Privacy and Security
Since our founding, the Elk County Community Foundation has been committed to maintaining the confidentiality, integrity and security of personal information entrusted to us by current donors, potential donors, the officers and staff of nonprofit agencies who approach us for funding and the people that they serve.
Like all organizations with a Web presence, the Elk County Community Foundation receives standard tracking data: information from your browser, including your IP address and the page you visited, is recorded in our Web site server logs. This data is analyzed internally to determine how to best provide information to visitors to our Web site as well as to help diagnose problems with our server. We do not collect e-mail addresses. Personal information is never collected during this tracking process. We do not share, loan, rent, or sell information of any kind that we receive from users. The Foundation does not collect information about individuals who come to the website.
Information that you provide to us by filling out online forms is located on a secure server. We have put into effect appropriate procedures to safeguard and secure the information we collect online.
Once you provide us with personal or professional information, that data remains confidential. We will not share any information you provide with any individual or organization.
Links to Other Sites
Copyright in the text materials contained in this Web site is owned by the Elk County Community Foundation. These text materials may be used, downloaded, reproduced or reprinted, provided that this copyright notice appears on all copies and provided that such use, download, reproduction or reprint is for noncommercial or personal use only. The text materials contained in the Web site may not be modified in any way.
Copyright in the photographs, illustrations, artworks and other graphic materials are reserved to the Elk County Community Foundation and/or the copyright owners (licensors). Prior permission to use, download, reproduce or reprint any photograph, illustration, artwork or other graphic material must be obtained by the copyright owner, regardless of intended use.
Any use of "Elk County Community Foundation," its logo, text, and/or graphic materials contained in this Web site in any manner to express or imply endorsement, sponsorship, affiliation or association of the user with or by the Elk County Community Foundation, is strictly prohibited.
Web Links to The ECCF Web Site
You may establish a hypertext link to this site from your Web site, so long as the page containing the link properly attributes the linked site to the Elk County Community Foundation and does not state or imply any sponsorship of your site by the Elk County Community Foundation. We may revoke this permission at any time. Without prior written consent of the Elk County Community Foundation, you may not create a link to this site that incorporates or relies upon, in whole or in part, any content from any page on this Web site, or that incorporates any copyrighted or otherwise intellectual property of the Elk County Community Foundation.
GRANTEE GRIEVANCE POLICY
The Elk County Community Foundation is committed to fostering communication with applicants for whom grants were denied. The following policy will be followed by all Foundation staff:
1. Grant denial letters will be drafted and distributed in a timely manner.
2. The reason(s) for denial should be presented in the letter, as determined by the Executive Director.
3. The Executive Director will handle phones calls, letters, e-mails or other communications regarding a denied application.
4. The Executive Director will personally respond to the applicant through a telephone call or meeting. Any significant actions or follow-up will be documented and placed in the applicant's file to be made available for review during subsequent funding cycles.
5. If the applicant is not satisfied with communications with the Executive Director, the issue is referred to the Board of Directors.
Donor Grievance Policy
The Community Foundation maintains an open-door grievance policy. Donors are encouraged to express any dissatisfaction they have after working with the Community Foundation.
The Foundation follows the wishes of the donor as stated in the fund agreement. If the Foundation does not follow the terms of the agreement, it could loose its status as a public foundation. It would be highly unusual for a community foundation to not follow the donors’ wishes.
The Executive Director will try to remedy the situation on the spot. If it is a policy matter, the director will take the issue to the executive committee. If the committee feels it is a situation requiring a board vote, the topic will be brought before the board.
Conflict of Interest Policy
The Elk County Foundation is committed to integrity and fairness in the conduct of all of its activities. Inevitably, the interests of Directors and staff employees will involve them in organizations, causes, and other endeavors which may intersect with the affairs of the Foundation. It would disadvantage the Foundation to deprive it of the involvement of interested colleagues, but their participation in Foundation decision making cannot impair the fairness and integrity of Foundation processes. This statement of principle is intended to further the work of the Foundation by facilitating the contributions of its employees and Directors through providing for disclosure of other interests and by requiring abstention from decision-making actions which affect non-Foundation affiliations or interests. These principles are intended to preclude any such appearance of a conflict of interest because the Foundation would suffer if there were any appearance of bias or self-interest in its activities.
