Policies & Standards

Purpose

To expedite the conduct of routine business during board meetings in order to allocate more meeting time to discussions of substantive issues.

Policy

1. The consent agenda should consist of routine financial, legal and administrative matters that require board action such as, but not limited to, minutes, staff reports, committee minutes/reports and approval of operating policies and policy revisions.

2. Consent agenda items are expected to be non-controversial and not requiring of discussion.

3. The consent agenda generally is voted on in a single majority vote, but it may be divided into several, separate items.

4. Motions, resolutions and all supporting materials for the consent agenda should be sent to board members at least one week in advance. 

5. The consent agenda should be considered early in a board meeting. The Chair will ask if any member wishes to remove an item from the consent agenda for separate consideration, and if so, the Chair will schedule it for later in the meeting.

A committee of the board called the Executive Compensation Review Committee will meet every year prior to the September board meeting to set Executive Compensation for the coming fiscal year. The committee will be comprised of the Treasurer and two other independent board members. The committee will elect a chair.

The committee shall:

1. conduct review using salary guides, studies and/or the Form 990’s of similar NGOS.

2. study comparable salary and benefits data, such as data available from salary and benefits surveys, to learn what employers of a similar budget size that are located in the same, or a similar geographic region, pay their senior leaders. The comparison will include data from other nonprofits of a similar mission focus. The data shall be updated at least every other year.

3. document who was involved and the process used to conduct the review, as well as the disposition of the full board’s decision to approve officer compensation. The document of the process shall be attached to the minutes and copies of both shall be kept in personnel files. The documentation should demonstrate that the board took comparable data into consideration when it approved the compensation.

Key Elements

An effective performance evaluation begins with a mutually understood process. The board needs to determine the appropriate role for the board chair, individual board members, and any committee. It should also address how the chief executive will participate in the process and what kind of evaluation tool to use.

The performance evaluation should take into account the chief executive’s job description, annual goals and objectives, and any other relevant factors identified or approved by the board. The executive’s annual goals and objectives should be closely tied to the organization’s annual goals and objectives.

The evaluation should include the chief executive’s own self-assessment as well as the board’s evaluation of his or her performance. The full board needs to review both.

The evaluation should be conducted annually and documented in writing, particularly where the outcome is adverse and/or could lead to dismissal. In all cases, the assessment will provide a permanent record that can be referred to by both the chief executive and the board, greatly increasing clarity and certainty.

The assessment process should be separated from compensation even if performance is a key element in setting or reviewing the compensation level of the chief executive. Compensation should not drive evaluation; it should be discussed independently after coming to a mutual agreement on evaluation results.

Monitoring Chief Executive Performance

Systematic and rigorous monitoring of the chief executive’s performance will be measured against the achievement of organizational goals.

1. Monitoring is used to determine the degree to which organizational performance goals are being met. Data that do not do this will not be considered to be monitoring data.
2. The board will acquire monitoring data by using one or more of the following methods:
   • By internal report, in which the chief executive discloses compliance information to the board
   • By external report, in which an external, disinterested third party selected by the board assesses compliance with organizational performance goals
   • By direct board inspection, in which a designated member or members of the board assess compliance with the appropriate goal
   • Monitoring will occur at a frequency and by a method chosen by the board. The board can monitor any organizational goal at any time by any method, but will ordinarily depend on a routine schedule that is negotiated annually with the chief executive. However, the formal evaluation of the CEO’s performance will occur annually before the September board meeting.
3. The CEO will provide regular information necessary for monitoring progress against organizational goals.

1. Reason for Policy

As a nonprofit, tax-exempt entity, this organization has been organized for the public benefit and depends on grants, charitable contributions, and other forms of public support. This organization, therefore, has a mandate to at all times promote public, not private, interests, and to avoid conflicts of interest. The Internal Revenue Service as well as state corporate, tax, and consumer protection officials view the operations of nonprofit organizations akin to public trust, with legally enforceable accountability to both governmental authorities and members of the public.

 2. Summary of Policy

Any possible conflict of interest on the part of a director, officer, or management employee, (“Decision Makers,” as defined below in Section 3), shall be fully and promptly disclosed to the Chair of the Board of Directors, who shall promptly investigate the facts and report to the Board as a matter of record. Disclosure shall be made as soon as a Decision Maker discovers a personal or other entity interest which could affect the activities, programs, property, employees, or services of this organization, or any matter or transaction potentially requiring Board action. Further, each Decision Maker shall complete the Annual Conflicts of Interest Questionnaire (Attachment A) confirming that all conflicts and potential conflicts existing during the previous year, or currently existing, have been disclosed both upon hire/appointment and on an annual basis. Other employees, interns, and volunteers (“Non-Decision Makers”) shall make known to the Chief Legal Officer as soon as they are aware any affiliation they might have with an actual or potential supplier of goods and services, recipient of grant funds, or organization with competing or conflicting objectives. The Chief Legal Officer shall work with the Non-Decision Maker to mitigate the potential conflict (ex. internally segregating the Non-Decision Maker from the conflict of interest).

When a Decision Maker’s possible conflict has been identified, the Board Chair shall determine whether the possible conflict may be material as long as the possible conflict does not involve the Board Chair. If the Board Chair determines a material conflict may exist, or if the possible conflict involves the Board Chair, the Board shall be notified and fully informed so that it can determine whether a conflict actually exists and whether it is material. Where a material conflict exists, the Board shall determine whether the contemplated transaction or other conflicting involvement may be authorized as just, fair and reasonable as to the organization. The decisions of the Board on these matters will be guided by independent counsel as appropriate, and their guiding principle shall be the integrity and best interest of this organization and the advancement of its purposes.

Between the general public and this organization and its Decisions Makers, there exists a fiduciary duty that carries with it a broad and unbending duty of loyalty. The Decision Makers have the responsibility to administer the affairs of this organization honestly and prudently, and to exercise their best care, skill, and judgment for the sole benefit of this organization. These persons shall exercise the utmost good faith in all transactions related to their duties, and they shall not use their positions with this organization or knowledge gained therefrom for their personal benefit. The best interests of this organization must always have the first priority. All transactions must only be approved if they secure for this organization full competitive advantages as to product, service, and price, and contains no material element of private benefit.

 3. Persons Concerned

This policy is directed not only to directors and officers but to all employees who can influence the actions of this organization or its Board or make commitments on their behalf (“Decision Makers”). For example, this would include all who make purchasing decisions, all other persons who might be described as “management personnel,” and all who have highly sensitive proprietary information concerning the organization (collectively “Decision Makers”). This policy also applies to other employees, interns, and volunteers who shall report conflicts as part of the hiring onboarding process and as conflicts arise.

 4. Areas in Which Conflicts May Arise

Conflicts of interest may arise with third party entities whenever a Decision Maker is wearing a second hat of responsibility, either personally or with another organization. These conflicts occur in a multitude of contexts. Here are a few examples:

• Persons or entities supplying goods and services to this organization.
• Persons or entities from whom this organization leases property, equipment, and staff.
• Persons or entities with whom this organization is dealing or planning to deal in connection with the donation, purchase, or sale of real estate, securities, or other property.
• Persons or entities paying honoraria or royalties for products or services delivered by this organization or its agents or employees.
• Other nonprofit or for-profit organizations pursuing possible affiliation or collaboration for a transaction, project, or ongoing program.
• Foundations, government grantors or contractors, corporations, or others supporting the organization.
• Agencies, organizations, and associations that monitor, regulate, or otherwise affect the operations of this organization.

5. Nature of Conflicting Interests

A material conflicting interest is defined as an interest, direct or indirect, between a Decision Maker and any other person or entity (such as those examples mentioned in Section 4) which might affect or influence, or might reasonably be thought by others to affect or influence, the judgment or conduct of a Decision-Maker of this organization. As examples, direct interests might arise through:

•  Owning stock or holding debt or other proprietary interests in any third party dealing with this organization or its affiliate.1

• Investing in a business in which this organization or an affiliate holds an interest that reasonably could affect the value of the individual’s investment.

• Investing in a non-publicly traded business in which the Decision Maker either owns 5% or more of the voting stock or in any other way exercises effective influence of the business.

• Holding office, serving on the board, participating in the management or being otherwise employed (or formerly employed) in any third party dealing with this organization or its affiliate.

• Receiving any form of remuneration or benefit for services with respect to individual transactions involving this organization or its affiliate.

• Using this organization’s or any affiliate’s personnel, equipment, supplies, or resources, or goodwill for personal benefit, or for other than organization-approved activities, programs and purposes.

• Receiving personal gifts or loans from third parties dealing with this organization or its affiliate. (Receipt of any gift is disapproved except gifts of nominal value which could not be refused without discourtesy. No personal gift of money should ever be accepted.)

• Obtaining or possessing an interest in real estate, securities or other property that this organization or its affiliate might consider buying or leasing.

• Expending staff time during normal business hours for personal affairs or for other organizations, nonprofit or otherwise.

• Obtaining or reserving personal ownership or royalty interest in copyrights, trademarks or patents in which this organization or its affiliate has an interest.

 6. Indirect Interests of Related Parties

Conflicting interests may also be indirect. A Decision Maker will be considered to have an indirect interest in another entity, transaction, or property if any of the following have an interest:

• A family member of a Decision Maker. (Family member is defined by the IRS for these purposes as spouses, brothers and sisters (by whole or half-blood), spouses of brothers and sisters (by whole or half-blood), ancestors, children, grandchildren, great-grandchildren, and spouses of children, grandchildren, and great-grandchildren.)
• An estate or trust of which Decision Maker or family member is a beneficiary, personal representative, or trustee.
• An entity of which a family member of the Decision Maker is an officer, director or employee, or in which the family member has an ownership or other proprietary interests.
• A colleague or employee of a law firm, accounting firm, or other professional entity of which the Decision Maker or family member is an owner, employee, or otherwise affiliated.

7. Interpretation of This Statement of Policy

The relations listed in Section 4 potentially giving rise to areas of conflicting interests and the direct and indirect interests listed in Sections 5 and 6 are not exhaustive. Conceivably, conflicts might arise in other areas or through other relations. It is expected that each Decision Maker will recognize such areas and relation by analogy.

The fact that one of the interests described in Sections 5 and 6 does not necessarily mean that a conflict exists, or that the conflict, if it exists, is sufficiently material to be of practical importance, or if material, is necessarily adverse to the interests of the organization. However, it is the policy of the Board that the existence of any of the interests described in Sections 5 and 6 shall be promptly disclosed and fully investigated before any transaction is consummated. It shall be the continuing responsibility of all Decision Makers to scrutinize their transactions and outside business interests and relationships for potential conflicts and to immediately make disclosures of all relevant facts and circumstances.

As soon as practical after a Decision Maker’s potential conflict is identified, the Board Chair shall determine whether the possible conflict may be material as long as the possible conflict does not involve the Board Chair. If the Board Chair determines a material conflict may exist, or if the possible conflict involves one of these two persons, the Board shall be notified and fully informed so that it can determine whether a conflict actually exists and whether it is material. Where a material conflict exists, the Board shall determine whether the contemplated transaction may be authorized as just, fair, reasonable, and in the best interest of the organization. The decisions of the Board on these matters will be guided by independent counsel as appropriate, and their guiding principle shall be the integrity and best interests of this organization and the advancement of its purposes.

Any Board member having a possible conflict of interest on any matter shall not vote or use his or her personal influence on the matter and shall be recused from final discussion and voting after answering all board questions and fully informing the board of all pertinent detail. The Minutes of the Board will reflect all conflicts of interest disclosures and abstentions from voting and the existence of a quorum.

8. Annual Conflicts of Interests Questionnaire

To further promote and facilitate the full disclosure of potential and actual conflicts of interest, each Decision Maker shall complete the Annual Conflicts of Interest Questionnaire (Attachment A) upon appointment to World Hope International Inc., and at least once each year thereafter.

ATTACHMENT A

World Hope International, Inc.

Annual Conflict of Interest Statement

For Officers, Directors, and Key employees.

No member of the World Hope Board of Directors, or employee, intern, or volunteer shall derive any personal profit or gain, directly or indirectly, by reason of his or her participation with World Hope.

Each individual shall disclose to World Hope any personal interest, in any matter related to World Hope and shall refrain from participation in any decision on such matter. Each individual shall disclose any affiliation he or she might have with an actual or potential supplier of goods and services, recipient of grant funds, or organization with competing or conflicting objectives.

Any member of the World Hope Board or Key employee who is an officer, board member, a committee member or staff member of a partner organization shall identify his or her affiliation with such organizations; further, in connection with any policy committee or board action specifically directed to that organization, he/she shall not participate in the decision affecting that organization and the decision must be made and/or ratified by the full board.

Any member of the World Hope Board or Key employee shall refrain from obtaining any list of World Hope donors for personal or private solicitation purposes at any time during or after their term.

Now this is to certify that I, except as described below, am not now nor at any time have been:

1) A participant, directly or indirectly, in any arrangement, agreement, investment, or other activity with any vendor, supplier, or other party; doing business with World Hope which has resulted or could result in personal benefit to me.

With the exception of the following: __________________________________________________________________________________________________________________________________________________________________________

2) A recipient, directly or indirectly, of any loans or gifts of any kind from or on behalf of any person or organization engaged in any transaction with the World Hope.

With the exception of the following: __________________________________________________________________________________________________________________________________________________________________________

Affiliations: _________________________________________________________________________________________________________________________________________________________________________________________________________________________________

Date: ________________

Signature: ___________________________________

Printed name: ________________________________

World Hope International does not and shall not unlawfully discriminate on the basis of race, color, national origin, age, handicap, religion, or sex

GUIDELINES FOR APPROPRIATE CONDUCT

In order to conduct the operations of WHI efficiently and professionally, all employees are to follow the rules of conduct that will protect the interests and safety of all employees and the company. All employees are expected to act in a professional manner with customers, and the general public.

Although it is not possible to list all forms of inappropriate behavior and conduct, the following are examples that are considered inappropriate and may result in disciplinary action up to and including termination of employment:

• Falsifying employment or other company records;
• Violating the Anti-Harassment policy;
• Violating certain state, federal or local laws and regulations;
• Violating security or safety rules or failing to observe safety rules or safety practices; failing to wear required safety equipment; tampering with equipment or safety equipment;
• Soliciting gratuities from customers or clients;
• Displaying excessive or unexcused absenteeism or tardiness;
• Possessing firearms, weapons or explosives on company property without authorization, in violation of policy or while on duty;
• Using the company’s property and supplies, particularly for personal purposes in an excessive, unnecessary or unauthorized way;
• Negligent damage of property;
• Violating the Violence in the Workplace policy;
• Violating the Drug-Free Workplace policy;
• Committing theft or unauthorized possession of company property or the property of fellow employees; possessing or removing any company property, including documents, from the premises without prior permission from the management; using company equipment or property for personal reasons without proper authorization; using company equipment for profit;
• Giving confidential or proprietary information to competitors; working for a competing business while an employee of the company; breaking confidentiality of information such as Social Security Numbers, including any part of Social Security Numbers. Personal information also includes driver’s license numbers, state-issued identification card numbers, date of birth, credit or debit or other account numbers, passport numbers, alien registration numbers or health insurance identification numbers;
• Engaging in abusive conduct, or bullying, such as using obscene, abusive or threatening language or gestures or other verbal or physical conduct a reasonable person would find threatening, intimidating, or humiliating;
• Soliciting, selling, or collecting funds for any purpose while on working time (not including meals and authorized breaks). Employees who are not on working time shall not interfere with the work of employees who are on working time.

Where appropriate, supervisors will follow a process of progressive employee discipline. Before or during the application of any discipline, employees may be given an opportunity to relate their version of the incident or problem and provide an explanation. Examples of progressive employee discipline include:

• Verbal Counseling – A conversation with an employee explaining that the employee’s conduct or poor performance is unacceptable, and repeated or continued unacceptable conduct or performance will result in more severe disciplinary action. A record of the notice of the verbal counseling may be made and retained in the employee’s personnel file.
• Written Counseling – A written document or memo that describes the unacceptable conduct or performance of the employee and specifies needed changes or improvements. A copy of the written counseling generally will be retained in the employee’s personnel file.
• Termination – If an employee fails to follow acceptable conduct or performance standards, the company may terminate the employee’s employment.
Depending on the specific circumstances, the company may suspend or terminate an employee without prior discipline, or without following a particular order of discipline.

OFF DUTY CONDUCT

The way in which workers conduct and present themselves off-duty can have a significant impact on WHI’s business, reputation, sales, customer relations and workplace environment. Accordingly, while WHI respects employees’ personal freedom, it also has a legitimate interest in establishing standards of off-duty conduct and holding workers accountable for following those standards, including through the use of discipline, up to and including termination.

Examples of permissible off duty conduct include, but are not limited to:

• Smoking, and use of other lawful products (may want to add consistent with substance abuse policy if the client has one)
• Involvement in political activity, such as: o Promoting voter turnout
o Attendance at, participation in, and/or volunteering for a political candidate of your choice
o Promoting a political candidate of your choice, (e.g., yard signs, bumper stickers, attending rallies, etc.)
o Responsible use of social media
o Charity fundraising or volunteering

The following off-duty conduct will be considered a work-related matter subject to discipline:

• Illegal drug use;
• Driving under the influence of drugs and/or alcohol;
• Sexual misconduct;
• Racist or sexist remarks or conduct;
• Inappropriate comments and/or jokes in violation of WHI’s anti-harassment, anti-discrimination, or equal employment policies
• Threats against coworkers or supervisors;
• Has consequences that render you unable to perform your job or any part of your job effectively;
• Makes it difficult for the Company to manage its operations and/or direct its workforce efficiently.

ETHICS

WHI is committed to providing a work environment governed by the highest ethical and legal standards. In all situations, employees are expected to conduct activities with integrity, ethically and in accordance with applicable laws and regulations.

Part of maintaining an ethical workplace is providing employees the opportunity to provide honest feedback. The company will not tolerate retaliation of any kind against an employee who reports in good faith a violation of law or of this policy.

WHI encourages employees to report any actual or potential violations of applicable laws or regulations and any unethical, dishonest or improper conduct to your supervisor, the president/CEO or WHI’s Human Resources Department. If employees are uncertain as to whether there are any laws or regulations that may impact work, employees are responsible for requesting guidance from their supervisor or WHI’s Human Resources Department.

CONFLICT OF INTEREST

In all situations, employees are expected to conduct activities with integrity, ethically and in accordance with applicable laws and regulations. Employees should not engage in any work activity, practice or conduct which is or appears to be a conflict of interest for the company, its customers, suppliers, contractors, competitors or any person doing or seeking to do business with WHI, as described below.

Employees are to act in the best interests of the company, regardless of personal preference, and must not create the perception of personal advantage. An actual or potential conflict of interest occurs when an employee is in a position to influence a decision that may result in a personal gain for that employee or for a relative (related by blood or marriage, or a similar relationship).

The mere existence of a relationship with outside firms does not necessarily create a conflict of interest. However, if an employee has any influence on transactions involving purchases, contracts or leases, employees must disclose the existence of the relationship to a supervisor as soon as possible.

Employees may not solicit or accept a promise of future employment based on any gift, loan, gratuity, reward or anything else of monetary value that might appear to influence your judgment or create a conflict in the performance of your job. Employees may accept occasional unsolicited courtesy gifts or favors (such as business lunches, tickets to sporting events or cultural events, holiday baskets, flowers, etc.) so long as the gifts or favors have a market value under $100, are customary in the industry, and do not influence or appear to influence the employee’s judgment or conduct. Employees are encouraged to contact their supervisor for guidance as needed prior to the acceptance of any gift or favor.

CONFIDENTIALITY OF BUSINESS INFORMATION

WHI is committed to protecting the confidentiality of information that we handle for our clients or customers. The general business affairs of our customers and clients will not be discussed with anyone outside the organization except as required in the normal course of business. Confidential information regarding our business includes, but is not limited to, inventions, discoveries, improvements, processes, formulas, software, apparatus, equipment, methods, trade secrets, research, client data and information or cost or purchases of Client’s products or services will not be disclosed to any party without the appropriate consent of WHI.

CONFIDENTIALITY OF SOCIAL SECURITY NUMBERS AND OTHER CONFIDENTIAL EMPLOYEE INFORMATION

WHI is committed to protecting the confidential information of all employees and clients or customers. Employees are required to maintain the confidentiality of all employee or customer or client information including but not limited to, Social Security Numbers, including any part of Social Security Numbers, driver’s license numbers, state-issued identification card numbers, date of birth, credit or debit or other account numbers, passport numbers, alien registration numbers, health insurance identification numbers or health information.

If an employee has access to employee personal information, they must safeguard it by keeping the information, whether in paper or electronic format, in a secure location and only access the data for authorized business purposes. Employee personal information will only be shared with co-workers who need it as part of their job requirements.

Employees should only include a portion or complete Social Security Number or other employees personal information in internal e-mails if required by a specific business need. If WHI has an authorized business need to send any type of personal information outside the company, either in an email or in an attachment to an email, WHI must use approved encryption technology to encrypt the email prior to sending it. Employees are expected to comply with applicable state laws that restrict the use of a full or partial Social Security Number.

WHI utilizes company shred machines or shred receptacles to dispose of paper documents that contain employee personal information. WHI destroys computer media or files containing employee personal information in a manner ensuring confidentiality. PROTECTED HEALTH INFORMATION

WHI takes the privacy of our employees seriously. The company’s privacy policies and procedures strengthen our commitment to maintaining the confidentiality of personal health information. All employees are expected to comply with the company’s privacy policies and procedures.

ABSENTEEISM AND TARDINESS

Regular attendance is important to the smooth operation of WHI and ensuring the faithful use of donor funds. All employees follow an internal WHI Absenteeism and Tardiness Policy.

DRUG-FREE WORKPLACE

WHI is committed to protecting the safety, health and well-being of all employees, customers, clients, and vendors in our workplace. “Workplace” includes company property, any company-sponsored activity or any other site where you are performing work or representing the company.

The term “drug” as used in this policy includes alcoholic beverages and prescription drugs, as well as illegal inhalants and illegal drugs and/or controlled substances including, but not limited to, marijuana, opiates (e.g., heroin, morphine), cocaine, phencyclidine (PCP), and amphetamines.

All employees are expected to contribute to maintaining a drug-free workplace. Prohibited activities under this policy include the possession, use, sale, attempted sale, distribution, manufacture, purchase, attempted purchase, transfer or cultivation of drugs in the workplace. Employees are also prohibited from being at the workplace with a detectable amount of drugs in their system. However, the use and/or possession of prescription drugs, when taken as directed and obtained with a valid prescription under federal law, is not a violation of this policy.

As a condition of continued employment, all employees must comply with this policy. An employee who engages in an activity prohibited by this policy shall be subject to disciplinary action, up to and including immediate termination of employment. This policy is not intended to replace or otherwise alter applicable U.S. Department of Transportation obligations or any other federal, state or local agency drug testing regulations related to a particular industry.

TOBACCO-FREE WORKPLACE

WHI is committed to providing all employees with a safe and healthy work environment. All company premises are smoke-free unless clearly marked otherwise. Smoking a cigarette, cigar, e-cigarette, or pipe or any other form of tobacco, as well as the chewing of tobacco, is not allowed. For your convenience, designated smoking areas are clearly marked. Employees are expected to use waste disposal receptacles for smoking products.

ANTI-HARASSMENT

WHI is committed to a work environment in which all individuals are treated with respect and dignity and are free from all forms of harassment and discrimination. Any form of harassment, even when not unlawful or directed at a protected category, is prohibited and will not be tolerated. All employees, including supervisors, co-workers, vendors, contractors, customers or other third parties, are expected to adhere to this policy.

Reported or suspected occurrences of harassment or discrimination will be promptly and thoroughly investigated. Following an investigation, WHI will promptly take any necessary and appropriate disciplinary action.

WHI will not permit or condone any acts of retaliation against anyone who files or cooperates in the investigation of harassment or discrimination complaints.

The term “harassment” includes harassment based on any category protected by federal, state or local law, which may include, but is not limited to, unwelcome slurs, jokes, or verbal, graphic or physical conduct relating to an individual’s race, color, religious creed, sex, national origin, ancestry, citizenship status, pregnancy, childbirth, physical disability, mental and/or intellectual disability, age, military status or status as a Vietnam-era or special disabled veteran, marital status, registered domestic partner or civil union status, familial status, gender (including sex stereotyping and gender identity or expression), medical condition (including, but not limited to, cancer-related or HIV/AIDS-related), genetic information, or sexual orientation.

