(Originally approved by the Board of Directors of the Society of Environmental Journalists on March 13, 1999; revised November 7, 2020; revised January 18, 2022.)
Contents
A. Purpose and Principles
B. Policy on Acceptability of Income Sources
C. Policy on Fundraising by Partner Organizations for SEJ Programs
D. Policy on FEJ (Fund for Environmental Journalism) Fundraising and Grantmaking
E. Policy on Expenses
F. Financial and Accounting Controls
G. Investment Policy
H. 21st Century Fund Endowment
I. Tax Status Policy
J. Document Retention and Destruction Policy
A. Purpose and Principles
(From current practice and 7/31/10, 1/29/11, 5/4/19 and 1/18/22 board amendments.)
These Financial Policies are intended to allow SEJ to develop the resources it needs to be a vital, stable and dynamic organization, while protecting its integrity and independence. They are guided by the following principles:
Support for SEJ's Mission: SEJ may solicit and accept donations from acceptable sources that support SEJ's mission, without regard to their opinions or positions with respect to environmental issues.
Independence and Integrity: SEJ shall retain full control over the use of all income, other than those conditions agreed to through standard grant application processes. The organization reserves the right to decline or return any donation which, in the opinion of the board or the board's designees, may conflict with these principles or otherwise damage the integrity of the organization.
Transparency and Accountability: Solicitation, review and acceptance of all donations shall be conducted in accordance with these Policies, which will be considered among the organization's governing documents and be readily available to all members of the organization and general public. These policies are binding on SEJ employees and board members in their official actions. Exceptions are allowed only if approved in advance by the Executive Committee with a report to the full Board at the next regular meeting. Throughout this document, where duties are assigned to the Executive Director, it is understood that the Executive Director may delegate such duties to other employees or to consultants and other non-employees. However, in all such cases, the Executive Director shall retain full and sole responsibility for ensuring that the delegated duties are properly carried out.
Disclosure and Recognition: SEJ values transparency. A list of its financial supporters and funding sources, including anonymous donations, shall be published on the organization's website at least annually. In addition, each year's IRS Form 990 shall be posted on sej.org, excluding Schedule B (listing details of individual contributors and contributions), consistent with the Internal Revenue Service's general practice for making Form 990s available through its website.
B. Policy on Acceptability of Income Sources
(From current practice, 3/14/98 finance committee draft policy, and 4/5/03, 3/20/04, 7/31/10, 1/29/11, 1/26/13 and 4/23/16 board amendments.)
1. Acceptable sources of income include:
- Direct program revenues, including membership dues; conference registrations; sales of subscriptions and other merchandise; mailing list rentals; and similar forms of earned income as may be identified and approved by the Board.
- Grants in any amount from charitable foundations, educational institutions and media companies, given for purposes consistent with the organization's strategic plan.
- Grants from any independent government or government-chartered agency whose mission is primarily competitive grant-making, such as the National Science Foundation.
- Unrestricted general support gifts or bequests up to $15,000 per calendar year from any individual or entity (other than charitable foundations, educational institutions and media companies, mentioned above) under the principles of support for SEJ’s mission, independence and integrity, as described in section A. Total support from these sources may not exceed 20% of SEJ’s approved annual budget in any given year. Prior Board approval is required for any restricted gifts and all such gifts or bequests over $15,000.
2. Restricted sources of income:
- Gifts from non-media corporations, government agencies, and organizations, other than those allowed under section B(1.) above, are unacceptable unless explicitly approved in advance by the Board, with the following exceptions:
— Matching gifts provided by corporations or other organizations through established employer matching gifts programs;
— In-kind gifts from such corporations, agencies or organizations, including speaker time and travel, documents, admittance to facilities, local transportation to or within facilities and nearby areas, or to revenues received under section B(1.) above.
— Sponsorship of annual and regional conferences. Donations must be transparent and follow the sponsorship plan as approved by the board. Sponsorship can be used for any conference expenses and can be applied to future SEJ conferences or events. SEJ retains full editorial control of event content and speakers.
3. Right of Decline and Return:
- SEJ reserves the right to decline or return any donation, grant, or other gift which, in the opinion of the board or the board's designees, may prove to conflict with the organization's independence or otherwise damage its integrity.
C. Policy on Fundraising by Partner Organizations for SEJ Programs
(Adopted by the SEJ board January 12, 2002; amended January 28, 2006 and May 9, 2020. Please see related Policy Regarding SEJ Endorsements, Co-Sponsorships and Partnerships for Journalism and Environmental Education Programs.)
All SEJ programs undertaken in partnership with or hosted by educational institutions, journalism organizations, news organizations and other entities (henceforth termed “partner organizations”) are managed in accordance with SEJ’s partnership guidelines on “Endorsements, Co-Sponsorships and Partnerships for Journalism and Environmental Education Programs.”
Fundraising efforts undertaken by partner organizations to meet their financial commitments to SEJ programs are not bound by SEJ's internal policies governing the solicitation of grants and sponsorships. However, this does not constitute implied or actual endorsement by SEJ of donors or their products, services, advertising, other messaging or opinions.