Directors and staff employees of the Foundation are committed to communicating fully with the Foundation regarding any relationships or commitment which could affect the impartial fulfillment of their role in the affairs of the Foundation. This policy refers to such a relationship or commitment as affiliation. Affiliation may be defined as the close involvement with a vendor, service provider, or grantee on the part of (a) a director of the Foundation (b) staff member of the Foundation, or (c) the spouse or equivalent, parents, or children of a director or staff member.
Affiliation includes, but is not limited to, serving as a board member, employee, or consultant to a current or potential grantee, service provider, or vendor, or doing business with the grantee, service provider, or vendor. Antecedent affiliations and indirect associations also warrant disclosure. In principle, extra-Foundation affiliations or interests should be disclosed to other participants in the Foundation’s decision-making process whenever there is any doubt about whether disclosure is required.
Disclosures regarding affiliations or conflicts of interest ordinarily should be made by members of the staff or Board to the Executive Director or to the President of the Board of Directors. Formal notation of disclosure should be part of the process and documented in Board meeting minutes as appropriate.
Abstention from Foundation Decision Making
In all situations in which disclosure of affecting relationships should be made, the Foundation-affiliated individual should abstain from decision-taking actions, and that abstention should be formally noted in the Foundation’s minutes. With disclosure to other participants, the work of the Foundation is furthered by the willingness of its employees and Directors, however interested, to share information bearing upon the matter under consideration. Such participation is encouraged.
No Return Benefit
In considering any decision regarding an organization or person with which a Foundation employee or Director is affiliated, the Foundation shall avoid any transaction which results in any direct or indirect economic benefit to the affiliated person or which would constitute self-dealing under Internal Revenue Code Section 4941. Incidental and tenuous benefits to affiliated persons, such as name recognition or public acknowledgment, are permitted.
Avoid the Appearance of Conflict
While substance of integrity is the essence of the Foundation’s approach to these matters, avoiding the appearance of conflict is an important collateral objective. To that end, the Foundation will not customarily make grants to, or contract with, organizations which employ affiliated persons. The Board of Directors may vote to approve exceptions to this policy when the work of the Foundation will be furthered thereby or where the grant or contract will not affect the job or compensation of the affiliated person in question.
No significant personal benefit of any nature may be derived by any affiliated person from any such organization.
This Conflict of Interest Policy shall be reviewed annually with all Elk County Community Foundation Board of Directors and Staff members. Documentation of this review will include annual policy notification and signed statement of understanding and compliance to be retained on file by the Executive Director.
Confidentiality of Donor Records & Donor Anonymity Policy
The Elk County Community Foundation recognizes that the efficient operation of the Foundation requires the maintenance and management of extensive donor and prospect records. These records often contain sensitive information that has been shared with or developed by the Foundation staff on a confidential basis.
Additionally, donors and prospects are frequently attracted to The Community Foundation on the basis of its ability to assure temporary or permanent anonymity. The purpose of this policy is to state the position of the Foundation on anonymity and donor/prospect records. “Records” means all files, including electronic data, containing information on donors or prospective donors to the Foundation.
Confidentiality of Records
The executive director shall be responsible for maintaining the confidentiality of donor and prospect records. The director may, in his/her discretion, make all or part of any record available to staff members or Foundation volunteers to assist them in executing their responsibilities.
The Foundation’s auditors are authorized to review donor and prospect records as required for the purposes for which they are engaged.
To carry out its responsibilities, the Board of Directors may also need to review donor/prospect records. All board members shall respect the Foundation’s significant interest in protecting the sensitive nature of those records.
Publication of Donor Names
Unless otherwise requested by the donor, the names of all individual donors will be listed in the Foundation’s annual report and/or in other appropriate vehicles. Donors may request in writing or email to have their names removed from any or all publications. The Foundation will not publish the amount of any donor’s gift without the permission of the donor. Donors making gifts to the Foundation by bequest or testamentary devise are deemed to have granted such permission.
Donors should be aware that it is the Foundation’s policy to, from time to time, publish the current market value of its funds, from which a reader may be able to determine the approximate size of a donor’s gift.
