It’s been some time since these guidelines were passed with Sarbannes-Oxley but we still run into non profit organizations who don’t realize that this applies to them. So here is a reminder.
Document Destruction - all organizations should have a written, mandatory document retention and periodic destruction policy. Such a policy also helps limit accidental or innocent destruction. The policy should include guidelines for handling electronic files and voicemail. Electronic documents and voicemail messages have the same status as paper files in litigation-related cases. The policy should also cover back-up procedures, archiving of documents, and regular check-ups of the reliability of the system.
Whistle-Blower Protection - all organizations should develop procedures for handling employee complaints. A nonprofit must establish a confidential and anonymous mechanism to encourage employees to report any inappropriateness within the entity's financial management. No punishment - including firing, demotion, suspension, harassment, failure to consider the employee for promotion or any other kind of discrimination - is allowed. Even if the claims are unfounded, the nonprofit may not reprimand the employee. The law does not force the employee to demonstrate misconduct; a reasonable belief or suspicion that a fraud exists is enough to create a protected status for the employee.
The National Council of Non Profit Organizations has a nice sample policy at these links. http://www.ncna.org/index.cfm?fuseaction=page.viewPage&pageID=430 for a whistleblower policy and http://www.ncna.org/index.cfm?fuseaction=Page.viewPage&pageId=429#q6 for a document destruction policy.
Thursday, February 22, 2007
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