Any entity wishing to be represented or to represent itself as a partner organization of SEJ, including but not limited to use of SEJ’s name or logo on materials or messages, may do so only with SEJ’s written approval.
D. Policy on FEJ (Fund for Environmental Journalism) Fundraising and Grantmaking
(As revised by the board on April 18, 2015 and May 9, 2020.)
SEJ provides grants to journalists and news organizations through its Fund for Environmental Journalism program.
SEJ accepts FEJ underwriting from varied funders (referred to hereafter as “underwriters”).
SEJ encourages unrestricted grantmaking for reporting projects on any environment-related topic. SEJ’s Executive Director has full authority to develop, purpose and accept funding to underwrite the FEJ, pursuant to due diligence and consultation as needed with the Executive Committee.
For each competitive FEJ funding cycle, SEJ appoints an editorially independent judging panel to select grantees.
All proposals and binding agreements between underwriters and SEJ, and between SEJ and FEJ grantees, strictly reinforce the editorial independence of both judges and grantees.
Grantees have full editorial control of their reporting projects, including decisions regarding production methods, publication and distribution.
Underwriters do not have the right to review FEJ grant applications, participate in FEJ judging panels or review FEJ-funded projects at any stage before publication.
Note: These statements of clarification have been added to program information pages of the Fund for Environmental Journalism to clarify policy and practice regarding editorial independence.
E. Policy on Expenses
(Updated September 28, 2024. Last revised by the board on January 26, 2019.)
1. Policy on SEJ expense reimbursement for board members:
a) SEJ will reimburse board members for reasonable expenses related to attending in-person or hybrid board meetings, including coach airfare, ground transportation, per diem expenses for meals not provided directly by SEJ (as set by the GSA) and lodging, up to an annual cap of $2,500 for board members residing in the United States and Canada and $5,000 for board members residing elsewhere. Reimbursement may cover board business days and travel days, and may be issued in advance.
The Executive Committee may approve additional reimbursement related to board meetings on a case-by-case basis.
Board members will not be reimbursed for non-business related expenses and should make every effort to minimize expenses where possible. No alcohol purchases shall be made or reimbursed by SEJ, except when approved by the Executive Committee.
Board members are encouraged to attend and contribute volunteer time to the annual SEJ Conference. Board members’ conference registration and event fees will be waived if there is a formal board meeting or membership meeting during the conference, or they have contributed meaningfully to the operation of the conference itself such as by serving as a speaker, panel moderator, conference tour leader, conference co-chair or in a conference staff support role approved by the executive director.
Whenever possible, board members are encouraged to seek funding from their employers if applicable and/or other sources to cover their conference travel and lodging expenses. When these options are not feasible, the Executive Committee may approve reimbursement for board members' conference-related lodging and travel expenses up to a cap of $1,250 for those residing in the United States and Canada and $2,500 for those residing elsewhere. These amounts are separate from and in addition to the annual cap for board meeting expenses.
Board members are expected and encouraged to make a personally meaningful contribution to SEJ as part of their charitable giving, based on their individual capacity.
b) Reporting: The organization will annually tabulate, report and include in the minutes of the first board meeting of each calendar year the total meeting-related costs for the previous calendar year. This will include the average amount reimbursed, reported out by dividing total costs by the number of board members and board members in attendance.
c) Reimbursement requests must be filed within 30 days of the conclusion of the trip. Reimbursement requests must be submitted via the online expense form including itemized receipts. For cash expenses without receipts, please include a detailed list including date, location, date goods/services and amount. All expenses over $50 require a receipt, and every effort should be made to submit legible copies of receipts for all expenses. SEJ will make a good faith effort to pay reimbursements within 30 days after receipt of completed reimbursement requests, including all required receipts or other documentation.
2. Policy on SEJ expense reimbursement for staff, contractors and invited guests:
a) For SEJ staff and contractors: All reasonable and acceptable travel expenses will be paid for assigned business-related trips. Acceptable expenses include transportation, hotel, meals and incidentals. Meal and incidental expenses (per diem) and mileage reimbursement shall not exceed the rates set by the Internal Revenue Service. Employees will be reimbursed only for actual expenses under the per diem limit. Hotels and airlines used shall be economical, clean and safe. If the trip involves additional non-SEJ related events or travel, the employee or contractor should deduct the additional time-based costs (rental cars, hotel rooms) from the reimbursement.
No alcohol expenses shall be made or reimbursed by SEJ, except when approved by the Executive Director or Executive Committee.
First and business class travel and accommodations will not be reimbursed. In situations of disability, physical impairment or other hardship, the Executive Director (or Executive Committee, in the case of the Executive Director) can authorize exceptions to these rules.
b) Speakers, fellows and other SEJ invited guests may be offered reimbursement of travel expenses as specified in their invitation to participate in SEJ events or as negotiated with SEJ staff. Eligible expenses and reimbursement requests are subject to the same guidelines as listed above. First and business class travel and accommodations will not be reimbursed.
c) Reimbursement requests must be filed within 30 days of the conclusion of the trip. Reimbursement requests must be submitted via the online expense form including itemized receipts. For cash expenses without receipts, please include a detailed list including date, location, goods/services and amount. All expenses over $50 require a receipt, and every effort should be made to submit legible copies of receipts for all expenses.
