Policies + Legal

Terms of Use
The Boston Foundation offers the contents of this website as a service to Greater Boston.  The views expressed in the forums, reports, findings, presentations and other materials are supplied by a wide range of individuals, agencies and organizations, and are provided through this website to contribute to an informed civic discourse.  The Boston Foundation makes no warranties or representations regarding such content, and hereby disclaims any liability, on any theory, resulting from any use thereof.

Please note that use of the related DonorFirst or Planned Giving Design Center is governed by the terms and conditions of those websites.

The Boston Foundation (“TBF”) - PRIVACY POLICY

Introduction
This Privacy Policy establishes guidelines for the collection, use, and confidential treatment of our donors’ personal information that we obtain from non-public sources, including www.tbf.org (“TBF Site” or “Site”).When you provide us with your personal information, you agree to the terms of the TBF Privacy Policy in effect at that time.

Third-Party Links
The Site may contain links to third-party sites on the Internet (“Third Party Sites”).  Your use of all third-party sites are at your own risk it is your sole responsibility to evaluate the content and usefulness of the information obtained from third-party sites.  We are not responsible for the privacy practices or the content of such websites.  If you are concerned about the privacy policy of a certain third party, you may contact them directly or visit their individual web site to learn more about their individual privacy policies.

How We Collect and Use Your Personal Information
TBF respects and values the trust you place in us when you give us your personal information and is committed to maintaining the confidentiality of our donors’ personal information.

We collect personal information about you from the following two (2) sources:

Information you give us on Fund Agreements or other forms (such as your name, address, assets, and income); and
Information about your grant transactions with us (such as your fund balance, grant history, and parties to transactions).
TBF restricts access to personal information to those employees who need to know that personal information to provide our services to you.

Information Collected by Third-Parties on the TBF Site
In order to enable visitors to TBF’s Site to make donations to TBF and the non-profit organizations that it supports we have arranged for a vendor named Kimbia, Inc. (“Kimbia”) to host a widget through which visitors can make donations and access details about those donations (the “Donate Now Widget”). When you make a donation through the Donate Now Widget, you may be asked to provide certain contact information (such as your name, address, telephone number and e-mail address) and billing information (such as your credit card number and expiration date) in order to enable your donation to be processed and a confirmation to be provided to you. TBF will not have access to the complete credit card information that you submit via the Donate Now Widget (although it may retain the last four digits of your credit card number in order to process any refunds); and Kimbia will be entitled to use such information solely for the purpose of processing the transaction and permitting you to access your transaction details. Kimbia’s privacy and security policies are available via the Donate Now Widget and will provide you information about the steps that Kimbia takes to protect your information from unauthorized access, disclosure or use. We encourage you to read Kimbia’s privacy and security policies so that you understand how Kimbia will use, protect and disseminate the information you submit through the Donate Now Widget.

In certain cases, TBF may allow third-party ad-serving companies or ad networks to display advertisements on the Site. Some of these ad networks may place a persistent cookie on the TBF Site or a third party site through which they serve ads in order to recognize your computer each time they send you an online advertisement regardless of the site on which the ad is displayed. Thus, third party ad-serving companies or ad networks may compile information about where you are using your computer, where you saw their advertisements, and which ads you clicked on. This information allows the third party to deliver targeted advertisements that it believes will be of interest to you. TBF does not have access to the cookies that may be placed by the third-party ad-serving companies or ad networks. We will not share information that will specifically identify you to a third-party ad-serving company or ad network unless we receive your prior, affirmative consent.

TBF Site Usage Information
Information (e.g., log files, cookies, Internet tags, web beacons, etc.) we collect from you through your use of the Site will be used to (a) monitor the operation, technical functions and quality of the Site, (b) compile general statistics regarding use of the Site, and (c) analyze demographic information about the Site’s users. We may also use such information for research or improvements of the Site and the services we offer you. This data is also used by TBF to deliver customized content to you when your use indicates that you are interested in a particular subject area.

Sharing Your Personal Information
We do not disclose any personal information about our donors, or former donors, to anyone except as permitted or required by law.

