PPD 371: Midterm

Large-scale giving

"Mega-Philanthropy" • Often personal connection to cause, long-time supporter, cultivated relationships Global Philanthropists Circle • Wealthiest families giving away money for long-term impact, social elite, facilitating networking Giving Pledge • Wealthiest families pledge to give away half of their wealth, no requirements for impact or immediate donations

Philanthropy

Accounts for 13% of revenue for nonprofits - Includes the giving of time or money for public purposes; bequests (money from wills) - Typically results in longer term outcomes - Involves time, networking, and stewardship from the nonprofit

Strategic/Venture Philanthropy vs Charity

Also known as venture philanthropy, it is a style of giving that is more involved and pulls ideas from the for-profit market. It involves seeking out root causes of societal issues to find a solution versus providing direct relief. - Philanthropists see their grants as investments rather than gifts and as such expect to see a return and progress toward specified goals. - partner with the grantee to provide non-monetary support such as extensive coaching and mentoring to the nonprofits senior managers - involved in critical hiring decisions - The process is especially popular with young/tech donors. It affects how grantors and grantees interact and relative expectations. - fund overhead) - provide long-term funding and follow-on funding - investors will often take one or more seats on the board to help shape strategy - nonprofits can count on venture investors to help raise money for next stage of growth - investors are engaged with nonprofit for 5-7 years *This is important to the nonprofit sector because it advances the efforts of nonprofits to continue working towards their mission long-term until they reach those end results. The difference is in the method that they use to reach the outcome of improving the world/alleviating suffering. - Charity seeks out direct relief (band-aid) to a societal problem while Philanthropy seeks out to resolve the root causes of said problem.

Supporting Organizations

Are a subset of public charities that must distribute at least 85% of their annual income to their supported charities three types: - type 1 are under direct control of the supported organization - type 2 are under common control with the supported organization - type 3 are not necessarily related to the supported organization

What state is professor Graddy from?

California

Types of Public Charities

Community Foundations: financial support from public; lets donors have more control with Donor-advised funds; build an endowment for long-term philanthropy Supporting organizations: A charity that carries out its mission by supporting other public charities Group entities

FORM 990 Counter

Compliance form vs transparency form - Submission of the form itself does not guarantee compliance (ex. what if only 3% of money raised goes to programming) - Forms are hard to understand-> not digestible content for public - Recommend to eliminate form or properly fund IRS - Focus on audited financial statements impact reports and organizational policies like conflicts of interests, whistleblowing which promote transparency - What matters is the story behind the numbers - Reducing overhead will hurt organizational capacity

SCOTUS Hobby Lobby

Established first amendment rights for corporations because Hobby lobby did not want to pay their employees birth control; court ruled that corporations are exempt from laws that the owner objects to on religious grounds under the religious freedom restoration act

SCOTUS Citizens United Decision

Established for-profit corporations and 501c4 nonprofits as people under the first amendment - drastic increase in 501c4 registrations - drastic increase in funds spent in elections by nonprofits JOHNSON AMENDMENT:501c3 receive tax deduction as a trade-off for surrendering their freedom of speech to lobby - tax deduction is considered a subsidy so it can be forgone to get the benefit of free speech

How foundations can change

Foundations excel in R&D but have yet to find ways to support their grantees in longer-term, sustainable ways. - until foundations accept their accountability to society and meet their obligation to create value, they exist in a world where they cannot fail - There is little transparency in the philanthropy sector because there is no standardized public information flows about profits and losses like in the private sector which makes it difficult to evaluate foundations which insinuates the belief that funders' design the solutions The venture capital model can show foundations how to help nonprofits build strong organizations nonprofits need ask foundations to invest in their overhead by explaining that they know where to strengthen their organizations and how to deploy resources efficiently and strategically to get the job done. foundations can become fully engaged partners by providing advice, management assistance, access to professional service firms, clout, and a host of other non-cash resources foundations should offer longer term support until the nonprofits are ready for the next stage of funding

The Starvation cycle

Foundations have unrealistic expectations of overhead costs -> Nonprofits lie about or neglect overhead costs -> Foundations believe their expectations are accurate -> Nonprofit structures deteriorate *As the cycle continues, nonprofits continue cutting overhead costs which will actually limit the nonprofits organizational capacity to fulfil their responsibilities if they don't have the financial support to cover their overhead. Foundations typically want overhead costs below 20% - in reality the median is 40%

