Policies and Procedures Section 1 Administrative (ADM)
as of January 29, 2025
ADMINISTRATIVE (ADM) SECTION 500 – COMPLIANCE
ADMINISTRATIVE (ADM) Section 100 – Board of Directors
REFERENCECODE: ADM - 100 - GJR
TITLE: Code of Conduct – Board of Directors Policy
APPROVEDBY: GJR Board of Directors
DATEAPPROVED: 9/25/2019
DATEREVISED: 9/25/2019
ADM-100-GJR - Code of Conduct: Board of Directors Policy
It is the policy of the agency boards to clearly define board member code of conduct.
REFERENCECODE: ADM - 100 - 001 - GJR
TITLE: Code of Conduct: Board of Directors Procedure
APPROVEDBY: GJR Administrators
DATEAPPROVED: 11/2/2021
DATEREVISED: 12/7/2023
ADM-100-001-GJR - Code of Conduct: Board of Directors Procedure
It is the intent of George Junior Republic and Affiliates (GJR) to provide the highest quality services available to persons served. Our commitment as an organization is to create an environment that is safe, nurturing, empowering, and promotes growth and success for persons who participate in our services. To clarify our vision on how this will be accomplished, the Ethical Code of Conduct outlines specific expectations of GJR board members as we strive to achieve our mission together.
1. GJR board members will comply with all laws and conduct its business in keeping with the highest dignity, moral, legal, ethical, and corporate standards.
2. Each GJR board member stands in a fiduciary relationship to GJR and is required to perform their duties as a director, including their duties as a member of any committee of the board upon which the director may serve, in good faith; in a manner the director reasonably believes to be in the best interest of GJR; and with such care, including reasonable inquiry, skill, and diligence, as a person of ordinary prudence would use under similar circumstances.
3. GJR board members, in their fiduciary capacity, will oversee and guide the long-term investments of GJR by establishing guidelines by which an investment fund is managed.
4. GJR board members shall make reasonable efforts to avoid a conflict of interest with GJR; that is, when an individual’s private interest interferes in any way or appears to interfere with GJR’s interest as a whole.
5. GJR board members will have oversight of gift acceptance and fundraising by way of the board’s Executive Committee and the Development Coordinator
6. GJR board members will not discriminate based on race, culture, age, gender, sexual orientation or identity, religion, socioeconomic status, or language.
7. GJR board members will adhere to the GJR Nepotism Policy as established by the board.
8. GJR board members will maintain strict confidentiality regarding persons served.
9. GJR board members will uphold the GJR Whistleblower Policy in reporting any wrongful conduct.
10. GJR adheres to zero tolerance of staff and/or person served regarding sexual abuse and sexual harassment. Board members are required to report any incidents of sexual abuse or sexual harassment of which they have knowledge. GJR board members will fully cooperate with authorities in investigations of any allegations of abuse.
11. GJR board members who, in good faith, suspect and report violations of the Ethical Code of Conduct or any area of organizational compliance will be protected from any form of retaliation and/or reprisal.
12. If contacted by a current employee or employees about alleged or suspected wrongdoing at GJR, board members may not attempt to resolve such matters with GJR staff at any level. Instead, the member should report the contact and the issue to the Chair of the GJR Parent board as soon as possible for appropriate action. This is not to be construed as precluding or limiting contacts between board members and employees. It is merely to make clear the board member's responsibility when the contacts do occur.
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REFERENCECODE: ADM - 101 - GJR
TITLE: Agency Resources Policy
APPROVEDBY: GJR Board of Directors
DATEAPPROVED: 9/25/2019
DATEREVISED: 9/25/2019
ADM-101-GJR - Agency Resources Policy
It is the policy of the George Junior Republic and Affiliates (GJR) boards to clearly define the personal use of agency resources.
January 29, 2025
REFERENCECODE: ADM - 101 - 001 - GJR
TITLE: Agency Resources Procedure
APPROVEDBY: GJR Administrators
DATEAPPROVED: 8/3/2020
DATEREVISED: 8/3/2020
ADM-101-001-GJR - Agency Resources Procedure
George Junior Republic prohibits personal use of agency resources. George Junior Republic assets may only be used for the benefit of the organization and not for the personal benefit of staff. For example: Employees may not use George Junior Republic vehicles for personal purposes.
George Junior Republic maintenance staff may not perform services on company time for an employee or an employee’s family member.
REFERENCECODE: ADM - 102 - GJR
TITLE: Chief Executive Officer Evaluation Policy
APPROVEDBY: GJR Board of Directors
DATEAPPROVED: 9/25/2019
DATEREVISED: 9/25/2019
ADM-102-GJR - Chief Executive Officer Evaluation Policy
It is the policy of the George Junior Republic and Affiliates (GJR) boards to clearly define and implement the Chief Executive Officer evaluation process.
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REFERENCECODE: ADM - 102 - 001 - GJR
TITLE: Chief Executive Officer Evaluation Procedure
APPROVEDBY: GJR Administrators
DATEAPPROVED: 8/3/2020
DATEREVISED: 8/3/2020
ADM-102-001-GJR - Chief Executive Officer Evaluation Procedure
The Chief Executive Officer will have a performance evaluation completed each year. The process will help determine compensation and provide feedback to the Chief Executive Officer. This will be accomplished in two formats.
A. A performance evaluation of the Chief Executive Officer will be completed by each board member and returned to the Chairman of the Compensation and Benefits Committee. The Chairman, along with the Board of Directors, will review the evaluations and share with the Chief Executive Officer.
B. A 360° evaluation of the Chief Executive Officer will be completed by each administrative staff that reports directly to the Chief Executive Officer. Evaluations will be returned to the Chairman of the Compensation and Benefits Committee, reviewed with the Board of Directors, and shared with the Chief Executive Officer.
REFERENCECODE: ADM - 103 - GJR
TITLE: Chief Executive Officer Expense Policy
APPROVEDBY: GJR Board of Directors
DATEAPPROVED: 9/25/2019
DATEREVISED: 9/25/2019
ADM-103-GJR - Chief Executive Officer Expense Policy
It is the policy of the George Junior Republic and Affiliates (GJR) boards to clearly define the expense reconciliation process for the Chief Executive Officer.
REFERENCECODE: ADM - 103 - 001 - GJR
TITLE: Chief Executive Officer Expense Procedure
APPROVEDBY: GJR Administrators
DATEAPPROVED: 8/3/2020
DATEREVISED: 8/3/2020
ADM-103-001-GJR - Chief Executive Officer Expense Procedure
Any and all expenses incurred by the CEO and submitted for reimbursement shall be a result of conducting business on behalf of George Junior Republic and its related entities. Reimbursement of these expenses shall have proper supporting documentation which includes original receipts as well as a description of the business purpose for which the expense was incurred. A reconciliation of the expenses shall be submitted to the Finance Department for processing.
Cash advances may be requested by the CEO prior to the occurrence of a business event. In a timely fashion, after the event, a reconciliation of the advance (including appropriate receipts) shall be submitted to the Finance Department for processing.
Finance shall maintain copies of the expense reports and approvals. All expense reimbursements and cash advances to the CEO in excess of $1,000 for any single event must be approved in writing by the chairman or other officer of the Board prior to disbursement. For example, a trip to a conference involving $800 in hotel costs and $600 in airfare would be subject to prior approval because it exceeded $1,000. Annually, an analysis of all CEO expense reimbursements and advances for the prior year will be presented to the Board for review and approval.
REFERENCECODE: ADM - 104 - GJR
TITLE: Conflict of Interest Policy
APPROVEDBY: GJR Board of Directors
DATEAPPROVED: 9/25/2019
DATEREVISED: 9/25/2019
ADM-104-GJR - Conflict of Interest Policy
It is the policy of the George Junior Republic and Affiliates (GJR) boards to comply with all laws and to conduct its business in keeping with the highest moral, legal, ethical and corporate standards. GJR desires to be responsible members of the various communities with which they interact and to assure the welfare of those dependent upon GJR in any manner.
REFERENCECODE: ADM - 104 - 001 - GJR
TITLE: Conflict of Interest Procedure
APPROVEDBY: GJR Administrators
DATEAPPROVED: 8/3/2020
DATEREVISED: 8/3/2020
ADM-104-001-GJR - Conflict of Interest Procedure
A. George Junior Republic and its affiliated corporations (“GJR”) desire to be responsible members of the various communities with which they interact and to assure the welfare of those dependent upon GJR in any manner. It is the policy of GJR to comply with all laws and to conduct its business in keeping with the highest moral, legal, ethical and corporate standards. This Policy applies to GJR’s directors and officers (including, without limitation, Chief Executive Officers).
B. No code of conduct can replace the thoughtful behavior of an ethical director and officer, and accordingly, GJR relies upon each individual within the organization to act with integrity, to use good judgment and to act appropriately in any given situation. Nevertheless, this Conflict of Interests Policy (“Policy”) has been created because GJR believes that it can help focus directors and officers on potential areas of conflicts of interest, provide guidance to help officers and directors recognize potential conflicts, and help to foster a culture of honesty and accountability.
C. GJR and its related corporate entities require all directors and officers to carefully review this Policy and to make every effort to remain in full compliance with both the letter and the spirit of the Policy. Questions regarding the Policy may be directed to the Chairman of the GJR Board of Directors or the Chief Executive Officer.
D. Fiduciary Duty of Directors: Each director stands in a fiduciary relation to GJR and is required to perform his or her duties as a director, including his or her duties as a member of any committee of the Board upon which the director may serve, in good faith, in a manner the director reasonably believes to be in the best interests of GJR, and with such care, including reasonable inquiry, skill and diligence, as a person of ordinary prudence would use under similar circumstances. In performing their duties, each director may rely in good faith on information, opinions, and reports or statements, including financial statements and other financial data. In each case, the information can be prepared or presented by any of the following:
1. One or more GJR officers or employees whom the director reasonably believes to be reliable and competent in the matters presented;
2. Counsel, public accountants, or other persons as to matters which the director reasonably believes to be within the professional or expert competence of such persons; and
3. A committee of a GJR Board upon which the director does not serve, as to matters within its designated authority, which committee the director reasonably believes to merit confidence.
4. A director shall not be considered to be acting in good faith if the director has knowledge concerning the matter in question that would cause their reliance to be unwarranted.
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E. Conflict of Interests: Each GJR officer and director has a duty to act in a manner intended to further GJR’s best interests. Accordingly, each director and officer shall make reasonable efforts to avoid a conflict of interest with GJR. Typically, a conflict of interest occurs when an individual’s private interest interferes in any way–or even appears to interfere–with GJR’s interests as a whole. When an actual or potential conflict of interests exists, the officer or director shall conduct himself or herself in a manner consistent with this Policy.
F. An actual or potential conflict of interest exists when any of the following exists or is threatened:
1. An officer or director has an ownership or investment interest in or compensation relationship with an organization or person with which GJR does or proposes to do business or an organization or person that competes with GJR; or
2. An officer or director receives remuneration for performing services for GJR and GJR is determining his or her remuneration; or
3. An officer or director serves as an officer or director or key employee of an organization that competes with or does business with GJR.
G. A conflict also exists when a similar circumstance exists with respect to a family member of a director or officer or a company 35% owned by a director or officer and his or her family members. Annually, each director and officer shall complete a disclosure statement reflecting his or her interests. Family members include spouses, children, parents, siblings, grandparents, grandchildren and their respective spouses.
H. If at any time a director or officer (i) has or may have a conflict of interest, or (ii) is unable to act in the best interests of GJR on any issue because of a personal situation, employment, conflicting interest, or other reason, the director or officer shall recuse himself or herself from voting on the subject and shall leave the room while the matter is discussed. Recusing himself or herself shall not prevent a director or officer from participating in other activities or discussions where no conflict of interest exists.
I. The Board may approve a transaction that is the subject of a conflict only if it has determined (i) that the transaction or arrangement is in GJR’s best interest and for its own benefit, (ii) that it is fair and reasonable to GJR and (iii) after exercising due diligence, GJR would not obtain a more advantageous transaction with reasonable efforts under the circumstances. Where appropriate the Board shall obtain comparable information to assist it in reaching such conclusions. For example, when setting compensation for officers or selling to or purchasing from a director, prior to reaching its decision on the matter, the Board will obtain comparable information from which it may assess the reasonableness of the compensation or consideration. Such comparable information must be considered by the Board prior to reaching a decision on the matter.
J. The minutes of all meetings shall reflect (i) the names of the persons who disclosed any conflicts; (ii) the determination as to whether an actual or potential conflict of interest existed; (iii) the names of the persons who were present for discussions and votes relating to the transaction or arrangement; (iv) the content of the discussions, including any alternatives to the proposed transaction or arrangement and the basis for the determination of the Board, including any comparability data; (v) the voting record, including any abstention from voting; and (vi) any action to be taken.
K. Without limiting the foregoing, the following are examples of potential conflicts:
1. A director owns 35% of a company that does or seeks to do business with GJR.
2. The family member of the CEO does or seeks to do business with GJR.
L. Prohibited Activities Certain activities are prohibited even if the conflict of interest process described in Section III above is satisfied.
1. GJR may not loan money to a director or officer or a family member of a director or officer.
2. No GJR officer or director or family member may accept any gift in excess of $200 in value (a “Prohibited Gift”) or lavish entertainment from companies or persons that do or seek to do business with GJR. Each GJR officer and director shall promptly report to the Chief Financial Officer, all gifts (including without limitation, Prohibited Gifts) and entertainment; provided that business lunches with a value of less than $50 need not be reported.