The names of donors of memorial or honor gifts may be released to the honoree, next of kin, or appropriate member of the immediate family, unless otherwise specified by the donor. Gift amounts are not to be released without express consent of the donor.
The executive director is authorized to accept anonymous gifts to the Foundation. In the event the Executive director is uncertain about the desirability of accepting an anonymous gift, he/she shall consult with the Executive Committee.
The executive director shall disclose to the Executive Committee, upon a request by a majority of the Executive Committee, the names of any anonymous donors.
The Elk County Community Foundation honors all requests by donors to curtail mailings and/or solicitations. Donor lists are not shared with any other organization.
The Elk County Community Foundation assures that its solicitations are free from undue influence or excessive pressure, and are respectful of the needs and interests of donors or potential donors.
The Elk County Community Foundation
Statement of Investment Policy and Guidelines
Statement of Purpose
The Elk County Community Foundation is a vehicle that will enable citizens of Elk County and surrounding areas to achieve their philanthropic expectations and in so doing strengthen the quality of life in the region. The Elk County Community Foundation is prepared to assist those organizations and institutions designed to enhance the social welfare of the area. In carrying out this mission the Foundation provides matching money grants, seed money, and partnership grants to a host of educational, health care, cultural, youth development, social welfare, and community development needs.
The Foundation is a public supported charitable organization under Section 501 (c) (3) of the Internal Revenue Code. Its purpose is to be a vehicle to receive and accept gifts to be administered for charitable purposes primarily in and for the Elk County region of Pennsylvania.
The purpose of the Statement of Investment Policy and Guidelines is to assist the Directors of the Elk County Community Foundation (the Directors) in more effectively supervising and monitoring the investment activities of the Foundation by:
- Stating in writing attitudes, expectations, and goals for the investment of Foundation assets;
- Detailing the spending policy to meet the short-term and long-term objectives of the Foundation;
- Providing a basis for reviewing all investment management organizations;
- Encouraging effective communication between the Directors and their investment managers; and
- Setting objectives against which the performance results can be measured.
The Directors will review this Statement of Investment Policy and Guidelines at least annually, and they will approve all material changes to it.
The Foundation assets are to be managed in accordance with the policy guidelines expressed herein, or expressed by separate written instructions when the Investment Committee deems deviation prudent and desirable
Roles and Responsibilities
Elk County Community Foundation Directors
The Directors are responsible for approving this and future investment policy statements of the Foundation.
Elk County Community Foundation Investment Committee
The Investment Committee (“Committee”) is responsible for determining investment policies and strategies, and selecting and monitoring the performance of the investment managers/mutual funds, investment advisors, and other fiduciaries.
Elk County Community Foundation Staff
The primary responsibilities of the Elk County Community Foundation Staff include:
- Carrying out policies set by the Directors and Committee
- Day to day operations
- Making, recording and auditing financial transactions
- Providing quarterly performance reports
General Objectives & Guidelines
I. Investment Goals
The broad-based investment goals of the Foundation are to:
- Protect the integrity of the Foundation’s asset base and to assist the Foundation in meeting its goals;
- Provide for the operating needs of the Foundation;
- At a minimum, preserve the inflation adjusted value of the Foundation assets after administrative costs and spending needs;
- Prudently invest assets in a high-quality, diversified manner;
- Achieve the optimal return possible within the specified risk parameters; and
- Adhere to the established guidelines.
Beginning in calendar 2002, the annual spending policy, including expense disbursements for charitable purposes, of the Foundation’s assets is to be 4%, plus fees of the market value as of 12/31 of the previous year. However, the distribution will be monitored to comply with IRS requirements. This amount will be determined annually and may vary depending on the needs of the Foundation.
The Foundation’s assets will distribute all income generated from the portfolio not to exceed 4%, of the market value, plus its proportionate share of expenses. If income from the restricted assets does not meet a minimum of 4% plus fees, the drawdown will be generated on a total return basis, including, dividends and interest plus realized and unrealized gains. As a result it is expected that principal may need to be spent if income levels are not sufficient to meet the 4% plus fees level. Expenses and payout may very dependent upon the distribution needs of a specific fund as negotiated by the donor and the Foundation.
