The Innocent Justice Foundation Performance Audit
Lisa Andaleon Derek Floyd Kaila Mangrum Justin Schaberg Kyra Wilson
University of San Diego LEAD 501: Nonprofit Sector Management Fundamentals Professors Pat Libby and Mary McDonald Fall 2011
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Established in 2008, The Innocent Justice Foundation (TIJF) helps rescue children from sexual abuse by supporting law enforcement agencies nationwide that investigate Internet crimes against children. One of TIJF’s core programs, present since its founding, is a free grant-writing service that assists any law enforcement agency nationwide that conducts child pornography investigations; specifically, TIJF seeks funding on the law enforcement agency’s behalf to procure updated technology solutions to aid them with their child pornography investigations. By 2009, however, TIJF received a $500,000 federal grant from the United States Department of Justice (DOJ), Office of Juvenile Justice and Delinquency Prevention (OJJDP), to produce and deliver a national mental health and wellness training for individuals exposed to child pornography through their course of work. This training, called Supporting Heroes In Foundational mental health Training (SHIFT), has now become TIJF’s core program, in addition to the free grant-writing. Given the rapid growth TIJF experienced in such a short period of time, the President and CEO (CEO) requested a performance audit be conducted to help the organization benchmark its current procedures against national best practice standards so that she and the Board would have a frame of reference as they chart future growth. The consulting team (the team) reviewed the Standards for Excellence (Standards), BoardSource and the Better Business Bureau (BBB) ethics and accountability guidelines. The team selected Standards (1998-2004) as the basis for the performance audit because of its specific and comprehensive guidelines that would enable TIJF to establish a solid foundation of policies and procedures from which the organization can build upon. Furthermore, the
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matrix format of the fifty-five standards supporting the guiding principles provides a straightforward means to present audit findings to TIJF. To prepare audit findings, the team utilized several tools and resources. The team reviewed many TIJF documents including: Board Minutes; Bylaws; the Employee Handbook; Operations Manual; Board Policies Manual; sample donor gift acknowledgement letters; program evaluation tools; public educational materials; TIJF websites and social media; IRS Form 990 for 2008-2010; audited financial statements; and other internal accounting records. The team also conducted independent interviews with the CEO, two local Board members, and staff to encourage and promote transparency and candid dialogue. Finally, the team took what it learned from the research and interviews and collectively decided what resources would be most helpful to recommend to the organization. Because TIJF is in the building phase of its lifecycle, there were many areas where the team made recommendations to help the organization move to the next stage of development. The following report presents these suggestions and best practices examples. A flash drive with all documents included in the report is also provided. The team congratulates TIJF on its significant progress in establishing best practices operations since its founding in 2008. Of the fifty-five standards outlined, the performance audit revealed that TIJF was fully compliant with 27 percent, partially compliant with 42 percent and not compliant with 25 percent, totaling 69 percent overall in full or partial compliance.
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Mission and Program Mission The mission statement of a nonprofit organization defines the organization’s purpose and is essential to operating an efficient organization (Standards, 2007d). TIJF has a mission statement that partially complies with Standards (1998-2004). Because of TIJF’s rapid growth, one of its major programs, SHIFT, is not clearly reflected in the stated mission. Standards (2007d) require that an organization’s mission formally state the organization’s purpose as defined and approved by the board. A review of the Board Minutes show, however, that TIJF’s Board has not recently reviewed the mission, especially in relation to the adoption of its federally funded core program SHIFT. In order to reach full compliance, TIJF’s Board should review and approve a mission statement that accurately reflects TIJF’s current programmatic activity, including SHIFT. During an interview with the Board, the team learned that the Board would undergo a strategic planning process in 2012 and review the mission and current programs. A concise mission statement should communicate: why you exist, how you do it, what you value and who you serve (Libby, 2007). The team provided sample documents for developing mission and values statements, as well as ‘best practice’ guides with exemplary examples of mission and values statements (Section 1A1). Program Evaluation TIJF does a thorough evaluation of its government funded SHIFT Wellness program, including: pre- & post- tests, attendee evaluations, a six month follow up survey, as well as a cost per student analysis. For the free grant writing program, TIJF receives a narrative and