F. Financial and Accounting Controls
(Amended by the SEJ board July 19, 2003; January 28, 2006; April 28, 2007; November 7, 2020 and January 18, 2022.)
The purpose of this policy is to formulate financial and accounting controls practices and procedures for the Society of Environmental Journalists, outline the safeguards that shall be implemented to ensure that financial transactions are properly authorized, appropriated, executed and recorded, and establish the process and timeframe for review of financial operations and activities.
The SEJ Board of Directors has delegated oversight responsibility for this policy to the SEJ Treasurer and the finance committee of which the Treasurer is the chair.
The Executive Director, in consultation with the Treasurer and Finance Committee, shall prepare an annual budget for the organization that provides for such programs and support services as are outlined in the current strategic plan, which shall form the basis for all SEJ spending. The annual budget shall be considered and approved by the full Board of Directors during the first scheduled quarterly board meeting of each current calendar year.
A: Cash Receipts
SEJ shall adhere to the following policies for cash receipts and other incoming revenues.
Revenue shall be recorded on an accrual basis, so that revenue appears in the proper accounting period, regardless of the timing of the actual deposit of payment. Communication of any anticipated revenue in the form of grants, donations or other support are communicated to the SEJ Accountant at the time of notification/acceptance. Invoices will be created for any unconditional promises of support at the time that they are made, and payments will be applied when received.
- Checks
Checks received by mail shall be retrieved from the physical location at least biweekly. Checks shall be endorsed “for deposit only” immediately upon receipt. All cash and checks shall be deposited as promptly as possible. Deposit detail and confirmations, and copies of checks and remittance advice, shall be retained in SEJ files.SEJ staff shall prepare an up-to-date list of all cash and checks received, available as a view-only document on the cloud drive, and make available the list to the staff and SEJ Treasurer on a weekly basis.
Restricted contributions shall be clearly identified and recorded as restricted on the general ledger. SEJ shall send acknowledgements to contributors and copies of or record of such acknowledgements shall be kept on file.
Physical checks shall be destroyed according to bank recommendations, or no less than 60 days following deposit.
- Credit Cards
SEJ receives income through online credit card payments for conference registration, member dues, exhibitor fees, gifts and other categories of revenue. These funds are deposited directly into SEJ’s checking account. SEJ staff shall make access available to SEJ’s Accountant detailed transaction reporting from the various credit card e-commerce systems to enable proper categorization and classification of revenue, refunds and fees, and to allow for research of any payment discrepancies. - ACH/EFT/Wire Payments
Payments made by direct deposit to SEJ’s banking accounts are usually accompanied by an electronic remittance or correspondence, which is provided to SEJ’s Accountant along with any applicable classification instructions and supporting documentation at the time received. The Accountant will notify SEJ staff of any such banking activity for which prior notification was not received at the time the accounts are reconciled. - Gifts of Stock
Gifts of stock received to SEJ’s investments account are recorded at the value received upon transfer and classified as unrestricted gifts to programs. Stocks are sold soon thereafter according to SEJ board policy, and the appropriate gain/loss is recorded upon the sale. - Banking Transfers
Executive Director shall provide SEJ Accountant with weekly information on funds transfers to and from SEJ accounts, undertaken in the normal course of cash flow management. - Endowment Funds
Funds received which are designated by the donor as intended for the endowment shall be deposited into the proper endowment account upon receipt whenever possible. When this is not possible, a transfer shall be made with appropriate documentation on the earliest possible date.
B: Outgoing Expenses
SEJ shall adhere to the following policies for cash disbursements and other outgoing expenses.
All expenses shall be approved in advance by an authorized person, including the SEJ Executive Director and SEJ Treasurer.
All invoices received from vendors, expense reimbursement requests prepared by staff or board members, and ad hoc payment requests shall be reviewed by SEJ staff and forwarded to SEJ’s online accounts payable software email for processing by the Accountant. Invoices will be entered in the appropriate period regardless of when payment is intended to be made. Data associated with each item should include not only all basic invoice info (To SEJ, from specific individual or organization, amount due, make check payable to, mail to) but also date of receipt for the invoice or check request; classification or category number of the expense; name of person approving payment. Additional information can be included in the email body if not included on the actual invoice, and attached to the bill record. Requests for reimbursement shall be checked for mathematical accuracy and reasonableness before approval. All invoices shall be assigned for the appropriate approvals at the invoice level within the online payment solution, which includes review and approval by the Executive Director and Deputy Director. Invoices of more than $5,000 should also be assigned to the Treasurer or a designated board member for additional approval.
