Neuhaus Education Center Policies

Privacy Policy

Copyright Policy

Whistleblower Policy

Conflict of Interest

Equal Employment and Enrollment Opportunity Policy


Privacy Policy

Neuhaus Education Center (NEC takes the privacy of its website users seriously and is committed to safeguarding user information. This privacy statement explains the personal information that the Center collects from users of www.neuhaus.org and how the Center uses, discloses, and protects such information. Please note that this privacy policy applies only to the web pages, tools and content owned and operated by the Center at this website, and does not apply to any information collected outside the website.

We encourage users to read through and understand our privacy statement. We may update this statement from time to time to address new issues or to reflect changes on our website, so please check back often. We may also contact users to inform them of any material changes to our privacy statement. If you have any questions or concerns about our privacy statement, please contact us at info@neuhaus.org.

What Information Is Collected

In general, you can visit this website without revealing your identity or providing any personal information. If, however, you decide to participate in certain activities, including our online registration, purchase of materials, or online giving program, we may ask for your name, address, email, phone number, and other information related to the activity, such as occupation, school, and/or grade level or specialization. Also, if you decide to make a donation to the Center or to purchase an item from the online store, we will ask for payment information, which includes a credit card number. In no case will we ask for your driver’s license number.

How Information Is Collected

We collect personally identifiable information from you when you voluntarily submit it. We do not use cookies or other internal tracking mechanisms to collect any personal information about you. 

How Information Is Used

Our primary purpose in collecting and processing your personal information is to: 

  • (1) provide the products, services, and resources that you request, such as registration for workshops and/or classes, receipt of our newsletter and class schedules, or periodic email updates; 
  • (2) respond to questions related to the products, services, resources, and events offered through this website; and
  • (3) send you materials on certain Center services, resources, and events about which you may be interested.

We also may use your personal information to notify you about updates to the site.

We do not sell or rent your personal information to anyone. Moreover, we do not share or otherwise disclose your personal information to outside parties other than third-party site administrators (for operational and maintenance purposes only). 

Who Has Access to Information

Access to your information is limited to those Center employees, such as administrators, who need it for administrative and programming purposes. 

How Information is Protected

We take reasonable measures to protect the privacy, accuracy, and reliability of any personal information you choose to provide to us and to protect such information from loss, misuse, unauthorized access, disclosure, alteration, and destruction. We also safeguard your personal information by limiting the number of employees who may access such information and by permitting access to it only for administrative and programming purposes.


How To Update Information

You will always have the opportunity to update your information. If you have submitted personal information through the Center website and you would like to access that information, you may send an email to info@neuhaus.org. We will use reasonable efforts to supply you with this information and update your information as requested.

How To End Participation

You can let us know at any time if you wish to end your participation in Center activities by emailing us at info@neuhaus.org. Within a reasonable time of your giving this notice, your information will become inactive in our database, and it will no longer be viewed, accessed, or used by Center employees. If, however, you decide to participate again in any Center activities, we reserve the right to access your prior information at the time of renewed contact or participation.

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Copyright

Neuhaus Education Center (Neuhaus) manuals and other course materials are proprietary, copyrighted works that cannot be copied or reproduced by any means, including graphic, electronic, mechanical, photocopying, etc., without the express written permission from Neuhaus. In addition, Neuhaus presentation materials such as PowerPoint presentations, overhead transparencies, lecture notes, handouts, etc. may be used only as designed for, and in conjunction with, the specific curriculum. To use Neuhaus materials in any other way requires the express written permission from Neuhaus.

The contents and lesson plan structures of Neuhaus curricula are covered by copyrights owned by Neuhaus. Any work or product based upon a copyrighted work is a derivative work. Therefore, any work based on any Neuhaus curriculum constitutes a derivative work and the creation and use of such a derivative work violates Neuhaus’ copyright. Thus, no changes can be made to the content or lesson plan structure of Neuhaus curricula without the express written permission from Neuhaus.

Whistleblower Policy

Any employee who in good faith reports an illegal act, including discrimination and harassment, by any other employee or Board member may not be suspended, terminated, or subject to retribution as a result of the report.

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Conflict of Interest Policy

Article I: Purpose
Article II: Definitions
Article III: Procedures
Article IV: Records of Proceedings
Article V: Compensation
Article VI: Annual Statements
Article VII: Periodic Reviews
Article VIII: Use of Outside Experts

Article I
Purpose

The purpose of the conflict of interest policy is to protect Neuhaus Education Center's contemplating entering into a transaction or arrangement that might benefit the private interest of an officer or director of the Organization or might result in a possible excess benefit transaction. This policy is intended to supplement but not replace any applicable state and federal laws governing conflict of interest applicable to nonprofit and charitable organizations.

