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InterAction's Private Voluntary Organization (PVO)
Standards
InterAction
Mission Statement Statement
of Commitment
Preface InterAction
PVO Standards Guidelines
Interpretive
Guidance Commonly
Asked Questions
Background
1.0 Preamble | 2.0
Governance | 3.0 Organizational
Integrity | 4.0 Finances
5.0 Communications to the
US Public
6.0 Management
Practice and Human Resources | 7.0
Program | 8.0 Public Policy
9.0 Implementation | 10.0 Guidelines
The PVO Standards Committee works with member organizations
in promoting standards for PVOs in the areas of governance, finance, communications
with the U.S. public, management practice, human resources, program and
public policy. Compliance with the PVO Standards is a requirement for
admission to InterAction. The Committee works within the InterAction network
and disseminates our standard setting experience to other coalitions and
audiences around the world. The Nominating Committee recommends to the
Executive Committee candidates for membership on the PVO Standards Committee.
InterAction Mission Statement
InterAction, a membership association of US private voluntary organizations,
exists to enhance the effectiveness and professional capacities of its
members engaged in international humanitarian efforts.
Further, InterAction exists to foster partnership, collaboration, leadership
and the power of this community to speak as one voice as we strive to
achieve a world of self-reliance, justice and peace.
To realize this mission, InterAction works to:
- Enhance the identity, autonomy, credibility and diverse perspectives
of each member agency;
- Provide a broadly-based, participatory forum for professional consultation,
coordination and concerted action;
- Foster the effectiveness and recognition of our community both professionally
and publicly;
- Set a standard of the highest ethics in carrying out our mission.
InterAction Statement
of Commitment
We are committed to:
- Advocating and fostering human dignity and development;
- Striving for world justice through programs of economic and social
development, relief and reconstruction;
- Ameliorating the plight of refugees and migrants through relief, protection,
settlement in place, voluntary repatriation, or resettlement to a third
country;
- Helping people help themselves;
- Building public awareness and understanding as a necessary prerequisite
for humanitarian assistance;
- Initiating a dialogue on public policy issues of importance to the
membership;
- Being accountable to our individual constituencies, the American public,
and the people we strive to assist;
- Respecting the diversity of perspectives and methods of operation
of member agencies as a source of strength and creativity;
- Working in a spirit of collaboration and partnership as the most effective
way to achieve common objectives;
- Encouraging professional competence, ethical practices and quality
of service.
For information on how your organization can become a member of InterAction,
contact InterAction’s Co-Managers of Member Services at (202) 667-8227.
Preface
Under a 1992 agreement worked among members, all existing and prospective
InterAction member organizations have had to certify compliance with the
newly adopted PVO Standards as of January 1994. At the end of every calendar
year, each InterAction member is asked to review the Standards and re-certify
compliance.
Intended to ensure and strengthen public confidence in the integrity,
quality and effectiveness of member organizations and their programs,
the standards were created when the overseas work of PVOs was dramatically
increasing in scope and significance. Defining the financial, operational
and ethical code of conduct for InterAction and its member agencies, these
high and objective standards, self-applied, set InterAction members apart
from many other charitable organizations. Indeed, in various aspects,
the InterAction PVO Standards exceed the prevailing standards of the Better
Business Bureau and the National Charities Information Bureau.
Gender and diversity amendments to the standards, which became effective
in January 1998, grew from the realization that organizations need to
diversify their boards and staff in order to become more effective and
credible, as they implement programs serving a widely diverse population
overseas. In 2000, additional amendments for people with disabilities
were included. In 2000, additional amendments for people with disabilities
were included.
Some history: The Standards were born at a meeting of InterAction’s
Executive Committee in March of 1989. Kenneth Phillips, then president
of Childreach, urged InterAction to develop a set of ethical standards
covering governance, financial reporting, fundraising, public relations,
management practice, human resources, public policy and program services.
The effort was initiated in recognition of both the growing size and consequence
of the programs of InterAction members and the significance of the members
publicly committing themselves, as a community, to a reliable means to
ensure the public’s trust.
Between 1990 and 1992, a PVO Standards Committee representing a cross-section
of InterAction agencies met frequently and circulated several drafts of
each section to the full membership. The Standards were unanimously approved
at the November 5, 1992 InterAction board meeting. Self-certification
began in 1993 and requires the CEO and/or Board Chairperson of each InterAction
member certify that his/her agency is in compliance with the agreed-on
standards, or where it is not in compliance, to indicate what steps they
have committed to take to attain compliance. The self-certification process
continues to involve active dialogue between the elected Standards Committee
and the members. An interpretive guidance is included at the back of this
document, and InterAction maintains a resource center of relevant materials
for use by the members.
InterAction is especially indebted to Ken Phillips, who served as InterAction’s
elected Chairman of the Board and of the Executive Committee from November
1990 through November 1992, for his vision and for the skillful way in
which he guided the open process to assure full involvement of InterAction’s
membership.
We wish also to commend the consultant to the Standards Committee, Barkley
Calkins, for his diligence in directing the entire process, which continues
today as the Standards evolve. His ability to work with the members, to
develop early drafts and to explain the intended process is very helpful
in this important yet delicate area.
InterAction proudly heralds these Standards to the larger PVO community,
to the media, to the donors and to the international community itself.
We are indebted to the Rockefeller Brothers Fund, most notably to its
program officer William Moody, for its financial support and leadership
in fostering this important process.
Finally, I am pleased to report that InterAction's PVO Standards have
directly and significantly influenced the standards-setting processes
of comparable groups in Canada, Japan, Asia, Eastern Europe and Central
Europe. Thus, in addition to reinforcing public confidence in our own
members, we are pleased to note InterAction’s leadership in facilitating
the increasing adoption of open and transparent financial, operational
and ethical standards among NGOs in numerous other countries.
Mary E. McClymont
President & CEO
June 2001
InterAction PVO Standards
1.0 Preamble
1.1 InterAction, a membership association of US private voluntary organizations,
exists to enhance the effectiveness and professional capacities of its
members engaged in international humanitarian efforts.
1.2 InterAction follows the highest ethical standards in carrying out
its mission. We are committed to encouraging professional competence,
ethical practices, and quality services.
1.3 Each member organization shall adhere to those unique principles
of governance, volunteer involvement, support from the private sector,
fundraising, service, and programs which enable it to be accurately described
as a private and voluntary organization.