All disbursements will be issued through the accounts payable software by check or electronic payment, following approval for payment by the Executive Director. In rare cases, a payment may need to be made directly by SEJ, which shall be issued in the form of pre-numbered checks. In such cases, SEJ will provide the Accountant with a copy of the payment request or invoice, and a copy of the check issued, upon disbursement. Some vendors may be set up for routine autopay from SEJ checking accountant with approval from Executive Director, and copies of any supporting approvals and documentation will be maintained in the same manner as other payments. SEJ shall prohibit issuing checks payable to cash.
SEJ shall prohibit advance signing of checks, except in limited circumstances with written approval by the Treasurer.
All voided checks shall be documented as such and promptly destroyed.
Bank statements shall be received and reviewed by the SEJ Treasurer, who shall be given access to online accounts data.
Advance payments to vendors and/or employees shall be recorded as prepaid expenses and controlled in a manner which assures that they shall be offset against invoices or expense vouchers.
Expense reimbursements shall be done in accordance with SEJ’s expense policy.
No payment, or aggregate payments, of $600 or more shall be made to any individual or business for services without first obtaining and filing that entity’s W-9 tax form if subject to U.S. tax laws, or the appropriate equivalent for international recipients. SEJ shall be obligated to provide all qualifying vendors with a 1099 in January of the following fiscal year.
Payments made by credit card shall be done in accordance with SEJ’s credit card policy.
C: Payroll
SEJ shall adhere to the following policies for payroll.
Payroll is submitted biweekly by the Accountant via full service payroll provider, using standard hours and established salaried rates for all employees. Should any changes be necessary, they are communicated by the Executive Director using the appropriate payroll change authorization form. Reports are reviewed by the Executive Director once payroll has been submitted. The Executive Director is responsible for assuring the cash balance is sufficient to cover the full amount of payroll and taxes.
Withheld employment taxes and employer taxes shall be paid on a timely basis to the taxing authorities via payroll service provider. SEJ Executive Director shall monitor payments to ensure completion.
D: Fixed Assets
SEJ shall adhere to the following policies for fixed assets.
It is the organization’s policy to capitalize all items which have a unit cost greater than $1,500. Items purchased with a value or cost less than $1,500 will be expensed in the period purchased. The Board of Directors approves the capital acquisitions budget at the beginning of each year. Unbudgeted capital acquisitions more than $5,000, must be approved by the Executive Director or Treasurer.
The organization shall maintain a capitalization and depreciation policy, using IRS guidelines for valuation and depreciation.
Additions to fixed assets shall be recorded in a fixed asset ledger within the general ledger. The fixed asset ledger shall include a description of each item, serial number, location, date of acquisition, cost or fair value if donated, useful life, depreciation method, accumulated depreciation and funding source if funds were provided by a funding source with restrictions on disposition of assets. The fixed asset ledger shall be reconciled with the general ledger annually. Purchase, transfer and disposal of fixed assets shall be promptly recorded in the ledger. The organization shall conduct a physical inventory annually and update the fixed asset and the general ledgers when necessary, including for the audit and placement of property insurance.
E: General
SEJ shall follow these accounting procedures and other general policies.
SEJ has designated a Chart of Accounts specific to its operational needs and the needs of its financial statements. The Chart of Accounts is structured so that financial statements can be shown by natural classification (expense type) as well as by functional classification (program vs. fundraising vs. administration). The Executive Director is responsible for maintaining the Chart of Accounts and revising as necessary. The Chart of Accounts is attached to the Accounting Manual as an addendum.
The general ledger is automated and maintained using the accounting software. All input and balancing is the responsibility of the Accountant with final approval by the Executive Director.
The Executive Director or designee should review the general ledger on a periodic basis for any unusual transactions.
Accounting records shall be up to date and monthly financial statements shall be prepared on a timely basis (timely being defined as 10 days to three weeks). Financial statements shall consist of, at minimum, a Statement of Activities, Statement of Financial Position and a Statement of Cash Flows or rolling forecast, depending on the needs of the organization. When applicable, such statements shall be compared to the approved budget and/or prior year results. Reports are to be reviewed by the Executive Director and presented to the SEJ Treasurer and the finance committee monthly, and presented to the board at quarterly meetings.
The SEJ Executive Director shall report any significant issues (For example: national crisis, recession, etc.) that could potentially harm SEJ’s financial future, and report any significant changes in income or expenditure to SEJ’s executive committee, of which the Treasurer is a member, within 30 days of such knowledge. A significant change is defined as one that would significantly alter the annual plan of operation or would result in a change of more than 10% from the total amount of the organization's approved budget. The Executive Committee will provide guidance to the Executive Director as needed, and inform the full board at the next board meeting or sooner if warranted.
An accounting procedure and policies manual shall be maintained, reviewed and revised annually and shall outline who performs the basic duties of accounting staff when they take annual vacation.
F: Contracts
Procurement of supplies and other expendable property, equipment, real property and other services shall be made only by authorized persons within the organization. All contracts will be reviewed and approved by the Executive Director and be based upon board approved expenditures.
SEJ is required to submit requests for proposal to three or more vendors for significant capital expense or contractual expense more than $25,000. Contracts over this amount must be approved by the SEJ Treasurer. The Treasurer may waive the competitive bidding requirement depending on the situation.
