Purpose: 

The purpose of this Whistleblower Policy is to encourage and enable employees, volunteers, board members, and other stakeholders of Esperanto-USA to report any violations or suspected violations of laws, regulations, or policies without fear of retaliation.

Scope: 

This policy applies to all employees, officers, directors, volunteers, and consultants.

Policy:

1. Reporting Violations:
   1. Any individual who becomes aware of illegal or unethical behavior within the organization is encouraged to report the matter to the Executive Director, President, or another board member.
   2. Reports can be made anonymously if desired, and confidentiality will be maintained to the extent possible.
2. No Retaliation:
   1. Esperanto-USA will not tolerate retaliation against anyone who in good faith reports a violation or assists in the investigation of a reported violation. Retaliation includes termination, demotion, harassment, or any adverse action against the whistleblower.
3. Investigation:
   1. All reports will be investigated promptly and thoroughly. The findings will be communicated to the Board of Directors, and appropriate action will be taken based on the findings.
4. False Allegations:
   1. Deliberately false or malicious reports will not be tolerated and may result in disciplinary action.

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Purpose: 

This Document Retention and Destruction Policy is designed to ensure that Esperanto-USA properly maintains important records and documents in compliance with legal requirements and to promote the timely destruction of obsolete records.

Policy:

1. Retention Periods:
   1. Financial Records (e.g., budgets, financial statements, tax returns): Retain for at least 7 years.
   2. Governance Documents (e.g., board minutes, by-laws, policies): Retain permanently.
   3. Contracts and Legal Agreements: Retain for at least 7 years after the contract expires.
   4. Employee and Payroll Records: Retain for at least 7 years after termination.
   5. Donor Records: Retain for at least 7 years. 
   6. Restricted donation and bequest instructions/conditions: Retained for at least the lifetime of the endowment or term of the instructions/conditions. May be retained longer for historical reasons.
   7. Correspondence (emails, letters): Casual correspondences not related to official business and email notifications from systems, can be retained (or deleted/destroyed) at the will of the recipient. Correspondences containing an official decision or discussion about the above categories should be retained per their guidelines.
      1. Example of items that can be deleted: emails discussing a project that don’t contain a financial approval or decision; emails of a personal nature; emails from Google Docs summarizing document changes so long as the document itself is retained per the above guidelines.
2. Electronic Records:
   1. Electronic documents, including emails, should be retained and destroyed in accordance with this policy.
3. Document Destruction:
   1. Documents should be destroyed after the expiration of the relevant retention period. Paper documents will be shredded, and electronic documents will be permanently deleted.
4. Litigation Holds:
   1. In the event of litigation or governmental investigation, all relevant documents must be retained and may not be destroyed until the matter is resolved.
5. Compliance:
   1. Failure to comply with this policy may result in disciplinary action. The Board of Directors will review compliance annually.

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Purpose: 

The Conflict of Interest Policy is designed to help board members, officers, and employees of Esperanto-USA identify situations that present potential conflicts of interest and to provide a process for addressing such conflicts.

Policy:

1. Definition of Conflict of Interest:
   1. A conflict of interest arises when an individual’s personal interests interfere, or appear to interfere, with the interests of Esperanto-USA. This includes financial interests or affiliations with vendors, donors, or other non-profits.
2. Duty to Disclose:
   1. Board members, officers, and employees must disclose any personal (friends, acquaintances, non-legal “family”), financial (stake or ownership in a business), or familial (in any way considered part of one’s legal family) interest in a transaction, contract, or other decision involving Esperanto-USA.
      1. Example: if board member A is recommending that her friend, relative, acquaintance, or own business be used to perform printing services for “Usona Esperantisto”, the board member would need to disclose that there is a relationship between them and the 3rd party and they would have to recuse themselves from voting on using the service. 
      2. Example: the CO of E-USA needs an accountant to perform tax services. Her niece just graduated from college with an accounting degree and would like to perform the service. The CO should remit the decision to the Board, explain that there is a familial relationship between the CO and the niece, and defer to the Board’s decision on whether or not to allow the niece to perform that service.
3. Recusal from Decision-Making:
   1. Individuals with a conflict of interest shall not participate in discussions or votes related to the matter in which they have an interest.
4. Annual Statements:
   1. All board members, officers, and key employees will annually complete a disclosure form identifying any potential conflicts of interest.
5. Violations of the Policy:
   1. If the board of Esperanto-USA determines that a conflict of interest was not disclosed or handled appropriately, it may take disciplinary action, including removal from the Board or termination of employment.

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