Overhead Expenses

Full costs vs Surplus: - push to cover operating costs; more push to create reserves to not just break-even but to strengthen the finances of the nonprofit - Uncommon practice for nonprofits= issue of financial education-> many nonprofits are not used to having surplus (a savings) ex. Weingart foundation moved to reserve-building after the 2008 financial crisis-> portion of grants go to reserves

Grantmaking

Grant making is the tool we use in philanthropy to distribute those funds so we can address those problems Challenges to grant making: - Not accountable - No transparency - Grant makers want more outcomes - values of granmaking lies in risk but they are risk-averse - Grantees want less restrictions from grant maker

Tax Policy

Indirect support - Federal income tax exemption: does not apply to income from unrelated activities (applies to ALL nonprofits 501c's because of non-distribution constraint) - Charitable Donations Income tax Deduction: a 501c3 nonprofit qualifies for this tax deduction for donations to their organization. Individuals who make donations and itemize their taxes may subtract their gifts to these organizations from their taxable income amount so they pay taxes on less income (you can deduct up to 50% of AGI pre-covid), creating an incentive to give. It provides a larger 'discount' the more money you make (the higher the tax bracket you are in). The deduction is important as it is a government incentive to give to charitable nonprofits by reducing the cost of giving. However, many believe it should be changed as it disproportionally benefits wealthier donors and does not benefit all donors, thus people believe donations would continue without it. NOTE: APPLIES TO NONPROFITS, THE DONORS ONLY BENEFIT - State Property tax exemption: with budget decreases, some states are increasing regulation of the policy and are removing exemptions when nonprofits are not sufficiently benefiting state residents - State income credits for charitable donations: some states offer income tax credits for individual donations which are applied to tax bill (deductions applied to taxable income). These credits are typically small and targeted towards specific causes ex. In LA 36% credit up to $720 donation to playgrounds in depressed communities

Nonprofit funding models

Individual donations: 1. heartfelt connector- inspire a large segment of the population across income levels ex. make a wish foundation 2. Beneficiary builder- supported by those who have previously benefited from their services ex. hospitals, universities 3. Member motivator- current member-supported ex. congregations, churches Government: 1. Public provider: government outsources/contracts with nonprofit to provide service delivery 2. Policy innovator: cost-saving innovations that provide governments with new models to address existing issues 3. Beneficiary Broker: Nonprofits engaged in service delivery or mixed markets where the consumer chooses their place of service service so competition between firms for government funds Multiple Sources: 1. Market Maker: Work in market areas that are constrained (organ donations) where regulation limits for-profit activity but a market for the product or service remains 2. Local Nationalizer: National networks of local chapters. widespread problems with community interest. Each individual entity is small, but together they represent large organziations ex. Big brothers big sisters, Teach for America Concentrated Source: 1. Big Bettor: supported by single individual or foundation of few entities; may be funded by the founder with strong personal ties; strong financial base for quick growth around a focused issue ex. medical research Institutes Corporations: 1. Resource Recycler: Supported by in-kind donations from corporations that are redistributed; reduces waste; nonprofit is an intermediary between corporation and recipient; often international ex. AmeriCares Foundation get from readings??

Lobbying

Is the act of advocating for or against specific legislation either to the public (grassroots) or to legislators (direct) - Direct: "vote no on proposition 22" - Grassroots: expressing a view about legislation and urging the public to contact legislators 501c3s are not allowed to oppose or support candidates ->Johnsonamendment 501c4s are not subject to lobbying limits because their donations are not tax deductible *nonprofits may advocate generally for causes more easily with less restrictions but they may never campaign for a specific candidate. Instead they may create a 501c4 to execute a more extensive lobbying effort since they do not qualify for the charitable donations income tax deduction.

tax subsidy

Items that the government strategically avoids taxing to encourage purchasing behavior that aligns with government goals.

