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The Sarbanes-Oxley Act of 2002

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C. Consider formalizing such non-required practices such as:<br />

<br />

<br />

<br />

<br />

<br />

If you have an audit committee, have it comprised <strong>of</strong> board members who are not<br />

also on staff, and if you are audited but don’t have an audit committee, consider<br />

forming such a committee or task force<br />

Prohibit loans from the organization to board members (some states’ corporate<br />

laws prohibit this)<br />

If you have a financial consulting firm, choose one that is different from your<br />

auditing firm<br />

Have the full board approve compensation for the executive director and the top<br />

staff financial <strong>of</strong>ficer<br />

Adopt an Ethics or Conflict <strong>of</strong> Interest Policy<br />

Upcoming issues <strong>of</strong> Blue Avocado will discuss Ethics and Conflict <strong>of</strong> Interest Policies<br />

and include Model Policies.<br />

See also:<br />

<br />

<br />

Model Whistleblower Policy for Nonpr<strong>of</strong>its by Tom Silk<br />

Model Document Retention Policy for Nonpr<strong>of</strong>its by Tom Silk<br />

Page 99 <strong>of</strong> 208

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