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Policies/SchoolONE Policy § 1.3.02. Student Contact and Background Screening

2026-07-19T09:15:34Z

Gibran Rahman: Created page with "= Article III. SchoolONE Private School Policies = == Subarticle A. SchoolONE California Private School Policies == == Chapter 1. Vision, Leadership, Faculty and Staff, Resources, Continuous Improvement, and Accountability and Compliance == == SchoolONE Policy § 1.3.02. Student Contact and Background Screening. == (a) Purpose. (1) SchoolONE is committed to student safety in all instructional settings, including in-person instruction, distance learning, tutoring, adv..."

Policies/EducateONE Organizational Policy § 11.8.00. Public Inspection and Disclosure Policy

2026-07-19T09:13:38Z

Gibran Rahman: Created page with "= Article I. EducateONE Organizational Policies = == Chapter 11. Corporate Records, Minutes, Reports, and Inspection Rights == == EducateONE Organizational Policy § 11.8.00. Public Inspection and Disclosure Policy. == (a) Public Availability. (1) EducateONE shall make final Board-approved policies available on its website. (2) If a final Board-approved policy has not yet been posted on EducateONE’s website, the policy may be requested from EducateONE and may be pr..."

= Article I. EducateONE Organizational Policies =

== Chapter 11. Corporate Records, Minutes, Reports, and Inspection Rights ==

== EducateONE Organizational Policy § 11.8.00. Public Inspection and Disclosure Policy. ==
(a) Public Availability.

(1) EducateONE shall make final Board-approved policies available on its website.

(2) If a final Board-approved policy has not yet been posted on EducateONE’s website, the policy may be requested from EducateONE and may be provided in any reasonable format, subject to reasonable copying, mailing, or delivery costs.

(3) Examples of policies and public organizational documents that will be available include EducateONE’s articles of incorporation, bylaws, conflict of interest policy, federal tax-exemption application and all attachments, IRS determination letter, annual information returns, required schedules and attachments, Form 990-T, audited financial statements, and other public organizational documents, records, reports, filings, or materials.

(b) Confidential Policies and Materials.

(1) EducateONE reserves its lawful authority to maintain confidential policies, policy materials, internal procedures, privileged materials, security-sensitive materials, personnel-related materials, student or family records, donor-confidential information, investigation materials, drafts, superseded materials, and other records or materials that are not public organizational documents.
----Source Note

This policy is adapted from Public Counsel’s Community Development Project, Form 990 Series Public Disclosure Policy and Memorandum, including its sample Public Disclosure Policy for tax-exempt organizations. The policy has been modified for EducateONE’s organizational structure, website-posting approach, public transparency commitment, confidentiality reservation, policy numbering, source-note placement, and drafting style.

Policies/EducateONE Organizational Policy § 2.6.00. Political Campaign, Legislative Activity, and Lobbying Policy

2026-07-19T09:11:09Z

Gibran Rahman: Created page with "= Article I. EducateONE Organizational Policies = == Chapter 2. Tax-Exempt Status, Charitable Limitations, and Private Benefit Restrictions == == EducateONE Organizational Policy § 2.6.00. Political Campaign, Legislative Activity, and Lobbying Policy. == (a) Lobbying Activities. (1) It is the policy of EducateONE that any lobbying or political campaign activities undertaken by EducateONE, or by any employee, Board member, or other agent of EducateONE on behalf of Edu..."

= Article I. EducateONE Organizational Policies =

== Chapter 2. Tax-Exempt Status, Charitable Limitations, and Private Benefit Restrictions ==

== EducateONE Organizational Policy § 2.6.00. Political Campaign, Legislative Activity, and Lobbying Policy. ==
(a) Lobbying Activities.

(1) It is the policy of EducateONE that any lobbying or political campaign activities undertaken by EducateONE, or by any employee, Board member, or other agent of EducateONE on behalf of EducateONE, shall comply with the applicable federal and state requirements, including those established under the Internal Revenue Code, the Lobbying Disclosure Act of 1995, as amended, the Federal Election Campaign Act, and the Byrd Anti-Lobbying Amendment.

(2) No employee, Board member, or other agent of EducateONE shall engage in any lobbying activity on behalf of EducateONE without the express prior approval of the Executive Director.

(b) Political Campaign Activities.

(1) EducateONE, and any employee, Board member, or other agent acting on behalf of EducateONE, is absolutely prohibited from participating or intervening in any political campaign.

(2) A “political campaign” shall be deemed to begin when an individual announces his or her candidacy for an elective public office, or is proposed by others for an elective public office.

(c) Expenditure of Federal Funds.

(1) EducateONE prohibits the expenditure of any federal funds received by EducateONE as the recipient of a federal contract, grant, loan, or cooperative agreement for lobbying or political campaign activities.

(2) In addition, no federal funds shall be used to pay any person or organization for influencing or attempting to influence an officer or employee of an agency or member of Congress, or employee of a member of Congress, with respect to:

(A) the awarding of any federal contract;

(B) the making of any federal grant;

(C) the making of any federal loan;

(D) the entering into of any cooperative agreement; or

(E) the extension or modification of any federal contract, grant, loan, or cooperative agreement.

(d) Reporting.

(1) EducateONE shall ensure that all disclosures of lobbying which are required by law are submitted in a timely manner.

(e) Accreditation and Standards-Setting Activity.

(1) EducateONE may participate in lawful accreditation, standards-setting, public-comment, regulatory, legislative, and public-policy processes.

(2) EducateONE shall not use private influence, association leverage, undisclosed conflicts, insider access, or back-channel pressure to improperly influence an accrediting body’s standards, policies, procedures, recognition decisions, institutional decisions, program decisions, or accreditation actions.

(3) Nothing in this subdivision prohibits EducateONE from submitting public comments, responding to accreditor requests, communicating through ordinary authorized channels, participating in open policy processes, or advocating for innovation-friendly, student-centered, outcome-based, competition-supporting, or less restrictive standards.

(f) Individual Activity.

(1) Nothing in this policy shall preclude an employee, Board member, or other agent of EducateONE from engaging in political campaign activities or lobbying activities on his or her own time, provided that EducateONE is not connected with such activities and provided that EducateONE’s funds and other resources are not used in connection with such activities.
----Source Note

This policy is adapted from the Sample Policy on Lobbying and Political Campaign Activities published through health-center advocacy materials, with modifications for EducateONE’s charitable, educational, and tax-exempt structure. The accreditation and standards-setting subdivision is informed by the U.S. Department of Education’s 2026 Accreditation, Innovation, and Modernization negotiated-rulemaking consensus language concerning accreditor independence, related association influence, public feedback, credential inflation, and unnecessary barriers to entry.

References

Internal Revenue Code section 501(c)(3).

Lobbying Disclosure Act of 1995.

Federal Election Campaign Act.

Byrd Anti-Lobbying Amendment.

U.S. Department of Education, Accreditation, Innovation, and Modernization Negotiated Rulemaking, Final Version Consensus Language, May 21, 2026.

Policies/SchoolONE Policy § 1.3.01. California Commission Credential Designation

2026-07-19T09:03:23Z

Gibran Rahman: Created page with "= Article III. SchoolONE Private School Policies = == Subarticle A. SchoolONE California Private School Policies == == Chapter 1. Vision, Leadership, Faculty and Staff, Resources, Continuous Improvement, and Accountability and Compliance == == SchoolONE Policy § 1.3.01. California Commission Credential Designation. == (a) Purpose. (1) SchoolONE recognizes that some private-school employees may perform instructional, administrative, supervisory, counseling, pupil per..."

= Article III. SchoolONE Private School Policies =

== Subarticle A. SchoolONE California Private School Policies ==

== Chapter 1. Vision, Leadership, Faculty and Staff, Resources, Continuous Improvement, and Accountability and Compliance ==

== SchoolONE Policy § 1.3.01. California Commission Credential Designation. ==
(a) Purpose.

(1) SchoolONE recognizes that some private-school employees may perform instructional, administrative, supervisory, counseling, pupil personnel, special education, student-support, career technical, adult education, designated-subject, or other professional education duties that are similar to duties that, in an equivalent California public school position, may require a credential, permit, certificate, authorization, waiver, approval, or other educator-authorizing document issued, recognized, administered, or required by the California Commission on Teacher Credentialing.

(2) This policy clarifies when such credentials or documents are required by SchoolONE, when they are voluntarily recognized or designated, and how any such designation must be documented.