Carenegies Gospel of Wealth

Jusxtaposition: those who we must help are the ones who will help themselves/rarely need other help; those worthy of assistance with rarely need it - Argued for the obligation of wealthy to return riches to society within their lifetime

how: Accountability devices

Mandated Public Disclosure • The 990 and the 990-PF • Audited Financial Statements Measures of Social Benefit • Evaluation • Performance & Impact Measurement

Anchoring Theories of the Nonprofit Sector to explain why we have nonprofits today

Market Failure: there are limitations to the market in that the market system works well in supplying private goods (the goods we consume individually such as shoes, cars, clothing, food) but it has difficulty responding to demands for public goods (the the goods that can only be consumed collectively such as clean air, national defense, and safe neighborhoods). -> nonprofits as an alternative; if demand = heterogenous, nonprofits are better able to respond to demand because they allow groups of individuals to pool their resources voluntarily to produce collective goods they mutually desire -> demand=homogenous, then government will do a reasonable job Pluralism: nonprofits have the flexibility and freedom to express a variety of perspectives from social to political and religious Stakeholder/supply-side theory: a need for nonprofits is not enough to ensure that these organisations are created, a supply of individuals who take initiate to form them is more important Trust Goods: Goods you must put trust in the provider for such as nursing homes and day care due to the information asymmetries between buyers and sellers of goods and services in for-profit firms, whose profit-maximising objective may cause them to cut corners on unsuspecting consumers-> nonprofits act as an alternative for for-profit business providers because the non-distribution constraint makes them more trustworthy Modernization: as economies became more complex and populations more dispersed, traditional institutions (their kin networks) could no longer provide sufficient protections and people found it necessary to join voluntary groupings leading to the foundations that nonprofits were built upon Solidarity: the nonprofit sector was created in response to the need to foster sentiments of solidarity and equality for which the basis of our democracy was built on ex. gathering together for political purposes

Corporate Philanthropy

Need business case for giving • Employee engagement, marketing for expanded customer base & company's reputation, can not diminish shareholder value

non-distribution constraint

Nonprofit organizations may not distribute profits to employees and/or owners. Instead, profits should be reinvested in the organization to further the public good. This quality allows nonprofits to receive the federal income tax exemption as they are not motivated for personal gain.

Types of Private Foundations

Operating foundation: an uncommon structure that runs their own charitable programs internally and rarely make outside grants *must distribute either 85% of their net income or 4.25% of their assets annually Non-operating foundation: describe the majority of private grant making foundations - corporate foundation: vehicle for corporate philanthropy - Family foundation: family has majority board control *a minimum of 5% of their assets must be paid out through their charitable activity annually

Types of Nonprofits

Over 30 types of tax exempt nonprofits with 29 sub-types of 501c organizations: - 501c3 religious, charitable, educational, etc - 501c4 Social welfare - 501c5 Labor, agricultural, - 501c6 Chambers of commerce - 501c8 Fraternal beneficiary societies - 501c21 Black Lung Trusts

Why overhead is important?

Overhead funding is essential because underfunding it can lead to nonfunctioning computers, staff members who lack the training needed for their positions, and, in one instance, furniture so old and beaten down that the movers refused to move it Overhead leads to program success

Strategic/Venture Philanthropy vs. Foundations

People in nonprofits are frustrated their programs goals are not being achieved-> social problems persist and may even be worsening= limited impact Main issue with foundations is that they focus on program efficacy but are not suited to building the organizational strength necessary to implement their ideas - regard overhead/organizational capacity as a burden as a result nonprofits go underfunded - don't connect overhead expenses to program success foundations face little risk when making grants because they are often not spending enough compared to venture capitalists who invest in risky projects foundations assume an oversight role compared to partnership role that would develop strong managers investors engaged with nonprofit for 5-7 years whereas foundations will not fund any program for more than 2-3 years because nonprofits should become self-sustaining in that time

Sunsets for Private Foundations

Philanthropic strategy of "giving while living" 8-12% of foundations will sunset Reasons to sunset: greater impact by giving away larger amounts of money & preserve family mission Ways to sunset: spend down at rate to match termination date-> transfer ownership to community at end ex. gates foundation will sunset 20 years after trustees have passed Pros: - puts a lot of money in circulation - increases power in short term - better communication with grantees Cons: - long term life increases funds over time providing more to serve problems that may be greater later in time

Venture Philanthropy

Pro: Business approach in determination of how to give vs blindly giving-> giving away money more strategically What you give provides the result that you want Provide a solution that works Con: - reduction in ownership - finding investors can be time consuming - require a high roi - funding released from time to time after reaching certain milestones