2.0 Governance
2.1 A member organization shall be governed fairly, impartially, and
responsibly by an independent Board of Directors and its duly constituted
Executive Committee.
2.2 Each organization shall have an independent, active, and informed
Board of Directors, serving without compensation as directors. The Board
shall have policies which specify the frequency of Board meetings (at
least two per year) and adequate attendance by directors (at least a majority
on average). The Board may designate an Executive Committee to act in
its place as long as the Executive Committee has policy-making authority.
The Board shall have policies restricting the number of employees who
are voting members of the Board; providing limits for directors being
related to one another, the Founder, or the Executive Director; and establishing
limited terms of service for directors and officers.
2.3 The Board shall adopt a policy which prohibits direct and indirect
conflicts of interest by members of the Board, employees, and volunteers.
Board members, employees and volunteers shall make known to the Board
any affiliation they might have with an actual or potential supplier of
goods and services, recipient of grant funds, or organization with competing
or conflicting objectives. Board members and employees shall absent themselves
from discussion and abstain from voting or otherwise participating in
the decision on any issue in which there is a conflict of interest. Large
or otherwise inappropriate gifts to Board members or staff for personal
use shall be forbidden.
2.4 Though the Board may delegate to staff, it must accept ultimate responsibility
for governance over all aspects of the organization.
2.5 The Board shall approve the annual budget, appoint an independent
auditor, receive the annual, audited financial statements, and appoint
an Audit Committee to review the financial statements and activities of
the organization.
2.6 The Board shall adopt a policy requiring that no person shall be
excluded from participation in the organization, be denied the benefits
of the organization, or be otherwise subjected to discrimination by the
organization, on the basis of race, color, national origin, age, religion,
handicap, or sex. (The preceding sentence notwithstanding, pursuant to
Section 702 of the Civil Rights Act of 1984, religious organizations may
discriminate in their employment practices with regard to religion only.)
2.6.1 Each agency will develop a written policy that affirms its commitment
to gender equity in organizational structures and in staff and board composition.
The policy should be fully integrated into an organization’s plans
and operations.
2.6.2 Each agency will develop a written policy that affirms its commitment
to ethnic and racial diversity in organizational structures, in staff
and board composition. The policy should be fully integrated into an organization’s
operations, in a manner consistent with its mission and the constituency
it serves.
2.6.3 Each agency will develop a written policy that affirms its commitment
to the inclusion of people with disabilities in organizational structures
and in staff and board composition. The policy should be fully integrated
into an organization’s plans and operations, in a manner consistent
with its mission and the constituency it serves.
2.7 All activities shall be conducted within applicable laws.
3.0 Organizational Integrity
3.1 The affairs of the member organization shall be conducted with integrity
and truthfulness. The organization's activities shall be open and accessible
to scrutiny by its donors, except for personnel matters and proprietary
information.
3.2 Each organization shall have a written standard of conduct for its
directors, employees and volunteers, which they shall commit to follow.
3.3 The organization shall endeavor to assure confidentiality to employees
desiring it who present evidence of misconduct or other irregularities
on the part of anyone associated with the organization.
3.4 The organization shall oppose and shall not be a willing party to
wrongdoing, corruption, bribery, other financial impropriety, or illegal
acts in any of its activities. It shall take prompt and firm corrective
action whenever and wherever wrongdoing of any kind is found among its
Board, employees, contractors, and volunteers. Ethics standards shall
be maintained despite possible prevailing contrary practices elsewhere.
3.5 In all of its activities, a member shall respect the dignity, values,
history, religion, and culture of all of its constituents.
3.6 A member shall recognize that all of its activities impact on the
public perception of the PVO community, and that it shares a significant
responsibility to enhance the public trust.
4.0 Finances
4.1 The finances of a member organization shall be conducted in such
a way as to assure appropriate use of funds and accountability to donors.
4.2 The organization shall have an annual audited financial statement,
conducted by an independent Certified Public Accountant. The audited financial
statement shall comply with Generally Accepte`d Accounting Standards and
Requirements according to the AICPA and the FASB. The auditors shall present
a "management letter" to the Board of Directors. (Organizations
with less than $100,000 annual income need not have an independent auditor.)
4. 3 The organization shall complete and file Form 990 annually to the
US Government. (Religious organizations are exempt by law from this provision.)
4.4 The audited financial statement (and the Form 990, if applicable)
shall be provided to any inquirer upon reasonable written request.
4.5 An Annual Report including a statement of the organization's purpose,
full or summary financial statement, description of the goals, summary
of overall program activities, results of the work of the organization,
and information about current Board members shall be provided upon written
or verbal request.
4.6 The organization's combined fundraising and administration costs
shall be kept to the minimum necessary to meet the agency's needs. Allocations
of expenditures to administration, fundraising, and program services shall
reflect the organization's purposes, actual activities, and generally
accepted accounting principles.
4.7 The organization shall operate a budget approved by the Board. It
shall account for funds from the moment they are received until they are
used in the project or services. It shall exercise adequate internal controls
over disbursements to avoid unauthorized payments. The organization shall
not have secret funds and it shall prohibit and unaudited transactions
or loans to Board members and to staff.
4.8 Contributions shall be used as promised or implied in the fundraising
appeal or as requested by the donor. If funds cannot be spent this way,
they shall be returned to the donor, or the donor shall be advised of
the planned alternative use and given the opportunity to request a return
of the contribution. Organizations shall substantiate, upon request, that
their application of funds is in accordance with donor intent or request.
Resources shall not be used as instruments of partisan influence or personal
gain.
4.9 International currency exchange shall comply with applicable laws,
have appropriate Government approvals, and be clearly recorded.
5.0 Communications
to the US Public
5.1 The member organization shall be committed to full, honest, and accurate
disclosure of relevant information concerning its goals, programs, finances,
and governance.
5.2 Fundraising solicitations shall be truthful, shall accurately describe
the organization's identity, purpose, programs, and need, shall only make
claims which the organization can fulfill, and shall avoid placing excessive
pressure on donors. There shall be no material omissions or exaggerations
of fact, no use of misleading photographs, nor any other communication
which would tend to create a false impression or misunderstanding. Information
in the organization's appeals should give accurate balance to the actual
programs for which the funds solicited will be used. The organization
shall not undertake negative advertising or criticize other member organizations
to benefit themselves.
5.3 An organization's communications shall respect the dignity, values,
history, religion, and culture of the people served by the programs. They
shall neither minimize nor overstate the human and material needs of those
whom it assists.
