NNNGO RECORDS RETENTION POLICY

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NNNGO RECORDS RETENTION POLICY

Records Retention Policy

I. Objective.

The objective of this Records Retention Policy is to further HOFOWEM’s mission by ensuring that Hope for Women in Nigeria Initiative operates effectively and efficiently and complies with all applicable laws and regulations governing the management, retention and destruction of HOFOWEM’s records.


II. Criminal Sanctions and Other Penalties

This Records Retention Policy is intended to ensure and facilitate HOFOWEM’s compliance with all applicable laws and regulations governing the retention and destruction HOFOWEM’s records. Federal, and other laws and regulations require Hope for Women in Nigeria Initiative to maintain certain types of records for particular periods. Failure to maintain such records may subject the organization and/or individuals to penalties and fines and may compromise the organization’s position in litigation. It is a federal crime, punishable by a fine and up to twenty years in prison, for anyone to knowingly alter, destroy, mutilate, conceal, cover up, falsify, or make a false entry in any record with the intent to impede, obstruct, or influence the investigation or proper administration of any matter within the jurisdiction of a federal department or agency or any bankruptcy case. The same penalty applies to anyone who alters, destroys, mutilates, or conceals a record, or attempts to do so, with the intent to impair the object’s integrity or availability for use in an official proceeding, regardless of whether such proceeding is pending or about to be instituted at the time of the offense


III. Implementation of Policy

It is the responsibility of each Hope for Women in Nigeria Initiative employee to maintain and destroy the records that he or she originates, or otherwise receives, in accordance with this Records Retention Policy (and any procedures adopted by HOFOWEM and/or the Records Management Officer) and in order to comply with all applicable federal, and other laws and regulations governing the retention and destruction of HOFOWEM’s records, as such may be communicated by the Records Management Officer, from time to time. An employee need not maintain a copy of a record when the original or an official copy is maintained elsewhere.


IV. Record Defined

A “record” is any recorded information in any format (including without limitation paper, electronic and audiovisual materials), wherever such information is stored, that has been created by or for Hope for Women in Nigeria Initiative, or received by HOFOWEM in connection with the transaction of the organization’s business. Informal materials of transitory utility (e.g., temporary notes of internal meetings, casual or personal email, etc.) shall not be considered “records” for purposes of this Records Retention Policy.


V. Records Management Officer

The Chief Administrative Officer or other designated staff member shall serve as HOFOWEM’s Records Management Officer. To ensure compliance with this Records Retention Policy, the Records Management Officer is responsible for overseeing the implementation of, and compliance with, this Records Retention Policy.


VI. Retention of Records

A. Retention Schedule.

The Retention Schedule, attached to this Records Retention Policy as Appendix A, lists the time period during which specific types of records shall not be destroyed. In the event a record is not listed on the Retention Schedule, contact the Records Management Officer to determine the appropriate retention period for such record.


B. Disposition of Records;

Retention Beyond Applicable Retention Schedule Period Employees shall dispose of all records following the expiration of the applicable retention period in accordance with this Records Retention Policy, unless (i) the Records Management Officer determines that a record must be retained for a longer period to comply with legal or other requirements or (ii) the employee who originates or receives the record or the Records Management Officer determines that retention of the record for a longer period otherwise serves a reasonable business purpose. The Records Management Officer shall promptly communicate to employees the decision to suspend or extend an applicable retention period for HOFOWEM’s records (see Section VII below).


VII. Suspension of Destruction of Records

If a lawsuit, claim or other legal proceeding, or government investigation or government inquiry (a “Matter”) is pending or threatened against Hope for Women in Nigeria Initiative, the Records Management Officer shall suspend any scheduled disposal of relevant documents and promptly notify employees of such suspension.

Records with potential relevance to a Matter (whether pending or threatened) must not be destroyed–in accordance with the attached Retention Schedule or otherwise–unless the Records Management Officer, on advice of legal counsel, has authorized such destruction.

Employees who become aware of a Matter (whether pending or threatened) against Hope for Women in Nigeria Initiative shall promptly notify the Records Management Officer so that HOFOWEM can ensure the preservation of all records relating to such Matter in accordance with this Section VII. Employees must consult with the Records Management Officer (who shall consult with legal counsel for HOFOWEM) before disposing of records that may be needed in connection with a Matter (whether pending or threatened). Hope for Women in Nigeria Initiative shall take reasonable steps actively to preserve evidence and maintain any documents or information that may be discoverable in connection with such Matter.

In the event of the occurrence of a Matter (whether pending or threatened), the definition of the term “record” may be expanded to include even transitory documents that refer or relate in some way to such Matter, and employees may be asked to preserve such records.