501c Organizations

Public Serving: - 501c3 charitable organizations and funding intermediaries (public charities and private foundations) - 501c4 social welfare organizations - religious congregations Member serving: - 501c5 Labor unions - 501c6 Business associations - 501c8 Fraternal Societies

Tech-based philanthropy

Rise in number of young, technology-made philanthropists -Giving primarily to foundations & DAFs • Support scientific, strategic approach • Want innovative solutions • Measure impact • Value teams and collaboration ex. Arnold foundation are only motivated to solve problems Long term research agenda Rigourours review process for grants Prior evidence of success required

Types of Goods

Rival: Increased consumption of a good detracts from others' consumption of that good (not open to everyone) Excludable: can stop someone from accessing a good - Private Goods: goods that are excludable and rival such as laptops and doctor appointments - Club Goods: goods that are excludable and non-rival such as health insurance and country clubs because you must pay (excludable) but they are open to everyone (non-rival) - Common Pool Resources: goods that are non-excludable and rival such as emergency rooms and the fish in the ocean - Public Goods: goods that are non-excludable and non-rival-> you cannot stop people from accessing them and increased consumption does not detract from other's consumption; because of these qualities the private market fails to adequately supply them creating a market failure. As a result, the nonprofit sector exists to provide public goods such as herd immunity medical research, national defense, air quality, and education

Sunset vs Perpetuity

Sunset: - die -spend money now -immediate impact Perpetuity: - continue giving after death - gradual giving -long-term impact - legacy continues

Johnson Amendment

Tax code that restricts 501c3 nonprofits from endorsing/opposing political candidates - includes universities and religious congregations - congregations are automatically tax-exempt under the belief that taxing them would destroy the free exercise of religion thus elected officials tried repealing the Johnson amendment citing free speech of church - following citizens united decision there was a renewed push but courts still sided that the tax deduction subsidy argument and a tradeoff of free speech

What is the largest foundation in the US?

The Bill and Melinda Gates Foundation - Non-operating family foundation

SCOTUS Dartmouth Decision

The Supreme Court ruled that the state of New Hampshire had violated the contract clause in its attempt to install a new board of trustees for Dartmouth College - established the separation of state from donation control - set up the concept of private charitable organisations within constitutional law

Form 990

The annual reporting form that details the organizations revenue, expenses, mission, key salaries and grant making activity filed by public charities with at least $25,000 in revenue - 2007 revision added nonfinancial information like mission and program activity - 2008 revision included governance and compensation to increase transparency (audience changed from IRS to general public) -Schedule B is not public AKA can't see donor details only IRS sees them *This form is the primary source of data on charities and their operations which the public can access to evaluate the nonprofit. FORM 990-EZ for orgs with 200k-500k in assets FORM 990-EN for orgs with less than 50K in revenue

The Buffet Donation

The largest gift $$ to the largest Foundation (the gates foundation) by the richest man - requires Bill or Melinda to remain alive and active in the policy setting of the foundation - the funds must be used for charitable purposes - the funds can be used for administrative expenditures - the funds must be spent on top of the foundation's annual payout requirement

What is the key difference between nonprofit and for-profit hospitals in the US?

Their tax status

Private Foundations

are classified as grant making organizations that act as charitable intermediaries between donors and nonprofits - "financial services" for nonprofit sector

Charitable Choice

is the push to increase governments funds to faith-based organizations to offer social services PROS: - created in response to belief and fear that FBOs are more effective than government but are discriminated against in competition for public dollars CONS - attack on the separation of church and state because the government would be funding churches - there is evidence that suggests there is no significant discrimination against FBOs in public funding streams and only a minority are actively engaged in social service activities and that they are more likely to participate in short-term/emergency need rather than long-term solutions. CHARITABLE CHOICE IS NOT A FORMAL POLICY

Gen Z giving

more focused on charity and immediate results since giving online is easier and faster -give based on passion not risk

Payout Requirement Policy

private non-operating foundations are required to pay out a minimum of 5% of their assets through their charitable activity annually which prevents foundations from using the organization as a tax shelter and holds them accountable to perform charitable activities by mandating expenditures that benefit the public good. Since the average endowment growth rates are 7-8% annually, the 5% level allows private foundations to operate in perpetuity (because they are giving away as much as they are giving) - majority of foundations only use 5% a year - foundations that go over the minimum spend more on salaries & management which means they are more likely to be growing - average endowment growth rate is 8% growth rate ensures foundations remain in perpetuity Private operating foundations must distribute either 85% of their net income or 4.25% of their assets annually