5.4 If an organization sells, rents, or exchanges the names of its donors,
it shall notify the donors of its intention to do so, giving them the
option to be eliminated from the list for sale, rent or exchange.
5.5 If the organization engages in fundraising events or cause- related
marketing, the amount of funds going to the charity shall be clearly described
prior to, or in conjunction with, the effort.
5.6 Organizations shall control all fundraising activities conducted
on their behalf. All fundraising contracts and agreements shall be reduced
to writing.
5.7 Staff engaged in fundraising and public relations should meet the
standards of the National Society of Fundraising Executives and Public
Relations Society of America respectively
6.0 Management
Practice and Human Resources
6.1 A member organization shall endeavor to follow best management practices
appropriate to its mission, operations, and governance structure.
6.2 A member organization shall periodically reassess its mission and
operations in light of the changing world environment through an on-going
strategic planning process.
6.3 A member organization shall have clear, well-defined, written policies
and procedures relating to all employees and volunteers, including host
country nationals and expatriates.
6.3.1 Such policies shall clearly define and protect the rights of employees,
assuring fair treatment in all matters.
6.3.2 Employee benefits shall be clearly described and communicated,
and the organization shall make financial arrangements to protect its
ability to honor its obligations to employees.
6.3.3 The organization's expectations of employees shall be clearly defined
and communicated.
6.4 A member organization shall have policies and procedures to promote
gender and minority equity, pluralism, diversity, and affirmative action
in recruitment, hiring, training, professional development, and advancement.
6.4.1 Promoting Gender Equity
6.4.1.1 Gender sensitization will be fully integrated into an organization’s
human resource development program for staff at all levels to improve
organizational effectiveness and to promote non-discriminatory working
relationships and respect for diversity in work and management styles.
6.4.1.2 Agencies will strive to increase the numbers of women in senior
decision-making positions at headquarters and in the field, on Boards
of Directors, and on advisory groups where they are currently underrepresented.
6.4.1.3 An important criterion in hiring and personnel evaluation policies
and practices will be a demonstrated understanding of gender issues and
a commitment to gender equity.
6.4.1.4 Each agency will institute family friendly policies and create
an environment that enables both women and men to balance work and family
life.
6.4.1.5 Agencies will have policies and practices that support equal
pay for equal work.
6.4.1.6 Program and senior staff will be trained in gender analysis for
programs planning, implementation, and evaluation.
6.4.2 Promoting Diversity
6.4.2.1 Diversity sensitization will be fully integrated into an organization’s
human resource development program for staff at all levels in order to
promote non-discriminatory working relationships, respect for diversity
in work and management styles, and an organizational culture which supports
diversity.
6.4.2.2 Agencies will strive to increase ethnic and racial diversity,
where there is under-representation, in senior decision-making positions
at headquarters, in the field, and on Boards of Directors.
6.4.2.3 An important criterion in hiring and personnel evaluation policies
and practices will be a demonstrated understanding of and commitment to
diversity issues.
6.4.2.4 Agencies will have policies and practices that support equal
pay for equal work.
6.4.3 Promoting People With Disabilities
6.4.3.1 Agencies will strive to increase the numbers of people with disabilities,
where there is under-representation, in senior decision-making positions
at headquarters, in the field and on boards of directors.
6.4.3.2 In order to embrace diversity in its organizational culture,
agencies will integrate disability into the diversity sensitization program
within an organization’s human resource development program for staff
at all levels. This will improve organizational effectiveness, promote
non-discriminatory working relationships and create a respect for diversity
in work and management styles.
6.5 A member shall endeavor to recruit and retain staff that combine
professional competence with a commitment to service.
7.0 Program
7.1 General Program Standards
7.1.1 A member's program shall facilitate self-reliance, self-help, popular
participation and sustainable development, so as to avoid dependency.
7.1.2 Participants from all groups affected should, to the maximum extent
possible, be responsible for the design, implementation, and evaluation
of projects and programs.
7.1.3 A member shall give priority to working with or through local and
national institutions and groups, encouraging their creation where they
do not already exist, or strengthening them where they do.
7.1.4 In its program activities, members shall respect and foster human
rights, both socio-economic and civil-political.
7.1.5 A member's programs shall respect the dignity, values, history,
religion, and culture of the people served.
7.1.6 A member's fundamental concern shall be the well-being of those
affected; its programs shall assist those who are at risk without political,
religious, gender, or other discrimination; and a high priority shall
be given to strengthening the capacities of the most vulnerable groups,
typically women, children, minorities, the disabled, and the very poor.
7.1.7 Where possible, programs shall promote the advancement of the status
of women and their empowerment.
7.1.8 In the planning of programs and projects, a member shall consider
the full range of potential impacts upon the host country including: the
potential to strengthen the capacity of local structures and institutions
to absorb constructively financial and other inputs, and where resources
exceed capacity, to create new auxiliary structures such as locally controlled
foundations or funds; the potential for sustaining the program in the
future; the effect upon the demand and markets for locally produced goods
and services; the potential for individual and community empowerment;
and the effects upon the natural environment and ecosystems.
7.1.9 A member shall have defined procedures for evaluating, both qualitatively
and quantitatively, its programs and projects. These procedures shall
address both the efficiency of the use of inputs, and the effectiveness
of the outputs, i.e. the impacts on the program participants, and the
relationship of these impacts to the cost of achieving them.
7.1.10 A member shall be willing to share program knowledge and experience
with program participants, other agencies, donors, and other constituencies.
7.1.11 Members shall adhere to the professional standards in their field
of activity.
7.2 Promoting Gender Equity
7.2.1 Consistent with its mission and the constituency it serves, members
will establish a mechanism which operates with a mandate from the CEO
to promote and monitor the integration of gender equity in programs.
7.2.2 Gender awareness will be integrated into each stage of the program
process, from review of project proposals to implementation and evaluation
to ensure that projects foster participation and benefits for both women
and men. Members will collaborate with local NGO partner organizations
in the field on these efforts.
7.3 Promoting Diversity
7.3.1 Consistent with its mission and the constituency it serves, members
will establish a mechanism which operates with a mandate from the CEO
to promote awareness of diversity in programs, where appropriate.
7.3.2 Where appropriate, awareness of diversity issues will be incorporated
into each stage of the program process, from review of project proposals
to implementation and evaluation to ensure that projects foster participation
and benefits for all affected groups. Members will collaborate with partner
NGO organizations in the field to integrate diversity issues into their
programs.
