundation Office will NOT need a W-9 and will NOT issue a 1099

Exception – If the GIPS Employee owns, or holds an ownership stake in a business from which the services are being contracted, the payment for service shall be made to the business using the procedures outlined in 1 and 2 above. When this is the case, the business shall have a separate identification number from the GIPS Employee's personal social security number and the service shall be an "arms length" transaction and therefore the GIPS Employee shall not have any part in authorizing the payment for the service.

4. The Foundation Board reserves the right to require any other documentation of services rendered that they deem necessary.
5. All transactions are subject to examination by internal and external auditors.

 

Grand Island Public Schools Foundation
Credit Card Policies and Procedures


Objectives:

1. To allow Grand Island Public Schools Foundation personnel and Umbrella Organization members access to efficient and alternative means of payment for approved expenses related to business travel and supplies.
2. To improve managerial reporting related to credit card purchases.
3. To improve efficiency and reduce costs of payables processing.

Policies:
1. Corporate credit cards will be issued to individuals only with approval of the Finance Committee.
2. Credit cards will be issued to Foundation Staff and representatives from Umbrella Organizations.
3. Credit cards will be used for business purposes only. Personal purchases of any type are not allowed.
4. The following purchases are not allowed:
• Capital equipment and upgrades over $5,000
• Construction, renovation/installation
• Controlled substances
• Items or services on term contracts
• Personal items or loans
• Telephones, related equipment, or services
• Any other items deemed inconsistent with the values of the Foundation
5. Cash advances on credit cards are not allowed.
6. Cardholders will be required to sign an agreement indicating they accept these terms. Individuals who do not adhere to these policies and procedures risk revocation of their credit card privileges and/or disciplinary action.
7. The card may be revoked at any time based on change of assignment. The card is not an entitlement, nor reflective of title or position.
8. All transactions are subject to examination by internal and external auditors.

Procedures
1. Credit cards may be requested for prospective cardholders by written request to the Foundation Finance Committee.
2. Detailed receipts must be submitted to the Foundation office by the 20th of each month to enable timely payments of amounts due.
3. In the case of meals and entertainment, each receipt must include the names of all persons or groups involved in the purchase, and a brief description of the business purpose of the purchase, in accordance with Internal Revenue Service regulations.
4. All receipts submitted must include the initials of the cardholder.

 

The Grand Island Public Schools Foundation

Document Retention/ Destruction Policy


The Grand Island Public Schools Foundation takes seriously its obligation to preserve information relating to litigation, audits and investigations. The Sarbanes-Oxley Act of July 30, 2002, makes it a crime to alter, cover up, falsify, or destroy any document to prevent its use in an official proceeding. Failure on the part of employees to follow this policy can result in possible civil and criminal sanctions against GIPS Foundation and its employees and possible disciplinary action against responsible individuals (up to and including termination of employment).

Each employee has an obligation to contact the Executive Director or Board President of a potential or actual litigation, external audit, investigation or similar proceeding involving the GIPS Foundation. The information listed in the retention schedule listed below is intended as a guideline and may not contain all the records the GIPS Foundation may be required to keep in the future. Questions regarding the retention of documents not listed in this chart should be directed to the Executive Director. Any documents with a signature require a hard copy.

Category of File - Item - Retention - Period

Corporate Records
Articles of Incorporation - Permanent
Bylaws - Permanent
Board and committee meeting minutes - Permanent
Board of Trustees Conflict of Interest disclosure forms - 7 years

Finance & Administration
Accounts payable ledger - 7 years
Accounts receivable ledger - 7 years
Auditor management letters - Permanent
Bank deposits & statements - 7 years
Umbrella Account Applications - 7 years after completion
Chart of accounts - 7 years
Check register & checks - 7 years
Contracts & agreements - 7 years after expiration
Correspondence – general - 7 years
Equipment files & maintenance records - 7 years
Expense reports - 7 years
Financial statements (audited) - Permanent
Payroll Entries - 7 Years
General ledgers & journals (includes bank reconciliations, fund accounting by quarter, payouts allocation, single fund allocation, trust statements) - 7 years

Grants made by GIPS Foundation
Approved grants (includes scholarships) – all documentation supporting grant payment, including application/recommendation, due diligence, grant agreement letters, grant transmittal letters, and post grant reporting information, if any. - 7 years after completion of funded program, or date of grant if general operating support

Grants to GIPS Foundation
Grant Request, award letters & other correspondence - Permanent
Financial Reports - Permanent

Insurance
Policies – occurrence type - Permanent
Policies – claims-made type - Permanent
Insurance related reports - 7 years

Investment
Investment performance reports - 7 years
Investment manager correspondence - 7 years
Investment manager contracts - 7 years after all obligations end
Investment consultant reports - 7 years

Real Estate
Deeds - Permanent
Leases (expired) - 7 years after all obligations end
Mortgages, security agreements - 7 years after all obligations end
Purchase agreements - 7 years after disposition requirement