SEJ will not make purchases or enter into contracts that involve a real or apparent conflict of interest on the part of an employee. Such a conflict would arise if an employee, a member of the employee’s immediate family, the employee’s partner or an organization that employs or is about to employ any of the parties mentioned in this sentence has a financial or other interest in a purchase or contract originating with SEJ. Employees will discuss all conflicts, certain or uncertain, with the Executive Director; if the Executive Director is uncertain whether their own circumstances represent a conflict in a given situation, the question should be referred to the President or the Treasurer.
A system for contract administration shall be maintained to ensure contractor conformance with the terms, conditions and specifications of the contract and to ensure adequate and timely follow up of all purchases. SEJ shall evaluate contractor performance and document, as appropriate, whether contractors have met the terms, conditions and specifications of the contract. All contracts, including small purchases, awarded by SEJ and their contractors where the source of the funds, directly or indirectly, is the federal government, shall follow procurement provisions as outlined by the applicable federal guidelines.
G: Segregation of Duties
The organization’s financial duties shall be distributed among multiple people to help ensure protection from fraud and error. The distribution of duties aims for maximum protection of the organization’s assets while also considering efficiency of operations. No one individual will be responsible for the receipt, approval and disbursement of any payments to employees or vendors. No one individual will be responsible for the receipt, recording into the general ledger and reconciliation of the bank statement, for cash receipts.
The submission of invoices or requests for payment may fall to any number of staff or outside vendors. The Accountant shall enter every invoice into the general ledger using the accounts payable platform, and assign it to the appropriate reviewers/approvers, which will be no less than the Executive Director and a second designee.
Cash receipts will be received and logged by the Executive Director or designee, recorded in the accounting system by the Accountant, and the bank deposits reconciled to the general ledger by the Accountant. Any discrepancies are to be immediately investigated.
The Accountant shall prepare monthly financial reports, and shall prevent the entry of any data into the general ledger once reports have been prepared for the prior accounting period. The reports and all supporting general ledger detail will be made available to the Executive Director and any member of the Board for review.
H: Security of Assets
The organization maintains physical security of its assets to ensure that only people who are authorized have physical or indirect access to money, securities, real estate and other valuable property.
Access to cash accounts is restricted to those members of leadership and board of directors who have signature authority, namely the Executive Director, Deputy Director, Board President and Treasurer. Limited access is provided to designated accounting staff for the purposes of depositing funds and accessing statements and transaction detail. No member of the staff or board shall open any cash, credit card, investment or other type of account without express authorization and signature of the Executive Director.
Physical assets such as blank checks, credit cards and computers, printers and office machinery shall be secured outside of business hours whenever possible. Staff shall follow the protocols established within the electronic device policy for information security. SEJ staff shall inventory all physical assets located in employee home offices yearly. An inventoried list will be shared annually with the Board President and the Treasurer.
Passwords shall be used to prevent unauthorized access to computers, accounting software, banking applications and any other purchased or web-based software in which sensitive information is stored. Passwords should follow appropriate security recommendations and be reset periodically. Passwords shall not be shared outside the secure password management system.
SEJ maintains cash balances in bank accounts among multiple federally insured financial institutions, according to the source and purpose of the funds. Cash may include highly liquid investments, with an initial maturity of three months or less. Deposits may at times exceed federally insured limits, and the Executive Director, in consultation with the Treasurer, periodically evaluates any potential risk before taking appropriate action.
The Executive Director is responsible for monitoring cash balances on a frequent basis and assuring that SEJ has sufficient cash on hand to honor its obligations to creditors and staff.
Bank statements are retrieved from an online banking portal and downloaded as a pdf file. The bank statements are to be reconciled by the Accountant every month, no more than one week after receipt of the report. The general ledger and the reconciled bank statements will be adjusted to agree monthly. Reconciliation reports will be provided to the Executive Director for review.
I: Audit
An Audit Committee, appointed by the board, shall arrange for and oversee an annual independent audit of the organization's financial statements.
The Committee shall be composed of three members, none of whom shall be the current Treasurer. At least one member shall be a board member other than the Treasurer, who will act as the primary liaison between the committee and the Board, and at least one member shall be an SEJ member who is not currently serving on the Board. Committee members will serve staggered three-year terms, but no member shall serve more than two consecutive three-year terms.
The Committee shall select a chair from its members each year, who will be the primary liaison between the Committee and the Executive Director and the auditor. The Committee shall meet at times and in the manner of its choosing for discussions with the Executive Director and the organization's auditor, subject to current budget constraints.