(b) Definition of California Commission Credential.

(1) For purposes of this policy, a “California Commission Credential” means any credential, certificate, permit, authorization, waiver, approval, document, or other educator-authorizing instrument issued, recognized, administered, or required by the California Commission on Teacher Credentialing.

(2) This definition applies to all such instruments, whether currently existing or created in the future, and regardless of title, category, subject area, service area, grade level, authorization type, employment setting, or credential pathway.

(c) General Rule.

(1) An employee’s performance of duties that would require a California Commission Credential in an equivalent California public school position does not, by itself, automatically require the employee to hold that credential solely because SchoolONE is a private school.

(2) A California Commission Credential is required for a SchoolONE position only when one or more of the following applies:

(A) applicable law requires the credential;

(B) SchoolONE expressly requires the credential for the position;

(C) an accreditation, contract, program, funding, placement, regulatory, or other binding requirement requires the credential;

(D) the employee’s written employment agreement requires the credential;

(E) SchoolONE designates the position as credential-required in writing; or

(F) the employee voluntarily elects, and SchoolONE approves, credential designation under this policy.

(d) Credential-Like Duties Do Not Create Automatic Credential Requirement.

(1) A position may involve duties that are similar to duties performed by credentialed personnel in California public schools without being credential-required under SchoolONE policy.

(2) Such duties may include instructional, administrative, supervisory, counseling, pupil personnel, special education, student-support, career technical, adult education, designated-subject, or other professional education duties.

(3) The existence of such duties does not create an automatic credential requirement unless the position is designated as credential-required under this policy or unless a separate legal, contractual, accreditation, program, regulatory, or other binding requirement applies.

(e) School-Designated Credential Requirement.

(1) SchoolONE may designate a position as credential-required, credential-preferred, credential-recognized, or credential-supported when SchoolONE determines that such designation is appropriate for educational, operational, accreditation, contractual, student-safety, credentialing, professional-development, or institutional reasons.

(2) Any SchoolONE-designated credential requirement must be documented in writing.

(3) The written designation should identify:

(A) the position or employee covered;

(B) the California Commission Credential involved;

(C) the effective date of the designation;

(D) the purpose of the designation;

(E) whether the credential is required, preferred, recognized, supported, temporary, conditional, or voluntary;

(F) any credential-related requirements adopted by SchoolONE; and

(G) the SchoolONE official approving the designation.

(f) Voluntary Employee Credential Designation.

(1) An employee may request that SchoolONE designate the employee’s role as requiring, recognizing, or supporting a California Commission Credential.

(2) SchoolONE may approve the request when the employee’s duties are substantially related to the credential sought, held, maintained, renewed, cleared, verified, or used for professional qualification purposes.

(3) Approval is discretionary and must be made in writing by the Head of School, Superintendent, Executive Director, Principal, Board Chair, or other authorized SchoolONE official.

(g) Effect of Written Credential Designation.

(1) Once a position or employee is credential-designated in writing, the employee agrees to comply with the credential-related requirements adopted by SchoolONE for that designation.

(2) These requirements may include, as applicable:

(A) obtaining, holding, maintaining, renewing, clearing, or verifying the applicable California Commission Credential;

(B) maintaining any required authorization, permit, certificate, waiver, approval, or other document connected to the designation;

(C) complying with applicable induction, mentoring, supervision, evaluation, professional-growth, experience, or service-verification requirements;

(D) providing proof of credential status upon request;

(E) promptly notifying SchoolONE of any expiration, lapse, denial, suspension, revocation, restriction, investigation, or other material change in credential status;

(F) authorizing SchoolONE to verify credential status and credential-related service;

(G) performing only those credential-designated duties approved by SchoolONE;

(H) cooperating with credential, induction, accreditation, employment, or program documentation processes; and

(I) complying with additional credential-related requirements that would apply to an equivalent California public school assignment, to the extent expressly adopted by SchoolONE in writing.

(h) Written Election for Voluntary Designation.

(1) A voluntary credential designation must be documented in a written election signed by the employee and an authorized SchoolONE official.

(2) The written election shall state:

(A) the employee’s name and position;

(B) the California Commission Credential involved;

(C) the effective date of the designation;

(D) the duties supporting the designation;

(E) whether the employee currently holds the credential or is seeking it;

(F) the credential-related requirements accepted by the employee;

(G) whether the designation is required, preferred, recognized, supported, temporary, conditional, or voluntary;

(H) whether the designation is connected to induction, renewal, clearing, experience verification, accreditation, employment, professional qualification, or another stated purpose;

(I) the SchoolONE official approving the designation; and

(J) the duration of the designation, if limited.

(3) The signed election and approval shall be maintained in the employee’s permanent personnel file.

(i) Permanent File Requirement.

(1) Any written credential designation, voluntary election, approval, modification, revocation, or related credential-status documentation shall be maintained in the employee’s permanent personnel file.

(2) SchoolONE may also maintain copies in any credentialing, accreditation, human resources, compliance, or program file as appropriate.

(j) No Implied or Retroactive Designation.

(1) Credential designation is not created by job title, informal practice, job description, similarity to a public school role, parent expectation, employee preference, possession of a credential, or performance of credential-like duties.

(2) Credential designation exists only when:

(A) SchoolONE requires the credential in writing;

(B) the employee’s written employment agreement requires the credential;

(C) a binding legal, accreditation, contract, program, regulatory, or other external requirement applies; or

(D) the employee makes a written election and SchoolONE approves it in writing.

(3) Unless one of these conditions is satisfied, the position shall not be treated as credential-required under SchoolONE policy.

(k) Credential Status and Continued Eligibility.

(1) When a credential designation is in effect, the employee is responsible for maintaining the credential status required by the designation.

(2) The employee must promptly notify SchoolONE if:

(A) the credential expires or lapses;

(B) the credential is denied, suspended, revoked, restricted, placed under review, or otherwise affected;

(C) the employee fails to complete a required renewal, induction, clearing, authorization, or professional obligation;

(D) the employee is no longer eligible for the credential;

(E) the employee’s credential no longer covers the designated duties; or

(F) any other material change affects the employee’s credential status.

(3) SchoolONE may require updated documentation of credential status at any time.

(l) SchoolONE Verification of Service.

(1) SchoolONE may verify an employee’s service, duties, dates of employment, assignment, performance, supervision, or professional experience when reasonably necessary for credentialing, induction, renewal, clearing, accreditation, employment, professional qualification, or other SchoolONE-approved purposes.

(2) Any verification shall be accurate, duty-based, and consistent with SchoolONE’s records.

(3) SchoolONE is not required to verify service as credential-equivalent unless SchoolONE determines that the employee’s actual duties and records support such verification.

(m) Revocation, Modification, or Expiration of Designation.

(1) SchoolONE may revoke, modify, suspend, or decline to renew a credential designation if:

(A) the employee no longer performs duties supporting the designation;

(B) the employee fails to maintain required credential status;

(C) the employee does not satisfy credential-related obligations;

(D) the designation was approved for a limited purpose that has ended;

(E) the employee changes position or assignment;

(F) SchoolONE determines that the designation is no longer necessary or appropriate;

(G) applicable law, accreditation requirements, program rules, credentialing requirements, or SchoolONE needs change; or

(H) SchoolONE determines that revocation or modification is in the best interests of SchoolONE.

(2) Any revocation, modification, suspension, or expiration should be documented in writing and placed in the employee’s permanent personnel file.

(n) No Public-School Status Created.

(1) Credential designation under this policy does not convert SchoolONE into a public school, charter school, school district, county office of education, local educational agency, or public employer.

(2) Credential designation does not make public-school employment laws, collective bargaining rules, assignment-monitoring systems, tenure rules, seniority rules, salary schedules, evaluation systems, dismissal procedures, or other public-school requirements applicable to SchoolONE unless separately required by law or expressly adopted by SchoolONE in writing.

(o) No Waiver of Legal Requirements.

(1) Nothing in this policy waives, limits, avoids, or supersedes any legal, credential, background-check, student-safety, employment, accreditation, contractual, program, regulatory, or other binding requirement that independently applies to SchoolONE or to the employee.

(2) If applicable law or another binding requirement requires a California Commission Credential, background check, clearance, training, qualification, or other condition for a particular role, the employee must satisfy that requirement regardless of whether a voluntary credential designation has been made under this policy.

(p) SchoolONE Discretion.

(1) SchoolONE retains discretion to determine whether a California Commission Credential is required, preferred, recognized, supported, or unnecessary for any position, subject to applicable law and binding external requirements.