Sexual harassment consists of unwelcome sexual advances, requests for sexual favors, or other verbal or physical conduct of a sexual nature where:

• Submission to such conduct is an explicit or implicit term or condition of employment;
• Employment decisions are based on an employee’s submission to or rejection of such conduct; or
• Such conduct unreasonably interferes with an individual’s work performance or creates an intimidating, hostile or offensive working environment.

Complaint Procedure

WHI provides employees with a convenient and reliable method for reporting incidents of alleged harassment, including sexual harassment, and discrimination. Any employee who feels harassed or discriminated against is encouraged to immediately inform the alleged offender that the behavior is unwelcome. In many instances, the person is unaware his or her conduct is offensive, and this action alone may often resolve the problem. If the informal discussion with the alleged offender is unsuccessful in remedying the problem, or if you do not feel comfortable with such an approach, you should immediately report the conduct to your immediate supervisor, manager or Chief Legal Officer.

If an employee wishes to make an anonymous complaint, they may do so. However, the scope of WHI’s investigation may be limited based on the information provided.

Confidentiality

All reports of alleged harassment, sexual harassment, or discrimination will be treated seriously. Confidentiality will be maintained to the extent possible. However, to conduct a thorough investigation, certain information may need to be disclosed to other individuals, including the alleged offender. Consequently, absolute confidentiality cannot be promised and cannot be guaranteed.

Investigative Procedure

Once a complaint of alleged harassment, sexual harassment, or discrimination is received, WHI will begin a prompt and thorough investigation. The investigation may include interviews with all involved employees, including the alleged harasser, and any employees who are aware of facts or incidents alleged to have occurred.

Following an investigation, WHI will promptly take any necessary and appropriate disciplinary action. Disciplinary action will be taken if the investigation reveals that an employee has acted in a manner that is not in alignment with the goals of this policy. WHI may address any workplace issue discovered during an investigation. This may include some or all of the following steps:

• Restore any lost terms, conditions, or benefits of employment to the complaining employee.
• Discipline the alleged harasser. This discipline may include written disciplinary warnings, transfer, demotion, suspension and/or termination of employment.
• If the alleged harassment, sexual harassment, or discrimination is from a vendor, contractor, customer or other third parties, WHI will take appropriate action to stop the conduct.

If an employee makes a complaint but feels that the action taken in response has not remedied the situation, the employee should make an additional complaint following the complaint procedure outlined in this policy.

Duties of Employees and Supervisors

All employees of the company, both management and non-management, are responsible for assuring that a workplace free of harassment, sexual harassment, and discrimination is maintained. Any employee may file a complaint regarding incidents experienced personally or incidents observed in the workplace. The company strives to maintain a pleasant work environment where all employees are able to effectively perform their work without interference of any type and request the assistance of all employees in this effort.

All managers and supervisors are responsible for doing all they can to prevent and discourage harassment, sexual harassment, and discrimination from occurring. If a complaint of harassment, sexual harassment or discrimination is raised, the individual to whom the complaint is made (i.e., supervisor, manager, company owner) should act promptly to notify the Chief Legal Officer so an investigation may promptly proceed. WHI may discipline any managers or supervisors who fail to follow this policy, which discipline, may include termination.

ANTI-BULLYING

WHI is committed to a work environment in which all individuals are treated with respect and dignity and are free from all forms of abusive conduct. Abusive conduct, or “bullying,” is the conduct of an employer or employee in the workplace, with malice, that a reasonable person would find hostile, offensive, and unrelated to an employer’s legitimate business interests.

It includes unwelcome or unacceptable behavior including repeated infliction of verbal abuse, such as derogatory remarks, insults, epithets, verbal or physical conduct that a reasonable person would find threatening, intimidating, or humiliating, or the gratuitous sabotage or undermining of a person’s work performance and may be directed at an individual or a group. Bullying behavior is often persistent and part of a pattern, but it can also occur as a single incident if it is especially severe and egregious. It is usually carried out by an individual but can also be an aspect of group behavior. Some examples of bullying behavior are

•Excessive supervision;
•Belittling or disregarding opinions or suggestions;
• Manipulating the ability of someone to do their work (e.g., overloading, underloading, withholding information, setting meaningless tasks, setting deadlines that cannot be met, giving deliberately ambiguous instructions);
• Unfairly blaming for mistakes;
• Trivializing of work and achievements;
• Abusive and offensive language;
• Insults;
• Teasing;
• Public humiliation in any form;
• Spreading rumor and innuendo;
• Unreasonable criticism;
• Isolating people from normal work interaction;
• Deliberate exclusion;
• Practical jokes;
• Name-calling;
• Threats of physical harm or other types of retribution

Bullying may be intentional or unintentional. However, it must be noted that where an allegation of bullying is made, the intent of the alleged bully is irrelevant, and will not be given consideration when disciplining an employee. It is the effect of the behavior upon the individual which is important.

WHI encourages all employees to report any instance of bullying behavior. Reported or suspected occurrences of bullying will be promptly and thoroughly investigated. Following an investigation, WHI will promptly take any necessary and appropriate disciplinary action.

WHI will not permit or condone any acts of retaliation against anyone who files or cooperates in the investigation of bullying complaints.WHI provides its employees with a convenient and reliable method for reporting incidents of alleged harassment, including sexual harassment and discrimination. Any employee who feels harassed or discriminated against should follow the complaint procedure as described in the Anti-Harassment policy.

VIOLENCE IN THE WORKPLACE

WHI is committed to providing a safe workplace for employees, customers, vendors, volunteers, independent contractors and others with whom we do business. The company has zero tolerance for violent acts or threats of violence.

Employees are expected to conduct themselves in a non-threatening, non-abusive manner at all times. Any direct, conditional or veiled threat of harm to any employee, guest or company property will be considered unacceptable behavior. Acts of violence, intimidation or bullying of others will not be tolerated.

All employees share responsibility in identifying and alleviating threatening or violent behaviors. Anyone who is subjected to or threatened with violence, or who is aware of another individual who has been subjected to or threatened with violence, is to immediately report this information to his/her supervisor, a management member or Chief Legal Officer. Employees must assume that any threat is serious. WHI will carefully investigate reports and maintain employee confidentiality to the fullest extent possible.

WHI will take disciplinary action, up to and including termination, and/or legal action as appropriate, against any employee who commits or threatens to commit a violent act against any person while on company premises or while engaged in company business off the premises.

WEAPONS

WHI strives to provide a safe and secure workplace for employees, clients, customers and visitors. The company has zero tolerance for, and forbids the possession of any type of weapon, firearm, explosive and/or ammunition while on company property or conducting company business. For purposes of this policy, company property includes, but is not limited to, all company facilities, company-provided vehicles and equipment that are either leased or owned by the company or a company client.

Possession of firearms or other weapons may be cause for discipline, including, but not limited to, the immediate termination of employment. In enforcing this policy, WHI reserves the right to request inspections of any employee and their personal effects while on company property, to the extent allowable under applicable law. Any employee who refuses to allow an inspection will be subject to the same disciplinary action as having been found in possession of firearms or other weapons.

RETALIATION

WHI prohibits retaliation in the workplace. All employees should feel secure when reporting, in good faith, claims to management for workplace harassment, discrimination, bullying or unethical actions or behaviors. Employees have a responsibility to report harmful and unethical behavior and conduct. Likewise, WHI has a duty to keep the workplace a safe environment for all employees.

Upon receipt of receiving a complaint or allegation of inappropriate behavior or conduct, a member of management or procured the third party will take prompt action to investigate the claim, which includes interviewing employees who are aware of facts or alleged incident, interviewing the employee named in the alleged claim, and any necessary follow up.

During this process, all information will be kept as confidential as possible; however, full confidentiality cannot be guaranteed.

Retaliation towards an employee who reports a claim or participates in an investigation is against the law and will not be tolerated. Retaliation will lead to disciplinary action up to and including termination of employment.

ROMANTIC RELATIONSHIPS

WHI strongly believes that an environment where employees maintain clear boundaries between employee personal and business interactions is most effective for conducting business. Romantic relationships may cause misunderstandings, conflicts of interest, complaints of favoritism, negative employee morale, and has the potential for sexual harassment claims if the relationship ends.

All employees are strongly discouraged from becoming romantically involved with co-workers, especially in relationships where employees are in a supervisor-subordinate relationship. Employees are expected to behave in a professional manner in the workplace and must follow the company’s policy against unlawful harassment of any kind, including sexual harassment.

An employee who is romantically involved with a supervisor or co-worker should immediately and fully disclose the relevant circumstances to their supervisor or another management member so that a determination can be made as to whether the relationship presents an actual or potential conflict of interest. If so, the company may take appropriate action according to the circumstances, up to and including transfer or termination of employment.

World Hope International requires directors, officers, employees, interns, and volunteers to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of WHI, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.

Reporting Responsibility: It is the responsibility of all directors, officers, employees, interns, and volunteers to comply with the Code of Conduct and to report violations or suspected violations in accordance with this Whistleblower Policy.

No Retaliation: No person who in good faith reports conduct under this policy shall suffer harassment, retaliation, or adverse employment consequences. An employee who retaliates against someone who has reported conduct 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 WHI prior to seeking resolution outside the organization.

Reporting Violations: This policy suggests that employees, interns, and volunteers share their questions, concerns, suggestions, or complaints with someone who can address them properly. For example, an employee’s supervisor is in the best position to address an area of concern. However, if you are not comfortable speaking with your supervisor or you are not satisfied with your supervisor’s response, you are encouraged to speak with the Chief Legal Officer (CLO) or anyone in management whom you are comfortable approaching. Supervisors and managers are required to report suspected violations of the Code of Conduct to the CLO. Per the PSEA Investigative Policy in 3.43, direct all reports of sexual exploitation or abuse to SAFE@wordhope.org. Reports of all other misconduct, including fraud, should be directed to OmbudsmanPortal@wordhope.org.

If any person knows of or has a suspicion about misconduct, dishonesty or fraud, the Chief Legal Officer (CLO) should be contacted. If the alleged wrongdoing concerns the CLO, then The Chief Executive Officer should be contacted. If the alleged wrongdoing concerns the CEO, the Chair of the Board of Directors should be notified instead.

If the CEO, Chair, or other officers of World Hope International receives information about the misconduct, dishonesty or fraud, they shall inform the Chair of the Board of Directors, who shall determine the procedure for investigating all credible allegations.

Investigation: WHI’s Investigation Procedure will be used as follows unless allegations of either fraud or sexual exploitation or abuse are present. In those cases, separate procedures are followed pursuant to those policies.

When WHI receives a report of misconduct or suspected misconduct, an investigative team will be formed to decide whether to proceed to a full investigation or conduct a preliminary investigation to gather relevant data as to whether a full investigation should occur. At all times, the privacy and reputation of individuals will be respected. There will be no punishment or other retaliation for the reporting of conduct under this policy. If the person providing the information requests anonymity, this request will be respected to the extent that doing so does not impede any investigation.

Investigative Team: The investigative team will be made up of the CLO and the relevant Country Director, as well as anyone required by the Anti-Fraud or PSEA Policies. If any conflicts of interest warrant removal, that investigative team member will be removed.

Investigation Plan: The investigative team is responsible for constructing a written investigation plan which addresses the background material to be collected, the witnesses to be interviewed, the potential use of interpreters, ongoing witness and complainant needs for referral, confidentiality with regard to the identity of the complainant, witnesses, and the subject, an evaluation of any conflicts of interest, a risk assessment for the investigation, and timeframes for each stage of the investigation to ensure that the investigation is completed at the earliest point possible without compromising the quality of the investigation.

Gather Background Material: Investigators shall consider what forms of evidence may exist and how to access it, including work logs, rosters, photos, emails, correspondence, subjects of job descriptions of complainant and subject, description of project or program, contracts, leave requests.

Interview Witnesses: Investigators shall consider the order of witnesses to be interviewed, with the flexibility to the idea that one interview may reveal the identities of others who should be interviewed. Witnesses should be interviewed in the language of their choice, and the interview should be conducted in a safe and supportive environment with due care and awareness of guidance on interviewing particularly vulnerable people. The purpose of interviewing is to establish whether there has been a breach of the code of conduct, not to mediate between the subject and victim or debate the morality of the subject’s actions.

Reporting: The investigation team shall write an investigation report containing the following elements, and absent any conflict of interest, shall present the report to the decisionmaker. The CEO is the decisionmaker in most non-fraud investigations. In investigations containing allegations of fraud, the Finance Committee will be the decisionmaker. If the CEO is the subject of the investigation, the Board of Directors shall be the decisionmaker.

• Introduction This section shall include the name and title of investigators, the name of the subject(s), a statement of confidentiality, the date, the scope of the investigation (how many complainants, witnesses, subjects), location of investigation, nature of the complaint and what elements are to be proven, and any impediments faced by the investigative team.
• Executive Summary This section includes an overview of the investigation from the beginning to the report.
• Findings This section should analyze each complaint separately if more than one, and summarize the evidence for each complaint, including interviews and documentary evidence. The section should state the evidence impartially whether it supports or refutes the complaints.
• Conclusions & Recommendations This section should state the recommendations of the investigative team for each complaint. If substantiated by reasonable inference, the investigative team should recommend appropriate disciplinary action. If unsubstantiated by insufficient or unclear evidence, disciplinary actions should not be taken, though training or supervision may be recommended if there is an indication of poor practice or negligence that does not rise to the level of abuse or exploitation. If the investigative team finds evidence to suggest that the complaint was a malicious complaint, appropriate disciplinary action should be taken against the complainant. This section should also address any risks or concerns about retaliation against the complainant or witnesses with concrete plans to monitor or protect the complainant or witnesses. If the subject leaves the organization during the investigation, the team should continue any investigations of serious allegations and add a note to file. Finally, this section should contain an analysis of the adequacy of the organization’s response to the allegation and allegations in general.

Outcomes

After a disciplinary decision has been made, the investigation team should memorialize the decision. All individuals with documents pertaining to an investigation will ensure that such documents are preserved securely and have been provided to the lead internal investigator.

This information should also be included in an annual report including the number of reported incidents, actions taken, and how WHI is continually strengthening its safeguarding system.

Communication

Throughout this process, WHI will keep complainants, witnesses, and subjects informed on relevant aspects of the investigation process by determining a specific investigative team member to be responsible to share information as part of the investigation plan. The outcomes should be made available to the survivor and the subject at the conclusion of the investigation.

As outlined in the policies below, WHI is opposed to wrongdoing, terrorism, corruption, bribery, other financial impropriety, and illegal acts under U.S. law in any of its activities.

World Hope International (“WHI”) expects its employees to comply with the laws of the United States and other locally applicable laws and to maintain the highest ethical standards of business conduct. WHI is fully committed to complying with all anti-corruption laws wherever it conducts business. Among these anti-corruption laws are the U.S. Foreign Corrupt Practices Act (“FCPA”) and similar international laws regulating payments to foreign public officials, foreign candidates, and foreign political parties.

This Policy applies to all Employees and Agents of WHI worldwide. Failure to comply with this Policy may result in significant civil and criminal penalties for WHI and the individuals involved and are grounds for disciplinary action against such individuals, up to and including termination.

General Prohibition

WHI, its employee and agents are prohibited from giving, offering, or promising anything of value to a foreign government official with the intent to obtain or retain any business or any other advantage.

This prohibition should be interpreted broadly. The following concepts are essential to understanding the scope of the prohibition against bribing foreign government officials.

Giving – You are prohibited from directly making any improper payment, gift, offer, or promise, as well as from making any such payment, gift, offer, or promise indirectly. You may not instruct, authorize, or allow a third party (including any WHI consultant or agent) to make a prohibited payment on your behalf, and you may not make a payment to a third party knowing or having reason to know that it will likely be given improperly to a foreign government official. In other words, liability may be imposed not only when WHI actually knows or authorizes a payment, but also when it turns a “blind eye” to (or ignores) indicators suggesting that violations may occur.

Anything of Value – “Anything of value” includes not only cash and cash equivalents, but also gifts, entertainment, accommodations, charitable contributions, and anything else of tangible or intangible value.

Foreign Government Official – “Foreign Government Official” includes officers and employees, regardless of rank, of any non-U.S. governments (pursuant to the FCPA), national governments, and government-owned or -controlled companies and public international organizations, such as the United Nations and World Health Organization. “Foreign Government Official” also includes political parties, party officials, and candidates for political office.

Business or Advantage – Any improper payment in connection with WHI business is prohibited, including payments to obtain government business or to gain any other advantage, such as the reduction in taxes, tolerance of non-compliance with applicable rules, or other favors or preferential treatment.

Business Entertainment, Gifts, and Travel Expenses

Business entertainment, gifts, and payment for travel expenses for Foreign Government Officials are acceptable only following receipt of all pre-approvals, including the approval of WHI’s President.

The President will approve entertainment only if it has a valid business purpose and is reasonable in view of such business purpose. Entertainment will not be approved if it does not provide an opportunity to address business issues, is lavish, is requested too frequently for the particular Foreign Government Official or might otherwise prove embarrassing for WHI.

Gifts will be approved only if they are of token value, are legal and customary in the jurisdiction in which they are given and will be given openly to the Foreign Government Official.

Travel expenses, including food and lodging, will be approved only if they are directly related to the promotion or demonstration of WHI products or services or related to the execution of a contract. Expenses beyond what is reasonably necessary for the business purpose, including lavish accommodations or expenses for spouses and children, will not be approved.

In all cases that entertainment, gifts or travel expenses are approved, the expenses must be supported by receipts and accurately recorded in WHI books. To the extent possible, all expenses should be paid directly to the vendor of the services.

Consultants, Agents, Joint Venture Partners, and Other Intermediaries

When retaining a consultant or agent outside the United States that may interact with Foreign Government Officials or entering into a joint venture arrangement outside the United States, WHI employee must conduct FCPA due diligence commensurate with the level of FCPA risk posed by the prospective engagement. The purpose of such due diligence is to enable a WHI employee to conclude with reasonable assurance that the proposed intermediary understands and will fully abide by the FCPA and WHI’s Policy. WHI must have a written agreement with each of its intermediaries, and the agreement must specifically bind such party to comply with the FCPA as if it applied directly to such party. Should questions arise as to these matters, WHI employees should seek early direction from the President on the specific pre-engagement procedures that must be followed.

In evaluating potential intermediaries, and then during any subsequent relationship with such parties, WHI employees must be conscious of any “red flags” that may be present or arise. A “red flag” is a fact or circumstance that serves as a warning signal that an intermediary may act corruptly. A list of examples of red flags is attached to this Policy. It is the responsibility of the employee that observes a red flag to either resolve such a red flag by further investigation or to refer the matter to WHI’s President.

Record-Keeping

Employees must help to ensure that corporate books and records (which include virtually all forms of business documentation) accurately and fairly reflect, in reasonable detail, all transactions and dispositions of assets. No undisclosed or unrecorded fund or asset may be established or maintained for any purpose. No employee shall participate in falsifying any accounting or other business records, and all employees must respond fully and truthfully to any questions from WHI’s internal or independent auditors.

Reporting Violations

Violations of this Policy should be reported to the relevant individual as instructed in the Whistleblower Policy. There will be no retaliation or any adverse employment consequence for reporting information in good faith, per the Whistleblower Policy. However, making a report does not protect an employee from appropriate disciplinary action regarding his/her own conduct that may violate this policy.

FCPA Red Flags

During the due diligence process and during the course of a relationship with consultants or agents (collectively “intermediaries”) that represent WHI outside the United States (pursuant to the FCPA) and that interact with government officials on WHI’s behalf, special attention should be given to so-called “red flags.” A red flag is a fact or circumstance that serves as a warning signal that an intermediary may act corruptly, in violation of the U.S. Foreign Corrupt Practices Act (“FCPA”) or other applicable laws.

The existence of one or even more red flags does not necessarily preclude the retention or continued engagement of the intermediary, but additional due diligence or inquiry will be required to resolve all issues the red flags raised. Failure to resolve a red flag by either determining that it does not indicate potential past or future corruption or by dismissing the intermediary may lead to WHI being held liable for any improper acts of the intermediary.

Reputation

• The country has a reputation for corruption (see the Transparency International Corruption Perceptions Index, available at http://www.transparency.org/policy_research/ surveys_indices/cpi)
• The intermediary has a reputation for unethical conduct
• The intermediary has been terminated by other companies for improper conduct
• The intermediary has been subject to civil or criminal enforcement actions

Ties to Government

• The intermediary has family or business ties to government officials
• The intermediary makes large or frequent political contributions
• The intermediary was recommended by a government official, who is a potential customer or regulator

Capabilities

• The intermediary is not expected to perform substantial work
• The intermediary lacks the staff or facilities to perform the required work
• The intermediary lacks relevant industry or technical experience or has not been in business for very long
• The intermediary has poor financial stability or credit

Compensation

• The intermediary requests a commission or other payment significantly above the market rate or requests a substantial up-front payment
• The intermediary requests that payment be made in cash or in checks payable to cash or bearer
• The intermediary requests that payment be made through a third party or in a third country
• The intermediary requests an invoice to reflect a higher amount than the actual price of the goods supplied
• The intermediary refuses to properly document expenses

Questionable Circumstances

• The intermediary requests anonymity or that the relationship remains a secret
• The intermediary does not cooperate with the due diligence investigation or refuses to make representations and warranties
• The representation is illegal under local law
•  The intermediary makes suspicious statements such as needing money to “get the business” or “make the necessary arrangement

1. Introduction

World Hope International (WHI) is committed to the highest possible standards of openness, transparency and accountability in all its affairs. We wish to promote a culture of honesty and opposition to fraud in all its forms.

The organization operates in many countries and the size and nature of our operations puts us at risk of loss due to fraud. The purpose of this policy is to provide:

• A clear definition of what we mean by “fraud”
• A definitive statement to staff forbidding fraudulent activity in all its forms
• A summary to staff of their responsibilities for identifying exposures to fraudulent activities, for establishing controls and procedures for preventing such fraudulent activity and/or detecting such fraudulent activity when it occurs.
• Guidance to employees as to action which should be taken where they suspect any fraudulent activity.
• Clear guidance as to responsibilities for conducting investigations into fraud-related activities.
• Protection to employees in circumstances where they may be at risk of victimization as a consequence of reporting, or being a witness to, fraudulent activities. This also includes any ‘whistle-blowers’.
• This document is intended to provide guidance and should be read in conjunction with the relevant Human Resource Policies in relation to Investigation
• Overseas Finance Policies & Procedures in relation to Reporting Fraud/Theft and Negligence.

 This document will be reviewed periodically in order to determine whether it remains useful, relevant and effective.

2. Definitions

WHI defines fraud as: “The theft or misuse of WHI’s funds or other resources, by an employee or a third party, which may or may not also involve misstatement of financial documents or records to conceal the theft or misuse.”

For example, fraud includes but is not limited to the following:

• Theft of funds or any other WHI property
• Falsification of costs or expenses
• Forgery or alteration of documents
• Destruction or removal of records
• Inappropriate personal use of WHI’s assets
• Employees seeking or accepting cash, gifts or other benefits from third parties in exchange for preferment of the third parties in their dealings with WHI
• Blackmail or extortion
• Offering, promising or giving of a bribe and requesting, agreeing to receive or accepting a bribe for any reason
• Paying of excessive prices or fees to third parties with the aim of personal gain.

3. WHI Policy

Fraud in all its forms is wrong and is unacceptable to WHI. This is because where fraud occurs:

• It is not just a loss to WHI, but ultimately to our beneficiaries, people living in extreme poverty and the most vulnerable of the world’s citizens
• It may have a major impact on our reputation, on donor confidence and therefore again on our beneficiaries.

WHI’s objective is that fraud is eliminated from its activities. Any indications of fraud will be rigorously investigated and dealt with in a firm and controlled way.

4. Responsibilities of Employees

Managers

It is the responsibility of managers to be familiar with the types of fraud that might occur in their area, to be alert for any indication of fraud or improper activity and to maintain controls to avoid such occurrences.

Managers are required to ensure that all staff under their control be given a copy of this policy in a language they can understand and acknowledge its receipt.

Managers should also ensure that staff be encouraged to report suspected issues of fraud.

All Staff

It is the responsibility of all employees, interns, and volunteers to carry out their work in such a way as to prevent fraud from occurring in the workplace. Employees must also be alert for occurrences of fraud, be aware that unusual transactions or behaviors could be indications of fraud and report potential cases of fraud as outlined below.

5. Reporting Suspected Fraud

Employees are required to report issues of suspected fraud. Employees should report their suspicions as outlined in the Whistleblower Policy.

Employees who suspect fraud should not do any of the following:

• Contact the suspected individual(s) directly in an effort to determine facts, demand explanations or restitution.
• Discuss the issue with anyone within WHI other than the people listed above.
• Discuss the issue with anyone outside of WHI, except as required by law.