3. Directors and officers and family members shall use GJR’s personnel and assets only for GJR’s benefit and not for their own personal benefit or that of a family member. GJR assets shall only be used for legitimate business purposes and in an otherwise responsible and reasonably efficient manner.
4. Each director and officer shall maintain as confidential GJR information that is confidential and shall not disclose such information to others or use it for his or her personal benefit.
5. No director or officer may engage in political campaign activity on GJR premises or use GJR assets (including computers and phones) to engage in political campaign activity. Any director or officer who chooses to participate in political campaign activity shall not do so when representing GJR and shall not engage in political campaign activity at a time or place or in a manner that suggests he or she is representing GJR.
6. No director or officer or family member shall take for himself/herself personally, whether for economic gain or otherwise, opportunities that such person discovers or cultivates through the use of GJR’s personnel or assets.
7. GJR staff members and their immediate family are not permitted to serve on the Board of Directors of the relevant GJR company.
M. Each officer and director covered by this Policy shall complete an annual Conflict of Interest
Acknowledgement and Disclosure acknowledging receipt, review and understanding of the Policy and describing any actual or potential conflict of interest. It is his or her duty to make a full, frank and fair disclosure of the circumstances giving rise to an actual or potential conflict of interest. Each officer and director is also obligated to file immediately a supplemental disclosure if, during that year, there is any change in circumstances that alters or makes incomplete the information provided in the annual disclosure or that otherwise would present an actual or potential conflict of interest.
N. Disclosure statements shall be reviewed on a regular basis by the Board Chairperson. Additionally, each officer and director who believes that an actual or potential conflict of interest exists with
respect to another, shall immediately advise the Board or its designee of any such concern. Thereafter, disinterested members of the Board shall take action consistent with this Policy to investigate and identify the existence of an actual or possible conflict.
O. In the event that a majority of the disinterested Board concludes that a conflict exists, the disinterested Board may further investigate alternatives and solutions and, by majority vote, take appropriate remedial actions to address the conflict and otherwise enforce this Policy. Any interested person may not participate in or be present for the discussions and deliberations pertaining to the conflict. The Board, at its discretion, may also appoint a disinterested person or committee to investigate alternatives and solutions to the transaction or arrangement determined to be a conflict, which person or committee shall report to the Board.
P. Any director or officer who violates this policy and procedure may be subject to removal.
Q. Review and Revision: The Board reserves the right to amend, revise or revoke this Policy in its sole discretion, and the Policy imposes no legally enforceable obligation against GJR. Any amendments and revisions shall be promptly communicated to GJR’s officers and directors.
REFERENCECODE: ADM - 105 - GJR
TITLE: Financial Transaction Policy
APPROVEDBY: GJR Board of Directors
DATEAPPROVED: 9/25/2019
DATEREVISED: 9/25/2019
ADM-105-GJR - Financial Transaction Policy
It is the policy of the agency to define for all George Junior Republic and related entity employees the financial transaction process.
REFERENCECODE: ADM - 105 - 001 - GJR
TITLE: Financial Transaction Procedure
APPROVEDBY: GJR Administrators
DATEAPPROVED: 8/3/2020
DATEREVISED: 8/3/2020
ADM-105-001-GJR - Financial Transaction Procedure
The Chief Financial Officer is instructed to request any documentation necessary to validate and support any and all financial transactions of George Junior Republic and related entities. These transactions would include, but not be limited to, those made between George Junior Republic and its vendors, as well as payroll related matters. This practice should be exercised by all Finance staff as well.
In the event that a request is made to the Chief Financial Officer or the Finance staff to process a transaction without supporting documentation and after the Chief Financial Officer has requested such documentation, the Chief Financial Officer is required to notify the Chief Executive Officer or the Chairman of the Board of the event in writing.
REFERENCECODE: ADM - 106 - GJR
TITLE: Investment Policy
APPROVEDBY: GJR Board of Directors
DATEAPPROVED: 9/25/2019
DATEREVISED: 9/25/2019
ADM-106-GJR - Investment Policy
It is the policy of the George Junior Republic and Affiliates (GJR) boards to clearly define the oversight and guidance of the Board of Directors and Investment Committee in their fiduciary capacity to oversee the longterm investments (“Investment Fund”) of George Junior Republic. These guidelines are established for the Investment Fund in order to maintain financial support to fulfill its mission.
REFERENCECODE: ADM - 106 - 001 - GJR
TITLE: Investment Procedure
APPROVEDBY: GJR Administrator
DATEAPPROVED: 8/3/2020
DATEREVISED: 8/3/2020
ADM-106-001-GJR - Investment Procedure
Responsibility of the Board of Directors and Investment Committee
It is the responsibility of the Board to approve and amend as appropriate the Investment Policy, establishing strategic policy guidelines by which the Investment Fund is to be managed. The Board of Directors delegates to the Investment Committee of the Board the following responsibilities: The Investment Committee will implement the Investment Policy and adhere to its stated goals, the Investment Committee will review the performance of the managed investments according to objectives and will meet with the Investment Manager(s) on a periodic basis of no less than once a year, the Investment Committee will select, hire and/or terminate Investment Manager(s) and consultants. It is the responsibility of the Investment Committee to establish asset allocation targets and appropriate guidelines and restrictions for the Investment Manager(s), and to review the Statement of Investment Policy no less than annually.
Responsibility of Investment Manager(s)
Each Investment Manager has the authority to purchase and sell securities at their discretion, as long as investment decisions are made in conformity with the guidelines set forth in this Investment Policy. The Investment Manager(s) will review the Investment Policy no less than annually and make recommendations for changes, if any, to the Investment Committee.
REFERENCECODE: ADM - 107 - GJR
TITLE: Personal Purchases Policy
APPROVEDBY: GJR Board of Directors
DATEAPPROVED: 9/25/2019
DATEREVISED: 9/25/2019
ADM-107-GJR - Personal Purchases Policy
It is the policy of the George Junior Republic and Affiliates (GJR) boards to clearly define personal purchases through the organization or any of its affiliates.
REFERENCECODE: ADM - 107- 001 - GJR
TITLE: Personal Purchases Procedure
APPROVEDBY: GJR Administrators
DATEAPPROVED: 8/3/2020
DATEREVISED: 8/3/2020
ADM-107-001-GJR - Personal Purchases Procedure
George Junior Republic prohibits personal purchases of any kind in which any of the corporations would purchase goods or materials on behalf of any employee, director, or officer, which do not have a clear business purpose for the benefit of George Junior Republic. For example: Employees, directors, or officers may not purchase through George Junior Republic any materials or goods for their own home or residence, i.e., paint, roofing shingles, computer supplies, etc.
REFERENCECODE: ADM - 108 - GJR
TITLE: Strategic Plan Policy
APPROVEDBY: GJR Board of Directors
DATEAPPROVED: 9/25/2019
DATEREVISED: 9/25/2019
ADM-108-GJR - Strategic Plan Policy
It is the policy of the organization to have a strategic plan in place. The plan allows for direction of the organization that has been approved by the Board of Directors. The strategic plan will guide the organization to viable means of operation from now and into the future. The strategic plan will be in place for a time period of approximately three years and/or as deemed appropriate by the Board of Directors.
REFERENCECODE: ADM - 108 - 001 - GJR
TITLE: Strategic Plan Procedure
APPROVEDBY: GJR Administrators
DATEAPPROVED: 8/3/2020
DATEREVISED: 8/3/2020
ADM-108-001-GJR - Strategic Plan Procedure
A. In the formulation of the strategic plan, the Board of Directors will play a vital role in the direction and guidance of the organization. A strategic planning committee will be formed by the GJR Board of Directors and key leaders within the organization.
B. The agency reserves the right to review outside strategic planning vendors to assist in facilitating the strategic planning process.
C. The final strategic plan will be voted on for approval by the Board of Directors.
REFERENCECODE: ADM - 109 - GJR
TITLE: Succession Planning Policy
APPROVEDBY: GJR Board of Directors
DATEAPPROVED: 9/25/2019
DATEREVISED: 9/25/2019
ADM-109-GJR - Succession Planning Policy
The Board of Directors is responsible for the appointment of the Chief Executive Officer (CEO), who is responsible for the ongoing management of the agency. The duties and responsibilities of the CEO are contained in his/her job description. In the absence of the CEO, the Vice Presidents and the Chief Financial Officer shall have the authority to act on behalf of the CEO. If a change in the office of CEO becomes necessary, the Board of Directors will assure appropriate interim leadership is appointed and written notification shall be provided to the Commonwealth survey agencies that monitor the agency within the prescribed regulatory time limits.
REFERENCECODE: ADM - 109 - 001 - GJR
TITLE: Succession Planning Procedure
APPROVEDBY: GJR Administrators
DATEAPPROVED: 8/3/2020
DATEREVISED: 11/21/2024
ADM-109-001-GJR - Succession Planning Procedure
A. Upon the vacancy of the CEO, the Board of Directors will assign authority as appropriate to the delegated administrative staff and the Chief Financial Officer of the organization to act in a manner in the CEO’s absence.
B. In the event that the CEO is absent from his/her duties, the Board reserves the right to appoint a CEO or an acting CEO if it so chooses.
C. The Board of Directors may conduct a CEO search and utilize an outside talent management agency for the purposes of recruitment to fulfill these duties. This process will be delivered through the process of a selection committee designated by the Board of Directors.
D. In the event that a CEO has announced his/her retirement or submitted his/her resignation to the Board of Directors, the previous actions will be at the discretion of the Board of Directors.
REFERENCECODE: ADM - 110 - GJR
TITLE: Executive Compensation Policy
APPROVEDBY: GJR Board of Directors
DATEAPPROVED: 9/25/2019
DATEREVISED: 9/25/2019
ADM-110-GJR - Executive Compensation Policy
It is the policy of the agency that the Board of Directors, or designated committee, has general oversight of the organization’s benefits and compensation packages and meets annually in February or March. Specific duties include yearly evaluation of the Chief Executive Officer of the organization, as well as evaluation of executive and administrative employee positions.
REFERENCECODE: ADM - 110 - 001 - GJR
TITLE: Executive Compensation Procedure
APPROVEDBY: GJR Administrators
DATEAPPROVED: 8/3/2020
DATEREVISED: 8/3/2020
ADM-110-001-GJR - Executive Compensation Procedure
A. A salary survey is used to benchmark compensation for key executive positions utilizing industryspecific reports and other studies. The committee meets independent of the executives to discuss performance relative to the position job description. During these deliberations, the committee also considers input obtained from other board members, staff, professional advisors and other informed community leaders.
B. In addition to annual salary, other benefits are reviewed and monitored including, but not limited to, deferred compensation, club memberships, use of a company vehicle and any other form of compensation subject to inclusion in the annual compensation as reported on the Chief Executive Officer’s annual W-2.
(ADM)
ADM-200-GJR - Budget Policy
REFERENCECODE: ADM - 200 - GJR
TITLE: Budget
APPROVEDBY: GJR Board of Directors
DATEAPPROVED: 9/25/2019
DATEREVISED: 9/25/2019
The organization shall have a budget setting process in place and in-line with the organization’s needs.
REFERENCECODE: ADM - 200-001 - GJR
TITLE: Budget Procedures
APPROVEDBY: GJR Administrators
DATEAPPROVED: 8/3/2020
DATEREVISED: 8/3/2020
ADM-200-001-GJR - Budget Procedure
A written budget is prepared prior to the start of the fiscal year, which begins on July 1. Reasonable projections of revenue, expense, and capital expenditures are used to formulate the proposed budget. Input from various stakeholders is obtained in gathering information. Comparisons to historical performance is also analyzed by providing prior fiscal year performance and available year-to-date information. Considerations are made to external environmental changes.
In early June, the proposed budget is presented first to the Audit/Finance Committee for its review with management. The committee will then recommend the budget be presented to the Board for approval. The proposed budget is then presented to the Board mid-June for approval.
The budget is disseminated, as appropriate, to personnel and stakeholders.
REFERENCECODE: ADM - 201 - GJR
TITLE: Cash Forecasts Policy
APPROVEDBY: GJR Board of Directors
DATEAPPROVED: 9/25/2019
DATEREVISED: 9/25/2019
ADM-201-GJR - Cash Forecasts Policy
Guidelines are established to review and monitor on a consistent basis the cash needs of the organization in order to manage borrowings as well as idle cash.
REFERENCECODE: ADM - 201-001 - GJR
TITLE: Cash Forecasts Procedure
APPROVEDBY: GJR Administrators
DATEAPPROVED: 8/3/2020
DATEREVISED: 8/3/2020
ADM-201-001-GJR - Cash Forecasts Procedure
The Chief Financial Officer reviews the cash balance for the organization on a weekly basis. A review/discussion take place with the accounts payable and accounts receivable accountants to determine weekly cash flows. If there presents a need for cash to satisfy all vendor invoices, the Chief Financial Officer will use the available line of credit to facilitate cash flow. If the organization has built more than 120 days of cash on hand and has consistently maintained that balance over a reasonable period of time, management will notify the Audit/Finance Committee with a recommendation to move the excess cash to an investment account.
REFERENCECODE: ADM - 202 - GJR
TITLE: Internal Controls and Financial Oversight Policy
APPROVEDBY: GJR Board of Directors
DATEAPPROVED: 9/25/2019
DATEREVISED: 9/25/2019
ADM-202-GJR - Internal Controls and Financial Oversight Policy
The organization implements and maintains sound financial management practices. The organization employs sufficient and REVISED internal controls to facilitate fiscal responsibility according to United States Generally Accepted Accounting Principles (GAAP).