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financial report detailing the impact in the communities from the law enforcement agencies for which TIJF procures high technology equipment and/or software. The team however, found no evidence of an evaluation system for TIJF’s public education programs, and therefore we find TIJF in partial compliance with this standard. Standards (2007k) explain that a nonprofit should both quantitatively and qualitatively evaluate all of its projects and programs in relation to its mission to address programmatic efficiency and effectiveness and measure outcomes of programs in relation to cost. The team notes that once the Board has updated, reviewed and approved the mission statement, all current and future programs should then be evaluated in relation to the mission. We have included best practice program evaluation tools and models for review (Section 1C1). Program Service TIJF works hard to ensure program participant satisfaction and due to the sensitive nature of the material (i.e., mental health training), confidentiality is honored to the utmost degree. There was, however, no evidence of a formal grievance procedure to address complaints and dissatisfaction by program participants, as recommended by Standards (2007l); therefore, the team found TIJF in partial compliance with this standard. To achieve full compliance, the team recommends TIJF implement a grievance policy for program participants. We have included two Standards (2007l) sample grievance policies, as well as five BoardSource sample complaint policies that can be modified to be applied to program participants (Section 1D1). Governing Body
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A strong and engaged nonprofit board is crucial to the efficient operation of a nonprofit, as the board has the legal responsibility to ensure the organization’s health (Standards, 2007h). According to Standards (2007b), the role of the board is to determine the mission of the organization, establish management policies and procedures, assure adequate human and financial resources, and actively monitor the organization’s financial and programmatic performance. This section will focus on the governing duties of the board. TIJF is an emerging organization and that is reflected in the Board’s development. The team reviewed the Board minutes, Bylaws and Board Policies Manual, interviewed the CEO and two active Board Members, and compared the team’s finding to the eight individual principles outlined in Standards (1998-2004). The team found TIJF either partial or not in compliance with thirtyseven of the Standards. This can be typical of small nonprofits just starting out. To help the Board prioritize, the team has identified the top three principles that are the highest priority to address: financial reporting and policies, developing short- and long-term plans for the organization, and increasing the capacity of the Board. These priorities will help the Board set goals, give the CEO guidance, and will support, through increased capacity, the development of the needed skills and resources to achieve them. Board Responsibilities A primary responsibility of the board is to engage in short-term and long-term planning. It is vital that the board engage in the planning process because it gives the staff and board clear goals, offers an opportunity to reflect on core issues, and stimulates teamwork and a sense of shared mission (Standards, 2007h). The CEO has a five to ten year
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plan and a set of strategic goals outlined in the original Business Plan written in 2008, and updated January 10, 2010. According to the Board minutes, however, this Plan has not been reviewed or agreed upon by the Board. Most nonprofit strategic plans only look three to five years in the future because of the rapidly changing economic environment (Standards, 2007h). This is especially true for organizations that are in early stages of development and may need to adapt as they grow. During our interview, Board members said that the Board is preparing to conduct a strategic planning process starting in January 2012. To assist in the process, we have included a sample strategic plan from another organization for review. The nonprofit Metro (Section 2A1) strategic plan is a good example because it has the elements of a strong strategic plan: development of a stakeholder evaluation that was then charted in the Strengths, Weaknesses, Opportunities and Threats or S.W.O.T. analysis. Metro’s S.W.O.T. analysis then lead to clearly outlined problems and solutions on how to achieve the goals set forth in the strategic plan. To have the time to discuss the short- and long-term plans for the organization, boards often hold retreats. We have also included a paper, entitled, “To Go Forward, Retreat” (Hughes. n.d.) because it gives a good overview of the strategic planning process and has basic worksheets to help the Board and staff prepare for and get the most out of a retreat (Section 2A1). Board Composition Board members should be personally committed to the mission of the organization and have skills that help the organization accomplish the mission (Standards, 2007a). TIJF’s board is still in the early stages of development and this is reflected in the Board’s composition