 The purpose of this prompt notification is to ensure transparency in dealing with the issues and to allow the sharing of experience of similar situations that may already have arisen elsewhere.

6. Investigation Guidelines

6.1 Investigation Team

Upon receiving a complaint, an Investigation Team should include the CFO, the CLO, and the Country Director if applicable. This team, led by the CFO, shall create an Investigation Plan, setting the scope of the investigation and listing potential witnesses and materials to be interviewed and gathered, respectively. This plan shall be presented to the Finance Committee for approval by a simple majority before the investigation commences.

When conducting their investigation, investigators must be careful to protect the identity and existence of documents or of a whistleblower.

6.2 Investigation

The purpose of the investigation is to establish the facts. All work of the investigation team should be documented, including transcripts of interviews conducted. The investigation should be held in a timely manner and the CEO should be kept informed of any major developments.

In order to ensure confidentiality, as per the Whistleblower’s Protection Policy guidelines as listed in the Employee Handbook; ‘A confidentiality clause is part of the interview notes sign-off statement, and breaches of confidentiality may result in disciplinary action for employees of WHI’. To maintain confidentiality, disclosure of details of the allegation being investigated should be appropriate to the situation and to the person being interviewed, while not misleading the witness in any way.

Where external expert advice is required, for example, the opinion of a lawyer, this advice should be summarized in an appendix to the investigation report.

6.3 Investigation Report

At the conclusion of the investigation, the team, led by the CFO, will write an Investigation Report to be submitted to the CEO, who will submit to the Finance Committee, containing the following sections:

• Introduction This section shall include the name and title of investigators, the name of the subject(s), a statement of confidentiality, the date, the scope of the investigation (how many complainants, witnesses, subjects), location of investigation, nature of the complaint and what elements are to be proven, and any impediments faced by the investigative team.
• Executive Summary This section includes an overview of the investigation from the beginning to the report.
• Findings This section should analyze each complaint separately if more than one, and summarize the evidence for each complaint, including interviews and documentary evidence. The section should state the evidence impartially whether it supports or refutes the complaints.
• Conclusions & Recommendations This section should state the recommendations of the investigative team for each complaint. If misconduct or the appearance of misconduct is substantiated by reasonable inference, the investigative team should recommend appropriate disciplinary action. If unsubstantiated by insufficient or unclear evidence, disciplinary actions should not be taken, though training or supervision may be recommended if there is an indication of poor practice or negligence. If the investigative team finds evidence to suggest that the complaint was a malicious complaint, appropriate disciplinary action should be taken against the complainant. This section should also address any risks or concerns about retaliation against the complainant or witnesses with concrete plans to monitor or protect the complainant or witnesses. If the subject leaves the organization during the investigation, the team should continue any investigations of serious allegations and add a note to file. Finally, this section should contain an analysis of the adequacy of the organization’s response to the allegation and allegations in general.

The Finance Committee will be the final decisionmaker on any action to be taken based on the Investigation Report, approving the recommendations by a simple majority.

The person(s) that initially reported the suspicions should be informed of the outcome of the investigation, but this should be done only once the report and proposed course of action has been finalized.

7. Safeguards for Employees

The safety of whistleblowers is a very important consideration for investigators and one that must not be taken lightly. The organization has an obligation to protect staff members who have come forward to report wrongdoing and will follow the Whistleblower Policy.

8. Actions Arising from Fraud Investigations

8.1 Disciplinary procedures

An employee, contractor, employee, affiliate whose conduct results in a substantiated allegation of fraud has committed gross misconduct and will be dealt with in accordance with the Employee Handbook on Disciplinary Action. Sufficiently substantiated allegations of fraud may result in dismissal.

In addition, where appropriate, WHI will refer significant fraud to the local law enforcement agencies with a view to initiating criminal prosecution. Consideration should be given to the local context and the consequences in terms of human rights of initiating criminal prosecution against the individuals involved. In every case, the final decision whether or not to prosecute should be taken by the Finance Committee.

8.2 Changes to systems of controls

The fraud investigation is likely to highlight where there has been a failure of supervision and/or a breakdown or absence of control; the course of action required to improve systems should be documented in the investigation report and implemented when this report is finalized.

8.3 Recovery of losses

Where WHI has suffered loss, full restitution will be sought of any benefit or advantage obtained and the recovery of costs will be sought from the individual(s) or organizations responsible for the loss.

If the individual or organization cannot or will not make good the loss, consideration will be given to taking civil legal action to recover losses. This is in addition to any criminal proceedings which may result.

9. Application to Partner Organizations and Consultants

Contracts with partner organizations and with consultants should make explicit reference to the existence of this policy and should require partner agencies and consultants to report any frauds that arise in their dealings with the organization or that in any way involve the resources of the organization. In addition, all contracts with partners and consultants should either include a copy of this policy as an attachment or clearly specify where a copy can be obtained.

10. Effective Date

The Anti-Fraud Policy will come into effect immediately upon approval by the Board of Directors.

11. Review of this Policy

In the interests of maintaining best practice, the contents of this Anti-Fraud Policy will be reviewed by the Audit Committee every three years.

Introduction

This policy is part of the PSEA framework, which clarifies definitions and responsibilities regarding prohibited behavior and the associated PSEA procedures outline the reporting and investigation processes. The benefits of an investigation policy include a transparent system, a consistent approach, protection of staff and beneficiaries, and a commitment to the minimization of SEA and protection of human rights.

Scope

This investigation policy applies to all World Hope International staff and volunteers, contractors, interns, partners and Board of Directors. Managers also have a responsibility to support and develop systems that maintain an environment where all parties involved with WHI understand how to behave, how to raise complaints and concerns, and what action will be taken

Duty to Report

The Code of Conduct as well as the InterAgency Standing Committee (IASC) Core Principles on PSEA state that it is the duty and the responsibility of all staff, associates, and partners to report any PSEA concerns. All staff, contractors, board members, interns and volunteers have mandated reporters and must report suspected allegations of abuse, exploitation, neglect, whether allegedly perpetrated by a staff of the agency or not. Suspected abuse happening with program partners or in the community must be reported to appropriate authorities. All staff are mandated to report – being aware of a situation and not reporting is cause for termination. Reporting should happen by phone or email as soon as possible – and no later than 24 hours – even if there is incomplete information. Staff may report anonymously to SAFE@wordhope.org or to +1.703.923.9414 and expect a confidential response from HQ.

Reviewing Allegations

Confidentiality WHI will protect the confidentiality of sexual exploitation and abuse allegations to the greatest extent possible in order to protect the integrity of the investigation and prevent embarrassment, further discrimination or harassment, or retaliation. WHI cannot guarantee, however, complete confidentiality, because the organization cannot conduct an effective investigation without revealing certain information to the alleged perpetrator and potential witnesses. WHI will share information about allegations of sexual exploitation, abuse and harassment only with those who need to know about it. Records relating to sexual exploitation, abuse and harassment complaints will also be kept confidential on the same basis.

Receiving a Complaint WHI’s Chief Legal Officer (CLO) may receive complaints directly or be referred by other staff. Once the complaint is received, the CLO, in consultation with the Director of Anti-Trafficking and Gender-Based Violence (DATGBV), will consider the appropriate steps to take, including a preliminary inquiry, per the Investigation Procedures.

Immediate Action Medical assistance and counseling must be made available to anyone who has been potentially harmed by any alleged sexual exploitation or sexual abuse. This will generally be through referral to the appropriate service provider. The physical and psychological well-being of any alleged victim must be a primary concern throughout the reporting and investigation process. The alleged perpetrator shall preliminarily be placed on leave on a case-by-case basis, and the Investigation Team must prioritize the safety of the complainant.

Preliminary Investigation Upon receiving a complaint, the CLO and DATGBV must decide whether to proceed to a full investigation or conduct a preliminary investigation to gather relevant data as to whether a full investigation should occur. This preliminary investigation can entail gathering personnel files of those involved, brief interviews with the complainant, or others. Investigators should presume that an investigation should take place unless the preliminary investigation finds that there are no grounds to proceed.

Investigative Team

The investigative team will be made up of the CLO and the DATGBV, absent any conflict of interest warranting an investigator’s removal. In order to ensure professional care and competence, investigators must be/possess the following:

• Experienced, reliable professional investigator with experience in dealing with highly sensitive cases
• Trained in conducting interviews, including with children and people who experienced trauma
• Demonstrated sensitivity and knowledge to cultural diversity and gender issues, including GBV experience if possible
• Fluent in relevant languages, or willing to vet and access interpreters, for interviews with personnel and other witnesses
• Proven communication and organizational skills

 A pool of investigators from internal and external sources should be established over time as the organization grows.

Investigation Process

Investigation Plan The investigative team is responsible for constructing a written investigation plan which addresses the background material to be collected, the witnesses to be interviewed, the potential use of interpreters, ongoing witness and complainant needs for referral, confidentiality with regard to the identity of the complainant, witnesses, and the subject, an evaluation of any conflicts of interest, a risk assessment for the investigation, and timeframes for each stage of the investigation to ensure that the investigation is completed at the earliest point possible without compromising the quality of the investigation.

Gather Background Material Investigators shall consider what forms of evidence may exist and how to access it, including work logs, rosters, photos, emails, correspondence, subjects of job descriptions of complainant and subject, description of project or program, contracts, leave requests.

Interview Witnesses Investigators shall consider the order of witnesses to be interviewed, with the flexibility to the idea that one interview may reveal the identities of others who should be interviewed. Witnesses should be interviewed in the language of their choice, and the interview should be conducted in a safe and supportive environment with due care and awareness of guidance on interviewing particularly vulnerable people. The purpose of interviewing is to establish whether there has been a breach of the rules on sexual exploitation and abuse or whether a crime has been committed, not to mediate between the subject and victim or debate the morality of the subject’s actions.

Reporting

The investigation team shall write an investigation report containing the following elements, and absent any conflict of interest, shall present the report to the CEO as decisionmaker.

• Introduction This section shall include the name and title of investigators, the name of the subject(s), a statement of confidentiality, the date, the scope of the investigation (how many complainants, witnesses, subjects), location of investigation, nature of the complaint and what elements are to be proven, and any impediments faced by the investigative team.
• Executive Summary This section includes an overview of the investigation from the beginning to the report.
• Findings This section should analyze each complaint separately if more than one, and summarize the evidence for each complaint, including interviews and documentary evidence. The section should state the evidence impartially whether it supports or refutes the complaints.
• Conclusions & Recommendations This section should state the recommendations of the investigative team for each complaint. If substantiated by reasonable inference, the investigative team should recommend appropriate disciplinary action. If unsubstantiated by insufficient or unclear evidence, disciplinary actions should not be taken, though training or supervision may be recommended if there is an indication of poor practice or negligence that does not rise to the level of abuse or exploitation. If the investigative team finds evidence to establish that the complaint was a malicious complaint, appropriate disciplinary action should be taken against the complainant. This section should also address any risks or concerns about retaliation against the survivor or witnesses with concrete plans to monitor or protect the survivor or witnesses. If the subject leaves the organization during the investigation, the team should continue any investigations of serious allegations and add a note to file. Finally, this section should contain an analysis of the adequacy of the organization’s response to the allegation and SEA allegations in general.

Outcomes

After a disciplinary decision has been made, the investigation team should memorialize the decision. All individuals with documents pertaining to an investigation will ensure that such documents are preserved securely and have been provided to the lead internal investigator.

This information should also be included in an annual report including the number of reported incidents, actions taken, and how WHI is continually strengthening its safeguarding system.

Communication

Throughout this process, WHI will keep survivors, witnesses, and subjects informed on relevant aspects of the investigation process by determining a specific investigative team member to be responsible to share information as part of the investigation plan. The outcomes should be made available to the survivor and the subject at the conclusion of the investigation.

Date of event:

Time of event:

Client/Program Recipient and/or Alleged Victim(s) involved:

Staff present when incident occurred:

Location where event occurred:

Nature of incident (please check all that apply): Sexual-related incident: ___ Physical acting-out incident:___

Staff Related Incident:____ Family-related incident:____ Other:____

Please use back of page, if you run out of space here.

Action taken:

Please use back of page, if you run out of space here.

Name of person making report:___________________________

Signature of person making report:___________________________ Date: __________

Please complete form and submit to supervisor or Country Director within 24 hours of event. If there is an allegation of abuse, the Country Director MUST be notified. Notify via phone if supervisor or Country Director is not on site.

Physical Abuse: The actual or potential physical harm perpetrated against a child. Physically abusive behavior includes, but is not limited to, shoving, hitting, slapping, shaking, throwing, punching, kicking, biting, burning, drowning, strangling and poisoning. Physical harm may also be caused when a parent or caretaker fabricates the symptoms of, or deliberately induces, illness in a child. Harmful cultural practices, including, but not limited to, female genital cutting is included in this category.

Neglect: The failure by a parent or caregiver to provide a child (where they are in a position to do so) with the conditions that are culturally accepted as being essential for their physical and emotional development and wellbeing.

Emotional Abuse: A parent or caregiver’s inappropriate verbal or symbolic acts toward a child, or a pattern of failure over time to provide a child with adequate non-physical nurture and emotional availability. Such acts have a high probability of damaging a child’s self-esteem or social competence.

Sexual Abuse: The use of a child for sexual gratification by an adult or significantly older child or adolescent. Sexually abusive behaviors can include fondling genitals; masturbation; oral sex; vaginal or anal penetration by a penis, finger or any other object; kissing; fondling; voyeurism; exhibitionism; and exposing the child to, or involving the child in, pornography or encouraging the child to behave sexually.

Spiritual Abuse: The actions by a spiritual leader or system that try to control, manipulate or dominate a child. This control is often in the form of fear. Spiritual abuse also includes misidentification of demonic or witchcraft influences.

Ill-treatment: Disciplining or correcting a child in an unreasonable and seriously inappropriate or improper manner; making excessive and/or degrading demands of a child; hostile use of force towards a child; and/or a pattern of hostile or unreasonable and seriously inappropriate degrading comments or behavior towards a child.

Exploitation (commercial and/or sexual): This may include one or more of the following:

• committing or coercing another person to commit abuse against a child
• possessing, controlling, producing, distributing, obtaining or transmitting child exploitation material
• committing or coercing another person to commit an act or acts of grooming or online grooming
• using a minor for profit, labor, sexual gratification, or some other personal or financial advantage
• treating a child in a certain way for the benefit of others and to the detriment of the child’s physical or mental health, education, moral or social-emotional development.

Child Labor: Involvement of children in any work that deprives them of their childhood, interferes with their ability to attend regular school, and that is mentally, physically, socially or morally dangerous and harmful.

Child Pornography or Child Abuse Images: In accordance with the Optional Protocol to the Convention on the Rights of the Child, ‘child pornography’ means ‘any representation, by whatever means, of a child engaged in real or simulated explicit sexual activities or any representation of the sexual parts of a child for primarily sexual purposes.’ The latest trend, online sexual exploitation of children, is the use of online video streaming to distribute child pornography, often real-time sexual acts.

Grooming: Generally, refers to behavior by an offender towards a child over time that makes it easier for an offender to procure a child for sexual activity. For example, an offender might build a relationship of trust with the child, and then seek to sexualize that relationship (for example by encouraging romantic feelings, or exposing the child to sexual concepts through pornography).

Online Grooming: The act of sending an electronic message to a child, with the intention of procuring the recipient to engage in or submit to sexual activity with another person, including, but not necessarily, the sender; or of sending an electronic message with indecent content to a recipient whom the sender believes to be a child.

Best Interests of the Child: This is the consideration for a child’s well-being when making decisions regarding them, recognizing their right to optimal physical and mental development.

Do No Harm: A principle in the humanitarian sector refers to an organization’s responsibility to minimize the harm they may be doing inadvertently as a result of program activities.

All WHI staff and volunteers are required to abide by this policy and sign an agreement to the Child Protection Code of Conduct (Annex I). This policy applies as well to partner organizations, consultants, contractors, and others with whom WHI enters a formal relationship to undertake to program (whether working directly with children or not).

We take seriously the responsibility to ensure that our staff and volunteers, our operations, and our programs do no harm to children and that any concerns about children’s safety within the programs or communities in which we work are reported appropriately.

In order to know how best to safeguard, we must understand the risks that children face. Every program/country office will assess risk bi-annually (Annex III) and develop a risk mitigation plan with the protection advisor for risks identified. We recognize that risk may vary according to a child’s status and we commit to programming that is tailored address varying vulnerabilities.

We work together to promote an environment that maintains awareness of risks for child abuse and prevents abuse, exploitation, and neglect. This would include, but is not limited to: limiting unsupervised interactions with children; prohibiting exposure to pornography; and complying with applicable laws, regulations, or customs regarding the photographing, filming, or other image-generating activities of children.

Wherein we undertake actions on behalf of children, their best interests will be considered in determining the action. We believe children have the right to have their voice heard, and wherever possible, we seek to hear from children regarding programming that impacts them.

All staff, contractors, board members, interns and volunteers are mandated reporters and must report suspected allegations of abuse, exploitation, neglect, whether allegedly perpetrated by staff of the agency or not. Suspected abuse happening with program partners or in the community must be reported to appropriate authorities.

WHI handles reports with confidentiality, takes seriously all allegations, supports the investigations of state authorities and to the point of probable termination and / or prosecution of any staff or volunteer found to have abused or exploited children.

WHI’s guidelines for managing concerns or allegations of child exploitation and abuse, and policy non-compliance are found in Annex IV.

All staff must engage in training on the Child Protection Policy and on child safeguarding yearly. This training is to be handled by the focal points, protection advisor or consultant experienced in child protection, with support from the protection advisor as necessary.

All visitors to the program must sign awareness and agreement to the Child Protection Policy.

The Country Director (or their designee) are assigned as protection focal points, responsible to monitor for protection issues within programs, receive reports made, and work with the investigation team as required to assure allegations are appropriately responded to.

A synopsis of the policy and Code of Conduct must be posted in all offices and public spaces where WHI runs programming, with contact details as to whom to report concerns. Staff must explain to participants of every new activity the Code of Conduct and the means by which to report in case a participant wants to raise a concern about staff conduct.

In the consulting with communities around the design and evaluation of programs, children should be included to ensure their views on the possible impacts of a program are heard and their views on their own safety and protection need incorporating into the program.

During monitoring and evaluation processes, emerging child protection and general protection risks should be monitored and assessed as well.

Within the development of all programming, not only will child protection needs be considered, but gender and diversity will also be, to ensure dignity, access, participation, and safety for all.

Whenever in the field, staff and volunteers must be easily identifiable as working for WHI, wearing the WHI logo on their clothing or hat or on a name badge.

Within the design of programming, children should be consulted, to understand their perspectives on what will help to ensure safeguarding.

Within the implementation of programming, we encourage the involvement of parents/caregivers and the community as much as possible through, for example, membership on committees or steering/planning groups as well as involvement in day-to-day activities.

A record is kept of the name and contact for a caregiver for every child participating in programming, along with their consent for the child to participate.

Within program implementation, we proactively discuss with children what makes them feel safe and unsafe and agree on ways for children to protect themselves, and make a report if they have a concern about themselves or their peers.

When taking photographs and footage, staff must ensure all participants provide age-appropriate informed consent and are aware that they can withdraw that consent at any time. (Annex II)

When conducting home visits, the following recommendations help to assure safety for both the staff and the children involved:

• always have two adults present
• pre-arrange the appointments with those being visited (this removes the risk of staff being able to visit without a prior formal appointment)
• do not continue with the appointment if children are alone in the house, however, in the case of child-headed households, put additional measures in place such as asking an extended family member or community leader to be present
• provide opportunity for feedback from children and young people during visits

HR conducts child-safe screening procedures with the hiring of all staff and volunteers. These include:

All staff/volunteers- prior to being hired- must have a criminal background check for all countries in which the individual has lived for 12 months or longer over the past ten years and for all countries of citizenship. In case the hiring process is urgent and the staff is an essential staff, the hiring may proceed while waiting for the police check.

Provision may be made for cases where criminal record checks have not been completed in time or where a country does not provide criminal record checks of adequate reliability. In these cases, a statutory declaration (Annex IV) or equivalent may be used instead of a criminal record check.

All employees/staff must also undergo reference checks, in which their integrity and appropriateness with children will be reviewed.

WHI reserves the right not to engage any individual in an activity that the agency believes to pose an unacceptable risk to children’s safety or wellbeing. If the criminal background check does not reveal crimes against children but reveals any other activity which may pose a risk to children or the staff and community served, WHI reserves the right to not engage that person in employment.

All contracts or HR policies will layout a provision that the staff may be suspended or transferred to other duties if there are allegations of child abuse/exploitation made, and in the event, the investigation of the allegations come back with any determination of abuse/exploitation or likelihood of, termination and reports made to the police may result.

Guidelines for collecting and using children’s images for work-related purposes:

• Obtain informed consent from the child and parent or guardian of the child before photographing or filming a child. An explanation of how the photograph or film will be used must be provided.
• Take care to ensure local traditions or restrictions for reproducing personal images are adhered to before photographing or filming a child.
• Ensure photographs, films, videos and DVDs present children in a dignified and respectful manner and not in a vulnerable or submissive manner. Children should be adequately clothed and not in poses that could be seen as sexually suggestive.
• Ensure images are honest representations of the context and the facts.
• Ensure file labels, metadata or text descriptions do not reveal identifying information about a child when sending images electronically or publishing images in any form.
• Images of children must not show them in states of undress or in inappropriate poses.
• Details attached to images and included in stories must not allow that child to be traced to his or her home or community.
• Distinctive buildings, street signs or landmarks should not be included in an image if they identify where a child lives or works.
• Geotagging of images should be disabled when taking photographs.
• Ensure the photographer/journalist/translator you have employed has been properly vetted and signed the Code of Conduct and Child Protection Policy.

Protection from Sexual Abuse, Exploitation and Sexual Harassment and Child Protection Risk Framework (*see also, PSEA and Sexual Harassment Code of Conduct)

Step 1: Risk Assessment
Activity Risks
Potential Considerations

Personnel deployed:

• away from their usual location/country of residence
• to remote/rural location/s
• to a humanitarian or emergency setting
• who are unaccompanied

Interaction with individuals who:

• are children
• are young adults
• have a disability
• are of an ethnic, indigenous, religious or sexual minority
• are experiencing poverty
• are prostituted people
• are impacted by disasters, conflicts or crises
• are displaced, refugees, migrants or asylum seekers
• are part of female-headed households
• are victims/survivors of trafficking and/or other forms of sexual and gender-based violence
• are in contact with the law
• are accessing residential/shelter services

Circumstances where staff have access to sensitive/confidential personal information

For example:

• health care providers
• counseling services
• medical personnel
• humanitarian aid coordinators

High-risk activities

For example:

• construction/infrastructure in developing country settings – these can have a higher risk of sexual abuse, exploitation and harassment gave the construction industry is male-dominated; and that construction in developing countries often involves the temporary movement of workers from other areas
•  humanitarian assistance

• disaster response

• security in conflict or post-conflict or disaster settings

Provision of goods and/or services that may create a power imbalance

For example:

• services for vulnerable groups of women (survivors of exploitation or gender-based violence)
• food distribution
• medical supplies
• emergency supplies following a disaster
• training
• residential/shelter services
• disability services
• justice facilities
• counseling and support services
• community consultation (data collection, surveying, training)
• health sector programs
• parenting and child protection programs

Staff or personnel who have an actual or perceived level of authority

For example:

• security workers
• police
• teachers
• aid workers
• humanitarian workers
• medical personnel
• NGO personnel
• security services

Organizational Risk Factors

Does the organization:

• have poor leadership on PSEA and sexual harassment?
• lack of awareness and implementation of child protection safeguarding measures?
• have a historic lack of diversity in the workplace?
• fail to consider PSEA and sexual harassment in core organizational policies and procedures?
• have geographically isolated workspaces, with employees working in small groups and having fewer opportunities to interact with their Head Office?
• have primarily young workforces?
• normalize “sexualized banter”?
• tolerate/encourage alcohol consumption?
• have a very hierarchical structure i.e. are there both high-ranking (Executives) and low-ranking employees in the organizational hierarchy; are there gendered power disparities (e.g. most of the low-ranking employees are female)?
• have poor reporting mechanisms and transparency around sexual exploitation, abuse and harassment incidents?

Step 2: Mitigating Measures/Minimum Standards in Place

PSEA and Sexual Harassment

1. Have a PSEA and Sexual Harassment policy or other documented policies and procedures in place and clearly communicate expectations of this Policy, and how this policy will be communicated not only internally, but detail how partners will be expected to comply.

2. Have reporting and investigation procedures in place.

3. Have risk management processes that include the risk of SEA and sexual harassment.

4. Effective PSEA and sexual harassment training in place.

5. Recruitment and screening processes and employment practices address and manage the risk of SEA and sexual harassment.

