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IRS 990-N Postcard
IRS 990-N Postcard
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Conflict of Interest Policy
Employees and Board Members have a responsibility to act in the best interest of NWF and are prohibited from using NWF and their position for private profit or benefit, such as a current or potential ownership or investment interest, or compensation arrangement. The private interest may be a direct benefit to the covered person, or an indirect benefit through another party to whom the covered individual has a family, business, or other affiliation.
Disclosure: Key Employees, such as the Executive Director, and Board Members must submit a written disclosure annually. Additionally, when a Board Member who has a financial or personal interest in any matter coming before the Board, they will a) fully disclose the nature of the interest and b) withdraw from discussion, lobbying, and voting on the matter.
Decisions: Any transaction or vote involving a potential conflict of interest may be approved only when a majority of disinterested Board Members determine that it is in the best interest of the corporation to do so.
Records of Proceedings: The minutes of meetings at which such votes are taken will record such disclosure, abstention, and rationale for approval. At the start of each Board Meeting, the Chair will ask if any Board Members have any conflicts of interest to declare.
Failure to Disclose: The Board will investigate any failures to disclose conflicts of interest and take appropriate disciplinary and corrective actions.
- Individuals who have or may have a conflict of interest related to a contract or transaction that is not the subject of Board action must disclose the details of such interest to the Executive Director. The Executive Director must report all disclosures, including their own, to the Board Chair. The individual must not participate or attempt to influence the discussions or decisions related to the conflict.
- Prior to Board action on a contract or transaction, Board Members who have or may have a conflict of interest must disclose the details of such interest. Board Members who will not be at a meeting must submit their disclosure to the Board Chair or Vice Chair. Disclosures will be recorded in the meeting minutes.
- If it is not entirely clear whether a conflict of interest exists, disclosures must be made as outlined above. The Executive Committee must determine whether there exists a conflict of interest that is subject to this policy.
- Board Members with conflicts of interest must not participate or attempt to influence the discussions or decisions related to the conflict. Board Members with conflicts will be excluded from the vote and the count determining presence of a quorum for the vote. Ineligibility will be recorded in the meeting minutes.
- Each Board meeting will begin by asking if anyone has conflicts of interest to declare. This request and any responses will be recorded in the meeting minutes.
NWF requires its employees and volunteers, including its Board and committee members, to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of NWF, it is important to comply with all applicable laws and regulatory requirements.
Reporting: NWF encourages everyone to share their concerns and complaints regarding NWF and its operations with the appropriate organization authority.
- A Board Member or committee member should present his or her concerns to the Chair of the Board.
- An employee or volunteer should present his or her concerns to the Executive Director.
- However, if a Board Member is not comfortable speaking with the Chair of the Board or is not comfortable with the Chair of the Board’s response, or if an employee or volunteer is not comfortable speaking with the Executive Director or is not satisfied with the Executive Director’s response, the Board Member, employee, or volunteer is encouraged to speak with anyone on the Board whom the individual is comfortable in approaching, or to directly contact NWF’s outside legal counsel, whose contact information can be obtained from the Executive Director.
Requirement of Good Faith: Anyone filing a complaint concerning a violation or suspected violation of NWF’s policies, or any laws or regulation requirements, must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.
No Retaliation: No individual who in good faith reports a violation may suffer harassment, retaliation, or any adverse employment consequence. Any individual who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment or volunteer status. This Whistleblower Policy is intended to encourage and enable all individuals to report violations and concerns within NWF to NWF prior to seeking resolution outside NWF.
Compliance Officer: NWF’s Executive Director, working with the Chair of the Board, will act as NWF’s Compliance Officer. The Compliance Officer is responsible for investigating and resolving complaints and allegations concerning violations of all applicable laws and regulations, including NWF’s bylaws and/or Code of Conduct.
- The Board Chair, or the Chair’s designee, will take on the Compliance Officer role if the complaint involves the Executive Director.
- If the complaint involves both the Executive Director and Board Chair, the Vice Chair will carry out the functions of the Compliance Officer.