The Committee's work shall be guided by SEJ's financial policies and procedures. Each year the Committee shall:
- Select an independent auditor, and determine the auditor's compensation, in consultation with the Executive Director, and with approval from the SEJ Board;
- Consult with the accounting team and auditor to identify any materially relevant changes to all new laws, regulations and best practices regarding nonprofit sector finances and audit procedures;
- Conduct entrance and exit conferences with auditor, and other conversations as needed;
- Review and determine the acceptability of the audit and management letter addressed to the SEJ Board, along with any other supporting documents provided by auditor;
- Ensure timely completion of the audit;
- Report to the SEJ Board on the finished audit, supporting documents and management letter provided to the SEJ Board by the auditor, along with management's response at the completion of the committee's work;
- Approve of any non-audit services to be provided to SEJ by auditor/auditing firm;
- Advise the Executive Director as needed about any recommendations for possible revisions to the SEJ financial policies and procedures.
As part of the audit process, the Executive Director shall respond to all substantial questions, suggestions and comments offered by the auditor and Audit Committee, and that response shall be included with the Committee's report to the board.
The Committee also will oversee preparation of the organization's annual Form 990 by the auditor. The auditor will be directed to provide a draft of the Form 990 to members of both the Audit Committee and Finance Committee at least two weeks before filing of the Form 990 with the Internal Revenue Service, in order to provide those committee members with an opportunity to review it before it is filed.
G. Investment Policy
(From finance committee discussions prior to 7/98 board meeting, current practice, NCNB sample guidelines, and 7/04 board amendment. Updated May 1, 2021.)
See SEJ's Investment Policy and Procedures here.
H. 21st Century Fund Endowment
(Adopted January 24, 2004, amended 3/20/2004 and 7/31/2010.)
1. Purpose
The 21st Century Fund is SEJ's general endowment. The purpose of the Fund is to secure the organization's future by providing a vital layer of protection from the uncertainties of year-to-year fundraising for the operating budget. The Fund's proceeds will be used to help fund core operations (including staff and program costs) as well as special projects deemed by the board to be of great importance to SEJ.
2. Fundraising
a. Acceptable sources of Funds: The 21st Century Fund accepts gifts from individuals. Such donations are governed by the appropriate sections of Purposes and Principles and Acceptability of Income Sources (Sections A & B, above).
b. Control of Fund: SEJ shall retain full control over the use of income from the 21st Century Fund. The organization will accept no conditions or restrictions, express or implied, on any donations to this fund. This principle shall be included in all written and verbal solicitations, and/or acknowledgements, and shall be acknowledged in writing by all donors of $10,000 or more.
c. Balance and Diversity of Donors: So as not to be, or appear to be, overly dependent on donations from any particular sector or type of individuals beyond the journalism community, SEJ shall strive to raise at least 25% of its 21st Century Fund from SEJ members, founding and other former board members and other journalism leaders, and to raise the remainder from a broad array of individual donors beyond the journalism community.
d. Review and Approval Process: Solicitation and review of prospective donations of $10,000 or more, including review of any unsolicited donations of such size, is carried out by the Development and Fundraising subcommittee of the board’s Finance Committee, in concert with the Executive Director and other appropriate staff members. The board may also authorize others outside the organization to solicit such funds on its behalf, provided that such persons work in concert with and are subject to the authority of the Finance Committee. No donations of $10,000 or more may be accepted through any other channels or processes.
Prospective donations of $10,000 or more must be approved by a majority of the Development and Fundraising subcommittee. As ex-officio members of the subcommittee, the SEJ Treasurer and President each have veto power over any prospective gift to the 21st Century Fund.
As with all SEJ income, donations of $10,000 or more are subject to the review of the full Board, and the Board reserves the right to reject or return any that may conflict with the organization's independence or otherwise damage its integrity.
3. Management, Investment & Spending
(Existing language — from revision approved by board 7.03. Amended by the board January 13, 2007.)
a. Management: The 21st Century Fund shall be managed and reported to the Board and Independent Auditor by the Executive Director with reference to two internal bookkeeping accounts: "21st Century—Donor" (funds contributed by individual and institutional donors) and "21st Century—Internal" (funds transferred from SEJ's operating budget by action of the Board). These funds may be co-mingled in a single investment account, provided that strict accounting records are kept and reported, to identify dollars considered to be within each category.
The "21st Century—Donor" account is a permanently-restricted account. Donations deposited in this account may not be transferred to another SEJ account. Only the interest, dividends and/or realized capital gains from this account may be used by the organization.
The "21st Century—Internal" account is a board-restricted account. Interest, dividends, and/or capital gains from this account may be used by the organization. In addition, by action of the Board, assets transferred into this account may be drawn upon to help pay for endowment fundraising-related expenses, or returned to SEJ's general operating accounts.
b. Investment: Assets in the 21st Century Fund shall be prudently invested to balance growth with protection of the principal of the underlying assets, consistent with the policies stated in section F, Investment Policy, above.
c. Dissolution: Should SEJ ever cease to exist, the Board at the time of dissolution shall donate the assets of the 21st Century Fund to another journalism education organization or academic institution in support of programs to improve the quality, accuracy and visibility of environmental reporting.
I. Tax Status Policy
(From SEJ attorney Gail Ross, memo 3/26/93.)