6. Prohibit transactional sex for all personnel, while engaged with WHI.

7. Prohibit fraternization ⁴ for all national and non-national personnel, while engaged within the delivery of programming.

Child Protection

1. Have a Child Protection Policy in place that includes a commitment to preventing a person from working with children if they pose an unacceptable risk, and details procedures to protect children in programming, as well explains how the policy will be communicated not only internally, but also with partners, visitors to sites, and vendors.

2. Have reporting and investigation procedures in place that are child-friendly.

3. Have risk management processes that include the risk of SEA and sexual harassment.

4. Effective Child Protection policy and procedures training in place.

5. Recruitment and screening processes and employment practices address and manage the risk of child abuse and exploitation.

6. The organization’s employment contracts contain provisions for suspension or transfer to other duties of any employee who is under investigation and provisions to dismiss any employee after an investigation.

7. Adherence to the policy is monitored on an ongoing basis by management.

⁴ Any relationship that involves, or appears to involve, partiality, preferential treatment or improper use of rank or position including but not limited to voluntary sexual behavior, including sexual behavior not amounting to intercourse, a close and emotional relationship involving public displays of affection or private intimacy and the public expression of intimate relations.

Handling Reported Cases

If a child makes a report, we will:

1. Listen carefully (without reacting strongly or expressing views on it. A reaction of shock could cause the child to stop sharing).

2. Let the child know they have done the right thing to report.

3. Let them know it is not their fault.

4. Tell them you are taking their concerns seriously.

5. Ask open questions (What happened?) rather than leading questions.

6. To the level that is appropriate for their maturity level, explain what you will do next.

7. Make the report to appropriate authorities

If you are aware of potential abuse, but the child is not reporting it, do not approach the child. Follow the reporting procedures below and a competent person will be identified to intervene.

Who reports to whom?

All staff are mandated to report – being aware of a situation and not reporting is cause for termination. Reporting should happen by phone or email as soon as possible – and no later than 24 hours – even if there is incomplete information. Staff may report anonymously to SAFE@wordhope.org or to +1.703.923.9414 and expect a confidential response from HQ.

Level 1: An allegation is made against a staff regardless of whether the child is in a WHI program or not – The President/CEO and Country Director must be informed immediately, an investigative team formed, and wherein sex abuse and/or trafficking is alleged, police informed.

Level 2: An allegation is made about the abuse of a child in the program, but WHI staff are not the accused. The Country Director must be informed immediately. The information is shared with relevant program partners and local authorities. HQ may or may not be informed.

Level 3: An allegation is made about a child in the community served, not in the program and the accused is NOT a WHI staff – The Country Director must ensure that relevant local authorities investigate. HQ need not be informed.

Response once a report is received

1. The Country Director ensures a response to assure the immediate safety and care of the victim.

2. If the allegation involves staff (employees, volunteers, etc) they are removed from activities engaging with children, or suspension for probable cause, while an investigation is underway.

3. An investigative committee is assigned by the Country Director (or HQ) to determine what happened and an appropriate response (both for the child, and for any staff involved).

4. If the allegation is about sexual abuse, whether by staff or not, a report must be made immediately to the local police. The investigation must be left solely to the police.

5. If the case does not involve staff, volunteers, consultants, the report should be passed on to the appropriate authorities in-country (often the Ministry of Social Welfare or Children’s Affairs).

6. The Country Director (or HQ) must ensure clear and confidential documentation is kept regarding the case and WHI’s response. An incident report form should be filled out and kept on file to record the response (Annex V).

7. Once the report is handled, an after-action should be conducted with the Country Director and relevant staff to determine how the response was handled and what, if anything, can be done to prevent what happened and improve incident management.

Form

Form

Adoption of a document retention policy sets guidelines and facilitates directors’ fulfillment of the duty of care, establishes transparency, and ensures compliance. World Hope International shall use its best efforts to retain records in accordance with this Record Retention and Document Destruction Policy. Directors, Officers, Employees, Volunteers, and Interns shall not knowingly destroy any document in violation of this policy or with the intent to obstruct or influence an investigation or administration of any matter within the jurisdiction of any department agency of the United States. Documents that have been retained beyond the period indicated in the chart below may be destroyed periodically, taking into consideration constraints on storage space and employee time. Notwithstanding the foregoing, if litigation is filed or government investigation is commenced against WHI, from the date that the action is known to WHI, all destruction of documents shall be suspended as promptly as is reasonable under the circumstances.

The corporate records of World Hope International, (hereafter “WHI”) are important assets. Corporate records include essentially all records you produce as an employee, whether paper or electronic. A record may be as obvious as a memorandum, an e-mail, a contract or a case study, or something not as obvious, such as a computerized desk calendar, an appointment book or an expense record.

The law requires WHI to maintain certain types of corporate records, usually for a specified period of time. [please see attached schedule] Failure to retain those records or those minimum periods could subject you and WHI to penalties and fines, cause the loss of rights, obstruct justice, spoil potential evidence in a lawsuit, place WHI in contempt of court, or seriously disadvantage WHI in litigation.

WHI expect all employees to fully comply with any published records retention or destruction policies and schedules, provided that all employees should note the following general exception to any stated destruction schedule: If you believe, or WHI informs you, that WHI records are relevant to litigation, or potential litigation (i.e., a dispute that could result in litigation), then you must preserve those records until the Legal Department determines the records are no longer needed. That exception supersedes any previously or subsequently established destruction schedule for those records. If you believe that exception may apply or have any question regarding the possible applicability of that exception, please contact the Legal Department.

From time to time WHI establishes retention or destruction policies or schedules for specific categories of records in order to ensure legal compliance, and also to accomplish other objectives, such as preserving intellectual property and cost management. Several categories of documents that bear special consideration are identified below. While minimum retention periods are suggested, the retention of the documents identified below and of documents not included in the identified categories should be determined primarily by the application of the general guidelines affecting document retention identified above, as well as any other pertinent factors.

Tax Records. Tax records include, but may not be limited to, documents concerning payroll, expenses, proof of deductions, business costs, accounting procedures, and other documents concerning WHI’s revenues. Tax records should be retained for at least six years from the date of filing the applicable return.

Employment Records/Personnel Records. State and federal statutes require WHI to keep certain recruitment, employment and personnel information. WHI should also keep personnel files that reflect performance reviews and any complaints brought against WHI or individual employees under applicable state and federal statutes. WHI should also keep all final memoranda and correspondence reflecting performance reviews and actions taken by or against personnel in the employee’s personnel file. Employment and personnel records should be retained for six years.

Board and Board Committee Materials. Meeting minutes should be retained in perpetuity in WHI’s minute book or on Boardable. A clean copy of all Board and Board Committee materials should be kept for no less than three years by WHI.

Press Releases/Public Filings. WHI should retain permanent copies of all press releases and publicly filed documents under the theory that WHI should have its own copy to test the accuracy of any document a member of the public can theoretically produce against WHI.

Legal Files. Legal counsel should be consulted to determine the retention period of particular documents, but legal documents should generally be maintained for a period of ten years.

Marketing and Sales Documents. WHI should keep final copies of marketing and sales documents for the same period of time it keeps other corporate files, generally three years. An exception to the three-year policy may be sales invoices, contracts, leases, licenses and other legal documentation. These documents should be kept for a least three years beyond the life of the agreement.

Development/Intellectual Property and Trade Secrets. Development documents are often subject to intellectual property protection in their final form (e.g., patents and copyrights). The documents detailing the development process are often also of value to WHI and are protected as a trade secret where WHI: derives independent economic value from the secrecy of the information; and WHI has taken affirmative steps to keep the information confidential. WHI should keep all documents designated as containing trade secret information for at least the life of the trade secret.

Contracts. Finally, execution copies of all contracts entered into by WHI should be retained. WHI should retain copies of the final contracts for at least three years beyond the life of the agreement, and longer in the case of publicly filed contracts.

Electronic Mail. E-mail that needs to be saved should be either: printed in hard copy and kept in the appropriate file; or downloaded to a computer file and kept electronically or on disk as a separate file.

The retention period depends upon the subject matter of the e-mail, as covered elsewhere in this policy. [please see attached schedule]

Failure to comply with this Document Retention Policy may result in punitive action against the employee, including suspension or termination.

This table is designed to provide guidance for document retention subject to the exceptions and provisions stated in the Documentation Retention Policy.

WHEREAS, the World Hope International (WHI) board of directors seeks to establish a policy on effectiveness assessment to help ensure that the organization has defined, measurable goals in place and objectives in place to evaluate the success and impact of its program(s) in fulfilling these goals and objectives,

IT IS THEREFORE RESOLVED THAT the Board of Directors adopts the following policy:

Annually, WHI will review its goals and objectives toward achieving its mission and will complete a performance and effectiveness assessment of its programs based on that review. This kind of review will be led by the Monitoring and Evaluation Specialist in order to determine how programs are impacting participants.

Annually, the CEO will submit a written report of this assessment to the Board containing the following:

• Description of WHI’s objectives
• Description of WHI activities undertaken to achieve goals and objectives
• Description of WHI’s outcomes relative to those objectives, including unintended or indirect outcomes
• Accounting of corresponding expenditures
• Discussion of material circumstances related to WHI’s effectiveness
• Assessment of implementation of results from the previous year’s report
• Recommendations for future actions WHI can take to increase the effectiveness

Monitoring is defined as the routine process of collecting and recording data and information in order to track progress toward expected results. Evaluation is defined as an assessment, conducted as systematically and impartially as possible, of a program to analyze the level of achievement of both expected and unexpected results by examining appropriate criteria such as relevance, effectiveness, efficiency, impact, and sustainability.

WHI’s objectives shall be specific, measurable, attainable, and related to the organizational mission. Programs shall be informed by relevant prior evidence, articulate a rationale for action, and explain the means by which program activities will produce the intended outcomes, and detail how monitoring and evaluation will be undertaken. WHI M&E will provide opportunities for community participation, partner and program participant feedback, and stakeholder involvement, as applicable. The resulting board report on organizational effectiveness will be made public, and the annual report shall justify M&E costs.

At the conclusion of this process, WHI will revise the goals and objectives for WHI, as needed, for the upcoming term and will suggest means of measuring them.

M&E Framework⁵

To be completed by each technical director per program area. [Sample BELOW]

⁵ The Logical Framework Template by tools4dev is licensed under a Creative Commons Attribution-ShareAlike 3.0 Unported License.

3.71 Introduction

Purpose

The purpose of this policy is to ensure that all goods and services purchased by World Hope International are obtained in a cost-effective manner and in compliance with applicable Federal regulations as well as all other public and/or private donor requirements and support transparent and competitive procurement practices resulting in maximum value and benefits to the organization/grantee/donor.

World Hope International is committed to promoting full and open competition. This requires that all personnel involved in the procurement process abide by the policies outlined within.

Scope

The provisions of this Procurement Policy shall apply to all purchases made by WHI employees, Contractors, or volunteers purchasing on behalf of World Hope International. All WHI personnel are responsible for ensuring that the procedures detailed in this policy are understood and implemented in accordance with all applicable Federal and other donor requirements.

Deviations from the provisions of this Procurement Policy must be approved in writing prior to the execution of a purchase by a member of WHI’s executive management team.

Purchasing Responsibility

WHI executive management has overall responsibility for this Procurement Policy, which includes reviewing the procedures contained within this policy at least annually to ensure compliance with all applicable Federal regulations and other donor requirements.

WHI executive and/or program management shall have the responsibility for distributing this Procurement Policy to all WHI personnel with a role and/or responsibility related to the purchasing process

Donor Authority Requirements

WHI is a non-profit organization that receives funding from a variety of sources, including U.S. Federal agencies as well as other public and private donors. Any purchase made by WHI will adhere to all applicable donor rules and regulations.

When procuring goods and/or services to be reflected as direct costs under U.S. Federal awards, WHI will abide by all applicable U.S. Government, including the Office of Management and Budget (OMB) Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.

When procuring goods and/or services to be recovered under other public or private donors, WHI will abide by the terms and conditions stipulated by each individual donor.

The appropriate certifications and assurances, or other terms and conditions required by a donor organization, including U.S. Federal agencies as well any other public or private donor, will be flowed down as required to all lower-tier organizations (e.g. sub-recipients, contractors, vendors).

WHI strives to ensure full and open competition, guarantee the objective performance of contracts and grants, and eliminate the possibility for unfair competitive advantages. Proposal and vendor selection shall be based on responsiveness to solicitations, price, quality, deadlines of delivery, accountability and fulfillment of the service, and other relevant factors.

Ethical Standards

It is the policy of World Hope International to procure only those items which are required to perform the mission and/or fill a bona fide need. Procurements will be made with complete impartiality based strictly on the merits of supplier proposals and applicable related considerations such as delivery, quantity, etc.

Business will be conducted ethically in a manner above reproach and with total impartiality and preferential treatment for none.

Organization employees will not solicit or accept, directly or indirectly, any gift, favor, entertainment, loan or anything of monetary value, from anyone maintaining a business connection with World Hope International.

All staff involved in the procurement process will avoid any action or circumstances–such as a gratuity (a payment or gift to obtain favorable treatment or influence an award), family relationship, or financial interest–that might conflict with the proper performance of their duties or compromise the organization’s acquisition process and will assure that their conduct at all times is in a manner that maintains trust and confidence in the integrity of the procurement process.

3.72 Roles and Responsibilities

The following roles support WHI’s purchasing requirements. Each has a distinctive role and/or authority to make a purchase on behalf of WHI. At present, resources comprise:

• Requestor – All procurement requests from staff should be pre-approved by their line manager in accordance with a specific Level of Authority established by the CFO. For procurements with an estimated value of $2,000, the Purchase Requisition Form must be completed (as described in the subsequent actions of this policy). This level may be further reduced in a specified context by the CFO.
• Technical Director – The relevant Technical Director is responsible for ensuring goods and services of a technical nature are procured in accordance with this policy, with appropriate technical standards in selection, and procurement delivery procedures. as well as, any additional agreed-upon donor terms and conditions (as described in the subsequent sections of this policy). Technical Directors may be programmatic, such as WASH, or a support function, such as IT.
• Country Director – The Country Director is responsible for ensuring competent, rigorous and timely capacity to procure within the financial policies as well as compliance with the source and nationality rules for the particular grants under implementation. The Country Director shares accountability, with the relevant Finance Director, in maintaining adequate banking and cash controls in procurement as well as compliance with specific donor regulation. Where a Country Director is not present, the appropriate Program Manager and COO share this responsibility.
• Financial Director – The senior finance position is responsible for transparent and enabling procurement procedures, appropriate cash controls, and clear financial reporting on the procurement process.
• Chief Financial Officer – Recommends Level of Authority for the COO, and with the COO, for specific programs and countries. Levels of Authority are reviewed at least annually by the CFO and CEO.
• Procurement Committee – Led and selected by WHI Finance to manage the Prequalified Purchases exercise
• Chief Legal Officer – Provides terms guidance where required in the Level of Authority, standard terms and conditions for procurement agreements, and risk assessments on major transactions.

3.73 Methods for Procurement

Prequalified Purchases

A Pre-qualification listing is a supplier list that is approved by the Procurement Committee, led by WHI Finance and inclusive of WHI Programs. This process starts begins at each fiscal year. In the initial meeting, the committee agrees on the services and products, which qualify for the pre-qualification process. The products and services classified under the pre-qualification listing are those routinely used to achieve program goals and objectives. The procurement committee agrees and designs the procedures for bid solicitation.

Solicitation documents should be submitted to only vendor companies that supply products and services agreed to by the procurement committee. Examples of routine services are hotel and airline bookings, office cleaning services, photocopying and printing services, office utilities, travel and taxi hire, conference facilities, and translation services. The products may include office supplies, stationery, and cleaning supplies. All potential bidders should receive solicitation requests to ensure equal treatment and fairness.

If potential bidders’ request for additional information, feedback should be made available in a written letter or email communication without delay. All potential bidders should be given information simultaneously to ensure equal and fair treatment. Prompt responses will mitigate against delays, which could jeopardize the submission of bids. Again, under exceptional circumstances, an extension may be granted, and all potential bidders should be informed.

Finance should set a date when all the bids will be opened and reviewed by the Procurement Committee. The committee may use the selection criteria of best price, product, quality, past performance) to select the best bidders. Additional screening of the selected bidders should be done to confirm that they are not debarred and suspended by the host government and any foreign institutions. These processes are important in mitigating against supplier risk and ensure that the supply chain is protected.

All the members present at the Procurement Committee should approve the minutes to support the selection process. After approving the minutes, the Controller or Country Director shall notify the selected bidders in a letter or email communication. The Controller or Country Director should establish a supplier list and circulate it in an email or internal memo to all the departments and staff involved in the procurement processes.

When utilizing the preferred vendor list for an in-budget expense, employees are empowered to make purchases without going through the entirety of this Procurement Policy. When utilizing the preferred vendor list for an out-of-budget expense, specific approval must be given by the Chief Executive Officer.

The supplier list should be reviewed after six months for any changes, which may occur in the approved companies.

Small Purchases (Micro-purchases)

Procurement by micro-purchase is the acquisition of supplies or services, where the aggregate dollar amount does not exceed $10,000. While micro-purchases are not required to be formally completed, WHI is responsible for executing the purchase and record the transaction. WHI may award procurements under $10,000 without soliciting formal competitive quotations from potential vendors. For these smaller procurements, however, WHI program management should still consider reasonableness to ensure that prices are prudent based on the type of items being procured. This type of purchase will require the completion of a check request form. See Appendix III for example Check Request Form.

Competitive Bids For procurements using Federal funds which exceed the Simplified Acquisition Threshold (currently $250,000), WHI shall prepare and publicize formal Requests for Proposals/ Qualifications (“RFP” / “RFQ”) and solicit proposals from an adequate number of qualified sources. At a minimum, WHI should solicit responses from at least two bidders.

An RFQ is a solicitation document used to communicate WHI’s requirements to prospective contractors. RFQs solicit information rather than binding offers. A quotation is not an offer and, consequently, cannot be accepted by WHI to form a binding contract. Therefore, issuance by WHI of an order in response to a supplier’s quotation does not establish a contract. The order is an offer by WHI to the supplier to buy certain supplies or services upon specified terms and conditions. A contract is established when the supplier accepts the offer. An RFP is a solicitation document used in negotiated procurements to communicate WHI requirements to prospective contractors and to solicit proposals from them. RFPs must contain the information necessary to enable prospective contractors to prepare proposals properly. RFPs contain essentially all the terms and conditions of the prospective contract. When specified in an RFP/RFQ, WHI reserves the right to award a contract on the basis of initial offers received, without any written or oral discussions with offerors.

WHI executive management shall establish appropriate evaluation criteria within the solicitation for the procurement at hand, and all proposals will be reviewed against the aforementioned criteria. Vendor selections shall be awarded to the responsible bidder whose proposal is most advantageous to the WHI program, with the price and other factors considered.

Sole Source

Procurement by the noncompetitive proposal is procurement through solicitation of a proposal from only one source. WHI shall limit its use of sole-sourced procurements unless deemed absolutely necessary by WHI management or specifically requested by a donor. If a non-competitive proposal method is determined due to the single/sole source nature of a product/service or supplier, and the order exceeds $10,000, a written sourcing justification determination of price reasonableness is required. The sourcing justification is to be included within the procurement file record.

The following is a list of conditions and characteristics that serve as justification for utilizing sole source procurements.

 • The item is available only from a single source – Only one company (or individual) can provide sought after the item(s)/service(s). This condition is usually based on the fact that a company has proprietary rights in the product/service being sought, or it has a unique product or service, which alone will satisfy the client’s minimum needs. However, a single source does not mean desirable or nice-to-have. It means the only one. This must be supported by facts as well as the absolute need for that item/service.
• Compatibility and/or Interchangeability – Only one company can provide an item which is compatible and/or interchangeable with existing requirements. However, the absolute need for compatibility must be established, and the justification must include an explanation of how it was determined that no other product/service is compatible and/or interchangeable.
• Unusual or Compelling Urgency – Only one company can meet the required delivery or performance schedule. The justification must show the validity of the schedule, the consequences or impact of not meeting it, and that WHI could not have avoided the urgency – that it was unforeseen. It must also show how he/she determined that the recommended source can meet the schedule. In other words, it must be demonstrated that the acquisition from other than the sole source would present unacceptable risks and/or delays to the WHI program; and that acquisition from the sole source would not present such risks.
• Approved by the Donor – WHI may limit competition to a single potential provider if so approved by WHI’s donor.
• Single Response – Instances, when WHI attempts to solicit bids by multiple potential vendors and only one vendor, responds, WHI may proceed based on the single response. In such cases, WHI must document its reasonableness determination in the procurement file.

 3.74 Procurement Process

 The procurement procedures are designed in such a way to support the following:

• Maximum value
• Transparency
• Compliance with donor requirements
• Proper internal controls
• Efficiency
• Sufficient budgetary management
• Adequate documentation to allow complete audit or review at a later date

 The procedures are broken into a number of steps in the process in which forms and approvals are used to ensure that the above goals are met. Segregation of tasks and appropriate approvals are built into the procedures.

Requisition for Goods/Services

All procurement requests from staff should be pre-approved by their line manager in line with a specific Level of Authority established by the CFO. For procurements with an estimated value of $1,500 the Purchase Requisition form must be completed (as described in the subsequent sections of this policy). This level may be further reduced in a specific context by the CFO.

A Purchase Requisition is a written request describing a program’s needed services and/or products and providing the rationale for the services and/or products. Before creating a purchase requisition, the requestor determines the scope of work, deliverables, and period of performance, any business requirements, and the budget. See Appendix I for example Purchase Requisition Form.

At a minimum, every requisition for goods and/or services must include the following information:

• Request Date
• Requestor Name
• Program Name & Country
• Requested Item(s)
• Description of Items to be Procured
• Method of Procurement
• Potential sources of supply (if available)
• Quantity
• Cost Estimate (if possible)
• If a particular brand name is requested, the specification must list the requirements or salient characteristics as well as appropriate nomenclature
• Delivery or performance schedules which are realistic and specific
• The proposed account code to be charged (project, department/country, and program code)
• Certification & Approval Section (to be approved utilizing Level of Authority Document)

 Once a Requisition Request and method of procurement is approved, the team moves forward with source selection.

Vendor Selection Criteria

It is WHI policy to only procure goods and services from responsible vendors. Prior to procuring goods/services in excess of $3,000, WHI purchasing personnel should make reasonable efforts to ensure that vendors have the ability to deliver goods and/or services required. WHI staff should consider the following criteria:

• Degree of fit with the specifications/requirements

• Price

• Reliability and quality

• Warranty

• Delivery data

• Quality of service if after-sale service is likely to be a significant consideration

• Past performance of the vendor.

• Payment terms

In addition, the following questions should be considered:

• Has the vendor done this type of work previously?
• Is the vendor described as an on-going financial concern?
• Is the vendor in good standing?
• For procurement under federal awards, is the organization an excluded party? An appropriate check must be maintained in the procurement file as detailed.

Price Analysis

Price analysis is performed to determine that the price is fair and reasonable, which justifies the source selection as a responsible contractor/vendor. Price analysis is a commonly used method to determine a fair and reasonable price because it is less complex and time-consuming than other methods. Price analysis is required for every purchasing action over $10,000. In order of preference, the accepted forms of price analysis are:

1. Adequate price competition. a. Adequate price competition exists when:

(a) at least two responsible offerors respond to the solicitation;
(b) the offerors are able to satisfy the requirement;
(c) the offerors respond independently; and
(d) each offeror submitted an offer which response to the expressed requirements of the solicitation

2. Prices set by law or regulation.

a. A copy of the rate schedules set by the applicable law or regulation will be obtained and included in the procurement file record for verification of the price(s) quoted.

3. Established catalog or market prices.

a. A copy or screenshot of the catalog/published price list, or, at least, the page on which the price(s) appear(s) must be obtained and included in the procurement file record for verification of the offered price(s).
b. Established market prices are based on the same principle as catalog prices except there is no catalog. A market price is a current price established in the usual or ordinary course of business between buyers and sellers free to bargain. Prices must be verified independent of the offeror and the file documented accordingly.

4. Comparison to previous competitive purchases.

a. Price analysis clearly demonstrates that the proposed price is reasonable in comparison with current or recent prices for the same or similar items, adjusted to reflect changes in market conditions, economic conditions, quantities, or terms and conditions under contracts that resulted from adequate price competition. MSI must ensure that the previous price was determined to be fair and reasonable.

5. Comparison to Previous Competitive Purchases

a. This determination must be based upon a physical review of the previous files. Changes in quantity, quality, delivery schedules and economic situation must be taken into consideration. Further, the Procurement Officer must ensure that the previous price was determined to be fair and reasonable.