This Section VII supersedes the timing of records destruction pursuant to the Retention Schedule. On conclusion of the Matter, general applicability of the Retention Schedule shall resume only after the Records Management Officer, on advice of legal counsel, has authorized such resumption.

Adopted: July 11, 2016, 2007

Amended:


APPENDIX A


RETENTION SCHEDULE


Record Category Record Type Minimum Retention Requirement
1. CORPORATE/ORGANIZING DOCUMENTS A. Organizational:
• Bylaws (including all amendments)
• Corporate Charter (including all amendments)
• Corporate Seal
• Qualifications to do Business
• State Licenses and Registrations
• Taxpayer Identification Number
Permanent
B. Board of Directors:
• Agendas
• Audit Reports (internal)
• Board Books
• Board Presentations
• Board Resolutions/Minutes
• Committee Charters
• Committee Resolutions/Minutes
• Committee Reports
• Conflict of Interest and other Board Policies
Permanent
• Compensation Consultant Reports/ Compensation Studies Relating
to Compensation of Directors, Officers and Key Employees
• Conflict of Interest Disclosure Forms
• Correspondence with Directors
• Determinations Relating to Compensation of Directors, Officers
and Key Employees
• Determinations Relating to Transactions with Related Parties
• Investment Reports/Briefings
Seven years
C. Tax-Exemption: • Application for Tax Exemption (including all related
correspondence with IRS) • IRS Determination Letter
•Post-Determination Letter Correspondence with IRS Regarding
Tax-Exempt Status
• State Tax Exemption (application and related materials)
Seven years
D. Tax and Tax Accounting; State Reporting:
• Correspondence with State Tax Authorities
Permanent
• Federal Tax Returns (Form CAC/IT 4.)
• State Tax Filings
• Annual/Periodic State Reports
• Backup Tax Work papers and Related Documentation
• Internal Determinations Relating to Income and Excise
Tax Liability
Seven years
E. IRS Audit-Related Materials:
• Closing Agreements
• Revenue Agent Reports
Permanent
• IDRs and Responses thereto Seven years
II.GENERAL RECORDS • Annual Reports Permanent
• Correspondence and Letters
• Documentation of Exempt Function Activities
• Press Releases
• Promotional and Sponsorship Materials
Seven years
III.GRANTS/ DONATIONS/AWARDS A. Grant Proposals:
• Awarded Grants
Seven Years (from date of final grant report)
• Rejected Grants One Year (from date of rejection)
B. Grant Award Letters/Agreements (including all exhibits) Seven Years (from date of final grant report)
C. Grant Rejection Letters One Year (from date of rejection)
D. Grant Reports Seven Years (from date of final grant report)
IV.ADMINISTRATION A. General:
• Insurance Policies
Permanent
• Building & Equipment Leases and Related Agreements Seven Years (after termination of lease)
B. Policies and Procedures:
• Accounting
• Internal Controls
• Personnel Policies
• Other Related Materials
Seven Years (from expiration or termination of policy)
C. Procurement:
• Contracts
Seven Years (from termination of contract)
• Purchase Orders Seven Years
V. BENEFIT AND RETIREMENTPLANS • Employee Benefit Plan Documents – Plan Documents, Summary
Plan Descriptions, Superseded Plan Documents and Summary Plan
Descriptions, Notices, IRS Letter of Determination,
Insurance Contracts, and Third Party Administrator
Contracts (including medical, dental, life, and disability plans) • Employee Benefit Files – Benefit Information Filed by
Employee Name (including benefit statements, benefit elections, beneficiary
designations, annuity contracts, benefit calculations,
and compensation and service histories) • Minutes –Employee Benefit Plans’ Board of Directors
Meetings (including investment committee meetings, etc.) • Employee Benefit Plans’ Board of Directors Reports –
monthly financial statements • Investment Reports (summary) • Outside Investment Managers (contracts and investment
performance reports)
Permanent
• Monthly Premium Bills and Census Seven Years
• Qualified Domestic Relations Orders Six Years (from the date participant or beneficiary no
longer has an accrued benefit under the plan)
• Summary Annual Reports Six Years (from the date participant/alternate payee no longer
has an accrued benefit under the plan)
• Claims Files Six Years (from the date the approved or denied claim is final)
• Plans’ Annual Reports on Form CAC/IT 4 (and
all supporting documents)
Six Years (from the date the Form is filed)
• Plans’ Annual Financial Statements Six Years (from the end of the year to which the audit applies)
• Plan Testing Records – Discrimination Tests Six Years (from the end of the year in which
the testing records are used)
• Investment Records (detail) Six Years (from the date of the transaction)
• Tax Deduction Records (records sufficient to justify
employer deductions for plan contributions)
Six Years (from later of date of filing or payment of tax)
• Payroll Records Six Years (after the later of return due date or date tax is paid)
VI.FINANCE A. General Accounting
• Audited Financial Statements
• Auditors Reports; Management Letters
• General Ledger (one copy for each calendar year)
Permanent
• Accounts Payable Ledgers and Schedules
• Accounts Receivable Ledgers and Schedules
• Accruals
• Budgets; Related Reports
• Cash Receipts and Disbursements
• Employee Benefits Paid
• Expense Reports
• Fees and Commitments
• Investment Account Statements
• Journal Entries
• Notes Receivable Ledgers and Schedules
• Other Financial Reports
• Payment Files
• Payroll Records (including computer service company records)
• Petty Cash Vouchers
• Prepaid Items
• Reconciliations
• Time Sheets/Leave Reports
• Travel Vouchers
• Wire Transfers
• Year End Adjusting Entries
• Year End Trial Balances
Seven Years
• Capital Assets Schedule
• Depreciation Schedules
Seven Years (after item is fully depreciated)
B. Banking and Related Materials
• Bank Statements
• Canceled Checks
• Cash Receipts
• Chart of Accounts
• Check Register
• Check Requests and Expense Reports
• Checks and Check Stubs
• Delegation of Authority
• Deposit Slips
• Interest Statementss
Seven Years
C. Tax-Related Material
• Cost or other Proof of Substantiation for Tax Basis of Property
• IRS Forms & Other Employment Tax Forms
Seven Years
D. Interim Financial having a relatively short useful life may be
generated and circulated. Such information should be retained only
so long as it is actively being used. Once superseded, or once the
information is incorporated into a quarterly or yearly report, most
interim summaries and reports have no further value. Consequently,
interim reports and similar items containing information within the
categories outlined above generally do not need to be retained if
they are superseded or their data is incorporated into a more
comprehensive report. Please check with the Records Management
Officer before disposing of such materials.
Check with Records Management Officer
VII.PERSONNEL RECORDS A. Personnel Files:
• Official Personnel Files of Active Employees
Retained During Active Employment
• Information Relating to Charges or Complaints
of Discrimination (pending or reasonably foreseeable)
Retained Until Final Disposition of All Legal
Proceedings Relating Thereto
• Official Personnel Files of Inactive Employees (Including
staff employment agreements and annual evaluations;
security clearance information)
Six Years (after employment period ends except
as otherwise indicated in this section and as
applicable for benefits-related records above)
• Personnel Records—other (Personnel records relating to
recruitment and hiring (including records pertaining to a
decision not to hire particular individuals, job orders
submitted to employment agencies for recruitment; and
advertisements or notices relating to job openings);
employment terminations and resignations; and other
personnel actions)
Six Years (from the date of the personnel action)
• Immigration and Nationality Documents Six Years (from hire date or one year after
termination, whichever is later)
B. Wage and Hour (Payroll) Records
• Staff Salary Summaries
• Payroll Records including: name, employee identification
number, home address, date of birth, gender, occupation,
time of day and day of week on which employee’s work week
begins, total wages for each pay period, and date of payment