Darren Walker and the Ford Foundation

raises key issues in the philanthropic sector such as: - contrast of founders with modern values: the founders were eugenicist probably wouldn't believe that a black gay male was the leader today

Governance

refers to how an organization is run. Specifically, governance includes informal operations of a firm, its financial management, legal and ethical responsibilities, mission alignment, and long-term strategic planning. - Good governance is crucial to a successful organization and reflects legal compliance, public disclosure, effective management, strong financial oversight, and responsible fundraising. Having an involved and effective board is a key element to good governance in a nonprofit which are largely responsible for a variety of functions within the nonprofit such as fundraising, planning, and monitoring programs and services.

Norm of self-interest

refers to the notion that individuals only act on the basis of their own material gain which places a big mistrust in nonprofit employees because this goes against what they stand for- which is to work on causes that don't directly affect them for nothing in return. This creates suspicion and hostility towards the nonprofit sector because they are inherently not acting in their self-interest by working to help others.

Donor-Advised Funds (DAFs)

separate funds maintained by a grantmaking charity where donors have an advisory role in distribution which increases donor control. Though the sponsoring organization ultimately controls how the funds are distributed, it typically honors the wishes of the donor. They are growing in popularity as there is no financial reporting for the donor and gifts to the DAF are still deductible from their taxes. It allows donors more flexibility in the timing for their gifts and the potential for anonymity. - They are often used within community foundation - donors have an advisory role in distribution= more control -provides immediate tax benefit while delaying spending on public goods

Tax Immunity

the doctrine that the Constitution does not allow one level of government to tax the essential functions of another; limits the government's ability to control and collect revenue.

Form 990-PF

the reporting form for private foundations - less detailed - does not include mission, organisational structure, and governance info

Lack of Transparency

• Boards are not accountable to donors, public • Foundations are not setup to be accountable to others • Don't compare outcomes • Little transparency of grantmaking strategies

Charity Fraud

• Federal Trade Commission announced legal action against 4 cancer charities defrauding donors to benefit own selves and families/friends • All four are connected to James Reynolds and his family • National Children's Leukemia Foundation being sued by attorney general's office for using only $57,541 of the $9.7 million raised for charitable purposes "Organizations spending 80 or 90 cents out of a dollar [on fundraising] have some explaining to do."

Shifting focus

• Financial oversight is critical but not the only obligation of the board • Need to focus on financial sustainability of their nonprofit • Boards, like funders, need to be comfortable with profits • Boards need to be more deeply engaged in the work of the nonprofit

Board Duties

• Fundraise (29%) • Monitor programs and services (32%) • Monitor own performance (17%) • Planning (44%) • Community relations (27%) • Public education/advertising (23%)

Good Governance

• Legal compliance & public disclosure: - Conflict of interest policies - Whistleblower policy - Policies and practices publicly available • Effective governance: - Active governing body - Board meets regularly - Board regulations reviewed regularly - Diverse board - Majority of board is independent - Board members are not compensated • Strong financial oversight: - Spend significant amount of funds on mission programming - Financial records and review • Responsible fundraising: - Donor's intent is followed - Protect privacy of donors - Acknowledgements of donations in compliance with IRS regulation

Prize Philanthropy

• Recognition Prizes - work previously completed; goals achieved, reward • Incentive Prizes - bring attention to an area, induce behavior/spending; competition based • Resource Prizes - after competition, winners given resources to complete project, meet goal

Facts & figures

- 1.54 million nonprofit organisations registered with IRS in 2016 (religious congregations that meet 501c3 status are automatically considered tax-exempt and are not required to register with IRS) - $1.05 trillion contribution to US economy in 2016 - 2018 total giving = $427.7 billion - 5.6% of US GDP and 10% of employment

Regulatory Policy

- Governance: IRS responsbile for oversight of nonprofits but lacks staff, budgets, and measures; only audited 0.71% of nonprofits in 2011; IRS was sued for not provided electronic versions of Form 990s PDFs which the judge ruled in favour of the public; nearly all applicants are approved but takes 2 years to get approval - Advocacy: Non-lobbying, lobbying, testimony, self-defense, election activity - Fundraising:

