Policies

This privacy statement discloses the privacy practices for the official website of N Street Village, Inc., a not-for-profit organization incorporated under the US Internal Revenue Code Sec. 3(c). In this statement N Street Village, Inc. and www.nstreetvillage.org will be referred to as N Street Village.

Information Collection and Use

N Street Village is the sole owner of the information collected on this site. We will not sell, share, or rent this information to others.

E-newsletter

If a user wishes to subscribe to our newsletter, we require an email address and name only. Users have the option to sign up for additional mailings by providing their postal address. You can subscribe or unsubscribe from the newsletter by emailing communications@www.nstreetvillage.org with REMOVE in the subject line.

Links

This site contains links to other sites. Please be aware N Street Village does not claim any responsibility for the privacy practices of other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of each website they visit that collects personally identifiable information. This privacy statement applies solely to information collected by www.nstreetvillage.org.

Security

This site takes every precaution to protect our users’ information, and we have security measures in place to protect the loss, misuse, and alteration of the information under our control.

Notifications of Changes

If we decide to change our privacy policy, we will post a notice of those changes on our home page so users are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

Questions or Comments

If you have any questions about this privacy statement, the practices of this site, or your interaction with this site, you can contact:

Website Manager, N Street Village, Inc., 1333 N Street NW, Washington, D.C. 20005 or communications@www.nstreetvillage.org

1. Agreement to Terms

N Street Village, Inc. provides access and use of this site (‘Site’) subject to your agreement to the following ‘Terms of Use’ (the ‘Terms’). Please read these Terms carefully before accessing or using the Site. By accessing or using the Site, you agree to be bound by these Terms.

The Terms, as well as the Site (and information contained within the Site) may be updated or revised from time to time without notice to you. You agree to periodically review these Terms, and your continued access to or use of the Site shall constitute your acceptance of the updated or revised Terms.

2. Ownership and Restrictions on Use of Materials

Unless otherwise noted, all materials, including images, illustrations, designs, icons, photographs and written material contained on the Site (collectively, the ‘Contents’) are copyrights, trademarks, and/or other intellectual properties owned or controlled by N Street Village, Inc.
The Contents of the Site are intended solely for personal, non-commercial use by the users of our site. You may view, copy, and print the Contents displayed on this site subject to the following conditions:

(i) you use the material for non-commercial use only,

(ii) you keep intact all copyright and other proprietary notices,

(iii) you make no modifications to any materials,

(iv) you do not use the materials in a manner that suggests an association with any of our services.

3. No Liability

Under no circumstances will N Street Village, Inc. be liable for any consequence relating directly or indirectly to any action or inaction you take based on the information, services or other material on the Site. While N Street Village, Inc. will attempt to keep its Site current, accurate and complete, N Street Village, Inc. and its suppliers cannot guarantee, and will not be responsible for any damage or loss related to the timeliness, accuracy or completeness of the information, services, or other material on the Site.

4. Internet Links

The Site may provide links to other Internet sites. N Street Village, Inc. has no control over such sites; N Street Village, Inc. does not endorse, and is not responsible for any such sites or the information, material, products or services contained on or accessible through those sites. You acknowledge that N Street Village, Inc. shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance upon any such information, material, products or services.

5. Indemnification

You agree to indemnify, defend and hold harmless N Street Village, Inc., its affiliates, governing board, officers, agents, employees, partners, and suppliers from any liability, loss, claim, demand, and expense (including reasonable attorneys’ fees) related to (a) your use of the Site or (b) your violation of these Terms.

6. Modifications to Site

N Street Village, Inc. reserves the right to, from time to time, discontinue either, temporarily or permanently, the information, services, products, and/or other content to the Site.

7. Disclaimer of Warranty

YOU EXPRESSLY UNDERSTAND AND AGREE THAT THIS SITE, AND ALL INFORMATION AND CONTENT ON THE SITE, IS PROVIDED ON AN ‘AS IS’ AND ‘AS AVAILABLE’ BASIS. N STREET VILLAGE AND ITS INFORMATION SUPPLIERS DISCLAIM ALL EXPRESS AND IMPLIED WARRANTIES WITH REGARD TO THE SITE AND ALL INFORMATION, SERVICES AND MATERIALS CONTAINED ON THE SITE.