Purchase Orders

Once Vendor selection is completed, the Requestor initiates the Purchase Order Process. A separate Purchase Order must be prepared for procurement items identified in the Level of Authority. A Purchase Order provides a clear document trail that demonstrates and supports all the procurement requirements relating to a clear description of what needs to be procured, transparency, adequate controls, and competitive process. See Appendix II for example Purchase Order Form.

The Purchase Order clearly describes all the pertinent expectations and details of the order. It serves to represent a formal commitment by the organization to enter into a contractual relationship with the vendor. Though in some cases the vendor may not require a formal purchase order, it serves as an important internal document which shows that an appropriate official within World Hope International has reviewed the entire procurement process and has agreed to place the order with this particular vendor. The Purchase Orders must utilize World Hope International relevant Standard Conditions of Purchase by purchase type (ie, Construction Services, Hardware Purchases, Consultant Agreements). If a vendor refuses to sign up to WHI’s Standard Conditions of Purchase, the Requestor must engage the Chief Legal Officer to negotiate terms and conditions acceptable to World Hope International.

The signatory authority for the Purchase Order is identified in the internal Level of Authority Document. All Purchase Orders must be accompanied by supporting documentation and maintained in the procurement file accordingly.

Records

A procurement file shall be maintained by WHI for each procurement action above $3,000. The documentation maintained depends on the procurement method selected, and may include the following:

• Completed and Approved Requisition Form
• Completed and Approved Purchase Order Form
• Vendor Quotes and Price Estimates
• Sole Source justification
• RFP/RFQ
• Responses to Solicitations
• Vendor Selection Rationale (including price/cost analysis)
• Excluded Parties List Check
• Inspection Acknowledgement and Approval of Goods/Services Received
• Vendor Invoices
• Invoice Payment Confirmation/Documentation
• Vendor Evaluations & Comments (if applicable)
• Appropriate Approvals (both Requisition and Signatory Authority)
• All Other Relevant Supporting Documentation.

Levels of Authority / Delegation of Authority

In Section 7.3 of the Bylaws, the Board of Directors empowers the Chief Executive Officer in the management of the organization. The Chief Executive Officer may further delegate these powers and duties, which the Chief Executive Officer has elected to do via the Internal Document titled, “Levels of Authority – September 2020.”

3.75 Documentation

Record Retention

All records associated with this policy shall be kept in compliance with the Record Retention policy.

3.76 Code of Conduct

Employees, Contractors, volunteers, and affiliates shall comply with WHI’s Conflict of Interest Policy.

No acceptance or solicitation of Gratuities (refer to bribery policy).

Any violation of the Code of Conduct may result in termination.

AF 2.1 Consolidated Audit. Branch Offices shall participate in the World Hope International annual audit. Branch offices may be required to have an independent audit in addition to participating in the consolidated audit.

AF 2.2 Audited Financial Statements. Audited financial statements shall be presented in the accrual method of accounting in accordance with Generally Accepted Accounting Principles for Not-For-Profit Organizations. Financial statements not initially prepared on an accrual basis at the Branch Offices must be converted to the accrual basis by December 31st of each year.

AF 2.3 Board Conference with External Auditors. The board of directors or a board committee will confer with members of the external audit field team, independent of staff, within a reasonable time following completion of the annual audit to review pertinent information including the audited financial statements, proposed audit entries and management letter comments, as well as the auditors’ impressions of the accounting function, internal controls and staff competency. The fact that such a conference took place shall be reflected in the minutes of the next board of directors meeting.

AF 2.4 Functional Time Studies. World Hope will have a mechanism in place for each fiscal year for the purpose of determining and implementing an appropriate functional allocation methodology for indirect expenses.

AF 3.1 Budget. Financial Statements and Registrations., Each Branch Office shall provide headquarters with copies of the following materials within the time frames specified for each fiscal year: (a) proof of renewal of country registration in electronic format within 10 days of receipt; b) electronic copies of the financial statements and audit findings from an external independent audit; (c) audit reports from grant agencies with findings, if any within 5 days of receiving the report;

AF 3.2 Monthly Reconciliations and Roll Forward Schedules. By the 15th of each month for the prior month, all Branch Offices shall complete all bank reconciliations and submit all roll forward schedules for all asset and liability accounts to HQ.

AF 4.1 Secure Storage. All Branches shall ensure that cash, checks, and other negotiable instruments kept in the Branch office are locked and secure at all times.

AF 4.2 Receipts for Cash Donations. All donations of currency to a branch shall be receipted immediately.

AF 4.3 Check Cashing. Branches shall not accept checks in exchange for cash.

AF 4.4 Deposit Requirements. Branches shall establish either (a) a reasonable dollar value threshold not to exceed $1,000 or (b) a timetable not to exceed five working days, for funds received (cash and checks) that may be maintained in the branch office at any given time. Receipts beyond this threshold must be deposited by the following business day.

AF 4.5 Counting Cash. All cash collected at branch office events shall be counted in the presence of at least two individuals, and then recounted upon delivery to the branch office.

AF 4.6 Petty Cash. All disbursements from petty cash must be supported by appropriate documentation (e.g., invoice, receipt, purchase order, etc.) Petty cash funds must be audited monthly by a member of staff that is not involved in maintaining the fund. Petty cash transactions will be capped at $100. The fund custodian will be responsible to safeguard the cash in a safe.

AF 4.7 Cash Advances. Branches and HQ shall prohibit cash advances to staff with the exception of program advances for materials and travel, as well as in cases of sudden disaster relief. Branches are encouraged to establish credit with vendors to eliminate the need for advances.

AF 5.1 Check Limits. HQ and branch offices shall define, in writing, the dollar value-limit for which any individual with signatory authority may issue a check. Any checks above this dollar limit shall require two signatures. The Threshold for HQ is $10,000 for physical checks. Electronic bill payments for HQ require the system approval of the CFO and only the CEO can release for payment regardless of amount.

AF 5.2 Blank Checks. Checks shall not under any circumstances be signed in a blank or incomplete form.

AF 5.3 Signature Authority. No office shall permit any individual with signatory authority to be the sole signer on a check made payable to himself or herself or a family member with the exception of a regular payroll check that is prepared by staff other than the signer.

AF 6.1 Authorization. HQ shall maintain only bank accounts that have been properly authorized by the board of directors. Other branches must have the CEO’s authorization in writing to open a new account. Also, when closing an account, the branch must receive a letter of closure from the Bank and forward by email to the CFO at HQ within 5 business days. All accounts must be owned by World Hope and held in World Hope’s name.

AF 6.2 Signatories. For the US Branch, the board of directors shall approve all signatories on cash accounts, convertible instruments, credit cards, and lines of credit. At least one branch board member shall have signatory authority on all cash accounts and convertible instruments held by the US Branch. Finance and Accounting staff are not permitted to be authorized signers. Each office must set a dollar threshold where there must be two signers.

AF 6.3 Reconciliations. Branch bank reconciliations shall be prepared electronically in the accounting software monthly and shall be reviewed in a timely manner by someone other than the preparer. The reconciliations will be released by the HQ Controller by the 15th of the following month.

AF 7.1 Ownership. Headquarters and all branches shall ensure that all investment instruments purchased by the branch are held solely in the name of the branch.

AF 7.2 Board Approval. Headquarters and all branches shall invest only in financial instruments approved by the chapter’s board of directors.

AF 7.3 Speculative Instruments. Headquarters and all branches shall not invest funds in speculative instruments (i.e., junk bonds, distressed securities, commodities, unregistered or restricted stocks, secured loans and other high-risk instruments) and shall convert donated speculative instruments within 30 days.

AF 8.1 Authority to Spend. Budget holders have the authorization to commit the organization up to their annual approved budget if cash flow permits, but must follow the Procurement Policy of the branch office where the expenditure will occur.

AF 8.2 Loans and Advances. Branches shall not make loans or staff advances of funds for personal use or to borrow against a future paycheck, or otherwise allow the personal use of any branch resources. Any and all loans for any purpose by Branches must have the CEO’s approval in writing. Loans made by HQ, with the exception of travel advances, must be approved by the Board of Directors. Loans to board members and officers must follow a due diligence process to establish reasonableness according to IRS guidelines.

AF 8.3 Review of CEO Expenses. A designated member(s) of the board of directors must review and approve in a timely manner all personal expense reports and credit card purchases of the CEO. The said process and the results thereof must be clearly documented by initialing and dating the documents.

AF 8.4 Review of Invoices. All invoices shall be reviewed for accuracy and approved by a branch-designated individual prior to payment by the branch ensuring that the procurement policy was followed, and evidence of such approval shall be noted on the invoice/check request form or by an electronic audit trail in the payment system. At HQ, the CFO must review and approve all invoices before payment either by initialing or by electronically releasing documents in the payment systems.

AF 8.5 Procurement. All Branches shall comply with the HQ procurement policy at a minimum. Branches may create addendums to the US policy with lower procurement thresholds. All employees must comply with the Procurement Policy for the branch that they are working in.

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AF 9.1 Daily Log. A complete and accurate daily log of all cash and checks received shall be maintained at HQ and in all branch offices.

AF 9.2 Fixed Asset Inventory. Headquarters and all branches shall maintain a complete and accurate fixed asset inventory and shall verify assets annually. This inventory shall be documented at the end of each year. When assets are verified, they must be reviewed for impairment considering whether events or changes in circumstances indicate that the carrying amount may not be recoverable. (See Summary of Significant Accounting Policies.) The HQ shall keep a master fixed asset inventory record for all branches. All tangible costs greater than $5,000 and with a useful life of more than one year must be capitalized and depreciated. Upon retirement or disposal of assets, costs and accumulated depreciation must be eliminated from respective accounts and resulting gain or loss is included in revenue or expenses.

AF 9.3 Internal Event Records. HQ and branch offices shall maintain itemized revenue and expense records for all internal events.

AF 9.4 Supporting Documentation. All disbursements in excess of $25 shall be supported by appropriate documentation from the vendor/payee (e.g., invoice, purchase order, contract, etc.) before payment is made. All supporting documentation must be maintained in vendor files for three years. (See the Records and Retention policy)

AF 9.5 Disbursements. Documents must be kept according to the Records and Retention Policy unless there are specific requirements of a granting agency to maintain records for a longer period or the local government requires longer retention.

AF 10.1 Organization

World Hope International, Inc. (World Hope) is a not-for-profit organization incorporated under the Indiana Non-Profit Corporation Act. World Hope’s mission is to alleviate suffering, injustice and poverty. World Hope pursues this mission by identifying and equipping field-based leadership and, with that leadership, implementing responses that are positive and sustainable. These responses address clean water & energy, global health, protection, and social ventures. The consolidated financial statements include the accounts of World Hope, but do not include the various foreign locations where World Hope may provide some support but over which it has no legal or direct control.

AF 10.2 Principles of Consolidation

Consolidated financial statements reflect the activities of World Hope and entities of which it has legal or direct control (collectively known as WHI). The financial statements of the organizations are consolidated because they are under common control and there is an economic interest. All material intercompany balances and transactions will be eliminated during consolidation.

AF 10.3 Basis of Accounting and Presentation

Consolidated financial statements of WHI shall use the accrual basis of accounting in accordance with accounting principles generally accepted in the United States of America (GAAP). Consequently, revenue is recognized when earned and expenses are recognized when the obligation is incurred.

AF 10.4 Cash and Cash Equivalents

WHI considers all highly liquid investments, other than amounts held as part of the short-term or long-term investment portfolios, with purchased maturities of three months or less to be cash equivalents. Cash and cash equivalents include amounts in checking accounts and money market funds. Restricted cash relates to WHI’s split-interest agreements.

AF 10.5 Pledges Receivable

Promises to give are recognized as contributions when the donor has made an unconditional promise to contribute funds to WHI in future periods. Promises to give are recorded at their net realizable value if expected to be collected in one year or at their present value if expected to be collected in more than one year. Conditional promises to give are recognized when conditions on which they depend are substantially met. WHI provides for probable uncollectible amounts through a provision for bad debt expense and an adjustment to an allowance based on its assessment of the current status of individual accounts. Balances that are still outstanding after management has used reasonable collection efforts are written off.

AF 10.6 Inventory

Inventory shall be stated at the lower of cost or market using the first-in, first-out method.

AF 10.7 Investments

Investments consist of money market funds that are recorded at fair value. Fair value is the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date.

AF 10.8 Fair Value of Financial Instrument

Financial Accounting Standards Board (FASB) Accounting Standards Codification (ASC) Topic 820, Fair Value Measurement, defines fair value, establishes a framework for measuring fair value in accordance with GAAP and expands disclosures about fair value measurement. The ASC emphasizes that fair value is a market-based measurement, not an entity-specific measurement, and therefore a fair value measurement should be determined based on the assumptions that market participants would use in pricing the asset or liability. As a basis for considering market participant assumptions in fair value measurement, the ASC established a fair value hierarchy based upon the transparency of the inputs to the valuation of an asset or liability. These inputs may be observable, whereby market participant assumptions are developed based on market data obtained from independent sources, or unobservable, whereby market participant assumptions are developed by the reporting entity based on the best information available in the circumstances.

The three levels of the fair value hierarchy are described as follows:

Level 1 – Based on unadjusted, quoted market prices in active markets for identical assets or liabilities accessible at the measurement date.

Level 2 – Based on inputs, other than quoted prices included in Level 1, that are observable for the asset or liability, either directly or indirectly, such as quoted prices for similar assets or liabilities in active markets.

Level 3 – Based on unobservable inputs for the asset or liability, including the reporting entity’s own assumptions in determining fair value.

AF 10.9 Property and Equipment

Office and other equipment, furniture and fixtures, vehicles and software are stated at cost and are depreciated or amortized on a straight-line basis over the estimated useful lives of the assets, ranging from three to five years, with no salvage value. Leasehold improvements are stated at cost and are amortized using the straight-line method over the remaining life of the lease. Buildings and improvements recorded at cost and depreciated over 27.5 years. Expenditures for minor repairs and maintenance costs are expensed when incurred. World Hope capitalizes all property and equipment purchased with a cost of $5,000 or more. Upon retirement or disposal of assets, costs and accumulated depreciation are eliminated from the respective accounts and any resulting gain or loss is included in revenue or expenses.

AF 10.10 Split-Interest Agreements

WHI’s split-interest agreements with donors consist of a charitable gift annuity and an annuity receivable. WHI initially records revenue from charitable gift annuity contributions in the year in which the agreement is executed. The amount of the revenue recognized in the first year is the difference between the amount of the assets received and the fair value of the future cash flows expected to be paid to the designated beneficiaries. In succeeding years, revenue is recorded for the reduction in the present value of future cash payments to the beneficiaries. The charitable gift annuity assets are included in restricted cash and cash equivalents and the liabilities are included in charitable gift annuities in the accompanying consolidated statement of financial position.

AF 10.11 Transactions in Foreign Currencies

WHI conducts many of its programs through field offices in foreign countries and, accordingly, transacts in the local currencies of those countries. These foreign currency transactions are translated into U.S. dollars using methods that make the rate used in the particular field office as close as possible to reality. Translations are made using a monthly rate based on rates for U.S. dollar-local currency conversions through the bank. The resulting gain or loss is recorded. The U.S. dollar is considered the functional and reporting currency of WHI. All currency exchange shall comply with applicable laws, have appropriate government approvals, and be clearly recorded.

AF 10.12 Classification of Net Assets

The net assets of WHI are reported as follows:

• Undesignated, unrestricted net assets represent the portion of expendable funds that are available for support of WHI’s operations.
• Temporarily restricted net assets represent amounts that are specifically restricted by donors or grantors for various purposes or periods of time.
• Permanently restricted net assets represent amounts that include donor-imposed restrictions that stipulate that the resources be maintained in perpetuity and that only the investment earnings on such amounts be used in the manner specified by the donor.

AF 10.13 Revenue Recognition

WHI recognizes all unconditional contributed support in the period in which the commitment to give is made. Grants and contributions are considered unrestricted and are available for operations unless specifically restricted by the donor. WHI reports gifts of cash and other assets as temporarily restricted if they are received with donor stipulations that limit the use of the donated assets. When a stipulated time restriction ends or a purpose restriction is satisfied, temporarily restricted net assets are reclassified to unrestricted net assets and reported in the accompanying consolidated statement of activities as net assets released from restrictions. The support that is restricted by the donor is reported as an increase in unrestricted net assets if the restriction expires in the reporting period in which the support is recognized.

WHI has cost-reimbursable grants and contracts with U.S. government agencies and other organizations. Revenue from these grants and contracts is recognized as costs are incurred on the basis of direct costs plus allowable indirect costs. Direct and indirect expenses incurred but not reimbursed under these grants and contracts are reported as part of grants and accounts receivable in the accompanying consolidated statement of financial position.

Program income is recognized when earned. Amounts that have not been collected as of year-end are included in grants and accounts receivable in the accompanying consolidated statement of financial position net of any anticipated losses due to uncollectible accounts.

AF 10.14 In-Kind Contributions

In-kind contributions received by WHI consist of clothing, hygiene products, equipment, drugs, and medical supplies and are recorded as in-kind contributions in the accompanying consolidated statement of activities at the estimated fair value at the time of receipt. Fair value is the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date. Upon donation to another organization, the materials are expensed at their estimated fair value at the time of the donation to WHI and are included in grants and assistance in the accompanying consolidated statement of functional expenses. WHI’s programs are also furthered by a substantial number of nonprofessional volunteers who have donated their services to WHI. The value of these services is not reflected in the accompanying consolidated financial statements because they do not meet the criteria for recognition under GAAP.

AF 10.15 Functional Expenses

The costs of providing the various programs and other activities will be summarized on a functional basis in the consolidated statement of functional expenses. Direct costs associated with specific programs are recorded as program expenses. Indirect costs are allocated to specific programs based on a cost-share allocation basis.

AF 10.16 Estimates

The preparation of the consolidated financial statements in conformity with GAAP requires management to make estimates and assumptions that affect certain reported amounts and disclosures. Accordingly, actual results could differ from those estimates.

WHI’s communications shall respect the dignity, values, history, religion, and culture of its staff and the people served by the programs. They shall neither minimize nor overstate the human and material needs of those whom it assists.

Overwhelmingly, vulnerable people, including children, do not get to control how they are depicted visually. This underscores the need for WHI to ensure that its use of images of staff and beneficiaries upholds their right to be treated with respect. With regard to photographing children, the best interest of the child must always be paramount.

Accurate Representation

Use of WHI’s images should not misrepresent the subject’s identity or circumstances. Examples of misrepresentation could include the use of photos of children from one country in an article about children in a nearby country, or a misleading description of the events within a photograph. Misrepresentations may be well-intentioned but violate the right of subjects to be accurately represented.

Coverage/Clothing:

Children and adults must not be photographed, filmed or otherwise pictorially represented in any state of undress. Genitalia and breasts must not be exposed, and WHI shall strictly review of photos of shirtless children to ensure the child’s image is not misused.

Dignity:

The image, video or story shall present the subject in a state or quality of being worthy of honor or respect. The subject should be portrayed as someone contributing to his or her own success, rather than a helpless victim. Only photos and videos that demonstrate respect for beneficiaries may be used.

Care:

Children in grave health or dangerous situations are not to be depicted without care (e.g. a baby alone and crying; under attack, severe acute malnutrition, fresh wounds or extreme physical trauma, etc.).

Releases:

Verbal or written releases are required. A release includes informing the subject in his or her preferred language of the intended use of the photo or film and obtaining informed consent. If the subject is under the age of 18, the legal guardian of the subject must also give informed consent. This consent is voluntary and can be revoked at any time. These releases shall accompany all photos in transfer to WHI.

Written releases are required for every individual photographed if:

• Private or personal information is revealed in the photograph or accompanying caption or story. In particular: health status, health behavior or activities, employment, personal history, status as a survivor or perpetrator of gender-based violence
• Individuals or small groups in clinical or educational settings
• Survivors of sexual abuse, exploitation or gender-based violence
• Persons engaged in politically sensitive or socially marginalized activities
• Persons in private settings i.e. in areas or undertaking activities which they could reasonably expect to be private
• Photographs of individuals in the context of culturally sensitive, politically sensitive, taboo or high-stigma issues
• If individuals may be put at risk of reprisal, violence or rejection in their communities as a result of exposing their identity
• Whenever the photograph or accompanying story clearly identifies and provides substantial information about a particular individual

WHI photographers are required to prepare approved consent forms ahead of time in the local language of the area they will be visiting, or make use of an interpreter if necessary, to orally translate the consent form into the local language. Visitors traveling with or to WHI programs are required to read and agree to this policy.

Guidelines for Interviews

Do no harm to any person. Avoid questions, attitudes or comments that are judgmental or insensitive to cultural values, that place someone in danger or expose him or her to humiliation, or that reactivate a person’s pain and grief from traumatic events. Always provide an accurate context for the subject’s story or image.

Ensure that the interviewee (and guardian, if the interviewee is under the age of 18), know they are talking with a reporter. Explain the purpose of the interview and its intended use.

Assess any potential risks, including retaliation, stigmatization, rejection or attacks by family or communities, prosecution, or misguided attempts to “rescue” the interviewee.

No payments or any other forms of compensation are to be provided to anyone in exchange for their interview, photo or consent.

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Interviewing Children

No staging: Do not ask children to tell a story or take an action that is not part of their own history. Do not ask children to promote products contributed by corporate supporters. Pay attention to where and how the child is interviewed. Limit the number of interviewers and photographers. Try to make certain that a child is comfortable and able to tell her/his story without outside pressure, including pressure from the interviewer. In film, video and radio interviews, consider what the choice of visual or audio background might imply about the child, her/his life and the story. Ensure that the child will not be endangered or adversely affected by showing her/his home, community or general whereabouts.

Do not give any information that could lead to a child being identified or traced. For example, if the child is from a small village, it might be easy for the child to be identified by another villager. Provide the region or district where the child lives, rather than naming the village. Do not name the school the child attends. Use first names only.

Always change the name and obscure the visual identity of any child who is identified as: A victim of sexual abuse or exploitation; A perpetrator of physical or sexual abuse; Charged or convicted of a crime; A current or former child combatant; HIV positive, living with AIDS or has died from AIDS, unless the child, a parent or a guardian gives fully informed consent; or Any child who does not wish to be named and identifiable, or whose parent/guardian does not wish the child to be named and identifiable.

Always change the name and consider obscuring the visual identity of a child identified as: An asylum seeker, refugee or internally displaced person; and/or orphaned, abandoned or separated from parents/guardians.

When changing a child’s name to protect their identity, ask them at the time of the interview what name they would prefer to be used. If the child does not state a preference for a certain name, work with someone from the community to select a name that is culturally appropriate given the child’s gender, ethnicity, religious background, etc. Whenever possible, choose a name that is short and easily pronounced or understood by an audience that may be unfamiliar with the child’s culture.

Confirm the accuracy of what the child has to say, either with other children or an adult, preferably with both. When in doubt about whether a child is at risk, report on the general situation for children rather than on an individual child, no matter how newsworthy the story. Do not invent a tragic future the child may face “if we don’t help.”

World Hope International created this Privacy Statement to demonstrate respect for your privacy preferences and to disclose our information collection and sharing practices. Regardless of whether you provide us with your personal information via our website or in another manner (e.g. telephone, regular mail or face-to-face), we strive to honor your privacy preferences.

By accessing and/or using this website, you have agreed to 1) abide by the practices described in this Privacy Statement, as may be amended from time to time, and 2) the transfer, processing, and maintenance of your personal and sensitive information in the United States of America.

The personal information we collect:

Depending on the type of communication or transaction, the personal information we collect may include but is not limited to, your name, postal address, zip code, telephone numbers, organization name, email address, credit card, bank information or billing information.

Where and when we collect personal information:

You will be asked to provide your personal information when making donations, requesting communications, applying for a job with World Hope International and/or in connection with other World Hope International business (whether it is via the website, e-mail, direct mail or telephone communications).

We do not knowingly collect information from children:

We do not knowingly collect or solicit personal information from anyone under the age of 18 or knowingly allow such persons to provide us with their personal information without parent or guardian consent. If you are under 18, do not send any information about yourself to us, including your name, address, telephone numbers, or e-mail address, unless you have your parent’s or guardian’s permission. In the event we learn that we collected personal information from anyone under the age of 18, and do not have a parent or guardian’s consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about anyone under the age of 18, please contact us at donorcare@wordhope.org or call us Monday through Friday, 8:30 AM – 5:00 PM Eastern Time at (703) 923-9414.