Security of Information
TBF is committed to protecting the security of your personal information transmitted to and from this website and will take reasonable security precautions to help protect your personal information from unauthorized access, use, or disclosure. However, we cannot guarantee the security of our database, nor can we guarantee that information you supply won't be intercepted while being transmitted to us over the Internet. With respect to financial information that you transmit via the Donate Now Widget, please review the privacy and data security policies of Kimbia, the vendor that will be transmitting your donation information to the entity responsible for processing and settling those transactions.

Contact Information
If you have any questions, comments, or concerns about TBF’s Privacy Policy and TBF’s privacy and security practices, you can contact TBF via:

Phone:   617-338-1700

Mailing Address:
The Boston Foundation
75 Arlington Street, 3rd Floor
Boston, MA 02116

Changes to TBF’s Privacy Policy
Because we will continue to implement new technologies and improve the features and services we provide, the TBF Privacy Policy is subject to change.  For that reason, we encourage you to periodically review the TBF Privacy Policy.

Last Updated: 4/1/2012

WHISTLEBLOWER POLICY

CODE OF BUSINESS CONDUCT AND ETHICS

Amended December 14, 2011

I. Introduction

The Boston Foundation, Inc. strives to conduct its business in an ethical manner and in compliance with applicable laws, rules and regulations.

This Code of Business Conduct and Ethics (the “Code”) governs the business decisions made and actions taken by the Foundation’s directors, officers and employees.

The integrity, reputation and viability of the Foundation ultimately depend upon the individual actions of the Foundation’s employees, officers and directors. As a result, each such individual is personally responsible and accountable for compliance with this Code. All references in the Code to “employees” should be understood to include all employees, officers and directors of the Foundation, unless the context requires otherwise.

The standards of conduct in this Code provide general guidance for resolving a variety of legal and ethical questions for employees, officers and directors. However, while the specific provisions of this Code attempt to describe certain foreseeable circumstances and to state the employee’s, officer’s and director’s obligations in such event, it is impossible to anticipate all possibilities. Therefore, in addition to compliance with the Code and applicable laws, rules and regulations, all Foundation employees, officers, and directors are expected to observe the highest standards of business and personal ethics in the discharge of their assigned duties and responsibilities.

Finally, this Code is in addition to all other Foundation policies and/or agreements and is not intended to reduce or limit other obligations that you may have to the Foundation. In particular, policies that support this Code and relate specifically to matters described herein include, but are not limited to, the following:

 Conflict of Interest Policy and Duality of Interest Policies
 Confidentiality Policy
 Grantmaking Guidelines and Procedures
 Policy on Employee Expense Reports
 Problem Resolution Policy
 Information Technology (IT) Policy

II. Administration of Code

The Board of Directors, through its Audit Committee, shall be responsible for the content of the Code and for periodically reviewing the Code. The Audit Committee shall be responsible for proposing any changes to the Code that are deemed necessary or appropriate. The Code will be administered by the Foundation’s management, specifically the Chief Financial Officer (“CFO”) who will perform various ongoing administrative functions in connection with the Code, including responding to questions about the Code and circulating or otherwise communicating updates to the Code.

A copy of the Code shall be supplied to all employees, officers and directors upon commencement of their association with the Foundation. Updates will be provided upon any change to the Code. A copy of the Code is also available to all employees, officers and directors by requesting one from the Human Resources department. The Code will be included in all new employee handbooks and new director orientations.

The Foundation’s management shall take reasonable steps to insure compliance with the Code. This includes any systems that might be used to investigate and detect conduct in violation of the Code and, when appropriate, to impose and enforce appropriate disciplinary measures for violations of the Code. The disciplinary measures may include, but are not limited to, counseling, oral or written reprimands, warnings, probation or suspension with or without pay, demotions, reductions in salary, termination of employment or service to the Foundation, and restitution.

The Foundation’s CFO shall report at least annually to the Audit Committee on these compliance efforts including, without limitation, reporting of alleged violations of the Code and the actions taken with respect to any such violation. The Audit Committee shall in turn report to the Board regarding the Foundation’s compliance efforts.

