AICF adheres to the best practices of not-for-profit governance and operates with full transparency that allows its supporters to be confident that their contributions are being used effectively. AICF welcomes inquiries by current and potential supporters to learn more about its programs and operations. Please call our offices at (212) 557-1600.
Should any person know or have a reasonable belief that persons associated with the Foundation plan to engage or have engaged in illegal or unethical conduct in connection with the finances or other aspect of the Foundation’s operations, that person should immediately file a complaint with the Executive Director (a “Complaint”). Employees of the Foundation may submit Complaints on a confidential, anonymous basis. If the Complaint concerns the Executive Director or the complainant is not comfortable reporting to the Executive Director, then the complainant should notify the President, Treasurer or other Officer or Director instead.
The Executive Director, President, Treasurer or other Officer or Director will report all Complaints to the chair of the Finance Committee, Executive Committee or a member of the Board, or if the chair is the subject of the Complaint, to another member of the committee, prior to the next scheduled meeting. Reports to the chair or other committee member or to a Director will include a copy of the Complaint, its date, nature and source (unless the complainant is an employee who has requested confidentiality and/or anonymity), how it was communicated, whether the Executive Director or President, Treasurer or other Officer or Director, regards the Complaint as credible, and proposals to address it. The chair or other committee member will promptly report the Complaint to the full committee, except that the Complaint will not be shared with an individual who is the subject of the Complaint. Likewise, if a Complaint is reported to a Director, she or he will promptly report the Complaint to the full Board, except to any individual who is the subject of the Complaint. All credible allegations will be followed up promptly, with a further investigation conducted if needed to resolve disputed facts. In conducting its investigations, the Foundation will respect an employee’s request for confidentiality and/or anonymity and will strive to keep the identity of other complainants as confidential as possible, consistent with the need to conduct an adequate review and investigation.
The committee to which a Complaint has been reported will inform the Board if any Complaint is confirmed, or if the committee otherwise believes that the Board should be made aware of the situation. The committee will have ultimate authority over the treatment of any Complaints reported to it, subject to the Board’s oversight. The committee or, in the case of Complaints reported to the full Board, the Board will ensure that records of all Complaints are maintained in accordance with the Foundation’s document retention policy.
The Foundation will take appropriate action in response to any Complaints, including, but not limited to, disciplinary action (up to and including termination) against any person who, in the Foundation’s assessment, has engaged in misconduct and reporting such misconduct to the relevant civil or criminal authorities as required by law.
The Foundation will not knowingly, with the intent to retaliate, take any action harmful to any person, including interference with lawful employment or livelihood, for reporting a Complaint in good faith pursuant to this policy or to law enforcement officers, governmental agencies or bodies, or persons with supervisory authority over the complainant. Likewise, there will be no punishment or other retaliation for providing information regarding a Complaint in good faith to, or otherwise assisting in any investigation regarding a Complaint conducted by, the Foundation, law enforcement officers, governmental agencies or bodies, or persons with supervisory authority over the complainant. Finally, there will be no punishment or other retaliation for filing a Complaint in good faith, or otherwise participating or assisting in a proceeding filed or about to be filed (with any knowledge of the Foundation) regarding any Complaint. An individual who deliberately or maliciously provides false information may be subject to disciplinary action (up to and including termination).
CORPORATE RECORDS:
Articles of Incorporation (Permanent)
Board Meeting and Board Committee Minutes (Permanent)
By-Laws (Permanent)
Board Policies/Resolutions (Permanent)
IRS Application for Tax-Exempt Status (Permanent)
IRS Determination Letter (Permanent)
State Sales Tax Exemption Letter (Permanent)
Charitable Registration Statements (Permanent)
Correspondence (Legal & other important matters) (Permanent)
Trademarks, Copyrights & Patents (Permanent)
Deeds (Permanent)
Whistleblower Complaints (Permanent)
Press Releases & Other Historical Records (Permanent)
All Legal Records (Endowments, Trusts, etc.) (Permanent)
Contracts, Leases, etc. (after expiration) (7 Years)
ACCOUNTING RECORDS
Audited Financial Statements (Permanent)
Auditor Management Letter (Permanent)
Depreciation Schedules (Permanent)
General Ledger (Permanent)
Insurance Policies (Permanent)
Pension Programs (Permanent)
Employment & Termination Agreements (Permanent)
Employee Handbooks (Permanent)
Journal Entries (7 Years)
Accounts Payable Invoices (7 Years)
All Payroll Records (registers, W-2’s, etc.) (7 Years)
Employee Personnel Files (after termination) (7 Years)
Bank Statements and Cancelled Checks (7 Years)
Donor Acknowledgements Letters (7 Years)
403 (b) Funds Transmittal Forms (7 Years)
Investment Reports & Statements (7 Years)
Form 1099’s (7 Years)
Cash Receipts Journals& Bank & Credit Card Deposit Slips (3 Years)
Bank Reconciliations (3 Years)
INFORMATION RETURNS
Form 990 & Attachments (Permanent)
Form 5500 & Attachments (Permanent)
Form TD F 90-22.1 Report on Foreign Bank & Financial Accounts (Permanent)
All State Information/Tax Returns (Permanent)
All records are stored in a place and manner determined by the Director of Finance
ELECTRONIC INFORMATION
Electronic documents will be retained as if they were paper documents. Therefore, any electronic files that fall into one of the document types on the above schedule will be maintained for the appropriate amount of time. If an employee has sufficient reason to keep an e-mail message, the message should be printed in hard copy and kept in the appropriate file or moved to an archive computer file folder.
All servers will be backed up and the information stored off premises on a basis to be determined by the Information Technology Department (IT).
Deleted e-mails by employees remain in AICF’s computer system. The IT Department will be responsible for permanently removing deleted e-mails from the computer system every two weeks.
DOCUMENT DESTRUCTION
The Director of Finance is responsible for the ongoing process of identifying the records that have met the required retention period and overseeing their destruction. The method of destruction will be determined by the Director of Finance but shredding of financial and employee records are mandatory.
Document destruction will be suspended immediately upon any indication of an official investigation or when a lawsuit is filed or appears imminent. Destruction will be reinstated upon the conclusion of the investigation/lawsuit.
COMPLIANCE
Failure on the part of employees of AICF to follow this policy can result in possible civil and criminal sanctions against AICF and its employees and possible disciplinary action against responsible individuals. The Director of Finance and the Finance Committee of the Board will periodically review these procedures with legal counsel and AICF’s certified public accounting firm to ensure that it is in compliance with new or revised regulations.