Collection and Use of Information We collect two kinds of information: (i) site usage data, which is not individually identifiable, and (ii) individually identifiable information.
Site Usage Data Our Web server automatically recognizes and collects the domain name of each visitor to our Web site. We collect information about visitors to our site, such as the number of visitors, what pages they access and the length of their visit. This information is used in aggregate form in order to manage our Web site and improve its content. Visitors to RF-US’s website and other online projects are able to browse anonymously. We do log the IP addresses and originating domains of visitors to our site, and several times a year we examine this data to gain a general understanding of traffic on our site and what features on our site may be of special or particular interest. IP addresses are not linked to personally identifiable information.
Individually Identifiable Information We collect individually identifiable information about you when you choose to share information about yourself, for example, when you make a donation, request information or sign up to be an advocate. This information may include your postal or e-mail address, telephone number and issues of interest Individually identifiable information is used to provide you with information or to deliver the services you have requested. If you provide your postal address, telephone number or e-mail address to the RF-US online, you may receive periodic contacts from us. In the future, on certain parts of some of our site, only persons who provide us with the requested personally identifiable information may be able to use tools or otherwise participate in the site’s activities and offerings. We also may collect certain non-personally identifiable information when you visit some Web pages or fill o t forms such as the type of browser you are using (e.g., Google Chrome, Firefox, Safari), the type of operating system you are using, (e.g., Windows, Mac OS, Android) and the domain name of your Internet service provider (e.g., Optimum, Verizon, Comcast).
Community Tools Some portions of our site may provide special services and offer interactive tools that allow users to upload information for public consumption. In some cases, users can share experiences, give advice and connect with others. Please remember hat chat rooms, message boards and personal pages are public forums and personal information disclosed there will be seen by others. In addition, please exercise caution when posting information or providing information about yourself to others, especially contact information, such as street address, telephone number or email address.
Cookies We use a technology called a “cookie” to recognize you when you return to our site. Cookies help make your visit more convenient and enjoyable. However, if you wish, you may direct your browser to reject cookies.
Sharing Information with Others RF-US respects and protects the privacy of our volunteers, donors, supporters, and patrons, as well as of individuals visiting our web site and other online projects. We do not sell, rent, share, or exchange our e-mail lists. RF-US maintains a database that includes contact information about our volunteers, donors, supporters, and patrons. Our database will not be sold, rented, shared, exchanged, or be used for anything other than RF-US activity.
Email Communications We occasionally send out an email newsletter and direct email communications to RF-US site visitors to highlight news, information and opportunities available from the RF-US. You can elect not to receive communications from us, by noting your preference in response to communications from us. In addition, all RF-US a-newsletters and direct email communications have easy-to-follow unsubscribe instructions a, the bottom of each email.
Children Online Protecting the privacy of the very young is especially important. For that reason, we adhere to the 11998 Children’s Online Privacy Protection Act (COPPA). (For more information, visit the Federal Trade Commission’s COPPA site at http://www.ftc.gov/bcp/online/edcams/kidzprivacy/adults.htm.) Whenever we collect or maintain information at our Web site from those we actually know are under 13, we obtain parental consent before any personally identifiable information is collected, used or disclosed.
Security In order to prevent unauthorized access and protect our users’ personal information, we strive to maintain physical, electronic and administrative safeguards to secure the information we collect online. For example, online shopping and contributions are processes using a secure server. This secure server software, SSL (Secure Sockets Layer), encrypts all information you input before it is sent to us. Furthermore, all oft e customer transactional data we collect is protected against unauthorized access with the use of digital certificates.
Questions or Concerns Whenever you have any questions or concerns, please contact us through any medium you prefer. Your complete satisfaction in dealing with the RF-US is important to us. If you have questions about the RF-US’s privacy practices described above, or RF-US generally, please send an e-mail message to email@example.com. Thank you. The RF-US follows the online Privacy Guidelines and the Guidelines on Ethical Business Practice of The Direct Marketing Association (DMA). For more information on these Guidelines visit the DMA at http://the-dma.org.
Conflict of Interest Policy
Article I — Purpose The purpose of this policy is to protect the interest of Rainforest Foundation — US (“RF- US”), a tax-exempt organization, when it is contemplating entering into a transaction or arrangement that might benefit the private interest of an RF-US officer or director or might result in a possible excess benefit transaction. This 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
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.
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 the RF-US has a transaction or arrangement;
b. A compensation arrangement with the RF-US or with any entity or individual with which the RF-US 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 RF-US 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. Under Article Ill, Section 2, a person who has a financial interest may have a conflict of interest only if the appropriate governing board or committee decides that a conflict of interest exists.
Article Ill — 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 governing 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, he/she shall leave the governing 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 governing board or 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 governing 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 governing board or committee shall determine whether the RF-US 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 governing board or committee
shall determine by a majority vote of the disinterested directors whether the transaction
or arrangement is in the RF-US’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 governing board or 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
b. If, after hearing the member’s response and after making further investigation as warranted by the circumstances, the governing board or 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 governing 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 governing 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 governing board who receives compensation, directly or indirectly, from the RF-US 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 RF-US for services is precluded from voting on matters pertaining to that member’s compensation.
c. No voting member of the governing board or any committee whose jurisdiction includes compensation matters and who receives compensation, directly or indirectly, from the RF-US, either individually or collectively, is prohibited from providing information to any committee regarding compensation.
