Kids Across America

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Conflict of Interest Policy

  1. Reason for Statement

    Kids Across America Foundation (aka I’m Third Foundation) here in referred to as “the
    organization.” The organization, as a ministry initiated and sustained by God, has amandate to conduct all of its affairs decently and above reproach both in the sight of God and man. That accountability includes a commitment to operate with the highest level of integrity and to avoid conflicts of interest. This duty is underscored by Standard #6 of
    the Evangelical Council for Financial Accountability (ECFA).

    As a nonprofit, tax-exempt entity, the organization depends on charitable contributions from the public. Maintenance of its tax-exempt status is important both for its continued financial stability and for the receipt of contributions and public support. Therefore, the IRS and state corporate and tax officials view the operations of the organization as a public trust, accountable to both governmental authorities and members of the public.

    Between the organization and its Board, officers, and management employees, there exists a fiduciary duty which carries with it a broad and unbending duty of loyalty. The Board, officers, and management employees have the responsibility to administer the affairs of the organization honestly and prudently, and to exercise their best care, skill and judgment for the sole benefit of the organization. Those persons shall exercise the utmost good faith in all transactions involved in their duties, and they shall not use their positions with the organization or knowledge gained there from for their personal benefit. The interests of the organization must have the first priority, and all purchases of goods and services must be affected on a basis that secures for the organization full competitive advantages as to product, service and price.

  2. Persons Concerned This statement is directed to Trustees and officers, and those employees annually designated by the Board who can influence the actions of the organization or its Board, or make commitments on their behalf. For example, this would include all who make purchasing decisions, all other persons who might be described as “management personnel,” and all who have proprietary information concerning the organization.

  3. Areas in Which Conflicts May Arise

    Conflicts of interest may arise in the relations of Trustees, officers, and management
    employees with any of the following third parties:

    1. Persons or entities supplying goods and services to the organization.
    2. Persons or entities from whom the organization leases property and equipment.
    3. Persons or entities with whom the organization is dealing or planning to deal in connection with the gift, purchase or sale of real estate, securities, or other property.
    4. Persons or entities paying honoraria or royalties for products or for service delivered by the organization for its agents or employees.
    5. Other ministries or nonprofit organizations.
    6. Donors and others supporting the organization.
    7. Stations or programmers carrying the organizations programming.
    8. Agencies, organization and associations that affect the operations of the organization.

  4. Nature of Conflicting Interest

    A material conflicting interest may be defined as an interest, direct or indirect, between any person or entity mentioned in Section 3, and a Trustee, officer or management employee, which might affect, or might reasonable be thought by others to affect, the judgment or conduct of a Trustee, officer or management employee of the organization. Such an interest might arise through:

    1. Owning stock or holding debt or other proprietary interests in any third party dealing with the organization.
    2. Holding office, serving on the Board, participating in management or being otherwise employed (or formerly employed) in any third party dealing with the organization.
    3. Receiving remuneration for services with respect to individual transactions involving the organization.
    4. Using the organization’s personnel, equipment, supplies or goodwill for other than organization approved activities, programs and purposes.
    5. Receiving personal gifts or loans from third parties dealing with the organizations. Receipt of any gift is disapproved except gifts of nominal value which could not be refused without discourtesy. No personal gift of money should ever be accepted).
    6. Obtaining an interest in real estate, securities or other property that the organization might consider buying or leasing.
    7. Expending staff time during the normal business hours for personal affairs or for other organizations, civic or otherwise, to the detriment of work performance for the organization.

  5. Indirect Interest

    As noted above, conflicting interests may be indirect. A Trustee, officer or management employee will be considered to have an indirect interest in another entity or transaction if any of the following have an interest:

    1. A family member of a Trustee, officer or management employee. (Family member is defined for these purposes as all persons related by blood or marriage).
    2. An estate or trust of which the Trustee, officer or management employee or member of his family is a beneficiary, personal representative, or trustee.
    3. A company of which a member of the family of the Trustee, officer or management employee is an officer, director or employee, or in which he has ownership or other proprietary interest.