Tax
Correspondence with legal counsel or accountants, not otherwise listed - 7 years after return is filed
IRS exemption determination & related correspondence - Permanent
Tax audit closing letters - Permanent
Tax returns (990. W-2's) - Permanent
Withholding tax statements - 7 years

Fund Agreements
Signed fund Agreement forms (originals) - Permanent
Signed advised fund recommendation forms - Permanent
Pledge agreements including payroll deduction forms - 4 years after completion

Consulting Services
Consulting contracts - 7 years after all obligations end

Human Resources
Benefits: retirement plans (plan descriptions, plan documents) - Permanent
Benefits: welfare plans (plan descriptions, plan documents) - 7 years
Consultant contracts/files (expired) - 7 years after all obligations end
Employment offer letter - 7 years after all obligations end
Disability & sick-benefit records - Permanent
Employment applications - 3 years
Employee handbooks - Permanent
Employee personnel files - Permanent
Payroll Registers / W-2/ 1099 - Permanent
Workers comp claims (after settlement) - 7 years

Technology
Software licenses & support agreements - Same as legal requirement

 

The Donor Bill of Rights


The Grand Island Public Schools Foundation has adopted the Donor Bill of Rights as written by the Association of Fundraising Professionals (AFP). The Donor Bill of Rights is reprinted and adopted with permission from AFP.

Philanthropy is based on voluntary action for the common good. It is a tradition of giving and sharing that is primary to the quality of life. To ensure that philanthropy merits the respect and trust of the general public, and that donors and prospective donors can have full confidence in the nonprofit organizations and causes they are asked to support, we declare that all donors have these rights:

I. To be informed of the organization's mission, of the way the organization intends to use donated resources, and of its capacity to use donations effectively for their intended purposes.

II. To be informed of the identity of those serving on the organization's governing board, and to expect the board to exercise prudent judgment in its stewardship responsibilities.

III. To have access to the organization's most recent financial statements.

IV. To be assured their gifts will be used for the purposes for which they were given.

V. To receive appropriate acknowledgement and recognition.

VI. To be assured that information about their donation is handled with respect and with confidentiality to the extent provided by law.

VII. To expect that all relationships with individuals representing organizations of interest to the donor will be professional in nature.

VIII. To be informed whether those seeking donations are volunteers, employees of the organization or hired solicitors.

IX. To have the opportunity for their names to be deleted from mailing lists that an organization may intend to share.

X. To feel free to ask questions when making a donation and to receive prompt, truthful and forthright answers.

 

Donor Privacy Policy


The Grand Island Public Schools Foundation is committed to respecting the privacy of our constituency including donors, students, staff, and alumni. The types of information that the Foundation collects and maintains are as follows:

Contact information: name, address, telephone number, class year (if applicable), e-mail address, and date of death if deceased.

Giving information

Information on events attended, publications received and special requests for program information

Information provided by the constituent in the form of comments or suggestions

The Grand Island Public Schools Foundation uses the above information from our constituency to understand their interest in our mission and to update them on the Foundation's and/or School District's plans or activities. This information is shared with staff, board members, volunteers and consultants only on a "need to know" basis. Additionally, donors may be listed in publications such as the Foundation's annual report. All requests for anonymity will be honored.

The Grand Island Public Schools Foundation assures our constituency that their names and addresses will not be sold, rented, or leased to any third party with the following exception: Alumni contact information may be shared with publishers or contractors whose primary business is the development of alumni directories.

 

Grand Island Public Schools Foundation Gift Acceptance Policy


Statement of Policy

Private giving helps ensure Grand Island Public Schools Foundation’s excellence in services offered to support the on-going needs of students of the Grand Island Public Schools.  Private gifts allow the Foundation to fund scholarships, programs, equipment, building and campus renovations, and new facilities.  The Grand Island Public Schools Foundation office plans, coordinates, and implements fund-raising programs with parents, community members, friends, corporations, and foundations.

 

Mission
The Grand Island Public Schools Foundation (the Foundation) will enhance student educational opportunities through its support of the Grand Island Public Schools by seeking, securing, and managing resources for scholarships, projects and programs. 

The Foundation exists to secure private gifts for the benefit of Grand Island Public School students, programs and facilities.  The Foundation is an organized corporation, exempt from federal tax liability by Internal Revenue Code Section 501(c)(3), and qualifies as a Public Charity under Internal Revenue Code Section 509.

All gift acceptance policies and procedures at the Foundation shall be interpreted in light of two overriding principles:

Principle 1: A gift shall not be accepted by the Foundation if such acceptance would not be in the interest of the donor.

A determination of the donor’s “interest” shall include, but not be limited to, the donor’s financial situation and philanthropic interests, as well as any tax or other legal matters revealed while planning for a gift. The Foundation shall not encourage any gifts that are inappropriate in light of the donor’s personal or financial situation.

Principle 2:  The Foundation will accept only gifts that support the Foundation’s mission. The Foundation reserves the right to accept or deny any gift.

In certain unique cases, a gift may be considered inappropriate due to particular restrictions imposed by the donor, or the nature of the gift. By its very definition, a gift cannot be associated with a private benefit that would jeopardize the charitable contribution deduction under IRC section 170 if the donor and beneficiary of the restriction have less than an arms-length relationship.

