Birchbark Foundation Inc.

“A draft copy of the 990 return is provided to the board of directors for review before filing.”

“Birchbark's policy on regularly and consistently monitoring and enforcing compliance with the conflict of interest policy involves several key practices designed to ensure that all employees, executives, and board members act in the best interests of the organization and avoid any activities or relationships that could lead to a conflict of interest. 1. Regular monitoring: annual declarations: all relevant parties may be required to complete an annual conflict of interest disclosure form. This form typically asks individuals to disclose any relationships, activities, or interests that could potentially conflict with their duties to the organization. Ongoing updates: individuals must update their conflict of interest declarations whenever new potential conflicts arise. This ensures that the organization is aware of any changes in circumstances that could affect decision-making. Internal audits: periodic audits might be conducted to review compliance with the conflict of interest policy. These audits could include reviewing contracts, financial transactions, and other records to identify any potential conflicts of interest. 2. Consistent enforcement: clear procedures: the policy should outline clear procedures for addressing potential conflicts of interest. This might include steps for investigating reported conflicts, determining whether a conflict exists, and deciding on the appropriate course of action. Consequences for non-compliance: the policy should specify the consequences for failing to comply with conflict of interest requirements. This could range from corrective actions, such as removing the individual from the decision-making process, to more severe measures like termination or legal action, depending on the severity of the violation. Training and communication: regular training sessions might be conducted to ensure that all relevant parties understand the conflict of interest policy and their responsibilities under it. This can include examples of potential conflicts and guidance on how to handle them. Ethics committee or officer: an ethics committee or designated officer may be responsible for overseeing compliance with the conflict of interest policy. This body would be tasked with reviewing disclosures, investigating potential conflicts, and ensuring that appropriate actions are taken when necessary. 3. Transparency and reporting: documentation: all disclosures, investigations, and decisions related to conflicts of interest should be well-documented. This ensures transparency and provides a record that can be reviewed if questions arise later. Reporting to stakeholders: in some cases, particularly for significant conflicts of interest, the organization might report the situation to its stakeholders (e.g., board members, shareholders, or the public) to maintain transparency and trust. 4. Continuous improvement: policy review: the conflict of interest policy should be reviewed and updated regularly to ensure it remains effective and relevant. This might involve adjusting the policy to address new types of conflicts or changes in the organization's operations or regulatory environment. By implementing such a policy, birchbark would be able to mitigate the risks associated with conflicts of interest, ensure ethical behavior within the organization, and maintain the trust of stakeholders.”

“Here is a sample policy for determining the compensation of officers and key employees at birchbark foundation, inc. That includes independent review, use of comparability data, and contemporaneous substantiation of the deliberation and decision-making process: compensation policy for officers and key employees purpose: the purpose of this policy is to establish a fair, reasonable, and transparent process for determining the compensation of officers and key employees of birchbark foundation, inc. ("birchbark"). This process includes an independent review, the use of appropriate comparability data, and the maintenance of contemporaneous records to substantiate the deliberation and decisions made by the organization's governing body. Scope: this policy applies to the compensation of all officers and key employees of birchbark, as defined by the irs and the organization's bylaws. Policy statement: birchbark foundation, inc. Is committed to ensuring that the compensation of its officers and key employees is consistent with the organization's mission, financial health, and applicable laws and regulations. The compensation process will be conducted in a manner that is objective, transparent, and free from conflicts of interest. Procedures: 1.independent review: ocompensation committee: the board of directors shall establish a compensation committee composed of independent directors who have no conflicts of interest regarding the compensation arrangements of the officers and key employees being reviewed. Oindependence requirement: no member of the compensation committee shall have a direct or indirect interest in the compensation being determined. Members must be free from any relationships or interests that could impair their ability to make unbiased decisions. 2.use of comparability data: odata collection: the compensation committee shall obtain and review appropriate comparability data before making any compensation decisions. This data may include, but is not limited to: compensation surveys conducted by independent firms information about compensation levels for similarly qualified individuals in comparable positions at similar organizations written offers from comparable organizations competing for the services of the officer or key employee compensation paid by other nonprofit organizations, taking into account geographic location, size, and scope of activities omarket analysis: the committee shall analyze the data to ensure that the compensation being considered is reasonable in light of the comparability data reviewed. 3.contemporaneous substantiation of deliberation and decision: odocumentation: the compensation committee shall document the entire process of determining compensation, including: the terms of the compensation arrangement the date and details of the meeting(s) where the compensation was discussed and approved the members of the committee who were present during the deliberations and their vote the comparability data relied upon and how it was obtained any actions taken to resolve potential conflicts of interest the basis for the final determination of compensation ominutes: detailed minutes of the committee's meetings shall be recorded and approved promptly after the meeting. These minutes shall serve as the official record of the committee's deliberations and decisions. Orecord retention: all documents, including minutes, comparability data, and other relevant materials, shall be retained in accordance with birchbark's document retention and destruction policy. 4.final approval: oboard ratification: the compensation committee's recommendations shall be submitted to the full board of directors for final approval. The board shall review the committee's work and ratify the compensation arrangements if they agree with the recommendations. Oconflict of interest recusal: any board member with a conflict of interest regarding the compensation arrangement shall recuse themselves from the discussion and voting process”

“The organization makes their governing documents available to the public by written request.”