N STREET VILLAGE MAKES NO WARRANTY THAT (a) THE SITE WILL MEET YOUR REQUIREMENTS OR THAT THE RESULTS THAT MAY BE OBTAINED FROM THE SITE WILL BE SATISFACTORY; (b) THE SITE WILL BE UNINTERRUPTED, TIMELY, SECURE, OR ERROR-FREE; (c) THE QUALITY OF ANY PRODUCTS, SERVICES, INFORMATION OR OTHER MATERIAL PURCHASED OR OBTAINED BY YOU THROUGH THE SITE WILL MEET YOUR EXPECTATIONS, AND; (d) ANY ERRORS IN THE SITE WILL BE CORRECTED.

8. General Provisions

These Terms constitute the entire agreement between you and N Street Village, Inc. and govern your use of the Site, superseding any prior agreements between you and N Street Village regarding the Site (including, but not limited to, any prior versions of these Terms).

These Terms and the resolution of any dispute related to these Terms or the Site shall be governed by and construed in accordance with the laws of the District of Columbia, without giving effect to any principles of conflicts of law. N Street Village’s failure to insist upon strict enforcement of any provision of these Terms shall not be construed as a waiver of any provision or right. If any provision of these Terms is held to be invalid or unenforceable, the remaining provisions of these Terms will be enforced in accordance with their terms. The section headings in these Terms are for convenience only and have no legal or contractual effect.

9. Termination

These terms are effective until terminated by either party. You may terminate these terms at any time by discontinuing use of the Site and destroying all content obtained from the Site. Your access to the Site may be terminated immediately without notice from us if, in our sole discretion, you fail to comply with any term or provision of these terms. Upon termination, you must cease use of the Site and destroy all contents obtained from the Site.

10. Contact Us

If you have any comments of questions regarding these Terms, you may contact us at: Website Manager, N Street Village, Inc., 1333 N St. NW, Washington, D.C. 20005 or communications@www.nstreetvillage.org

Purpose. The purpose of the conflicts of interest policy is to protect the Corporation’s interest when it is contemplating entering into a transaction or arrangement that might benefit the private interest of an interested person. This policy is intended to supplement but not replace any applicable state laws governing conflicts of interest applicable to public charities.

Definitions. For the purpose of these bylaws and all Corporation rules, regulations and policies promulgated from time to time in furtherance thereof, an interested person shall be defined as any person who is or was during the previous five years in a position to exercise substantial influence over the Corporation’s affairs including any Director, officer, substantial donor, senior manager or member of a committee with board-delegated powers (each a “Fiduciary”).

1. A Fiduciary has a financial interest (a “Financial Interest”) if he or she has, directly or indirectly, through any member of his or her family, any business or professional associate, or any entity with which he or she is connected:
   • an ownership or investment interest in any entity with which the Corporation has a transaction or arrangement; or
   • a compensation arrangement with the Corporation or any entity or individual with which the Corporation has a transaction or arrangement; or
   • a potential ownership or investment in, or compensation arrangement with, any entity or individual with which the Corporation is negotiating a transaction or arrangement.
2. Compensation includes direct and indirect remuneration as well as gifts or favors that are substantial in nature.
3. A family member means a spouse, siblings (including half siblings), spouses of siblings, ancestors, children and other descendants and spouses of children and other descendants.
4. An entity means any corporation in which the Fiduciary or a family member owns more than 35 percent of its combined voting power; any partnership in which the Fiduciary or a family member owns more than 35 percent of the profits interest; and a trust or estate in which the Fiduciary or a family member owns more than 35 percent of the beneficial interest.
5. A conflict of interest means any situation in which a Fiduciary’s interests may be adverse to the interests of the Corporation; and any situation in which a Fiduciary is in a position to influence a decision of the Corporation in such a way that it will, or might appear to, benefit the Fiduciary, a family member of the Fiduciary, or an entity to which either the Fiduciary or a family member of the Fiduciary are related. A conflict of interest includes Financial Interests.
   1. A Financial Interest is not necessarily a conflict of interest. A person who has a financial interest may have a conflict of interest only if the Board or appropriate committee of the Board decides that a conflict of interest exists.