Article VI — Annual Statements Each director, principal officer and member of a committee with governing board delegated powers shall annually sign a statement which affirms such person:
a. Has received a copy of the conflicts of interest policy,
b. Has read and understands the policy,
c. Has agreed to comply with the policy, and
d. Understands that RF-US is a charitable organization and that in order to maintain its
federal tax exemption it must engage primarily in activities which accomplish one or more of its tax-exempt purposes.
Article VII — Periodic Reviews To ensure that RF-US 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 RF-US’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, RF-US may, but need not, use outside advisors. If outside experts are used, their use shall not relieve the governing board of its responsibility for ensuring that periodic reviews are conducted.
If RFUS receives reports of well-grounded suspicions of corruption and other misconduct, whether from within the organization or outside it, the appropriate program staff deals with it initially. Should the case call for it, an in-depth investigation is carried out, with outside assistance (for example a local auditor) if needed. Should a whistle-blower not be in a position to report to the Program Coordinator, or choose to remain anonymous, for explicit and reasonable grounds, he/she may alternatively direct his/her report to: firstname.lastname@example.org, and it will be addressed by the Executive Director
The report should include:
- The full name and position of the whistle-blower (unless he/she wants to remain anonymous – if so, reasonable grounds must be given);
- The organization where the circumstances occurred;
- The period, and date and time if applicable, of the circumstances concerned;
- The precise description of the circumstances (i.e. what has been witnessed, and where);
- The identity and contact details of other witnesses, if applicable;
- Any known previous circumstances involving the same person(s).
The staff of a partner organization has the obligation to report suspected corruption, and has the option to bypass immediate superiors, even go outside their local unit, directly to top management or RFUS.
RFUS staff has the obligation to report suspected corruption to their immediate superiors. An incident reporting system aims to track a wider range of incidents that a staff member may experience, such as assault, theft, or being asked to pay a bribe, which do not necessarily require employee protection or confidentiality. Recording of all incidents is important as it serves not only to account for potential financial losses, but also to learn and improve existing prevention and risk mitigation measures – and not only in regard to corruption.
The identity of whistle-blowers will not be revealed, if explicitly requested so or when anonymity applies. Reports will be dealt with confidentially. In the event the identity of a whistle-blower is uncovered, and implies serious risks of retaliation, RFUS commits to take appropriate measures, and to the extent possible, to ensure the safety of the whistle-blower.
Should RFUS staff face threats as a result of a corruption case, RFUS will ensure his/her protection and safety, including by making necessary adjustments to his/her responsibilities and tasks.
All reports of well-grounded suspicions of corruption will be treated immediately. The whistle-blower should get confirmation of reception of his/her report within reasonable time. RFUS management will decide who is to be involved in dealing with the case and what measures should be taken, according to the type of case and who it involves. All documents relating to the case are to be registered and filed in RFUS’s e-archives, with restricted access to staff members involved in dealing with the case.
The RFUS Anti-Corruption Policy will be translated to Portuguese and Spanish, and attached to contracts with partner organizations, circulated within partner organizations, and directly explained by RFUS staff to members of the organizations’ technical and decision-making bodies, to ensure the latter are informed about RFUS’s whistle-blowing mechanism.
The board develops a comparative base for the evaluation of executive compensation that approximates our organization. This is then reviewed by the board in determination of any annual salary adjustments from the perspective of market competitiveness and prior year performance.
Record Retention Policy
Rainforest Foundation US 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:
- Paper or electronic documents indicated under the terms for retention in the following section will be transferred and maintained by the Office Manager;
- All other paper documents will be destroyed after three years;
- All other electronic documents will be deleted from all individual computers, data bases, networks, and back-up storage after one year;
- No paper or electronic documents will be destroyed or deleted if pertinent to any ongoing or anticipated government investigation or proceeding or private litigation; and
- No paper or electronic documents will be destroyed or deleted as required to comply with government auditing standards.
The following table indicates the Rainforest Foundation US’ document retention policy. In addition, Rainforest Foundation US will keep documents longer in order to comply with individual grant award requirements.
|Type of Document||Minimum Requirement|
|Accounts payable ledgers and schedules||7 years|
|Bank reconciliations||2 years|
|Bank Statements||3 years|
|Checks (for important payments and purchases)||Permanently|
|Contracts, mortgages, notes, and leases (expired)||7 years|
|Contracts (still in effect)||Contract Period|
|Correspondence (general)||2 years|
|Correspondence (legal and important matters)||Permanently|
|Correspondence (with customers and vendors)||2 years|
|Deeds, mortgages, and bills of sale||Permanently|
|Duplicate deposit slips(general)||2 years|
|Employment Applications||3 years|
|Expense analyses/expense distribution schedules||7 years|
|Year-end financial statements||Permanently|
|Insurance records, current accident reports, claims, policies, and so on (active and expired)||Permanently|
|Internal audit reports||3 years|
|Inventory records for products, materials, and supplies||3 years|
|Invoices (to customers, from vendors)||7 years|
|Minute books, bylaws, and charter||Permanently|
|Patents and related papers||Permanently|
|Payroll records and summaries||7 years|
|Personnel files (terminated employees)||7 years|
|Retirement and pension records||Permanently|
|Tax returns and worksheets||Permanently|
|Trademark registrations and copyrights||Permanently|
|Withholding tax statements||7 years|