REFERENCECODE: ADM - 202 - 001 - GJR
TITLE: Internal Controls and Financial Oversight Procedure
APPROVEDBY: GJR Board of Directors
DATEAPPROVED: 1/7/2021
DATEREVISED: 12/7/2023
ADM-202-001-GJR - Internal Controls and Financial Oversight Procedure
Finance Department meetings take place on an as needed basis. Items discussed at the meetings include any relevant training topics related to non-profit accounting, project deadlines, operational changes impacting allocation of expenses, etc.
A. Accounts Payable (A/P)
The accounts payable process functions under the authority of the A/P staff. Invoice batches are prepared as deemed necessary. This includes review for proper invoice date, due date, general ledger account, vendor, invoice amount and proper authorization. In addition, documented verification of the receipt of the item purchased is included (shipping/packing receipt).
Items over $1,000 that have a useful life in excess of one year are recorded as an asset and then depreciation is recorded over the useful life of the asset.
A/P check runs are completed on a weekly basis or as deemed necessary. Factors taken into account regarding the prioritization of printing include the urgent nature of the check and the need to meet the terms of the invoices. These requirements are then tied to effective cash management.
The A/P staff will run the ‘unpaid but entered’ report, which is then reviewed along with the cash balance report. As it is determined that sufficient cash exists, the checks will be cut. The Chief Financial Officer reviews and approves the ‘Checks – Batch Control Report’ via signature. Once the check run is complete, the report is filed. The invoices are then filed in alphabetical order by vendor, along with a check stub. Checks are mailed with a copy of the remittance slip the same day.
After a check batch is run, the check date, check numbers, and check amounts are entered into ‘Positive Pay’ at the bank where the operating account resides by the A/P staff. If there are less than five checks, this information is entered manually into the system. Otherwise, a CSV file is uploaded to the bank’s ‘Positive Pay’ system. This process will track and flag any discrepancies when a check is cashed by the vendor. If there is a discrepancy, the A/P staff has the ability to pay it, deny payment, and void the check.
As part of the month-end close process, the reconciliation between the A/P aging report and the General Ledger is completed by the Finance Department
B. Accounts Receivable (A/R)
At the end of the month, the admission and discharges for the current month are reviewed. The A/R staff end dates a client’s plan in order for the release date to be documented on the invoice.
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The A/R staff then generates the county/state invoices based upon the number of billable days and the contracted per diem rate. These invoices are in paper form. The invoice provides a detailed list of persons served, the program(s) in which the person participated, and the number of days spent in each program, along with the admittance date for each program.
The A/R staff reviews each invoice to ensure the client has the correct number of days.
The A/R staff compare the total number of days for each person served, monthly, to ensure that they are billing for the same number of days when a person served is determined to have medical eligibility and the per diem is shared between the county placing agency (for room/board) and the managed care organization (MCO for mental health/treatment).
Residential Medicaid and/or Commercial Insurance Funded Programs - the A/R staff communicates with treatment team staff and does an eligibility check in the Pennsylvania Promise system to determine funding. An eligibility check is also performed by liaisons and treatment team prior to the client being placed. This additional check ensures that funding has not changed. The A/R staff attaches the correct coverage plan and bed billing procedure into the electronic health record Treatment team staff work to obtain authorizations which the A/R staff reviews for accuracy and enters into the electronic health record Residential billing occurs once per month and is generated in batches by payer and program. The invoices are in the form of electronic 837 professional files that are uploaded to the clearinghouse for distribution to the different payers.
Clinical/Therapeutic Outpatient Mental Health – the A/R staff performs eligibility checks and also obtains authorizations from the payers that require authorization. The A/R staff attaches the coverage plans and enters authorizations into the electronic health record. The Outpatient Services Director reviews services for documentation accuracy. If a documentation error renders a service to be non-billable, it is noted on the service. In the electronic health record, the A/R staff adjusts off non-billable services prior to billing. Billing occurs twice per month and is generated in batches by payer and program. The invoices are in the form of electronic 837 professional files that are uploaded to the clearinghouse for distribution to the different payers.
All payments arrive in the form of direct deposit or paper check. The A/P staff provides documentation of each deposit to the A/R staff. This documentation serves to notify the A/R staff that a deposit has occurred. From the clearinghouse or payer website, the A/R staff retrieves the electronic 835 file that corresponds to the payment and uploads it into the electronic health record. The A/R staff does a Cash Journal entry into Dynamics to record the payment received for residential and Medicaid payments made into the electronic health record. The Finance Department reconciles the payments in the electronic health record to the deposits on the bank statement and general ledger.
A “GL Extract Summary” is run in the electronic health record at the close of the period in order for the Finance Department to record the revenue for each program into Dynamics.
A random sample of 10% of all invoices of persons served from all program services (residential) and outpatient are reviewed on a quarterly basis according to the following schedule: October, January, April and July.
Cash receipts paid by check are deposited by the A/P staff using a deposit slip and copies of the checks are provided to A/R staff. Electronic payments received from MCOs are automatically posted via remittance file.
Detail for all services provided during a month are imported into Dynamics, the accounting software. Likewise, cash receipts detail is imported into Dynamics with exception to monthly county billing which is manually posted in Dynamics.
As part of the month-end close process, the reconciliation between the A/R aging report and the general ledger is completed by the Finance Department. The A/R aging report is reviewed by the A/R staff. Any accounts determined to be likely uncollectible will be referred for special collection efforts.
C. Journal Entries
Only the Finance Department is authorized to make journal entries and review prior to posting entries for month-end close.
D. Monthly Closing/Year End Closing
The financial close is performed monthly and all accounting information is released to the general ledger once a month. The information is recorded in Dynamics by the Finance Department and charged as the activity is happening. The general ledger balance is the same as the prior month end even though activity is being recorded throughout the month until posting takes place.
A monthly close worksheet is followed for each month end close. This spreadsheet serves as a checklist to ensure that all month end information is recorded, reconciled, and reviewed. The spreadsheet is broken down into a general ledger category with tasks for each category, for example, reconcile cash in cash manager, reconcile cash receipts with the Finance Department spreadsheet, record monthly expense, record depreciation expense, etc. (*Note this is not an all-inclusive list).
Overall, analytic checks are performed to ensure that the balance sheet and income statement accounts appear reasonable. Reconciliations for cash (cash manager module), A/R and A/P are completed. Also, salaries and related expenses are reconciled to pay registers and quarterly/annual wage registers.
Costs that are directly associated with a program are expensed as such. Those costs that cannot be directly associated with a program are allocated monthly based on the cost allocation plan, which is updated annually to reflect current statistical data. Examples of allocations include personnel expense, days of service per program, and facility square footage.
The monthly financial statements are generated. These statements are unaudited and are used for management purposes only.
E. Payroll
As part of the quarter-end close process, reconciliation between the 941 reports/wage-tax register and the general ledger are completed. The reconciliation includes all journal entries that affect the payroll accounts included on the 941. This is completed by the Finance Department
The HR Department is responsible for entering new employee infomation into ADP’s website along with their demographic data (DOB, address, etc.). The HR/payroll system is web-hosted by ADP. HR provides Payroll with employee information (new hire/change notice) detailing the employee’s pay rate in the ADP database and any changes to their compensation. Payroll also has access to add a termination date to an employee and/or make changes to their Paid Time Off (PTO) days, which are tracked inside ADP’s website. These are also supported by a New Hire Employee Change Form.
Some employees ‘punch’ their hours worked in a time/labor system in ADP. The employee’s supervisor approves or edits ‘punched’ time as needed. At the end of each week, Payroll moves the electronic batch file into the payroll system for processing. Payroll reviews these batches for errors, etc. and then approves these batches for processing.
Other employees use a paper time card to record their time, which is also authorized by their supervisor and then entered into the payroll system by Payroll. Payroll compares the total hours inside ADP to batch entry tape run on an adding machine, which consists of the total hours summed from the actual timecards by department. This documentation is retained as supporting documents for each bi-weekly payroll.
HR notifies Payroll when an employee has changes in the following: pay rate change, deductions; deferral percentage, or 401(k) plan participation. Payroll enters the deferral rate or pay rate change, which is based on the employee’s/participant’s status sheet.
F. Employees are paid on a bi-weekly basis.
After the payroll is processed by ADP and returned to Payroll, custom reports are generated which provides support for garnishments, child support, etc. and generates expense vouchers from within the system and forwards to the A/P staff. Labor distribution reports are utilized for the proper recording of expenses by department and program into the general ledger.
G. Pension
Human Resources notifies Payroll when an employee has a change in their deferral percentage or elects to begin/stop participation in the 401(k) plan. Payroll enters the deferral rate into ADP.
Twice a year (in January and July), Payroll extracts a report from ADP listing participants, deferral amounts and percentages. Both Payroll and the Finance Department review/proof the template to ensure proper employer match.
When an employee terminates employment, an employee change status is completed by the HR Department and documented in the personnel file. HR is responsible to update the status on the pension website and to inform the Payroll Accountant, who updates the termination status within the payroll system.
H. Capital Leases
As part of the month-end close process, reconciliation between the capital lease amortization schedule and the general ledger is completed. This is completed by the Finance Department.
I. Fixed Assets
Fixed assets are maintained in a database by the organization’s audit firm for depreciation purposes. The Finance Department works with the Facilities/Purchasing and Information Technology Departments to verify that all fixed assets are properly recorded on the depreciation schedule and disposals are recorded for assets no longer in use.
J. Travel Expenses
Agency staff that engage in company business may incur related expenses and are responsible for submitting appropriate documentation for their expenditures. Once the expenses are incurred, all supporting documentation along with an Expense Reconciliation Form is completed by the employee. The employee’s supervisor is also required to sign off on the Expense Reconciliation Form. The information included on the report includes the employee’s name, date of the expense(s), program/department, whether or not the expenditure was paid with company sources (credit/purchasing card, petty cash, cash advance) or paid by the employee, the amount due to the employee as reimbursement, and the signature of the approving supervisor.
Reimbursement to the employee will only be made with the proper documentation and authorization. Employees who incur unapproved expenditures may be personally liable for the expenditure and may face disciplinary action.
K. Purchasing Card Use
A purchasing card is issued in an employee’s name and a dollar limit is assigned to their card based on the need of purchasing business related goods/services. The card limit is approved by the Finance Department.
Cardholders are expected to comply with internal control procedures in order to protect company assets. This includes keeping receipts, reconciling Visa purchasing monthly memo statements, and following proper card security measures.
A cardholder must surrender the card upon termination of employment (voluntary/involuntary termination). At this point, no further use of the account is authorized.
L. Student Funds
A separate bank account is used to hold funds owned by persons served. This account is supported by a computerized ledger for each individual person served. Any activity/transaction in the account directed by the person served is supported by a ‘Withdrawal Form’ or a ‘Deposit Form’.
The Deposit Form is a triplicate form which includes the person served name, amount of deposit, type of deposit (cash, money order, check), the signature/date of the staff member processing the form and the Finance member receiving the funds to deposit into the bank account. The white copy is retained by the Finance Department, the yellow copy is retained by the staff member, and the pink copy is provided to the person served.
The Withdrawal Form is also a triplicate form which includes the date, name of the person served, amount requested for withdrawal, staff member name/signature, and the name/signature of the supervisor/Campus Director. When the amount requested is processed, the person served and the staff member sign for the amount received. The white copy is retained by the Finance Department, the yellow copy is returned to the Finance Department with the person served signature, and the pink copy is provided to the person served.
Persons served, through direct care staff members, can request their account balance via a phone call to the A/P staff.
The BARJ Coordinator also provides the Finance Department with a work log of persons served earning funds to pay fines/restitution and or court costs. Based upon the number of hours worked, the person served receives a deposit into their account by a check generated by A/P and then the amounts are recorded as deposits ear marked for fines/restitution in the student fund account of each person served. These funds are tracked separately in the student fund from allowance funds or any other deposits from all other sources. The BARJ Coordinator documents in the Electronic Health Record the amount of fines/restitution and/or court costs owed to the county/victim, etc. The Finance Department remits the total balance of earned funds available as identified for the purpose of fines/restitution and or court costs.
Persons served may withdraw their remaining funds upon discharge. Persons served who do not withdraw their funds at discharge will have a check mailed to them. Multiple attempts are made to return funds to persons served. If persons served do not process their check, their funds are reported to the Commonwealth of Pennsylvania Bureau of Unclaimed Property. Once reported, George Junior Republic in PA is no longer the holder of the funds. Persons served can file a claim form on the PA Treasurer Unclaimed Property website.
REFERENCECODE: ADM - 203 - GJR
TITLE: Financial Statements and Audit Reporting Policy
APPROVEDBY: GJR Board of Directors
DATEAPPROVED: 9/25/2019
DATEREVISED: 9/25/2019
ADM-203-GJR - Financial Statements and Audit Reporting Policy
It is the policy of the organization to report on its financial operation on a yearly basis. Financial information is presented in a form that is useful to its stakeholders.
REFERENCECODE: ADM - 203 - 001 - GJR
TITLE: Financial Statement and Audit Reporting Procedure
APPROVEDBY: GJR Administrators
DATEAPPROVED: 8/3/2020
DATEREVISED: 8/3/2020
ADM-203-001-GJR - Financial Statement and Audit Reporting Procedure
For internally generated statements, actual comparisons to budget information is reviewed on a monthly basis. Activity for both the month and year-to-date are reviewed by the Chief Accountant and Chief Financial Officer. Accounts with variances are reviewed and discussed, where appropriate, with department heads and administrators. Reports are disseminated to department heads for the areas in which they are responsible.
