Financial Policy

Financial Policies

Table of Contents

Finance Committee
Approval of plans and commitments before they are implemented

III. Budget Variance

Accurate, timely financial reports and information returns
Financial Condition
Banking institutions and accounts

VII. Deposits

VIII. Grants, gifts, and pledges

Donated goods and services
Fixed assets
Line of credit

XII. Credit card

XIII. Procurement and purchasing

XIV. Subcontractors

Disbursements

XVI. Payroll

XVII. Reconciliation of banking/security statements

XVIII. Expense Reimbursements

XIX. Fraud

Nepotism Policy

XXI. Whistle Blower

Summary

Florida Partnership to End Domestic Violence, Inc. (FPEDV) strives to have the best possible internal controls and financial systems. These financial policies are created by the Finance Committee and approved by the Board of Directors to guide the work of the Board, staff, and outsourced financial management.

Finance Committee

The Board of Directors of FPEDV will annually appoint a Finance Committee that works with the Board Treasurer to ensure the appropriate preparation of an annual budget, appropriate handling and distribution of funds, and the appropriate preparation and presentation of regular financial statements. The Finance Committee directs, reviews, and presents the annual audit to the Board of Directors.

Approval of plans and commitments before they are implemented
The Board of Directors will set the annual budget, based on FPEDV fiscal year (October through September), to direct how funds are spent. The annual budget will be prepared

utilizing a “Zero Based Budget” methodology, whereby each expense item is reviewed in detail prior to being included in the budget. The budget will include presentation of the following items, as applicable:

Revenue – Sources and amounts that FPEDV conservatively anticipates receiving and against budgeted expenditures during the current budget year

Expenditures – outlays reasonably expected to occur within the time frame of the budget year, for the following categories:

Personnel Staffing Salaries and Fringe Benefits

Occupancy Expenses

Office Supplies Expenses

IT/Computer Expenses

Training and Technical Support Expenses

Travel Expenses

Contractual Service Expenses

Miscellaneous Expenses

Capital Expenditures – outlays of a significant nature that will benefit the organization beyond the current operating cycle such as equipment purchases or equipment leases for extended periods of time.

Budgetary changes shall require board approval when changes affect the existing budgetary line items by an aggregate of $10,000 or more, or when the change impacts the requirement of obtaining 3 bids by funding source, or if a single item is more than $10,000 and is not part of the existing approved budget.

III. Budget Variance

It is the policy of FPEDV that programs and activities related to the annual services shall be governed by allocations approved during the budget process and adopted by the Board. However, it is recognized that there are circumstances that arise during a fiscal period that result in actual revenues and expenditures varying from budgeted amounts. When these circumstances arise and are of a material nature, the variance will be brought to the attention of the Finance Committee as part of the monthly review of FPEDV’s financial performance. Notations of the amount of the variance and its cause will be documented in the reporting presented to the Finance Committee for further discussion and resolution, if deemed necessary by the Finance Committee. The financial results and the findings of the Finance Committee will be presented to the Board of Directors for additional discussion and guidance as appropriate.

Accurate, timely financial reports and information returns

The Finance Committee oversees that FPEDV provides accurate, timely financial reports and information returns.

The Finance Committee will review financial statements on a monthly basis, to include the following:
Statement of Financial Position (Balance Sheet)
Statement of Activities (Income Statement)
Statement of Cash Flows
Additional information as requested or needed

The Statement of Financial Position will include a comparison to the approved budget.

Informational and compliance returns and other required filings falling within the purview of the Finance Committee will be presented to the Finance Committee as completed for review and filing sign off when appropriate. Returns requiring Board review and sign off will be forwarded to the Board when appropriate.

The Board of Directors will receive sufficiently detailed financial reporting enable the Board to accurately assess the financial performance of FPEDV. Such reporting will include variance analysis of actual performance v. approved budget and other supporting information as requested.
The FPEDV accounting department through the Director of Financial Services will maintain a calendar of Financial Statement reporting deadlines as well as a corporate compliance schedule listing all other external report filing deadlines. The Finance Committee, through the Director of Financial Services will advise the Board of Directors of the status or completion and filing of these reports/returns as they occur, and will present them in sufficient time to allow the Board adequate time for proper review, inquiry and follow up.
FPEDV accounting staff will at all times maintain fiscal records in a manner that is clearly auditable and provides the level of recordkeeping necessary to effectively and efficiently prepare funding source reimbursement requirements.
Financial Condition

FPEDV will operate in a sound and fiscally prudent manner. The Board of Directors, Chief Executive Officer and the Director of Financial Services shall protect the long‐term financial strength of the agency by:

Limiting expenditures to Board‐stated priorities; consulting with the Finance Committee, Executive Committee and the Board of Directors on exceptions.
Guarding against incurring indebtedness other than trade payables incurred in the ordinary course of doing business
Settling payroll and debts in a timely manner.
Maintaining the cash reserves in the equivalent of a documented amount (90 Days of operating expenses). This amount is to be reviewed annually by the Chief Executive Officer, the Finance Committee and will be documented in meeting minutes.

