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Policies

NOTICE OF NONDISCRIMINATORY POLICY AS TO STUDENTS OF INDIAN COMMUNITY SCHOOL OF MILWAUKEE, INC.

ANTI-DISCRIMINATION EMPLOYMENT POLICY

CONFLICT OF INTEREST/NEPOTISM POLICY

No person will be hired for or transferred or promoted to a position if that hire, transfer or promotion would create a conflict of interest or would result in the direct supervision of one relative in the following list by another:

Those of legal foster relationship to the same degree of kinship.

The School also will not hire for any position any person who is a relative of the Chief Executive Officer or of the Human Resources Manager, if that person falls into any of the just-listed categories.

In addition, particularly given the School's prohibition against consensual intimate relationships between supervisors and those employees under their supervision (see the "Anti-harassment Policy", set forth above), the School will not hire, transfer or promote a person to any position in which that person would be in a direct supervisor-supervisee relationship with an employee with whom, the School concludes, that person apparently has a romantic relationship or any other relationship that might compromise the supervisor's objectivity. In the event employees already in a direct supervisor-supervisee relationship appear to the School to have developed a romantic relationship or any other relationship that might compromise the supervisor's objectivity, the School at its discretion may transfer or terminate the employment of one or both of the employees.

CONFLICT OF INTEREST POLICY

PURPOSE

The Indian Community School of Milwaukee, Inc. (the "School") is committed to integrity and fairness in the conduct of all of its activities. All decisions of the School’s Board of Directors made directly or by delegation through its:

• directors;
• officers;
• standing, ad hoc, and advisory committees;
• consultants;
• advisors; and
• employees

shall be made solely on the basis of a desire to promote the best interests of the School. From time to time, potential conflicts of interest or the appearance of conflicts of interest inevitably will arise. The Board will deal with such conflicts of interest openly and in accordance with the following principles and procedures.

This Conflict of Interest Policy (the "Policy") is intended to supplement, but not replace, any federal or state laws governing conflicts of interest applicable to not-for-profit organizations that are described in Section 501(c)(3) of the Internal Revenue Code of 1986 (the "Code") and are public charities described in Code Sections 170(b)(1)(A)(ii) and 509(a)(1). This Policy may be amended from time to time by the Board of Directors.

DISCLOSURE

Each director, officer, committee member, consultant, advisor and employee of the School will be annually provided with a copy of this Policy.

Before commencing duties as a director, officer, non-director committee member, or key School employee, such person must execute the Conflict of Interest Disclosure Statement. So long as such person’s relationship continues with the School, that person will annually execute and continuously abide by the Conflict of Interest Disclosure Statement as it exists from time to time. For purposes of this requirement, the term "key employees" shall mean those employees with authority to make administrative decisions on behalf of the School and generally shall include those employees who are identified as key employees on the School’s annual Form 990.

All actual and potential conflicts of interests must be immediately disclosed to the Board of Directors or its designee. By way of illustration but not in limitation, actual and potential conflicts of interest include:

• Service as a board member, trustee, officer, or employee of any organization that applies for financial assistance from the School or to which the School provides financial assistance;
• Service as a board member, trustee, officer, or employee of, or Material Interest in, an organization with which the School conducts or may conduct financial or business transactions (including vendor relationships);
• Similar service with or Material Interest in any such organization by any Family Member or other Related Party of a director, officer, committee member, consultant, advisor, or employee;
• Any interest that an objective third party could reasonably believe could cause the individual’s action or contemplated action to be affected in whole or in part by self-interest or by an interest favoring a Family Member or other Related Party; and
• Any other situation that may prevent the director, officer, committee member, consultant, advisor, or employee from acting impartially and in the best interests of the School.

When in doubt as to the existence of a conflict of interest, disclosure is required.

All directors, officers, committee members, consultants, advisors, and employees are under a continuing obligation to make full disclosure to the Board of Directors or its designee of all situations involving either actual or potential conflicts of interest, whenever such situations may arise.

The term "Family Member" means an individual’s spouse, domestic partner, grandparent, great grandparent, sibling, child, grandchild, great grandchild, immediate household member, and the spouses of the individual’s sibling, child, grandchild, great grandchild, and household member.