7.4 Promoting People With Disabilities
7.4.1 Consistent with its mission and the constituency it serves, members
will establish a mechanism which operates with a mandate from the CEO
to promote and monitor the inclusion of people with disabilities in programs.
7.4.2 Disability inclusion strategies will be integrated into each stage
of the program process, from review of project proposals to implementation
and evaluation to ensure that projects foster participation and benefits
for all affected groups, including disabled,men, women and children. Members
will collaborate with local NGO partner organizations in the field on
these efforts.
7.4.3 Member programs and activities should be held in accessible locations
to the maximum extent feasible. Organizations will provide training and
conference materials in alternative formats as applicable (Braille, sign
language interpreters, etc.). Member agencies should plan financially
to reasonably accommodate people with disabilities in member programs
and activities
7.5 Emergency, Civil Conflict and Disaster Response
7.5.1 A member shall use its best efforts to ensure that assistance is
provided on a non-discriminatory basis. To the maximum extent possible,
disaster response should be treated as a humanitarian and non-political
matter.
7.5.2 Agencies engaged in disaster response will be guided and informed
by the Sphere Project’s Humanitarian Charter and Minimum Standards
in Disaster Response.
7.5.3 A member shall affirm that, in responding to disasters for the
benefit of civilian populations, its response will be coordinated with
other local and international humanitarian organizations in order to ensure
prompt action and effective allocation of resources, and to avoid duplication
of effort.
7.6 Material Assistance
7.6.1 Programs involving the provision of emergency and material assistance
shall be carried out, to the maximum extent feasible, in a manner intended
to undergird and enhance local know-how and productive capacity, to avoid
the creation of dependencies, to reduce vulnerability to future disasters,
and to lay the basis for longer term development.
7.6.2 Materials provided shall be appropriate, based on an assessment
of local needs, and sensitive to the local culture and situation. Materials
provided shall be appropriate, based on an assessment of local needs,
and sensitive to the local culture and situation. Any donations of goods
and services will be accessible to disabled men, women and children.
7.6.3 Members involved in the provision of food aid shall be guided and
informed by the Representative Food Aid Standards" promulgated by
Food Aid Management. A member utilizing gifts-in-kind shall be guided
and informed by the "Interagency Gifts-In-Kind Standards Project"
of the Association of Evangelical Relief and Development Organizations
(AERDO).
7.6.4 A member receiving and distributing medical supplies shall be guided
and informed by "The Use of Essential Drugs" containing the
sixth model list of essential drugs promulgated by the World Health Organization.
7.6.5 A member utilizing gifts-in-kind shall have policies that clearly
describe the valuation and auditing methods used, including diminution
of value based on dating and shelf life; establish limits to the number
of times that goods will be passed to other PVOs before being passed on
to an end user; assure that only gifts-in-kind that are related to the
basic mission and purposes of the organization, and that are appropriate
to the local situation, will be received and disbursed; that processing
fees will be assessed in relation to the cost incurred, not to the value
of the goods involved; that gifts-in- kind will be used for the purpose
intended by the donor and will not be diverted for financial gain unrelated
to the purpose for which the gift was made; and that proper documentation
will be maintained on all gift-in-kind transactions.
7.7 Migration and Refugee Assistance
7.7.1 A member involved in migration and refugee affairs shall be guided
and informed by the 1951 UN Convention and l967 Protocol Relating to the
Status of Refugees.
7.7 2 Those agencies active in the US Reception and Placement Program
of Refugee Resettlement shall adhere to the mutually agreed upon Bureau
for Refugee Program Guidelines for Participants.
7.8 Development
7.8.1 Members involved in development assistance shall be guided by the
professional standards developed by recognized authorities related to
their sectoral areas of discipline. Examples could include, but are not
limited to the following: the "Guidelines for Drinking Water Quality"
promulgated by the World Health Organization; "Housing and Health:
An Agenda for Action" promulgated by the World Health Organization;
the "World Declaration on the Survival, Protection and Development
of Children" promulgated by UNICEF; and "Learning for All: Bridging
Domestic and International Education; Conference Report, US Coalition
for Education for All".
7.9 Child Sponsorship
7.9.1 InterAction member agencies (members) involved in child sponsorship
use a variety of child centered approaches to development which foster
mutually beneficial, supportive relationships among peoples from widely
varied cultural and economic backgrounds. Their programs shall facilitate
self-reliance, self-help and popular participation. They shall regularly
update the status of each sponsored child and report significant changes
which impact the child’s participation in the program to the sponsor.
They shall be guided and informed by the principles contained in the United
Nations Convention on the Rights of the Child.
7.9.2 The resources generated through child sponsorship shall be used
and accounted for in a manner consistent with the programs and purposes
described in appeals. Where initial appeals to, or ongoing communications
with, sponsors promise or imply benefits to specific children, members
shall have procedures in place that enable it to document that the sponsored
child benefit from any programs or projects supported with their sponsor’s
funds.
7.9.3 Members engaged in child sponsorship shall adopt policies and practices
to ensure that sponsored children and their families benefit in identifiable
ways from sponsors’ contributions.
7.9.4 Members that pool sponsorship contributions to support child-focused
community development projects shall ensure that children in sponsored
families are among the principal beneficiaries of these projects.
7.9.5 Members that promise or imply benefits to sponsored children in
their marketing materials shall have procedures in place to document that
children in sponsored families receive the advertised benefits.
7.9.6 Members shall never knowingly enroll a child or family already
enrolled by another sponsorship agency; nor shall a member seek more than
one sponsor for a child unless this fact is clearly communicated to sponsors.
7.9.7 Members whose primary focus is other than child sponsorship programs
shall not use sponsorship purely as a fundraising tool, but shall seek
to make their sponsorship programs consistent with the agency’s overall
mission and purposes.
7.9.8 Members shall have clear policies and procedures to respect the
privacy and dignity of sponsored children and their families. Members
shall seek to protect sponsors from inappropriate solicitations from sponsored
families.
7.9.9 Members shall be truthful in marketing and advertising.
7.9.10 Marketing materials shall be accurate and current in their portrayal
of conditions involving families and children depicted in these materials.
Promotional appeals and marketing materials that use visual images to
solicit donations shall accurately reflect the current work of the member.
If historical images are used, the context and year the image was created
shall be clearly identified in the appeal.
7.9.11 Members that pool sponsorship contributions to support child-focused
community development projects shall note this practice in all sponsorship
marketing materials.