Article II
Definitions

  1. Interested Person
    Any trustee, principal officer, or member of a committee with governing board delegated powers, who has a direct or indirect financial interest, as defined below, is an interested person.
  2. Financial Interest
    A person has a financial interest if the person has, directly or indirectly, through business, investment, or family:
    1. An ownership or investment interest in any entity with which the Organization has a transaction or arrangement,
    2. A compensation arrangement with the Organization or with any entity or individual with which the Organization has a transaction or arrangement, or
    3. 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.
      Compensation includes direct and indirect remuneration as well as gifts or favors that are not substantial.
      A financial interest is not necessarily a conflict of interest. Under Article III, Section 2, a person who has a financial interest may have a conflict of interest only in the appropriate governing board or committee decides that a conflict of interest exists.

Article III
Procedures

  1. 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 directors and members of committees with governing board delegated powers considering the proposed transaction or arrangement.
  2. Determining Whether a Conflict of Interest Exists
    After disclosure of financial interest and all material facts, and after any discussion with the interested person, he/she shall leave the governing board or committee meeting while the determination of a conflict of interest is discussed and voted upon. The remaining board or committee members shall decide if a conflict of interest exists.
  3. Procedures for Addressing the Conflict of Interest
    1. An interested person may make a presentation at the governing board or committee meeting, but after the presentation he/she shall leave the meeting during the discussion of, and the vote on, the transaction or arrangement involving the possible conflict of interest.
    2. The chairperson of the governing board or committee shall, if appropriate, appoint a disinterested person or committee to investigate alternatives to the proposed transaction or arrangement.
    3. After exercising due diligence, the governing board or committee shall determine whether the Organization can obtain with reasonable efforts a more advantageous transaction or arrangement from a person or entity that would not give rise to a conflict of interest.
    4. If a more advantageous transaction or arrangement is not reasonably possible under circumstances not producing a conflict of interest, the governing board or committee shall determine by majority vote of the disinterested directors whether the transaction or arrangement is in the Organization's best interest, for its own benefit, and whether it is fair and reasonable. In conformity with the above determination it shall make its decision as to whether to enter into the transaction or arrangement.
  4. Violations of the Conflicts of Interest Policy
    1. If the governing board or committee has reasonable cause to believe 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 governing board or committee determines the member has failed to disclose an actual or possible conflict of interest, it shall take appropriate disciplinary and corrective action.

Article IV
Records of Proceedings

The minutes of the governing board and all committees with board delegated powers shall contain:

  1. The names of the persons who disclosed or otherwise were found to have a financial interest in connection with an actual or possible conflict of interest, the nature of the financial interest, any action taken to determine whether a conflict of interest was present, and the governing board's or committee's decision as to whether a conflict of interest in fact existed.
  2. The names of the persons who were present for discussions and votes relating to the transaction or arrangement, the content of the discussion, including any alternatives to the proposed transaction or arrangement, and a record of any votes taken in connection with the proceedings.

Article V
Compensation

  1. A voting member of the governing board who receives compensation, directly or indirectly, from the Organization for services is precluded from voting on matters pertaining to that member's compensation.
  2. A voting member of any committee whose jurisdiction includes compensation matters and who receives compensation, directly or indirectly, from the Organization for services is precluded from voting on matters pertaining to that member's compensation.
  3. No voting member of the governing board or any committee whose jurisdiction includes compensation matters and who receives compensation, directly or indirectly, from the Organization, either individually or collectively, is prohibited from providing information to any committee regarding compensation.

Article VI
Annual Statements

Each director, principal officer and member of a committee with governing board delegated powers shall annually sign a statement which affirms such person:

  1. Has received a copy of the conflicts of interest policy,
  2. Has read and understands the policy,
  3. Has agreed to comply with the policy, and
  4. Understands the Organization is charitable and in order to maintain its federal tax exemption it must engage primarily in activities which accomplish one or more of its tax-exempt purposes.

Article VII
Periodic Reviews

To ensure the Organization operates in a matter consistent with charitable purposes and does not engage in activities that could jeopardize its tax-exempt status, periodic reviews shall be conducted. The periodic reviews shall, at a minimum, include the following subjects:

  1. Whether compensation arrangements and benefits are reasonable, based on competent survey information, and the result of arm's length bargaining.
  2. Whether partnerships, joint ventures, and arrangements with management organizations conform to the Organization's written policies, are properly recorded, reflect reasonable investment or payments for goods and services, further charitable purposes and do not result in inurement, impermissible private benefit or in an excess benefit transaction.

Article VIII
Use of Outside Experts

When conducting the periodic reviews as provided for in Article VII, the Organization may, but need not, use outside advisors. If outside experts are used, their use shall not relieve the governing board of its responsibility for ensuring periodic reviews are conducted.

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Equal Employment and Enrollment Opportunity Policy

Neuhaus Education Center provides equal program enrollment and employment opportunity without regard to race, color, sex, religion, national origin, age, gender, sexual orientation, or disability. Neuhaus conforms to all applicable federal and state laws, rules, guidelines and regulations and provides equal employment opportunity in all employment and employee relations.

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