CEO Compensation Determination Policy
The Brother Benno Foundation’s Board of Directors provides direction and issues policies for the annual review and approval of employee compensation. The positions of CEO, Executive Director, President of the Board of Directors (top management official), other officers, and all Board Members are volunteer positions that are uncompensated.”
Donor Privacy Policy
The Brother Benno Foundation respects the privacy of its donors and exercises accounting practices to secure donor privacy. We hold all donor information in strict confidence and will not sell, trade, or share any donor information with other organizations or any type of business.
Conflict of Interest Policy
It is The Brother Benno Foundation’s policy that all employees avoid any conflict between their personal interests and those of the Foundation. The purpose of this policy is to ensure that the Foundation’s honesty and integrity, and therefore its reputation, are not compromised. The fundamental principle guiding this policy is that no employee should have, or appear to have, personal interests or relationships that actually or potentially conflict with the best interests of the Foundation.
It is not possible to give an exhaustive list of situations that might involve violations of this policy. However, the situations that would constitute a conflict in most cases include but are not limited to:
- Holding an interest in or accepting free or discounted goods from any organization that does, or is seeking to do, business with the Foundation, by any employee who is in a position to directly or indirectly influence either the Foundation’s decision to do business, or the terms upon which business would be done with such organization.
- Holding any interest in an organization that competes with the Foundation.
- Being employed by (including as a consultant) or serving on the board of any organization which does, or is seeking to do, business with the Foundation or which competes with the Foundation.
- Profiting personally, e.g., through commissions, loans, expense reimbursements or other payments, from any organization seeking to do business with the Foundation.
A conflict of interest would also exist when a member of an employee’s immediate family is involved in situations such as those above.
This policy is not intended to prohibit the acceptance of modest courtesies, openly given and accepted as part of the usual business amenities, for example, occasional business-related meals or promotional items of nominal or minor value.
It is the employee’s responsibility to report any actual or potential conflict that may exist and inquire if any question arises as to the ethics of any decision.
Whistleblower Policy
General
The Brother Benno Foundation requires directors, officers, and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of the organization, 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, and employees to comply with the policy and to report violations or suspected violations in accordance with this Whistleblower Policy.
No Retaliation
No director, officer, or employee who in good faith reports a violation of the policy shall suffer harassment, retaliation, or adverse employment consequence. An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment. This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns within the organization prior to seeking resolution outside the organization.
Reporting Violations
The Brother Benno Foundation’s open door policy suggests that employees share their questions, concerns, suggestions, or complaints with someone who can address them properly. In most cases, 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 someone on the executive committee or anyone in management with whom you are comfortable in approaching. Supervisors and managers are required to report suspected violations of this policy to the executive committee, who has specific and exclusive responsibility to investigate all reported violations. For suspected fraud, or when you are not satisfied, or you are uncomfortable with the following the organization’s open door policy, individuals should contact the executive committee directly.
Compliance Officer
The executive committee is responsible for investigating and resolving all reported complaints and allegations concerning violations of the policy and, at its discretion, shall advise the board of directors.
Accounting and Auditing Matters
The treasurer of the board of directors shall address all reported concerns or complaints regarding corporate accounting practices, internal controls, or auditing. The treasurer shall immediately notify the board of directors of any complaint.
Acting in Good Faith
Anyone filing a complaint concerning a violation or suspected violation of this policy must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation of the policy. 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.
Confidentiality
Violations or suspected violations may be submitted on a confidential basis by the complainant or may be submitted anonymously. 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 executive committee will personally notify the sender and acknowledge receipt in writing, not to include electronic transmission, of the reported violation or suspected violation within five business days. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.