7.9.12 Members shall clearly communicate to sponsors their definition
of benefit to sponsored children, and shall periodically communicate the
indicators used to monitor and evaluate these benefits.
7.9.13 Members engaged in child-focused community development projects
shall have clearly defined and publicly stated criteria for establishing
partnerships with communities and for fostering community empowerment
through participation in the planning of programs and projects.
7.9.14 Members shall have the capacity of providing financial and performance
oversight and child monitoring at the local level, whether through a field
office structure or through partnerships with local entities. They shall
have established policies and procedures for ongoing program monitoring
and evaluation.
7.9.15 Members engaged in child sponsorship should develop policies that
support the inclusion of children with disabilities and their families
in child sponsorship programs and child-focused community development
projects.
7.10 Development Education
7.10.1 The focus of development education efforts should be to engage
the US public in the recognition of global interdependence and its long-term
impact upon the well being of all societies, and to develop a constituency
in support of a constructive US role in the world.
7.10.2 A member involved in development education shall be informed and
guided by the "Guidelines for PVOs: An Aid to the Development of
Education, Public Information and Fundraising Materials About Africa"
from "Toward Partnership in Africa", pp. 146-160, with suitable
adaptation to other areas of the world.
7.10.3 A member shall make a clear distinction between its fundraising
and development education efforts, especially in its financial reporting,
adhering to the relevant positions of the American Institute of Certified
Public Accountants (AICPA) regarding the appropriate allocation of the
expenses related to these activities.
8.0 Public Policy
8.1 A member organization shall have a clear policy describing the circumstances
in which it will involve itself in advocacy, public policy and/or lobbying
activities.
8.2 Members adopting advocacy and public policy positions shall have
an organizationally-approved policy that defines the process for adopting
and implementing such positions.
8.3 Advocacy, public policy, and lobbying activities by members shall
be non-partisan (i.e. not associated with a specific political party)
in nature, and shall conform with applicable US non-profit law.
8.4 Activities intended to influence public policy in the US or other
countries shall be undertaken in accordance with the individual member
organization's established policies, and within applicable laws.
8.5 In taking public policy positions, member organizations shall be
informed and guided by public policy positions unanimously adopted by
InterAction.
9.0 Implementation
9.1 Self-certification that an agency meets the high ethical Standards
is required for membership in InterAction. Each applicant organization
accepts responsibility for following these Standards. An organization
which meets the InterAction Standards may refer in its promotional materials
to this fact. InterAction will maintain and make available a current list
of qualifying organizations.
9.2 Annual filing of the latest annual report, an audited financial statement,
and a statement and checklist, by the Chair of the Board of Directors
and/or the Chief Executive Officer of the organization, attesting that
it meets the high ethical Standards of InterAction will be required and
due December 31 of each year.
9.3 A Standards Committee shall be elected by the Board and shall consist
of members of the InterAction Board and recognized outside experts. The
Standards Committee will review and recommend to the Board revisions in
the Standards periodically.
9.4 The Standards Committee will receive and act upon credible complaints
of non-compliance with the standards. Complaints must be in writing and
present credible evidence regarding non-compliance with the standards.
The organization concerned will receive written notice outlining the alleged
violation(s), possible sanctions, and the right to respond. The organization
will have the opportunity to respond to the allegations, and to review
and respond to all charges and evidence to be considered by the Standards
Committee. The organization concerned will also have the right to appear
in person before the Standards Committee or its designee. The complaint
will be kept confidential to the extent possible, consistent with the
obligation to investigate.
If the Standards Committee deems an organization to be not in compliance
with the standards, it shall be given a reasonable time to make a serious
effort to come into compliance. The Standards Committee may recommend
to the executive committee that the membership of organizations which
do not come into compliance with the standards within a reasonable time
be suspended or terminated.
When a member agency substantially fails to maintain the standards for
admission and continuing membership, and fails or refuses to remedy this
situation within a reasonable time, the executive committee may, by majority
vote, suspend or terminate the membership of such member. Any organization
recommended for suspension or expulsion will be entitled to a hearing
before the executive committee prior to suspension or expulsion.
In the event of a negative determination by the executive committee,
the organization may appeal directly to the board of directors.
The Standards Committee will issue a report annually to the members.
9.5 The Standards covered in the Sections 1,2,3,4, and 5 became effective
for membership starting January 1, 1994. Delay in the effective date of
any specific Standard, or its application to a specific agency, may be
made by vote of the Board of Directors.
9.6 The Board of Directors of InterAction may, from time to time, add
to or change this set of Standards, subject to 2/3 approval by the members
in attendance at a regular meeting of the Board of Directors and with
appropriate notice.
9.7 InterAction maintains a Resource Center in its main office which
contains a copy of all of the codes and standards developed by other organizations
or coalitions, which are referred to in the InterAction Standards.
10.0 Guidelines
10.1 Guidelines represent Standards which the Board of Directors may,
from time to time, promulgated as recommended, but not required Standards.
Guidelines
It is recommended that, wherever applicable, a member organization should
meet the standards of the National Charities Information Bureau and the
Philanthropic Advisory Service of the Council of Better Business Bureaus.
It is recommended that a member organization should utilize volunteers
in its program and fundraising efforts to the greatest extent feasible
for its mission and structure. Wherever the organization is composed of,
or relies upon local, national, or international affiliates, the US member
should expect its affiliates to adhere to private voluntary organization
principles within their governance and programs. Each member organization
should seek to derive a substantial portion or amount of its funding from
sources in the private sector, locally, nationally, and internationally.
It is recommended that the Board of Directors should be large enough
and meet frequently enough to provide independent, active, and informed
decisions. It is recommended that the Board have at least ten members
and at least three meetings per year, of which at least one should be
of the full Board and the others of the Executive Committee, if the Executive
Committee has policy-making authority and consists of at least five persons.
It is also recommended that directors not be retained for paid consulting
or any other paid activities. One staff person may serve as a voting member
of the Board of Directors; larger representation of staff on the Board
should be limited to large organizations and large, active Boards. Normally,
individuals who are related to each other or to the Executive Director
or Founder should not serve on the Board of Directors.
It is recommended that diversity in the make-up of the Board and staff
should be a stated policy of the organization.