The Audit and Finance Committee is responsible for selection of the independent CPA firm charged to perform the audit. Typically, the committee hires the firm in three year segments. The audit firm will perform its site work in the months of June, July, and August. Once a draft of the statements is available, they are reviewed with management at the end of August. The first week of September, the audit firm meets with the committee, as well as management. The meeting includes discussions related to performance trends, financial solvency, etc. Any recommendations from the audit firm are discussed at that meeting. If there are recommendations, management will respond in writing as to what corrective actions are taken or reasons why corrective actions were not taken.
REFERENCECODE: ADM - 300 - GJR
TITLE: Scholarship Policy
APPROVEDBY: GJR Board of Directors
DATEAPPROVED: 9/25/2019
DATEREVISED: 9/25/2019
ADM-300-GJR - Scholarship Policy
The George Junior Republic Scholarship Fund assists George Junior Republic graduates with transitioning into a successful future. The process of applying for, securing, and maintaining a scholarship helps the persons served to take responsibility for the course of their future while finding meaningful ways to contribute to society as a whole. Through the Scholarship Program, the organization is able to help our persons served create a concrete connection between their hard work at George Junior Republic and their continued success.
REFERENCECODE: ADM - 301 - GJR
TITLE: Scholarship Non-Discrimination Policy
APPROVEDBY: GJR Board of Directors
DATEAPPROVED: 9/25/2019
DATEREVISED: 9/25/2019
ADM-301-GJR - Scholarship Non-Discrimination Policy
No person served will be denied a scholarship from the general Scholarship Fund based on the race, color, religious belief, sexual orientation, gender identity, national origin or ancestry, marital status, veteran status, or mental/physical disability unrelated to the applicant’s ability to pursue educational or vocational gains. Donors reserve the right to require that their donation be given to an applicant meeting their specific stipulations. In this event, an applicant may be exempt from receiving those specific funds, but will still be eligible to receive funds from the general Scholarship Fund.
ADMINISTRATIVE (ADM) Section 400 – Development and Marketing
REFERENCECODE: ADM - 400 - GJR
TITLE: Responsibility of Development Office Policy
APPROVEDBY: GJR Board of Directors
DATEAPPROVED: 9/25/2019
DATEREVISED: 9/25/2019
ADM-400-GJR - Responsibility of Development Office Policy
It is the policy of the agency that the Development Office is responsible for managing donations and reporting to the Finance Department on a monthly basis.
REFERENCECODE: ADM - 400 - 001 - GJR
TITLE: Responsibility of Development Office Procedure
APPROVEDBY: GJR Administrators
DATEAPPROVED: 8/3/2020
DATEREVISED: 11/21/2024
ADM-400-001-GJR - Responsibility of Development Office Procedure
A. Donor information is maintained in a database, the contents of which are highly confidential.
B. Monthly Financial Reporting
1. Five reports must be completed monthly and are due to Finance Department by the 5th every month, as follows:
a) Cash Receipts Journal by Date
b) Cash Receipts Journal by Fund
c) Pledge Report
d) Contributions and Expenditures
e) Contributions and Expenditures detailed report
2. All contributions and expenditures will be reconciled, recorded, and deposited into either Projects and Programs or Scholarship, and outlined on the spreadsheet as Contributions, Pledge Installments, Expenditures, Reimbursements, Reclass Funds, and Pledges. Totals for all Project and Program items are in the center of the spreadsheet with totals for all Scholarship items to the far right of the spreadsheet. The report detail is the supporting analysis of the first spreadsheet and totals must equal and reflect the Cash Receipt Journals. Completed financial reports are given to the Accounting Manager
C. Deposits
Deposit slips for all monies coming in must be deposited by 11:00 a.m. the day received. Deposits received after 11:00 a.m. must be locked in a drawer and deposited the next day. When deposits are made, the appropriate deposit slip must be completed. The checks received and the deposit slip must be copied two times. One will be held by the Development Office and the second copy is given to the Finance Department with the deposit slip and checks.
D. Thank You Letters
Thank You letters for each deposit are created after the deposit is entered into the established database and must be mailed to the donor within 48 hours of receipt.
REFERENCECODE: ADM - 401 - GJR
TITLE: Management of Grants Policy
APPROVEDBY: GJR Board of Directors
DATEAPPROVED: 9/25/2019
DATEREVISED: 1/29/2025
ADM-401-GJR - Management of Grants Policy
It is the policy of the agency that the Development Office is responsible for submitting and managing grants based on grantor requirements, and state and federal guidelines.
REFERENCECODE: ADM - 401 - 001 - GJR
TITLE: Management of Grants Procedure
APPROVEDBY: GJR Administrator
DATEAPPROVED: 8/3/2020
DATEREVISED: 11/21/2024
ADM-401-001-GJR - Management of Grants Procedure
A. Work Plan
1. Each grant will have a clearly defined work plan listing objectives under each goal.
2. The work plan will outline broad goals, specific objectives, staff assignments, goal dates, sources of evaluation, and outcomes for each defined objective.
B. Evaluative Measures
1. Grant success will be measured based on the outcomes of the work plan and the evaluative tools associated with each objective.
2. Evaluative tools will be used to assist in the analysis of the grant, and to gauge the success of the program and the investment in a proposed project.
C. Quantitative and Qualitative Sources of Data
Quantitative data will be managed via the use of an Access database/Excel spreadsheet, or whenever possible, via the utilization of the following tools:
1. Electronic Medical Record
2. Electronic Health Record
D. Qualitative Data will be managed via standardized surveys. If surveys are developed internally they will be reviewed by the Compliance Officer.
Whenever possible, surveys will be entered into Survey Monkey and data will be extracted from Survey Monkey based on designated timeframes throughout the course of the grant.
E. Establishment of indirect cost
The organization will utilize an established de minimis indirect cost rate.
F. Establishment of Specified Cost Center for each grant
In order to accurately manage each grant received, individualized cost centers should be established for each new funding stream. Grant funds should not be co-mingled with other funds received by the organization. The benefit of having specified costs centers is to improve tracking of grant related expenses. Expenditures related to the grant should be easily identified within the grant and proof of expenses should be kept on file.
These include:
1. Purchase orders
2. Receiving records
3. Paid invoices
4. Cancelled checks
5. Personnel payroll
6. Time and attendance records
7. Documents related to competitive bid
8. Any other evidence to support expenditures
G. Vendor invoices should include the following information:
1. Payee
2. Inventory date and number of items purchased
3. Description of each item purchased/product/service
4. Unit of price per product/service
5. Total amount of the product/service
6. Total invoice amount
H. In addition,
1. Funds should not be expended outside of the project period.
2. Each contract or purchase order should be established within the project period timeframe.
3. Each line item within the budget narrative should provide a description of the expenditure in detail.
4. Only items in the approved grant budget should be approved within the financial detail of the grant
5. Expenses to the grant should not be incurred without prior approval.
6. Budgetary changes should be approved by the grantor prior to the distribution of funds.
I Inventory
Inventory should be kept for all items purchased with grant funds. Prior to purchase, George Junior Republic will find out if there are restrictions on the equipment and if equipment needs returned at the end of the project period.
J. Federal Grants
Federal agencies may require George Junior Republic to comply with certain federal regulations as listed in the grant contract.
K. Travel Cost
If travel is required as part of the grant, each employee’s time and mileage associated with specified grant travel will be included within the budget and reimbursed based on organizational policies.
L Employee Job Duties
Grant-funded employees should have clear job descriptions outlining the scope of their work and number of FTE’s under the grant. As previously mentioned, travel costs will be outlined for each grant-funded employee.
M. Time Reporting
1. Timesheets are required for each employee working under the grant.
2. An employee working under multiple projects should have a time sheet delineating the time spent on the specified grant and they should complete a timecard on a daily basis.
3. The time sheet should be signed by the employee and the supervisor.
4. If an employee spends 100% of time on the grant, the employee should sign an attestation every six months attesting to this fact. The employee’s supervisor should also sign the certification.
5. Codes or project names should be added to the timecard and easily pulled for audit purposes.
6. Grant-funded employees should only be paid based on actual expenses.
7. Volunteers ‘employed’ under the grant should also keep track of their time.
8. Reports must be submitted based on the reporting requirements listed in the grant.
N. Monitoring of Grant
The grant work plan and Office of Management and Budget (OMB) circulars will be utilized for grant monitoring.
O. Progress Reports
Progress reports will be submitted in a timely fashion based on the requirements provided by the grantor.
P. Grant Management Integrity
Selected proposals should align with the mission of George Junior Republic. Mismanagement of grant funds must be avoided at all costs. Examples of mismanagement include purchases based on unallowable expenses, using grant funds for unrelated expenses, and commingling grant funds.
In addition, George Junior Republic will not inflate budget numbers in proposals or have unsupported costs and purchases paid with grant funds.
REFERENCECODE: ADM - 402 - GJR
TITLE: Gift Acceptance Policy
APPROVEDBY: GJR Board of Directors
DATEAPPROVED: 9/25/2019
DATEREVISED: 9/25/2019
ADM-402-GJR - Gift Acceptance Policy
It is the policy of George Junior Republic (“GJR”) and its controlled organizations (together “GJR Entities”) to encourage the solicitation and acceptance of gifts to the GJR Entities for purposes that will help GJR further and fulfill its mission. GJR is responsible for charitable solicitation activities and for managing gifts, contributions, and endowment funds to and for the benefit of the GJR Entities.
REFERENCECODE: ADM - 402 - 001 - GJR
TITLE: Gift Acceptance Procedure
APPROVEDBY: GJR Administrators
DATEAPPROVED: 8/3/2020
DATEREVISED: 11/21/2024
ADM-402-001-GJR - Gift Acceptance Procedure
A. Purpose of Gift Acceptance Policy
This Gift Acceptance Policy provides guidance to prospective donors and their advisors when making gifts to a GJR Entity and to GJR representatives authorized to accept gifts. This Gift Acceptance Policy is designed to protect the interests of the GJR Entities and benefit all parties, and should be construed to foster goodwill and generosity among all donors to the GJR Entities and the community. The provisions of this Gift Acceptance Policy shall apply to all gifts tendered to a GJR Entity.
B. Responsibility for Fund Raising Activities
The Development Office or their designated staff has primary responsibility for all fund raising. All fund raising proposals must be cleared with the Development Office prior to being undertaken. The Development Office may delegate responsibility for fund raising, but all gifts and pledges to any GJR Entity must be reported to the Development Office as soon as possible after receipt. The Development Office shall deliver to the Board of Directors of GJR regular reports of solicitations, gift acceptances, and development totals by and for the GJR Entities.
C. Gift Acceptance
The Executive Committee is charged with the responsibility of properly screening and accepting all gifts to a GJR Entity, and making recommendations to the Board of Directors of GJR regarding gift acceptance issues when appropriate. GJR’s Executive Committee shall be authorized to make the final decision regarding whether to accept any particular gift that is an acceptable gift as described in Section VI of this Gift Acceptance Policy, but may defer this decision to the Board of Directors of GJR when it deems appropriate to do so. The Executive Committee is not authorized to accept any gift that is not an acceptable gift as described in Section VI of this Gift Acceptance Policy; such decisions must be made by the Board of Directors of GJR. The Executive Committee may rely upon investigations and analysis performed by the Development Office. The Executive Committee is authorized to engage and rely upon the reports of qualified professionals when necessary to accomplish its work. The Executive Committee shall report to the Board of Directors of GJR quarterly regarding its work.
D. Conflict of Interest
GJR will urge all prospective donors to seek the assistance of personal legal and financial advisors in matters relating to their gifts and the resulting tax and estate planning consequences. No
January 29, 2025
representative of a GJR Entity is authorized to offer financial, legal, or tax advice to donors regarding the tax and estate planning consequences of a prospective gift or on any other matter. For example, a representative of a GJR Entity shall not advise the donor regarding the deductibility of a proposed gift; rather, the prospective donor should seek the counsel of a qualified advisor regarding that issue.
E. Restrictions on Gifts
GJR will accept unrestricted, restricted, and deferred gifts; provided, however, that GJR shall not accept any gift that is not consistent with its stated vision, purposes, or priorities. GJR will not accept gifts that are too restrictive in purpose. Gifts that are too restrictive in purpose include those that violate the terms of the Articles of Incorporation of a GJR Entity, gifts that are too difficult to administer, and gifts that are for purposes outside or inconsistent with the vision of GJR. GJR will endeavor to honor the wishes of the donor with respect to restricted gifts to GJR. In appropriate circumstances, GJR may seek donor or court approval to modify gift restrictions.
F.
Types of Gifts
The following gifts are acceptable:
Cash
Tangible Personal Property
Securities
Real Estate
Remainder Interests in Property
Bargain Sales
Life Insurance
Charitable Gift Annuities
Charitable Remainder Trusts/Charitable Lead Trusts
Retirement Plan Beneficiary Designations
Bequests
Other Gifts
G. The following criteria and consideration shall govern the acceptance of each gift form.
1. Cash: Cash is acceptable in any form. Checks shall be made payable to George Junior Republic and shall be delivered to GJR’s administrative offices. All cash shall be promptly deposited into an account maintained in the name of GJR.