  6. Interpretation of This Statement of Policy

    The areas of conflicting interest listed in Section 3, and the relations in those areas which may give rise to conflict, as listed in Section 4, are not exhaustive. Conceivably, conflicts might arise in other areas or through other relations. It is assumed that the Trustees, officers, and management employees will recognize such areas and relation by analogy.

    The fact that one of the interests described in Section 4 exists does not necessarily mean that a conflict exists, or that the conflict, if it exists, is material enough to be of practical importance, or if material, that upon full disclosure of all relevant facts and circumstances that it is necessarily adverse to the interests of the organization. However, it is the policy of the Board that the existence of any of the interests described in Section 4 shall be disclosed before any transaction is consummated. It shall be the continuing responsibility of Trustees, officers and management employees to scrutinize their transactions outside business interests and relationships for potential conflicts and to immediately make such disclosures.

    Disclosure should be made to the President (or if he is the one with the conflict, then to the Chairman of the Board), who shall bring these matters to the attention of the Board. The Board shall then determine whether a conflict exists and is material, and in the presence of an existing material conflict, whether the contemplated transaction may be authorized as just, fair and reasonable as to the contemplated transaction may be authorized as just, fair and reasonable as to the organization. The decisions of the Board on these matters will rest in their sole discretion, and their first concern must be the welfare of the organization and the advancement of its purposes.

    CERTIFICATION I HAVE CAREFULLY READ THE FOREGOING Statement of Policy concerning Conflicts of Interest and, in signing this certificate, I have considered not only the literal expression of the policy, but also its intents I hereby certify that, except as hereinafter stated, I do no, to the best of my knowledge: (1) have any of the relations described in Section 4 with any person or firm of the classes listed in Section 3: and (2) I have no interests conflicting with the interest of this organization, nor do I have any relationship that may appear conflicting.

    THE EXCEPTIONS ARE: If any situation should arise in the future which I believe may involve me in a conflict of interest, I will promptly and fully disclose the circumstances to the President or the Chairman of the Board, directly or through my immediate superior.

Kids Across America Whistle Blowers Policy

Kids Across America is committed to developing and maintaining open lines of communication with and among employees and uses a variety of communication methods to insure employees are kept informed, listened to and have an opportunity to provide input.

In addition, all employees have responsibilities which require timely sharing of information and concerns with leadership. You are encouraged to bring any concerns to the attention of your supervisor or anyone in management.

However, there may be times where more discreet communication is warranted. KAA is offering another avenue for employees to report something ethically or legally wrong at work via our HOTLINE program:

If you see something ethically or legally wrong at work – including THEFT, DISCRIMINATION, DISHONESTY, DRUG/ALCOHOL USE, UNSAFE PRACTICES, HARASSMENT, THREATENING BEHAVIOR, POLICY VIOLATIONS please call this toll free number: 877-509-3509

This hotline is operated 24/7 by a company called “The Network” which specializes in this type of hotline program. You will not be required to identify yourself unless you so choose to do so. In fact, in order to encourage employees to call, our contract with the Network specifies that they not let us know the identity or phone number of a caller unless you give them the ok to provide it.

We will use the information you provide to do a thorough investigation and take appropriate action. Please be as detailed as possible when you call in, because we must be able to substantiate reports in order to take definitive action. Feedback and follow-up back to the anonymous caller via The Network can also be done if requested by the caller.