There must be a distance between the donor and recipient such that the recipient does not receive benefits that are otherwise not available to colleagues of similar status and interest. For example, in the capacity of donor, an individual cannot subsidize his/her own salary, travel funds, or fringe benefits.

 

Reason for Policy
While this document is intended to provide guidance to the Foundation Office and other Foundation personnel regarding acceptance of prospective gifts, donors are ultimately responsible for ensuring that the proposed gift furthers their charitable, financial, and estate planning goals. The Foundation Office does not provide legal, accounting, tax, or other advice to prospective donors. Therefore, each prospective donor is urged to seek the advice of independent legal counsel in the gift planning process.

Who Should Know This Policy

  •  Foundation Board of Directors
  • Foundation Staff                            

 

General Definitions
Word Definition

Gift
A gift is consideration given for which the donor receives no direct benefit and requires nothing in exchange beyond an assurance that the intent of the contribution will be honored. A gift may also include a “quid pro quo contribution” within the meaning of section 6115 of the Internal Revenue Code where goods or services may be provided to the donor in recognition of the consideration given by the donor. Where there is a quid pro quo contribution, the disclosure and substantiation requirements of the Internal Revenue Code will be complied with. Gifts made to the Foundation and gifts made directly to Grand Island Public Schools are both processed and reported by the Foundation Office.

Conditional Gift
Gifts which, because of some qualifier or restriction, are considered non-routine. Conditional gifts may commit the Foundation to act within a specified time or use a gift for a specific purpose. A conditional gift may also include a bargain sale of property to the Foundation where the acquisition price paid for the property will be less than the property’s fair market value and there is a donative intent in establishing the acquisition price of the property below its fair market value.

Outright Gift
These gifts are typically gifts of cash, stocks, bonds, real property, tangible personal property, or gifts-in-kind.

Pledge
Pledges are commitments to give a specific dollar amount according to a fixed time schedule.

Planned Gift
Planned gifts generally are gifts or commitments made in the present with the benefit to the Foundation "deferred" until a future date. Planned gifts may include outright gifts of appreciated property (securities and real estate) or gifts of tangible personal property.

Endowment
A gift of at least $12,500 (assuming x 4% = $500 annual distribution) to be invested for the purpose of producing present and future income that may be expended or reinvested with the original gift. The principal of the endowment is kept intact. Income is expended according to the donor’s stipulation and may be unrestricted or restricted.

Qualified Appraisal
Such appraisals are customarily obtained by the donor to support the allowance of specific income tax charitable deductions. Qualified appraisals are required when the claimed deduction for the donated property, other than money or publicly traded securities, is more than $5,000, or $10,000 for non-publicly traded securities. Property may be valued internally by using the fair market value as determined by qualified appraisals supplied by the donor.

 

Types of Gifts
Gifts to the Foundation may be in the form of outright gifts, pledges, or deferred commitments.

Outright Gifts
Cash and cash equivalents. Cash is often the easiest way to give and most frequently received form of gift accepted by the Foundation. These gifts can take the form of currency, check, or credit card contribution. Cash may be delivered in person, by mail, by Electronic Funds Transfer (EFT), or by wire transfer. Cash gifts are reported the date the cash is received in the Foundation office. If gifts are transferred by EFT or wire, the date of the gift is the date that the money is transferred into the Foundation’s bank account. Credit card gifts are reported on the date that the credit card charges are processed.

 The Foundation will accept cash as a payment or donation for transacting business provided it meets the following criteria:

  1. Is official currency of the United States of America
  2. Is less than $1,500 in currency per donor, per 12-month period (checks or other forms of payment are not considered against this annual currency threshold).


Publicly Traded Securities

Securities (1) listed on an exchange in which quotations are published daily; (2) regularly traded in national or regional over-the-counter markets for which published quotations are available; or (3) that are shares of a mutual fund for which quotations are published on a daily basis in a newspaper of general circulation throughout the United States, will be accepted as outright gifts or toward pledges. The value of securities is determined on the recognized gift date, which is established when the donor relinquishes control of the securities. The average of the high and low trading prices on the gift date determine the value of securities for reporting purposes.

Donations made shall be liquidated at fair market value upon being entrusted into the professional money manager’s care and reinvested immediately into the Foundation’s portfolio.

Closely Held Securities (non-public)
The Foundation shall examine any issue that is not publicly traded prior to its acceptance as a gift and may decline a gift of such securities if it deems them difficult to value or not easily marketable. The Finance Committee must approve gifts of non-publicly held securities prior to acceptance.

Real Property
Real property includes improved or unimproved land, personal residences, farmland, commercial property, rental property, and mineral interests. If it is the intention of the donor that the Foundation not immediately dispose of real property, an agreement must be made in writing between the Foundation and the donor before the Foundation may accept such property. All gifted real estate must be tested to be in conformity with state and federal laws, including EPA regulations, and the donor must provide satisfactory evidence of environmental compliance.