Disclosure. In connection with any actual or possible conflicts of interest, any Fiduciary shall disclose any and all material facts to the President or Chair at the earliest possible time after the conflict of interest becomes known to the Fiduciary and should be made a matter of record through such annual or other reporting and certification procedures as the Directors shall require from time to time.

Determination and Procedure. Disclosure of the actual or possible conflict of interest and all material facts shall be made to the Directors or the members of the governing committee of the Board delegated powers to consider the proposed transaction or arrangement. After discussion with the relevant Fiduciary, the Directors or the members of the governing committee of the Board shall finally determine whether any conflict of interest exists. The Fiduciary shall leave the Directors’ meeting or the meeting of the governing committees of the Board while the determination of a conflict of interest is discussed and voted upon. If the Directors or the members of governing committees of the Board determine that a conflict of interest exists with respect to a transaction or situation, the Directors or the members of governing committees of the Board must take the following actions:

1. allow the Fiduciary to make a presentation to the Board, but after such presentation, the Fiduciary shall leave the meeting during the discussion of, and the vote on, the transaction or situation that results in the conflict of interest;
2. appoint, if the Directors deem it appropriate to do so, a disinterested person or committee to investigate alternatives to the transaction or situation;
3. after exercising due diligence, determine by a majority vote whether the Corporation can obtain a more advantageous transaction or situation with reasonable efforts from a person that would not give rise to a conflict off interest; and
4. if a more advantageous transaction or situation is not reasonably possible under circumstances not producing a conflict of interest, determine by majority vote of disinterested Directors present at such meeting whether the transaction or situation is in the Corporation’s best interest and for its own benefit; and whether it is fair and reasonable to the Corporation; and in conformity with the above determination it shall make its decision as to whether to enter the transaction or situation.

Additional Compensation Procedural Rules

1. A voting member of the Board who receives compensation, directly or indirectly, from the Corporation for services is precluded from voting on matters pertaining to the member’s compensation.
2. A voting member of the Board whose jurisdiction includes compensation matters and who receives compensation, directly or indirectly, from the Corporation for services is precluded from voting on matters pertaining to that member’s compensation.
3. No voting member of the Board or committee delegated powers by the Board whose jurisdictions includes compensation matters and who receives compensation, directly or indirectly, from the Corporation, either individually or collectively, is prohibited from providing information to any committee regarding compensation.

Violations of Conflicts of Interest Policy

1. If the Board or the members of the governing committee of the Board has reason to believe that a member has failed to disclose actual or possible conflicts of interest, it shall inform the member of the basis for such belief and afford the member an opportunity to explain the alleged failure to disclose.
2. If, after hearing the member’s response and after making further investigation as warranted by the circumstances, the Board or committee determines the member has failed to disclose an actual or possible conflict of interest, it shall take appropriate disciplinary action and corrective action.

Recordkeeping. The minutes of the Directors’ meetings and all committees with board-delegated powers shall include:

1. the documentation, including comparability data, upon which the Directors based their decision that a transaction or situation is in the Corporation’s best interest and is fair and reasonable to the Corporation;
2. the names of the Fiduciaries who disclosed or were otherwise found to have a financial interest in connection with an actual or possible conflict, the nature of the financial interest, any action taken to determine whether a conflict of interest was present, and whether the Directors determined that there was indeed a conflict of interest; and
3. the names of the persons who where present for discussions and votes relating to the transaction or situation; the content of these discussions, including any alternatives to the proposed transaction or situation; and a record of any votes taken.

Distribution of and Assent to the Policy. Each Fiduciary shall sign an annual statement that he or she:

1. has received a copy of the Corporation’s conflict of interest policy;
2. has read and understands the policy;
3. agrees to comply with the policy;
4. understands that the policy applies to the Board and all committees having board-delegated powers; and
5. understands that the Corporation is a tax-exempt organization and that in order for it to maintain its tax-exempt status, it must continuously engage primarily in activities which accomplish one or more of its tax-exempt purposes.

Our Commitment to Our Donors:

We will not sell, share or trade our donors’ names or personal information with any other entity, nor
send mailings to our donors on behalf of other organizations.

This policy applies to all information received by N Street Village, both online and offline, including
electronic, written and oral communications.