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and work. It is clear that there are Board members who are committed to the organization as demonstrated by their efforts to fundraise on behalf of TIJF. There is, however, inconsistency in some Board members attendance at meetings. This can make it difficult for the Board to conduct its business. In particular, at the July 2011 Board meeting, too few disinterested Board members were present to vote on the CEO’s compensation plan. Since TIJF has Board members outside of the San Diego Region, we have included a BoardSource document (Section 2B1) on how to get the best from virtual attendance to make sure the Board is best utilizing its members’ service. The team suggests that the Board focus on increasing the number of members on the Board. The Board showed movement in the right direction by voting at the September 2010 meeting to increase the size of the Board from five to nine members. This change still needs to be updated in the Bylaws (2008), which currently state that the Board should have no more than five members. As the Board looks to expand in the coming year, it is important they keep in mind the diversity of the Board. A diverse board can mean very different things to different nonprofits. As part of the strategic planning process, the Board should have a discussion about what diversity means and produce a written policy. We have attached sample worksheets to help guide the conversation in the appendix (Section 2B5). Conflict of Interest Standards (1998-2004) require nonprofits to have a written conflict of interest policy. This policy should be applicable to all board members, staff, and volunteers who have significant independent decision making authority regarding the resources of the
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organization (Standards, 2007c). The purpose of the policy is to ensure that all individuals act in the best interest of the organization and its constituents. The team reviewed TIJF’s conflict of interest policy, adopted from the IRS website, and recommends the organization require signatures from all involved volunteers and staff to achieve full compliance. For sample signature pages, see Section 3B1 in the Appendix. In addition, the conflict of interest policy must include a statement for the volunteers, paid staff, and family members to disclose any known interest that the individual has in any business entity which transacts business with the organization (Standards, 2007c). The team found no evidence of a disclosure statement. To be fully compliant, the team recommends adopting a disclosure statement along with the confidentiality policy, and requires that all Board members, staff, and volunteers who have significant independent decision making authority regarding the resources of the organization, sign and date the disclosure statement annually or as needed if a known disclosure arises. Sample disclosure agreements are included in Section 3B2 of the Appendix. Human Resources TIJF has a written Employee Handbook (2011) detailing the organization’s personnel policies and procedures that is partially compliant with best practices. The Employee Handbook (2011) covers Standards’ (1998-2004) recommended basic elements of the employment relationship, including: working conditions; employee benefits, including paid time off (PTO); workers’ compensation; confidentiality of employee, client and organization records and information; and employee growth and development. To bring the Employee Handbook (2011) to full compliance, the team recommends the following:
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Standards (2007j) strongly recommends that organizations should state in the very
beginning of their handbook that the policies contained within it “do not create an express or implied contract” (p 2). While TIJF has an employment at will statement, it is located toward the end of the Employee Handbook (2011) on page 22 and should be placed prominently in the document to be effective. Therefore, the team suggests TIJF move the disclaimer to the beginning of the handbook (2011), immediately following the letter of introduction from the CEO. 2.
TIJF has researched and implemented a best practice employee evaluation system that
it adapted from an applied project for Jewish Family Service retrieved from the University of San Diego’s Institute for Nonprofit Education and Research Best Practice Library. The team found evidence that the first TIJF annual employee review using this employee development plan was conducted in July 2011. A general description of TIJF’s Employee Development Plan process and timeline should be included in the next revision of the Handbook to comply with Standards (2007j) best practices. 3.
Standards (2007j) recommends including a policy on hiring and firing of employees in
an employee handbook. While TIJF has both a Hiring Employees and Terminating Employees policy, those policies can only be found in the TIJF Operations Manual (2010c, pp. 8-9). The team recommends moving these policies to TIJF’s Employee Handbook (2011). 4.
Standards (2007j) also recommends instituting a grievance procedure to ensure that
all staff, volunteers, and program recipients can voice concerns or complaints without being penalized. The current TIJF handbook (2011) does not include a grievance procedure policy; however we have included examples in the appendix (Section 4A1).