Personal Property
The Foundation may consider gifts of personal property, including but not limited to works of art, patents, copyrights, antiques, stamp and coin collections, jewelry, furniture, rare books, manuscripts, or any other item that has a determinable value. The Finance Committee may approve such donations only after a review indicates that the property is either readily marketable or needed by the Foundation or Grand Island Public Schools. It is the policy of the Foundation to sell or otherwise dispose of all gifts of personal property, unless the items can be used by the Foundation in a manner related to, education, discovery, or engagement. The Foundation’s intention to either resell the property or to retain and use it to further its charitable activities shall be communicated to the donor in writing at the time of the gift.

Gifts-in-kind
Gifts-in-kind for which donors are eligible for a charitable gift deduction in accordance with current IRS regulations should be reported at the fair market value placed on them by an independent, expert appraiser. Only those gifts in-kind that can be converted to cash, or items such as equipment, books, artworks, etc. that can be used in support of delivery of education or support programs, should be reported. Receiving departments must agree to use the in-kind materials before accepting the gift. Depending on the appraised value of the donated item, IRS Form 8283 may be submitted to the Foundation. If the donor does not supply a value, someone in the receiving department who has knowledge of the general type of item should provide a statement of condition. Internal values of donated items are not to be shared with donors.

Pledges
Pledges are commitments to give a specific dollar amount according to a fixed time schedule. All pledges are required to be in writing.

The following minimum information must exist to substantiate a pledge:

  • the amount of the pledge must be clearly specified;
  • there should be a clearly defined payment schedule;
  • the donor may not prescribe contingencies or conditions;
  • the donor must be considered to be financially capable of making the gift;
  • changes to original pledges must be documented in writing.

Pledge recording:

  • Anticipated matching gifts will not be included in pledge amounts.
  • Pledges and expected matching gifts will qualify for donor recognition in appropriate giving level groups.
  • Under- and over-paid pledges (as a result of either rounding, gift valuation, or incremental giving) will be noted as paid in full when donors’ intents are clearly to pay commitments in full.
  • Before defaulted pledges are written off, pledge deactivation requests must be reviewed and approved by the Executive Director and Board President.


Other Gifts

Gifts which do not fall into one of the foregoing categories will be evaluated on a case by case basis in accordance with this Policy. 

 

Planned Gifts

Charitable Bequests
Donors can make charitable bequests to the Foundation in wills or living trusts.

Charitable Remainder Trust
A charitable remainder trust is established when a donor irrevocably transfers money or securities to a trustee who invests the assets to pay annual lifetime income to the donor or others chosen by the donor. At the end of the beneficiaries’ lives, the remaining trust assets are distributed to the Foundation.  

Annuity trusts provide the tax advantages of current contributions with the security of fixed, lifetime incomes, generally for the donors and their spouses. The agreed-upon annual payments remain unchanged regardless of how the investments perform. The unitrust differs from the annuity trust by providing a variable income. Payment is based on a fixed percentage of the net fair market value of the trust assets as valued annually.

Charitable Lead Trust
This type of gift provides an income stream for a specified period of time to the Foundation.  The Foundation receives the income from the trust and applies it to the specific project. The principal is then returned at the end of the set period to whomever the donor designates.

Gifts of Life Insurance
Gifts of life insurance may name the Foundation beneficiary of the policy or as beneficiary and owner.  Said policies should be reviewed on the policy anniversary date to ensure adequate funding to sustain the policy.

Retained Life Estate
Donors can receive a sizable charitable income tax deduction by making a gift to the Foundation of their personal residence or farm, while retaining full use and rights to the property during their lifetime.

Revocable Trust
Through a written agreement, the donor transfers assets to a trustee. Income is paid to the donor for the term of the trust.

 

Endowments
To assure the acceptability of endowment gifts, the Executive Director will notify the Finance Committee which has the authority to recommend approval for standard agreements.

Unique, nonstandard endowment agreements may require additional review and approvals.  It is the responsibility of the Executive Director to obtain recommendations from the Finance Committee before final approval.

 

Procedures

Finance Committee
The Finance Committee shall consist of the following:

  • GIPS Foundation Executive Director.
  • GIPS Foundation Board President.
  • GIPS Foundation Vice President
  • GIPS Foundation Secretary
  • GIPS Foundation Treasurer
  • and other GIPS Foundation Board Members appointed by the Board President

The Finance Committee shall review all gifts of significant risk. All such gifts shall be documented by a written understanding between the donor and the Foundation, and must be approved by the Finance  Committee before the GIPS Foundation may accept the gifts. Once a gift has been accepted, the Grand Island Public Schools Foundation Office is responsible for recording and acknowledging it.

Gifts of Significant Risk

  • Non-publicly traded securities
  • All gifts of real property
  • Gifts of personal property if not to be used by GIPS or the Foundation
  • All gifts of real or tangible personal property subject to donor restrictions regarding the disposal of such property
  • Any bargain sale of property where a donative element is associated with the acquisition of property by the Foundation below its fair market value
  • Cash gifts with significant donor restrictions
  • All gifts of unusual items or gifts of questionable value

The committee shall meet as necessary to approve specific gifts.