1. To preserve the organization's 501(c)(3) tax-exempt status, the Board through its strategic plan shall ensure that the organization is operated exclusively for qualified exempt purposes, including charitable and educational purposes, and that no more than an insubstantial portion of the organization's activities are devoted to the furtherance of non-exempt purposes. Examples of non-exempt purposes might include a members-only job bank or health insurance program, or other activities that result solely in a private benefit without serving an overriding public interest.
2. No part of the organization's activities may constitute intervention or participation in any political campaign on behalf of any candidate for public office. No substantial part of the organization's activities may consist of political, lobbying or non-exempt purposes as defined in paragraph I(1.) above.
3. The organization shall offer no guidance to donors about the deductibility of their gifts other than to inform them that SEJ is a 501(c)(3) organization, gifts to which may be tax deductible under U.S. tax laws.
J. Document Retention and Destruction Policy
(Adopted by the SEJ board January 30, 2021.)
I. PURPOSE
In accordance with the Sarbanes-Oxley Act, which makes it a crime to alter, cover up, falsify or destroy any document with the intent of impeding or obstructing any official proceeding, this policy provides for the systematic review, retention and destruction of documents received or created by SEJ in connection with the transaction of organization business. This policy covers all records and documents, regardless of physical form, contains guidelines for how long certain documents should be kept and how records should be destroyed. The policy is designed to ensure compliance with federal and state laws and regulations, to eliminate accidental or innocent destruction of records, and to facilitate SEJ’s operations by promoting efficiency and freeing up valuable storage space.
In some cases, the applicable retention policy is dictated by statute or law. In other cases, it may be a matter of judgement or board policy.
When under federal investigation or where litigation is either ongoing or imminent, state clearly that all document destruction must stop and documents must be preserved.
II. RULES
The Organization's staff, volunteers, members of the Board of Directors and outsiders (i.e., independent contractors via agreements with them) are required to honor these rules:
a. Paper or electronic documents indicated under the terms for retention below will be transferred and maintained by the Executive Office staff.
b. All other documents may be destroyed after three years.
c. No paper or electronic documents will be destroyed or deleted if pertinent to any ongoing or anticipated government investigation or proceeding or litigation.
III. TERMS FOR RETENTION
Terms for retention should be adhered whether in physical or electronic form.
a. Retain permanently:
i. Governance Records – Charter and amendments, Bylaws, Articles of Incorporation other organizational documents, and Board of meeting minutes, policies/resolutions
ii. Tax Records – Filed state and federal tax returns/reports and supporting records, IRS tax exemption determination letter and related correspondence, files related to tax audits, Sales Tax Exemption letter
iii. Bank check registers, Payroll Registers, State Unemployment Tax Records
iv. Intellectual Property Records – Copyright and trademark registrations and sample of protected works
v. Financial Records – Audited Financial Statement Reports and attorney contingent liability letter, fixed asset schedule, depreciation schedule, general ledgers
vi. Legal, Insurance and Safety Records: Appraisals, Copyright Registrations, Environmental Studies, Insurance Policies, Real Estate documents, Stock & Bond Records, Trademark Registrations
vii. Employment and Termination Agreements, Retirement and Pension Plan documents
viii. Annual Reports to the Secretary of State/Attorney General
ix. Board Meeting and Board Committee Minutes
b. Retain for seven years:
i. Lease and contract/license records – Software license agreements, vendor, hotel, and service agreements, independent contractor agreements, employment agreements, consultant agreements, and all other agreements (retain during the term of the agreement and for seven years after the termination, expiration, non-renewal of each agreement)
ii. Contracts (after expiration)
iii. Business Expense Records
iv. IRS 1099s
v. Journal entries
vi. Invoices
vii. Bank deposit slips, bank statements and reconcilements, electronic funds transfers
viii. Earnings records, Payroll tax returns, W-2 Statements
ix. Records relating to promotion, demotion, or discharge (7 years event)
x. Donor records and acknowledgement letters
c. Retain for six years:
i. Pension and benefit records – Pension (ERISA) plan participant/beneficiary records, actuarial reports, related correspondence with government agencies, and supporting records
ii. Employee/employment records (time to toll (stopping the clock) after employment separation or contractor termination) – Employee names, addresses, social security numbers, dates of birth, INS Form I-9, resume/application materials, job descriptions, dates of hire and termination/separation, evaluations, compensation information, promotions, transfers, disciplinary matters, time/payroll records, leave/comp time/FMLA, engagement and discharge correspondence, documentation of basis for independent contractor status
iii. Leases
d. Retain for five years:
i. Government relations records – State and federal lobbying and political activity reports and supporting records
ii. Grant application and contracts (5 years after completion)
iii. Accident reports and Workers Compensation Records
iv. Salary schedules
v. Sales records (dues, exhibitor fees, sponsorship, event registrations)
vi. OSHA documents
vii. Documentation – dues, new members, registrations, sponsorship agreements, exhibitor applications
e. Retain for three years:
i. All other electronic records, documents and files – Correspondence files, past budgets, bank statements, publications, employee manuals/policies and procedures
ii. survey information.
iii. Correspondence (general)
iv. General contracts (three years after termination)
v. Employment applications
vi. I-9 Forms (three years after termination)
vii. Petty cash vouchers, cash receipts, credit card receipts
f. Retain for two years:
i. Time cards
Exceptions – Exceptions to these rules and terms for retention may be granted only by the SEJ President or Executive Director.