It is recommended that member organizations actively inform their contributors
about the organization’s use of funds, including the full and complete
exposition of salary and non-salary executive compensation. It is recommended
that all donors receive basic information about the organization’s
finances, based on the most recent audited financial statement. This information
could be contained in a receipt or acknowledgement, a subsequent appeal,
or a regular report to donors.
It is recommended that no more than 35% of expenditures are spent on
administration and fundraising costs. Agencies with sources of income
which do not require large fundraising efforts should have proportionately
lower costs.
With reference to section 2.7 of the Standards, it is recognized that
some organizations, as a matter of conscience, may, as policy, choose
not to follow certain laws.
Examples of policy issues intended to define and protect the rights of
employees, as required by Standard 6.3.1 include: terms of employment
and termination; grievance procedures; right to due process; clear job
definition and periodic performance appraisals; recognition of family
responsibility; privacy regarding personal matters not directly related
to job performance; and a safe workplace free from illegal drugs, secondary
smoke, environmental hazards, and any form of harassment, racial, sexual,
cultural, religious or other.
Examples of policy issues to define an organization’s expectations
of employees, as required by Standard 6.3.3 include: the obligation to
protect confidential information relating to the agency’s plans and
activities; the avoidance of conflict of interest situations; the maintenance
of consistently high professional standards and conduct; and avoidance
of substance abuse.
It is recommended that each member consider adopting a socially responsive
investment policy (i.e. investments in stocks, bonds, and other financial
instruments) which either contributes to his or her humanitarian objectives,
or renders no negative effects on those objectives.
PVO STANDARDS ADDENDUMs
Interpretive
Guidance to InterAction’s Standards and Guidelines
Approved by the Executive Committee, September 13, 1993
Amended by the Executive Committee, March 10, 1994
Amended by the Executive Committee, May 7, 1997
Background
This is intended to be read with the PVO Standards – and the related
Guidelines – promulgated by InterAction for its members; it provides
elaboration on the intent and applications of Standards that may need
further explanation, on input from other relevant sources. The Standards
are requirements for membership in InterAction; the Guidelines are recommendations
from the Board, but are not requirements for membership.
Some of the Standards and Guidelines refer to codes and standards developed
by other organizations. Members and prospective members are reminded that
copies of these materials are available in InterAction’s Resource
Center and may be obtained by contacting Julie Novick, Manager, Member
Services at (202) 667-8227, ext. 157.
Interpretive Guidance
Section 1.0, Preamble
The existence of a dynamic and creative nongovernmental, nonprofit sector
is dependent upon the public’s confidence in the efficacy of its
programs, and in the integrity of the individuals and organizations comprising
the sector. Matters of program quality and individual and organizational
integrity are ultimately the responsibility of each individual organization,
its board, staff and constituents. However, umbrella groups that represent
communities of interest within the nonprofit sector also have a significant
leadership role to play in building the public trust by clearly defining
high standards of governance, management, and programs to guide its members,
and by developing appropriate mechanisms to ensure accountability.
Experience confirms that the action of one nonprofit with even an appearance
of impropriety hurts the whole sector by undermining public confidence.
A collective commitment to quality and integrity by coalitions like InterAction
is one essential dimension of the overall process of maintaining and enhancing
the public trust.
As a voluntary association, InterAction’s Standards derive their
weight and credibility from the collective commitment of the membership.
InterAction’s Standards are NOT to be understood as supplanting the
need for each individual member agency to manage its affairs with a concern
for matters of program quality and individual and organizational integrity;
they are rather intended to complement the commitment of every member
organization.
Section 2.0, Governance
The existence of an independent, functioning, volunteer board is critical
to any nonprofit organization; "independent" is construed to
mean not beholden to the paid staff or to any other interests. The governing
instruments – e.g. charter, articles of incorporation, and bylaws
– should set forth the organization’s basic goals and purposes,
and define the organizational structure, including the governance structure.
The Standards in this section elaborate on this fundamental requirement.
2.1 (See also Guidelines 3 and 4)
For a board to be "independent," it shall normally not include
more than one paid staff person, typically the chief staff officer, who
shall not chair the board or serve as treasurer; a greater representation
of paid staff on the board should be limited to large organizations with
large, active boards, and in such cases, a policy regarding the maximum
staff representation should be clearly defined. The board chair and the
chief staff officer should be independent of one another, i.e. not related
by family or by close business or professional associations.
2.2 (see also 2.6)
In some situations, it is appropriate to substitute "executive committee"
or "advisory committee" for the term board. Examples include:
Membership organizations typically have a board comprising representatives
of all member organizations who serve as long as their organization remains
a member; in these cases, the Executive Committee performs the real governance
functions, and is the entity that should have an elected membership, with
defined terms of office, etc.
US entities that are subsidiary to a non-US parent organization may appropriately
apply the provisions of this section to the advisory committee or other
entity charged with responsibility for US operations.
The requirement that board policies include limited terms of services
is NOT intended to force board members to retire after a specified time;
for example, if board members have three-year terms, nothing in the Standards
is intended to prohibit any or all of them from being re-elected for as
many consecutive three-year terms as the board deems appropriate. The
presence of defined terms simply ensures a periodic review of each board
member’s performance; approval of a new term connotes a renewed commitment
by both the organization and the individual board member, and thus represents
good institutional practice.
The provisions regarding terms of service (2.2) and nondiscrimination
(2.6) notwithstanding, InterAction recognizes that the boards of organizations
founded by particular religious traditions for the purpose of providing
international services may appropriately comprise representatives of the
leadership of that tradition. Such organizations are exempt from the provisions
of Standards 2.2 and 2.6 relating to terms of service and discrimination
on the basis of religion. InterAction recommends that such organizations
consider the use of advisory committees or other vehicles to proactively
seek to hear diverse views.
2.3 (See also 3.2)
A formal board policy regarding conflicts of interest is essential. At
a minimum these must cover all board members, and all employees with supervisory
responsibility. It is strongly recommended that they also cover employees
below the supervisory level, and volunteers so that the commitment to
individual integrity is organization-wide.
However, InterAction has concluded that members who elect to exempt staff
and/or volunteers with no supervisory responsibility from their conflict
of interest policy are not in violation of the spirit and intent of this
Standard; the policy governing such exemptions should be clearly defined.
Board members and employees should absent themselves from discussion,
as well as from voting or otherwise participating in any decision in which
they have a conflict of interest. If the expertise of an individual with
a conflict of interest on a pending decision is desired, it should be
provided apart from the decision-making process, and a written record
should clearly reflect their absence form the decision process.