(2) SchoolONE may impose credential requirements that are higher than the minimum required by law when SchoolONE determines that doing so serves SchoolONE’s educational, operational, accreditation, contractual, student-safety, credentialing, professional-development, or institutional interests.

(q) Interpretation.

(1) This policy shall be interpreted broadly to apply to all California Commission Credentials and all credential-related designations involving SchoolONE employees.

(2) No credential, authorization, permit, certificate, waiver, approval, document, or future educator-authorizing instrument shall be excluded from this policy merely because it is not specifically named.
----Source Note

This policy was developed for SchoolONE California Private School Policies to clarify when California Commission on Teacher Credentialing credentials and related documents are required, recognized, supported, or voluntarily designated for SchoolONE private-school employees. The policy is intended to preserve SchoolONE’s private-school flexibility while allowing credential-related designations when required by law, accreditation, contract, program participation, employment agreement, SchoolONE determination, or voluntary written election.

Policies/EducateONE Organizational Policy § 12.1.00. Financial Management and Controls

2026-07-19T09:00:22Z

Gibran Rahman: Created page with "= Article I. EducateONE Organizational Policies = == Chapter 12. Finance, Accounting, Internal Controls, Banking, and Gifts == == EducateONE Organizational Policy § 12.1.00. Financial Management and Controls. == (a) '''Philosophy.''' (1) The purpose of financial management in the operation of all EducateONE activities is to fulfill the organization’s mission in the most effective and efficient manner and to remain accountable to stakeholders, including students, fa..."

= Article I. EducateONE Organizational Policies =

== Chapter 12. Finance, Accounting, Internal Controls, Banking, and Gifts ==

== EducateONE Organizational Policy § 12.1.00. Financial Management and Controls. ==
(a) '''Philosophy.'''

(1) The purpose of financial management in the operation of all EducateONE activities is to fulfill the organization’s mission in the most effective and efficient manner and to remain accountable to stakeholders, including students, families, partners, funders, employees, and the community.

(2) In order to accomplish this, EducateONE commits to providing accurate and complete financial data for internal and external use by the Executive Director and the Board of Directors.

(b) '''Authority.'''

(1) The Board of Directors is ultimately responsible for the financial management of all activities.

(2) The Treasurer is authorized to act on the Board’s behalf on financial matters when action is required in advance of a meeting of the Board of Directors.

(3) The Executive Director is responsible for the day-to-day financial management of the organization.

(4) The Board authorizes the Executive Director to hire and supervise staff and independent consultants, pay bills, receive funds, and maintain bank accounts.

(5) The Executive Director is authorized to sign checks up to $2,500.

(6) Checks for amounts greater than $2,500 shall require the signature of the Treasurer or Board Chair.

(7) The Executive Director is authorized to enter into contracts for activities that have been approved by the Board as a part of budgets or plans.

(8) The Board of Directors must authorize any contracts outside of the parameters described in paragraph (7), and all contracts with a financial value greater than $15,000.

(9) The Executive Director is authorized to manage expenses within the parameters of the overall approved budget, reporting to the Finance Committee on variances and the reason for these variances.

(10) The Board of Directors must approve any use of the board-designated cash reserve fund.

(c) '''Responsibilities of the Executive Director.'''

(1) The Executive Director shall:

(A) account for donor-restricted and board-designated funds separately from general operating funds, and clearly define the restrictions applicable to these funds;

(B) report the financial results of EducateONE operations according to the schedule established by the Finance Committee, but at least quarterly;

(C) pay all obligations and file required reports in a timely manner;

(D) make no contractual commitment for bank loans, corporate credit cards, or real estate leases or purchases without specific approval of the Board;

(E) record fixed assets with purchase prices greater than $500 as capital assets in accounting records;

(F) ensure that depreciation of capital assets does not exceed five years for furniture and equipment, or three years for computer and other technology equipment;

(G) limit vendor credit accounts to prudent and necessary levels; and

(H) obtain competitive bids for items or services costing in excess of $5,000 per unit.

(2) Selection under paragraph (1)(H) shall be based on cost, service, and other elements of the contract.

(3) EducateONE may award the bid to any provider and is not required to accept the lowest cost proposal.

(d) '''Responsibilities of the Board of Directors.'''

(1) The Board of Directors shall:

(A) review financial reports at each board meeting; and

(B) provide adequate training to members to enable each member to fulfill his or her financial oversight role.

(e) '''Financial Transactions with Insiders.'''

(1) No advances of funds to employees, officers, or directors are authorized.

(2) Direct and necessary expenses, including travel for meetings and other activities related to carrying out responsibilities, shall be reimbursed.

(3) In no case shall EducateONE borrow funds from any employee, officer, or director of the organization without specific authorization from the Board of Directors.

(f) '''Budget.'''

(1) In order to ensure that planned activities minimize the risk of financial jeopardy and are consistent with board-approved priorities, long-range organization goals, and specific five-year objectives, the Executive Director shall:

(A) submit operating and capital budgets to the Finance Committee in time for reasonable approval by the Board prior to each fiscal year; and

(B) use responsible assumptions and projections as background, with the general goal of an unrestricted surplus.

(g) '''Gift Acceptance.'''

(1) EducateONE may accept stock or other negotiable instruments as a vehicle for donors to transfer assets to the organization.

(2) Transfer and recording the value of the asset shall be done in a consistent manner and in compliance with accounting standards.

(3) The Executive Director shall sell any stock given to the organization immediately upon receipt by the organization.

(4) EducateONE shall accept contributions of goods or services other than cash that are related to the programs and operations of EducateONE.

(5) Any other contributions of non-cash items must be reviewed and approved by the Board of Directors before acceptance.

(h) '''Asset Protection.'''

(1) In order to ensure that the assets of EducateONE are adequately protected and maintained, the Executive Director shall:

(A) insure against theft and casualty losses to the organization and against liability losses to Board members, staff, or the organization itself to levels indicated in consultation with suitable professional resources;

(B) plan and carry out suitable protection and maintenance of property, building, and equipment;

(C) avoid actions that would expose the organization, its board, or its staff to claims of liability;

(D) protect intellectual property, information, and files from unauthorized access, tampering, loss, or significant damage; and

(E) receive, process, and disburse funds under controls that are sufficient to maintain basic segregation of duties to protect bank accounts, income receipts, and payments.
----Source Note

This policy is adapted from the “Nonprofit Financial Policy Example” published by Propel Nonprofits as part of its nonprofit resource library and customized for EducateONE.

Policies/EducateONE Organizational Policy § 11.7.00. Whistleblower and Non-Retaliation Policy

2026-07-19T08:58:36Z

Gibran Rahman: Created page with "= Article I. EducateONE Organizational Policies = == Chapter 11. Corporate Records, Minutes, Reports, and Inspection Rights == == EducateONE Organizational Policy § 11.7.00. Whistleblower and Non-Retaliation Policy. == (a) Purpose. (1) In order to support lawful conduct, charitable integrity, financial accountability, tax-exempt compliance, institutional trust, and protection against retaliation, this policy establishes a method for reporting suspected violations and..."

= Article I. EducateONE Organizational Policies =

== Chapter 11. Corporate Records, Minutes, Reports, and Inspection Rights ==

== EducateONE Organizational Policy § 11.7.00. Whistleblower and Non-Retaliation Policy. ==
(a) Purpose.

(1) In order to support lawful conduct, charitable integrity, financial accountability, tax-exempt compliance, institutional trust, and protection against retaliation, this policy establishes a method for reporting suspected violations and prohibits retaliation against persons who make good-faith reports or cooperate in the review of reported concerns.

(2) This policy is intended to encourage reporting of suspected violations of law, regulation, policy, financial-control requirement, ethical obligation, or other matter covered by this policy.

(3) This policy is not intended to create any right, procedure, investigation requirement, employment protection, student-status protection, contractual right, or appeal right beyond what is required by law or expressly adopted by EducateONE.

(b) Scope.

(1) This policy applies to EducateONE and any controlled EducateONE institution, school, program, service, activity, or operation.

(2) This policy applies to reports made by directors, officers, employees, contractors, volunteers, students, families, program participants, vendors, donors, applicants, visitors, and other persons who interact with EducateONE or its controlled institutions, programs, services, activities, or operations.

(c) Reportable Violations.

