Code of Ethics
I. Personal and Professional Integrity
All Staff, Board Members, and Volunteers of the Hand Up Network act with honesty, integrity and
openness in all their dealings as representatives of the Hand Up Network. The Hand Up Network
promotes a working environment that values respect, fairness, and integrity.
The Hand Up Network has a clearly stated mission and purpose, approved by the Board of
Directors, in pursuit of the public good. All of its programs support that mission and all who work
for or on behalf of the Hand Up Network understand and are loyal to that mission and purpose.
The Hand Up Network has a Board of Directors that is responsible for setting the mission and
strategic direction of the Hand Up Network. The CEO is responsible for the daily execution and
operation of the ministry. The Board of Directors provides oversight of the CEO, finances,
operations, and policies of the Hand Up Network.
IV. Legal Compliance
The Hand Up Network is knowledgeable of and complies with all laws and regulations of the State
of Texas and United States of America.
The Hand Up Network and its subsidiaries manage its funds in a transparent and responsible
manner at all times.
V. Openness and Disclosure
The Hand Up Network provides comprehensive and timely information to its supporters, and
volunteers and seeks to respond in a timely manner to reasonable requests for information. All
information about the Hand Up Network will fully and honestly reflect the policies and practices of
the Hand Up Network. Basic informational data about the Hand Up Network, such as the Form 990,
reviews and compilations, and financial statements will be posted on the Hand Up Network’s
website or otherwise available to the public. All solicitation materials accurately represent the Hand
Up Network’s policies and practices and will reflect the dignity of program beneficiaries. All financial
and Hand Up Network program reports will be complete and accurate in all material respects.
VI. Program Evaluation
The Hand Up Network regularly reviews program effectiveness and has mechanisms to incorporate
lessons learned into future programs. The Hand Up Network is committed to improving program
and Hand Up Network’s effectiveness and develops mechanisms to promote learning from its
activities and the field. The Hand Up Network is responsive to changes in its field of activity and is
responsive to the needs of its constituencies.
VII. Fundraising & Volunteer Information
Hand Up Network raises funds from the public or from donor institutions through requests that are
truthful in their solicitation materials. Hand Up Network respects the privacy concerns of individual
donors and expend funds consistent with donor intent. HUN will not share Donor and Volunteer
Information with outside agencies unless approval is provided in advance. Hand Up Network
discloses important and relevant information to potential donors for its services and programs.
HUN does not knowingly allow other organizations or services to track individual visitors to our website. Our site captures limited information about visits to our site, but we use this information internally to analyze general traffic patterns (e.g., what pages are most/least popular), perform routine system maintenance, and develop more opportunities for our supporters to engage with the Ministry. HUN does not sell, rent, or otherwise share any personal information collected via emails to sent to HUN. HUN only uses the information submitted to interact and respond to HUN related activities. HUN does not sell, rent or otherwise share any personal information collected from subscriptions to our website, e-newsletters, etc.
This website may contain links to other sites. Please be aware that HUN is not responsible for the privacy practices of such other sites. This privacy statement applies solely to information collected by this website.
Conditions of Use and Revisions
CONFLICT OF INTEREST POLICY
Article I Purpose
The purpose of this Conflict of Interest Policy (this “Conflict Policy”) is to protect the interests of the HAND UP NETWORK (the “Corporation”) when it is contemplating entering into a transaction or arrangement that might benefit the private interest of an officer or director of the Corporation or other Interested Person (as defined below) or might result in a possible excess benefit transaction under federal tax laws and regulations. This Conflict Policy is intended to supplement but not replace any applicable state and federal laws governing conflict of interest applicable to nonprofit and charitable organizations.
Article II Definitions
1. “Family Member” means a person’s spouse, parents/parents-in-law, ancestors, brothers and sisters (whole or half blood), children (whether natural or adopted), grandchildren, great-grandchildren, and spouses of brothers, sisters, children, grandchildren and great grandchildren.
