Legal & Policies

Effective Date: January 1, 2025 | Last Updated: April 1, 2026

I. Purpose & Governance Structure

The Board of Directors (the "Board") of Eagle-X Impact Foundation (the "Organization") is responsible for the overall governance, strategic direction, financial oversight, and legal compliance of the Organization. This policy establishes the structure, roles, responsibilities, and operating procedures of the Board to ensure effective stewardship and accountability in service of our mission to support postpartum mothers through the Wings of Care initiative.

II. Board Composition

A. Size: The Board shall consist of no fewer than 3 and no more than 15 members as specified in the Organization's Bylaws.

B. Diversity & Inclusion: The Board shall strive to reflect the diversity of the communities we serve, including but not limited to diversity in race, ethnicity, gender, age, professional background, and lived experience. Priority consideration will be given to individuals with expertise in:

• Nonprofit management and governance
• Healthcare, mental health, or social services
• Finance, accounting, or audit
• Legal, compliance, or risk management
• Fundraising and donor relations
• Marketing, communications, or public relations
• Postpartum care or maternal health advocacy

C. Independence: A majority of Board members shall be independent, meaning they do not receive compensation from the Organization (other than reimbursement of reasonable expenses) and have no material financial interest in the Organization's transactions.

III. Board Member Selection & Terms

A. Nomination Process: The Board Governance Committee (or the full Board if no committee exists) shall identify, evaluate, and nominate candidates for Board membership based on:

• Alignment with the Organization's mission and values
• Demonstrated commitment to service and philanthropy
• Professional expertise and network connections
• Ability to contribute time, talent, and financial support
• Completion of background check and reference verification

B. Election: New Board members shall be elected by a majority vote of the current Board at a regular or special meeting.

C. Term Length: Board members serve three-year terms and may serve up to two consecutive terms (six years total). After a one-year break, former members may be re-elected to the Board.

D. Onboarding: New Board members shall receive:

• Comprehensive orientation to the Organization's history, programs, and financials
• Copies of Bylaws, policies, strategic plan, and recent meeting minutes
• Training on fiduciary duties, conflict of interest, and legal obligations
• Introduction to staff, fellow Board members, and key partners

IV. Board Member Responsibilities

Each Board member has a fiduciary duty to act in the best interests of the Organization and is expected to:

A. Duty of Care: Exercise reasonable diligence in decision-making by:

• Attending at least 75% of Board meetings (in-person or virtually)
• Reviewing meeting materials in advance
• Actively participating in discussions and votes
• Staying informed about the Organization's programs and finances

B. Duty of Loyalty: Act in the Organization's best interests by:

• Avoiding conflicts of interest and disclosing potential conflicts
• Maintaining confidentiality of sensitive information
• Putting the Organization's needs above personal interests
• Supporting Board decisions once made, even if personally dissenting

C. Duty of Obedience: Ensure compliance with laws and mission by:

• Ensuring activities align with the Organization's tax-exempt purpose
• Monitoring compliance with federal, state, and local regulations
• Reviewing and approving major contracts, policies, and expenditures
• Overseeing financial audits and IRS Form 990 filing

D. Financial Contribution: Board members are expected to make personally meaningful annual financial contributions to the Organization (give or get) and actively participate in fundraising efforts.

E. Ambassador Role: Serve as advocates by:

• Promoting the Organization's mission in the community
• Making introductions to potential donors, volunteers, and partners
• Attending and supporting Organization events
• Providing testimonials and endorsements when appropriate

V. Board Officers

The Board shall elect the following officers annually:

A. Board Chair: Presides over Board meetings, sets agendas (with Executive Director), serves as primary liaison to the Executive Director, represents the Board publicly, and ensures Board effectiveness.

B. Vice Chair: Assumes Chair responsibilities in their absence, assists with strategic initiatives, and chairs special committees as needed.

C. Secretary: Ensures accurate recording of meeting minutes, maintains organizational records, oversees governance document updates, and certifies Board actions when required.

D. Treasurer: Chairs the Finance Committee, oversees financial management and reporting, presents financial reports at Board meetings, and ensures audit compliance.

VI. Board Meetings

A. Frequency: The Board shall meet at least quarterly (four times per year), with additional special meetings called as needed.

B. Notice: Members shall receive at least 10 days' advance notice of regular meetings and 48 hours' notice for special meetings, along with meeting materials.

C. Quorum: A majority of Board members must be present (in-person or virtually) to conduct official business.

D. Voting: Each Board member has one vote. Decisions require a majority vote of those present, unless otherwise specified in the Bylaws. Members with conflicts of interest must abstain from related votes.

E. Executive Sessions: The Board may meet in executive session (without staff present) to discuss sensitive matters such as Executive Director performance, legal issues, or personnel matters.

VII. Board Committees

The Board may establish standing and ad hoc committees, which may include:

• Executive Committee: Acts on behalf of the Board between meetings on urgent matters
• Finance Committee: Oversees budget, financial policies, audit, and investment management
• Governance Committee: Manages Board recruitment, orientation, evaluation, and policy review
• Fundraising/Development Committee: Guides fundraising strategy and donor cultivation
• Program Committee: Reviews program effectiveness and strategic alignment

Committees make recommendations to the full Board but do not have independent decision-making authority unless specifically delegated.

VIII. Board-Staff Relationship

A. Executive Director: The Board hires, evaluates, and (if necessary) terminates the Executive Director, who is responsible for day-to-day operations, staff management, and program implementation.

B. Board Role: The Board focuses on governance, strategy, and oversight—not operational management. Board members should not direct staff or interfere with daily operations.

C. Communication: The Board Chair serves as the primary liaison between the Board and Executive Director, ensuring clear communication and alignment.

IX. Board Self-Evaluation

The Board shall conduct an annual self-assessment to evaluate:

• Board composition and diversity
• Meeting effectiveness and engagement
• Committee performance
• Strategic planning and goal achievement
• Financial oversight and fundraising
• Areas for improvement and professional development needs

X. Removal & Resignation

A. Resignation: Board members may resign by written notice to the Board Chair. The Board may request a transition period to ensure continuity.

B. Removal for Cause: A Board member may be removed for failure to attend meetings, breach of fiduciary duty, violation of the Conflict of Interest Policy, or conduct detrimental to the Organization. Removal requires a two-thirds vote of the Board after providing the member an opportunity to respond.

XI. Policy Review

This policy shall be reviewed annually by the Governance Committee and updated as necessary to reflect best practices in nonprofit governance.

Effective Date: January 1, 2025 | Last Updated: April 1, 2026

I. Purpose

This Conflict of Interest Policy is designed to help Board Members, officers, employees, and volunteers of Eagle-X Impact Foundation ("the Organization") identify situations that present potential conflicts of interest and to provide the Organization with procedures to appropriately manage conflicts in accordance with legal requirements and the goals of accountability and transparency.

II. Definitions

Interested Person: Any Board Member, officer, employee, or volunteer with a direct or indirect financial interest, as defined below.