(1) For purposes of this policy, a “Violation” means a suspected violation of law, regulation, policy, financial-control requirement, ethical obligation, or other matter that may affect EducateONE’s charitable, educational, tax-exempt, governance, financial, legal, or institutional responsibilities.

(2) Reportable Violations may include, but are not limited to:

(A) misuse, diversion, or improper private use of charitable assets;

(B) private inurement, impermissible private benefit, excess benefit transactions, or undisclosed conflicts of interest;

(C) false, misleading, incomplete, or improper accounting, auditing, financial reporting, tax-exempt reporting, donor reporting, or internal-control practices;

(D) unlawful destruction, alteration, concealment, or falsification of records; and

(E) unlawful discrimination, unlawful preference, unlawful retaliation, or other unlawful conduct in admissions, employment, student assistance, scholarships, programs, services, or institutional operations.

(3) The examples in paragraph (2) are illustrative only and do not limit the types of concerns that may be reported under this policy.

(d) No Retaliation.

(1) EducateONE shall not retaliate against any director, officer, employee, contractor, volunteer, student, family member, program participant, vendor, donor, applicant, visitor, or other person who, in good faith, reports a suspected Violation, participates in a review, or cooperates with an investigation.

(2) Prohibited retaliation includes termination, demotion, suspension, harassment, discrimination, intimidation, adverse assignment, adverse compensation action, exclusion from participation, or other adverse action because of a good-faith report, participation in a review, or cooperation with an investigation.

(3) A person who believes retaliation has occurred may report the retaliation under this policy.

(e) Reporting Violations.

(1) A person may report a suspected Violation to the Compliance Officer.

(2) A person may also report a suspected Violation to the Chairperson of the Board of Directors, or to the Ombuds if EducateONE has established such a role.

(3) A report may be made to the Chairperson of the Board of Directors or the Ombuds when:

(A) the report involves the Compliance Officer;

(B) the Compliance Officer may have a conflict of interest;

(C) the reporting person is uncomfortable reporting to the Compliance Officer;

(D) the Compliance Officer is unavailable; or

(E) the reporting person otherwise believes that reporting to the Chairperson or Ombuds is appropriate.

(4) EducateONE may designate additional persons, offices, systems, or methods for receiving reports.

(f) Anonymous Reports.

(1) Reports may be submitted anonymously.

(2) Anonymous reports may be submitted by postal mail to the Compliance Officer, the Chairperson of the Board of Directors, or the Ombuds if EducateONE has established such a role.

(3) EducateONE may also permit anonymous reports through a web form, third-party reporting system, hotline, electronic submission process, or any other method designated by EducateONE.

(4) Anonymous reports should include enough information for EducateONE to understand and review the concern, but a person is not required to identify themselves in order to make an anonymous report.

(5) EducateONE may review anonymous reports to the extent reasonably possible based on the information provided.

(g) Compliance Officer; Handling Reported Violations.

(1) The Compliance Officer, or a person designated by the Compliance Officer, may review reported Violations and cause appropriate corrective action to be taken when warranted.

(2) The Compliance Officer shall acknowledge receipt of a report within ten business days, but only to the extent the reporting person’s identity is disclosed or a return address or other return contact method is provided.

(3) The reporting person may be informed of the action taken or expected to be taken, to the extent reasonably possible and consistent with privacy, confidentiality, legal, employment, student-record, investigation, and institutional limitations.

(4) If the Compliance Officer is suspected of having committed a Violation, has a conflict of interest, or is otherwise unable to receive or review the report, the report may be made to the Chairperson of the Board of Directors or to the Ombuds if EducateONE has established such a role.

(5) A report involving the Compliance Officer may be reviewed by the Chairperson of the Board of Directors, the Ombuds if EducateONE has established such a role, the Board of Directors, or another person or body designated by the Board of Directors.

(6) For purposes of this policy, the Compliance Officer shall be the role or office designated by EducateONE.

(7) Reports to the Compliance Officer may be sent to EducateONE’s corporate address unless EducateONE designates another reporting address or method.

(h) Accounting, Auditing, and Financial Matters.

(1) Reports concerning accounting, internal accounting controls, auditing, financial reporting, tax-exempt compliance, charitable assets, or similar financial matters may be referred to the Board of Directors or to a committee designated by the Board of Directors.

(2) The Board of Directors or a committee designated by the Board of Directors may address such reports in any lawful manner it determines appropriate under the circumstances.

(3) The Compliance Officer may notify the Executive Director, the Chairperson of the Board of Directors, the Board of Directors, or a committee designated by the Board of Directors of reported Violations, as appropriate under the circumstances.

(i) Confidentiality.

(1) EducateONE shall make reasonable efforts to treat reports made under this policy with appropriate confidentiality.

(2) Confidentiality may be limited when disclosure is necessary or appropriate for review, investigation, corrective action, legal compliance, governance oversight, employment action, student or participant safety, protection of legal rights, response to legal process, communication with legal counsel, accounting or audit review, insurance purposes, or another lawful institutional purpose.

(3) Nothing in this policy requires EducateONE to maintain confidentiality in a manner that would prevent EducateONE from complying with law, protecting persons or property, preserving records, investigating a reported concern, correcting a violation, or carrying out its legal, fiduciary, educational, charitable, or institutional responsibilities.

(j) Periodic Review.

(1) The Board of Directors or a committee designated by the Board of Directors may periodically review this policy and any reporting mechanisms established under it.

(2) A periodic review may consider whether reporting channels, non-retaliation protections, confidentiality practices, and record-preservation practices remain appropriate for EducateONE’s legal, charitable, educational, governance, and institutional needs.

(k) Relationship to Other Requirements.

(1) This policy supplements and does not replace any applicable law, employment policy, student policy, grievance process, complaint process, disciplinary process, reporting obligation, financial-control policy, conflict-of-interest policy, nondiscrimination policy, records-retention policy, contract, grant condition, donor restriction, accreditation requirement, insurance requirement, or other binding obligation.

(2) If another binding requirement imposes stricter requirements for a specific report, person, program, school, institution, contract, grant, or activity, EducateONE shall comply with the stricter requirement for that specific matter.

(l) Interpretation.

(1) This policy shall be interpreted to encourage good-faith reporting, prohibit retaliation, protect lawful institutional discretion, and preserve EducateONE’s ability to respond to reported concerns in a manner appropriate to the circumstances.

(2) Nothing in this policy shall be interpreted to require EducateONE to disclose confidential, privileged, personnel, student, participant, investigative, legal, financial, governance, or institutional information except as required by law or authorized by EducateONE.

(3) If any provision of this policy is determined to be inconsistent with applicable law, the provision shall be interpreted or limited to the extent necessary to comply with law while preserving the maximum lawful discretion of EducateONE.
----Source Note

This policy is adapted from Public Counsel’s Community Development Project, Annotated Form of Whistleblower Policy, including its Form of Whistleblower Policy for a California Public Benefit Nonprofit Corporation. The annotations, explanatory endnotes, optional adoption resolution, and separate acknowledgment form have been omitted from this EducateONE draft. This policy has been modified for EducateONE’s organizational structure, reporting roles, anonymous-reporting approach, policy numbering, source-note placement, and drafting style.

Policies/EducateONE Organizational Policy § 11.6.00. Records Retention and Destruction

2026-07-19T08:56:21Z

Gibran Rahman: Created page with "= Article I. EducateONE Organizational Policies = == Chapter 11. Corporate Records, Minutes, Reports, and Inspection Rights == == EducateONE Organizational Policy § 11.6.00. Records Retention and Destruction. == (a) Purpose. (1) In order to preserve EducateONE’s tax-exempt status, legal compliance, corporate integrity, financial accountability, and institutional flexibility, this policy establishes minimum limits on premature destruction of records and preserves Ed..."

= Article I. EducateONE Organizational Policies =

== Chapter 11. Corporate Records, Minutes, Reports, and Inspection Rights ==

== EducateONE Organizational Policy § 11.6.00. Records Retention and Destruction. ==
(a) Purpose.

(1) In order to preserve EducateONE’s tax-exempt status, legal compliance, corporate integrity, financial accountability, and institutional flexibility, this policy establishes minimum limits on premature destruction of records and preserves EducateONE’s authority to destroy records when retention is no longer required by law, records hold, contract, grant condition, donor restriction, accreditation requirement, insurance requirement, institutional policy, or other binding obligation.

(2) This policy is intended to prevent unlawful, premature, improper, or misleading destruction of records.

(3) This policy is not intended to require permanent retention of records unless permanent retention is required by this policy or another binding requirement.