Using restricted contributions only for the purpose required by the contribution.
The Chief Executive Officer will at all times be in contact with the Board of Directors, Corporate Officers and members of relevant committees of the organization regarding its fiscal status.
Banking institutions and accounts

To minimize risk and maximize benefit, FPEDV utilizes only federally insured local banking and savings institutions. The amount on deposit with any one institution may not in the usual course of business exceed the FDIC insured limits. The Finance Committee will review the banking relationship annually.

VII. Deposits

It is the policy of FPEDV to use a system of internal controls that allows for the accounting of all cash received in such a way as to reduce the risk of fraud or misappropriation.

All income intended for FPEDV will be properly received, deposited, recorded, reconciled, and kept under adequate security. Any cash received must be promptly and fully deposited.

Invoices generated for various dues, services and other types of billing will direct the payor to remit to the FPEDV P.O. box located in Tallahassee, Florida. At such time as it is available in the future, payments of FPEDV generated invoices may be made electronically by direct deposit ACH or wire. The Director of Financial Services is responsible for copying all checks received, copying/scanning all checks, and endorsing them “FPEDV for Deposit Only” along with the FPEDP bank account number and depositing them either physically or online by photo capture. All incoming checks will be listed or copies of checks scanned and forwarded to the Treasurer to confirm receipt and further confirm deposit to the FPEDV bank account via online review of account activity on the bank’s website. The Director of Financial Services is responsible for resolving any questions noted by the Treasurer from the Treasurer’s review of bank account activity. The Director of Financial Services, or the designated financial staff associate, codes the checks and records the deposit into the checking account of the computerized books of account. To the extent needed, further posting of cash receipts to accounting subledgers will also take place.

Cash received by any party must be turned into the Director of Financial Services or designee approved by the CEO or delegate. All monies will be placed in a sealed envelope, signed by staff, and turned in immediately to the Director of Financial Services or designee for deposit.

During times of staff shortages, duties of logging incoming cash receipts, preparing deposit, and making deposit will be reassigned to ensure separation of duties among available staff.

VIII. Grants, gifts and pledges

All grants and gifts will be properly received and recorded. Compliance with terms of any related restrictions will be monitored by staff and reported to the Finance Committee. Pledges are recorded at the time they are made. Thank you letters to donors follow IRS regulations.

Donated goods and services

Donated goods and services are recorded in the accounting records when they would have been purchased if they were not donated. Gifts are recorded at fair market value. Where the gift is of a material nature (as determined by FPEDV management or committee), a knowledgeable independent appraisal source may be used to assign the fair market value of the gift.

Fixed assets

Expenditures for land, building and equipment are recorded at cost. Donated assets and capitalized donated leases are recorded at their estimated fair market values at the date of donation. Depreciation expenses are calculated using the straight‐line method and the following estimated useful lives:

Buildings and improvements – 10‐35 years

Furniture and equipment – 3‐10 years

Vehicles – 3‐5 years

Maintenance and repairs, which materially add to the value of the property or appreciably prolong its life, are recorded as an increase to the appropriate asset account.

FPEDV capitalizes all fixed assets with a cost greater than or equal to $2,500 and a useful life of at least three years, unless otherwise stipulated by a grant. When an asset is purchased through a grant, the grant’s capitalization rules apply. FPEDV will conduct a regular inventory of fixed assets and maintain a central list of fixed assets which includes date of purchase, registration numbers, warranty information, original cost, and estimated life.

Line of credit

FPEDV may maintain an appropriate line of credit to ensure regular cash flow, the use of which must be approved by the Chief Executive Officer, BOD Executive Committee with consultation from the Finance Committee. The line of credit application must have board approval.

XII. Credit/Debit card

FPEDV may maintain credit/debit card accounts to facilitate efficient operations. Credit /debit cards will only be issued in the name of specific employees with specific credit limits as appropriate and willbe adequately safeguarded at all times. All credit/debit card transactions will be only for proper purposes and will be properly recorded.