Financial Interest: A person has a financial interest if they have, directly or indirectly, through business, investment, or family:

• An ownership or investment interest in any entity with which the Organization has a transaction or arrangement
• A compensation arrangement with the Organization or with any entity or individual with which the Organization has a transaction or arrangement
• A potential ownership or investment interest in, or compensation arrangement with, any entity or individual with which the Organization is negotiating a transaction or arrangement

III. Procedures

Duty to Disclose: 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 Board of Directors.

Determining Whether a Conflict Exists: After disclosure of the financial interest and all material facts, the interested person shall leave the meeting while the determination of a conflict of interest is discussed and voted upon. The remaining Board members shall decide if a conflict of interest exists.

Procedures for Addressing Conflicts: If a conflict of interest exists:

• The interested person may present information at a Board meeting, but must leave during discussion and vote
• The Board shall investigate alternatives to the proposed transaction or arrangement
• The Board shall determine by majority vote whether the transaction is in the Organization's best interest and for its own benefit, and whether it is fair and reasonable
• The Board shall make its decision as to whether to enter into the transaction or arrangement

IV. Annual Disclosure

Each Board Member, officer, and key employee shall annually sign a statement which:

• Affirms that they have received a copy of this policy
• Affirms that they have read and understand the policy
• Agrees to comply with the policy
• Discloses any financial interests that could give rise to conflicts of interest

V. Record of Conflicts

The minutes of the Board shall contain:

• The names of persons who disclosed or were found to have a financial interest, the nature of the interest, action taken, and the Board's decision
• The names of persons who were present for discussions and votes
• The content of the discussion, including alternatives considered
• A record of any votes taken

VI. Compensation Approval

A voting member of the Board who receives compensation from the Organization for services is precluded from voting on matters pertaining to that member's compensation. No voting member whose jurisdiction includes compensation matters may vote on compensation for themselves.

VII. Violations

If the Board has reasonable cause to believe a member has failed to disclose actual or possible conflicts of interest, it shall inform the member and afford an opportunity to explain. If, after investigation, the Board determines that a violation has occurred, appropriate disciplinary action shall be taken, up to and including removal from the Board.

Effective Date: January 1, 2025 | Last Updated: April 1, 2026

I. Purpose

Eagle-X Impact Foundation (the "Organization") is committed to operating with the highest standards of integrity, transparency, and legal compliance. This Whistleblower Protection Policy encourages Board members, employees, volunteers, and contractors to report suspected misconduct, illegal activities, fraud, or violations of organizational policies without fear of retaliation.

This policy complies with the Sarbanes-Oxley Act (Section 806), IRS requirements for 501(c)(3) organizations, and Texas state whistleblower protection laws.

II. Scope

This policy applies to all individuals associated with the Organization, including:

• Board of Directors members
• Officers and employees (full-time, part-time, temporary)
• Volunteers and interns
• Contractors and consultants
• Partner organization representatives

III. Reportable Concerns

Individuals are encouraged to report good-faith concerns about:

• Financial Misconduct: Fraud, embezzlement, theft, misuse of funds, falsification of financial records, or improper accounting practices
• Legal Violations: Violations of federal, state, or local laws, including tax law, employment law, health and safety regulations, or environmental laws
• Conflicts of Interest: Undisclosed conflicts, self-dealing, or failure to follow the Conflict of Interest Policy
• Governance Issues: Board misconduct, failure to fulfill fiduciary duties, or violations of Bylaws
• Donor Fraud: Misrepresentation to donors, improper gift handling, or failure to honor donor restrictions
• Discrimination or Harassment: Violations of equal opportunity, sexual harassment, or hostile work environment
• Program Misconduct: Abuse or neglect of clients, violations of client privacy (HIPAA), or failure to follow program policies
• Document Destruction: Improper destruction of records or obstruction of investigations
• Retaliation: Actions taken against individuals who report concerns in good faith

IV. Reporting Procedures

Individuals who become aware of suspected misconduct should report concerns as follows:

A. Good Faith Requirement: Reports must be made in good faith with a reasonable belief that misconduct has occurred. False accusations made knowingly or with reckless disregard for the truth are not protected and may result in disciplinary action.

B. Anonymous Reporting: Reports may be made anonymously, though providing contact information helps facilitate investigation and follow-up.

C. No Requirement to Investigate First: Individuals are not expected to investigate concerns themselves. Simply report suspected misconduct through appropriate channels.

V. Investigation Process

Upon receiving a report, the Organization will:

• Acknowledge Receipt: Confirm receipt of the report within 5 business days (if contact information provided)
• Conduct Preliminary Assessment: Determine if the concern warrants investigation
• Designate Investigator: Assign an appropriate investigator (Board Chair, outside counsel, independent investigator, or committee) based on the nature and severity of the allegation
• Maintain Confidentiality: Share information only with those who need to know for investigation purposes
• Conduct Thorough Investigation: Interview relevant parties, review documents, and gather evidence
• Document Findings: Prepare a written report with findings and recommendations
• Take Appropriate Action: Implement corrective measures, disciplinary action, policy changes, or referral to law enforcement as warranted
• Provide Updates: Communicate investigation status and resolution to the reporter (if contact information provided), subject to confidentiality constraints

Timeline: Investigations will be completed as promptly as possible, typically within 30-60 days, depending on complexity. The reporter will be notified if additional time is needed.

VI. Prohibition Against Retaliation

Protected Activities: Individuals are protected when they:

• Report suspected misconduct through internal channels
• Cooperate with internal or external investigations
• File complaints with regulatory agencies (IRS, DOL, EEOC, etc.)
• Testify in legal proceedings related to organizational misconduct
• Refuse to participate in illegal activities

Consequences of Retaliation: Anyone who retaliates against a whistleblower will face disciplinary action up to and including termination or removal from the Board.

VII. Confidentiality

The Organization will make reasonable efforts to maintain confidentiality throughout the reporting and investigation process, subject to legal requirements and the need to conduct a thorough investigation. However, absolute confidentiality cannot be guaranteed, particularly if:

• The Organization is legally required to disclose information
• Disclosure is necessary to conduct a fair investigation
• The matter is referred to law enforcement or regulatory agencies

VIII. Document Retention

All records related to whistleblower reports and investigations shall be retained for at least seven (7) years in accordance with the Organization's Document Retention Policy and legal requirements. No individual may destroy, alter, or conceal documents related to a report or investigation.

IX. External Reporting Rights

Nothing in this policy prevents individuals from reporting suspected misconduct to external authorities, including:

• IRS: Tax-exempt organization violations (Form 13909)
• Texas Attorney General: Charitable organization fraud
• Equal Employment Opportunity Commission (EEOC): Discrimination or harassment
• Department of Labor (DOL): Wage and hour violations
• Law Enforcement: Criminal activity

Individuals who report to external agencies in good faith are protected from retaliation under federal and state whistleblower protection laws.