(b) Scope.

(1) This policy applies to records of EducateONE and any controlled EducateONE institution, school, program, service, activity, or operation, except where a more specific policy applies.

(2) This policy applies to records in any format, including paper records, electronic records, email, messages, databases, cloud files, scans, images, audio, video, metadata, backups, and records maintained through third-party systems.

(3) Student, child, learner, participant, academic, enrollment, attendance, assessment, disciplinary, health, safety, service, accommodation, financial-aid, and related educational records shall be governed by applicable school-specific, institution-specific, program-specific, jurisdiction-specific, or legally required record policies or schedules.

(c) General Prohibition on Premature Destruction.

(1) EducateONE shall not knowingly destroy, delete, alter, conceal, falsify, or fail to preserve a record before the applicable minimum retention period has expired.

(2) EducateONE shall not destroy a record if destruction is prohibited by:

(A) applicable law;

(B) a records hold;

(C) a pending or reasonably anticipated audit, investigation, litigation, claim, demand, subpoena, government inquiry, regulatory review, IRS inquiry, accreditation review, donor dispute, or insurance matter;

(D) a contract, grant condition, donor restriction, accreditation requirement, insurance requirement, institutional policy, or other binding obligation; or

(E) a Board directive or written instruction from an authorized officer.

(3) After the applicable minimum retention period has expired, EducateONE may destroy records in any lawful manner unless continued retention is required under paragraph (2).

(d) Records Hold.

(1) EducateONE shall not destroy, delete, alter, conceal, or fail to preserve records that are subject to a records hold.

(2) A records hold applies when EducateONE knows or reasonably should know that records may be relevant to:

(A) litigation;

(B) a threatened or reasonably anticipated claim;

(C) an IRS inquiry or tax examination;

(D) a government investigation or regulatory review;

(E) an audit;

(F) an accreditation review;

(G) a subpoena, document request, or legal demand;

(H) a donor, grant, contract, insurance, employment, student, or institutional dispute; or

(I) another matter requiring preservation by law or binding obligation.

(3) A records hold remains in effect until released by the Board of Directors, Executive Director, legal counsel, or another authorized person.

(e) Minimum Retention Periods.

(1) EducateONE shall not destroy the following records before the applicable minimum retention period has expired:

(A) Articles of incorporation, bylaws, amendments, corporate registrations, corporate status records, IRS exemption application materials, IRS determination letters, Board minutes, Board resolutions, member records if any, and final corporate governance records: permanent.

(B) Form 990, Form 990-EZ, Form 990-N confirmations, Form 199, RRF-1, and comparable annual tax-exempt, charitable-registration, or public-reporting filings: seven years after filing or due date, whichever is later.

(C) General accounting records, books of account, receipts, invoices, deposits, bank statements, reconciliations, expense records, donor acknowledgments, contribution records, financial statements, and records supporting tax, charitable, or public-reporting filings: seven years after the close of the applicable fiscal year.

(D) Employment tax records: four years after the tax due date or payment date, whichever is later.

(E) Payroll records, wage records, time records, wage statements, and wage-deduction records: four years after creation, final payment, or the end of the applicable pay period, whichever is later.

(F) Personnel records, employment applications, hiring records, promotion records, discipline records, termination records, and employment referral records: four years after creation, receipt, employment action, or separation from employment, whichever is later.

(G) Form I-9 employment eligibility records: the later of three years after the date of hire or one year after employment ends.

(H) Workplace injury and illness records required by occupational safety law: five years after the end of the calendar year covered by the record.

(I) Contracts, leases, memoranda of understanding, vendor agreements, service agreements, insurance policies, grant agreements, and other binding instruments: seven years after expiration, termination, final payment, final report, closeout, or final dispute resolution, whichever is later.

(J) Records of restricted gifts, donor restrictions, grant restrictions, and charitable-use restrictions: seven years after final expenditure, satisfaction of the restriction, final report, closeout, or final dispute resolution, whichever is later.

(K) Records documenting compensation, reimbursement, excess benefit transaction review, conflict-of-interest review, interested transactions, and related Board or committee action: seven years after final action, payment, reimbursement, tax year, or final dispute resolution, whichever is later.

(L) Records documenting student assistance, scholarships, educational grants, awards, discounts, waivers, or comparable assistance administered by EducateONE at the organizational level: seven years after final award, denial, payment, closeout, or last related tax, grant, or reporting year, whichever is later.

(M) Records required for private-school federal tax-exemption nondiscrimination compliance, including records of racial composition, scholarship and loan nondiscrimination evidence, solicitation materials, and admissions, program, and financial-aid materials: three years, unless a longer period applies under this policy or another binding requirement.

(N) Property records, asset records, depreciation records, title records, purchase records, sale records, and disposition records: seven years after disposition of the property and close of the final related tax, audit, insurance, or reporting year.

(O) Claims, complaints, investigations, incidents, disputes, demands, subpoenas, audit records, insurance claims, and legal matter records: seven years after final resolution, unless a longer period is required by law, records hold, insurance requirement, legal counsel, or other binding obligation.

(P) Final versions of policies, guidelines, handbooks, major manuals, and formally adopted institutional standards: permanent or until superseded plus seven years, whichever is longer.

(Q) Drafts, notes, working papers, duplicate copies, convenience copies, transitory records, routine notices, scheduling messages, spam, and informal records not otherwise covered by this policy: when no longer useful, unless subject to a records hold or other binding retention requirement.

(f) Longer Applicable Period Controls.

(1) If more than one retention period applies to a record, EducateONE shall not destroy the record before the longest applicable period has expired.

(2) If applicable law, contract, grant condition, donor restriction, accreditation requirement, insurance requirement, institutional policy, legal counsel instruction, or Board directive requires a longer period than this policy, EducateONE shall follow the longer period.

(g) No Required Retention Beyond Applicable Period.

(1) Nothing in this policy requires EducateONE to retain records after the applicable retention period has expired unless continued retention is required by law, records hold, contract, grant condition, donor restriction, accreditation requirement, insurance requirement, institutional policy, operational need, legal counsel instruction, Board directive, or other binding obligation.

(2) The expiration of a retention period authorizes, but does not require, destruction of records.

(3) EducateONE may determine the method, timing, format, system, and procedure for lawful record destruction.

(h) Electronic Records.

(1) EducateONE shall not destroy, delete, overwrite, migrate, convert, or alter electronic records in a manner that prevents required retention, public inspection, audit review, legal preservation, or production when such retention, inspection, review, preservation, or production is required by law or binding obligation.

(2) EducateONE may use any lawful electronic record system, cloud system, database, backup process, archive method, conversion method, or storage format unless prohibited by law or binding obligation.

(i) Public Inspection Records.

(1) EducateONE shall not destroy records required to be made available for public inspection before the applicable public-inspection period has expired.

(2) EducateONE shall not destroy records required to support its recognition or maintenance of tax-exempt status before the applicable retention period has expired.

(j) Relationship to School and Institution Records.

(1) This policy does not establish a complete student-record, child-record, pupil-record, special-education-record, health-record, public-school-record, preschool-record, university-record, or jurisdiction-specific education-record schedule.

(2) Such records shall be governed by applicable law and any school-specific, institution-specific, program-specific, jurisdiction-specific, accreditation-specific, or funding-specific policy or schedule.

(3) EducateONE shall not destroy such records before the applicable school-specific, institution-specific, program-specific, jurisdiction-specific, accreditation-specific, funding-specific, or legally required retention period has expired.

(k) Responsibility.

(1) The Executive Director or designee may administer this policy.

(2) The Board of Directors may direct retention or destruction of corporate governance records, Board records, committee records, tax-exemption records, and other records within the Board’s authority.

(3) A person who is uncertain whether a record may be destroyed shall not destroy the record until the question is resolved by the Executive Director, legal counsel, the Board of Directors, or another authorized person.

(l) Interpretation.

(1) This policy shall be interpreted to prevent unlawful, premature, improper, or misleading destruction of records while preserving EducateONE’s maximum lawful discretion to determine how records are created, stored, retained, classified, converted, archived, migrated, and destroyed.

(2) This policy shall not be interpreted to require EducateONE to maintain records permanently unless permanent retention is expressly required by this policy or another binding requirement.