XIII. Procurement and purchasing

FPEDV will always seek to maximize value and cost‐effectiveness in all procurement and purchasing. Procurement of products or services will at all times include consideration of vendors where contractually obligated and applicable.

Where practicable and available in the market, purchases of $2,500 or greater shall require at least three competitive bids. At a minimum, for all purchases exceeding $500 The senior management of FPEDV may at any time choose to advertise or issue an IFB (Invitation For Bids) or RFP (Requests For Proposal) in order to procure required goods or services through competitive bidding.

IFB: Competitive sealed bidding process, through which bids are publicly solicited and a firm fixed-price contract is awarded to the responsible bidder whose bid is the lowest in price. This sealed bidding process must minimally adhere to standards established applicable Florida Statute and applicable federal guidelines.

RFP: Process by which proposals for services are solicited through advertisement, and are used when specifications for procurement are not sufficiently clear to permit use of the IFB procedure. An award is made to the responsible firm whose proposal is most advantageous to the program, with price and other factors considered.

When implemented, FPEDV will maintain supporting documentation and justification for each of the above procurement processes used including but not limited to documentation of solicitation of estimates from potential vendors, vendor selection, final pricing including negotiations as applicable and purchase order. Documentation related to procurements shall be submitted to the fiscal department for storage with accounting records. If procurement is for the purpose of staff development such as attendance to a conference, a copy of the registration brochure and course recap (online) shall be submitted to the CEO for approval prior to registration for the event.

When implemented, FPEDV will contract with minority businesses, women’s business enterprises, and labor surplus area firms when possible. Procurement of Goods and Services for Fundraising Procurements related to fundraising initiatives will be conducted in a manner to provide, to the maximum extent practical, open and free competition. However, formal bids, IFBs, or RFPs shall not be required so long as prior consultation with the CEO and senior management occurs prior to securing such good or service. If the CEO is procuring the goods or services for fundraising efforts, formal bids, IFBs, or RFPs shall not be required so long as prior consultation with the President and Treasurer occurs prior to procurement.

Expense Approval Authority

The Director of Financial Services shall be authorized to approve budgeted expenses related to the ongoing operation of FPEDV up to and including $1,000, and monthly invoicing as presented in payment of previously agreed upon contract or lease terms greater than $1,000. The Chief Executive Officer shall be authorized to approve budgeted expenses related to the ongoing operation of FPEDV in excess of $1,000.

All budgeted expense reimbursements requested by employees (other than the Director of Financial Services) as part of the ongoing operation of FPEDV shall be approved by the Director of Financial Services up to and including $1,000. Budgeted expense reimbursements exceeding $1,000 shall be submitted for approval by the Director of Financial Services and also the Chief Executive Officer.

All expense reimbursements requested by the Director of Financial Services, irrespective of amount, shall be submitted for approval to the Chief Executive Officer.

All expense reimbursements requested by the Chief Executive Officer, irrespective of amount, shall be submitted for approval to the President of FPEDV.

XIV. Subcontractors

It is the policy of FPEDV that with respect to hiring contractors the following items are required. 1. Proof of licensure (if applicable)

Proof of current business license
Proof of current worker’s comp insurance, liability insurance and errors and omissions insurance (if applicable).
Completed IRS Form W-9, including signature (required for payment). Subcontractors may not be on the state or federal disbarred list. The subcontract agreement must indicate the scope of work to be performed.
Disbursements

Funds will be disbursed only upon proper authorization of management and only for valid business purposes.

Vendors will be directed to send invoices to FPEDV’s [email protected] email address or the FPEDV P.O. Box located in Tallahassee, FL. Prior to initial payment of an invoice, the Director of Financial Services shall obtain a completed Form W-9 from the vendor.

All disbursements will be initiated only from properly authorized documentation and will be properly recorded. No check may be made out to Cash.
The Board shall designate the corporate President, the corporate Vice President, the corporate Treasurer, the Chief Executive Office Director, the Director of Financial Services and any other Board member or staff member deemed appropriate as authorized signers of checks on behalf of FPEDV. Any check for an amount over $3,000 must carry two signatures on the check unless otherwise specifically authorized in advance by the Board of Directors (such as for payroll, office rent or other recurring contracted services). Signatures can be electronic.

All other invoices to be paid electronically via online checking that exceed $3,000 will require approval by two officers of FPEDV prior to initiating the electronic payment.

No check signer may sign a blank check.
Ensure that all expenditures are allowable expenses, accompanied by the original invoice/receipt, have the appropriate management approval, and the check and invoice amounts agree with one another and are defaced upon payment.
When check disbursements made where the payee is an authorized signer on the account, the check will be signed by authorized signers other than the payee.