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The team has also included the table of contents of Standards’ (2007j) Model Employee Handbook for review to see how a best practice handbook might be laid out and what might be included, as well as additional documents TIJF might find useful (Section 4A1). Standards (1998-2004) also recommend that the Board periodically review and approve the personnel policies. The team found TIJF compliant with this practice. The September 8, 2010 Board Minutes show that the Board reviewed and approved policies and procedures including the Operations Manual, Independent Contractor Agreement, and Employee Handbook. However, the Board Policies Manual (2010), Paragraph 4.6 Staff Compensation, states that “The CEO shall (a) develop and maintain an Employee Handbook that is reviewed annually (if budget allows) by competent legal counsel and (b) provide copies of this manual to the board for information around April 1 of each year” (p. 19). To fully comply with Standards (2007j), however, the team recommends that this language change to explicitly state that the Board shall annually review and approve the Employee Handbook, keeping in mind that currently the CEO and Board Treasurer are interested parties and should recuse themselves from any voting on employee policies. Volunteers Standards (2007o) states that volunteers hold an important and critical role with nonprofits and should be included in personnel policy procedures as well. While TIJF does not currently engage volunteers in daily operations, Standards (2007o) endorses nonprofits to have policies and procedures in place for volunteers, regardless of how frequently or in what capacity volunteers are utilized. Standards (2007o) also recommend volunteer policies and procedures addressing the following at minimum: initial assessment and screening;
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assignment to, and training for appropriate work responsibilities; ongoing supervision and evaluation; and opportunities for advancement. The team has included several sample volunteer manuals and templates to assist TIJF in bringing this standard to full compliance (Section 4A2). Employee Orientation Standards (2007j) recommend that new employees should receive an orientation to introduce them to the organization, its policies and procedures, as well as the employee’s job description and responsibilities. New employees should also sign a form acknowledging that they were given copies of the Employee Handbook (2011) and were properly oriented to the organization (Standards, 2007j). The team found TIJF partially compliant with this standard as there was no evidence of a written job description for a recently hired employee. Standards (2007j) recommend that every position have a written job description and that the job description is reviewed during a new hire’s orientation processes, as well as reviewed and amended annually as part of the employee’s performance evaluation. To strengthen TIJF’s orientation process, the team included a comprehensive New Employee Orientation Checklist that could be adapted and used to ensure all areas are fully compliant during employee orientation (Section 4C1). Financial and Legal All nonprofits must practice sound financial management and comply with many diverse legal and regulatory requirements (Standards, 2007). When the team interviewed members of the TIJF Board, it was clear that finance and legal was one of their highest priority areas for development. Compliance with financial reporting and accountability can
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positively and directly affect other areas of business (i.e. fundraising and development). TIJF shows evidence of independent audits for 2008, 2009 and 2010, yet Board approval of the audits is not documented in the Board minutes. Further, the team found no evidence of regular, meaningful financial reporting to the Board, or that comprehensive financial policies and procedures are in place. The team rated TIJF not in compliance with this standard and recommends TIJF review sample documents provided in the Appendix (Section 5A2). Budgets TIJF has not developed formal working operating or capital budgets since its founding in 2008. The team reviewed the Board Policies Manual which contains guidelines and references to its budgeting, (Paragraphs 3.6(d), 4.4.3.2, 4.4.3.4, 5.2.1) and the Business Plan (January 10, 2010) which includes certain funding and revenue goals. The CEO indicated that the government grant from the Office of Juvenile Justice and Delinquency Prevention functions as their operating budget. According to Standards, this practice does not comply, however, minutes from several Board Meetings (March, 2010, November, 2010, March, 2011, May, 2011 and July, 2011) show evidence of discussion around creating a separate operating budget. The team reviewed the SHIFT, ICAC, and ARRA Recovery Grant budgets. While these documents do compare actual costs to budgets for various components of each grant, there is no formal, consolidated budget for the organization as a whole and no ongoing comprehensive comparison of actual financial results compared to budget. The team recommends that TIJF develop an operating budget for FY12 using best practices standards provided (Section 5A1) as part of the strategic planning process slated for January 2012. This budget can be used as a baseline for any projections included in the strategic plan.
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Financial Reporting and Policies TIJF regularly presents financial information to the Board. The format of the presentation is varied, and a trial balance listing of expenses appears to be the format most frequently used. TIJF converted accounting software from Quicken to QuickBooks in early 2009, and presented the Fiscal Year 2008 financials using the new software’s income statement report which provides a more common, and recommended view. There is however, no comparison to budget, balance sheet, or detailed income statement that shows each entry comprising the income statement account totals. The team recommends a monthly or quarterly financial package for the Board containing these three reports. This would facilitate timely and meaningful review by the Board. Note the Audits prepared for 2008, 2009 and 2010 present best practices financial statement formats, however there is no evidence that they have been formally approved by the Board. Whistleblower Protection Policy Paragraph 5.5.2 of the TIJF Board Policies Manual, “Internal Compliance,” is the only reference to a whistleblower protection policy. It is, however, indirect in that it just states that the CEO “shall meet all requirements for complying with federal, state, or local laws and regulations” (Board Policies Manual 2010). It refers to a list of these regulations but the list does not exist. The team recommends immediate development and Board approval of a formal whistleblower protection policy. Sample policies are provided in Section 5A4 of the Appendix. TIJF has established several financial policies, mostly in the area of internal controls and purchasing. The policies are located in four (4) different documents – Operations