2. A person has a financial interest (“Financial Interest”) if the person or any Family Member of such person has, directly or indirectly, through business, investment or otherwise: (a) An ownership or investment interest in any entity with which the Corporation has a transaction or arrangement, (b) A compensation arrangement with the Corporation or with any entity or individual with which the Corporation has a transaction or arrangement, or (c) A potential ownership or investment interest in, or compensation arrangement with, any entity or individual with which the Corporation is negotiating a transaction or arrangement. Compensation includes direct and indirect remuneration as well as gifts or favors that are not insubstantial. 2 A Financial Interest is not necessarily a conflict of interest. Under Article III, Section 2, an Interested Person may have a conflict of interest only if the Board of Directors (the “Board”) or appropriate committee, as the case may be, decides that a conflict of interest exists.
3. “Interested Person” means any director or officer of the Corporation or any member of a committee with Board delegated powers who has a Financial Interest.
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 directors and members of committees with Board delegated powers considering the proposed transaction or arrangement.
2. 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, the Interested Person shall leave the Board or committee meeting while the determination of a conflict of interest is discussed and voted upon. The remaining Board or committee members shall decide if a conflict of interest exists.
3. Procedures for Addressing the Conflict of Interest. (a) An Interested Person may make a presentation at the Board or committee meeting, but after the presentation, the Interested Person 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 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 committee shall determine whether the Corporation 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 committee shall determine by a majority vote of the disinterested directors present whether the transaction or arrangement is in the Corporation’s 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.
4. Violations of the Conflicts of Interest Policy. (a) If the Board or committee has reasonable cause to believe an Interested Person has failed to disclose actual or possible conflicts of interest, it shall inform the 3 Interested Person of the basis for such belief and afford the Interested Person an opportunity to explain the alleged failure to disclose. (b) If, after hearing the Interested Person’s response and after making further investigation as warranted by the circumstances, the Board or committee determines the Interested Person 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 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 the Corporation 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 the Corporation 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 the Corporation, either individually or collectively, is prohibited from providing information to the Board or any committee regarding compensation.
Article VI Annual Statements
Each director, principal officer and member of a committee with Board delegated powers shall annually sign a statement that affirms such person: (a) has received a copy of this Conflict Policy, 4 (b) has read and understands this Conflict Policy, (c) has agreed to comply with this Conflict Policy, and (d) understands the Corporation is charitable and in order to maintain its federal tax exemption, it must engage primarily in activities that accomplish one or more of its tax-exempt purposes.
Article VII Periodic Reviews
To ensure the Corporation 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, and the result of arm’s length bargaining, (b) Whether partnerships, joint ventures, and arrangements with management organizations conform to the Corporation’s written policies, are properly recorded, reflect reasonable investment or payments for goods and services, further charitable purposes and do not result in inurement, 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, the Corporation 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 conduct.
THE DESIGNATED FUNDS POLICY
This policy sets forth the conditions under which the Hand Up Network may accept designated gifts. Subject to this policy, the Hand Up Network may accept donations from those that wish to donate/support the work of this Hand Up Network.
The Hand Up Network desires to be careful to assure it is not involved in creating a tax deductible contribution for some purpose that would not otherwise qualify for a tax deduction. For instance, HUN wants to make sure that a donation to benevolence, missions, or ministries is for the purpose of furthering the work of the Hand Up Network (and not a non-deductible gift to an individual through the organization). For this reason HUN has set forth guidelines under which the Hand Up Network, as a tax exempt organization, can accept designated gifts
1. The designation must be for an approved project, program or the Hand Up Network (HUN).
2. HUN must maintain discretion and control over all contributions and the ultimate determination of how all donated funds are allocated. The Hand Up Network will make every effort to honor a donor’s designation, however contributions become the property of the Hand Up Network and as such the Hand Up Network has the discretion to determine how best to use all contributions to carry out our mission and purpose.
3. Designated gifts cannot be given to forward to specific organizations unless the management of HUN determines that this organization is a strategic partner and helping to execute the programs of the Hand Up Network.
4. Gifts designated for individuals or designated for the benefit of a specific individuals are not tax deductible contributions and the Hand Up Network will not accept such gifts.
5. HUN cannot accept gifts with verbal designations. Designations must be in writing in an accompanying memorandum or note or else indicated on the check.
6. HUN must, by law, reserve the right to disregard designations despite the directive by the individual donor.
7. All funds raised by an individual to participate on a HUN Project, Team, or Program are donations to HUN and once approved expenses related to that Project or Program are determined, the balance of those funds go to the General Hand Up Network Fund.