The Director of Financial Services pays bills minimally twice a month (excluding emergencies), near the 10th and the 25th of the month. All receipts will be coded with sufficient notation indicating as applicable the funding source, account number, amount, check number, date paid, and identifying the invoice’s approver. Once the checks are prepared, they will be forwarded to an authorized signer/signers for signature and mailing.

The online banking tools available to facilitate a more efficient payment workflow will be implemented upon assignment of appropriate restrictive disbursement protocols to the Director of Financial Services, Treasurer, President and Chief Executive Officer. The initial focus of this effort will be payment of standard, recurring contractual charges on a regular monthly cadence. All direct pay ACH transactions will be to accounts identified and confirmed by FPEDV account signers prior to initiating any payment transactions. Changes to vendor payment accounts will be reviewed and approved by FPEDV, and confirmed with the vendor prior to implementing the change.

All authorized checking account signers will be granted at a minimum online view access to information on disbursements, deposits, account balances, and monthly/quarterly bank statements. As needed, any account signer may request from staff additional information about transactions or back up documentation related to those expenses. This measure is to provide oversight to the determination of the necessity and reasonableness of the expense. The Treasurer will also be provided copies of tax or compliance returns upon filing as an oversight measure to ensure proper tax and compliance reporting is conducted.

XVI. Payroll

Payroll disbursements will be made only to bona fide employees and only upon proper authorization.

Changes to each payroll will be properly documented, and made in accordance with the salary and benefit agreements approved by the Chief Executive Officer and in place at the time the payroll is paid.

The Director of Financial Services will report monthly to the Finance Committee both actual payroll costs of the pay periods since the previous Finance Committee meeting along with the projected payroll cash outlay for the upcoming pay periods for the committee’s review and approval.

FPEDV will ensure that payroll disbursements are properly recorded and that related disbursements (such as payroll tax deposits) are made timely. Payroll checks will not be released prior to payday, and employee advances are not permitted.

XVII. Reconciliation of banking/security statements

All banking/security statements will be delivered unopened to a designated individual who is not otherwise involved in the preparation of checks, the depositing of funds, or is an authorized signer of checks. In the alternative, a PDF copy of the monthly bank statement generated by the bank through its website will be forwarded via email or other secured transfer portal. This designated individual shall acknowledge receipt and review each statement on a timely basis. An appropriately qualified finance staff person or equivalent designee will reconcile each bank

account monthly prior to the issuance of financial statements, providing a copy of the reconciliation to the FPEDV Director of Financial Services and Treasurer.

XVIII. Expense Reimbursements

Expense reimbursements will be made only to individuals submitting properly completed and approved expense reimbursement requests along with supporting documentation adequate to explain the business purpose of the expense or event. Authorization for incurring the expense to be reimbursed should be obtained from the individual’s immediate supervisor, corporate officer or board member prior to incurring the expense.

Out-of-pocket expenses incurred by the employee directly should be kept to a minimum if possible. All employees should attempt to use corporate business accounts where available, as well as use company credit cards (through authorized company credit card holders) whenever possible.

XIX. Fraud

This policy applies to any fraud or suspected fraud involving employees, corporate officers, Board of Directors, as well as members, vendors, consultants, contractors, funding sources and/or any other parties with a business relationship with FPEDV. Any investigative activity

required will be conducted without regard to the suspected wrongdoer’s length of service, position/title, or relationship with the organization.

Management is responsible for the detection and prevention of fraud, misappropriations, and other irregularities. Fraud is defined as the intentional, false representation or concealment of a material fact for the purpose of inducing another to act upon it to his or her injury. Each member of management should be familiar with the types of improprieties that might occur within their area of responsibility, and be alert for any indication of irregularity.

Any fraud that is detected or suspected must be reported immediately to the CEO, or the Chair of the Executive Committee.

Actions Constituting Fraud

1) Any dishonest or fraudulent act.

2) Forgery or alteration of any document or account belonging to FPEDV 3) Forgery or alteration of a check, bank draft, or any other financial document 4) Misappropriation of funds, securities, supplies, equipment, or other assets 5) Impropriety in the handling or reporting of money or financial transactions 6) Disclosing confidential and proprietary information to outside parties 7) Accepting or seeking anything of material value from contractors, vendors, or persons providing goods or services to FPEDV.

8) Destruction, removal or inappropriate use of records, furniture, fixtures, and equipment

9) Any similar or related irregularity

Irregularities concerning an employee’s moral, ethical, or behavioral conduct should be resolved by the staff person’s supervisor and/or CEO. Questions as to whether an action constitutes the suspected fraud will be decided by the CEO, or by the Chair of the Executive Committee if the actions are those of the CEO.