Category Listing
Documents that are not listed but are substantially similar to those listed in the schedule will be retained for the appropriate length of time.
1. Corporate Records
| Annual Reports to Secretary of State/Attorney General | Permanent |
| Articles of Incorporation | Permanent |
| Board Meeting and Board Committee Minutes | Permanent |
| Board Policies/Resolutions | Permanent |
| Bylaws | Permanent |
| Construction Documents | Permanent |
| Fixed Asset Records | Permanent |
| IRS Application for Tax-Exempt Status (Form 1023) | Permanent |
| IRS Determination Letter | Permanent |
| State Sales Tax Exemption Letter | Permanent |
| Contracts (after expiration) | 7 years |
| Correspondence (general) | 3 years |
2. Accounting and Corporate Tax Records
| Annual Audits and Financial Statements | Permanent |
| Depreciation Schedules | Permanent |
| General Ledgers | Permanent |
| IRS 990 Tax Returns | Permanent |
| Business Expense Records | 7 years |
| IRS 1099s | 7 years |
| Journal Entries | 7 years |
| Invoices | 7 years |
| Sales Records (dues, exhibitor fees, sponsorship, registration for events) | 5 years |
| Petty Cash Vouchers | 3 years |
| Cash Receipts | 3 years |
| Correspondence (general)Credit Card Receipts | 3 years |
3. Bank Records
| Check Registers | Permanent |
| Bank Deposit Slips | 7 years |
| Bank Statements and Reconciliation | 7 years |
| Electronic Fund Transfer Documents | 7 years |
4. Payroll and Employment Tax Records
| Payroll Registers | Permanent |
| State Unemployment Tax Records | Permanent |
| Earnings Records | 7 years |
| Garnishment Records | 7 years |
| Payroll Tax Returns | 7 years |
| W-2 Statements | 7 years |
5. Employee Records
| Employment and Termination Agreements | Permanent |
| Retirement and Pension Plan Documents | Permanent |
| Records Relating to Promotion, Demotion or Discharge | 7 years after termination |
| Accident Reports and Worker’s Compensation Records | 5 years |
| Salary Schedules | 5 years |
| Employment Applications | 3 years |
| I-9 Forms | 3 years after termination |
| Timecards | 2 years |
6. Member/Donor Records
| Membership and Donor Records | 7 years |
| Grant Applications and Contracts | 5 years after completion |
| Documentation – dues, new members, registrations, sponsorship agreements, exhibitor applications |
5 years after completion |
7. Legal, Insurance and Safety Records
| Appraisals | Permanent |
| Copyright Registrations | Permanent |
| Environmental Studies | Permanent |
| Insurance Policies | Permanent |
| Real Estate Documents | Permanent |
| Stock and Bond Records | Permanent |
| Trademark Registrations | Permanent |
| Leases | 6 years after expiration |
| OSHA Documents | 5 years |
| General Contracts | 3 years after termination |
IV. ELECTRONIC DOCUMENTS AND RECORDS
Electronic documents will be retained as if they were paper documents. Therefore, any electronic files, including records of donations made online, that fall into one of the document types on the above schedule will be maintained for the appropriate amount of time. If a user has sufficient reason to keep an email message, the message should be printed in hard copy and kept in the appropriate file or moved to an “archive” computer file folder. Backup and recovery methods will be tested on a regular basis.
Electronic files will be stored in secured Dropbox account and will be accessible to the Executive Director or designee. The Dropbox folder will be organized in seven folders. Each document will be labeled with the destruction date. The Folders are as follows:
1. Corporate Records
2. Accounting and Corporate Tax Records (This includes back-ups from QuickBooks.)
3. Bank Records
4. Payroll and Employment Tax Records
5. Employee Records
6. Member/Donor Records and Acknowledgement Letters (This includes back-ups from MemberClicks.)
7. Legal, Insurance and Safety Records
V. EMERGENCY PLANNING
SEJ’s physical records will be stored in a safe, secure and accessible manner in an off-site storage facility. Facility shall be climate controlled and accessible by the Executive Director or designee. Documents and financial files that are essential to keeping SEJ operating in an emergency will be duplicated or backed up at least every week and also maintained off site.
VI. DOCUMENT DESCRIPTION
SEJ’s Executive Director or designated staff is responsible for the ongoing process of identifying its records, which have met the required retention period and overseeing their destruction. Destruction of financial and personnel-related documents will be accomplished by shredding if paper based. If electronic, documents will be deleted from the secured Dropbox Folder.
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 conclusion of the investigation.
VII. COMPLIANCE
Failure on the part of employees to follow this policy can result in possible civil and criminal sanctions against SEJ and its employees and possible disciplinary action against responsible individuals. The chief financial officer and finance committee chair will periodically review these procedures with legal counsel or the organization’s certified public accountant to ensure that they are in compliance with new or revised regulations.
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