Accounting and Auditing Matters: The Finance Committee of the Board of Directors will address all reported concerns or complaints regarding NWF’s accounting practices, internal controls, or auditing. The Compliance Officer will immediately notify the Finance Committee of any such complaint and work with the Committee until the matter is resolved.
Confidentiality: Violations or suspected violations may be submitted anonymously or on a confidential basis by the complainant. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.
Handling of Reported Violations: The Compliance Officer, or the individual responsible for carrying out the Compliance Officer’s role with respect to a reported or suspected violation, will acknowledge receipt of the reported violation or suspected violation by writing a letter (or e-mail) to the complainant within five business days. All reports will be promptly investigated, and appropriate corrective action will be taken if warranted by the investigation.
Native Ways Federation (NWF) observes the highest level of ethical standards.
The purpose of this statement is to share with you our policy concerning the collection of data and personal information while ensuring the highest level of confidentiality, security, and privacy for its Supporters, which include its members, donors, affiliates, and nativeways.org website visitors.
Collection of Information
NWF may collect personal information and personally identifiable information or PII (“Personal Information”) of its Supporters, including but not limited to, name, email, phone number, demographics, business affiliation, and financial information, directly or from its member organizations.
NWF also collects website traffic data via cookies: a small string of text that is sent to your computer or device that can collect data regarding your operating system, browser type, device type, mobile device ID, screen resolution, IP address and other technical information. This information is used at an aggregate level to improve our website and marketing strategies. You can remove, block, or disable cookies using the settings in your web browser.
Use of Information
NWF uses this information for purposes including, but not limited to, marketing, analytics, and credit card processing.
NWF does not sell, trade, or share Personal Information with other organizations. We occasionally have third parties perform services on our behalf. These third parties have access to your personal information only as needed to perform their services for NWF and are contractually obligated to maintain the confidentiality and security of the personal information.
Supporters can change their Personal Information or opt-out of communications by submitting a request through our Contact Us form at https://www.nativeways.org/contact-us/ or in an email to email@example.com
Information for Donors
Donors can receive a summary of the types of Personal Information we store by submitting a request through our Contact Us form at https://www.nativeways.org/contact-us/ or in an email to firstname.lastname@example.org
NWF employs internal access controls to secure Personal Information. For example, the only people who see our donors’ information are those with a need to do so to perform their official duties on behalf of NWF. We use technical controls to secure the information that we collect, including but not limited to Transport Layer Security (TLS), encryption, password protection, and two-factor authentication. While we try our best to safeguard your personal information once we receive it, no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure.
Since our website is not designed specifically for children, NWF does not intentionally collect personal information from children under the age of 13. If we discover or receive information that we have inadvertently collected personal information from a individual under the age of 13, we will automatically delete it.
Links on our Website
Discontinue Contact Upon Request
It is the policy of the Native Ways Federation (NWF) to discontinue contacting any individual upon that person’s oral or written request directed to NWF, its professional fundraiser, or other agent.
NWF will maintain a record of all requests by individuals who indicate to NWF, its professional fundraiser, and other agents, that they do not wish to be contacted by or on behalf of NWF.
This policy does not prohibit contact by NWF that is solicited by an individual or their representative, even if they or their representative have requested to be placed on the “do not contact” list. Contact by NWF that is solicited by an individual whose name appears on the “do not contact” list will be limited to providing a direct response to the their inquiry and will not cause their name to be removed from the “do not contact” list.
NWF will maintain a record of all requests for discontinuance of contacts, effective with the adoption of this policy by NWF’s Board of Directors. Oral requests will be recorded in writing by the employees of NWF and maintained with the written requests. The records of individuals who have made such a request will be maintained by NWF to the extent necessary for legal or liability purposes.
Upon a person’s (or a person’s authorized representative’s) request that NWF discontinue further contact, the person’s name and address will be promptly removed from NWF’s database or modified to ensure that no further contact is made with the person. NWF will also take steps to ensure that the person’s name is removed from any external databases or records under NWF’s control.
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