(3) If any provision of this policy is determined to be inconsistent with applicable law, the provision shall be interpreted or limited to the extent necessary to comply with law while preserving the maximum lawful discretion of EducateONE.
----Source Note

This policy was developed for EducateONE to establish minimum records-retention and destruction limits while preserving organizational flexibility. The structure, numbering, source-note placement, and drafting approach follow EducateONE Organizational Guideline § 15.4.01. Policy Layout Standard and Style Guide. The policy is written primarily as a prohibition against premature or improper destruction of records, rather than as a comprehensive operational records-management procedure. Student-record details are intentionally reserved for school-specific, institution-specific, program-specific, jurisdiction-specific, accreditation-specific, and funding-specific policies.

References

Internal Revenue Code section 501(c)(3).

Internal Revenue Code section 6001.

Internal Revenue Code section 6104.

Internal Revenue Code section 6501.

Internal Revenue Code section 4958.

Treasury Regulation section 1.6001-1.

Treasury Regulation section 301.6104(d)-1.

Revenue Procedure 75-50.

IRS Form 1023 Instructions.

IRS Form 990 Instructions.

California Corporations Code section 6320.

California Corporations Code section 6333.

California Government Code section 12946.

California Labor Code section 226.

California Labor Code section 1174.

8 C.F.R. section 274a.2.

29 C.F.R. section 1904.33.

EducateONE Organizational Guideline § 15.4.01. Policy Layout Standard and Style Guide.

Policies/EducateONE Organizational Policy § 9.1.00. Executive Compensation

2026-07-19T08:53:14Z

Gibran Rahman: Created page with "= Article I. EducateONE Organizational Policies = == Chapter 9. Compensation, Reimbursement, and Excess Benefit Controls == == EducateONE Organizational Policy § 9.1.00. Executive Compensation. == (a) Policy and Purposes. (1) This is the policy of EducateONE with respect to the review and approval of compensation of its directors, officers, and executive employees. (2) It is the policy of EducateONE that all compensation paid by EducateONE, based upon a review of co..."

= Article I. EducateONE Organizational Policies =

== Chapter 9. Compensation, Reimbursement, and Excess Benefit Controls ==

== EducateONE Organizational Policy § 9.1.00. Executive Compensation. ==
(a) Policy and Purposes.

(1) This is the policy of EducateONE with respect to the review and approval of compensation of its directors, officers, and executive employees.

(2) It is the policy of EducateONE that all compensation paid by EducateONE, based upon a review of comparability information, be fair and reasonable and not excessive.

(3) This policy is intended to supplement and/or implement state and federal laws governing executive compensation that are applicable to nonprofit organizations.

(b) Compensated Individuals Covered by Policy.

(1) This policy provides a procedure for the review and approval of the compensation of Compensated Individuals.

(2) For purposes of this policy, “Compensated Individuals” are:

(A) EducateONE’s directors, officers, Chief Executive Officer, Executive Director, Chief Operating Officer, Chief Financial Officer, Treasurer, General Counsel, and any person with equivalent powers, duties, or responsibilities;

(B) any other disqualified person defined in Internal Revenue Code section 4958; and

(C) officers and key employees whose compensation is or would be reportable on IRS Form 990 or Form 990-EZ.

(c) Governing Body.

(1) The Board of Directors, excluding any director with a conflict of interest with respect to the compensation arrangement at issue, shall approve the compensation of Compensated Individuals.

(2) For purposes of this policy, the Board of Directors acting under this section is referred to as the “Governing Body.”

(d) Approval by Persons Without a Conflict of Interest.

(1) Compensation of Compensated Individuals shall be approved by the Governing Body, provided that persons with a conflict of interest with respect to the compensation arrangement at issue are not involved.

(2) Members of the Governing Body do not have a conflict of interest if they:

(A) are not benefitting from or participating in the compensation arrangement or a family member of any such person;

(B) are not in an employment relationship subject to the direction or control of any person benefitting from or participating in the compensation arrangement;

(C) do not receive compensation or other payments subject to the approval of any person benefitting from or participating in the compensation arrangement;

(D) have no material financial interest affected by the compensation arrangement; and

(E) do not approve a transaction providing economic benefits to any person participating in the compensation arrangement, who in turn has or will approve a transaction providing economic benefits to the member.

(e) Use of Comparability Data.

(1) In reviewing and approving compensation, the Governing Body shall rely upon comparability data to affirmatively determine that the compensation of the Compensated Individual is reasonable to EducateONE based upon information sufficient to determine whether the value of services is the amount that would ordinarily be paid for like services by like enterprises, whether taxable or tax exempt, under like circumstances.

(2) Relevant information includes, but is not limited to:

(A) compensation levels paid by similarly situated organizations, both taxable and tax exempt, for functionally comparable positions;

(B) the availability of similar services in the geographic area of EducateONE;

(C) current compensation surveys compiled by independent firms; and

(D) actual written offers from similar organizations competing for the services of the Compensated Individual.

(3) If EducateONE has average annual gross receipts of less than $1 million for the prior three tax years, the Governing Body will be deemed to have obtained appropriate comparability information if it has information on compensation paid by three comparable organizations in the same or similar communities for similar services.

(f) Compensation to Be Considered by Governing Body.

(1) In determining whether the compensation paid to the Compensated Individual is reasonable, the Governing Body must take into account all benefits paid to the Compensated Individual by EducateONE.

(2) Such benefits include, but are not limited to:

(A) base salary;

(B) fees;

(C) bonuses;

(D) severance payments;

(E) retirement benefits;

(F) fringe benefits; and

(G) payments to welfare benefit plans, including plans providing medical, dental, life insurance, and disability benefits.

(g) Prohibited Excess Compensation and Parachute Payments.

(1) The Governing Body shall not approve:

(A) compensation to any individual in excess of $1 million for a taxable year, including compensation paid by any entity related to EducateONE;

(B) a payment to a highly compensated employee, as defined in Internal Revenue Code section 414(q), that is contingent on the employee’s involuntary separation from EducateONE and where the present value of the payment is equal to or exceeds an amount equal to three times the employee’s average taxable wages; or

(C) any compensation arrangement that would result in an excise tax under Internal Revenue Code section 4960.

(2) If the Governing Body is uncertain whether a proposed compensation arrangement would fall within this subdivision, the Governing Body shall consult with an attorney or tax professional before approving the arrangement.

(3) This subdivision may be amended by the Board of Directors if future circumstances warrant, but unless and until formally amended, the prohibitions in this subdivision shall apply.

(h) Recording Compensation Deliberations.

(1) The Governing Body shall contemporaneously document and maintain records with respect to the deliberations and decisions regarding the compensation arrangement.

(2) The documentation of the decision shall include:

(A) the terms of the compensation;

(B) the date approved;

(C) the names of the members of the Governing Body who were present during the discussion;

(D) the comparability data obtained and relied upon, and how it was obtained;

(E) any action taken with respect to consideration of the compensation by a member of the Governing Body who had a conflict of interest with respect to the compensation;

(F) results of the vote on the compensation arrangement, including approvals and rejections by each voting member;

(G) if the reasonable compensation is higher or lower than the range of comparability data obtained, the basis for the decision; and

(H) if the Governing Body consulted with an attorney or tax professional pursuant to subdivision (g), documentation that such consultation occurred and the Governing Body’s determination that the proposed arrangement does not violate subdivision (g).

(3) Such records of the deliberations and decisions shall be prepared before the later of the next meeting of the Governing Body or sixty days after the decision as to compensation was made.

(4) Such records shall be approved by the Governing Body as reasonable, accurate, and complete within a reasonable time period after preparation.

(i) Schedule of Compensation Deliberations.

(1) The Governing Body’s review and approval of compensation shall occur:

(A) initially upon hiring;

(B) whenever the term of employment, if any, is renewed or extended; and

(C) whenever the compensation is modified.

(2) Separate review and approval shall not be required if a modification of compensation extends to substantially all employees.
----Source Note

This policy is adapted from Public Counsel’s Community Development Project, Annotated Executive Compensation Policy, May 2022, including its “Form of Executive Compensation Policy for a California Nonprofit Public Benefit Corporation.” The annotations and explanatory endnotes have been omitted from this EducateONE draft.

Policies/EducateONE Organizational Policy § 2.9.00. Student Assistance Policy

2026-07-19T08:50:52Z

Gibran Rahman: Created page with "= Article I. EducateONE Organizational Policies = == Chapter 2. Tax-Exempt Status, Charitable Limitations, and Private Benefit Restrictions == == EducateONE Organizational Policy § 2.9.00. Student Assistance Policy. == (a) Purpose. (1) In order to advance equal opportunity, individual merit, educational excellence, lawful standards, student access, and the charitable educational purposes of EducateONE, this policy authorizes EducateONE to provide student assistance i..."