Decisions of the committee must be made by consensus. If consensus cannot be reached, gifts will be forwarded to the Board of Directors for review and final decision.

Based upon the recommendation of the appropriate department all other gifts may be accepted by the Foundation Office.

 

Special Situations

Conditional Gifts
Conditional gifts are those gifts that, because of some qualifier or restriction, are considered non-routine. Conditional gifts may commit the Foundation to act within a specified time or use a gift for a specific purpose. If, in any instance, a gift offered by a donor would put the Foundation in an embarrassing or untenable position with the general public, the Foundation will decline acceptance. Time limits for holding a conditional gift may be reviewed by the Finance Committee. Gift acceptance agreements should specify a time period for meeting the conditions for the gift and should also indicate what will happen to the gift if conditions are not met. Primary choices are to move the gift to a different account or to refund the gift. The Executive Director will draft an acknowledgment of a conditional acceptance for appropriate signature. This will be sent to a donor within 10 days of approval of this form. A second acknowledgment letter will be sent when conditions have been satisfied.

Refunding of Gifts
In rare instances, the Foundation may deem it necessary to refund gifts, either because it is in the best interest of the Foundation or because conditions agreed to in accepting a gift cannot or will not be met. Requests for refunds may come either from the donor or from the recipient department and must include a statement of reason addressed to the Finance Committee.

 Conditions under which gifts may be refunded:

  • When conditions of acceptance cannot be met or cannot be agreed to.
  • When it is in the Foundation’s interest and when continuing to hold a gift would not enhance Grand Island Public Schools reputation either with the donor or with the general public.


Recognition Discounts & Services
The Foundation recognizes that corporations or private individuals may offer significant discounts on materials or services to Grand Island Public Schools. While these “gifts” do not qualify as tax-deductible donations, it is important to acknowledge and recognize these items through the Foundation’s formal stewardship programs. Donor acknowledgement of a significant discount on materials or services will be made by the Foundation and the receiving department at its discretion.

 

Grand Island Public Schools Foundation
Investment Policy


The Grand Island Public Schools Foundation, Board of Directors has a responsibility for the fiscal management of resources entrusted into its care. This includes, but is not limited to, management and investment of resources (over both short and long terms) to achieve the goals of the Foundation. The following investment goals, objectives, and strategies will be implemented to fulfill the responsibility of the Foundation Board.

The following are the stated investment goals of the Foundation.

To achieve a proper balance of investments between current investment income and future growth so as to:

A. Generate sufficient income to fund operations, scholarships and other goals;

B. Maintain future purchasing power of Foundation assets through capital growth

To structure assets so that the Foundation's investments portfolio will provide above average results (as compared to the S&P 500) in a variety of economic and market environments, as measured over meaningful periods of time.

The stated investment goals may be affected adversely by investment or market conditions over which the Board of Directors has no control.

Expectations and responsibilities of the Foundation

1. The Foundation shall establish a relationship with a professional money manager/financial advisor/financial services firm under the prudent professional standard, which shall be responsible for managing the Foundation's resources under this investment policy and under the following, but not limited to, conditions.

a. Detailed monthly investment reports shall be mailed or otherwise delivered to the Foundation's Executive Director.

b. Annually, or more often if the board deems advisable, the Foundation shall review the performance of the professional money manager/financial advisor /financial services firm and receive a report in person concerning the historical performance of the Foundation's portfolio, general financial health, financial concerns, if any, and suggested strategies to achieve the Foundation's stated goals.

c. Every ten years the Foundation shall conduct an evaluation and in-depth review of its relationship with the financial service firm. The purpose is to seek assurance that factors such as investment performance, cost, services and expertise are satisfactory for the Foundation's goals. The review may include an examination of other financial service firms. The Foundation may seek Requests for Qualifications (RFQ)'s from area financial managers for the purpose of reviewing qualified money managers available and interested in working with the Foundation's investments. At the conclusion of the review the Board may elect to extend its relationship with the current financial service firm or establish a new relationship with another firm. This will be done by a 2/3 majority vote of its members.

d. Not withstanding c, the Foundation may terminate its relationship with the money manager/financial advisor/financial services firm without cause at any time.

2. The Foundation's resources shall be invested under the following guiding principles according to the prudent professional standard. The assets shall be primarily invested in "high quality stock and mutual funds (front-load only)," through a financially sound mix of domestic and international mutual funds consisting of
a. Stocks
b. Bonds
c. Cash
d. Real Estate, if applicable

3. In determining the overall asset allocation the Foundation will consider its cash flow levels and variability, projected liquidity needs, need for current income and long term objectives. The Foundation will have at least 30% but not more than 80% of its total assets allocated to equities.

4. Foundation assets may also be invested in FDIC – insured certificates of deposit or other secured bank deposits, which are satisfactory to the Foundation

5. Donations made shall be liquidated at fair market value upon being entrusted into the professional money manager's care and reinvested immediately into the Foundation's portfolio.