The Hand Up Network (HUN) Code of Ethics and Conduct (“Code”) requires directors, officers
and employees to observe high moral standards of business and personal ethics in the conduct
of their duties and responsibilities. As employees and representatives of the Hand Up Network,
we must practice honesty and integrity in fulfilling our responsibilities and comply with all
applicable laws and regulations in each country we serve.
It is the responsibility of all directors, officers, and employees to comply with the Code and to
report violations or suspected violations in accordance with the Whistleblower Policy.
No director, officer or employee who in good faith reports a violation of the Code 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 Whistle blower Policy is intended to encourage and
enable employees and others to raise serious concerns within HUN prior to seeking resolution
outside the Organization.
The Code addresses HUN’s open door policy and 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 the CEO or to
anyone in management whom you are comfortable in approaching. Supervisors and managers
are required to report suspected violations of the Code of Conduct to HUN’s CEO directly, who
has specific and exclusive responsibility to investigate all reported violations. For suspected
fraud individuals should contact the CEO or Chairman of the Board.
Compliance Officer – CEO
The CEO is responsible for investigating and resolving all reported complaints and allegations concerning violations of the Code and, at his/her discretion, and shall advise the Chairman of the Finance and/or the Finance committee. The Compliance Officer has direct access to the Finance committee of the board of directors and is required to report to the Finance committee at least annually on compliance activity. HUN’s Finance Committee Chairman is the chair of the Finance committee.
Accounting and Financing Matters
The Finance Committee of the board of directors shall address all reported concerns or
complaints regarding corporate accounting practices, internal controls or Financing. The
Compliance Officer shall immediately notify the Finance committee of any such complaint and
work with the committee until the matter is resolved.
Acting in Good Faith
Anyone filing a complaint concerning a violation or suspected violation of the Code must be
acting in good faith and have reasonable grounds for believing the information disclosed
indicates a violation of the Code. 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
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
Handling of Reported Violations
The Compliance Officer will notify the sender and acknowledge receipt 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.
DOCUMENT DESTRUCTION AND RETENTION POLICY
POLICY 1. Policy and Purposes
This Policy represents the policy of the HAND UP NETWORK (the “organization”) with respect to the retention and destruction of documents and other records, both in hard copy and electronic media (which may merely be referred to as “documents” in this Policy). Purposes of the Policy include (a) retention and maintenance of documents necessary for the proper functioning of the organization as well as to comply with applicable legal requirements; (b) destruction of documents which no longer need to be retained; and (c) guidance for the Board of Directors, officers, staff and other constituencies with respect to their responsibilities concerning document retention and destruction. Notwithstanding the foregoing, the organization reserves the right to revise or revoke this Policy at any time.
- 2.1 Responsibilities of the Administrator.
- The organization’s CEO/PRESIDENT and CFO/BOOKEEPER shall be the administrator (“Administrator”) in charge of the administration of this Policy. The Administrator’s responsibilities shall include supervising and coordinating the retention and destruction of documents pursuant to this Policy and particularly the Document Retention Schedule included below. The Administrator shall also be responsible for documenting the actions taken to maintain and/or destroy organization documents and retaining such documentation. The Administrator may also modify the Document Retention Schedule from time to time as necessary to comply with law and/or to include additional or revised document categories as may be appropriate to reflect organizational policies and procedures. The Administrator is also authorized to periodically review this Policy and Policy compliance with legal counsel and to report to the Board of Directors as to compliance. The Administrator may also appoint one or more assistants to assist in carrying out the Administrator’s responsibilities, with the Administrator, however, retaining ultimate responsibility for administration of this Policy.
- 2.2 Responsibilities of Constituencies.
- This Policy also relates to the responsibilities of board members, staff, volunteers and outsiders with respect to maintaining and documenting the storage and destruction of the organization’s documents. The Administrator shall report to the Board of Directors (the board members acting as a body), which maintains the ultimate direction of management. The organization’s staff shall be familiar with this Policy, shall act in accordance therewith, and shall assist the Administrator, as requested, in implementing it. The responsibility Hand Up Network Document Retention and Destruction Policy 2/2019 of volunteers with respect to this Policy shall be to produce specifically identified documents upon request of management, if the volunteer still retains such documents. In that regard, after each project in which a volunteer has been involved, or each term which the volunteer has served, it shall be the responsibility of the Administrator to confirm whatever types of documents the volunteer retained and to request any such documents which the Administrator feels will be necessary for retention by the organization (not by the volunteer). Outsiders may include vendors or other service providers. Depending upon the sensitivity of the documents involved with the particular outsider relationship, the organization, through the Administrator, shall share this Policy with the outsider, requesting compliance. In particular instances, the Administrator may require that the contract with the outsider specify the particular responsibilities of the outsider with respect to this Policy.