X. Annual Acknowledgment

All Board members, officers, and key employees shall annually acknowledge receipt and understanding of this policy.

XI. Policy Review

This policy shall be reviewed annually and updated as necessary to reflect legal requirements and best practices.

Effective Date: January 1, 2025 | Last Updated: April 1, 2026

I. Purpose

Eagle-X Impact Foundation (the "Organization") maintains a Document Retention & Destruction Policy to ensure that necessary records are adequately protected and maintained, that outdated or unnecessary documents are disposed of properly, and that the Organization complies with legal and regulatory requirements. This policy also implements provisions of the Sarbanes-Oxley Act (SOX) prohibiting document destruction to impede federal investigations or proceedings.

II. Scope

This policy applies to all documents created, received, or maintained by the Organization in the course of business, including:

• Paper documents (originals and copies)
• Electronic documents (emails, files, databases, cloud storage)
• Audio and video recordings
• Text messages and instant messages related to business
• Social media posts and communications
• Photographs and images

III. Retention Schedule

The following retention periods are based on federal and state legal requirements, IRS regulations, best practices for 501(c)(3) organizations, and operational needs:

IV. Document Destruction Procedures

A. Regular Destruction: Once the retention period expires, documents should be destroyed according to the following procedures:

• Paper Documents: Shred or incinerate (cross-cut shredding minimum); never discard intact
• Electronic Files: Permanently delete using secure deletion software (not just "delete" or recycle bin)
• Hard Drives/Media: Physically destroy or use Department of Defense-level data wiping
• Cloud Storage: Permanently delete from all locations including backups and archives

B. Destruction Log: Maintain a log documenting:

• Date of destruction
• Description of documents destroyed
• Method of destruction
• Person authorizing and performing destruction

C. Annual Review: Each year, identify documents that have reached the end of their retention period and schedule for destruction.

V. Legal Hold Policy

VI. Storage & Security

A. Physical Storage:

• Store paper documents in locked cabinets or secure storage facilities
• Limit access to authorized personnel only
• Protect from fire, water damage, theft, and unauthorized access
• Maintain climate-controlled environment for long-term storage

B. Electronic Storage:

• Use encrypted cloud storage with strong access controls
• Implement regular backup procedures (daily incremental, weekly full)
• Store backups in geographically separate locations
• Use password protection and multi-factor authentication
• Regularly test backup restoration procedures

C. Confidential Information: Documents containing sensitive information (client data, financial information, personnel records) require heightened security measures including encryption and restricted access.

VII. Roles & Responsibilities

Executive Director: Overall responsibility for implementing and enforcing this policy

Records Manager (designated staff): Maintains retention schedule, coordinates annual document review and destruction, manages storage systems

All Staff & Volunteers: Comply with retention schedules, properly file and label documents, report suspected violations

Board Secretary: Ensures Board records are properly maintained and archived

VIII. Employee Departure

When staff or volunteers leave the Organization:

• All organizational documents (paper and electronic) must be returned or transferred
• Access to organizational accounts and systems must be immediately revoked
• Personal email accounts should not be used for organizational communications that need retention
• Exit interviews should include reminder of confidentiality obligations

IX. Policy Violations

Violations of this policy, including unauthorized destruction of documents or failure to comply with legal holds, will result in:

• Disciplinary action up to and including termination (employees/volunteers)
• Removal from the Board (Board members)
• Potential criminal prosecution under Sarbanes-Oxley Act (obstruction of justice)
• Civil liability for the Organization and individuals

X. Policy Review

This policy shall be reviewed every three (3) years or when there are significant changes to legal requirements, organizational operations, or technology. Updates will be approved by the Board of Directors.

Effective Date: January 1, 2025 | Last Updated: April 1, 2026

I. Purpose

Eagle-X Impact Foundation ("the Organization") accepts gifts from individuals, corporations, foundations, and other entities to support our mission of serving postpartum mothers through the Wings of Care initiative. This policy provides guidelines for accepting, refusing, and managing charitable contributions to ensure alignment with our mission, legal compliance, and donor stewardship.

II. Types of Acceptable Gifts

The Organization accepts the following types of gifts:

A. Unrestricted Gifts
Cash, checks, credit card payments, and electronic transfers without donor-imposed restrictions. These gifts provide maximum flexibility for program needs.

B. Restricted Gifts
Donations designated for specific programs (e.g., "home cleaning services," "mental health support," "care packages"). The Organization must be able to fulfill the restriction and will work with donors to ensure their intent can be honored.

C. In-Kind Donations
Non-cash contributions including:

• Cleaning supplies and equipment
• Care package items (baby products, personal care items, etc.)
• Professional services (accounting, legal, marketing)
• Gift cards for partner services

Note: In-kind donations must be useful to our programs and in good condition. The donor is responsible for determining fair market value for tax purposes; the Organization will provide acknowledgment of receipt but not valuations.

D. Planned Gifts
Bequests through wills, beneficiary designations on life insurance or retirement accounts, charitable gift annuities, and charitable trusts. Donors are encouraged to consult with their own legal and financial advisors.

E. Matching Gifts
Corporate matching gifts that align with our mission and do not impose unacceptable restrictions.

III. Gifts Requiring Special Review

The following gifts require review and approval by the Executive Director and/or Board of Directors:

• Gifts over $10,000
• Real estate or property
• Stocks, bonds, or securities
• Vehicles or equipment requiring maintenance
• Gifts with complex restrictions or donor recognition requirements
• Gifts that may create conflicts of interest or reputational risk

IV. Gifts the Organization Will Not Accept

The Organization reserves the right to refuse gifts that:

• Are inconsistent with our mission or values
• Impose undue administrative or financial burdens
• Require the Organization to act in ways contrary to our principles
• Create actual or perceived conflicts of interest
• Come from sources involved in illegal activities or reputational harm
• Would jeopardize our 501(c)(3) tax-exempt status
• Are designated for specific individuals rather than program purposes
• Involve goods that are expired, unsafe, or unusable

V. Donor Recognition & Anonymity

The Organization respects donor privacy and will:

• Honor requests for anonymity in all public materials
• Recognize donors according to their preferences (full name, initials, or anonymous)
• Never share, sell, or trade donor information
• Provide appropriate acknowledgment levels based on gift size (with donor consent)

VI. Gift Acknowledgment & Tax Receipts

All donors will receive:

• A written acknowledgment within 48 hours of receipt for gifts under $250
• An official tax receipt within 15 days for gifts of $250 or more
• Receipts that comply with IRS requirements, including:
  • Organization name, address, and EIN
  • Date and amount of contribution
  • Description of in-kind gifts (no valuation provided by Organization)
  • Statement: "No goods or services were provided in exchange for this contribution" (when applicable)

VII. Restricted Gift Management

When a donor designates a gift for a specific purpose, the Organization will:

• Use the gift only for the stated purpose
• Track restricted funds separately in accounting records
• Contact the donor if the restriction cannot be fulfilled or if circumstances change
• Obtain written donor approval before redirecting restricted funds

VIII. Donor Bill of Rights

Eagle-X Impact Foundation adheres to the Donor Bill of Rights, ensuring all donors have the right to:

• Be informed of the Organization's mission and how resources are used
• Know the identity of Board Members and expect prudent financial management
• Review the Organization's most recent financial statements
• Receive appropriate acknowledgment and recognition
• Have their gifts used for intended purposes
• Receive prompt responses to inquiries about donations

IX. Policy Review

This policy will be reviewed annually by the Board of Directors and updated as necessary to reflect best practices and legal requirements.