2.5 (See also 4.7)
Responsibility for an annual budget, including both projected income
and expense, is a basic and essential board function.
InterAction recommends the establishment of a separate Audit Committee
of the board. Members electing to periodically use the full board as an
Audit Committee may still be considered to be in compliance with the spirit
and intent of this Standard; however, their board minutes should clearly
reflect the fact that the full board assumed the role of Audit Committee
for purposes of reviewing the financial statements and activities of the
organization.
2.7 (See also Guideline 7)
The term "applicable laws" should be understood to include
US law, host country law, and international law. The Standard notwithstanding,
InterAction affirms the possibility of conscientious objection in the
context of a clearly defined organizational policy.
Section 3.0, Organizational
Integrity
Member organizations must be committed to integrity and truthfulness;
its activities should be open and accessible to scrutiny by donors.
3.1
Personnel matters and information considered proprietary might be appropriate
exceptions to the general rule of openness and accessibility; InterAction
recommends establishing clear policies that define and limit the exceptions.
3.2 and 3.6
It is neither possible nor desirable for members to attempt to suggest
a detailed set of regulations that would cover all aspects of the professional
behavior and ethical conduct for every individual associated with the
organization. However, members must recognize that their reputation for
program quality and for individual and organizational integrity reflects
on the whole PVO community. InterAction considers a written code of conduct
to provide guidance for directors, employees and volunteers to be an essential
vehicle for communicating institutional expectations.
In additions to a policy regarding conflicts of interest – per 2.3
– and the need to comply with applicable laws – per 2.7 –
such a code might address unethical personal financial gain, acceptance
of large or otherwise inappropriate gifts, avoidance of inappropriate
political activity, etc. Sample codes from various members are available
in the Resource Center at InterAction.
3.3
In assuring protection to employees desiring to present evidence of misconduct,
members should define at least two separate channels of communication.
Reporting to the CEO will normally be the primary recourse; however, if
this is the sole recourse, the employee is not protected in cases where
the CEO may be party to the conduct in question. An option to bring the
concern to the board chair or other appropriate party(ies) should be clearly
communicated as an alternative.
3.5 (See also 5.3 and 7.1.5)
The people and organizations in developing countries who are served by
PVO programs are the constituency to which this Standard primarily refers;
however, the interests of all interested parties including donors, board,
staff and volunteers are also to be respected. The term "respected"
does not imply acceptance of the status quo, but rather a good faith effort
to be intentional about considering the dignity, values, etc. of all parties
who could appropriately be considered "stakeholders" in the
member’s programs.
Section
4.0, Finances (See also Guideline 5)
Financial accountability and sound financial management are at the heart
of the relationship of trust between donors and donees.
4.6 (See also Guideline 6)
The organizational structures and the nature of the programs of members
are widely varied. InterAction’s Guideline 6 recommends that fundraising
and administrative expense not exceed 35% of total expenditure; however,
defining a single numerical Standard for such a diverse coalition is impractical.
InterAction does expect each member to have its own internal target for
fundraising and administrative expense that is appropriate to the nature
of its structure and programs.
4.8
A member should have clearly defined procedures for handling the excess
when an appeal for funds for a specific purpose is oversubscribed. Ideally
this should mean going back to the donor(s) to return the excess or to
obtain approval for an alternative use of the funds. However, if the funding
has come from a large number of small donors, going back to the donors
may not be feasible.
When funding is invited from the general public for a specific purpose,
the plans for handling any excess should be spelled out as an integral
part of the appeal. Although this may also be done through language contained
in the receipt given donors, InterAction strongly recommends that it be
done as an integral part of the original appeal.
Section 5.0,
Communications to the Public
Honest and accurate communications are essential to the public trust.
5.2
The term "negative advertising" covers any public statements
that seek to enhance the image of one member agency at the expense of
others, individually or collectively, by name or by implication. Such
tactics inevitably have the long-term effect of undermining public confidence
in the sector, and are deemed contrary to the collegial spirit of the
InterAction coalition.
5.4
Notification can include a statement in the organization’s annual
report which informs donors that their name may be on lists which are
for sale, rent or exchange. In addition, the statement should advise donors
to contact the organization if they want their name removed from the lists.
5.5
Cause related marketing refers to arrangements in which a for-profit
organization agrees to donate a portion of the revenue from the sale of
certain goods or services to a specific charity or cause. With both this
kind of fundraising and the more traditional benefit events, the amount
of the funds going to the charity should be described prior to, or in
conjunction with, the effort.
Section
6.0, Management Practice and Human Resources (See also Guidelines 5, 8
and 9)
In an environment of increased competition for limited resources and
intensified scrutiny of PVO performance, it is imperative that members,
regardless of their size, be committed to recruiting and retaining staff
that combine professional competence with a commitment to service.
The appropriate use of volunteers and the management of expatriate and
host country national field staff present special challenges to nonprofits
– like InterAction’s members – with internationally oriented
programs.
Members should provide a full and complete exposition of salary and non-salary
executive compensation. Their governing bodies shall recognize and affirm
a fundamental obligation to ensure that executive compensation is fair
and reasonable in the context of current norms within the nonprofit sector.
6.4
Organizations with less than 50 staff members are legally exempt from
the requirements for affirmative action.
Section 7.0, Program
In an environment of some public skepticism about the long-term value
of nonprofit programs internationally, members must be attentive to the
long term impacts and the cost effectiveness of their programs. InterAction’s
Program Standards represent the breaking of significant new ground for
a nonprofit coalition.
The Program Standards have two broad and interrelated objectives, 1)
to confirm InterAction’s core values, e.g. member programs must be
undertaken in a spirit of partnership, and with the intent of fostering
self-reliance and avoiding the creation of dependencies, and 2) to ensure
that programs embody good "quality" as defined by various appropriate
authorities such as the World Health Organization and others.
The Program Standards define a dynamic framework within which InterAction
members are expected to operate. Over time, the Standards Committee, working
in consultation with individual members will continue to recommend changes
based on experience.
Section 8.0, Public Policy
InterAction and a growing number of its members are increasingly involved
in advocacy, public policy and lobbying. It is imperative for those members
so choosing to have written policies that clearly define and delineate
the circumstances in which it will be involved in such activities.
Gender Amendments
InterAction will provide assistance to members in advancing the status
of women in their organizations and programs, promote the sharing of experiences
amongst members, and providing tools for integrating gender in program
planning, implementation and evaluation. InterAction will report periodically
on its support to members and on member agency progress in attaining gender
equity.