2. Tangible Personal Property: All gifts of tangible personal property shall be examined by the Executive Committee in light of the following criteria:
a. Does the property fulfill GJR’s vision?
b. Is the property marketable?
c. Is this property free of any restrictions on its use, display or sale, including any liens against the property?
d. Is the property free of any carrying costs?
e. If the answer to any of the above is “No,” there shall be a presumption that GJR will not accept such property. That presumption may be overturned, however,
3. Securities: GJR may accept publicly traded securities, closely held securities and interests in partnerships, and other pass-through entities subject to the limitations described below.
a. Publicly Traded Securities: Marketable securities may be transferred to an account maintained at one or more brokerage firms, or delivered physically with the transferor’s signature or stock power attached. As a general rule, all marketable securities shall be sold upon receipt unless otherwise directed by GJR’s Board of Directors or Investment Committee, if any. In some cases, marketable securities may be restricted by applicable securities laws; in such instances, the final determination on the acceptance of the restricted securities shall be made by GJR’s Executive Committee.
Generally, GJR will not accept contributed property if the prospective donor wishes to restrict GJR’s ability to liquidate such property. However, in extraordinary circumstances, the Executive Committee, after consultation with legal counsel, may agree to accept property subject to restrictions on resale imposed by the donor. In no event shall an employee, agent, or volunteer of any GJR Entity commit to a potential donor that a particular security will be held by GJR unless authorized to do so by an officer of GJR under direction of the Executive Committee.
b. Closely Held Securities: Closely held securities, which include debt and equity positions in non-publicly traded companies, may be accepted subject to the approval of GJR’s Executive Committee. However, prior to acceptance, gifts of closely held securities must be reviewed with regard to the following considerations:
i. Are there restrictions on the security that would prevent GJR from ultimately converting those assets to cash?
ii. Is the security unmarketable?
iii. Will the security generate any undesirable tax consequences for any GJR Entity?
iv. If the answer to any of the above questions is “Yes,” there shall be a presumption that the gift shall not be accepted. Such presumption may be overturned, however, by direction of the Executive Committee. Further review and recommendation by an outside professional or advisor may be sought before making a final decision on acceptance of the gift. Every effort will be made to sell closely held securities as quickly as possible.
c. Pass-Through Entity Interests: Gifts of interests in pass-through entities, including partnerships and limited liability companies, will only be accepted by GJR upon approval of the Executive Committee, which, with the assistance of
January 29, 2025 by direction of the Executive Committee after appropriate review and consideration.
legal counsel must review the agreements that govern the pass-through entity giving consideration to the following issues:
i. What is the value of the interest? Generally, GJR will not accept an interest in a pass-through entity that does not have a value, after all applicable discounts, of at least $10,000, as determined by a qualified appraiser.
ii. Is GJR the beneficiary of the income and liquidation proceeds of the passthrough entity interest?
iii. What are the costs to GJR of holding the interest, including administrative responsibilities, tax-return preparation, and unrelated business income tax?
iv. Is GJR’s interest sufficiently liquid? Does the governing agreement provide GJR the power to redeem its interest?
v. Will holding the pass through interest cause any adverse tax consequences for GJR?
4. Real Estate: Gifts of real estate may include developed property, undeveloped property, and gifts subject to a prior life interest (see paragraph 5 below). Prior to acceptance of any gift of real estate, GJR shall consult with qualified real estate professionals regarding issues raised by the property, including, for example, any liabilities, environmental or otherwise, that may exist or may be incurred by acceptance of the subject property.
Before accepting a gift of real estate, GJR shall obtain its own appraisal of the property and shall not rely upon an appraisal commissioned by the donor. The donor may elect to have its own appraisal to value the property, but GJR shall not allow the donor to use GJR’s appraisal. Each of both GJR and the donor shall bear its own expenses incurred in the assessment of a gift of property.
a. Due to the expenses associated with a gift of real estate, only gifts of real estate equal to or greater than $100,000 in value shall be accepted.
b. When appropriate, a title binder shall be obtained by GJR prior to the acceptance of the real property gift. The cost of this title binder shall generally be the expense of the donor.
c. In addition to the review of the real property as described above, the Executive Committee shall approve a gift of real estate only after consideration of the following issues:
d. Is the property useful for the purposes of GJR?
e. Is the property marketable?
f. What is the property’s fair market value?
g. Are there any restrictions, reservations, easements or other limitations associated with the property?
h. Are there carrying costs, which may include insurance, property taxes, mortgages or notes, etc., associated with the property?
i. Is the property subject to a mortgage?
5. Remainder Interests in Property: GJR will accept a remainder interest in a personal residence, farm, or other property, subject to the provisions of paragraph 4 above. The donor or other occupants may continue to occupy the property for the duration of the stated life or lives. At the death of the donor and/or other life beneficiary(ies), GJR may use the property or reduce it to cash. Where GJR receives a gift of a remainder interest, expenses for maintenance, insurance premiums, real estate taxes, and any property indebtedness are to be paid by the donor or primary beneficiary. In addition, the donor or primary beneficiary may also be asked to pay other costs related to the contributed property and the life interest of such property, including, but not limited to, real estate commissions, property appraisals, and other costs of sale.
Caveat: Gifts of remainder interests in property often involve a donor’s primary residence, which is often his or her most substantial asset. This fact can lead to situations in which the donor or the donor’s family seeks to convert to cash the property in which the remainder interest was donated. For example, an elderly donor makes a charitable contribution of the remainder interest in their primary residence. Due to the donor’s failing health, the residence falls into disrepair. Eventually, the donor requires long-term care, but does not have the financial resources to secure such care. The donor’s family may even go to court seeking to undo the gift of the remainder interest, but is usually denied. As a result, the donee charity could be faced with ownership of a residence in disrepair and a great deal of negative publicity. Accordingly, prior to accepting a gift of a remainder interest in property, GJR must provide written notice to the potential donor of the irrevocable nature and the potential consequences of the gift.
6. Bargain Sales: GJR may enter into a bargain sale arrangement in instances in which the bargain sale furthers the vision and purposes of GJR. When determining the appropriateness of the transactions, the Executive Committee shall obtain an independent appraisal substantiating the value of the property. If GJR assumes debt with the property, the debt ratio must be less than 50% of the appraised market value. The Executive Committee shall also determine whether GJR will use the property, or whether there is a market for the sale of the property, allowing the sale within 12 months of receipt. The Executive Committee shall calculate the costs to safeguard, insure, and maintain the property (including property tax, if applicable) during the holding period.
7. Life Insurance: GJR must be named as both beneficiary and irrevocable owner of 100% of an insurance policy before a life insurance policy can be an irrevocable gift. If any interest in the policy inures to the benefit of any party other than GJR, GJR shall not accept the proposed gift of insurance. Furthermore, prior to accepting the gift of insurance, the Executive Committee must be satisfied that the company that issued the policy proposed for contribution to GJR is of reasonable quality, based primarily on thirdparty rankings.
A gift of insurance is valued at its interpolated terminal reserve value, or cash surrender value, upon receipt. If the donor contributes future premium payments, GJR will include the entire amount of the additional premium payment as a gift in the year that it is made.
If the donor does not elect to continue to make gifts to cover premium payments on the life insurance policy, GJR may:
Continue to pay the premiums; Convert the policy to paid-up insurance; or Surrender the policy for its current cash value. In no event will GJR obligate itself to continue premium payments on contributed insurance policies.
8 Charitable Remainder Trusts/Charitable Lead Trusts: GJR will accept designations as a charitable beneficiary of charitable remainder trusts or charitable lead trusts. GJR will not accept appointment of any GJR Entity or officer of a GJR Entity as Trustee of charitable remainder trusts or charitable lead trusts.
9. Retirement Plan Beneficiary Designations: Donors and supporters of GJR will be encouraged to name GJR as a beneficiary of their retirement plans and Individual Retirement Accounts. In the event such accounts hold assets other than cash, the Executive Committee shall apply the appropriate standard described in this Gift Acceptance Policy.
10. Bequests: Donors and supporters of GJR will be encouraged to make bequests to GJR in their wills and to name GJR as a beneficiary of their trusts. In the event of an inquiry by a prospective donor, representations as to the acceptability of property proposed to be given to GJR under a will or any other deferred gift arrangement shall be made only in accordance with the terms and provisions of this Gift Acceptance Policy. Any prospective donor considering a bequest to GJR shall be provided with at least the following information to be included in the bequest: 1) GJR’ s full name; 2) its tax identification number; and 3) its street address.
11. Other Gifts: The types of gifts listed in these policies and guidelines are by no means exhaustive. Proposed gifts of a type that are not contemplated in these policies and guidelines, including, for example, oil, gas and other mineral interests, operating businesses, and commercial co-venture arrangements, must be examined on a case-bycase basis by the Executive Committee and, as necessary, outside advisors. Any gift not specifically addressed by these policies and guidelines may only be accepted by approval of the Board of Directors of GJR.
GJR is not required to accept every gift that satisfies the requirements of this Section VI. Rather, notwithstanding any of the provisions of Section VI, GJR reserves the right to refuse any gift of any type in the sole discretion of the Board of Directors or the Executive Committee.
H. Miscellaneous Provisions
1. Appraisals and legal representation: It will be the responsibility of the donor to secure an appraisal (where required) and their own independent legal counsel for all gifts made to GJR.
2. Valuation of gifts for development purposes: GJR will record a gift received by GJR at its valuation for gift purposes on the date of the gift.
3. Responsibility for IRS filings upon sale of gift items: GJR is responsible for filing IRS Form 8282 upon the sale or disposition of any property other than money or publicly traded securities sold within three years of receipt by GJR when the charitable deduction value of the item is more than $5,000. GJR must file this form within 125 days of the date of sale or disposition of the asset. A copy of Form 8282 is attached to this Gift Acceptance Policy as Exhibit ”A.”
Acknowledgement of all gifts made to GJR and compliance with the current IRS requirements for gift acknowledgement shall be the responsibility of GJR. At the very least, gift acknowledgements from GJR must include a written statement as to the amount of cash or a description of the property contributed, an estimate of the value of goods or services, if any, received by the donor in consideration for the gift, unless the goods or services are” insubstantial” as that term is defined by the IRS, and any reduction in the donor’s charitable tax deduction due to the receipt of goods or services. Acknowledgements will be delivered to the donor within thirty (30) days of GJR’s receipt of the donation. GJR will not include a value for contributed property in the acknowledgement.
4. Naming: If the donor has been promised or has a reasonable expectation that a building, program, or something else will be named after the donor, GJR should enter into a written agreement with the donor specifying matters such as the name and the duration of the use of the name. The agreement should also authorize GJR to use the name and identify circumstances under which GJR can cease to use the name (e.g., adverse impact on GJR’s reputation, cessation of program, destruction of building, etc.)
I. Solicitation Registration Requirements
GJR shall establish and maintain appropriate and necessary registrations for charitable solicitations in each jurisdiction in which GJR will solicit contributions.
J. Use of Legal Counsel
GJR shall seek the advice of legal counsel knowledgeable in charitable matters for issues relating to acceptance of gifts when appropriate. Review by counsel is recommended for:
1. Closely held stock transfers that are subject to restrictions or buy-sell agreements.
2. Gifts involving contracts, such as bargain sales or other documents requiring GJR to assume an obligation.
3. Transactions with potential conflicts of interest that may risk IRS sanctions.
4. Gifts of interests in limited liability companies, partnerships, and other pass-through entities.
5. Other instances in which use of counsel is deemed appropriate by GJR’s President and Chief Executive Officer, GJR’s Board of Directors, and/ or the Executive Committee.
6. Gifts where the donor has been promised or reasonably expects that a building, program or something else will be named after the donor.
REFERENCECODE: ADM - 403 - GJR
TITLE: Educational Improvement Tax Credit (EITC) Policy
APPROVEDBY: GJR Board of Directors
DATEAPPROVED: 9/25/2019
DATEREVISED: 1/29/2025
ADM-403-GJR - Educational Improvement Tax Credit (EITC) Policy
George Junior Republic, as a participant in the Educational Improvement Tax Credit (EITC) program, will annually review and apply to be a Scholarship Organization as part of the Educational Improvement Tax Credit Program. George Junior Republic will seek guidance from the Department of Community and Economic Development in establishing the aforementioned policies.
REFERENCECODE: ADM - 403 - 001 - GJR
TITLE: Educational Improvement Tax Credit (EITC) Procedure
APPROVEDBY: GJR Administrators
DATEAPPROVED: 8/3/2020
DATEREVISED: 11/21/2024
ADM-403-001-GJR - Educational Improvement Tax Credit (EITC) Procedure
On an annual basis, George Junior Republic will complete the renewal application and supporting documentation for the EITC program as both a Scholarship Organization (SO) and Educational Improvement Organization (EIO). Application materials will be completed based on EITC application guidance.
Eligibility
Eligible participants include only persons served who are residents of Pennsylvania.
Record Keeping
All records related to EITC will be saved for a minimum of three years. Historical EITC documents will be stored by the Development Office.
Scholarship Organization
George Junior Republic, as a Scholarship Organization, will utilize 80% of its annual EITC-SO receipts to cover tuition to eligible Pennsylvania students to attend the Maurice Cohill, Jr. Academic Center, located on the George Junior Republic campus and operated by Grove City Area School District.
For purpose of the EITC program, George Junior Republic defines ‘tuition’ as room, board, program support, and all additional costs associated with a person served who is placed and cared for at the George Junior Republic Grove City campus.
All eligible persons served will be determined eligible based on their placement at the facility and additional guidelines defined by the PA Bureau of Economic Development.
Records on persons served receiving scholarship will be maintained and archived based on scholarship year and will include scholarship amount.