6. Each year in November, after seeking the professional money manager's recommendations, the Foundation Board will by 2/3 majority vote, declare a percentage of the restricted investments to be paid in scholarships awarded the following spring. The Foundation Board reserves the right to use dividends paid by funds to make up all or part of the percentage of restricted investments declared.

7. Additionally, each year in November, after seeking the professional money manager's recommendations, the Foundation Board will by 2/3 majority vote, declare a percentage of the unrestricted investments to be paid for unrestricted foundation business.

8. Investment arrangements made by the Foundation prior to the adoption of this investment policy are hereby "grandfathered" in and are not subject to said policy.

 

GRAND ISLAND Public Schools FOUNDATION
Small Lottery and Raffle License Policy


As needed, the Grand Island Public Schools Foundation will apply for a Nebraska State Small Lottery and Raffle License in accordance with the Nebraska Small Lottery and Raffle Regulations (35-400:35-504).

This license will be used from time to time by the Grand Island Public Schools Foundation or one of its umbrella organizations for fundraising purposes.

In accordance with Regulation 35-403, the Grand Island Public Schools Foundation names the Treasurer of the Foundation as "Utilization of Funds Member" with responsibility to adhere to all regulations set forth by Nebraska law.

The Grand Island Public Schools Foundation Board will approve up to one special use permit annually for groups and organizations wishing to conduct raffles that generate more than $5,000.

With regard to the use of the license, the Foundation Board requires the following:

1. Organization must be a member of the Foundation
2. Organization must give Foundation 90 days advance notice
3. Signed compliance statement (I have read the rules and will comply)
4. Raffles requiring a Nebraska Special Permit must be complete within 90 days
5. Payment of Foundation Fees
6. Payment of all state, local, and federal taxes and filing fees

For this service the Foundation will incur additional operational expenses. Therefore, organizations wishing to conduct a raffle/lottery will be required to pay the Foundation's standard 2.5% fee on all raffle income raised as well as any actual out-of-pocket expense that the Foundation may incur.

The Foundation will open a specific bank account in which to deposit all lottery/raffle funds. This bank account will be owned and accounted for by the Grand Island Public Schools Foundation.

 

GRAND ISLAND Public Schools FOUNDATION

POLICY FOR SCHOLARSHIP GRANTS TO INDIVIDUALS


I. Policy intent. The intent of this Policy for Scholarship Grants to Individuals (hereinafter referred to as "the Policy") is to define the procedures which the Grand Island Public Schools Foundation (hereafter referred to as "the Foundation") will use to ensure that scholarship grants are awarded on an objective and nondiscriminatory basis as provided in I.R.C. §4945(g) and to further make provisions so that the Foundation shall have no donor advised funds as provided in I.R.C. §4966.

II. Donor advised fund. For purposes of this Policy, a donor advised fund means a fund or account as described in I.R.C. §4966 which is separately identified by reference to contributions of a donor or donors, which is owned and controlled by the Foundation and with respect to which a donor (or any person appointed or designated by such donor ) has, or reasonably expects to have, advisory privileges with respect to the distribution or investment of amounts held in such fund or account by reason of the donor's status as a donor.

III. Funds with respect to which a donor advises. Notwithstanding anything herein to the contrary, all funds or accounts of the Foundation with respect to which a donor (or any person appointed or designated by such donor) advises as to which individuals receive grants for travel, study, or similar purposes shall be subject to the following requirements:

(a) Such person's advisory privileges shall be performed exclusively by such person in the person's capacity as a member of a committee all of the members of which are appointed by the Foundation;

(b) No combination of persons consisting of a donor (or any person appointed or designated by such donor) or persons related to such persons shall control, directly or indirectly, such committee; and

(c) All grants from such fund or account shall be awarded on an objective and nondiscriminatory basis pursuant to the procedure contained in this Policy and to be approved by the Board of Directors of the Foundation as provided in I.R.C. §4945(g) and all grants from such fund or account shall constitute a scholarship grant which would be subject to the provisions of I.R.C. §117(a) (as in effect on the day before the date of the enactment of the Tax Reform Act of 1986) and shall be used for study at an educational organization described in I.R.C. §170(b)(1)(A)(ii) as provided in I.R.C. §4945(g)(1).

IV. Scholarship grants to individuals.

(a) Eligibility. Except as otherwise provided by the specific terms of an grant agreement, only students, alumni and employees of the Grand Island Public School are eligible to receive scholarship grants from the Foundation. The specific terms of a grant agreement may provide for scholarship grants to recipients other than students, alumni and employees of the Grand Island Public Schools.

(b) Private benefit. Notwithstanding anything herein to the contrary, the person or persons who select recipients of scholarship grants shall not be in a position to derive a private benefit, directly or indirectly, if certain potential grantees are selected over others. In addition, the Foundation will follow its Conflict of Interest Policy as to employees, officers, a member of the Board of Directors or a member of a committee of the Foundation.