Effective Date: January 1, 2025 | Last Updated: April 1, 2026

I. Purpose

Eagle-X Impact Foundation (the "Organization") is committed to maintaining the highest standards of financial integrity, transparency, and accountability. This Financial Controls & Audit Policy establishes internal controls, accounting procedures, and oversight mechanisms to protect organizational assets, ensure accurate financial reporting, and comply with legal requirements for 501(c)(3) nonprofit organizations.

II. Financial Management Oversight

A. Board of Directors: Has ultimate fiduciary responsibility for financial oversight, including:

• Approving annual operating and capital budgets
• Reviewing quarterly financial statements
• Ensuring adequate internal controls and audit procedures
• Approving expenditures exceeding $25,000
• Monitoring investment performance and asset allocation

B. Finance Committee: Recommends financial policies, reviews financial reports, oversees audit process, and monitors budget performance.

C. Treasurer: Chairs Finance Committee, presents financial reports to the Board, ensures timely filing of tax returns and regulatory reports.

D. Executive Director: Responsible for day-to-day financial management, budget implementation, and ensuring compliance with financial policies.

E. Bookkeeper/Accountant: Maintains accounting records, processes transactions, reconciles accounts, and prepares financial reports.

III. Internal Controls

A. Segregation of Duties: To prevent fraud and error, the following duties shall be separated among different individuals:

• Authorization: Approving transactions (Executive Director or Board)
• Recording: Entering transactions in accounting system (Bookkeeper)
• Custody: Handling cash, checks, and bank deposits (designated staff)
• Reconciliation: Reviewing bank statements and account reconciliations (Treasurer or Finance Committee member)

Note: For small organizations where full segregation is not feasible, compensating controls such as Board review and dual signatures shall be implemented.

B. Dual Signatures: All checks, wire transfers, and electronic payments over $5,000 require two authorized signatures from:

• Executive Director
• Board Chair
• Treasurer
• Other Board-designated signatories

No individual may sign a check payable to themselves. Payments under $5,000 require one authorized signature.

C. Bank Account Access: Only authorized individuals may have access to bank accounts, online banking, and financial systems. Access shall be reviewed quarterly and updated when personnel changes occur.

IV. Revenue & Cash Receipts

A. Donation Processing:

• All donations (cash, checks, credit cards, in-kind) shall be logged immediately upon receipt with date, amount, donor name, and purpose
• Mail containing donations shall be opened by two people when possible
• Donations shall be deposited within 3 business days of receipt
• Restrictive endorsement stamps ("For Deposit Only") shall be applied immediately to all checks
• Donors shall receive written acknowledgment within 48 hours for amounts under $250, and within 15 days for amounts $250 or greater

B. Cash Handling:

• Cash shall be stored in a locked safe or drawer with limited access
• Cash counts shall be documented and verified by two individuals
• Cash receipts shall not be used for disbursements (no "netting")

C. Online Donations: Payment processing through secure third-party platforms (e.g., Stripe, PayPal, Network for Good) with daily reconciliation to bank statements and donor records.

V. Expenditures & Disbursements

A. Authorization Limits:

• Up to $5,000: Executive Director approval
• $5,001 - $25,000: Executive Director + Treasurer or Board Chair approval
• Over $25,000: Full Board approval

B. Payment Processing:

• All expenditures require supporting documentation (invoices, receipts, contracts)
• Payments shall be made only to approved vendors with proper W-9 forms on file
• Check stock shall be kept in a locked location with controlled access
• Voided checks shall be marked "VOID" and retained for audit purposes
• Electronic payments require documented approval before processing

C. Credit Cards:

• Organizational credit cards may be issued to Executive Director and authorized staff
• Credit cards are for business expenses only; personal use is prohibited
• Receipts must be submitted within 10 business days of purchase
• Monthly statements shall be reviewed by the Treasurer
• Lost or stolen cards must be reported immediately

D. Reimbursements:

• Staff and volunteers may be reimbursed for pre-approved business expenses
• Reimbursement requests must include original receipts and expense reports
• Mileage reimbursement follows current IRS standard mileage rate
• Reimbursements processed within 30 days of submission

VI. Accounting & Record Keeping

A. Accounting Method: The Organization uses the accrual basis of accounting in accordance with Generally Accepted Accounting Principles (GAAP) for nonprofits.

B. Chart of Accounts: Maintains a chart of accounts aligned with IRS Form 990 reporting categories and program service areas.

C. Bank Reconciliations: All bank and credit card accounts shall be reconciled monthly within 10 days of receiving statements. Reconciliations shall be reviewed by someone independent of transaction recording (Treasurer or Finance Committee member).

D. Financial Statements: The following reports shall be prepared:

• Monthly: Statement of Financial Position (Balance Sheet), Statement of Activities (Income Statement), Budget vs. Actual comparison
• Quarterly: Presented to Finance Committee and full Board
• Annual: Audited or reviewed financial statements by independent CPA

E. Restricted Funds: Donations with donor-imposed restrictions shall be tracked separately and used only for designated purposes. Compliance with restrictions shall be monitored and reported to the Board quarterly.

VII. Budgeting

A. Annual Budget: The Executive Director, with input from the Finance Committee, shall prepare an annual operating budget for Board approval by December 31 for the following fiscal year.

B. Budget Monitoring: Actual performance shall be compared to budget monthly. Variances exceeding 10% or $5,000 shall be explained to the Finance Committee.

C. Budget Amendments: Material budget amendments (exceeding 15% of total budget or $50,000) require Board approval.

VIII. Audit & External Review

A. Independent Audit/Review:

• The Organization shall engage an independent CPA firm to conduct an annual audit or review, depending on funding requirements and organizational size
• The audit firm shall be selected by the Finance Committee and approved by the Board
• The same audit firm shall not be retained for more than 5 consecutive years

B. Audit Committee: The Finance Committee (or designated Audit Committee) shall:

• Meet with auditors to discuss scope and findings
• Review audited financial statements and management letter
• Ensure management responds to audit recommendations
• Present audit results to the full Board

C. IRS Form 990: The Organization's annual Form 990 shall be prepared by a qualified accountant, reviewed by the Finance Committee and Executive Director, and approved by the Board before filing. Form 990 shall be filed by the extended deadline (November 15) and made publicly available on the Organization's website.

IX. Investment Policy

A. Reserve Funds: The Organization shall maintain an operating reserve equal to 3-6 months of operating expenses, invested in liquid, low-risk accounts.