Participatory Grantmaking

- Working with communities - Building trust Giving circles most popular with women Common interest; pool resources to give away funds together Increase participation within philanthropy especially among minorities More strategic Greater impact Long process Will not favour everyone Power struggles in bigger groups

Non-lobbying

- discussing broad social issues without mentioning specific legislation - making available the results of non-partisan analysis, study, or research

501(c)(3) Nonprofits

- exempt from paying federal income tax - can only lobby to certain extent -> Johnson amendment: Tax code that restricts 501c3 nonprofits from endorsing/opposing political candidates (501c3s receive tax deduction as a trade-off for surrendering their freedom of speech to lobby) - Some receive donor tax deductions: - Public charities (biggest group) - Private Foundations - Congregations

Expenditure Policy

- for nonprofit providers how the government spends money to incentivize nonprofit work: - government spending programs = direct support - loans - Grants & contratcs

How to break the starvation cycle

- funders must change their expectations by shifting their focus from costs to outcomes. In this sense, the nonprofit will be encouraged to have a bigger impact without feeling the pressure to misrepresent data or cut overhead. - Funder's must also be clear about their intended outcomes because then the nonprofit will be able to track progress and remain accountable for their work. - Nonprofits should commit to understanding their real overhead costs and only reporting accurate data so that funder's can begin to understand the true cost of overhead. - Another main point is that nonprofits must educate their donors that overhead costs are essential components of everyday work that must be done in order to carry out programming of the organization.

Dominant Industries share of revenues

- social services 11% Mixed markets - education 17.2% - Health 59.3%

Charitable Deduction: A failure in Philanthropy

-support the wealthy more than the poor because only a small share of donations go to social welfare and justice issues and those with bigger incomes receive a bigger deduction - not a subsidy(subsidies are things the government chooses not tax & tax immunity limits the government's ability to control and collect revenue from an activity) 2018 Tax reform increased standard deduction which reduced the number of families that itemise, thus decreasing charitable donations 2020 CARES ACT removed the AGI limit on deduction

Animal products professor Graddy has

1. French bull dog tape dispenser 2. Cat doorstop 3. Flamingo journal

5 defining characteristics of a nonprofit according to Salamon

1. Organizations 2. Private, non-government, 3. Non-profit distributing 4. Self-governing 5. Voluntary/ non-compulsory

Givesmart: Grantmaker-Grantee relationship

1. Partnership- characterized by high productivity and shared goals 2. Amiable association- High productivity, different goals (perhaps because of limited direct involvement by the donor) 3. forced march- Low productivity, shared goals; donors are behaving like "owners" exerting control, instead of like-minded supporters exercising influence 4. Train wreck- Low productivity, different goals

Nonprofit Accountability

1. financial responsibility 2. good governance - transparency 3. adherence to donor intent and mission - Issue of multiple stakeholders and changes over time 4. effectiveness and public trust

Mistrust in the Nonprofit sector

1/3 of Americans lack confidence in nonprofits 70% feel nonprofits waste money while 10% feel nonprofits spend money well Trusted more than government - 74% trust charities with their money more than the government • 75% want nonprofits to have more sway in the policy making process Examples" • More than 250 nonprofits formed for September 11th support Many along with Red Cross & Salvation Army came under scrutiny for poor allocation of funds and fundraising techniques Red Cross set aside almost half of the 9/11 funds raised for operations and future reserves while donors thought funds were going to victim's families • EduCap Inc., a multibillion-dollar student loan nonprofit • Charged high interest rates on loans to high-risk borrowers • Large salaries with "lavish perks", corporate gulfstream

Public Charities

5% of public charities account for 80% of public charities expenditures -churches, schools, hospitals -All organizations organized and operated for charitable, religious, educational, or literacy purpose, or prevention of cruelty to children / animals.

A failure at failing

A failure at failing - Philanthropy should be risk-taking; willing to fail in hope of innovation - Few foundations take on risky projects

Sarbanes-Oxley Act

A law passed by Congress that requires the CEO and CFO to certify that their firm's financial statements are accurate Legislation passed in 2002 to deter corporate fraud and improve corporate governance • External Audit • Independent Audit Committee • Rotating Auditors • Written Conflict of Interest Policy • Formal Whistleblower Policy • Information/Document Destruction & Retention Policy