To the extent any donations are processed through a third-party service provider, our donors’
information will only be used for purposes necessary to process the donation.

General

N Street Village requires directors, officers, and employees to observe the highest standards of business and personal ethics in the conduct of their duties and responsibilities.  As employees and representatives of N Street Village, we commit to acting honestly and with integrity in fulfilling our responsibilities and to comply with all applicable laws and regulations.

The purpose of this policy is to encourage all participants to disclose any wrongdoing that may adversely impact N Street Village, its clients and stakeholders, or the public at large.  It is the duty of all directors, officers, and employees to report violations or suspected violations in accordance with this policy.

Definitions

Good faith.  Good faith is evident when the report is made without malice or consideration of personal benefit and the complainant has a reasonable basis to believe that the report is true; provided, however, that a report does not have to be proven to be true to be made in good faith.  Good faith is lacking when the disclosure is known to be malicious or false.

Wrongdoing.  Examples of wrongdoing include, but are not limited to, fraud, including financial and accounting fraud, violation of laws and regulations, violations of N Street Village bylaws and policies, unethical behavior or practices, endangerment to public health or safety, and negligence of duty.

Adverse employment action.  Examples of adverse employment action include, but are not limited to, demotion, suspension, termination, transfer to a lesser position, denial of promotions, denial of benefits, threats, harassment or denial of compensation as a result of the employee’s report of wrongdoing, or any manner of discrimination against an employee in the terms and conditions of employment because of any other lawful act done by the employee pursuant to this policy.

No Retaliation

No director, officer or employee who in good faith reports wrongdoing shall suffer any adverse employment action.  An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment.  This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns within the organization prior to seeking resolution outside the organization.

Reporting Violations

Employees shall first share their questions, concerns, suggestions, or complaints concerning violations with the person who can address them properly, which in most cases is the supervisor of the alleged wrongdoer.  However, those employees not comfortable speaking with the supervisor or those employees not satisfied with the supervisor’s response are encouraged to report the concern to the CEO.  Should the concern involve suspected fraud, the CEO, or a member of the board of directors, or if the reporting party is uncomfortable making the report to the CEO, then such concerns should be taken directly to N Street Village’s Compliance Officer within five business days of the discovery of the incident or the response from the supervisor.  The chair of the Audit Committee serves as N Street Village’s Compliance Officer.  Should the complaint concern the Compliance Officer, notice should be given to the Chair of the Board of Directors.  Contact information for both of these officers is posted on the employee notice board.  

Anyone filing a complaint must be acting in good faith and have reasonable grounds for believing the information disclosed indicates wrongdoing.  Allegations that prove not to be substantiated and which are shown to have been made maliciously or knowingly to be false will be the basis for serious disciplinary action.

Violations or suspected violations may be submitted on a confidential basis by the complainant or may be submitted anonymously to the Compliance Officer.  Reports of suspected wrongdoing will be kept confidential to the extent possible, consistent with the need to conduct an adequate and thorough investigation.  

Investigation and Resolution

The Compliance Officer is responsible for investigating and resolving all reported complaints and allegations concerning violations of this policy and shall send notification of receipt of the report to the complainant (if known) within five business days.  The CEO shall report to the Compliance Officer all complaints of which s/he is aware within five business days of becoming aware of the complaint.  

The following factors shall be considered in determining whether management or the Audit Committee should investigate an allegation:

Who is the alleged wrongdoer?  If an executive officer, senior financial officer or other senior management employee is alleged to have engaged in wrongdoing, the Audit Committee shall perform the investigation.  Allegations regarding other employees may properly be handled by management.

How serious is the wrongdoing?  If, for example, the alleged action would constitute a violation involving the integrity of the financial statements of the organization, the Audit Committee should conduct the investigation, making use of legal counsel where appropriate and necessary.

The Compliance Officer has direct access to the Audit Committee of the board of directors and shall work with them until the matter is resolved and appropriate corrective action taken if warranted.  The Compliance Officer is required to report to the Audit Committee at least annually on compliance activity.

Contact Information 

Compliance Officer: Ruth Byrd, JD, 202-939-2045
Board Chair: Peter Shields, 202-719-3249