B. Investment Management: Long-term investments shall be managed according to the Organization's Investment Policy (if applicable), prioritizing preservation of capital, liquidity, and prudent returns consistent with the Uniform Prudent Management of Institutional Funds Act (UPMIFA).

X. Compliance & Reporting

The Organization shall comply with all federal, state, and local requirements, including:

• IRS Form 990: Filed annually
• Texas Charitable Organization Registration: Renewed annually with Attorney General
• Payroll Tax Filings: Federal and state (if applicable)
• 1099 Forms: Issued to contractors and vendors by January 31
• Sales Tax Exemption: Maintained with Texas Comptroller
• Fundraising Compliance: Registration in states where required for solicitation

XI. Fraud Prevention

The Organization maintains a zero-tolerance policy for fraud, theft, or misuse of funds. All suspected financial misconduct shall be reported immediately through the Whistleblower Policy and investigated thoroughly.

XII. Policy Review

This policy shall be reviewed annually by the Finance Committee and Board of Directors, and updated as necessary to reflect best practices and regulatory changes.

Effective Date: January 1, 2025 | Last Updated: April 1, 2026

Introduction

Eagle-X Impact Foundation (the "Organization") is deeply grateful for the generosity of our donors whose contributions make the Wings of Care initiative possible. We are committed to treating all donors with respect, transparency, and accountability. This Donor Bill of Rights, developed by leading philanthropic organizations, establishes the standards we uphold in our relationships with supporters.

Every donor has the following rights:

Effective Date: January 1, 2025 | Last Updated: April 1, 2026

I. Introduction

Eagle-X Impact Foundation ("the Organization," "we," "us," "our") operates the Wings of Care website and services. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website, register for services, volunteer, or partner with us.

By using our website or services, you consent to the practices described in this Privacy Policy. If you do not agree with this policy, please do not access or use our website or services.

II. Information We Collect

A. Personal Information You Provide
We collect information that you voluntarily provide when you:

• Register for Services (Moms): Name, contact information, address, pregnancy/postpartum status, household information, mental health screening responses, medical history related to postpartum care
• Volunteer: Name, contact information, address, availability, background check information, emergency contacts
• Partner with Us: Organization name, contact information, partnership interests, service areas
• Make Donations: Name, payment information (processed securely through third-party processors), mailing address
• Contact Us: Name, email address, phone number, message content

B. Protected Health Information (PHI)
For clients receiving mental health referrals or services, we may collect limited health information necessary to coordinate care. This information is protected under HIPAA regulations and our Business Associate Agreements with healthcare providers.

C. Automatically Collected Information
When you visit our website, we may automatically collect:

• IP address and browser type
• Device information (operating system, device type)
• Pages visited and time spent on pages
• Referral sources (how you found our website)
• Cookies and similar tracking technologies (see Section VIII)

III. How We Use Your Information

We use the information we collect to:

• Provide Services: Process registrations, coordinate home cleaning, schedule mental health appointments, deliver care packages
• Volunteer Management: Coordinate volunteer placements, conduct background checks, communicate opportunities
• Partnership Development: Establish and manage partnerships with service providers and organizations
• Communications: Send service updates, appointment reminders, newsletters (with consent), and respond to inquiries
• Donor Stewardship: Process donations, send tax receipts, provide impact updates
• Program Improvement: Analyze service effectiveness, identify needs, evaluate outcomes (using de-identified data)
• Legal Compliance: Fulfill legal obligations, respond to legal requests, protect rights and safety

IV. How We Share Your Information

We do not sell, rent, or trade your personal information. We may share your information only in the following circumstances:

• Service Providers: Vetted cleaning companies, mental health providers, care package vendors who help deliver our services (under confidentiality agreements)
• Business Associates: Healthcare partners bound by HIPAA Business Associate Agreements
• Legal Requirements: When required by law, court order, or to protect safety (e.g., mandatory child abuse reporting)
• With Your Consent: When you explicitly authorize us to share information

V. Data Security

We implement reasonable security measures to protect your information:

• Encryption of data in transit (SSL/TLS) and at rest
• Secure servers with restricted access
• Employee training on confidentiality and data protection
• Regular security assessments and updates
• Background checks for staff with access to sensitive information

However, no method of transmission over the internet is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

VI. Data Retention

We retain your information for as long as necessary to:

• Provide requested services
• Comply with legal obligations (e.g., IRS requires donor records for 7 years)
• Resolve disputes and enforce agreements
• Maintain program evaluation data (de-identified after active service ends)

You may request deletion of your information (see Section VII), subject to legal retention requirements.

VII. Your Privacy Rights

You have the right to:

• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your information (subject to legal exceptions)
• Opt-Out: Unsubscribe from marketing communications (service-related communications may still be sent)
• Restrict Processing: Request limitations on how we use your information

To exercise these rights, contact us at privacy@eagleximpact.tech or (346) 242-3200.

VIII. Cookies & Tracking Technologies

We use cookies (small text files stored on your device) to:

• Remember your preferences and settings
• Analyze website traffic and usage patterns
• Improve website functionality and user experience

You can control cookies through your browser settings. Disabling cookies may limit some website functionality.

IX. Third-Party Links

Our website may contain links to third-party websites (e.g., partner organizations, payment processors). We are not responsible for the privacy practices of these sites. We encourage you to review their privacy policies.

X. Children's Privacy

Our website is not intended for children under 18. We do not knowingly collect personal information from children. If you believe we have inadvertently collected information from a child, please contact us immediately.

XI. Changes to This Policy

We may update this Privacy Policy periodically. Changes will be posted on this page with the "Last Updated" date. Continued use of our website or services after changes constitutes acceptance of the updated policy.

XII. Contact Information

For questions, concerns, or to exercise your privacy rights, contact:

Effective Date: January 1, 2025 | Last Updated: April 1, 2026

I. Purpose

Eagle-X Impact Foundation (the "Organization") is committed to protecting the personal information of clients, donors, volunteers, and partners. This Data Breach Response Plan establishes procedures to prevent, detect, respond to, and recover from security incidents involving unauthorized access, disclosure, loss, or theft of sensitive data. The plan ensures compliance with federal and state data breach notification laws, HIPAA requirements for protected health information (PHI), and best practices for nonprofit organizations.

II. Scope & Definitions

A. Covered Data: This plan applies to all sensitive information maintained by the Organization, including:

• Personal Identifiable Information (PII): Names, addresses, phone numbers, email addresses, dates of birth, Social Security numbers
• Protected Health Information (PHI): Mental health screening results, therapy records, medical histories (subject to HIPAA)
• Financial Information: Donor credit card numbers, bank account information, payment records
• Confidential Program Data: Client applications, case notes, service records, eligibility determinations
• Employee/Volunteer Data: Personnel files, background checks, payroll information, I-9 forms

B. Data Breach Definition: Any suspected or confirmed incident involving unauthorized access to, acquisition of, use, disclosure, modification, or destruction of sensitive data that compromises the security, confidentiality, or integrity of the information.

