Our policies

Grievances and reporting concerns

For discrimination, retaliation, or a disability or language access problem in our programs, use the Civil Rights Complaint and Grievance Procedure. It includes the coordinator’s direct email, phone, and mailing address, assistance with filing, response targets, and appeals.

For a concern about your experience with GraduateSmart, email support@graduatesmart.org. Describe what happened, when it happened, and the resolution you are seeking.

Suspected illegal, unethical, fraudulent, or improper conduct is covered by our Whistleblower and Anti-Retaliation Policy. This includes misuse of charitable assets, undisclosed conflicts, falsified records, safety threats, violations of adopted policies, and improper scholarship administration.

Who receives a report

The Secretary serves as the Compliance Officer and reports directly to the Board. Under the policy, reports should ordinarily be made to the Compliance Officer in writing, by paper or email. For now, our website reporting address is support@graduatesmart.org. Address a governance report to the Secretary/Compliance Officer.

About this interim address: The founder reads this inbox. It is not an independent or anonymous reporting channel. If your concern involves the founder, or you need to avoid this inbox, use an alternate route under the policy rather than sending sensitive details here.

If the Compliance Officer is involved, the policy permits reporting directly to the President, Audit Committee Chair, or Board Chair if there is no audit committee. If you reasonably believe all of those officials are involved, the policy provides for reporting to the New York Attorney General’s Charities Bureau.

Investigation, confidentiality, and protection

The Compliance Officer or alternate conducts or supervises the investigation and reports its status and results to the Board. Confidentiality is protected to the extent possible consistent with a fair and complete investigation. Anonymous reports are accepted under the policy, although they may be harder to investigate; sending ordinary email can reveal your identity.

The policy prohibits retaliation for good-faith reporting, participation in an investigation, or refusal to participate in improper conduct. Knowingly false or malicious reports are not protected. Retaliation can result in disciplinary action, including removal or termination.

Read the full Document Retention and Whistleblower Policies (PDF)

Scholarship non-discrimination

The planned GraduateSmart Direct Scholarship Awards Program does not discriminate on the basis of race, color, national or ethnic origin, religion, gender, sexual orientation, gender identity, age, marital status, or disability.

The application package sets out objective selection criteria and a standardized scoring rubric. Our Conflict of Interest Policy requires selection criteria to be published in application materials and applied consistently to all applicants in a cycle. Committee members must disclose relationships with applicants and recuse themselves when a conflict exists.

Source: Form 1023 Schedule H, Section I, “Nondiscrimination,” and Conflict of Interest Policy, Article X. This statement concerns the planned scholarship program; it does not announce an open application cycle.

Read the scholarship safeguards in Article X (PDF)

Conflict of interest

Directors, principal officers, committee members with Board-delegated powers, and key employees must disclose actual or possible financial conflicts. Interested people leave the meeting for the conflict determination and for deliberation and voting on the affected transaction. Disinterested directors review alternatives and determine whether a transaction is fair, reasonable, and in the Corporation’s best interest. Decisions and votes are recorded in the minutes.

Covered officials sign annual disclosure statements. Scholarship awards cannot benefit directors, officers, key employees, substantial contributors, or their relatives. Scholarship committee conflicts require disclosure and recusal.

Read the full Conflict of Interest Policy (PDF)

Document retention and destruction

Our policy applies to organizational records in paper and electronic form. Formation documents, bylaws, Board minutes, tax filings, and specified scholarship records are retained permanently. Many financial records, donor records, annual conflict disclosures, and scholarship applications have seven-year retention periods. The full schedule sets out the applicable periods; the longest period applies when a record falls in more than one category.

The Treasurer or designee reviews records annually. Sensitive records are securely destroyed after the applicable period, with a permanent destruction log. A litigation hold immediately suspends destruction of relevant records until the President lifts the hold in writing. Electronic records follow the same schedule as paper records.

Student and platform-user information is governed by the platform’s own privacy policy, as specified in the retention schedule.

Read the complete retention schedule and procedures (PDF)

Bylaws and governance

Our bylaws define the Board’s authority, director terms, officer responsibilities, meetings, committees, conflicts of interest, and corporate records. Visit our Governance page for more about oversight, or request a copy of the bylaws at support@graduatesmart.org.

Privacy and website terms

Read our Privacy Policy and Terms of Use for this nonprofit website. Student accounts and data on graduatesmart.org are covered by the student platform’s Privacy Policy.