All EITC funds will be managed and reported via monthly reporting to Finance and annual reporting to the PA Bureau of Economic Development.
REFERENCECODE: ADM - 404 - GJR
TITLE: Fundraising Policy
APPROVEDBY: GJR Board of Directors
DATEAPPROVED: 9/25/2019
DATEREVISED: 1/29/2025
ADM-404-GJR - Fundraising Policy
It is the policy of the agency that philanthropy is voluntary and based on the common good. To ensure coordination of all fundraising efforts, no fundraising project or solicitation shall be undertaken at George Junior Republic without the knowledge and approval of the Development Office. The Parent company serves as the fundraising entity.
REFERENCECODE: ADM - 404 - 001 - GJR
TITLE: Fundraising Procedure
APPROVEDBY: GJR Administrators
DATEAPPROVED: 9/25/2019
DATEREVISED: 11/21/2024
ADM-404-001-GJR - Fundraising Procedure
Fundraising campaigns will include annual campaigns, planned gifts, and capital campaigns.
Campaigns Defined
A. Annual Campaigns are campaigns conducted each and every year for the purpose of raising money to assist in paying a non-profit organization’s regular, ongoing expenses.
B. B. Planned Gifts are defined as bequests, asset allocations, Charitable Gift Annuities and Charitable Remainder Trust, life insurance assignments, and retirement assignments. These gifts afford the donor significant tax savings and will be assigned to George Junior Republic by a donor.
The Development Office will seek planned gifts from staff, board members and current donors. Donors interested in making a planned gift will be encouraged to speak with their financial planner and estate attorney. George Junior Republic requests, if known, that a copy of the assigned donation be placed on file with the Development Office
Planned gifts will include the following categories:
1. Bequests: Donors can assign money, securities, personal property, real estate, or a combination to George Junior Republic by will, trust, or beneficiary designation. Bequests may be a specific amount, an amount determined by percentage or formula, or what is left in the estate after all other bequests have been made. George Junior Republic will accept permanently and temporarily restricted and unrestricted gifts. Advantages include:
a. Current assets will not be depleted
b. Provides the opportunity to change at will
c. Gifts may help avoid state and federal estate taxes
2. Charitable Gift Annuities: Donors may enter into a contract with George Junior Republic whereby the gift is transferred to the organization and the donor names one or two people, including him/herself, to receive a fixed annual payment for life. These gifts can be scheduled for immediate distribution or deferred until a future designated date (such as attainment of a certain age by the annuitant). Assets used to fund gift annuities include cash, securities, real estate (if converted to cash), and collectibles (if converted to cash).
Advantages include:
a. Supporting a worthy cause
b. Making a charitable tax deduction
c. Lowering or partially avoiding capital gains taxes or spread capital gains tax over a lifetime.
3. Charitable Remainder Trusts: Donors may choose to place a major gift of cash, securities, or property into a trust. The trust will pay a fixed amount or a percentage of value each year to
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the donor or others designated by the donor. When the donor or other beneficiary passes, whatever remains in the trust is transferred to the organization. Advantages include:
a. Tax deduction for the gift to charity
b. Assets removed from the donor’s taxable estate
c. Deferral of capital gains on sale of assets contributed to the trust
d. The trust can blend with other estate planning options
e. Trustee of trust may be the donor
f. Trust assets may be reinvested
4. Charitable Lead Trusts: Donors may contribute property to a trust that will immediately benefit George Junior Republic with regular and fixed payments for a set number of years. At the end of the term, the remainder of the trust will go to the donors identified beneficiaries. Advantages include:
a.A means to transfer wealth to the next generation
b.George Junior Republic will get the cash first
c. Potential tax benefits
5. Life Insurance: Donors may designate George Junior Republic the sole owner and beneficiary of policy. Advantages include:
a.Tax deductions when premiums are paid.
b.Possible estate tax savings.
6. Retirement Plan Designation: Donors may designate George Junior Republic as a retirement plan beneficiary.
C. Capital Campaigns
The strategic plan will outline the need for specific capital campaigns. The capital campaign process will be outlined based on a Case for Support. The capital campaign will involve a team of staff persons, board members, and other volunteers to engage the community and promote corporate support.
D. Building/Classroom Naming Rights
In the case of naming in recognition of philanthropy, the Board of Directors shall determine the minimum values of donations for any and all buildings, parts of buildings, and other spaces. The guiding principle shall be that the gift received has a correlation to the cost of the named building, or part of the building or space. The entire donation must be received before the building or space is named. Ultimate authority to accept or reject the funds rests with the Board of Directors.
E. Internet Giving
Giving opportunities will be available to donors online and will be outlined based on type of solicitation. Thank you letters and correspondence will be sent to all individuals participating in online giving opportunities.
REFERENCECODE: ADM - 405 - GJR
TITLE: Communications and Marketing Policy
APPROVEDBY: GJR Board of Directors
DATEAPPROVED: 6/29/2022
DATEREVISED: 1/29/2025
ADM-405-GJR – Communications and Marketing Policy
It is policy of George Junior Republic and Affiliates that the overall development and application of marketing and communications strategies will reside with administration and the Development Office. This will include the development of marketing and communications strategies for GJR and Affiliates.
REFERENCECODE: ADM - 405 - 001 - GJR
TITLE: Communication and Marketing Procedure
APPROVEDBY: GJR Administrators
DATEAPPROVED: 7/28/2022
DATEREVISED: 11/21/2024
ADM-405-001-GJR – Communication and Marketing Procedure
External communications will be coordinated through the Development Office. These activities may include, but are not limited to:
A. Publications (including print and electronic publications)
B. Organizational branding, logos and unit graphic identity
C. Advertising
D. Development of the website/webpages
E. Review and approval process for all items bearing GJR’s logo(s).
Corporate Sponsorship Identification
A. All sponsorship programs offering corporate identification including print publications, online, video, clothing and other items, must adhere to GJRs Brand Guidelines.
B. The Development Office is the contact department for inquiries related to corporate sponsorship.
Paid Advertising
A. All advertising, must be approved by the Development Office. This ensures appropriateness and consistency of GJR’s messaging and image.
REFERENCECODE: ADM - 406 - GJR
TITLE: Brand Guidelines Policy
APPROVEDBY: GJR Board of Directors
DATEAPPROVED: 6/29/2022
DATEREVISED: 1/29/2025
ADM-406-GJR – Brand Guidelines Policy
The development and application of GJR’s brand guidelines is determined by the Development Office and is approved by administration.
REFERENCECODE: ADM - 406 - 001 - GJR
TITLE: Brand Guidelines Procedure
APPROVEDBY: GJR Administrators
DATEAPPROVED: 7/28/2022
DATEREVISED: 11/21/2024
ADM-406-001-GJR – Brand Guidelines Procedure
GJR’s name and logo are the official emblems of GJR and Affiliates and may only be used for official purposes.
The GJR’s logos, along with accepted variations, are the primary graphic marks for GJR. The logos are designed to promote the GJR’s brand and must be used on all internal and external printed and electronic materials representing GJR. The logos must be used by all affiliates and departments and the logos are not to be modified by changing the font, proportions, color or other design alteration.
Nondiscrimination Notices
A nondiscrimination notice/statement may be placed on various marketing pieces, advertisements, etc., based on the discretion of the organization.
Postcards and one-page flyers for display:
If the document being distributed satisfies U.S. Postal Service requirements for being classified as a postcard or if the document is a one-page promotional flier intended for display (excluding flyers not intended for display purposes or flyers intended for student recruitment efforts), the following nondiscrimination notice may be used:
A. George Junior Republic and Affiliates is an equal opportunity/affirmative action institution.
News Releases
Press Releases are written by the Development Office or designee and approved by administration.
Campus Announcements
Organizational announcements will be placed on the intranet and pre-approved by the intranet administrator.
Responding to Media Inquiries and Government Relations
The Chief Executive Officer will respond to all media inquiries and will work directly with governmental authorities or assign a designee to serve in this capacity.
REFERENCECODE: ADM - 407 - GJR
TITLE: Web Standards Policy
APPROVEDBY: GJR Board of Directors
DATEAPPROVED: 6/29/2022
DATEREVISED: 6/29/2022
ADM-407-GJR – Web Standards Policy
The GJR Web Standards described herein apply to all GJR webpages and web-based services that use GJR web services. This policy applies to GJR webpages (gjr.org and its subdomains) and web-based services representing the GJR on the public internet. It pertains to all persons tasked with maintaining GJR websites.
REFERENCECODE: ADM - 407 - 001 - GJR
TITLE: Web Standards Procedure
APPROVEDBY: GJR Administrators
DATEAPPROVED: 7/28/2022
DATEREVISED: 11/21/2024
ADM-407-001-GJR – Web Standards Procedure
GJR Web Standards are intended to promote a strong and consistent GJR brand, in conjunction with a clear and accessible interface for those accessing information about GJR via the web. Each GJR website document is part of GJR’s public presentation, and should be written and edited with the same care and diligence that one would apply to a GJR print publication. All GJR websites shall comply with both GJR Web Standards and Section 508 accessibility standards as follows:
A. Domain Names
GJR websites must have domain names within the gjr.org domain, e.g. gjr.edu/careers or intranet.gjr.org. External domain names shall not host a GJR site or redirect to a gjr.org-based URL unless there is a valid marketing reason for doing so. In those rare cases, use of an external domain name must be approved by the Development Office
B. Design
GJR websites use GJR’s WordPress Content Management System (CMS) and GJR-approved web templates. The GJR approved web templates provide consistent branding and navigation while supporting a broad range of content and layout options. Sites that have received approval to be outside of this CMS are required to adhere to GJR brand standards in their design.
C. Training
In order to receive editing/publishing access, all persons tasked with maintaining the GJR website (web administrators) must receive training to use the campus WordPress environment and understand what is required to comply with GJR’s web standards.
D. Contact Information
GJR websites must provide up-to-date contact information (name, address, email) as a way for users to contact a GJR affiliated department/organization.
E. Ensuring Accuracy
GJR websites must be continuously maintained. Periodic review and necessary revision are needed to ensure that all GJR content is relevant, accurate and up-to-date, as required by the specific area/unit web administrator.
F. Confidential Information
Confidential information shall not be published on GJR websites. All published GJR webpages are submitted to public search engines (e.g., Google, Bing), even if that page has no inbound links (an orphaned page). Content that should not be found by site search should be removed by setting its status to “draft” or removing the page to “trash.”
G. Sponsorship
Only departments/organizations with an existing and approved advertising/sponsorship may be
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placed on the GJR website. For approval of prospective advertising/sponsorship programs, please contact the Development Office
H. Compliance with GJR Web Standards
If noncompliance with GJR Web Standards is found, the noncompliant page(s) may be placed in draft mode by the Development Office. When the Development Office places noncompliant pages in draft mode, the site administrator will be notified via email that the pages require updating before they can be returned to live status. The site administrator may then update the pages, keeping them in draft mode, and notify the Development Office when all updates have been made. The Development Office will then review the updated pages, determine if they are compliant with the GJR Web Standards, and if so, return the pages to live status.
Section 508 Amendment to the Rehabilitation Act of 1973 Information Technology Accessibility Standards
George Junior Republic complies with Section 508 Amendment to the Rehabilitation Act of 1973. Section 508 standards are based on the Web Content Accessibility Guidelines (WCAG) established by the Web Accessibility Initiative (WAI) of the World Wide Web Consortium (W3C). Compliance with Section 508 standards is required by law.
To report or discuss general concerns regarding George Junior Republic’s compliance with Section 508 Amendment to the Rehabilitation Act of 1973, please contact Human Resources at hr@gjr.org.
ADMINISTRATIVE (ADM) Section 500 – Compliance
REFERENCECODE: ADM - 500 - GJR
TITLE: Compliance Plan Policy
APPROVEDBY: GJR Board of Directors
DATEAPPROVED: 9/25/2019
DATEREVISED: 9/25/2019
ADM-500-GJR - Compliance Plan Policy
It is the policy of the agency to comply with all applicable laws and regulations that support the efforts of federal and state authorities in identifying incidents of fraud, waste, and abuse. The procedures that follow are intended to prevent, detect, and respond to potential issues of fraud, waste, and abuse.
REFERENCECODE: ADM - 500 - 001 - GJR
TITLE: Components of the Compliance Work Plan Procedure
APPROVEDBY: GJR Administrators
DATEAPPROVED: 8/3/2020
DATEREVISED: 8/3/2020
ADM-500-001-GJR - Components of the Compliance Work Plan Procedure
A. All employees, contractors, interns, and volunteers must conduct themselves in an ethical and legal manner as defined in the agency’s Code of Conduct.
B. All employees, contractors, interns, and volunteers have a duty to report potential or suspected incidents of fraud, waste, abuse, and other wrongdoing.
C. The Compliance Department has responsibility for receiving and acting upon all information suggesting the existence of possible fraud, waste, abuse, or other wrongdoing. This includes establishing the compliance work plan that includes the following elements:
1. Prevention:
a. Establishing written policies and procedures
b. Acting as the Compliance Officer through appointment by the Chief Executive Officer
c. Overseeing of training of all personnel
2. Detection:
a. Creating reporting mechanisms to include anonymous reporting options
b. Instituting and overseeing of internal auditing processes
c. Monitoring treatment of personnel and others who report in order to address potential for harassment or mistreatment
3. Corrective action:
a. Investigating quickly and thoroughly any reports of suspected fraud, waste, abuse, or other wrongdoing in order to remediate with corrective action
b. Supporting clear and consistent disciplinary action for anyone found to be involved in unlawful and/or unethical behavior
4. Evaluation of the Compliance Program
a. Reporting all findings to the Chief Executive Office and the Board of Directors on a frequent and regular basis
b. Ensuring that the compliance program is effective by tracking and trending findings
REFERENCECODE: ADM - 500 - 002 - GJR
TITLE: Responsibilities of Employees Procedure
APPROVEDBY: GJR Administrators
DATEAPPROVED: 8/3/2020
DATEREVISED: 8/3/2020
ADM-500-002-GJR - Responsibilities of Employees Procedure
A. All employees of the agency share a responsibility to ensure compliance with all applicable laws, regulations, and contractual agreements in their assigned areas.