III. Prevention Measures

The Organization maintains the following safeguards to prevent data breaches:

IV. Incident Response Team

The Data Breach Response Team consists of:

• Executive Director: Overall authority and decision-making; external communications lead
• IT Manager/Consultant: Technical investigation, containment, and remediation
• Privacy Officer (designated staff): HIPAA compliance, notification coordination, documentation
• Board Chair: Board liaison, major decision consultation, legal/insurance coordination
• Legal Counsel (as needed): Legal advice, regulatory guidance, notification review

V. Detection & Reporting

A. Detection Methods:

• Security alerts from IT systems (antivirus, firewall, intrusion detection)
• Reports from staff, volunteers, or partners
• Notification from third-party vendors or service providers
• Discovery during audits, assessments, or routine monitoring
• Client, donor, or public reports of suspicious activity

VI. Response Procedures (6-Phase Protocol)

VII. Notification Templates

Pre-approved notification letter templates are maintained by the Privacy Officer and include:

• Individual notification letter (PHI breach)
• Individual notification letter (PII/financial breach)
• Regulatory notification (HHS OCR, Texas AG)
• Media statement template
• Website posting template

All templates reviewed annually by legal counsel and updated as laws change.

VIII. Documentation Requirements

For every security incident (whether or not constitutes reportable breach), maintain:

• Incident Log: Date/time discovered, how detected, individuals notified, actions taken
• Risk Assessment: Analysis of whether notification required and why
• Investigation Report: Root cause, scope, affected data, number of individuals
• Notification Records: Copies of all notices sent, dates sent, recipient lists
• Remediation Plan: Steps taken to fix vulnerabilities and prevent recurrence
• Communications Log: All inquiries received and responses provided

Retention: All breach documentation retained for 7 years minimum (HIPAA requires 6 years from creation/last effective date).

IX. Training & Testing

A. Annual Training: All staff and volunteers with data access complete annual training covering:

• Recognizing and reporting security incidents
• Phishing and social engineering awareness
• Password security and MFA best practices
• Physical security (clean desk, secure disposal, device protection)
• Incident reporting procedures and contact information

B. Response Team Training: Annual tabletop exercise simulating breach scenario to test procedures and identify gaps.

C. Plan Testing: Full breach response simulation conducted every two years.

X. Policy Review & Updates

This plan shall be reviewed and updated:

• Annually (minimum)
• Following any actual breach incident
• When federal or state breach notification laws change
• When organizational systems, processes, or data types change significantly
• After tabletop exercises or simulations identify needed improvements

Effective Date: January 1, 2025 | Last Updated: April 1, 2026

I. Purpose

This Client Eligibility & Selection Policy establishes clear, fair, and consistent criteria for determining which mothers qualify for services through the Wings of Care initiative. This policy ensures equitable access to our limited resources, prioritizes those with greatest need, and maintains compliance with our 501(c)(3) charitable purpose.

II. Core Eligibility Requirements

To qualify for Wings of Care services, applicants must meet ALL of the following basic requirements:

III. Income Guidelines

Income eligibility is based on household size and gross annual income at or below 200% of the Federal Poverty Level (2026 guidelines):

Income Documentation: Applicants may provide recent pay stubs, tax returns, benefits statements (TANF, SSI, unemployment), or self-attestation if unable to provide documentation. We use the honor system and do not require extensive proof for initial eligibility.

IV. Priority Criteria

When demand exceeds capacity, priority is given to applicants with one or more of the following factors indicating higher need:

Note: Priority tiers guide waitlist management but do not guarantee or exclude services. All eligible applicants are considered based on holistic assessment and available resources.

V. Non-Discrimination Policy

VI. Application Process

Step 1: Initial Application

• Complete online application form at eagleximpact.tech/onboarding or request paper application
• Provide basic contact information, household details, income information
• Indicate which services are needed (cleaning, mental health, care packages, or multiple)
• Application available in English and Spanish

Step 2: Initial Screening

• Staff review application for basic eligibility (typically within 3-5 business days)
• Brief phone interview to verify information and assess needs
• Mental health screening using Edinburgh Postnatal Depression Scale (EPDS) if mental health services requested

Step 3: Eligibility Determination

• Applicant notified of eligibility status within 7 business days
• Approved: Receive service coordinator contact and begin scheduling
• Waitlist: Receive estimated wait time and priority tier, alternative resources provided
• Not Eligible: Receive explanation and referrals to other community resources

Step 4: Service Coordination

• Assigned service coordinator conducts intake interview
• Sign consent forms and service agreements
• Schedule home cleaning, mental health appointments, and/or care package delivery
• Receive orientation to program expectations and client responsibilities

VII. Ineligibility Reasons

Applications may be denied if:

• Applicant does not meet basic eligibility criteria (location, income, postpartum status)
• Currently receiving equivalent services from another organization (to avoid duplication)
• Home environment deemed unsafe for service providers (after safety assessment)
• Previous termination from Wings of Care services due to policy violations (case-by-case review possible after 6 months)
• Unable to provide informed consent
• Services requested are outside program scope

Applicants denied services will receive:

• Written explanation of ineligibility reason
• Referrals to alternative community resources
• Information about reapplication if circumstances change
• Right to appeal decision (see Appeals section)

VIII. Waitlist Management

When service capacity is reached, eligible applicants are placed on a waitlist:

• Priority Order: Waitlist organized by priority tier (1-3), then application date within each tier
• Communication: Applicants notified of waitlist status, estimated wait time (when possible), and position updates
• Interim Support: Resource lists and referrals provided while waiting
• Check-ins: Monthly contact to confirm continued interest and update information
• Removal from Waitlist: Automatic removal after 90 days of no response to outreach (can reapply)

IX. Special Circumstances

Emergency Cases: In situations involving imminent safety concerns, severe mental health crisis, or urgent need, applications may be expedited for immediate review by the Executive Director.

Extensions Beyond 12 Months Postpartum: Case-by-case exceptions may be granted for:

• Ongoing mental health treatment started within eligibility window
• Extraordinary circumstances (hospitalization, family crisis)
• Requires Executive Director approval

X. Appeals Process

Applicants who disagree with an eligibility determination may appeal:

• Timeline: Appeal must be submitted within 30 days of denial notification
• Process: Submit written appeal explaining why decision should be reconsidered, include any new supporting information
• Review: Executive Director reviews appeal and makes final decision within 14 business days
• Decision: Applicant notified in writing of appeal outcome with explanation

Appeal submissions: appeals@eagleximpact.tech or mail to Eagle-X Impact Foundation, Attn: Appeals, Houston, TX 77001

XI. Confidentiality

All application information is kept confidential in accordance with our Privacy Policy. Information is shared only with staff/volunteers directly involved in service provision and partner organizations providing services (with signed consent).