3. Suspension of Document Destruction; Compliance.
The organization becomes subject to a duty to preserve (or halt the destruction of) documents once litigation, an audit or a government investigation is reasonably anticipated. Further, federal law imposes criminal liability (with fines and/or imprisonment for not more than 20 years) upon whomever “knowingly alters, destroys, mutilates, conceals, covers up, falsifies, or makes a false entry in any record, document, or tangible object with the intent to impede, obstruct, or influence the investigation or proper administration of any matter within the jurisdiction of any department or agency of the United States … or in relation to or contemplation of any such matter or case.” Therefore, if the Administrator becomes aware that litigation, a governmental audit or a government investigation has been instituted, or is reasonably anticipated or contemplated, the Administrator shall immediately order a halt to all document destruction under this Policy, communicating the order to all affected constituencies in writing. The Administrator may thereafter amend or rescind the order only after conferring with legal counsel. If any board member or staff member becomes aware that litigation, a governmental audit or a government investigation has been instituted, or is reasonably anticipated or contemplated, with respect to the organization, and they are not sure whether the Administrator is aware of it, they shall make the Administrator aware of it. Failure to comply with this Policy, including, particularly, disobeying any destruction halt order, could result in possible civil or criminal sanctions. In addition, for staff, it could lead to disciplinary action including possible termination.
4. Electronic Documents; Document Integrity. Documents in electronic format shall be maintained just as hard copy or paper documents are, in accordance with the Document Retention Schedule. Due to the fact that the integrity of electronic documents, whether with respect to the ease of alteration or deletion, or otherwise, may come into question, the Administrator shall attempt to establish standards for document integrity, including guidelines for handling electronic files, backup procedures, archiving of documents, and regular checkups of the reliability of the system; provided, that such standards shall only be implemented to the extent that they are reasonably attainable considering the resources and other priorities of the organization.
It shall be the responsibility of the Administrator, after consultation with counsel, to determine how privacy laws will apply to the organization’s documents from and with respect to employees and other constituencies; to establish reasonable procedures for compliance with such privacy laws; and to allow for their audit and review on a regular basis. Hand Up Network Document Retention and Destruction Policy 2/2019
6. Emergency Planning.
Documents shall be stored in a safe and accessible manner. Documents which are necessary for the continued operation of the organization in the case of an emergency shall be regularly duplicated or backed up and maintained in an off-site location. The Administrator shall develop reasonable procedures for document retention in the case of an emergency.
7. Document Creation and Generation.
The Administrator shall discuss with staff the ways in which documents are created or generated. With respect to each employee or organizational function, the Administrator shall attempt to determine whether documents are created which can be easily segregated from others, so that, when it comes time to destroy (or retain) those documents, they can be easily culled from the others for disposition. For example, on an employee-by-employee basis, are e-mails and other documents of a significantly non-sensitive nature so that they might be deleted, even in the face of a litigation hold with respect to other, more sensitive, documents? This dialogue may help in achieving a major purpose of the Policy — to conserve resources — by identifying document streams in a way that will allow the Policy to routinely provide for destruction of documents. Ideally, the organization will create and archive documents in a way that can readily identify and destroy documents with similar expirations. Hand Up Network Document Retention and Destruction Policy 2/2019