Child Protection Plan Training

FULL TIME STAFF

All of our full time summer staff receives extensive training throughout the year in the following areas

  1. Risk Management
  2. Crisis Management
  3. Safety Policies & Procedures
  4. Zero Tolerance Policies Regarding Abuse
  5. Comprehensive Sexual Abuse Awareness & Prevention
  6. Proper conduct:
    1. Proper conduct is communicated to staff in writing, verbally, and modeled in the lives of our leadership staff
    2. Staff to Kamper conduct is stressed during staff training.
    3. Specific policies regarding modesty and one-on-one meetings


SUMMER STAFF

All summer staff receives training in the following areas:

  1. Summer Staff receive training on KAA policies and procedures prior to arrival of the campers
  2. Comprehensive Sexual Abuse Awareness & Prevention
  3. Certified Operator Instruction & Testing on all High Risk Activities
  4. Proper conduct:
    1. Proper conduct is communicated to staff in writing, verbally and modeled in the lives of our leadership staff
    2. Staff to Kamper conduct is stressed during staff training.
    3. Specific policies regarding modesty and one-on-one meetings provide accountability and security.
  5. Reporting System

In addition, no less than six corporate safety teams evaluate and oversee all activities at our Kamps. Each Kamp is also staffed with a “safety officer” who provides oversight and enforcement of safety practices.

KAMPER ORIENTATION

To promote a positive and healthy Kamp experience, each Kamp conducts Kamper orientation talks that include the following topics:

  1. Opening Day Safe & Secure Talk – In an age-appropriate manner, all Kampers will be instructed on what
    kinds of visual, verbal, and physical conduct are appropriate and what kinds are inappropriate at Kamp. This includes staff to Kamper conduct, Kamper to Kamper conduct, and modesty & one-on-one policy.
  2. Year-round Kamper contact – Godly relationships are an important part of the Kids Across America experience. We want to stay in contact with your family throughout the year in a way that respects your family and provides encouragement. We’ll explain what your Kamper should expect in terms of continuing communication from Kamp.
  3. Reporting System — At the beginning of every term, each Kamp will educate Kampers on the different methods available to report inappropriate conduct at Kamp.


A KALEO/PARENT’S ROLE

Kids Across America is committed to doing everything it can to protect children. Research supports that the best defense against child abuse is an informed and empowered child. Kaleo/Parents continue to be the primary source of protection and are encouraged to take an active role in preparing their children. Kids Across America recommends that kaleo/parents further educate themselves through the many good resources available and then have appropriate conversations with their children. Through the Kids Across America web site and e-mail correspondence, Kids Across America is committed to partner with kaleo/parents in this endeavor by providing information and education on hiring, training, and reporting practices that we use to create a positive and healthy environment for each Kamper.

Donor Privacy Policy

Kids Across America is committed to respecting the privacy of our donors. We have developed this privacy policy to ensure our donors that donor information will not be shared with any third party.

Awareness:
Kids Across America provides this Donor Privacy Policy to make you aware of our privacy policy, and to inform you of the way your information is used. We also provide you with the opportunity to remove your name from our mailing list, if you desire to do so.

Information Collected:
Here are the types of donor information that we collect and maintain:

  • e contact information: name, organization/church, complete address, phone number, email address;
  • payment information: credit card number and expiration date, and billing information;
  • shipping information: name, organization/church, complete address;
  • information concerning how you heard about Kids Across America;
  • information you wish to share: questions, comments, suggestions; and
  • your request to receive periodic updates; e.g., to individuals who request it, we will send periodic mailings related to specific fund-raising appeals, prayer concerns, and newsletters.

How Information is Used:
Kids Across America uses your information to understand your needs and provide you with better service. Specifically, we use your information to help you complete a transaction, communicate back to you, and update you on ministry happenings. Credit card numbers are used only for donation or payment processing and are not retained for other purposes. We use the comments you offer to provide you with information requested, and we take seriously each recommendation as to how we might improve communication.

No Sharing of Personal Information:
Kids Across America will not sell, rent, or lease your personal information to other organizations. We assure you that the identity of all our donors will be kept confidential. Use of donor information will be limited to the internal purposes of Kids Across America and only to further the ministry activities and purposes of Kids Across America.

Removing Your Name From Qur Mailing List:
It is our desire to not send unwanted mail to our donors. Please contact us if you wish to be removed from our mailing list.

Contacting Us:
If you have comments or questions about our donor privacy policy, please send an email to [email protected] or call us at 417 266-3131.