XII. Policy Review & Updates

This policy is reviewed annually and may be updated based on:

• Changes to Federal Poverty Level guidelines
• Expansion or contraction of service capacity
• New funding sources with specific eligibility requirements
• Program evaluation findings
• Community needs assessment

Applicants will be evaluated under the eligibility criteria in effect at the time of their application.

Effective Date: January 1, 2025 | Last Updated: April 1, 2026

I. Policy Statement

Eagle-X Impact Foundation ("the Organization") is committed to providing a safe environment for all clients, particularly mothers and children served through the Wings of Care initiative. This policy establishes clear protocols to prevent, identify, and respond to abuse, neglect, or harm involving vulnerable populations.

We have a zero-tolerance policy for any form of abuse, exploitation, or neglect. All staff, volunteers, Board members, and partners are required to comply with this policy and report any concerns immediately.

II. Scope

This policy applies to:

• All Board Members, staff, volunteers, contractors, and interns
• Partner organizations and their representatives
• Any individual representing the Organization in any capacity
• All interactions with clients, including mothers, children, and family members

III. Definitions of Abuse

Physical Abuse: Any intentional use of physical force that results in bodily injury, pain, or impairment, including hitting, shaking, burning, or inappropriate restraint.

Emotional Abuse: A pattern of behavior that impairs emotional development or sense of self-worth, including criticism, threats, rejection, withholding love/support, or exposure to violence.

Sexual Abuse: Any sexual activity or exploitation involving a child or vulnerable adult, including inappropriate touching, exposure, or use of sexually explicit materials.

Neglect: Failure to provide adequate food, shelter, medical care, supervision, or other necessities required for healthy development and safety.

IV. Prevention Measures

Background Checks: All volunteers and staff who have direct contact with clients must complete:

• Criminal background check (state and federal)
• Child abuse registry check (where applicable)
• Reference verification from previous employers or volunteer positions
• Renewal of background checks every two years

Training Requirements: All individuals covered by this policy must complete:

• Safeguarding training within 30 days of starting
• Annual refresher training
• Recognition of abuse indicators and reporting procedures

Two-Adult Rule: Whenever possible, two authorized adults should be present during home visits or service delivery. When this is not feasible, visits must be documented, scheduled in advance, and conducted during daylight hours.

Code of Conduct: All personnel must:

• Maintain appropriate professional boundaries
• Avoid being alone with a child in unsupervised settings
• Never engage in physical discipline or inappropriate physical contact
• Respect privacy and dignity of all clients
• Never accept or give inappropriate gifts
• Avoid sharing personal contact information or social media connections with clients

V. Reporting Procedures

Internal Reporting: In addition to mandatory reporting to authorities, concerns must be reported internally to:

• Safeguarding Officer: safeguarding@eagleximpact.tech | (346) 242-3200
• Executive Director (if Safeguarding Officer unavailable)
• Board Chair (if concern involves Executive Director)

What to Report:

• Observed or suspected abuse or neglect
• Allegations made by a child or vulnerable adult
• Concerning behavior by staff, volunteers, or partners
• Unsafe conditions in client homes
• Violations of this policy or Code of Conduct

VI. Investigation & Response

Upon receiving a report, the Organization will:

• Ensure the immediate safety of the individual(s) involved
• Document all information provided
• Cooperate fully with law enforcement and child protective services
• Suspend the accused individual from contact with clients pending investigation
• Provide support and resources to affected individuals
• Take appropriate disciplinary action if violations are substantiated

VII. Confidentiality & Non-Retaliation

All reports will be handled with appropriate confidentiality, shared only with those who need to know for investigation or safety purposes. The Organization strictly prohibits retaliation against anyone who reports concerns in good faith.

VIII. Policy Review

This policy will be reviewed annually and updated as needed to reflect best practices and legal requirements.

Effective Date: January 1, 2025 | Last Updated: April 1, 2026

I. Purpose

This Service Scope & Limitations Policy defines the services provided by Eagle-X Impact Foundation through the Wings of Care initiative, establishes clear boundaries for what we can and cannot provide, and ensures that clients, volunteers, and partners have accurate expectations. This policy protects both the Organization and those we serve by clarifying our mission focus and operational capacity.

II. Mission & Service Overview

Mission: Eagle-X Impact Foundation exists to support postpartum mothers through practical assistance, mental health access, and compassionate care during the critical months following childbirth.

Core Services: Wings of Care provides three primary services to eligible mothers:

• Home Cleaning Services: Professional cleaning to reduce household burden
• Mental Health Support: Referrals and connections to licensed mental health providers
• Care Packages: Essential items for mothers and babies delivered with care

III. Services We Provide

IV. Services We Do NOT Provide

To maintain focus on our mission and operate within our expertise and capacity, Wings of Care does NOT provide:

• Medical Care: We do not diagnose, treat, or provide medical advice. Clients should consult healthcare providers for all medical concerns.
• Childcare or Babysitting: We do not provide childcare services. We can refer to local childcare resources.
• Transportation: We do not provide transportation to appointments or errands. We can share information about community transportation resources.
• Legal Services: We do not provide legal advice or representation. We can refer to legal aid organizations for family law, housing, or immigration matters.
• Financial Assistance: We do not provide cash grants, rent assistance, or bill payment. We can refer to community assistance programs.
• Food Assistance: We do not operate a food pantry. We refer clients to local food banks, WIC, and SNAP programs.
• Housing Assistance: We do not provide housing placement or shelter services. We refer to housing authorities and homeless services.
• Substance Abuse Treatment: We do not provide addiction treatment but can refer to appropriate treatment programs.
• Domestic Violence Intervention: We do not provide shelter or legal advocacy but maintain referral relationships with domestic violence agencies (National Domestic Violence Hotline: 1-800-799-7233).

V. Service Duration & Frequency

Wings of Care provides short-term, transitional support during the postpartum period:

• Eligibility Window: Services available to mothers from pregnancy through 12 months postpartum (case-by-case extensions may be considered)
• Service Duration: Typically 1-3 months of support, depending on client needs and funding availability
• Home Cleaning: 1-3 sessions (not ongoing weekly service)
• Mental Health: Bridge funding for 3-6 therapy sessions while client transitions to insurance-covered or community-based care
• Care Packages: One comprehensive package, with potential for follow-up items based on need

Reason for Time Limits: Our model is designed to provide critical support during a specific vulnerable period, then help clients connect to sustainable, long-term resources. This allows us to serve more families with limited funding.

VI. Service Availability & Capacity

Geographic Service Area: Currently serving the Houston, Texas metropolitan area. Future expansion depends on funding and partnerships.

Funding Limitations: Services are provided based on available funding. When demand exceeds capacity:

• Priority given to clients with highest need based on eligibility criteria
• Waitlist established with estimated wait times provided
• Alternative resource referrals provided to all applicants
• No guarantee of service provision, though we strive to serve all eligible applicants

VII. Referral Network

When client needs exceed our service scope, we maintain referral relationships with:

• Mental health providers and community counseling centers
• Medical clinics and hospitals
• Food banks and nutritional assistance programs (WIC, SNAP)
• Housing assistance organizations
• Legal aid societies
• Domestic violence agencies
• Childcare resource and referral agencies
• Employment and job training programs
• Faith-based community support organizations

Warm Handoffs: Whenever possible, we provide "warm handoffs" by helping clients connect directly with partner organizations rather than simply providing contact information.