Information security:

World Hope International has layered security in our systems and only designated employees to have access to hard copies of your personal information. All online transactions are done on a secure server. This means that information entered on the transaction page is encrypted using SSL (Secure Socket Layer) before transmission. On secure pages, a “closed” lock symbol is displayed in the bottom part of your browser screen and the website address in the address bar at the top of the browser screen starts with an “https” instead of an “http”. Donation pages are verified by GeoTrust and transactions are processed using a PCI Compliant merchant account.

World Hope International is committed to donor privacy:

World Hope International respects your privacy and does not rent, sell or exchange its mailing lists.

Personal information will be shared internally at World Hope International to complete your donations or purchasing transactions, to contact you about our on-going work, discuss employment opportunities and ways that you can further support our efforts to help children in need. Your personal information will also be used to provide you access to the various sections of our website that have been personalized for your needs.

World Hope International will not rent, sell or exchange donor names and postal addresses with third parties. Except in the limited circumstances outlined below, World Hope International will never intentionally share your e-mail addresses, phone numbers or financial information.

Exceptions: World Hope International reserves the right to share your personal information in certain situations:

Credit Card Transactions, Electronic Fund Transfers, Payments by Check or Money Order and Online Transactions. World Hope International hires third parties to provide credit card, bank, payment and information processing services and order fulfillment services. If you choose to make an application for employment, make a donation online, by phone, through the mail or by other means or make a purchase from our online Gift Catalog we will share your personal information with our processing service providers. We make an effort to require all third-party service-providers to hold personal information in strict confidence. While we believe these other companies are upstanding and will treat your personal information responsibly, we do not own or control them and cannot guarantee your privacy.

Necessity. If we have reason to believe that there has been some inappropriate interference with or use of our website, communications, charitable services or personal or real property, or if we have reason to believe that one of the World Hope International website users, donors, employees or other related parties may have been injured or may have harmed some other party, we will disclose, without notice to you, personal information as we deem appropriate or if compelled by a legal or regulatory authority.

Merger, Acquisition or other Corporate Restructure. We also may transfer your personal information to a third party successor in interest if we are involved in an acquisition, merger or other transfer of control or sale of assets.

Requesting Communications. We share information provided by our website visitors with third parties that provide services on our behalf – for example, to send communications. These service providers are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or to comply with legal requirements.

You may always change your privacy preferences by contacting us:

If you would like to review your personal information or change your privacy preferences to ensure that your personal information is not shared outside of the organization, please e-mail us at donorservices@wordhope.org; call us Monday through Friday, 8:30 AM – 5:00 PM Eastern Time at (703) 923-9414

Cookies and Pixels:

A “cookie” is a small piece of data that is sent to your browser from World Hope International’s web server and is stored on your computer’s hard drive. Cookies are used to collect non-identifying information about the user, such as Web surfing behavior or user preferences for a specific website. World Hope International uses two different types of cookies: session-based and persistent cookies. Session-based cookies expire at the end of a browser session so once you close your browser the cookie simply terminates. Persistent cookies remain on your computer until you remove them. Persistent cookies are used to provide internal Website analytics. You can manually delete all cookies including persistent ones within your browser privacy. You can also set your browser to not accept cookies although this may prevent you from using some of the services offered by World Hope International’s website. In addition, World Hope International uses “pixels,” or transparent GIF files, to help manage online advertising. These pixels do not collect identifying information. The mechanisms identified here are used to improve the user experience on World Hope International’s website and are employed irrespective of “Do Not Track” requests.

Website Links:

In order to provide certain services and goods on our website, we contract with other companies and individuals. These additional services and goods may include “links” to other websites from our website. World Hope International’s privacy practices may not be applicable at any third-party sites. Anytime you leave the World Hope International website, we have no control regarding what information may be collected about you, nor do we control what third-parties might do with the information. For example, when you click on a merchant’s name at the World Hope International site, you will be connected with the third-party merchant’s website (even if the World Hope International name/logo is on the screen). This merchant website should have its own privacy statement applying to transactions at their website. It is important that you review any privacy policies on third-party sites carefully BEFORE you use any services or programs offered.

Changes to Privacy Practices:

From time to time, World Hope International may revise its privacy practices to address changing technology, security measures, and website functionality. We strive to provide you with timely notice of these changes. Please contact us if you have any questions about changes to our practices.

Contacting World Hope International about Privacy Preferences:

If you wish to change your privacy preferences to ensure that your personal information is not shared outside of the organization or have any questions please contact us.

1330 Braddock Place, Suite 301
Alexandria, VA 22314 USA
888-466-4673(HOPE)
703-594-8527
www.worldhope.org

For information regarding in-kind gift acceptance, see Section 4.0 Finances and Section 7.12 In-Kind Assistance.

Staff engaged in fundraising and public relations meet the ethical standards of the Association of Fundraising Professionals and Public Relations Society of America.

AFP Ethical Standards

The Association of Fundraising Professionals believes that ethical behavior fosters the development and growth of fundraising professionals and the fundraising profession and enhances philanthropy and volunteerism. AFP Members recognize their responsibility to ethically generate or support ethical generation of philanthropic support. Violation of the standards may subject the member to disciplinary sanctions as provided in the AFP Ethics Enforcement Procedures. AFP members, both individual and business, agree to abide (and ensure, to the best of their ability, that all members of their staff abide) by the AFP standards.

PUBLIC TRUST, TRANSPARENCY & CONFLICTS OF INTEREST

WHI Staff shall:

1. not engage in activities that harm the members’ organizations, clients or profession or knowingly bring the profession into disrepute.
2. not engage in activities that conflict with their fiduciary, ethical and legal obligations to their organizations, clients or profession.
3. effectively disclose all potential and actual conflicts of interest; such disclosure does not preclude or imply ethical impropriety.
4. not exploit any relationship with a donor, prospect, volunteer, client or employee for the benefit of the members or the members’ organizations.
5. comply with all applicable local, state, provincial and federal civil and criminal laws.
6. recognize their individual boundaries of professional competence.
7. present and supply products and/or services honestly and without misrepresentation.
8. establish the nature and purpose of any contractual relationship at the outset and be responsive and available to parties before, during and after any sale of materials and/or services.
9. never knowingly infringe the intellectual property rights of other parties.
10. protect the confidentiality of all privileged information relating to the provider/client relationships.
11. never disparage competitors untruthfully.

SOLICITATION & STEWARDSHIP OF PHILANTHROPIC FUNDS

WHI Staff shall:

12. ensure that all solicitation and communication materials are accurate and correctly reflect their organization’s mission and use of solicited funds.
13. ensure that donors receive informed, accurate and ethical advice about the value and tax implications of contributions.
14. ensure that contributions are used in accordance with donors’ intentions.
15. ensure proper stewardship of all revenue sources, including timely reports on the use and management of such funds.
16. obtain explicit consent by donors before altering the conditions of financial transactions.

TREATMENT OF CONFIDENTIAL & PROPRIETARY INFORMATION

WHI Staff shall:

17. not disclose privileged or confidential information to unauthorized parties.
18. adhere to the principle that all donor and prospect information created by, or on behalf of, an organization or a client is the property of that organization or client.
19. give donors and clients the opportunity to have their names removed from lists that are sold to, rented to or exchanged with other organizations.
20. when stating fundraising results, use accurate and consistent accounting methods that conform to the relevant guidelines adopted by the appropriate authority.

COMPENSATION, BONUSES & FINDER’S FEES

WHI Staff shall:

21. not accept compensation or enter into a contract that is based on a percentage of contributions; nor shall members accept finder’s fees or contingent fees.
22. be permitted to accept performance-based compensation, such as bonuses, only if such bonuses are in accord with prevailing practices within the members’ own organizations and are not based on a percentage of contributions.
23. neither offer nor accept payments or special considerations for the purpose of influencing the selection of products or services.
24. not pay finder’s fees, commissions or percentage compensation based on contributions.
25. meet the legal requirements for the disbursement of funds if they receive funds on behalf of a donor or client.

PRSA Code of Ethics.

PRSA CODE PROVISIONS OF CONDUCT

FREE FLOW OF INFORMATION

Core Principle Protecting and advancing the free flow of accurate and truthful information is essential to serving the public interest and contributing to informed decision making in a democratic society.

Intent:

• To maintain the integrity of relationships with the media, government officials, and the public.
• To aid informed decision-making.

Guidelines:

WHI shall:

• Preserve the integrity of the process of communication.
• Be honest and accurate in all communications.
• Act promptly to correct erroneous communications for which the practitioner is responsible.
• Preserve the free flow of unprejudiced information when giving or receiving gifts by ensuring that gifts are nominal, legal, and infrequent.

Examples of Improper Conduct Under this Provision:

• A member representing a ski manufacturer gives a pair of expensive racing skis to a sports magazine columnist, to influence the columnist to write favorable articles about the product.
• A member entertains a government official beyond legal limits and/or in violation of government reporting requirements.

COMPETITION

Core Principle Promoting healthy and fair competition among professionals preserves an ethical climate while fostering a robust business environment.

Intent:

• To promote respect and fair competition among public relations professionals.
• To serve the public interest by providing the widest choice of practitioner options.

Guidelines:

WHI shall:

• Follow ethical hiring practices designed to respect free and open competition without deliberately undermining a competitor.
• Preserve intellectual property rights in the marketplace.

 Examples of Improper Conduct Under This Provision:

• A member employed by a “client organization” shares helpful information with a counseling firm that is competing with others for the organization’s business.
• A member spreads malicious and unfounded rumors about a competitor in order to alienate the competitor’s clients and employees in a ploy to recruit people and businesses.

DISCLOSURE OF INFORMATION

Core Principle Open communication fosters informed decision making in a democratic society.

Intent:

To build trust with the public by revealing all information needed for responsible decision making.

Guidelines:

WHI shall:

• Be honest and accurate in all communications.
• Act promptly to correct erroneous communications for which the member is responsible.
• Investigate the truthfulness and accuracy of information released on behalf of those represented.
• Reveal the sponsors for causes and interests represented.
• Disclose financial interest (such as stock ownership) in a client’s organization.
• Avoid deceptive practices.

Examples of Improper Conduct Under this Provision:

• Front groups: A member implements “grassroots” campaigns or letter-writing campaigns to legislators on behalf of undisclosed interest groups.
• Lying by omission: A practitioner for a corporation knowingly fails to release financial information, giving a misleading impression of the corporation’s performance.
• A member discovers inaccurate information disseminated via a website or media kit and does not correct the information.
• A member deceives the public by employing people to pose as volunteers to speak at public hearings and participate in “grassroots” campaigns.

SAFEGUARDING CONFIDENCES

Core Principle Client trust requires appropriate protection of confidential and private information.

Intent:

To protect the privacy rights of clients, organizations, and individuals by safeguarding confidential information.

Guidelines:

• WHI shall: Safeguard the confidences and privacy rights of present, former, and prospective clients and employees.
• Protect privileged, confidential, or insider information gained from a client or organization.
• Immediately advise an appropriate authority if a member discovers that confidential information is being divulged by an employee of a client company or organization.

Examples of Improper Conduct Under This Provision:

• A member changes jobs take confidential information and use that information in the new position to the detriment of the former employer.
• A member intentionally leaks proprietary information to the detriment of some other party.

CONFLICTS OF INTEREST

Core Principle Avoiding real, potential or perceived conflicts of interest builds the trust of clients, employers, and the public.

Intent:

• To earn trust and mutual respect with clients or employers.
• To build trust with the public by avoiding or ending situations that put one’s personal or professional interests in conflict with society’s interests.

Guidelines:

WHI shall:

• Act in the best interests of the client or employer, even subordinating the member’s personal interests.
• Avoid actions and circumstances that may appear to compromise good business judgment or create a conflict between personal and professional interests.
• Disclose promptly any existing or potential conflict of interest to affected clients or organizations.
• Encourage clients and customers to determine if a conflict exists after notifying all affected parties.

Examples of Improper Conduct Under This Provision:

• The member fails to disclose that he or she has a strong financial interest in a client’s chief competitor.
• The member represents a “competitor company” or a “conflicting interest” without informing a prospective client.

ENHANCING THE PROFESSION

Core Principle Public relations professionals work constantly to strengthen the public’s trust in the profession.

Intent:

• To build respect and credibility with the public for the profession of public relations.
• To improve, adapt and expand professional practices.

Guidelines:

WHI shall:

• Acknowledge that there is an obligation to protect and enhance the profession.
• Keep informed and educated about practices in the profession to ensure ethical conduct.
• Actively pursue personal professional development.
• Decline representation of clients or organizations that urge or require actions contrary to this Code.
• Accurately define what public relations activities can accomplish.
• Counsel subordinates in proper ethical decision making.
• Require that subordinates adhere to the ethical requirements of the Code.
• Report practices that fail to comply with the Code, whether committed by PRSA members or not, to the appropriate authority.

Examples of Improper Conduct Under This Provision:

• A PRSA member declares publicly that a product the client sells is safe, without disclosing evidence to the contrary.
• A member initially assigns some questionable client work to a non-member practitioner to avoid the ethical obligation of PRSA membership.

Effective Date: November 14, 2022

World Hope International (hereinafter “We,” “Us,” “Our”) is offering a mobile messaging program (the “Program”), which you agree to use and participate in subject to these Mobile Messaging Terms and Conditions and Privacy Policy (the “Terms”).  By opting into or participating in any of our Programs, you accept and agree to these Terms, including, without limitation, your agreement to resolve any disputes with us through binding, individual-only arbitration, as detailed in the “Dispute Resolution” section below.  These Terms are limited to the Program and are not intended to modify other terms & conditions or privacy policy(ies) that may govern the relationship between you and Us in other contexts.

Modification of Terms:  We reserve the right to revise these Terms from time to time.  If we do revise these Terms, the revised terms will supersede prior revisions.  Unless we say otherwise, revisions will be effective upon the effective date indicated at the top of these Terms.  Any updates to these Terms shall be communicated to you by mobile message with a link to the updated Terms.  Your continued participation in the Program after receiving notice of the updated Terms constitutes your acceptance of any revisions.  If you do not agree to the revisions, you must opt out of the Program.

User Opt In: The Program allows users to receive mobile messages by affirmatively opting into the Program.  Regardless of the opt-in method you utilized to join the Program, you agree that these Terms apply to your participation in the Program.  By participating in the Program, you agree to receive autodialed or prerecorded marketing mobile messages at the phone number associated with your opt-in, and you understand that consent is not required to make any purchase from Us.  While you consent to receive messages sent using an autodialer, the foregoing shall not be interpreted to suggest or imply that any or all of Our mobile messages are sent using an automatic telephone dialing system (“ATDS” or “autodialer”).  Message and data rates may apply.

User Opt Out: If you do not wish to continue participating in the Program or no longer agree to these Terms, you agree to reply “STOP,” “QUIT,” “END,” “CANCEL,” “UNSUBSCRIBE,” or “STOP ALL” to any mobile message from Us in order to opt out of the Program.  You may receive an additional mobile message confirming your decision to opt out.  [Alternatively, you may opt out of the Program by calling +1 (703) 923-9414 or by sending an email to info@worldhhope.org.]  You understand and agree that the foregoing options are the only reasonable methods of opting out.  You also understand and agree that any other method of opting out, including, but not limited to, texting words other than those set forth above or verbally requesting one of our employees to remove you from our list is not a reasonable means of opting out.

T-Mobile and AT&T provide daily files for phone numbers that have deactivated from their network or been ported from one carrier to another. We proactively opt-out deactivated numbers from our subscription list.

Duty to Notify and Indemnify: If at any time you intend to stop using the mobile telephone number used to subscribe to the Program, including canceling your service plan or selling or transferring the phone number to another party, you agree that you will complete the User Opt Out process set forth above prior to ending your use of the mobile telephone number.  You understand and agree that your agreement to do so is a material part of these Terms.  You further agree that, if you discontinue the use of your mobile telephone number without notifying Us of such change, you agree that you will be responsible for all costs (including attorneys’ fees) and liabilities incurred by Us, or any party that assists in the delivery of the mobile messages, as a result of claims brought by the individual(s) who is later assigned that mobile telephone number.  This duty and agreement shall survive any cancellation or termination of your agreement to participate in any of our Programs.

YOU AGREE THAT YOU SHALL INDEMNIFY, DEFEND, AND HOLD US, OUR AGENTS, AND ANY THIRD-PARTY SERVICE PROVIDER WE USE TO SEND TEXT MESSAGES HARMLESS FROM ANY CLAIM OR LIABILITY RESULTING FROM YOUR FAILURE TO NOTIFY US OF A CHANGE IN THE INFORMATION YOU HAVE PROVIDED, INCLUDING, BUT NOT LIMITED TO, ANY CLAIM OR LIABILITY UNDER THE TELEPHONE CONSUMER PROTECTION ACT, 47 U.S.C. § 227, et seq., OR SIMILAR STATE AND FEDERAL LAWS, AND ANY REGULATIONS PROMULGATED THEREUNDER RESULTING FROM US ATTEMPTING TO CONTACT YOU AT THE MOBILE TELEPHONE NUMBER YOU PROVIDED.

Program Description: Without limiting the scope of the Program, users that opt into the Program can expect to receive messages concerning Our commercial activities and your relationship with Us, including, but not limited to, [messages concerning product advertisements and promotions of any kind, your account information, and your orders] from Us.

Cost and Frequency: Message and data rates may apply. The Program involves recurring mobile messages, and additional mobile messages may be sent periodically based on your interaction with Us.

Support Instructions: For support regarding the Program, text “HELP” to 65101 or email Us at info@worldhope.org.  Please note that the use of this email address is not an acceptable method of opting out of the program.  Opt outs must be submitted in accordance with the User Opt Out procedures set forth above.

MMS Disclosure: The Program will send SMS TMs (terminating messages) if your mobile device does not support MMS messaging.

Our Disclaimer of Warranty: The Program is offered on an “as-is” basis and may not be available in all areas at all times and may not continue to work in the event of product, software, coverage, or other changes made by your wireless carrier.  We will not be liable for any delays or failures in the receipt of any mobile messages connected with the Program.  Delivery of mobile messages is subject to effective transmission from your wireless service provider/network operator, and is outside of Our control.  T-Mobile is not liable for delayed or undelivered mobile messages.

Age Restriction: You may not use or engage with the Program if you are under thirteen (13) years of age.  If you use or engage with the Program and are between the ages of thirteen (13) and eighteen (18) years of age, you must have your parent’s or legal guardian’s permission to do so.  By using or engaging with the Platform, you acknowledge and agree that you are not under the age of thirteen (13), are between the ages of thirteen (13) and eighteen (18) and have your parent’s or legal guardian’s permission to use or engage with the Program, or are of adult age in your jurisdiction.  By using or engaging with the Program, you also acknowledge and agree that you are permitted by your jurisdiction’s applicable law to use and/or engage with the Program.

Truthful and Accurate Information:  When you complete forms online or otherwise provide Us information in connection with the Program, you agree to provide accurate, complete, and true information. You agree not to use a false or misleading name or a name that you are not authorized to use. If, in Our sole discretion, We believe that any such information is untrue, inaccurate, or incomplete, or you have opted into the Program for an ulterior purpose, We may refuse you access to the Program and pursue any appropriate legal remedies.

Our Warranty: We will not be liable for any delays or failures in the receipt of any mobile messages connected with this Program. Delivery of mobile messages is subject to effective transmission from your wireless service provider/network operator, and is outside of Our control.  T-Mobile is not liable for delayed or undelivered mobile messages.

Mobile Messaging Privacy Policy: We respect your privacy. This Mobile Messaging Privacy Policy describes any personal information that We collect or receive when you choose to participate in the Program, how We use or disclose your information, and your rights related to your personal information.  This Mobile Messaging Privacy Policy applies to all personal information collected, used, or shared by us when you opt-in to the Program and is strictly limited to the Program and has no effect on any other privacy policy(ies) that may govern the relationship between you and Us in other contexts.  Please contact Us if you have any questions about the information in this Privacy Policy.

Information We Collect and How We Use It: [The personal information We may collect, includes your name, phone number, email address and certain marketing preferences.  We may also collect data with respect to confirmation that a message has been delivered to you, confirmation that you have read a message, and related information. We may use the information for the following business purposes: (1) provide the Program and related customer service; (2) deliver information about Our products, services and promotions, (3) improve the Program and services, (4) prevent fraud and comply with law, and (5) protect the security of Our systems. We may combine the personal information We obtain through your participation in the Program with offline or other online personal information We retain about you. ]

When We Share Your Information: [WE DO NOT SELL, RENT, LOAN, TRADE, LEASE OR OTHERWISE TRANSFER FOR PROFIT ANY PHONE NUMBERS OR PERSONAL INFORMATION COLLECTED OR RECEIVED THROUGH THE PROGRAM TO ANY THIRD PARTY.] However, We may share your personal information with the third-party text messaging platform provider or other trusted service partners as may be necessary to send you messages under the Program and these Terms. We reserve the right at all times to disclose any information as necessary to satisfy any law, regulation or governmental request, to avoid liability, or to protect Our rights or property.

Contact Us: To exercise any of your rights related to your personal information, please contact us using one of the following methods:

• Call us at +1 (703) 923-9414;
• Visit us at https://worldhope.org;
• Send us an email at info@worldhope.org; or
• Write to us at 1330 Braddock Place, Suite 301 Alexandria, VA 22314.

California Residents.  Beginning January 1, 2020, if You are a California resident, as defined in Section 17014 of Title 18 of the California Code of Regulations, You have certain rights with regard to your personal information. This section describes those rights and explains how to exercise those rights.

Access to Information. You have the right to request that We disclose certain information to you about Our collection and use of your personal information over the past 12 months. Upon receipt of a verifiable request, we will provide you access to personal information We have collected about you or disclose to you the categories of personal information We have collected, the categories of sources from which We obtained that information, and how We have used or shared that information.

Right to Request Deletion. You also have the right to request that We delete any of your personal information that We collected from you and retained, subject to certain exceptions as allowable by law.  You understand that We may deny your deletion request as provided by law, including, but not limited to, retaining the information if it is necessary for Us to:

• Complete the transaction for which We collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of Our ongoing business relationship with you, or otherwise perform Our contract with you;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
• Debug products or identify and repair errors that impair existing intended functionality;
• Comply with a legal obligation, including, but not limited to, preserving evidence demonstrates our compliance with the Telephone Consumer Protection Act (“TCPA”) during the statute of limitations period applicable to the TCPA; and/or
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.  

To exercise any of your rights related to your personal information, please contact us using one of the methods indicated in the “Contact Us” section above.

Dispute Resolution: In the event that there is a dispute, claim, or controversy between you and Us, or between you and our third-party text messaging platform provider, or between you and any other third-party service provider acting on Our behalf to transmit the mobile messages related to the Program Description set forth above, arising out of or relating to federal or state statutory claims, common law claims, these Terms, or the breach, termination, enforcement, interpretation, or validity thereof, including, but not limited to, the determination of the scope or applicability of this agreement to arbitrate, such dispute, claim, or controversy will be, to the fullest extent permitted by law, determined by arbitration in Alexandria, VA before one arbitrator.

The parties agree to submit the dispute to binding arbitration in accordance with the Commercial Arbitration Rules of the American Arbitration Association (“AAA”) then in effect.  Except as otherwise provided herein, the arbitrator shall apply the substantive laws of the Federal Judicial Circuit in which Our principal place of business is located, without regard to its conflict of laws rules.  Within ten (10) calendar days after the arbitration demand is served upon a party, the parties must jointly select an arbitrator with at least five (5) years’ experience in that capacity and who has knowledge of and experience with the subject matter of the dispute.  If the parties do not agree on an arbitrator within ten (10) calendar days, either party may petition the AAA to appoint an arbitrator, who must satisfy the same experience requirement.  In the event of a dispute, the arbitrator shall decide the enforceability and interpretation of this arbitration agreement in accordance with the Federal Arbitration Act (“FAA”).  The parties also agree that the AAA’s rules governing Emergency Measures of Protection shall apply in lieu of seeking emergency injunctive relief from a court.  The decision of the arbitrator shall be final and binding, and no party shall have rights of appeal except for those provided in section 10 of the FAA.  Each party shall bear its share of the fees paid for the arbitrator and the administration of the arbitration; however, the arbitrator shall have the power to order one party to pay all or any portion of such fees as part of a well-reasoned decision.  The parties agree that the arbitrator shall have the authority to award attorneys’ fees only to the extent expressly authorized by statute or contract.  The arbitrator shall have no authority to award punitive damages and each party hereby waives any right to seek or recover punitive damages with respect to any dispute resolved by arbitration.  The parties agree to arbitrate solely on an individual basis, and this agreement does not permit class arbitration or any claims brought as a plaintiff or class member in any class or representative arbitration proceeding.  Except as may be required by law, neither a party nor the arbitrator may disclose the existence, content, or results, of any arbitration without the prior written consent of both parties, unless to protect or pursue a legal right.  If any term or provision of this Section is invalid, illegal, or unenforceable in any jurisdiction, such invalidity, illegality, or unenforceability shall not affect any other term or provision of this Section or invalidate or render unenforceable such term or provision in any other jurisdiction.  If for any reason a dispute proceeds in court rather than in arbitration, the parties hereby waive any right to a jury trial.  This arbitration provision shall survive any cancellation or termination of your agreement to participate in any of our Programs.

