Effective August 14, 2017
HELPS International believes in protecting the privacy of personal information collected from our supporters through all of our communication channels, as well as from visitors to our website.
“Personal Information” is information that identifies you personally, such as your name, address, telephone number, and email address. We collect and store the personally identifiable information that you have provided us via one of the email addresses identified on our website or when you contact us in person, by phone or email. We collect your name, email address and other contact information if you register for an event or a service trip. We may also collect your name, email address, telephone number and payment information when you make a contribution, either on our website, at a special event, over the phone or by mailing in a check. From time to time, we may collect personal information in ways not described above.
Use and Disclosure of Personal Information
We do not trade, share, or sell lists that include your personal information to third parties.
We do not send you mailings on behalf of other organizations.
We use your information to process a donation or event registration; to provide the services that you request and to communicate with you regarding such services; to respond to your inquiries and to contact you about your donation; to sent you notices or our e-newsletter; to provide and maintain our website; for internal business purposes such as identifying fundraising trends; and for other purposes to which you consent.
We will use your information to comply with the law or in the good faith belief that such action is necessary to conform to the requirements of law.
We will use the personal information to protect against potential fraud. We may verify with third parties the information collected in the course of processing a gift, event registration or other donation. If you use a credit or debit card on the website, we may use card authorization and fraud screening services to verify that your card information and address matches the information that you supplied to us and that the card being used has not been reported lost or stolen
You have the right to review information that we have collected about you. To review that information please contact the HELPS office in writing, via email at firstname.lastname@example.org or mail to HELPS International, 16610 Dallas Parkway, Suite 2025, Dallas, TX 75248.
To be removed from mailing lists or e-newsletter lists at any time, you may contact us at email@example.com.
DOCUMENT RETENTION AND DESTRUCTION POLICY
Effective August 14, 2017
HELPS International, Inc.’s Records Retention and Destruction Policy identifies the record retention responsibilities of staff, volunteers, members of the board of directors, and outsiders for maintaining and documenting the storage and destruction of the organization’s documents and
HELPS International’s staff, volunteers, members of the board of directors, committee members and outsiders (independent contractors via agreements with them) are required to honor the following rules:
a. Paper or electronic documents indicated under the terms for retention in the following section will be transferred and maintained by the Controller in Guatemala and the Accounting Manager in the U.S.
b. All other paper documents will be destroyed after five years;
c. All other electronic documents will be deleted from all individual computers, data bases, networks, and back-up storage after five years;
d. No paper or electronic documents will be destroyed or deleted if pertinent to any ongoing or anticipated government investigation or proceeding or private litigation (HELPS will check with legal counsel for any current or foreseen litigation if employees have not been notified); and
e. No paper or electronic documents will be destroyed or deleted as required to comply with government auditing standards (Single Audit Act).
This Policy was reviewed and approved by the HELPS International, Inc. Board of Directors on August 24, 2017. We reserve to change this policy from time to time. When we do, we will note the date of the last update on this page.
WHISTLEBLOWER PROTECTION POLICY
Effective August 14, 2017
HELPS International Incorporated (HELPS) 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 HELPS International Incorporated, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.
This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns internally so that HELPS International can address and correct inappropriate conduct and actions. It is the responsibility of all board members, officers, employees and volunteers to report concerns about violations of HELPS International’s code of ethics or suspected violations of law or regulations that govern HELPS International’s operations.
It is contrary to the values of HELPS International for anyone to retaliate against any board member, officer, employee or volunteer who in good faith reports an ethics violation, or a suspected violation of law, such as a complaint of discrimination, or suspected fraud, or suspected violation of any regulation governing the operations of HELPS. 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.
HELPS International has an open-door policy and suggests that employees share their questions, concerns, suggestions or complaints with their immediate supervisor. If you are not comfortable speaking with your immediate supervisor or you are not satisfied with your supervisor’s response, you are encouraged to speak with the Executive Director(s), or the organization’s founder and President. Supervisors and managers are required to report complaints or concerns about suspected ethical and legal violations in writing to HELPS International’s Executive Director(s), who have the responsibility to investigate all reported complaints. Employees with concerns or complaints may also submit their concerns in writing directly to their supervisor or the Executive Director(s).