B. Each employee will review and sign the Ethical Code of Conduct upon hire.
C. All employees are required to complete compliance training at hire as well as annually thereafter.
D. It is the responsibility of any employee suspecting fraud, waste, and/or abuse to report either directly or anonymously in order to allow investigation of the situation.
E. Concerns may be reported directly to your supervisor, any member of the management or administrative team, Risk Officer, and/or Compliance and Outcomes Coordinator.
F. Compliance issues may be reported anonymously by calling 724-459-9341, 724-458-9330 x1500, or x1500 from a campus telephone. Issues may be reported by email at tline@gjr.org.
G. All employees must fully cooperate with internal or external investigations.
REFERENCECODE: ADM - 500 - 003 - GJR
TITLE: Drift Procedures
APPROVEDBY: GJR Administrators
DATEAPPROVED: 8/3/2020
DATEREVISED: 8/3/2020
ADM-500-003-GJR - Drift Procedures
Drift – deviation from policies and procedures in the delivery of services either from a theoretical framework of a dosage or duration perspective
Any time the Supervisor of the staff delivering services determines that drift occurred, the following steps will be implemented:
A. Documentation of the supervisor’s findings will be drafted and given to the delivery staff on the Response to Drift Feedback Form.
B. The corrective action plan for drift will be completed by the supervisor and delivery staff.
C. The corrective action may include but is not limited to: review of the Policies and Procedures, retraining of staff, booster training, job shadowing, professional development, or additional monitoring.
D. Repetitive issues or patterns of deviance may result in disciplinary actions as outlined in the George Junior Republic Employee Handbook.
E. Copies of the Feedback Form will be kept on file and may be used for employee evaluations.
REFERENCECODE: ADM - 500 - 004 - GJR
TITLE: Responsibilities of Volunteers/Contractors/Interns Procedure
APPROVEDBY: GJR Administrators
DATEAPPROVED: 8/3/2020
DATEREVISED: 8/3/2020
ADM-500-004-GJR - Responsibilities of Volunteers/Contractors/Interns Procedure
A. All contractors of the agency share a responsibility to ensure compliance with all applicable laws, regulations, standards, and contractual agreements in their assigned areas.
B. Each contractor will review and sign the Ethical Code of Conduct as a part of the contracting process.
C. All volunteers/contractors/interns are required to complete compliance training at hire as well as annual refresher training.
D. It is the responsibility of all volunteers/contractors/interns to report either directly or anonymously any potential fraud, waste, and/or abuse concern in order to allow investigation.
E. All volunteers/contractors/interns must fully cooperate with internal or external investigations.
REFERENCECODE: ADM - 500 - 005 - GJR
TITLE: Responsibilities of Management and Board Members Procedure
APPROVEDBY: GJR Administrators
DATEAPPROVED: 8/3/2020
DATEREVISED: 12/7/2023
ADM-500-005-GJR - Responsibilities of Management and Board Members Procedure
A. All managers and board members of the agency share a responsibility to ensure compliance with all applicable laws, regulations, standards, and contractual agreements in their assigned areas.
B. Each employee and board member will review and sign the Ethical Code of Conduct upon hire or appointment
C. All managers are required to complete compliance training at hire as well as annual refresher training. Board members will receive compliance training at the designated annual training.
D. It is the responsibility of all managers and board members to report their own concern either directly or anonymously regarding potential fraud, waste, and/or abuse concern in order to allow investigation.
E. Managers and board members will also be responsible for reporting directly any complaints or concerns that are brought to their attention by any party to the Risk Officer or CEO.
F. Managers and board members will not retaliate against anyone who shares a compliance concern. Further, they must actively protect others from retaliation related to reporting any compliance concern.
G. All managers must fully cooperate with internal or external investigations.
REFERENCECODE: ADM - 500 - 006 - GJR
TITLE: Responsibilities of Risk Officer Procedure
APPROVEDBY: GJR Administrators
DATEAPPROVED: 8/3/2020
DATEREVISED: 12/7/2023
ADM-500-006-GJR - Responsibilities of Risk Officer Procedure
A. The Risk Officer is responsible for implementing the compliance program/department and the day to day operations within the agency.
B. The Risk Officer provides guidance to management, medical/clinical personnel, and individual departments regarding policies, procedures, regulations, laws, standards, and contractual issues.
C. The Risk Officer responds to alleged violations of rules, regulations, policies, and procedures by evaluating and initiating investigations when appropriate.
D. The Risk Officer works with Human Resources, Staff Development, and other departments as appropriate to develop an effective compliance training program, including appropriate introductory training for new employees and defined others, as well as ongoing training for all employees and managers.
E. The Risk Officer works with other departments to ensure that individuals and entities that are excluded from participation in Medicare, Medicaid, or other federal health care programs are not employed or retained by the organization.
F. Reports will be provided by the Compliance Risk on a regular basis and as requested to the Board of Directors and the administrative team of the agency.
REFERENCECODE: ADM - 501 - DA - GJR
TITLE: Approval of Compliance Plan Policy
APPROVEDBY: GJR Board of Directors
DATEAPPROVED: 9/25/2019
DATEREVISED: 9/25/2019
ADM-501-DA-GJR - Approval of Compliance Plan Policy
It is the policy of this facility that the governing body must approve a written compliance plan addressing the hiring of qualified staff.
REFERENCECODE: ADM - 501 - 001 - DA - GJR
TITLE: Approval of Compliance Plan Procedure
APPROVEDBY: GJR Administrators
DATEAPPROVED: 8/3/2020
DATEREVISED: 8/3/2020
ADM-501-001-DA-GJR - Approval of Compliance Plan Procedure
It is the procedure of this facility that the Facility Director creates and seeks annual approval by the governing body of the George Junior Republic Board for the hiring of qualified staff with the appropriate educational and experiential qualifications. It is the procedure of this facility to have this compliance plan available for all Department of Drug and Alcohol Programs audits.
REFERENCECODE: ADM - 502 - DA - GJR
TITLE: Drug and Alcohol Standards Compliance Policy
APPROVEDBY: GJR Board of Directors
DATEAPPROVED: 9/25/2019
DATEREVISED: 9/25/2019
ADM-502-DA-GJR - Drug and Alcohol Standards Compliance Policy
It is the policy of this agency to comply with the Standards for Inpatient Non-Hospital Activities – Residential Treatment and Rehabilitation identified by the Pennsylvania Department of Drug and Alcohol Programs in Chapters 704, 705, and 709.
REFERENCECODE: ADM - 503 - DA - GJR
TITLE: Drug and Alcohol Residential Facility Compliance Policy
APPROVEDBY: GJR Board of Directors
DATEAPPROVED: 9/25/2019
DATEREVISED: 9/25/2019
ADM-503-DA-GJR - Drug and Alcohol Residential Facility Compliance Policy
It is the policy of this facility to comply with the Pennsylvania Department of Drug and Alcohol Programs regulation requirements found in Chapters 704, 705, and 709.
REFERENCECODE: ADM - 503 - 001 - DA - GJR
TITLE: Drug and Alcohol Residential Facility Compliance Procedure
APPROVEDBY: GJR Administrators
DATEAPPROVED: 8/3/2020
DATEREVISED: 8/3/2020
ADM-503-001-DA-GJR - Drug and Alcohol Residential Facility Compliance Procedure
The Drug and Alcohol Facility complies with the following:
A. Hold a license under Chapter 709 or Chapter 711 of Title 28 of the Pennsylvania Code.
B. Maintain a certificate of occupancy from the Department of Labor and Industry or the local equivalent
C. Comply with all applicable federal, state, and local laws and ordinances
D. Maintain the exterior buildings and the physical grounds
E. Meet the requirements for living rooms and lounges
F. Provide counseling areas, sleeping accommodations, bathrooms, food service, heating and cooling, general safety and emergency procedures, fire safety, and childcare.
REFERENCECODE: ADM - 504 - GJR
TITLE: Suspension and Debarment Policy
APPROVEDBY: GJR Board of Directors
DATEAPPROVED: 9/25/2019
DATEREVISED: Update TBD
ADM-504-GJR - Suspension and Debarment Policy
It is the policy of the agency to comply with all compliance requirements to prevent, detect, and address potential fraud, waste, and abuse. This includes checking new and existing employees, board members, and contractors for suspension and debarment.
REFERENCECODE: ADM - 504 - 001 - GJR
TITLE: Suspension and Debarment Definitions Procedure
APPROVEDBY: GJR Administrators
DATEAPPROVED: 8/3/2020
DATEREVISED: 8/3/2020
ADM-504-001-GJR - Suspension and Debarment Definitions Procedure
A. Suspension and debarment processes protect the federal government and taxpayers from fraud, waste, and abuse by using tools to avoid doing business with non-responsible parties.
B. Suspension is an action taken by a suspending official that excludes or disqualifies a person or company from bidding on, receiving, or participating in federally funded contracts or grants for a temporary period of time, a twelve-month limit, pending the completion of an investigation or legal or administrative proceedings. A suspension has government-wide effect applying to all Federal programs and procurement.
C. Debarment is an action taken by a debarring official that excludes or disqualifies a person or company for a specific period of time, usually 3 years. A debarment has government-wide effect applying to all Federal programs and procurement.
REFERENCECODE: ADM - 504 - 002 - GJR
TITLE: Suspension and Debarment – New Employees Procedure
APPROVEDBY: GJR Administrators
DATEAPPROVED: 8/3/2020
DATEREVISED: 12/7/2023
ADM-504-002-GJR - Suspension and Debarment – New Employees Procedure
The Human Resources Department will establish that all newly hired employees have not been excluded from participation in Medicare, Medicaid, or other federal health care program. The steps to accomplish this task for new employees are as follows:
A. All newly hired employees are added to the payroll system and ADP with detailed demographic information.
B. All newly hired employees are screened upon hire by the assigned Human Resource staff using the “Verify Comply” search software. The new employees’ demographic information will be imported into the Verify Comply database for George Junior Republic to support ongoing monthly exclusion checks.
C. Should a new employee be found to be excluded from participation, the Human Resources Officer is informed via email of the finding. The Human Resources Officer will terminate employment with any new employee found to be excluded from participation in Medicare, Medicaid, or other federal health care programs.
D. The Human Resources staff assigned to complete exclusion checks retains the results of the new hire screening and sends these results via email to the Compliance and Outcomes Coordinator to confirm completion of the process and to maintain evidence of the outcomes.
REFERENCECODE: ADM - 504- 003 - GJR
TITLE: Suspension and Debarment – Routine Existing Employees Procedure
APPROVEDBY: GJR Administrators
DATEAPPROVED: 8/3/2020
DATEREVISED: 8/3/2020
ADM-504-003-GJR - Suspension and Debarment – Routine Existing Employees Procedure
The Human Resources Department will establish that all current employees have not been excluded from participation in Medicare, Medicaid, or other federal health care program through a monthly check. The steps to accomplish this task for existing employees are as follows:
A. The assigned Human Resources staff will maintain an active list of employees with the necessary demographic information in the “Verify Comply” search software.
B. The Comply Verify search is run each month by the assigned Human Resources staff on a predetermined date. Results of the monthly search are emailed to the Compliance and Outcomes Coordinator in order to confirm completion and to keep a second file of results for evidence purposes.
C. Should any employee be found to be excluded, the Human Resources Officer is informed by the Human Resources staff that ran the check. The Human Resources Officer will terminate the employment of any employee positively found to be excluded from participation in Medicare, Medicaid, or other federal health care programs.
REFERENCECODE: ADM - 504 - 004 - GJR
TITLE: Suspension and Debarment – New Contractors Procedures
APPROVEDBY: GJR Administrators
DATEAPPROVED: 8/3/2020
DATEREVISED: 8/3/2020
ADM-504-004-GJR - Suspension and Debarment – New Contractors Procedure
The Finance Department will establish that all new contractors or vendors, both individuals and businesses, have not been excluded from participation in Medicare, Medicaid, or other federal health care programs. The steps to accomplish this task for new employees are as follows:
A. All new contractors and vendors, individuals and businesses, to be employed by the agency will have their demographic information established through the Finance Department accounting system.
B. The assigned Finance Department staff will maintain an active database of all new and active contractors and vendors which will be uploaded into “Verify Comply” search software.
C. The Verify Comply search is run each month on a pre-determined date by the assigned Finance Department staff and results are emailed to the Compliance and Outcomes Coordinator to confirm completion and results of each monthly run for evidence purposes.
D. Should a vendor or contractor be found to be excluded from participation in Medicare, Medicaid, or other federal health care programs, then the Finance Department staff will immediately provide this information to the Chief Financial Officer (CFO). The CFO will ensure that the agency terminates any contract or business agreement with the excluded entity.