Miscellaneous: You warrant and represent to Us that you have all necessary rights, power, and authority to agree to these Terms and perform your obligations hereunder, and nothing contained in this Agreement or in the performance of such obligations will place you in breach of any other contract or obligation.  The failure of either party to exercise in any respect any right provided for herein will not be deemed a waiver of any further rights hereunder.  If any provision of these Terms is found to be unenforceable or invalid, that provision will be limited or eliminated to the minimum extent necessary so that this Agreement will otherwise remain in full force and effect and enforceable.  Any new features, changes, updates, or improvements of the Program shall be subject to these Terms unless explicitly stated otherwise in writing.

Onboarding

Before the first day, supervisors aim to prepare a workspace for a new employee with everything the employee needs to work, such as a desk, computer, phone, working email, software access, and any other necessary tools or supplies. Supervisors also prepare the following documents to give to the new employee on the first day:

• An outline for the new employee’s first week, with agenda items such as introductory meetings between the new hire and his or her key colleagues, team meals, training sessions, staff meetings, time to sign and review any necessary paperwork, and check-ins.
• Annual report, organizational chart, staff bios, and a copy of the new employee’s job description and his or her supervisor’s job description.

On the first day, supervisors are encouraged to do the following:

• Arrange an opportunity, like a meal or coffee, to let the new hire get to know the existing staff
• Meet with the new employee one-on-one
• Give the new employee an office tour
• Explain important safety and emergency information
• Provide information on accessing the building, including providing an identification card if necessary
• Review HR and administrative procedures
• Communicate WHI’s mission and how the new employee contributes to that mission

Within the first week, supervisors are encouraged to do the following:

• Resolve any issues with the workspace or equipment
• Discuss performance expectations and explain the Performance Management process, including semi-annual review

Training

While supervisors will be responsible for on-the-job training, the head of Human Resources may also direct or initiate training as appropriate. This training can take the form of instructor-led classes, online courses, or reference guides like the employee handbook. Training will include diversity sensitization, including disability, for staff at all levels in order to promote non-discriminatory working relationships, respect for diversity in work and management styles, and an organizational culture that supports diversity.

Performance Management

Supervisors shall conduct two performance reviews each year: once in March and once in October.

When a supervisor determines that an employee is not meeting expectations⁷, the supervisor should make aim to adhere to the following procedure:

1. Coaching. Clearly communicate expectations verbally and in writing. Be prepared to:

a. be direct and specific in identifying any deficiencies

b. problem-solve with employees

c. keep notes on content and date of conversations for own recollection and the HR file

d. provide consistent and timely feedback verbally and in writing when expectations are not met

2. Written Performance Accountability and Commitment Plan: If performance does not improve and the leader provided timely and consistent feedback, put the employee on a Performance Success Plan and outline expectations in a memo that contains the following:

a. Clear communication that the goal is the employee’s success

b. Schedule for supervisory feedback and employee self-reporting. For example, this could look like an increased frequency of meetings or reviews of work products.

c. If verbal coaching and written expectations do not lead to an improvement in a timely manner, or an issue is too time-sensitive to go through the above actions, the supervisor should work closely with a representative of Human Resources to write a time-specific document, a Final Performance Accountability Plan, about consequences, up to and including termination of employment. The document should state the problem(s), options, expectations, timeframe for assessment, and consequences, etc.

3. Consequences. If performance improvement with the Plan or any other further documents is insufficient, employment may be terminated.

a. After receiving an initial Written Performance Plan, an employee should have at least 30 days to demonstrate improvement. After receiving a Final Performance Accountability Plan, an employee will generally have no more than 30 days to demonstrate improvement. While the plan may include a timeframe, an employee may be terminated during a plan if there is not demonstrated improvement.

b. Even if an employee succeeds in substantially meeting expectations during the timeframe, and extra supervision is no longer required, the content of the performance feedback is relevant into the future. If similar problems recur, the timeframe for improving performance can be shorter than the first time.

Employee Resources

If the employee believes that the facts and circumstances upon which the Performance Accountability and Commitment Plan is based are inaccurate or incomplete, the employee may request a meeting with the immediate supervisor or the department leader. The employee may also request a conversation with his or her supervisor that is facilitated by Human Resources. If an employee believes there was a procedural flaw related to the administration of a Performance Accountability and Commitment Plan, the employee should notify Human Resources.

This policy is intended as a guideline to assist the inconsistent application of policies and programs for employees. This policy does not create a contract, implied or expressed, with WHI employees, who are employees at will.

Exiting Employees

Upon leaving WHI, all employees shall complete an exit interview.

⁷ For resources on performance management, see https://www.opm.gov/policy-data-oversight/performance-management/performance-management-cycle/#url=Planning

World Hope International is committed to equal pay for equal work. HQ and each branch will set a compensation structure based on regional market rates, pay grades, levels based on skills or competencies, or other similar structures. Part of the structure shall include a method of updating and adjusting the structure equitably.

Once structures are adopted, HQ will conduct annual internal pay audits to identify potential pay disparities based on gender, race, and disability.

7.2.1 Consistent with its mission and the constituency it serves, WHI promotes diversity in programs, where appropriate.

7.2.2 Diversity issues are incorporated into each stage of the program process, ideally from review of project proposals to implementation and evaluation, to ensure projects foster participation and benefits for all affected groups.

7.3.1 Consistent with its mission and the constituency it serves, WHI promotes and monitors the equitable participation of men and women (and girls and boys as appropriate) in the planning, designing, monitoring and evaluation of all aspect of programs.

7.3.2 Gender is integrated into each stage of the program process, from review of project proposals to implementation and evaluation, ideally reflecting the differences in how men, women, boys and girls are affected by programs and considering pre-existing and changing power dynamics and gender roles between men and women, including access to and control over resources and the different constraints and risks faced by men, women, boys and girls relative to one another, to ensure projects foster participation and benefits for both women and men, girls and boys.

7.4.1 WHI promotes and monitors the inclusion of people with disabilities in programs.

7.4.2 Disability inclusion strategies are integrated into each stage of the program process, from review of project proposals to implementation and evaluation, to ensure that projects foster participation and benefits for all affected groups, including disabled men, women, and children.

7.4.3 Programs and activities are held in accessible locations to the maximum extent feasible. Organizations will provide training and conference materials in alternate formats as applicable (Braille, sign-language interpreters, etc.). WHI plans financially to reasonably accommodate people with disabilities in member programs and activities.

7.5.1 WHI makes its best efforts to ensure its humanitarian action is in keeping with the principles of humanity, impartiality, neutrality, and independence.

7.5.2 WHI is guided and informed by the Sphere Project’s Humanitarian Charter and Minimum Standards in Disaster Response and associated standards.

7.5.3 WHI’s responses are coordinated with other local, national, and international humanitarian organizations in order to ensure prompt action and effective allocation of resources and to avoid duplication of effort.

7.5.4 Programs engaged in disaster response are guided and informed by the InterAction documents, The Security of National Staff: Towards Good Practices and Security Risk Management: NGO Approach and the Saving Lives Together framework.

Introduction

The security of World Hope International staff is of paramount importance. World Hope International recognizes that the nature of our work may, on occasions, place great demands on staff working in conditions of high risk, in remote and oftentimes austere locations around the globe.

World Hope International is committed to the development of procedures and practices aimed at ensuring the security of our staff.

As an organization, World Hope International takes all reasonable steps to ensure the security and well-being of staff and their families.

This policy covers the security of staff and the dependents of international staff who have accompanied status. It also deals with the protection of programs and assets from violence or the risk of violence. This can include intentional violence or risks such as theft, mugging, car-jacking, abduction or blackmail. Acts of unintentional violence, such as crossfire, land mines and general public disorder, are also addressed.

Safety issues are accidental hazards, such as car accidents or medical risks, and are dealt with in the Human Resources Policy.

Purpose

This document sets out the policy for the security of staff by defining basic security principles, applicable to all World Hope International staff and programs, at all times.

Approaches

In establishing appropriate risk management strategies, three basic security approaches are usually considered – acceptance, protection and deterrence.

Acceptance is generally emphasized as the preferred option for non-governmental organizations (NGOs) since it works towards increasing acceptance of, and hence protection for, an organization’s staff and programs by the host population.

Protection approaches emphasize devices and procedures to increase security (such as burglar bars, fences, improved lighting, guards) and the use of standard operating procedures for day-to-day activities. The intent is not so much to address the threat but to ‘harden the target’ – i.e. to make it more difficult for the organization or its staff to be attacked.

Deterrence approaches tend to be based around the use of counter-threats in the form of legal, economic or political sanctions, or through the use of retaliatory military force. This approach focuses on increasing the risk to the aggressor of launching an attack, and so intimidating potential enemies, and is generally considered unsuitable by most NGOs. However, the threat of sanctions in the form of closing or suspending programs is one often used by humanitarian agencies. The use of armed guards is also included in this approach and this is covered later in this document.

It is important to note that while these are recognized general approaches and represent best practice for the security management of NGOs working in insecure environments, each specific working environment will require its own combination of the three approaches.

Principles

Priority to Human Life

The security of personnel is of higher priority than the protection of assets, including premises, vehicles, office equipment or program materials.

Similarly, good judgment is required with regard to continued programming and presence in an area of insecurity, with a recognition that it may be necessary to accept an increased level of insecurity if, by maintaining a presence, the program staff are able to save the lives of people who would otherwise die.

Staff have Responsibilities and Rights

Security awareness is an ongoing collective responsibility and WHI commits to:

• Actively participate in and contribute to the maintenance of security measures.
• Be aware of security risks and team security.
• Understand and adhere to security measures.
• Be responsible for their own security and the security of staff they manage.
• Behave as a positive representative for World Hope International and adhere to WHI policies.

WHI staff is responsible for reporting to his/her line manager any actions or behavior that breaches policy or jeopardizes team security. Breaching security policy is a disciplinary offense and must be dealt with as such by the appropriate line manager.

Security awareness is an ongoing collective responsibility and WHI commits to:

• Actively participate in and contribute to the maintenance of security measures.
• Be aware of security risks and team security.
• Understand and adhere to security measures.
• Be responsible for their own security and the security of staff they manage.
• Behave as a positive representative for World Hope International and adhere to WHI policies.

 WHI staff is responsible for reporting to his/her line manager any actions or behavior that breaches policy or jeopardizes team security. Breaching security policy is a disciplinary offense and must be dealt with as such by the appropriate line manager.

Operational Managerial Responsibility

The Chief Executive Officer is responsible for the security of staff working for World Hope International.

Operational responsibility for the security of staff follows the line management structure. At a country level, responsibility for staff security rests with the Country Director, although the day-to-day management of security measures may be delegated to a security contact point in specific project areas.

Among the responsibilities for managing staff security are:

• Delegating security management tasks.
• Ensuring that all staff are updated on security incidents or issues and management decisions are taken in response to them.
• Ensuring that an adequate communications system is in place.
• Ensuring the maintenance of some form of ‘In-country Health Guidelines’ and that all staff are aware of these.
• Inducting/briefing all new staff and visitors on the security situation and security measures.
• Recognition that security management is demanding and that adequate time must be allocated to it.

Staff Skills and Capacity

World Hope International endeavors to ensure that all staff has the skills and capacity to analyze most security threats. World Hope International makes available various different resources for staff to learn about security threats in their area of responsibility.

This will be achieved through training, the active dissemination of security information and ongoing good security management practice.

Right to Withdraw

Irrespective of the judgment of the line manager or organization of the risk in a particular situation, any staff member may decline to take up work in an insecure area or may withdraw from such an area, having informed their manager that they intend to do so.

If an individual feels uncomfortable with the frequency or level of personal risk inherent in a position, a review should be undertaken between the individual and his/her line manager to determine an appropriate course of action. The relevant Human Resource Officer should be advised of the process and the outcome.

All Security Incidents Must Be Reported

All security incidents must be reported immediately to the Country Director and the Chief Executive Officer. These managers should be copied on all security incident reports to enable tracking, monitoring and analysis of security trends. The Virginia-based Chief Legal Officer will be advised of all such incidents that impinge on staff health.

Guidance as to what constitutes different levels of a security incident will be determined by a cooperative effort between relevant HQ and field managers.

As soon after the incident as possible, a post-incident report needs to be completed by all those involved in or affected by the incident. This allows for an analysis of the incident to be undertaken, so that the Country Director may determine why the incident happened, whether it could be prevented and how such incidents may be managed more effectively in the future.

The US staff will not contact the family members of staff involved in security incidents unless they are requested to do so by the Country Director.

Kidnap/Abduction

In the event of a member of staff being kidnapped or abducted, World Hope International’s stated policy pertains: In the event that a member of World Hope International staff is abducted, contact should be made as soon as possible with Virginia headquarters so that action can be coordinated at country and HQ levels. The Chief Executive Officer will assume ultimate decision-making authority, treat it as his/her top priority and will decide whether to convene an organizational Crisis Management Team (CMT).

World Hope International’s policy is not to pay any ransom requested to effect the release of a member of staff.

World Hope International will provide appropriate support to the immediate family during the period of the kidnap. The CMT will manage media relations and contact support for the next-of-kin.

In keeping with the line management structure, the reporting of such incidents should be made by the In-country manager, to the Chief Executive Officer.

Convening a Crisis Management Team

Depending on the nature of the incident, the Chief Executive l Officer will select the CMT, which is responsible for coordination, decision-making and delegation of responsibilities.

The Use of Armed Protection is Discouraged

World Hope International staff should not use armed protection without the explicit permission of the Chief Executive Officer since it may be seen to compromise our impartiality. This is particularly the case if the protection is not provided by a neutral force. This is not an absolute – in circumstances of instability, or where it is a requirement of the government or local authorities for vehicles to be escorted by police or military personnel, then armed protection can be considered.

World Hope International does not rule out the employment of armed guards for the protection of equipment and facilities, particularly in areas where violent crime is rife. However, the nature of this protection needs to be considered in light of the local context and the possible impact that its utilization may have on the local perception of World Hope International’s neutrality.

Permission to use or hire armed personnel (either directly or indirectly) may only be granted only by the Chief Executive Officer.

Firearms, or any weapons, should not be carried in World Hope International vehicles unless the security situation demands this, and even then may only occur if the Country Director has sanctioned this action following consultation with the Chief Executive Officer. Other than those people specifically employed to provide armed protection in exceptional circumstances, World Hope International staff must not carry or be seen to take up arms while on World Hope International duty or traveling under the auspices of World Hope International.

Limit Involvement with Armed Forces to Essential Humanitarian Actions

In determining the relationship between World Hope International and military forces, we should be guided by the IASC Armed Escort Guidelines. Engagement with military forces is a difficult area to be entirely prescriptive on, with local circumstances having a huge impact on the nature of any such relationships, but humanitarian agencies must maintain their independence of decision and action, and can never operate under the command of the military.

In those situations in which international peacekeeping forces have been deployed to a country, there is an obvious need to share certain types of information, particularly with regard to security, conditions in shared space (transport, aid movements, common use airfields), general estimates about the scale of the emergency, etc. However, the information should not be shared if it could in any way endanger communities or risk staff security, and must be guided by the Red Cross Code of Conduct principle – ‘We shall not endeavor to act as instruments of government foreign policy’.

Plan and Prepare for Evacuation based on Contractual Relationship

Planning and preparation for evacuation is an integral part of any security plan. Preparation should also be made for ‘hibernation’ – a situation when it is safer to stay in a location than to attempt to move or when an evacuation is not being considered.

World Hope International has different evacuation policies for national and international staff because of the different contractual relationships that we have with them. World Hope International has a contractual responsibility to return

International staff to their place of domicile and to evacuate them from their place of work should it become insecure. National staff must be split into two groups – those who have, as part of their contract, been relocated by World Hope International to work in the affected area, and those who originate from, and were hired in, that area.

A country evacuation plan must indicate World Hope International’s responsibility to each category of staff.

World Hope International is not obligated to evacuate those national staff employed within their area of domicile. However, World Hope International does have a responsibility to relocate national staff who have been seconded to work in an area of the country other than their home area, or who are temporarily visiting a program area. While having no contractual obligation to do so, World Hope International will do all it reasonably can, using national systems, to evacuate members of minority or at-risk groups who may be targeted by military groups likely to take over the evacuated area.

It is the responsibility of the Country Director to ensure that the parameters of World Hope International’s responsibilities to all staff (both national and international) and their dependents are made clear at the time of appointment and are clarified and communicated on a regular basis or as circumstances change.

The evacuation plan should also include details of previously defined arrangements for national staff to assume responsibility for offices and programs in the event of international staff evacuation. Arrangements must also be made for them to receive salaries in such an event and to have agreed limits on such arrangements. However, emergency hand-over to national staff must only be done with their consent and involvement. National staff must never be pressured to continue their work if to do so would expose them to undue danger or pressure from local government authorities.

The Order to withdraw from a Program Area

The order to withdraw from an area can be given by the local manager with immediate effect and is binding on all staff reporting to him or her, and to other staff visiting the area. If possible, the local manager should consult the Country Director or his/her line manager before ordering a withdrawal.

The Country Director may direct a team to withdraw from a project area, may suspend an office/program, and may override a local manager’s wish to remain in the program area. . However, a Country Director may not override a local manager’s decision to leave an area if he/she deems the current situation to be too insecure to remain. Longer-term program closure must be decided upon with approval from Chief Executive Officer.

The decision to suspend or temporarily close a program may only be taken by the Country Director and should be made in consultation with the Chief Executive Officer.

In those situations in which there is a UN agency overseeing security, and in the event that that agency recommends an evacuation of NGO staff, World Hope International staff are required to carry out that recommendation unless it is otherwise directed by the Country Director. In the event of a countermand of UN recommendations, the Country Director is required to inform the Chief Executive Officer in writing as to why such a decision has been made.

The Order to withdraw from a Country

Ultimately, the decision to withdraw international staff from a country, or to suspend activities in a country, may only be taken by the Chief Executive Officer for security.

Authorization to return to a Program Area

Authorization to return to an area after evacuation or suspension can only be given by the Country Director in consultation with the Chief Executive Officer. A systematic security review must be undertaken by the relevant manager and a written report, including recommendations, submitted to the Chief Executive Officer such a decision can be made

Authorization to return to a Country

Ultimately, the decision to return to a country following an evacuation or withdrawal may only be taken by the Chief Executive Officer.

Prepare Plans for Medical Emergencies

World Hope International has a mandatory evacuation insurance policy for US citizens working abroad either on a short term or long term basis.

Full Participation of National Staff in Security Planning

National staff should be involved in the formulation, review and implementation of security policy strategies. Each World Hope International country should analyze specific risks faced by national staff as part of the ongoing process of threat and vulnerability assessment. National staff should be included in security preparedness, training and human resource management procedures.

Maximize Co-ordination and Information Sharing

World Hope International should co-ordinate closely with other humanitarian and UN agencies in managing security. Security incidents should always be reported to other agencies and regular mechanisms for sharing information should be established or utilized if they are already in place.

Universal Application of Principles

The security principles outlined above apply to all World Hope International programs. Even those countries currently thought to be ‘secure’ must adhere to these essential principles.

Even though the cause for the detailed application of the principles is less likely to occur in some countries than in others, there has to be vigilance regardless of the global location – to minimize risk.

Policy Monitoring and Review Process

In recognition of the fact that both internal and external environments change, the scope and content of this policy will be reviewed periodically to reflect these changes. This review process will, in line with World Hope International’s values, be consultative and participatory in nature.

The responsibility for initiating the review process rests with World Hope International’s Chief Executive Officer.

Code of Conduct

The Code of Conduct for The International Red Cross and Red Crescent Movement and NGOs in Disaster Relief was developed and agreed upon by eight of the world’s largest disaster response agencies in the summer of 1994.

The Code of Conduct, like most professional codes, is a voluntary one. It lays down ten points of principle which all humanitarian actors should adhere to in their disaster response work, and goes on to describe the relationships that agencies working in disasters should seek with donor governments, host governments and the UN system.

World Hope International subscribes to these principles, and ensure our programs are implemented behind this backdrop.

The humanitarian imperative comes first.

Aid is given regardless of the race, creed or nationality of the recipients and without adverse distinction of any kind. Aid priorities are calculated on the basis of need alone.

Aid will not be used to further a particular political or religious standpoint.

We shall endeavor not to act as instruments of government foreign policy.

We shall respect culture and custom.

We shall attempt to build disaster response on local capacities.

Ways shall be found to involve program beneficiaries in the management of relief aid.

Relief aid must strive to reduce future vulnerabilities to disaster as well as meeting basic needs.

We hold ourselves accountable to both those we seek to assist and those from whom we accept resources.

In our information, publicity and advertising activities, we shall recognize disaster victims as dignified human beings, not hopeless objects.

7.6.1 WHI has policies specific to the organization’s mission at headquarters and security plans at the field level based on a security risk assessment.

7.6.2 WHI has appropriate resources to mitigate the organization’s identified security risks.

7.6.3 WHI created personnel procedures for hiring, preparing and supporting staff to cope with the security risks at their post of assignment, support them during their service, and address post assignment issues.

7.6.4 WHI incorporates accountability for security into their management systems at both the field and headquarters level

7.6.5 WHI works in a collaborative manner with other members of the humanitarian and development community to advance their common security interests.

7.6.6 WHI incorporates national staff into their risk reduction systems.

7.7.1 WHI, when responding to the needs of refugees and internally displaced persons, is guided and informed by the 1951 United Nations Convention and l967 Protocol Relating to the Status of Refugees and The Guiding Principles on Internal Displacement.

7.7.2 WHI, if active in the U.S. Reception and Placement Program of Refugee Resettlement, adheres to the mutually agreed upon Bureau of Population, Refugees and Migration Program Guidelines for Participants.

For a detailed examination of WHI’s response to PSEA, see 3.43 PSEA Policy. This 7.8 policy focuses on implementation but does not supersede 3.43.

7.8.1 WHI takes responsibility to ensure that beneficiaries are treated with dignity and respect and that certain minimum standards of behavior are observed.

7.8.2 Sexual exploitation and abuse by WHI staff constitute acts of gross misconduct and are therefore grounds for termination of employment.

7.8.3 Sexual activity by WHI staff and a beneficiary who is a child (a person under the age of 18) is prohibited regardless of the age of majority or age of consent locally. Mistaken belief in the age of a child is not a defense. The sole exception in applying this principle may be in the instance where a staff member is legally married to a person under the age of 18.

7.8.4 Exchange of money, employment, goods, or services, including assistance that is due to beneficiaries, for sex, sexual favors or other forms of humiliating, degrading or exploitative behavior is prohibited.

7.8.5 Sexual relationships between WHI staff and beneficiaries are strongly discouraged since they are based on inherently unequal power dynamics. Such relationships undermine the credibility and integrity of humanitarian aid work.

7.8.6 Where a staff develops concerns or suspicions regarding sexual abuse or exploitation by a fellow worker, whether in the same organization or not, s/he must report such concerns via established WHI reporting mechanisms.

7.8.7 WHI staff are obliged to create and maintain an environment that prevents sexual exploitation and abuse and promotes the implementation of their code of conduct. Managers at all levels have particular responsibilities to support and develop systems that maintain this environment.

7.9.1 When involved in development assistance, WHI is guided by the professional standards developed by recognized authorities related to their sectoral areas of the discipline. Examples could include but are not limited to, the following: the Guidelines for Drinking Water Quality15 promulgated by the World Health Organization (WHO); Housing and Health: An Agenda for Action16, promulgated by WHO; the World Declaration on the Survival, Protection and Development of Children17 promulgated by United Nations Children’s Fund; and Learning for All: Bridging Domestic and International Education; Conference Report18, the U.S. Coalition for Education for All.

7.10.1 WHI uses a variety of child-focused approaches to development, which fosters mutually beneficial, supportive relationships among peoples from widely varied cultural and economic backgrounds. Programs shall facilitate self-reliance, self-help, and popular participation. They shall regularly update the status of each sponsored child and report significant changes which impact the child’s participation in the program to the sponsor. They shall be guided and informed by the principles contained in the United Nations Convention on the Rights of the Child.