HELPS International’s Executive Director(s) are responsible for ensuring that all complaints about unethical or illegal conduct are investigated and resolved. The Compliance Officer(s) will advise the Board of Directors of all complaints and their resolution and will report at least annually to the Treasurer or Chair of the Finance Committee on compliance activity relating to accounting or alleged financial improprieties.
WHISTLEBLOWER PROTECTION POLICY
Effective August 14, 2017
For Directors, Officers, and Members of a Committee with Board Delegated Powers
Article I – Purpose
The purpose of this Board Conflict of Interest policy is to protect HELPS International’s interests when it is contemplating entering into a transaction or arrangement that might benefit the private interests of an officer or director of HELPS or might result in a possible excess benefit transaction.
1. This policy is intended to supplement, but not replace, any applicable state and federal laws governing conflicts of interest applicable to nonprofit and charitable organizations.
2. This policy is also intended to identify “independent” directors.
Article II – Definitions
1. Interested person – Any director, principal officer, or member of a committee with governing board delegated powers, who has a direct or indirect financial interest, as defined below, is an interested person.
2. Financial interest – A person has a financial interest if the person has, directly or indirectly, through business, investment, or family:
a. An ownership or investment interest in any entity with which HELPS has a transaction or arrangement,
b. A compensation arrangement with HELPS or with any entity or individual with which HELPS has a transaction or arrangement, or
c. A potential ownership or investment interest in, or compensation arrangement with, any entity or individual with which HELPS is negotiating a transaction or arrangement.
Compensation includes direct and indirect remuneration, as well as gifts or favors that are not insubstantial.
A financial interest is not necessarily a conflict of interest. A person who has a financial interest may have a conflict of interest only if the Board or Executive Committee decides that a conflict of interest exists, in accordance with this policy.
3. Independent Director – A director shall be considered “independent” for the purposes of this policy if he or she is “independent” as defined in the instructions for the IRS 990 form or, until such definition is available, the director:
a. is not, and has not been for a period of at least three years, an employee of HELPS or any entity in which HELPS has a financial interest;
b. does not directly or indirectly have a significant business relationship with HELPS, which might affect independence in decision-making;
c. is not employed as an executive of another corporation where any of HELPS’s executive officers or employees serve on that corporation’s compensation committee; and
d. does not have an immediate family member who is an executive officer or employee of HELPS or who holds a position that has a significant financial relationship with HELPS.
Article III – Procedures
1. Duty to Disclose – In connection with any actual or possible conflict of interest, an interested person must disclose the existence of the financial interest and be given the opportunity to disclose all material facts to the Board or Executive Committee.
2. Recusal of Self – Any director may recuse himself or herself at any time from involvement in any decision or discussion in which the director believes he or she has or may have a conflict of interest, without going through the process for determining whether a conflict of interest exists.
3. Determining Whether a Conflict of Interest Exists – After disclosure of the financial interest and all material facts, and after any discussion with the interested person, he/she shall leave the Board or Executive Committee meeting while the determination of a conflict of interest is discussed and voted upon. The remaining Board or Executive Committee members shall decide if a conflict of interest exists.
4. Procedures for Addressing the Conflict of Interest
a. An interested person may make a presentation at the Board or Executive Committee meeting, but after the presentation, he/she shall leave the meeting during the discussion of, and the vote on, the transaction or arrangement involving the possible conflict of interest.
b. The Chairperson of the Board or Executive Committee shall, if appropriate, appoint a disinterested person or committee to investigate alternatives to the proposed transaction or arrangement.
c. After exercising due diligence, the Board or Executive Committee shall determine whether HELPS can obtain with reasonable efforts a more advantageous transaction or arrangement from a person or entity that would not give rise to a conflict of interest.
d. If a more advantageous transaction or arrangement is not reasonably possible under circumstances not producing a conflict of interest, the Board or Executive Committee shall determine by a majority vote of the disinterested directors whether the transaction or arrangement is in HELPS’ best interest, for its own benefit, and whether it is fair and reasonable. In conformity with the above determination, it shall make its decision as to whether to enter into the transaction or arrangement.