III. Asset Allocation
Historical performance results and future expectations suggest that common stocks will provide higher total investment returns than fixed-income securities over a long-term investment horizon. However, one can expect an increase in portfolio volatility as the stock percentage is increased.
It is believed that the most significant decision to affect the overall volatility of results is that which controls the split among various asset classes, particularly the equity versus fixed-income ratio. Consequently, the Directors have decided to control this ratio by setting up a long-term asset allocation target. The assets are viewed as having a long-term horizon with moderate liquidity needs, with the exception of short term pass through funds. These will be invested in money market funds. The Committee’s goal is to maximize returns over the long-term and has therefore taken a long-term investment posture, which favors equity holdings.
Based on the investment goals and risk tolerances stated in this document, the following overall asset mix target is considered appropriate:
Investment Category Long-Term Target Range
Equity 60% 50% - 70%
Fixed Income 40% 30%-50%
Cash 0 0%-10%
The long-term allocation will be reviewed annually to determine its appropriateness for the Foundation’s long-term goals.
IV. Investment Policy Guidelines
- Asset Class Diversification
It is the goal of the Foundation to be well diversified. Diversification reduces the risk to the Foundation while maintaining the return potential. Within the equity allocation, the Directors seek appropriate diversification.
Except as stated in any mutual fund prospectus, there shall be no investments in non-marketable securities, short selling, securities lending, options trading, futures trading or other specialized investment activity, unless authorized by the Directors.
Equity Assets - Guidelines
The following investment directions are intended to apply to the investment of the equity portion of portfolio assets.
- Market Timing – Equity funds are designed to remain invested in common stocks. However, if attractive stocks cannot be found or in response to extraordinary market, economic, political or other conditions, the equity funds may invest a significant portion of assets in cash reserves but the Committee must approve holding more than 10% cash.
- Diversification – To protect the portfolio against undo risk of large losses, reasonable precautions shall be taken to avoid excessive concentration. Also, each mutual fund will be prudently diversified, adhering to each fund’s respective prospectus guidelines.
B. Evaluation and Review
The objective of the evaluation and review process is to monitor the program of the Foundation assets in achieving the overall investment objectives. Performance will be measured and reviewed quarterly by the Directors. Investment managers will present timely performance reports measured against the appropriate benchmarks. Particular attention will be directed toward determining whether:
- The total fund is achieving its stated objectives;
- The overall portfolio is performing satisfactorily in relation to both the objectives set forth in this Statement, as a primary consideration, and the stated benchmark composite index.
- The overall policies and objectives continue to be appropriate, reasonable, and achievable.
The guidelines listed below shall apply to the mutual funds chosen to implement the investment strategy. Although the Committee cannot dictate policy to mutual fund investment managers, it is the Committee’s intent to select and retain only mutual funds with policies that are similar to the Elk County Community Foundation, which shall be to protect the assets of the foundation and to strive to maximize total return consistent with the conservative nature of the mutual fund portfolio. Any mutual fund retained is expected to comply with the Securities and Exchange Commission’s disclosure requirements for mutual funds.
All mutual funds selected are expected to adhere to the following criteria:
- Each mutual fund must adhere to its stated philosophy and style.
- Performance objectives shall be as follows:
Managers will be measured against benchmarks developed by the Investment Manager and investment committee.
- If available, percentile ranking of portfolio’s one-year return against peer group should be above 50.
- If available, percentile ranking of portfolio’s three-year return against peer group should be above 50.
- If available, percentile ranking of portfolio’s five-year return against peer group should be above 50.
- Each mutual fund manager shall have the full investment discretion with regard to market timing and security selection, subject to the rebalancing policy set forth in section V.
The portfolio should be rebalanced quarterly back to its target asset mix, if it is out the specified range, using one of two approaches:
- Utilize cash flow to realign the portfolio closer to its original target mix subject to the approval of the Investment Committee.
- The investment committee will monitor the portfolio regularly and shall act within a reasonable period of time to evaluate deviation from approved ranges.
Approved by the Board of Directors: September 30, 2004
Amended by the Board of Directors: March 14, 2007
Amended by the Board of Directors: November 13, 2008