REFERENCECODE: ADM - 504 - 005 - GJR
TITLE: Suspension and Debarment – Routine Existing Contractors Procedure
APPROVEDBY: GJR Administrators
DATEAPPROVED: 8/3/2020
DATEREVISED: 8/3/2020
ADM-504-005-GJR - Suspension and Debarment – Routine Existing Contractors Procedure
The Finance Department will screen all active vendors and contractors, either as an individual or businesses, to ensure that they have not been excluded from participation in Medicare, Medicaid or other federal health care program on a monthly basis. The steps to accomplish this task for active contractors and vendors are as follows:
A. All contractors and vendors, individuals and businesses, used by the facility will have their demographic information established and maintained through the Finance Department accounting system.
B. The assigned Finance Department staff will maintain a database of all active contractors and vendors which will be uploaded into “Verify Comply” search software.
C. The Verify Comply search is run each month by the assigned Finance Department staff and results are emailed to the Compliance and Outcomes Coordinator to confirm completion and results of each monthly run are retained for evidence purposes.
D. Should a vendor or contractor be found to have become excluded from participation in Medicare, Medicaid, or other federal health care programs, then the Finance Department staff will immediately provide this information to the Chief Financial Officer. The CFO will ensure that the agency terminates any contract or business agreement with the excluded entity.
REFERENCECODE: ADM - 504 - 006 - GJR
TITLE: Suspension and Debarment – New Board of Director Members Procedure
APPROVEDBY: GJR Administrators
DATEAPPROVED: 8/3/2020
DATEREVISED: 8/3/2020
ADM-504-006-GJR - Suspension and Debarment – New Board of Director Members Procedure
The Chief Executive Officer’s office will establish that all proposed new members of the agency’s Board of Directors have not been excluded from participation in Medicare, Medicaid, or other federal health care programs. The steps to accomplish this task for new directors are as follows:
A. All new proposed members of the agency’s Boards of Directors will have their demographic information maintained through the Chief Executive Officer’s office.
B. The CEO’s Administrative Assistant will maintain an active database of all members of the Boards of Directors which will be uploaded into “Verify Comply” search software.
C. The Verify Comply search is run for proposed new board members and results are emailed to the Compliance and Outcomes Coordinator to confirm completion and results of each monthly run for evidence purposes.
D. Should a proposed new board member be found to be excluded from participation in Medicare, Medicaid, or other federal health care programs, then the Administrative Assistant will immediately provide this information to the Chief Executive Officer. The CEO will ensure that the Chairperson of the specific board and the Governance Committee is informed in order that an excluded entity is not permitted to become a member of the Boards of Directors.
REFERENCECODE: ADM - 504 - 007 - GJR
TITLE: Suspension and Debarment – Routine Board of Director Members Procedure
APPROVEDBY: GJR Administrators
DATEAPPROVED: 8/3/2020
DATEREVISED: 8/3/2020
ADM-504-007-GJR - Suspension and Debarment – Routine Board of Director Members Procedure
The Chief Executive Officer’s office will screen all members of the agency’s GJR Board of Directors monthly to ensure that no member has been excluded from participation in Medicare, Medicaid, or other federal health care programs. The steps to accomplish this task for new employees are as follows:
A. All members of the agency’s GJR Board of Directors will have their demographic information maintained through the Chief Executive Officer’s office.
B. The CEO’s Administrative Assistant will retain an active database of all members of the Boards of Directors which will be uploaded into “Verify Comply” search software.
C. The Verify Comply search is run for proposed new board members each month on a predetermined date by the Administrative Assistant and results are emailed to the Compliance and Outcomes Coordinator to confirm completion of each monthly run for evidence purposes.
D. Should a current board member be found to have become excluded from participation in Medicare, Medicaid, or other federal health care programs, then the Administrative Assistant will immediately provide this information to the Chief Executive Officer. The CEO will ensure that the Chairperson of the agency’s board and the Governance Committee is informed in order that an excluded entity in not permitted to continue serving as a member of the Boards of Directors.
REFERENCECODE: ADM - 505 - GJR
TITLE: Whistleblower Policy
APPROVEDBY: GJR Board of Directors
DATEAPPROVED: 8/3/2020
DATEREVISED: 9/29/2021
ADM-505-GJR - Whistleblower Policy
It is the policy of GJR and Affiliates that there will be no retaliation, including but not limited to termination, compensation decreases, poor work assignments, or threats of any kind, towards an employee who whistle blows
REFERENCECODE: ADM - 505 - 001 - GJR
TITLE: Whistleblower Procedure
APPROVEDBY: GJR Administrators
DATEAPPROVED: 8/3/2020
DATEREVISED: 8/3/2020
ADM-505-001-GJR - Whistleblower Procedure
A. Purpose
The agency is committed to lawful and ethical behavior in all of its activities. As such, the agency requires its officers and employees to observe high standards of business and personal ethics, and act with honesty and integrity when conducting their duties and responsibilities on behalf of the agency. The agency requires that directors, employees, interns, and volunteers comply with all applicable laws and regulations, as well as policies of the agency. “Wrongful conduct,” as defined in this procedure, of any kind is prohibited.
B. Wrongful conduct and the Reporting Responsibility of Employees
It is the responsibility of all directors, employees, contractors, interns, and volunteers of the agency to report wrongful conduct in accordance with this procedure. “Wrongful conduct” is any activity undertaken by a director, employee, contractor, intern, or volunteer in performance of his or her official duties that violates a federal, state, or local law or regulation, or a material policy of the agency. An activity may constitute wrongful conduct regardless of whether or not such activity is within the scope of the employee’s official duties on behalf of the agency. Examples of wrongful conduct may include, but are not limited to, corruption, bribery, theft, fraud, forgery, coercion, harassment, discrimination, violence, or misuse of the agency’s property or facilities.
C. Reporting Violations
If a director, employee, intern, contractor, or volunteer either knows or has a good faith belief that wrongful conduct has occurred, a director, employee, contractor, intern, or volunteer must report the wrongful conduct in a timely fashion. The director, employee, contractor, intern, or volunteer should report the wrongful conduct to his or her supervisor. If, however, a director, employee, contractor, intern, or volunteer prefers not to report the wrongful conduct to his or her supervisor or is unsatisfied with his or her supervisor’s response to the report of wrongful conduct, the director, employee, contractor, intern, or volunteer should report the wrongful conduct to the Compliance Officer, the Chief Executive Officer of the agency, or the Chairperson of the Board of Directors Governance Committee. Reports of wrongful conduct may be made in a way that identifies the reporter or made anonymously, at the discretion of the reporting director, employee, contractor, intern, or volunteer. The agency will maintain the confidentiality of reports of wrongful conduct to the extent feasible in light of the need to thoroughly investigate all reports and take appropriate corrective action.
D. Handling of Reported Wrongful Conduct
Once wrongful conduct has been reported, the supervisor to whom the report has been made must refer the report of wrongful conduct to the Compliance Officer or Chief Executive Officer of the agency, or the Chairman of the Governance Committee. Allegations of wrongful conduct will be taken seriously and investigated promptly. Upon receipt of a report of wrongful conduct, the Compliance Officer will conduct a full and fair investigation into the alleged wrongful conduct in compliance with the provisions of this procedure. Unless the allegations involve the Chief Executive Office, the Compliance Officer will notify the Chief Executive Officer of all investigations undertaken by the Compliance Officer and any resulting recommendations and actions. If, however, the report of wrongful conduct involves the Compliance Officer, the Compliance Officer will not participate in any way in the investigation of the wrongful conduct. Rather, the Chief Executive Officer or designee will conduct a full and fair investigation into the alleged wrongful conduct. Appropriate corrective action, up to and including termination, will be taken if warranted by the investigation.
E. Retaliation Prohibited
This procedure is intended to encourage directors, employees, contractor, interns, and volunteers to raise serious good faith concerns regarding illegal or unethical behavior so that appropriate action may be taken. As such, no director, employee, contractor, intern, or volunteer who in good faith reports wrongful conduct in compliance with this procedure will suffer adverse employment consequences, harassment, discrimination, or be otherwise retaliated against for reporting such wrongful conduct. Moreover, any individual who retaliates against a director, employee, contractor, intern, or volunteer who reports wrongful conduct in compliance with this procedure will be subject to disciplinary action, up to and including termination. Any director, employee, contractor, intern, or volunteer who is retaliated against for reporting wrongful conduct should report the act of retaliation in accordance with the terms of this procedure.
Under this procedure, directors, employees, contractors, interns, or volunteers are also protected from retaliation or adverse employment consequences for participating in an investigation by a regulatory authority, law enforcement agency, member or committee of Congress, or any person with supervisory authority over the director, employee, contractor, intern, or volunteer or who has authority to investigate wrongful conduct. Participating in an investigation includes, without limitation, filing a complaint, testifying, providing information or otherwise assisting in a proceeding or investigation related to the wrongful conduct. Any individual who retaliates against a director, employee, contractor, intern, or volunteer for participating in an investigation of wrongful conduct will be subject to disciplinary action, up to and including termination.
F. Acting in Good Faith
Any director, employee, contractor, intern, or volunteer who reports wrongful conduct or suspected wrongful conduct in accordance with this procedure should do so in good faith. Directors, employees, interns, or volunteers will not report acts of alleged wrongful conduct with the knowledge that the allegations are false. If a director, employee, contractor, intern, or volunteer
report alleged wrongful conduct with the knowledge that the allegation is false; then the agency will take appropriate disciplinary action.
REFERENCECODE: ADM - 506 - GJR
TITLE: Supplier Diversity Plan Policy
APPROVEDBY: GJR Board of Directors
DATEAPPROVED: 9/29/2021
DATEREVISED: 9/29/2021
ADM-506-GJR - Supplier Diversity Plan Policy
It is the policy of GJR and Affiliates to establish and adhere to a Supplier Diversity Plan that ensures minority, women, and disabled owned businesses have the unimpeded ability to compete in a fair and impartial procurement process
REFERENCECODE: ADM - 506 - 001 - GJR
TITLE: Supplier Diversity Plan Procedure
APPROVEDBY: GJR Administrators
DATEAPPROVED: 9/29/2021
DATEREVISED: 12/7/2023
ADM-506-001-GJR – Supplier Diversity Plan Procedure
SUPPLIER DIVERSITY PLAN
George Junior Republic in Pennsylvania recognizes that an open and competitive atmosphere is beneficial to all parties involved and it is our policy to foster this environment. George Junior Republic in Pennsylvania does not discriminate on any basis.
Accordingly, George Junior Republic in Pennsylvania will make good-faith efforts to utilize minority, women and disabled owned businesses throughout the procurement process. All efforts to contact and engage minorities, women, and disabled owned suppliers will be fair and impartial. No preference will be given to any business group or classification. The Supplier Diversity Program was created to ensure that minority, women, and disabled owned businesses have the unimpeded ability to compete in the procurement process and to do business with George Junior Republic in Pennsylvania.
George Junior Republic, located in Grove City, Pennsylvania, is virtually located at the crossroads of Interstate 80 and Interstate 79 in northwest Pennsylvania. The campus is approximately 60 miles north of Pittsburgh and 60 miles south of Erie. The demographic population of the Grove City Area School District is less than 3% minority population. According to the Grove City Area Chamber of Commerce, minority owned businesses relevant to George Junior Republic are less than 10%. Historically, our organization attempts to purchase and contract with as many providers in our immediate area as possible. However, due to our unique needs, we rely on vendors and suppliers well outside Grove City, Pennsylvania. Types of minority/women/disabled vendors and contracts are as follows:
• Legal services
• Physician services
• Psychiatric services
• Computer and program services
• Retail services
• Janitorial services
• Employment services
• Construction
1. Actively seek diverse suppliers through organizations that support these business categories and the use of solicitation lists.
2. Provide educational assistance to suppliers on the methods of doing business with George Junior Republic in Pennsylvania.
3. For purchase orders issued below the bidding threshold, the utilization of a diverse supplier base will be an objective facilitated by the purchasing staff.
A reporting of transactions will be performed to monitor the success of our efforts to partner with a diverse base of suppliers.
OWNERSHIP/CONTACT INFORMATION
Nathan M. Gressel
Chief Executive Officer
George Junior Republic in Pennsylvania
233 George Junior Road PO Box 1058
Grove City, PA 16127
724-458-9330 x2204
ORGANIZATIONAL STRUCTURE
Nathan M. Gressel
Chief Executive Officer
George Junior Republic in Pennsylvania
233 George Junior Road
Jarrod Gault
Procurement Director
George Junior Republic in Pennsylvania
233 George Junior Road PO Box 1058 PO Box 1058
Grove City, PA 16127
724-458-9330 x2204
Gerald Savo
Chief Financial Officer
George Junior Republic in Pennsylvania
233 George Junior Road PO Box 1058
Grove City, PA 16127
724-458-9330 x2202
Grove City, PA 16127
724-458-9330 x2321
PROCUREMENT PROCESS
Procurement process includes Request for Proposals, competitive bidding, networking activities, and some unsolicited proposals.
OEO REGISTER
George Junior Republic in Pennsylvania frequents the Pennsylvania Department of General Services database to recruit certified minority, women, and disabled-owned businesses and the process is documented.
MONITORING
The for-profit spend is tracked each month, compared to approved budget, then year-to-date. Participation is reported monthly to the Chief Financial Officer and documented in the Finance Department.
TRAINING
Diversity training is held two times per year at George Junior Republic in Pennsylvania. This training is required attendance by all staff.
SOCIAL MEDIA USAGE
George Junior Republic in Pennsylvania does not use its website or social media for procurement.
GEOGRAPHIC AREA(s)
Grove City, Pennsylvania, is the geographic area where services are most concentrated.