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Manual, Board Policies Manual, Bylaws and Employee Handbook. Best practices policies for investment of assets are missing and there is no policy for unrestricted current net assets. The team recommends development of a centralized financial policies manual that should be approved by the Board. The Board should also approve each subsequent addition or revision to these policies. Having all financial policies in one place will help the Board members, staff, and outside advisors easily and efficiently understand the financial infrastructure of TIJF and thus facilitate sound financial management. Financial policies from the centralized manual can be referenced in other TIJF procedure documents and manuals as required. Legal A formal process for ensuring compliance with all applicable laws has not yet been established by TIJF. The CEO informally monitors compliance; however, there is no evidence of reports that have been made to the Board based on Board minutes. To be compliant with this standard, the team recommends that TIJF go through the applicable sections of the attached best practices (Section 5B1). Results, as well as a plan to bring TIJF into compliance, should be presented to the Board for approval. Samples of document retention and destruction policies are provided in the Appendix (Section 5B1). In addition to legal compliance and accountability, Standards suggests periodic assessments of the organization’s need for insurance. TIJF is in full compliance with best practices regarding insurance. Openness Since nonprofits are supported by the public and also operate for public benefit, Standards (2007i) recommend the organization makes available to the public its information regarding mission, program activities, and finances. Standards (2007i) also recommend a
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nonprofit should be accessible and responsive to members of the public who express interest and request information from or about the organization. The annual report of a nonprofit organization functions as a snap shot of the organization’s mission, program activities, financial reports, board of directors, and managing staff. Generally, the annual report is useful for giving the public an idea of what the organization does, but it also can be helpful in recruiting board members, volunteers, community partners and fundraising (Standards, 2007i). Currently, TIJF does not have an annual report and does not fall in compliance with this standard. Examples of comparable annual reports as well as a helpful guide to creating one are provided in Section 6A1 of the Appendix. Fundraising Many of TIJF’s fundraising policies and procedures are in their developing stages and fall in partial compliance in reference to the Standards. After interviewing the CEO and members of the Board, the organization’s aspiration to enhance and diversify the overall fundraising practices became clear to the team. Most of the funding TIJF receives is from government grants. If that were to end, the organization would likely shut down. The team recommends that TIJF consider implementing the necessary policies to create a solid foundation for current, potential donors, and community partners to gain more confidence, transparency, and ultimately increased funding to their organization. Standards (2007g) recommend that over a five-year period, a nonprofit should realize revenue from fundraising and other development activities that are at least three times the amount spent on conducting them. TIJF has not been in business for the minimum requested 5
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years, but based on financial reports and Board minutes, TIJF shows full compliance in exceeding this ratio. Because it is not clear to the team that organization reports actual fundraising expenses accurately on the Form 990, the team gave a partial compliance rating for this Standard. In the Board Policies Manual (2010a) it states the CEO will develop a donor bill of rights. The team found no evidence of a Board approved policy to honor known intentions of the donor and recommends reviewing attached documents in Section 7B1. The Standards (2007g) recommend the organization respects the privacy wishes of the donor and to have policies in place to allow for anonymity if they choose. TIJF honors the wishes of a donor or potential donor to remain anonymous but does not include the option on either the electronic giving site or gift return envelope (TIJF website). The team recommends TIJF to include a clearly stated option to remain anonymous for the donor or potential donor on all future giving options (Section 7B2). The team provided sample donor privacy policies to review and encourages TIJF to include in their fundraising practices to achieve full compliance in donor relationships (Section 7B1). Although TIJF mentions gift acceptance procedures in their Board Policies Manual, a ‘board approved’ gift acceptance policy does not exist in regards to fundraising practices, development, and donor relations. According to Standards (2007n), an organization should have policies in place to govern the acceptance and disposition of charitable gifts that are received in the course of its regular fundraising activities. The team suggests TIJF consider reviewing and implementing a version of one of the attached policies provided in Section 7C1. Finally, to further strengthen TIJF’s fundraising principles, the team suggests reviewing policies provided in the Appendix (Section 7D3) to address the organization’s
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control over staff volunteers, consultants, contractors, other organizations, or businesses that are soliciting contributions on behalf of the organization. Without the appropriate policies in place, a nonprofit runs the risk of being misrepresented by individuals or partner organizations who solicit funds on their behalf. Public Affairs & Public Policy Public education and public policy advocacy are central to TIJF’s mission as stated in the Board Policy Manual (pp. 4-5) and on the organization’s website. The organization has elected for the expenditure test under Internal Revenue Service section 501h and engages in direct and grassroots lobbying in the areas of law enforcement support and the prevention of child sexual abuse. While TIJF’s various policy manuals (e.g., Board Policies Manual, Employee Handbook, and Operations Manual) all include best practice lobbying policies and descriptions of the organization’s advocacy agenda, the team found no evidence of a Board approved advocacy policy defining the process by which TIJF determines positions on specific issues (Standards, 1998-2004). The team has included sample advocacy policies for review to bring full compliance to this standard (Section 8A1). The team found TIJF fully compliant with Standard 8B1, which ensures the educational materials distributed to the public or media are factually accurate. TIJF’s materials are based on peer-reviewed research and the organization has an Advisory Board comprised of national experts in the fields of law enforcement, mental health, and child sexual abuse whose purpose includes ensuring the organization uses current data and research in all of its presentations. In addition, Standards (1998-2004) states that a nonprofit’s public policy advocacy efforts must be accomplished in a strictly nonpartisan manner. The Board Policy Manual
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(2010) clearly outlines that TIJF’s activities shall be conducted in a nonpartisan manner. The team found no evidence contrary to this statement, and therefore finds TIJF in full compliance with this Standard.