The CEO has the primary responsibility for the investigation of all suspected fraudulent acts as defined in the policy unless suspected fraudulent behavior is committed by the CEO, and then the Chair of the Executive Committee should investigate. The Chair of the Executive Committee may utilize whatever internal and/or external resources considered necessary in conducting an investigation. If an investigation substantiates that fraudulent activities have occurred, the CEO and/or the Chair of the Executive Committee may issue reports to appropriate designated personnel and, if appropriate, to the Board of Directors. The course of action to be taken (prosecute; refer the examination results to the appropriate law enforcement and/or regulatory agencies for independent investigation) is within the authority of the CEO/Chair of the Executive Committee.

The CEO and the Chair of the Executive Committee will treat all information received confidentially. Any employee who suspects dishonest or fraudulent activity will notify the CEO, the Chair of the Executive Committee or their respective supervisor immediately, and should not attempt to personally conduct investigations or interviews/interrogations related to any suspected fraudulent act. Specific reporting procedures are outlined below.

Investigation results will not be disclosed or discussed with anyone other than those who have a legitimate need to know as determined by the CEO or Chair of the Executive Committee. This is important in order to avoid damaging the reputations of persons suspected but subsequently found innocent of wrongful conduct and to protect the organization from potential civil liability.

Members of the FPEDV Board of Directors Executive Committee will have: 1) Free and unrestricted access to all records and premises, whether owned or rented. 2) The authority to examine, copy, and/or remove all or any portion of the contents of

files, desks, cabinets, and other storage facilities on the premises without prior knowledge or consent of any individual who may use or have custody or any such items or facilities when it is within the scope of the investigation.

Reporting Procedures

Extreme care is essential during the investigation of suspected improprieties or irregularities so as to avoid mistaken accusations or alerting suspected individuals that an investigation is under way.

An employee who discovers or suspects fraudulent activity will contact the CEO or the Chair of the Executive Committee immediately. The employee or other complainant may remain anonymous.

All inquiries concerning the activity under investigation from the suspected individual(s), their attorney or representative(s), or any other inquirer should be directed to the CEO, Chair of the Executive Committee or legal counsel.

No information concerning the status of an investigation will be given out. The proper response to any inquiry is “I am not at liberty to discuss this matter.” Under no circumstances should any reference be made to “the allegation”, “the crime”, “the fraud”, “the forgery”, “the misappropriation”, or any other specific reference.

The reporting individual should be informed of the following:

1) Do not contact the suspected individual in an effort to determine facts or demand restitution.

2) Do not discuss the case, facts, suspicions, or allegations with anyone unless specifically asked to do so by the CEO, Chair of the Executive Committee, or the organization’s legal counsel.

Nepotism Policy

FPEDV maintains a Nepotism Policy in which employment of a relative (spouse, partner, parent, child, sibling, in-law, or in a co-habitant relationship) is permitted, except in circumstances where an appointment would place related people in supervisory and subordinate roles within the same office or department, or in a situation where influence could be exerted, directly or indirectly, on future decisions concerning the status of employment, promotion, or compensation.

In order to reduce potential conflict of interest, applicants will not be considered for employment in a position in which they would be subject to supervision by a relative.

XXI. Whistle Blower Protection

The whistleblower protection is being implemented for FPEDV to comply with the Public Company Accounting Reform and Investor Protection Act of 2002 (Sarbanes‐Oxley). This provision in the legislation applies to all organizations, not just those that operate for profit.

An employee, board member or volunteer of FPEDV who reports waste, fraud, or abuse will not be terminated or otherwise retaliated against for making the report.

The report will be investigated and even if determined not to be waste, fraud, or abuse, the individual making the report will not be retaliated against. There will be no punishment for reporting problems – including termination of employment, demotion, suspension, harassment, failure to consider the employee for promotion, or any other kind of discrimination

FPEDV will follow the Grievance Policy to make a report of suspected waste, fraud, or abuse.

FPEDV is registered agency of Chapter 496, Florida Statutes, the Solicitation of Contributions Act, # CH65575. A COPY OF THE OFFICIAL REGISTRATION AND FINANCIAL INFORMATION MAY BE OBTAINED FROM THE DIVISION OF CONSUMER SERVICES BY CALLING TOLL-FREE (800-435-7352) WITHIN THE STATE. REGISTRATION DOES NOT IMPLY ENDORSEMENT, APPROVAL, OR RECOMMENDATION BY THE STATE.