(c) Selection of scholarship grant recipients. Scholarship Grant recipients will be selected on an objective and nondiscriminatory basis as provided in I.R.C. §4945(g) and all scholarship grants shall constitute a scholarship grant which would be subject to the provisions of I.R.C. §117(a) (as in effect on the day before the date of the enactment of the Tax Reform Act of 1986) and shall be used for study at an educational organization described in I.R.C. §170(b)(1)(A)(ii) as provided in I.R.C. §4945(g)(1). A scoring system may be developed and used in regard to the selection of scholarship grant recipients. When feasible, applicants for scholarship grants will be scored in anonymity. The selection of recipients shall be fair and impartial. An equity committee may be established to determine that the selection of recipients shall be fair and impartial. All members of the equity committee shall be subject to all of the provisions of this Policy.

(d) Selection criteria specific to funds separately identified by reference to contributions from a donor. The criteria to be used in selecting scholarship grant recipients in regard to funds separately identified by reference to contributions of a donor or donors which are owned by the Foundation must be based on criteria that are appropriate to the intent of the fund and described in any donor agreement when the fund was created. When the criteria stated in the original donor agreement is no longer relevant, a revised document (with donor consent and/or approval of the Board of Directors of the Foundation) may be substituted therefor. Notwithstanding anything herein to the contrary, any donor agreement shall be subject to the requirements of I.R.C. §4945(g)(1) as provided herein and any scholarship grants from funds separately identified by reference to contributions of a donor or donors which are owned by the Foundation shall be awarded on an objective and nondiscriminatory basis subject to the requirements of I.R.C. §4945(g) as provided herein and as required by I.R.C. §4966.

(e) Selection criteria specific to all scholarship grants. For all scholarship grants including, but not limited to, grants in regard to funds separately identified by reference to contributions of a donor or donors which are owned by the Foundation, criteria may include (but not be limited to) the following: prior academic performance, performance on tests designed to measure ability and aptitude for college work, recommendations from instructors, financial need, and the conclusions which the selection committee might draw from a personal interview as to the individual's motivation, character, ability and potential. Criteria may also include the applicant's place of residence, past or future attendance at a particular school, past or proposed course of study, and evidence of his or her artistic, scientific, or other special talent.

(f) Application process. Applicants for scholarship grants shall be required to submit such application forms and supporting materials as the Foundation may deem appropriate on a schedule to be determined by the Foundation.

(g) Scholarship/grant payments. Scholarships and grants will ordinarily be awarded for a period of one (1) year or a period of four (4) years as determined by the Board of Directors of the Foundation and/or the donor agreement. Scholarship recipients will have up to eleven (11) months after the award is made to claim (or begin claiming in the case of an award of four (4) years) their scholarship grants. If the scholarship grant recipient does not claim his or her scholarship in this designated period, the scholarship will be forfeited. The Foundation shall pay all scholarship grants directly to the educational institution described in I.R.C. §170(b)(1)(A)(ii). The Foundation shall require by agreement that each such institution agree to use the scholarship grant funds to defray the scholarship grant recipient's tuition and related expenses as defined in I.R.C. §117(a) (as in effect on the day before the date of the enactment of the Tax Reform Act of 1986). Generally, scholarships will be paid in equal installments to the educational institution. Scholarship grants that are $500 or less will be paid in one (1) installment (unless the recipient has a cumulative scholarship total with the Foundation of greater than $500). Scholarship grant recipients shall verify with the Foundation their enrollment in an educational institution described in I.R.C. §170(b)(1)(A)(ii) in order to have scholarship grants released to such educational institution. Scholarship grant recipients shall also provide other information as is deemed necessary by the Foundation.

(h) Selection Committees. The Foundation shall appoint all members of any selection committee charged with evaluating candidates for scholarship grants. Appointments shall be made by the Board of Directors. Nominations for any selection committee may be made by a committee duly appointed by the Board of Directors of the Foundation, the awards and grants committee of the Foundation or any designated employees of the Foundation. Subject to the requirements of Article III, a donor (or any person appointed or designated by such donor) may, in regard to scholarship grants from funds separately identified by reference to contributions of a donor or donors which are owned by the Foundation, participate in the selection process as a minority member of a selection committee; provided that no combination of persons consisting of a donor (or any person appointed or designated by such donor) or persons related to such persons shall control, directly or indirectly, such committee. Each member of any selection committee charged with evaluating applicants for scholarship grants shall be obligated to disclose to the Foundation any personal knowledge of and relationship with any potential scholarship grant recipient under consideration. A member of a selection committee shall not participate in the selection process when there is a circumstance where he or she would derive, directly or indirectly, a private benefit if any potential grantee or grantees are selected over others. In the event that a relative of a member of a selection committee submits an application for a scholarship grant, that respective member of the selection committee who is a relative of the applicant shall resign for that year. The Board of Directors shall appoint a replacement for that year.