Conclusion Upon completion of the performance audit for TIJF, the team found the Standards for Excellence evaluation model (1998-2004) an exemplary tool for determining the ethics and accountability for a nonprofit organization. The team really commends TIJF for the extraordinary work it has undergone to ensure it is meeting best practice standards to the best of its ability, and we hope this document will serve as a valuable reference guide as the CEO and Board embark on a strategic planning process in 2012. We look forward to seeing their continued growth and success.
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References Grace, K. S. (1997). Beyond Fund Raising: New Strategies for Nonprofit Innovation and Investment. New York, NY: John Wiley & Sons, Inc. Hughes, S. R. (n.d.). To Go Forward, Retreat. BoardSource. Retrieved from http://www.boardsource.org Libby, P. (2007). Definition of mission/vision statements. University of San Diego. San Diego, CA. Standards for Excellence Institute. (1998-2004). The standards for excellence: An ethics and accountability code for the nonprofit sector. Baltimore, MD. Standards for Excellence Institute ®. (2007a). The standards for excellence: Board composition. Baltimore, MD. Standards for Excellence Institute ®. (2007b). The standards for excellence: Conduct of the board. Baltimore, MD. Standards for Excellence Institute ®. (2007c). The standards for excellence: Conflict of interest. Baltimore, MD. Standards for Excellence Institute ®. (2007d). The standards for excellence: Developing and revising a mission statement. Baltimore, MD. Standards for Excellence Institute ®. (2007e). The standards for excellence: Employment of fundraising personnel and engagement of fundraising consultants. Baltimore, MD. Standards for Excellence Institute ®. (2007f). The standards for excellence: Fundraising costs. Baltimore, MD.
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Standards for Excellence Institute ®. (2007g). The standards for excellence: Fundraising practices. Baltimore, MD. Standards for Excellence Institute ®. (2007h). The standards for excellence: Ongoing planning by the board. Baltimore, MD. Standards for Excellence Institute ®. (2007i). The standards for excellence: Openness. Baltimore, MD. Standards for Excellence Institute ®. (2007j). The standards for excellence: Personnel policies and employee orientation. Baltimore, MD. Standards for Excellence Institute ®. (2007k). The standards for excellence: Program evaluation. Baltimore, MD. Standards for Excellence Institute ®. (2007l). The standards for excellence: Program service. San Diego, CA Standards for Excellence Institute ®. (2007m). The standards for excellence: Public policy advocacy promoting public participation. Baltimore, MD. Standards for Excellence Institute ®. (2007n). The standards for excellence: Solicitation and acceptance of gifts. Baltimore, MD. Standards for Excellence Institute ®. (2007o). The standards for excellence: Volunteer policies. Baltimore, MD. The Innocent Justice Foundation. (n.d.). Website. Retrieved from www.innocentjustice.org The Innocent Justice Foundation. (2008). Bylaws. Encinitas, CA. The Innocent Justice Foundation. (2010a). Board Policies Manual. Encinitas, CA. The Innocent Justice Foundation. (2010b). Business Plan. Encinitas, CA.
THE INNOCENT JUSTICE FOUNDATION PERFORMANCE AUDIT The Innocent Justice Foundation. (2010c). Operations Manual. Encinitas, CA. The Innocent Justice Foundation. (2011). Employee Handbook. Encinitas, CA.
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