III. Reporting Concerns/Receiving Advice

Every employee is required to act proactively by asking questions, seeking guidance and reporting suspected violations with respect to compliance with the Code, other policies and procedures of the Foundation, or any applicable government law, rule or regulation. If any employee believes that actions have taken place, may be taking place, or may be about to take place that violate or would violate the Code, he or she is obligated to bring the matter to the attention of the Foundation, as follows:

 The best starting point for an employee seeking advice on ethics-related issues or reporting potential violations is the CFO.
 In the case of accounting, internal accounting controls or auditing matters, any concerns or questions about violations with respect to such matters should be directed to the Chairman of the Audit Committee.
Employees must not use this compliance program in bad faith, or in a false or frivolous manner. Employees should only use this policy to report matters involving the Code, accounting or financial concerns or other ethics-related issues.
Grievances regarding employee policies, harassment, conflicts with others are to be handled through their supervisor or Director of Human Resources.
When reporting conduct suspected of violating the Code, the Foundation prefers that reporting persons identify themselves in order to facilitate the Foundation’s ability to take appropriate steps to address the report, including conducting any appropriate investigation. As noted later herein, the Foundation’s policy specifically prohibits retaliation against any such employee who acts in good faith to bring such matters to its attention.
Any person, including vendors, volunteers and others not employed by the Foundation who wish to make a report, may communicate with the CFO or the Chairman of the Audit Committee by any one of the following methods:
In person or in writing (which may be done anonymously)

If addressed to the CFO, either by facsimile to (617) 338-1604 or by U.S. Mail to:

Chief Financial Officer
The Boston Foundation, Inc.
75 Arlington Street
Boston, MA 02116
(617) 338-1700 (phone)
(marked Personal and Confidential)

If addressed to the Chairman of the Audit Committee, by U.S. Mail to:

Scott Squillace
Chair, Audit Committee
Squillace & Associates, P.C.
200 Park Plaza, Suite 115
Boston, MA 02116
(marked Personal and Confidential)

Both the CFO and the Chairman of the Audit Committee are authorized to carry out an investigation of any reports and may engage third parties to assist in any such investigations. The final report of any such investigation shall be provided to the Audit Committee and Board.
If the person making a report wishes to remain anonymous, he or she may do so, and the Foundation will use reasonable efforts to protect the confidentiality of the reporting person subject to applicable law, rule or regulation or to any applicable legal proceedings. In the event the report is made anonymously, however, the Foundation may not have sufficient information to look into or otherwise investigate or evaluate the allegations. Accordingly, persons who make reports anonymously should endeavor to provide as much detail as is reasonably necessary to permit the Foundation to evaluate the matter(s) set forth in the anonymous report and, if appropriate, to commence and conduct an appropriate investigation.
The Foundation expressly forbids any retaliation (including, without limitation, removal, discharge, demotion, suspension or any other threats, harassment or discrimination) against any person who, acting in good faith, reports suspected misconduct. Any person who participates in any such retaliation against a reporting person shall be subject to disciplinary action, including the possibility of termination.

EQUITY AND DIVERSITY POLICY STATEMENT

The Boston Foundation actively seeks to promote access, equity and diversity in our community, and to end discrimination based on race, color, religion, national origin, gender, age, sexual orientation, gender identity, citizenship, veteran’s status, or disability. We have a strong conviction that diversity benefits everyone, and is not only compatible with excellence, but actually promotes it.

We pursue this policy in a variety of ways.  First, a number of grants we make are specifically designed to promote diversity and increase access to services for historically disadvantaged groups.  Second, we strive for broad representation on our own Board and staff, recognizing that without such diversity, our ability to achieve excellence in our grantmaking would be seriously constrained.  Finally, we encourage diversity in the boards, staff and service populations of the organization receiving grants.

This policy reflects our commitment to equal access and opportunity, and our belief that performance is greatly enhanced when people with different backgrounds and perspectives are engaged in an organization's activities and decisions making process.  Organizations with diverse staffs and boards are in a stronger position to recruit from a varied talent pool, bring a wider range of viewpoints to decision making, and gain optimal public support for their activities.

In this spirit, those applying for grants are asked to provide specific information in the categories referenced above of their board, staff and service population.  As a result of this information gathering process, we are in a better position to evaluate and aid efforts to achieve diversity and equal opportunity   efforts which require vigorous and sustained attention at all levels of community life.