• For Non-Exempt Employees: records reflecting regular hourly rate
of pay; amount/nature of any payment excluded from the employee's
“regular rate” of pay; hours worked each workday, total hours worked
each work week; straight-time earnings, overtime pay, any additions/
deductions to wages; schedule of hours normally worked

• For Exempt Employees: records providing detailed explanation of
basis on which wages are paid to permit calculation for each pay
period of the employee’s total remuneration for employment,
including fringe benefits.
Three Years
C. Medical Records
• Material Related to Claims under Workers Compensation Laws
• Material Related to Claims under State/District Disability Laws
Seven Years (after completion)
Family and Medical Leave Act Leave Request (Forms, Medical
Certifications, Correspondence and Related Documentation)
• Material Evidencing Compliance with Occupational Safety
and Health Administration Requirements
Six Years
• Accommodation Requests and Related
Documentation Generated in Compliance with the
Americans With Disabilities Act
Six Years (from date record was made or from date
of personnel action, whichever is later. If
accommodation ongoing, maintain records through
period of employment and thereafter as noted above)
VIII. LEGAL • Property Records
• Property Appraisals
• Documents Related to the Acquisition and Sale
of Real Property
• Records of Efforts not to Infringe any Patent,
Trademark, Copyright, or Trade Secret
• Confidentiality and Nondisclosure Agreements
• Copyright Registrations
• Copyright Permissions for Use of Others’
Copyrighted Material
Permanent
• Regulatory Affairs Seven Years
• Contracts/Agreements (unless specifically
addressed elsewhere in this policy) • Deeds/Titles: Certification Letters • Licenses
Seven Years (after date of expiration)
• Litigation Seven Years (after final decision)
• Computer Software Licenses Seven Years (after use of software)