In promoting gender equity in programs, agencies are encouraged to collect
gender disaggregated data in order to be able to determine differential
participation of and impacts on women and on men.
Diversity Amendments
InterAction will provide assistance to members in advancing diversity
in their organizations and programs and promoting the sharing of experiences
amongst members. InterAction will report periodically on member agency
progress in diversity.
Commonly Asked
Questions
The following questions relate to the entire PVO Standards document.
1. How have the Standards benefited the community over the last five
years?
The Standards serve a critical internal and external role. Internally,
the Standards link members in the common pursuit of a set of values and
ethical code of conduct. Externally, the Standards certify to the public-at-large
that members have committed themselves to certain ideals and ways of operating.
At a time when the public trust in the nonprofit community has been shaken,
the Standards are a highly visible, professional statement that enhances
credibility with donors, governments, other NGO consortia, and the public
at large.
Specific examples follow:
- InterAction supports disaster response fundraising of its members
by informing the media that certain of the responding agencies are members
of InterAction, a coalition that sets standards for its members. Similarly,
individual member agencies are free to refer to their compliance with
InterAction’s high standards in fundraising and educational materials.
- The Standards have furthered InterAction’s position as a leader
among NGO coalitions around the world. Coalitions in Canada and Japan
used InterAction’s Standards as a model for their own standards,
and many other coalitions have studied them. For example, World Learning
has translated them into Russian for use in the former Soviet republics.
The International Center for Not-for-Profit Law used a modified version
of InterAction’s Standards as the centerpiece for the self-regulation
component of its work on regulating civil society in Eastern and Central
Europe.
- Funding organizations increasingly are aware of InterAction’s
commitment to excellence though the PVO Standards. The Independent Sector
and the Committee on International Grantmaking of the Council of Foundations
distributed the PVO Standards to their members, and the European Foundation
Center distributed copies at a major conference that they hosted.
Similarly, the charity watchdogs such as NCIB and the Philanthropic Advisory
Service of the Better Business Bureau have shown an interest in the coalition’s
initiative to self-regulate.
The organization Gifts-In-Kind now requires that their recipient organization
comply with InterAction’s Standards as a baseline of acceptability
before receiving material.
The Standards provide the Membership Committee with a useful framework
for considering prospective members and a foundation from which to resolve
disputes among members.
2. What if members are reluctant to sign the Standards?
InterAction is a voluntary association, and the Standards set by and
for its members have weight only to the extent that the membership supports
them. Self-certification is a clear, simple method of confirming member
support. If a member refuses to sign, the issue is referred to the PVO
Standards Committee. The PVO Standards Committee will request an explanation
from the member, determine whether the abstention is reasonable and forward
a recommendation on to the Executive Committee for final review. Under
InterAction’s bylaws, the Executive Committee may, by majority vote,
suspend or terminate the membership of an organization. Dismissal, however,
will always be a last resort and follow efforts to resolve the issue through
dialogue.
3. What is the legal status of the Standards as a whole document?
The Standards are best understood as statements of principles, and as
such are not legal requirements. Laws generally define minimums, while
principles embody the higher values that charitable organizations, by
their very nature, recognize and share. The public affirmation of the
principles embodied in the PVO Standards through the annual compliance
review process does not, in and of itself, create legal issues or liabilities;
however there could be legal consequences should agencies conduct themselves
or their programs in ways that are at odds with established US, international
or local law.
The principles contained in the PVO Standards are of two broad types:
1) Shared values, e.g. development programs should be participatory, employees
should be treated fairly, boards should be independent, etc.; 2) Quality
standards, i.e. members must consider the quality standards established
by appropriate authorities, e.g. receipt and distribution of medical supplies
should be guided by the regulations of WHO, financial management practices
by the norms of AICPA and FASB, fundraising practices by the norms of
the National Society of Fundraising Executives, etc.
Adherence to all relevant laws (or conscientious non-adherence) is ultimately
the responsibility of the boards of directors and staffs of member agencies.
The following questions relate to the Standards on gender equity and
diversity.
1. Is there increased legal liability for members who sign the Standards?
There is not increased legal liability for members who sign and strive
to uphold the Standards. In fact, the Standards may be protective of members
by demonstrating intent. However, as each member organization has its
unique practices, legal history and counsel, you should consult your organization’s
legal counsel with questions that may affect liability.
Current law covers such areas as equal pay for equal work, and nondiscrimination
for access to opportunities and resources. The Standards set forth by
InterAction in these areas track current law and do not go beyond it to
ask more of our members than is required by law.
The other areas covered by the gender equity and diversity guidelines,
such as training, awareness and programming are not covered by any body
of US law. Therefore, these are areas that are separate and independent
from US law. Rather, these Standards state the values and reflect the
expectations of the PVO community.
2. How can InterAction help members implement the gender equity and
diversity amendments to the Standards?
To support member initiatives related to gender equity, the Commission
on the Advancement of Women (CAW) will provide resources and learning
opportunities, including workshops, on-site consultations and materials,
such at Best Practices for Gender Integration in Organizations and Programs.
In addition, organizations such as Independent Sector and the National
Center for Nonprofit Boards can provide literature and training. There
are similar resources for diversity and inclusiveness. For both gender
and diversity efforts, InterAction will help broker "mentor"
relationships among InterAction members and provide recommendations for
consultants and resource people.
3. Aren’t the amendments awfully intrusive, prescriptive and
very detailed?
The gender and diversity amendments are consistent in tone and approach
with the rest of the Standards. They are neither more detailed nor specific
than those relating to governance and finance. InterAction recognizes
its members are independent, self-governing entities, and thus bear the
ultimate responsibility for matters of equality and integrity in their
own governance, management and programs. The PVO Standards are not intended
to supplant this fundamental responsibility of individual agencies, but
rather complement it with a statement of the values and aspirations of
our community.
4. Does "equal pay for equal work" mean that everybody in
the same job must get paid the same amount and that my organization has
to redo all our job descriptions and pay scales?
No. Equal pay for equal work is the legal standard for employees based
in the United States, but it recognizes that any given job must accommodate
a range of pay scales based on certain objective criteria such as a person’s
experience and salary history. What it seeks to prevent is discrimination
in pay based on gender, race, ethnic origin, age and disability. The expectation
to uphold this standard extends to all organizations, regardless of size.
In this respect, the standards exceed the current law.
InterAction
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