5. Violations of the Conflicts of Interest Policy
a. If the Board or Executive Committee has reasonable cause to believe a member has failed to disclose actual or possible conflicts of interest, it shall inform the member of the basis for such belief and afford the member an opportunity to explain the alleged failure to disclose.
b. If, after hearing the member’s response and after making further investigation as warranted by the circumstances, the Board or Executive Committee determines the member has failed to disclose an actual or possible conflict of interest, it shall take appropriate disciplinary and corrective action.
Article IV – Records of Proceedings
The minutes of the Board and all committees with board delegated powers shall contain:
a. The names of the persons who disclosed or otherwise were found to have a financial interest in connection with an actual or possible conflict of interest, the nature of the financial interest, any action taken to determine whether a conflict of interest was present, and the Board’s or Executive Committee’s decision as to whether a conflict of interest in fact existed.
b. The names of the persons who were present for discussions and votes relating to the transaction or arrangement, the content of the discussion, including any alternatives to the proposed transaction or arrangement, and a record of any votes taken in connection with the proceedings.
Article V – Compensation
a. A voting member of the Board who receives compensation, directly or indirectly, from HELPS for services is precluded from voting on matters pertaining to that member’s compensation.
b. A voting member of any committee whose jurisdiction includes compensation matters and who receives compensation, directly or indirectly, from HELPS for services is precluded from voting on matters pertaining to that member’s compensation.
c. No voting member of the Board or any committee whose jurisdiction includes compensation matters and who receives compensation, directly or indirectly, from HELPS, either individually or collectively, is prohibited from providing information to any committee regarding compensation.
Article VI – Annual Statements
1. Each director, principal officer and member of a committee with Board delegated powers shall annually sign a statement which affirms such person:
a. Has received a copy of the conflict of interest policy,
b. Has read and understands the policy
c. Has agreed to comply with the policy, and
d. Understands HELPS is charitable and in order to maintain its federal tax exemption it must engage primarily in activities which accomplish one or more of its tax-exempt purposes.
2. Each voting member of the Board shall annually sign a statement which declares whether such person is an independent director.
3. If at any time during the year, the information in the annual statement changes materially, the director shall disclose such changes and revise the annual disclosure form.
4. The Executive Committee shall regularly and consistently monitor and enforce compliance with this policy by reviewing annual statements and taking such other actions as are necessary for effective oversight.
Article VII – Periodic Reviews
To ensure HELPS operates in a manner consistent with charitable purposes and does not engage in activities that could jeopardize its tax-exempt status, periodic reviews shall be conducted. The periodic reviews shall, at a minimum, include the following subjects:
a. Whether compensation arrangements and benefits are reasonable, based on competent survey information (if reasonably available), and the result of arm’s length bargaining.
b. Whether partnerships, joint ventures, and arrangements with management organizations, if any, conform to HELPS’ written policies, are properly recorded, reflect reasonable investment or payments for goods and services, further charitable purposes and do not result in inurement or impermissible private benefit or in an excess benefit transaction.
Article VIII – Use of Outside Experts
When conducting the periodic reviews as provided for in Article VII, HELPS may, but need not, use outside advisors. If outside experts are used, their use shall not relieve the Board of its responsibility for ensuring periodic reviews are conducted.
Revision History by the HELPS Board:
Initial Conflict of Interest policy adopted January 1, 1991
Reviewed Conflict of Interest policy adopted August 24, 2017
*This policy is based on the IRS model Conflict of Interest policy, which is an attachment to Form 1023. It adds information needed to allow HELPS International to assess director independence in order to answer questions on Form 990.