= Article I. EducateONE Organizational Policies =

== Chapter 2. Tax-Exempt Status, Charitable Limitations, and Private Benefit Restrictions ==

== EducateONE Organizational Policy § 2.9.00. Student Assistance Policy. ==
(a) Purpose.

(1) In order to advance equal opportunity, individual merit, educational excellence, lawful standards, student access, and the charitable educational purposes of EducateONE, this policy authorizes EducateONE to provide student assistance in any lawful form that EducateONE determines, in its discretion, supports educational access, participation, achievement, readiness, continuity, safety, family responsibility, or other mission-related purposes.

(2) Student assistance shall be administered according to applicable law and the principle that persons should be considered as individuals, based on lawful and mission-consistent considerations.

(3) Student assistance shall not be administered through unlawful discrimination, racial preference, identity-based entitlement, private inurement, impermissible private benefit, donor earmarking for specific individuals, conflicted control, or any other practice that would jeopardize EducateONE’s charitable, educational, or tax-exempt purposes.

(4) Nothing in this policy shall be interpreted to require EducateONE to use any single method, formula, category, priority, procedure, or selection model for student assistance unless such method, formula, category, priority, procedure, or selection model is required by applicable law, binding grant terms, donor restriction, contract, accreditation requirement, or separate EducateONE policy.

(b) Scope.

(1) This policy applies to student assistance provided by EducateONE, SchoolONE, PreschoolONE, UniversityONE, and any other controlled EducateONE institution, school, program, service, activity, or operation.

(2) For purposes of this policy, “student assistance” means any lawful assistance, support, benefit, aid, payment, waiver, reduction, service, item, or other thing of value provided to or for the benefit of a student, applicant, prospective student, enrolled learner, program participant, family, guardian, or other person within a charitable, educational, or mission-related class served by EducateONE.

(c) Discretion Preserved.

(1) EducateONE may provide student assistance when EducateONE determines, in its discretion, that the assistance advances EducateONE’s charitable, educational, student-support, access, participation, continuity, or mission-related purposes.

(2) EducateONE may consider any lawful and mission-consistent basis for student assistance.

(3) EducateONE is not required to use the same basis, process, amount, condition, duration, priority, or form of assistance for every student, program, institution, funding source, or circumstance.

(4) EducateONE may approve individualized assistance when doing so is lawful, mission-consistent, and not prohibited by this policy.

(d) Charitable and Educational Class.

(1) Student assistance shall be administered for the benefit of a charitable, educational, or mission-related class served by EducateONE.

(2) EducateONE shall not establish or administer student assistance merely to benefit one or more pre-selected individuals for noncharitable private purposes.

(3) Nothing in this policy prohibits EducateONE from providing assistance to a specific individual when EducateONE determines that the assistance furthers EducateONE’s charitable, educational, student-support, access, participation, continuity, or mission-related purposes and is not otherwise prohibited by this policy.

(e) Prohibited Practices.

(1) EducateONE shall not provide, approve, administer, or continue student assistance in a manner that:

(A) results in private inurement;

(B) creates impermissible private benefit;

(C) creates an excess benefit transaction;

(D) is controlled by a donor for the benefit of a specific individual selected by the donor;

(E) is controlled by a conflicted person for the direct or indirect private benefit of that person or a related person;

(F) is administered through unlawful discrimination, unlawful racial preference, unlawful quota, unlawful racial balancing, identity-based entitlement, or other unlawful preference;

(G) is unrelated to EducateONE’s charitable, educational, student-support, access, participation, continuity, or mission-related purposes;

(H) is used as disguised compensation, a rebate, a kickback, a refund, an improper inducement, or an improper private benefit; or

(I) otherwise jeopardizes EducateONE’s charitable, educational, or tax-exempt purposes.

(f) Donor Control.

(1) EducateONE may accept donor-restricted contributions for student assistance when the restriction is lawful, charitable, educational, mission-consistent, and consistent with this policy.

(2) EducateONE shall retain discretion and control over student assistance funds.

(3) EducateONE shall not accept or administer a contribution that requires student assistance to be provided to a specific individual selected by the donor.

(4) A donor recommendation regarding a potential recipient is nonbinding and shall not be treated as a condition of the donor’s contribution.

(g) Conflicts of Interest.

(1) Student assistance decisions shall be administered consistently with EducateONE Organizational Policy § 8.1.00. Conflict of Interest Policy.

(2) A person with a conflict of interest shall not control or approve student assistance that would provide a direct or indirect private benefit to that person or a related person.

(3) The existence of a relationship between a potential recipient and a director, officer, employee, donor, contractor, volunteer, or other person connected to EducateONE does not automatically prohibit assistance if the conflict is disclosed, the conflicted person does not control or approve the assistance, and the assistance is otherwise lawful and consistent with this policy.

(h) No Entitlement Created.

(1) This policy does not create any right or entitlement to student assistance.

(2) EducateONE retains discretion to approve, deny, modify, reduce, suspend, discontinue, renew, condition, or decline student assistance, unless otherwise required by applicable law, binding grant terms, contract, donor restriction, or separate EducateONE policy.

(3) Prior approval of student assistance does not create a right to future assistance.

(i) Records.

(1) EducateONE shall maintain records reasonably sufficient to document that student assistance was approved for a lawful charitable, educational, student-support, access, participation, continuity, or mission-related purpose.

(2) Records shall be maintained in accordance with EducateONE’s records-retention practices and any applicable law, grant term, contract term, donor restriction, accreditation requirement, or program requirement.

(j) Relationship to Other Requirements.

(1) This policy supplements and does not replace any applicable law, grant requirement, contract requirement, donor restriction, accreditation requirement, program rule, financial-control policy, conflict-of-interest policy, nondiscrimination policy, school policy, or institution-specific policy.

(2) If another binding requirement imposes stricter requirements on a specific student assistance fund, program, award, recipient, school, institution, or activity, EducateONE shall comply with the stricter requirement for that specific fund, program, award, recipient, school, institution, or activity.

(k) Interpretation.

(1) This policy shall be interpreted broadly to preserve EducateONE’s ability to provide lawful, innovative, mission-consistent student assistance while maintaining compliance with applicable charitable, educational, tax-exempt, nondiscrimination, private-benefit, conflict-of-interest, donor-restriction, and recordkeeping requirements.

(2) Nothing in this policy shall be interpreted to prohibit EducateONE from providing assistance that is lawful, charitable, educational, mission-consistent, and not otherwise prohibited by this policy.

(3) If any provision of this policy is determined to be inconsistent with applicable law, the provision shall be interpreted or limited to the extent necessary to comply with law while preserving the maximum lawful discretion of EducateONE.
----Source Note

This policy was developed for EducateONE to establish broad authority and legal guardrails for student assistance while preserving institutional flexibility. The structure, numbering, source-note placement, and drafting approach follow EducateONE Organizational Guideline § 15.4.01. Policy Layout Standard and Style Guide. The purpose language is adapted from EducateONE Organizational Policy § 2.8.00. Non-Discrimination Policy. The conflict provisions are aligned with EducateONE Organizational Policy § 8.1.00. Conflict of Interest Policy. This policy is also informed by IRS Form 1023 Schedule H guidance concerning scholarships, fellowships, educational loans, and other educational grants to individuals; IRS guidance concerning individual grants and private benefit; federal civil-rights principles concerning merit, equal opportunity, and unlawful discrimination; and federal education guidance concerning racial preferences in scholarships and other educational programs.

References

Internal Revenue Code section 501(c)(3).

Internal Revenue Code section 4958.

Internal Revenue Code section 4945(g).

Treasury Regulation section 53.4945-4.

IRS Form 1023, Schedule H, Organizations Providing Scholarships, Fellowships, Educational Loans, or Other Educational Grants to Individuals and Private Foundations Requesting Advance Approval of Individual Grant Procedures.

IRS, IRC Section 4945(g) Individual Grants.

Executive Order 14173, Ending Illegal Discrimination and Restoring Merit-Based Opportunity.

Executive Order 14281, Restoring Equality of Opportunity and Meritocracy.

U.S. Department of Education, Dear Colleague Letter: Title VI of the Civil Rights Act in Light of Students for Fair Admissions v. Harvard, February 14, 2025.