VIII. Client Responsibilities

To receive services, clients are expected to:

• Provide accurate information during registration and screening
• Communicate availability for scheduled services
• Provide safe access to the home for cleaning services
• Notify us of schedule changes or cancellations with reasonable notice
• Treat staff, volunteers, and partner service providers with respect
• Follow through with mental health referrals and appointments
• Engage with case management follow-up communications

IX. Termination of Services

Services may be discontinued if:

• Client no longer meets eligibility criteria
• Service period has concluded (typically 1-3 months)
• Client requests discontinuation
• Client engages in threatening, abusive, or unsafe behavior toward staff, volunteers, or partners
• Client repeatedly misses scheduled services without notice (3+ no-shows)
• Client provides false information during registration
• Unsafe home conditions prevent service delivery

Clients will be notified in writing of service termination with reasons provided. Alternative resources will be offered when appropriate. Clients may appeal termination decisions through our Grievance Procedure.

X. Liability & Disclaimers

No Guarantee of Outcomes: While we strive to provide high-quality services, we cannot guarantee specific results or improvements in health, wellbeing, or life circumstances.

Partner Service Providers: Home cleaning and mental health services are provided by independent partner organizations. While we vet partners carefully, we are not responsible for the actions of third-party providers. Issues should be reported immediately to Wings of Care for resolution.

Mandatory Reporting: Staff and volunteers are mandatory reporters. We are legally required to report suspected child abuse, neglect, or danger to self/others to appropriate authorities.

XI. Policy Review

This policy shall be reviewed annually and updated as programs evolve, funding changes, or new partnerships develop.

Effective Date: January 1, 2025 | Last Updated: April 1, 2026

I. Purpose

Eagle-X Impact Foundation (the "Organization") is committed to providing high-quality, respectful services to all clients, volunteers, and partners. This Grievance & Complaint Procedure establishes a clear, fair, and accessible process for addressing concerns, resolving disputes, and ensuring accountability. We welcome feedback as an opportunity to improve our programs and relationships.

II. Scope

This policy applies to complaints and grievances from:

• Clients: Mothers receiving Wings of Care services
• Volunteers: Individuals contributing time and skills
• Partners: Organizations collaborating with us
• Donors: Individuals or entities providing financial support
• Community Members: General public with concerns about our operations

III. Types of Grievances

This procedure covers complaints regarding:

• Service Quality: Concerns about home cleaning, mental health referrals, care packages, or service coordination
• Service Denials: Disagreement with eligibility determination, waitlist placement, or service termination
• Staff/Volunteer Conduct: Unprofessional behavior, disrespect, or policy violations by personnel
• Partner Provider Issues: Problems with cleaning companies or mental health providers
• Communication: Inadequate information, unresponsiveness, or miscommunication
• Discrimination: Unfair treatment based on protected characteristics
• Privacy Violations: Unauthorized disclosure of confidential information
• Safety Concerns: Unsafe conditions or practices
• Donor Relations: Gift handling, recognition, or stewardship issues

IV. Grievance Process Overview

Our grievance process has three levels, designed to resolve concerns at the earliest possible stage:

V. How to File a Grievance

Grievances may be submitted through any of the following methods:

Information to Include: To help us address your concern effectively, please provide:

• Your name and contact information (anonymous complaints accepted but limit investigation)
• Date(s) and description of the incident or issue
• Names of individuals involved (if applicable)
• What happened and why you are concerned
• What resolution or outcome you are seeking
• Any supporting documentation (emails, photos, receipts, etc.)

VI. Investigation Process

When a formal grievance is received, the Organization will:

• Acknowledge Receipt: Confirm we received your grievance within 3 business days
• Assign Investigator: Designate appropriate person to investigate (service coordinator, Executive Director, or Board member depending on level and nature)
• Gather Information: Interview relevant parties, review documentation, and assess the situation
• Maintain Confidentiality: Share information only with those who need to know for investigation and resolution
• Make Determination: Decide whether the grievance is substantiated and what action is warranted
• Communicate Decision: Provide written explanation of findings, decision, and any actions taken
• Implement Resolution: Take corrective action, provide remedy, or make necessary changes
• Follow Up: Check in after resolution to ensure satisfaction and prevent recurrence

VII. Possible Outcomes

Depending on the grievance, resolution may include:

• Apology: Acknowledgment of error or poor service
• Corrective Action: Fixing the problem (rescheduling service, replacing items, additional support)
• Service Restoration: Reinstating services if improperly denied or terminated
• Personnel Action: Retraining, supervision, or disciplinary action for staff/volunteers
• Policy Change: Updating procedures to prevent similar issues
• Financial Remedy: Refund or compensation in appropriate cases
• Explanation: Clarification of policies or reasons for decisions (if no error found)
• Referral: Connection to alternative resources if we cannot resolve the issue

VIII. Timelines

If additional time is needed due to complexity or investigation requirements, you will be notified with an updated timeline.

IX. Right to Appeal

If you are dissatisfied with the resolution at any level, you may appeal to the next level:

• Level 1 decision → Appeal to Executive Director (Level 2)
• Level 2 decision → Appeal to Board Chair (Level 3)
• Level 3 decision by Board is final

Appeal Process: Submit written appeal within 14 days of receiving the decision, explaining why you disagree and what outcome you seek.

X. Non-Retaliation Policy

XI. Confidentiality

Grievances are handled confidentially to the extent possible. Information is shared only with:

• Staff/Board members investigating the grievance
• Individuals whose input is necessary for resolution
• Parties directly involved in the complaint
• Legal counsel or authorities when required

However, absolute confidentiality cannot be guaranteed when conducting a thorough and fair investigation.

XII. Anonymous Grievances

We accept anonymous grievances, but this may limit our ability to:

• Gather complete information about the situation
• Communicate our findings and resolution
• Follow up to ensure satisfaction
• Provide remedy directly to the complainant

We encourage providing contact information, but respect your choice to remain anonymous.

XIII. Record Keeping

All grievances, investigations, and resolutions are documented and retained for seven (7) years in accordance with our Document Retention Policy. Records are reviewed periodically to identify patterns and opportunities for improvement.

XIV. External Resources

While we encourage using our internal grievance process first, you also have the right to contact external agencies:

• Texas Attorney General: Charitable organization complaints (consumer.protection@oag.texas.gov)
• Better Business Bureau: Service quality concerns (www.bbb.org)
• IRS: Tax-exempt organization violations (Form 13909)
• Equal Employment Opportunity Commission: Discrimination complaints (www.eeoc.gov)

XV. Policy Review

This policy is reviewed annually and updated as needed based on feedback, best practices, and organizational growth.