8. Document Retention Schedule.
[Periods are suggested but are not necessarily a substitute for counsel’s own research and determination as to appropriate periods.] Document Type Retention Period Accounting and Finance Accounts Payable 7 years Accounts Receivable 7 years Annual Financial Statements and Audit Reports Permanent Bank Statements, Reconciliations & Deposit Slips 7 years Canceled Checks – routine 7 years Canceled Checks – special, such as loan repayment Permanent Credit Card Receipts 3 years Employee/Business Expense Reports/Documents 7 years General Ledger Permanent Interim Financial Statements 7 years Contributions/Gifts/Grants Contribution Records Permanent Documents Evidencing Terms of Gifts Permanent Grant Records 7 yrs after end of grant period Corporate and Exemption Articles of Incorporation and Amendments Permanent Bylaws and Amendments Permanent Minute Books, including Board & Committee Minutes Permanent Annual Reports to Attorney General & Secretary of State Permanent Other Corporate Filings Permanent IRS Exemption Application (Form 1023 or 1024) Permanent IRS Exemption Determination Letter Permanent State Exemption Application (if applicable) Permanent State Exemption Determination Letter (if applicable) Permanent Licenses and Permits Permanent Employer Identification (EIN) Designation Permanent Correspondence and Internal Memoranda Hard copy correspondence and internal memoranda relating to a particular document otherwise addressed in this Schedule should be retained for the same period as the document to which they relate. Hard copy correspondence and internal memoranda relating to routine matters with no lasting significance Two years Correspondence and internal memoranda important to the organization or having lasting significance Permanent, subject to review Hand Up Network Document Retention and Destruction Policy 2/2019 Electronic Mail (E-mail) to or from the organization Electronic mail (e-mails) relating to a particular document otherwise addressed in this Schedule should be retained for the same period as the document to which they relate, but may be retained in hard copy form with the document to which they relate. E-mails considered important to the organization or of lasting significance should be printed and stored in a central repository . Permanent, subject to review E-mails not included in either of the above categories 12 months Electronically Stored Documents Electronically stored documents (e.g., in pdf, text or other electronic format) comprising or relating to a particular document otherwise addressed in this Schedule should be retained for the same period as the document which they comprise or to which they relate, but may be retained in hard copy form (unless the electronic aspect is of significance). Electronically stored documents considered important to the organization or of lasting significance should be printed and stored in a central repository (unless the electronic aspect is of significance). Permanent, subject to review Electronically stored documents not included in either of the above categories Two years Employment, Personnel and Pension Personnel Records 10 yrs after employment ends Employee contracts 10 yrs after termination Retirement and pension records Permanent Insurance Property, D&O, Workers’ Compensation and General Liability Insurance Policies Permanent Insurance Claims Records Permanent Legal and Contracts Contracts, related correspondence and other supporting documentation 10 yrs after termination Legal correspondence Permanent Management and Miscellaneous Strategic Plans 7 years after expiration Disaster Recovery Plan 7 years after replacement Policies and Procedures Manual Current version with revision history Hand Up Network Document Retention and Destruction Policy 2/2019 Property – Real, Personal and Intellectual Property deeds and purchase/sale agreements Permanent Property Tax Permanent Real Property Leases Permanent Personal Property Leases 10 years after termination Trademarks, Copyrights and Patents Permanent Tax Tax exemption documents & correspondence Permanent IRS Rulings Permanent Annual information returns – federal & state Permanent Tax returns Permanent ********* HAND UP NETWORK Document Retention & Destruction Final 2/2019
EXECUTIVE COMPENSATION POLICY
- A. To assure that the Hand Up Network (HUN) is able to retain high quality executive leadership of the Hand Up Network by providing reasonable compensation.
- B. To assure that decisions regarding executive compensation are made through a process free of potential conflicts of interest.
II. Persons whose compensation is subject to this policy
- A. The President/CEO compensation shall be reviewed under this policy.
- B. If at some point in the future HUN employs a person performing the services of chief financial officer, that person’s compensation shall be reviewed in accordance with this policy.
III. Executive Committee
- A. The Executive Committee of the board is authorized to make recommendations to the Board regarding executive compensation.
- B. Only those members of the Executive Committee who are free of conflicts of interest may be involved in evaluation of executive compensation.
- C. The Executive Committee should, to the extent reasonably available, rely upon appropriate data as to comparability prior to making its recommendation, and shall contemporaneously place such data and other reasons for its recommendation in the minutes.
- 1. If the Executive Committee does not have data as to comparability, it shall document any other bases for believing the proposed compensation is reasonable.
- D. The Executive Committee shall make this determination at least once annually.
IV. Final Board Action
- A. Only those directors who are free of conflicts of interest may vote on executive compensation.
- B. The Board shall review and approve executive compensation, after a review of comparability data or other evidence that compensation is reasonable, and shall contemporaneously substantiate its deliberation and decision in the minutes.
Adopted by the Board on February 5, 2019.