EducateONE Organizational Policy § 2.8.00. Non-Discrimination Policy.

EducateONE Organizational Policy § 8.1.00. Conflict of Interest Policy.

EducateONE Organizational Guideline § 15.4.01. Policy Layout Standard and Style Guide.

Policies/EducateONE Organizational Policy § 2.8.00. Non-Discrimination Policy

2026-07-19T08:48:08Z

Gibran Rahman: Created page with "= Article I. EducateONE Organizational Policies = == Chapter 2. Tax-Exempt Status, Charitable Limitations, and Private Benefit Restrictions == == EducateONE Organizational Policy § 2.8.00. Non-Discrimination Policy == (a) Purpose. (1) In order to advance equal opportunity, individual merit, lawful standards, and the charitable educational purposes of EducateONE, this policy shall be administered according to applicable law and the principle that persons should be jud..."

Policies/EducateONE Organizational Policy § 8.1.00. Conflict of Interest Policy

2026-07-18T19:52:04Z

Gibran Rahman: Created page with "= Article I. EducateONE Organizational Policies = == Chapter 8. Conflicts of Interest, Interested Transactions, and Duty of Loyalty == == EducateONE Organizational Policy § 8.1.00. Conflict of Interest Policy. == (a) '''Corporate Status.''' (1) EducateONE is a California nonprofit public benefit corporation. (b) '''Purpose.''' (1) The purpose of the conflict of interest policy is to protect EducateONE's interest when it is contemplating entering into a transaction..."

= Article I. EducateONE Organizational Policies =

== Chapter 8. Conflicts of Interest, Interested Transactions, and Duty of Loyalty ==

== EducateONE Organizational Policy § 8.1.00. Conflict of Interest Policy. ==
(a) '''Corporate Status.'''

(1) EducateONE is a California nonprofit public benefit corporation.

(b) '''Purpose.'''

(1) The purpose of the conflict of interest policy is to protect EducateONE's interest when it is contemplating entering into a transaction or arrangement that might benefit the private interest of an officer or director of EducateONE or might result in a possible excess benefit transaction.

(2) This policy is intended to supplement but not replace any applicable state and federal laws governing conflict of interest applicable to nonprofit and charitable organizations.

(c) '''Definitions.'''

(1) '''Interested Person.'''

(A) Any director, principal officer, or member of a committee with governing board delegated powers, who has a direct or indirect financial interest, as defined below, is an interested person.

(2) '''Financial Interest.'''

(A) A person has a financial interest if the person has, directly or indirectly, through business, investment, or family:

(i) an ownership or investment interest in any entity with which EducateONE has a transaction or arrangement;

(ii) a compensation arrangement with EducateONE or with any entity or individual with which EducateONE has a transaction or arrangement; or

(iii) a potential ownership or investment interest in, or compensation arrangement with, any entity or individual with which EducateONE is negotiating a transaction or arrangement.

(B) Compensation includes direct and indirect remuneration as well as gifts or favors that aren’t insubstantial.

(C) A financial interest isn’t necessarily a conflict of interest.

(D) Under subdivision (d)(2), a person who has a financial interest may have a conflict of interest only if the appropriate governing board or committee decides that a conflict of interest exists.

(d) '''Procedures.'''

(1) '''Duty to Disclose.'''

(A) In connection with any actual or possible conflict of interest, an interested person must disclose the existence of the financial interest and be given the opportunity to disclose all material facts to the directors and members of committees with governing board delegated powers considering the proposed transaction or arrangement.

(2) '''Determining Whether a Conflict of Interest Exists.'''

(A) After disclosure of the financial interest and all material facts, and after any discussion with them, the interested persons shall leave the governing board or committee meeting while the determination of a conflict of interest is discussed and voted upon.

(B) The remaining board or committee members shall decide if a conflict of interest exists.

(3) '''Procedures for Addressing the Conflict of Interest.'''

(A) An interested person may make a presentation at the governing board or committee meeting, but after the presentation, they shall leave the meeting during the discussion of, and the vote on, the transaction or arrangement involving the possible conflict of interest.

(B) The chairperson of the governing board or committee shall, if appropriate, appoint a disinterested person or committee to investigate alternatives to the proposed transaction or arrangement.

(C) After exercising due diligence, the governing board or committee shall determine whether EducateONE can obtain, with reasonable efforts, a more advantageous transaction or arrangement from a person or entity that would not give rise to a conflict of interest.

(D) If a more advantageous transaction or arrangement isn’t reasonably possible under circumstances not producing a conflict of interest, the governing board or committee shall determine by a majority vote of the disinterested directors whether the transaction or arrangement is in EducateONE's best interest, for its own benefit, and whether it is fair and reasonable.

(E) In conformity with the above determination, it shall make its decision as to whether to enter into the transaction or arrangement.

(4) '''Violations of the Conflict of Interest Policy.'''

(A) If the governing board or committee has reasonable cause to believe a member has failed to disclose actual or possible conflicts of interest, it shall inform the member of the basis for such belief and afford the member an opportunity to explain the alleged failure to disclose.

(B) If, after hearing the member's response and after making further investigation as warranted by the circumstances, the governing board or committee determines the member has failed to disclose an actual or possible conflict of interest, it shall take appropriate disciplinary and corrective action.

(e) '''Records of Proceedings.'''

(1) The minutes of the governing board and all committees with board delegated powers shall contain:

(A) the names of the persons who disclosed or otherwise were found to have a financial interest in connection with an actual or possible conflict of interest;

(B) the nature of the financial interest;

(C) any action taken to determine whether a conflict of interest was present;

(D) the governing board's or committee's decision as to whether a conflict of interest in fact existed;

(E) the names of the persons who were present for discussions and votes relating to the transaction or arrangement;

(F) the content of the discussion, including any alternatives to the proposed transaction or arrangement; and

(G) a record of any votes taken in connection with the proceedings.

(f) '''Compensation.'''

(1) A voting member of the governing board who receives compensation, directly or indirectly, from EducateONE for services is precluded from voting on matters pertaining to that member's compensation.

(2) A voting member of any committee whose jurisdiction includes compensation matters and who receives compensation, directly or indirectly, from EducateONE for services is precluded from voting on matters pertaining to that member's compensation.

(3) No voting member of the governing board or any committee whose jurisdiction includes compensation matters and who receives compensation, directly or indirectly, from EducateONE, either individually or collectively, is prohibited from providing information to any committee regarding compensation.

(g) '''Annual Statements.'''

(1) Each director, principal officer, and member of a committee with governing board delegated powers shall annually sign a statement which affirms such person:

(A) has received a copy of the conflict of interest policy;

(B) has read and understands the policy;

(C) has agreed to comply with the policy; and

(D) understands EducateONE is charitable and in order to maintain its federal tax exemption it must engage primarily in activities that accomplish one or more of its tax-exempt purposes.

(h) '''Periodic Reviews.'''

(1) To ensure EducateONE operates in a manner consistent with charitable purposes, and doesn't engage in activities that could jeopardize its tax-exempt status, periodic reviews shall be conducted.

(2) The periodic reviews shall, at a minimum, include the following subjects:

(A) whether compensation arrangements and benefits are reasonable, based on competent survey information, and the result of arm's length bargaining; and

(B) whether partnerships, joint ventures, and arrangements with management organizations conform to EducateONE's written policies, are properly recorded, reflect reasonable investment or payments for goods and services, further charitable purposes and don't result in inurement, impermissible private benefit, or in an excess benefit transaction.

(i) '''Use of Outside Experts.'''

(1) When conducting the periodic reviews, as provided for in subdivision (h), EducateONE may, but need not, use outside advisors.

(2) If outside experts are used, their use shall not relieve the governing board of its responsibility for ensuring periodic reviews are conducted.
----'''Source Note'''

This policy is adapted from the IRS Appendix A sample conflict of interest policy for Form 1023, with hospital-specific provisions omitted because they do not apply to EducateONE. It has been converted to the EducateONE policy numbering and formatting standard.

User:Gibran Rahman

2026-07-18T18:57:33Z

Gibran Rahman: Fixed some typos.

13 years old from Bangladesh, lead Intern at EducateOne and Executive Assistant to the Principal.
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User:Gibran Rahman

2026-07-18T18:56:10Z

Gibran Rahman: I wrote about myself.

Lead Intern at EducatiOn and Executive Assistant to the Principal, based in Bangladesh. Dedicated to operational excellence, leadership development, and supporting institutional growth through high-level administrative management.
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