7.10.2 The resources generated through child sponsorship shall be used and accounted for in a manner consistent with the programs and purposes described in appeals. Where initial appeals to, or ongoing communications with, sponsors promise or imply benefits to specific children, WHI shall have procedures in place that enable it to document that the sponsored child benefits from any programs or projects supported with their sponsor’s funds.

7.10.3 WHI adopts policies and practices to ensure sponsored children and their families benefit in identifiable ways from sponsors’ contributions.

7.10.4 If WHI pools sponsorship contributions to support child-focused community development projects, WHI ensures every community with sponsored children benefits from programs.

7.10.5 WHI shall never knowingly enroll a child or family already enrolled by another sponsorship organization; nor shall WHI seek more than one sponsor for a child unless this fact is clearly communicated to sponsors. Where there is risk for multiple sponsorships in the field, WHI will seek ways to coordinate with other organizations to mitigate the risk.

7.10.6 WHI does not use sponsorship purely as a fundraising tool but seeks to make its sponsorship programs consistent with the organization’s overall mission and purposes.

7.10.7 WHI respects the privacy and dignity of sponsored children and their families. When displaying child information on open websites for the purpose of sponsorship, WHI protects the identity of the child by providing only limited biodata (which could include name, birth information, geographic location) which is combined in such a way as to prevent identification of the specific child. WHI seeks to protect sponsors from inappropriate solicitations from sponsored families.

7.10.8 Marketing materials are accurate and current in their portrayal of conditions involving families and children depicted in these materials. Promotional appeals and marketing materials that use visual images to solicit donations shall accurately reflect the current work of WHI. If historical images (i.e. taken more than 3 years ago) are used for solicitation purposes, the context and year the image was created shall be clearly identified in the appeal.

7.10.9 If WHI pools sponsorship contributions to support child-focused community development projects, it notes this practice in all sponsorship marketing materials.

7.10.10 WHI clearly communicates to sponsors its definition of benefit to sponsored children and periodically communicates to sponsors the indicators used to monitor and evaluate these benefits.

7.10.11 WHI has clearly defined and publicly stated criteria for establishing partnerships with communities and for fostering community empowerment through participation in the planning of programs and projects.

7.10.12 WHI has the capacity of providing financial and performance oversight and child monitoring at the local level, whether through a field office structure or through partnerships with local entities.

7.10.13 WHI strives to ensure sponsored families are periodically informed of the organization’s activities in their community.

7.10.14 When working with partners who have access to children or data on children, WHI verifies the partners have policies and practices in place to protect children or allow the partner to sign onto WHI’s policy.

7.11.1 The focus of public education efforts is to increase the U.S. public understanding of development issues by creating avenues for and contribute to raise the quality of informed debate, disseminating accurate information, evidence of effectiveness, transparency in the use of funds, and commitment not to oversimplify but to embrace the complexity that often accompanies the global development dialogue. This recognition of global interdependence and its long-term impact upon the well-being of all societies and to develop a constituency in support of a constructive U.S. role in the world.

7.11.2 WHI is informed by the following guidelines:

• Accuracy of Content: The description of the issue should be factually correct and when appropriate include sources. When describing a project, information about the geographic area, major activities, and what the intended or actual outcomes are should be included.

• Respect: Public education should be respectful in its use of language, description of people and lifestyles, bringing balance to different points of view while avoiding oversimplification.

• Constituent Voice: The voice of the people who are the subject matter of public education should be represented in materials. • Challenge to Further Learning and Action: Educational materials may challenge and inspire users to delve deeper into the subject matter – a better informed, committed and energized public is a good thing.

• Advocacy: Public education may be linked to advocacy, campaigns, and calls to action. Public education should not support a political party, candidate, or organization affiliated with a particular party.

• Cost: The cost of public education, covering administration, travel, staff, etc., should be reasonable and in proportion to referenced program or activities being implemented.

• Fundraising: Communications that will be fully expensed as a public education activity (which is a program expense) cannot include any element of collecting money.

• Religious Activities: Public education should not proselytize for any particular religion.

• Materials: Public education may include materials such as websites, social media, posters, magazine articles, radio segments, brochures, and other types of products as part of public education activities.

7.11.3 WHI makes a clear distinction between its fundraising and public education efforts, especially in its financial reporting, adhering to the relevant positions of the American Institute of Certified Public Accountants (AICPA) regarding the appropriate allocation of the expenses related to these activities. WHI affirms the commitment to maximize donor contributions to the field. In alignment with 7.11.1, WHI also affirms that it is over-simplistic to revert to overhead as the defining proxy for measuring program effectiveness.

7.12.1 Programs involving the provision of emergency and material assistance are carried out, to the maximum extent feasible, in a manner intended to support and enhance local know-how and productive capacity, to reduce vulnerability to future disasters, and to lay the basis for long-term development.

7.12.2 WHI ensures assistance is related to the basic mission and purposes of the organization and only items appropriate to the local situation are received and disbursed. All donated resources are approved by the recipient prior to shipment and appropriate to the recipient location, and donated items comply with quality standards in both country of origin and country of usage. Materials provided are appropriate (i.e. sensitive to the local culture and situation) and based on an assessment of local needs

7.12.3 WHI programs mitigate against negative outcomes resulting from gift-in-kind donations, such as local market disruption, diversion for nonhumanitarian purposes, dependency among beneficiaries, or environmental hazards resulting from the disposal of un-used or discarded items.

7.12.4 A number of resources guide and inform WHI professional standards in gift-in-kind activity, including, but not limited to: Guidelines for Drug Donations of the World Health Organization (WHO), the Sphere Standards for Emergency Response, the Interagency Gifts-In-Kind Standards of the Association of Evangelical Relief and Development Organizations (AERDO/ACCORD), the Guidelines of the Partnership for Quality Medical Donations (PQMD), and InterAction’s Pharmaceutical Recommended Methodology Decision Tree and Pricing Inputs Catalog.

7.12.5 WHI’s finance policies clearly describe the valuation and auditing methods used, to ensure the value of assistance is accurately stated. The basis and method for valuing donated gifts-in-kind is compliant with IRS requirements and FASB guidance and is disclosed in WHI’s audited financial statements. WHI ensures valuation sources are current and regularly considers relevant changes in market conditions when determining fair value. In order to enhance the credibility of the programmatic benefit gift-in-kind contributions create and to mitigate against the risk that gifts-in-kind values are viewed skeptically, WHI seeks valuation methodologies that exercise reasoned judgment in their interpretation of the “fair value” concept and their selection of source data when determining values. For purposes of recording revenue and expense, gifts-in-kind donations are valued at their fair value as of the date of donation. Donations and valuation techniques are not unduly influenced by the financial considerations of the member. Important guidance on fair value measurement can be found on the Financial Accounting Standards Board (FASB) website.

7.12.6 WHI ensures its fundraising solicitations do not create a false impression or misunderstanding about how its cash and non-cash resources are utilized.

7.12.7 WHI ensures fees related to gifts-in-kind assistance are assessed in relation to the cost incurred, not to the value of the goods involved; that those costs are clearly communicated to organizations that payment processing fees; that gifts-in-kind will be used for the purpose intended by the donor and will not be diverted for financial gain unrelated to the purpose for which the gift was made; and that proper documentation will be maintained on all gift-in-kind transactions. WHI ensures internal policies and controls exist to prevent gifts-in-kind from being bartered, traded or sold.

7.12.8 WHI complies with all relevant US export laws, including but not limited to regulations and statutes put in place by the US Departments of Treasury (OFAC), Commerce (BIS), Justice (DEA) and State as well as the US Patriot Act. WHI complies with applicable export and import laws and provide necessary support to recipient organizations undertaking importation processes

7.13.1 Regarding the provision of pharmaceutical and medical resources, WHI operates in a way consistent with its stated mission and nondiscriminatory practices, that does not compromise patient safety and that clearly delineates program expenses to be incurred by WHI and its recipient.

7.13.1.1 WHI is guided and informed by the World Health Organization Guidelines for Drug Donations and the WHO Model List of Essential Medicines in receipt and distribution of medical supplies.

7.13.2 WHI is guided by needs expressed by qualified host country recipients. Qualified recipients may be appropriate governmental organizations or qualified private sector entities, such as national or international non-governmental organizations, local hospitals, and community health centers. Drugs should not be sent without prior consent from the recipient.

7.13.3 All donations are based on an expressed need and relevant to the disease pattern and consumption rates in the recipient country.

7.13.3.1 All donated drugs or their generic equivalents are approved for use in the recipient country and appear on the national list of essential drugs or, if a national list is not available, on the WHO Model List of Essential Medicines, unless requested otherwise by the recipient.

7.13.3.2 The presentation, strength, and formulation of donated drugs are similar to those of drugs commonly used in the recipient country.

7.13.3.3 When making pharmaceutical and other medical donations, WHI shall ensure that the recipient has the adequate medical capacity to appropriately use the donated item (i.e. diagnostics and patient monitoring, continuity of therapy after the donation has been consumed, matching parts, consumables and/or equipment required, etc.).

7.13.3.4 All donated drugs should be obtained from reliable sources and comply with quality standards in both the country of origin and the country of usage.

7.13.3.5 Drugs that have been issued to patients and then returned to a pharmacy or elsewhere, or were given to health professionals as free samples, should not be donated.

7.13.3.6 After arrival in the recipient country, all donated drugs should have a remaining shelf life of at least one year. If an exception is made, the responsible professional at the receiving end must be informed of the quantity and remaining shelf life to allow for proper administration prior to expiration. In all cases, the date of arrival, the expiration dates, and the quantities of the drugs should be communicated to the recipient well in advance.

7.13.3.7 Donated drugs will not be used by recipients after expiry date. Disposal of unused drugs will also be compliant with applicable environmental standards and regulations, and WHI should establish an up-front understanding with the recipient as to who will bear the cost burden of destruction in the event that donated items cannot be used and need to be disposed of. Important guidance on this issue can be found in the following reference: “Guidelines for Safe Disposal of Unwanted Pharmaceuticals in and after Emergencies” of the World Health Organization

7.13.3.8 All drugs should be labeled in a language that is easily understood by health professionals in the recipient country; the label on each individual container should contain, at minimum, the International Nonproprietary Name (INN) or generic name, batch number, dosage form, strength, name of the manufacturer, quantity in the container, storage conditions, and expiration date.

7.13.3.9 WHI shall have systems in place that allow WHI and its recipients to implement product recalls.

7.13.4 The assurance of effective handling and delivery: The shipment and delivery of donations should be the responsibility of WHI and cause as little burden as possible to the qualified host-country recipient. WHI informs recipients of key logistical information regarding the delivery of pre-approved drug donation shipments being made between the recipient and WHI.

7.13.4.1 Donated drugs are presented in unit size and packaging appropriate for the dispensing authority.

7.13.4.2 All drug donations are packed in accordance with international shipping regulations and accompanied by a detailed packing list which specifies the contents of each numbered shipping unit by INN, dosage form, quantity, expiration date, volume, weight, and any special storage conditions. The weight per carton in each shipping unit should not exceed 50 kilograms. Unless in recipient-approved, pre-packaged units, drugs should not be mixed with other supplies in the same carton.

7.13.4.3 Costs of international and local transport, warehousing, port clearance, and appropriate storage and handling are paid by WHI unless specifically agreed otherwise with the recipient in advance.

7.13.5 WHI will maintain documentation relating to the handling and use of all donations.

7.13.5.1 Branches should maintain written policies and procedures to evaluate potential pharmaceutical donations to ensure that they meet appropriate programmatic, medical, cultural, and ethical criteria.

7.13.5.2 All donations should have proper documentation relating to product value, inventory, and verification of receipt, a record of transfer and to the extent possible, consumption.

7.14.1 CRITERIA FOR FOOD AID DISTRIBUTION

WHI will assess and consider the availability of locally sourced food commodities and the implications of both local purchase and the importation of food will have on local production and market systems. WHI will introduce general (free) distributions of food aid only when absolutely necessary, i.e., whenever a food aid response is required to sustain life, reduce and prevent malnutrition in food insecure communities or if there is a substantial risk key productive assets will be sold or consumed. Incentivized food distribution programs that are not “free”, i.e. food-for education or food-for-work, are not restricted to these crises. Food aid should be targeted to those most in need and discontinued as soon as possible. When free distributions of food become necessary, locally procured, culturally appropriate, dry rations should be used whenever appropriate. Both locally/regionally purchased and imported food aid distributions should avoid the creation of disincentives toward local food production and a negative impact on local markets. When importing food aid, WHI will assure that the populations served by the food aid are those living in extreme poverty (earning less than $1.25/day or measured by the level of child mortality), and therefore have little impact on the market share. Additionally, the extremity of need, together with careful rationing, will diminish greatly the issue of selling the food aid received.

7.14.2 FOOD AID POLICY AND COMPLIANCE

WHI will share technical and operational information that will contribute to the overall improvement of the efficiency and effectiveness of food aid. WHI should establish and periodically review a food aid policy that explains the organization’s purpose in using food as a program resource and its understanding of the responsibilities and obligations inherent in the use of food. As applicable, the policy should be in compliance with InterAction’s Food Aid Guidelines, which were informed by and/or drawn from Sphere Project Humanitarian Charter and Minimum Standards in Disaster Response, FAO/WHO Codex Alimentarius Standards27 and from best practices of InterAction member organizations.

7.14.3 FOOD AID RATION PLANNING

When rationing food aid (where the donor does not specify it) will design rations for distribution after investigating the population’s needs for energy, protein, fat and micronutrients. WHI will determine the amount of the rations to be distributed with a view of bridging the gap between the affected population’s requirement and its access and availability to food resources.

7.14.4 FOOD AID APPROPRIATENESS AND ACCEPTABILITY

WHI will provide food items that are appropriate and acceptable to recipients. WHI will avoid the distribution of foods that disrespect the cultural or religious traditions of the beneficiaries. If a nutritious food is procured that is not part of the regular diet of the beneficiary, an appropriate education component would be necessary in order to adapt the food and its preparation to the existing culture. WHI should avoid the sole distribution of foods lacking in nutritional value or rich in elements that would create health concerns, such as candy, particularly under conditions where they would be consumed in lieu of meals.

7.14.5 FOOD AID QUALITY AND SAFETY

WHI will distribute food of appropriate quality and fit for human consumption that conforms to international standards and the standards of recipient countries. Should the recipient country not have existing published standards, it is recommended that members use standards of The FAO/WHO Codex Alimentarius. WHI will follow up promptly and handle in a transparent and fair manner any recipient complaints about food quality that could affect the health of the recipient. This would not include individual taste preferences.

7.14.6 FOOD AID MANAGEMENT HANDLING

WHI will distribute, whenever possible, amounts of food that can be used efficiently and securely. Where circumstances allow, WHI will address food aid recipients’ difficulties in storage, preparing, cooking or consuming the food distributed, including the lack of access to cooking utensils, clean water and sanitation and cooking fuel required for safe methods of food preparation.

7.14.7 FOOD AID SUPPLY CHAIN MANAGEMENT

WHI will implement supply chain management systems that will ensure that food aid resources reach the intended beneficiaries. A typical supply chain may be structured as follows, allowing for some flexibility in the middle levels: the donor, the US NGO beneficiary, the principal distributing partner(s) in country, secondary distributing partners, aid workers/missionaries/relief workers/volunteers, final beneficiary. WHI should ensure the proper transportation channels are used in the moving of food aid from donor to final recipient (which may include tracking, overseas shipping, and local distribution). Depending on the food commodity, this may require refrigeration, fumigation, inspections, and proper importation documents, such as certificates required by recipient countries for the importation of various foods. To efficiently manage the supply chain, WHI should collect the proper reporting of impact and/or outcome measures of the final distribution. WHI should ensure proper distribution reporting at all levels of the chain, assuring that, should there be a recall of product; the member should be able to successfully remove the undistributed product out of circulation. Supply chain management and structure may vary according to the culture of each individual organization, but the aim of keeping the donor well-informed and aware of the good his contribution is accomplishing should be common to all.

7.14.8 FOOD AID DISTRIBUTION MANAGEMENT

WHI will assure that the method of food distribution is responsive, transparent, equitable and appropriate to local conditions. WHI should make certain that the recipients of food aid are identified and targeted on the basis of need, by means of an assessment carried out through consultation with stakeholders. Food aid should primarily assist the most vulnerable members of the community, such as children, the elderly, the disabled, identified in consultation with local groups and partner organizations and frequently monitored in order to avoid discrimination and assure that food continues to reach the intended recipients.

7.14.9 FOOD AID IN DISASTER RESPONSE

When responding with food aid to disasters, WHI will coordinate its efforts with informed advisors and stakeholders from UN cluster systems, local communities and governments and/or local NGOs to determine the most appropriate types and quantities of food aid, the most efficient supply chain management, and those most in need. Distributions of donated breast milk substitutes should be guided by advice given by WHO and/or UNICEF related to the intended beneficiaries and their current circumstances.

7.14.10 FOOD AID AND DEVELOPMENT PROGRAMS

WHI will, where possible, use food aid to support development in agriculture, aquaculture, animal husbandry, fish farming, education and other community development projects, allowing the recipients to build capital and capacity toward self-sufficiency.

7.14.11 VALUATION OF DONATED FOOD

Regarding basis and methods for valuing donated gifts-in-kind, please see section 7.12.5 in these standards. In addition, important guidance on fair value measurement can be found in Financial Accounting Standards Board (FASB) website.

7.15.1 PURPOSE OF DONATING BOOKS & EDUCATIONAL MATERIALS

When involved with book and educational materials donations, WHI shall strive to achieve the following developmental goals in the distribution destinations: expand literacy and the knowledge base of the readership; encourage the dissemination of knowledge broadly within the community; foster a systemic understanding of educational principles; support the attainment of national education goals; and thoughtfully enhance discussion in the public sphere.

7.15.2 CRITERIA FOR BOOKS DONATIONS

WHI shall not provide relevant books where needs have been communicated from local receiving organizations. WHI will screen books prior to shipment to ensure the books are culturally appropriate, are relevant to local or national circumstances, and will meet the needs of the local readers. WHI will not ship educational materials that have been removed due to outdated, false or offensive content or that transgress national laws and regulations for importing printed materials.

7.15.3 CRITERIA FOR EDUCATIONAL MATERIALS DONATIONS

WHI will ensure that donated educational materials comply with national educational standards. Recipient organizations should develop relationships with local education councils or authorities to establish which materials are most needed and conducive to the desired educational outcomes. Samples of educational materials may have to be sent to the destination country for approval by the government entity overseeing education. Educational materials should be sent only upon request and such materials should not dictate the education curriculum in any community. WHI should strive to obtain the most recently published educational materials.

7.15.4 POLICY FOR DONATING BOOKS & EDUCATIONAL MATERIALS

WHI shall share operational information to contribute to the development of improved resource management that will maximize the efficacy of book and educational material donations industry-wide. WHI will periodically review and evaluate internal policy to ensure book donations support locally/nationally desired literacy and educational outcomes to promote the greater development of readership and to not adversely affect local publishing industries.

7.15.5 DISTRIBUTION OF EDUCATIONAL MATERIALS

WHI will strive to utilize or develop partnerships with local organizations that can broadly benefit the communities by promoting gender equality and providing public access to books through schools or public libraries. The local organizations will have access to the communities and their readers and can communicate reading needs to donors. Destination organizations should request books and provide information to donors about potential readers, the premises where the books would be retained, and the reading needs of the communities. If possible, distributions of books and educational materials should complement other institutions and organizations.

7.15.6 CONDITION OF BOOKS & EDUCATIONAL MATERIALS

WHI should work with donors and recipients to ensure that only new or like-new books are donated. Preference should be given to quality over quantity

7.15.7 SHIPPING BOOKS & EDUCATIONAL MATERIALS

Product should be sorted, organized and labeled for identification, package appropriately for transit conditions. To avoid damage, books should be properly packed to protect against any weather-related contingencies of international shipping. WHI should have an accurate listing of the shipping contents to maintain transparency with destination country customs administrations and to provide an accurate inventory for destination organizations.”

7.15.8 RECEIVING BOOKS & EDUCATIONAL MATERIALS

WHI should ensure that recipient organizations have the capacity to receive and distribute the quantity and type of donated books and educational materials shipped to them, including offloading, storage and sorting of materials.

7.15.9 CLEARING CUSTOMS

WHI should prepare all necessary documentation and information for consignee organizations in order to facilitate customs clearance, in accordance with the recipient country requirements. Consignee organizations should manage relationships with the national authorities to facilitate duty/tax waiver and efficient processing of customs formalities.

7.15.10 VALUATION METHOD FOR BOOK DONATIONS

Regarding the basis and method for valuing donated gifts-in-kind, please see section 7.12.5.

7.16.1 PURPOSE OF CLOTHING DONATIONS

WHI shall use clothing donations to provide recipients with decent and adequate protection from the weather/environmental elements that will help foster a sense of self-decency and self-respect for inclusion and participation in society. Clothing donations should be made to support organizations’ local program activities and tied to a specific programs and organizational objectives.

7.16.2 ASSESSMENT OF CLOTHING NEEDS

WHI shall only ship and distribute clothing donations where needs have been communicated from local receiving organizations. WHI should assess the geography and weather of the recipient country to determine the type of clothing that will correctly match the needs. WHI should further assess the potential impact on the local economy and not send clothing to countries or localities where the impact would be negative. Before any clothing articles are shipped, members should assess the in-country laws and regulations to determine if any prohibitions will prevent the importation of certain articles of clothing

7.16.3 CLOTHING QUALITY REQUIREMENTS

WHI shall only accept and distribute clothing donations that are suitable for wear according to reasonable standards. Clothing articles, new or used, shall be free from defects or have only minimal defects that do not affect the intended wear of the clothing and are minimally distinguishable.

7.16.4 CULTURAL SENSITIVITY OF CLOTHING

“WHI will make reasonable efforts to take into account cultural sensitivities before clothing is accepted or sent for distribution to the beneficiaries. Cultural sensitivities should be considered on a country-by-country basis and take into account local knowledge, if possible. All donated clothing articles shall be free of offensive logos or statements and should be culturally sensitive. WHI shall not accept donations of offensive clothing unless reasonable efforts can be made to remove offensive logos or statements without negatively affecting the clothing functionality.”

7.16.5 SHIPPING CLOTHING

Shipments of clothing should be properly packed to minimize any potential damage during transport. A reasonable effort should be made in properly sorting and packaging like items to aid in efficient distribution by the receiving organization. WHI should have an accurate listing of the shipping contents to maintain transparency with destination country customs administrations and to provide an accurate inventory for receiving organizations.

7.16.6 CLEARING CUSTOMS

WHI should prepare all the necessary documentation and information for receiving organizations in order to facilitate customs clearance, in accordance with the recipient country requirements. Receiving organizations should manage relationships with the national authorities to facilitate duty/tax waivers and efficient processing of customs formalities. When shipping used clothing, fumigation requirements, if any, must be determined before shipment.

7.16.7 RECEIVING CLOTHING

WHI will ensure that recipient organizations have the capacity to receive and safely store clothing items. Storage facilities should be secure from theft; structurally adequate to avoid spoilage of clothing; and be accessible for monitoring and compliance.

7.16.8 ASSESSMENT OF DISTRIBUTION REQUIREMENTS

WHI will ensure that recipient organizations make assessments of the local conditions including emergencies and will prioritize distributions to address urgent needs. WHI should coordinate distributions with other NGOs to eliminate unnecessary duplications and to ensure the impacts of the distributions are maximized, especially in times of emergencies.

7.16.9 DISTRIBUTION LOGISTICS

WHI should tailor their distributions to local requirements on the ground and should use the distribution channels (local organizations, partners or groups) that most efficiently and effectively meet their objectives. WHI should ensure that the partner distribution structure is in compliance with organizational policies and objectives.

7.16.10 MATCHING CLOTHING TO BENEFICIARIES

WHI shall distribute clothing in appropriate sizes corresponding to individual beneficiaries. WHI should allow latitude for individual preference within reason if there is enough clothing to allow it.

7.16.11 NO DISCRIMINATION IN DISTRIBUTIONS OF CLOTHING

In making distributions of clothing, WHI shall in no case discriminate based on race, ethnicity, gender, sexual orientation or religious affiliation.

7.16.12 VALUATION METHODS FOR CLOTHING

Regarding the basis and method for valuing donated gifts-in-kind, please see section 7.12.5.

7.16.13 CLOTHING DONATED FOR RESALE

These policies are not intended to apply to clothing donations gathered for the purpose of domestic monetization. Neither do the policies prohibit the sale of donated clothing within the US to raise program revenue, whether sold to domestic wholesalers, retailers or end-users, or to overseas for-profit importers, provided WHI is transparent with donors (at collection sites and internet sites) regarding the resale of their donated clothing. Donated clothing imported into a host country under declaration of donation intent should not be sold under any circumstances.