(i) Restrictions on Scholarship Grants. As to scholarship grants from funds separately identified by reference to contributions of a donor or donors which are owned by the Foundation, no such scholarship grant shall be awarded to any relative of a member of a selection committee unless such member of the selection committee resigns for that year as provided hereinabove. Nothing herein shall prevent the award of a scholarship grant to an officer of the Foundation, a member of the Foundation's Board of Directors or any employee of the Foun¬dation or any relative of any officer of the Foundation, a member of the Foundation's Board of Directors or any employee of the Foundation; provided that the officer, member of the Board of Directors or employee who is an applicant or a relative of an applicant shall not participate in the selection of recipients for scholarship grants. In the event that a member of the Board of Directors or a relative of a member of the Board of Directors is selected as a recipient of a scholarship grant, the member of the Board of Directors who is selected or is the relative of the applicant selected as a recipient of a scholarship grant by the selection committees shall abstain from any discussion or vote on the approval of the recommendations of the selection committees and shall comply with the Foundation's Conflict of Interest Policy. Any employee of the Foundation may receive, accumulate and compile materials from applicants to submit to the selection committees but shall not participate in the selection of recipients for scholarship grants. Notwithstanding anything herein to the contrary, any relative of an officer of the Foundation, a member of the Foundation's Board of Directors or any employee of the Foundation shall be eligible for an Academic Aristocrat scholarship grant if such scholarship grant is awarded solely on the basis that such person meets the criteria of ranking in the top fifteen percent (15%) of his or her class and there is no discretion of the award of such scholarship grant to such person on the part of a selection committee. An applicant related to a donor (or any person appointed or designated by such donor) will not be eligible for a scholarship grant from funds separately identified by reference to contributions of a donor or donors which are owned by the Foundation in regard to which the applicant is related to such donor (or any person appointed or designated by such donor) that is part of the Academic Aristocrat program but will be eligible for a Academic Aristocrat scholarship grant from any funds separately identified by reference to contributions of a donor or donors which are owned by the Foundation in regard to which the applicant is not related to the donor (or any person appointed or designated by such donor) or from any funds that are not separately identified by reference to contributions of a donor or donors which are owned by the Foundation.

(j) Approval by Board of Directors of the Foundation. Each selection committee established under this Policy shall forward its recommendations to the Foundation in such form as established by the Foundation. The Board of Directors of the Foundation shall approve each scholarship grant made under this Policy; provided, however, that any member of the Board of Directors who is selected or is a relative of an applicant selected as a recipient of a scholarship grant by the selection committees shall abstain from any discussion or vote on the approval of the recommendations of the selection committees and shall comply with the Foundation's Conflict of Interest Policy as provided hereinabove.

(k) Use of Scholarship Grants. All scholarship grants shall be used only for study at an educational institution described in I.R.C. §170(b)(1)(A)(ii). Scholarship grants must be used for tuition and related expenses as defined in I.R.C. §117(a) (as in effect on the day before the date of the enactment of the Tax Reform Act of 1986).

(l) Renewals. A renewal of a scholarship grant which satisfied the requirements herein shall be permitted if:

(i) There is no information indicating that the original grant is being used for a purpose other than that for which it was made;

(ii) Any reports due at the time of the renewal decision pursuant to the terms of the original grant have been furnished; and

(iii) Any additional criteria and procedures for renewal are objective and nondiscriminatory.

(m) Reports. The Foundation shall obtain reports to determine whether the scholarship grant recipients have performed the activities that the grants are intended to finance.

(n) Retention of records. The Foundation shall retain the following records:

(i) All information the Foundation secures to evaluate the qualification of potential scholarship grant recipients;

(ii) Identification of recipients (including any relationship of any grantee to the Foundation sufficient to make the recipient a disqualified person of the Foundation within the meaning of I.R.C. §4946(a); and

(iii) Specification of the amount and purpose of the scholarship grant.

The retention of records shall be subject to the Document Retention/Destruction Policy of the Foundation.

(o) Policy of Nondiscrimination. All scholarship grants shall be awarded on a nondiscriminatory basis consistent with the requirements of I.R.C. §4945(g) as provided herein and shall not be based on race, creed, color or national origin; provided that the Foundation may establish funds for minority students or otherwise based on ethnicity or other criteria having the effect of furthering educational purposes in a manner supporting a policy of nondiscrimination.

235-2/323379

 

Grand Island Public Schools Foundation
Whistleblower Policy


General
The Grand Island Public Schools Foundation requires all employees to observe the highest standard of business and personal ethics in the conduct of their duties and responsibilities. As representatives of the Foundation, employees must practice honesty and integrity in fulfilling responsibilities and comply with all applicable laws and regulations.

Reporting Responsibility
It is the responsibility of all employees to comply with the law and to report violations or suspected violations in accordance with this Whistleblower Policy.

No Retaliation
No employee who in good faith reports a violation shall suffer harassment or retaliation, nor will he or she suffer an adverse employment consequence. An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment. This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns within the Foundation prior to seeking resolution outside the Foundation.

Reporting Violations
In most cases, an employee's supervisor is in the best position to address an area of concern. However, if an employee is not comfortable speaking with his or her supervisor, or is not satisfied with the supervisor's response, the employee is encouraged to speak with anyone in management that he or she is comfortable in approaching. Supervisors and managers are required to report suspected violations to the Foundation's Executive Director. If an employee is not satisfied with the Executive Director's decision, the employee should contact the Foundation's Board Officer directly.