Step by Step Inc.

“The organization emails a copy of the 990 to the Board prior to filing.”

“Rounding”

“Step By Step staff should operate free from any conflicts of interest that may affect their work for the organization. Step By Step positions should not be used for personal gain or advantage. Business transactions between Step By Step and staff members or entities related to staff members are prohibited unless the following conditions are met: 1. The transaction is determined by all parties involved to be in the best interest of Step By Step. 2. Evidence shows that the transaction is fair to Step By Step. If requested by the board of directors, a competitive bid or comparable valuation should be obtained. 3. A transaction of greater than $2,500 is approved by Step By Steps full board. 4. The transaction is fully disclosed in the financial statements. 5. The related party is excluded from the discussion and approval of the transaction. Staff and Board should annually sign a Conflict of Interest Disclosure Form. Step By Step staff may serve other causes while serving Step By Step, but should consider the potential for conflict before assisting an organization with principles divergent from those of this Christian establishment. Material that belongs to Step By Step may not be used by staff for personal benefit. Unless an individual agreement is reached, any material produced while working on behalf of Step By Step is the property of the organization. Staff members should not function as representatives for Step By Step when their personal interest may conflict with the interest of the organization. Staff members acceptance of gifts (unless of minimal value) from outside parties should be discussed with the Executive Director if the value of the gift exceeds $25. Personal relationships beyond a mentor/client relationship between Step By Step staff members or volunteers and clients or those related to clients are strictly prohibited, as they pose a significant conflict of interest for the staff involved. If this situation occurs, the staff member or volunteer concerned should immediately discontinue services to the client, explaining the potential for unnecessary conflict. Services for the client will be transferred to a different staff member or volunteer without conflict.”

“Document Retention and Destruction Policy: It is the policy of Step By Step to retain records as required by law and to destroy them when appropriate according to the following Records Retention Schedule. This policy ensures that necessary records and documents are adequately protected and maintained and ensures that records that are no longer needed or are of no value are discarded at the proper time. In addition, this policy aids employees in understanding their obligations in retaining electronic documents including email, web files, text files, sound and movie files, PDF documents, and all Microsoft Office or other formatted files. The Director of Operations (DOO) is the individual in charge of the administration of this policy and the implementation of processes and procedures to ensure that the Record Retention Schedule is followed. This individual is also authorized to: make modifications to the Record Retention Schedule to ensure that it is in compliance with local, state, and federal laws and includes the appropriate document and record categories for SBS; monitor local, state, and federal laws affecting record retention; annually review the record retention and disposal program; and monitor compliance with this policy. In the event Step By Step is served with any subpoena or request for documents or any employee becomes aware of a governmental investigation or audit concerning Step By Step or the commencement of any litigation against or concerning Step By Step, the employee will inform the DOO and any further disposal of documents will be suspended until the DOO, with the advice of counsel, determines otherwise. The DOO will take such steps as is necessary to promptly inform all staff of any suspension in the further disposal of documents. This policy applies to all physical records generated in the course of Step By Steps operation, including both original documents and reproductions. It also applies to the electronic documents described in the first paragraph of this policy. The Record Retention Schedule is organized as follows: 1. Accounting and Finance 2. Contracts 3. Corporate Records 4. Electronic Documents 5. Payroll Documents 6. Personnel Records 7. Property Records 8. Tax Records 9. Contribution Records 10. General The following are some common retention periods. These apply to both physical and electronic documents. If no physical copy of an electronic document is retained, the means to read the electronic document must also be retained. ACCOUNTING AND FINANCE Record Type Retention Period 1099s Permanent Accounts Payable & Accounts Receivable ledgers and schedules 7 years Annual Audit Reports and Financial Statements Permanent Annual Audit Records, including work papers and other documents that relate to the audit 7 years after completion of audit Annual Reports Permanent Authorizations and Appropriations for Expenditures 3 years Bank Deposit Slips 1 year Bank Statements 7 years Budgets 3 years Cash Disbursements Journal Permanent Cash Receipts Journal Permanent Chart of Accounts Permanent Checks (canceled), general 7 years Checks (canceled) for important payments such as taxes, purchases of property, special contracts, etc. Checks should be filed with the papers pertaining to the underlying transaction. Permanet Claims and Litigation Files 10 years Depreciation Schedules Permanent Employee Expense Reports 7 years Financial Statements (annual) Permanent Financial Statements (interim/internal) Permanent General Ledgers Permanent Insurance Policies (current) Permanent Insurance Policies (expired) 3 years Investment Records 7 years after sale of investment Invoices 3 years Leases 10 years Notes Receivable Ledgers and Schedules 7 years CONTRACTS Record Type Retention Period Contracts and Related Correspondence (including any proposal that resulted in the contract and all other supportive documentation 10 years after expiration or termination Copyright, Patent, and Trademark Registrations Permanent Patents, Cop”

“) Whistle-Blower Policy: It is the policy of SBS to be committed to the highest possible standards of ethical, moral, and legal conduct. Therefore, if any employee has a concern about suspected misconduct, dishonesty, and fraud, he or she will be protected from reprisals or victimization for whistle blowing in good faith. Any person knowing of or having suspicion of misconduct, dishonesty or fraud, shall notify the Executive Director (ED) immediately. If the alleged misconduct, dishonesty or fraud concerns the activities or behaviors of Executive Director, then the Chair of the Board Of Directors (BOD) or other designated BOD officer shall be notified immediately. When the ED and/or Chair of the BOD or other designated BOD officer receives information about misconduct, dishonesty or fraud, they will inform the BOD immediately and the BOD shall determine the procedure for investigating all credible allegations. At all times, the privacy and reputation of individuals involved shall be respected. No punishment or other retaliation will be permitted for the reporting of conduct under this policy. If the person providing the information requests anonymity, this request will be respected to the extent that doing so does not impede any investigation.”