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Standards of Conduct
for
Workplace Giving Federations and Funds
First
Adopted by the National Alliance for Choice in Giving Board of Directors,
January 2000
Revised
by the National Alliance for Choice in Giving Membership, January 13, 2004
Revised by the NACG Membership, January 22, 2005
1. Guiding Principles & Standards
for Workplace Giving Federations and Funds
- Employees shall have the opportunity for choice in directing
their charitable gifts through the workplace campaign.
- The workplace campaign belongs to the employer and employee
and the workplace solicitation policy is set by each individual employer,
not charitable federations/funds.
- Federations/funds shall not deliberately obstruct other federations
through negative campaigning, disinformation, intimidation, or other means.
- Federations/funds shall not prohibit their member agencies
from conducting workplace giving campaigns for their employees that include
other charitable federations.
- Federations/funds shall not engage in coercion of employees
or promote coercive campaigns.
- Federations/funds shall not engage in deceptive practices or
make exaggerated claims with respect to all aspects of the organization's
operations including marketing to donors, employers, member charities,
and grantees.
- Federations/funds shall honor all agreements including campaign
and access negotiated with other federations/funds.
2. General Financial Practices
Workplace giving federations and
funds shall:
- Comply with IRS Reporting Regulations.
- Comply with charitable organization reporting requirements
of the states in which they operate.
- Comply with generally accepted accounting principles for non-profit
organizations.
- Provide financial reports to their boards of trustees no less
than four times per year.
- Have its board adopt an annual budget that clearly itemize
all sources of income including but not limited to campaign revenues;
fees retained from campaign revenues; member dues; special events; foundations;
individuals; corporations; fees for services; and sales revenue.
- Conduct an annual financial audit performed by an independent
and accredited C.P.A firm unless total revenues on line 12 of IRS form
990 are below the current combined federal campaign audit requirement.
- Adopt clear distribution/allocations policies and make available
to the public.
- Inform donors of the actual percentage of their designated
and undesignated contributions that will be distributed to member agencies.
- Honor all designations and maintain financial systems that
ensure accurate tracking of designations to all agencies in good standing.
- Distribute funds to member organizations at least two times
per year.
- In both financial statements and public campaign reports, distinguish
between funds raised for the federation/fund's member organizations and
"agency transactions" -- those funds designated by employees to other
federations/funds and non-member organizations.
- Ensure that the total amount distributed to the member groups
as a percentage of what is received through the campaign be 75% or greater,
unless otherwise approved by the recipient agencies.
- The allowance for uncollectible pledges to members shall be
based on actual overall pledge loss, not estimated pledge loss.
- Report the value to the organization of "loaned executives"
as part of "Direct Public Support" on Part I, Line 1A of IRS Form 990
and as part of "noncash" contributions on Line 1d. A loaned executive
is defined as an individual employed by another corporation, government
agency, or nonprofit organization but providing full or part-time staffing
to the federation/fund in return for compensation by their legal employer.
- Make the following documents available to the public upon request:
- IRS Form 990
- Accountant's Audit
- Annual Report
3. Workplace Campaign Management
Standards
For federations/funds serving
in a contractual role as a campaign manager and/or fiscal agent for public
or private sector employers:
- The federation/fund will in no way intentionally use its role
as campaign manager to assert its interests over the interests of other
charitable organizations participating in the campaign.
- Federations/funds shall assess fair, reasonable, and documented
actual costs in their capacity as campaign manager. These fees shall not
exceed 15% of campaign revenues. When a federation/fund is serving strictly
as a fiscal agent without additional campaign management responsibilities,
these fees shall not exceed 5% of campaign revenues.
- Federations/funds serving as fiscal agent shall not include
the results of other federations and agencies in their own campaign goals
and results reported to the media and general public.
- Federations/funds shall conduct campaign operations such as
training, kick-off and other events and fiscal operations such as banking
and fund distribution separate from the federation/fund's non-campaign
management operations.
- Federations / funds shall respect the integrity of all donor
information and shall not use their position as campaign manager/ fiscal
agent to solicit or otherwise contact donors to other federations or funds
unless the contact is necessary to carry out fiscal agent duties.
If such contact is made, it shall be made clear that the contact is for
fiduciary duties and not for solicitation.
- Federations/funds shall distribute funds no less than quarterly,
unless otherwise instructed by the employer.
- The allowance for uncollectible pledges shall be based on actual
overall pledge loss, not estimated pledge loss. A federation/fund serving
as fiscal agent receives from the employer only those dollars actually
withheld from employee paychecks. It shall therefore distribute exactly
what it receives from each employer (less approved fees) and report the
actual pledge loss at the end of the campaign cycle.
- Interest earned on campaign revenues shall be tracked and distributed
to campaign participants on a pro-rata basis or applied toward campaign
costs.
- The federation/fund will comply with audit standards set by
the employer.
4. General Ethical & Professional
Standards
- A federation/fund shall assist in maintaining the integrity
and competence of workplace and payroll deduction campaigns and other
forms of legitimate charitable giving.
- A federation/fund shall ensure that all donations/charitable
contributions in its custody and control shall be remitted to the designated
charity pursuant to the donor's wishes.
- A federation/fund shall preserve the confidentiality of any
donor wishing to remain anonymous and/or any information such donor wishes
to remain confidential.
- A federation/fund shall exercise the best independent professional
judgment at all times.
- A federation/fund shall assist in improving and enhancing workplace
and payroll deduction campaigns for all members, participants and donors.
- A federation/fund shall avoid even the appearance of professional
impropriety.
- The Board of Directors of every federation/fund shall have
a conflict of interest policy.
- A federation/fund shall not condone or accept discrimination
based on age, gender, sexual orientation, race, economic status or physical
state and further shall avoid even the appearance of discrimination based
on age, gender, sexual orientation, race, economic status or physical state.
5. Other Recommendations
- Avoid borrowing against restricted campaign revenues.
- Promote diversity in boards, staff, & volunteers.
- Protect the interests of the federation/fund and its employees through
adequate insurance protection (fidelity bonding; general liability; workers
compensation).
- Provide a fair and reasonable compensation package for employees
- Abide by Independent Sector's Code
of Ethics for nonprofit and philanthropic organizations.
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