The term "Related Party" means any person to whom the individual is closely related (whether through blood, adoption, marriage, foster care, putative fatherhood, engagement, or any other close relationship) such that an objective third party could reasonably believe that the individual could be unable to maintain objectivity with respect to the person.

The term "Material Interest" means: (1) ownership of 10% or more of the equity or profits interest in an entity; or (2) the possibility that the individual may receive a financial or nonfinancial benefit, interest, or opportunity as a result of taking action on behalf or otherwise advocating for another person or entity. The term "Material Interest" generally does not include de minimis financial holdings in major institutions with which the School conducts or may conduct business or financial transactions.

The Chair of the Board shall determine the extent to which this Policy shall apply to any person not specifically identified above.

Disclosure of Service to Other Organizations

Prior to joining the board of directors or any committee of a grantee organization, potential grantee organization, or organization with which the School conducts or may conduct financial or business transactions, key employees must first obtain the approval of the Chair. Committee members must discuss any such intentions with the Chair prior to such service. Directors shall discuss any such intentions of their own with the full Board of Directors before committing to any such service.

It is expected that directors, officers, committee members, consultants, advisors, and employees will exercise good judgment in avoiding service to organizations that are primarily interested in gaining a financial or other benefit from a relationship to the School.

Special Situations

Individuals may be confronted with special situations that are not specifically addressed by this Policy. If any individual has a question as to the proper course of action, the matter should be disclosed to the Chair, Vice-Chair, or the Board of Directors. The Chair, Vice-Chair, or the Board of Directors, as the case may be, shall determine the appropriate handling of such special situations.

AVOIDANCE OF EXCESS BENEFIT TRANSACTIONS

The School shall avoid any transaction that results in an "excess benefit transaction" within the meaning of Code Section 4958 and the Treasury Regulations thereunder. Code Section 4958 and the Treasury Regulations thereunder state that if the School pays more than fair market value to one of its disqualified persons (e.g., a director, officer, key employee) for any property or services provided by such person, then the disqualified person will be subject to a penalty tax equal to 25% of the amount of the overpayment. The disqualified person must return the amount of the overpayment to the School or be subject to an additional penalty tax equal to 200% of the amount of the overpayment. Further, the School’s directors who approved the overpayment may be subject personally to a penalty tax in certain circumstances.

The Treasury Regulations create a procedure through which the School can demonstrate that compensation paid to its disqualified persons is reasonable and therefore not an excess benefit transaction. This procedure generally involves obtaining comparability data, requiring interested persons to abstain from the vote on the matter, and contemporaneously documenting the deliberation and decision-making process. Accordingly, the School shall take steps to review and approve compensation paid to its disqualified persons pursuant to the "rebuttable presumption" procedures set forth in the Treasury Regulations.

DEALING WITH CONFLICTS

Following an individual’s disclosure of an actual or potential conflict of interest, the Board of Directors or its designee shall determine whether a conflict of interest exists and, if so, shall determine the proper course of action to address the conflict of interest. The proper course of action generally shall include abstention from any vote on the matter by the individual with the conflict of interest. If each of the directors or members of a committee, as the case may be, has a conflict of interest with respect to a matter to be considered by the Board of Directors or the committee, then the Board of Directors shall develop an appropriate method of addressing the conflict of interest.

In general, after having fully disclosed any actual or potential conflict of interest, a director, officer, committee member, consultant, advisor, employee, or any other individual determined by the Chair to be subject to this Policy must:

• provide information requested by the Board of Directors or committee with respect to the conflict of interest;
• leave the room during the discussion and debate on the matter, if so requested by the Board of Directors;
• leave the room during the vote on the matter, if so requested by the Board of Directors; and
• abstain from any vote on the matter.

At all times all individuals affiliated with the School shall act in a manner consistent with their fiduciary obligations to the School and shall exercise particular care that no detriment to the interests of the School (or appearance of such detriment) may result from a conflict between these interests and any personal interests the individual may have.

Records of Proceedings

The minutes of meetings of the Board of Directors or any committee shall contain the names of the individuals who disclosed a conflict of interest, the actions taken by the Board of Directors or committee in response, and the abstention of the individual with the conflict of interest from the vote on the matter involved.

NO RETURN BENEFIT

No director, officer, committee member, consultant, advisor, or employee shall knowingly accept any material gift of goods or services when it could reasonably be inferred that the gift was intended to influence an official action by the Board of Directors.

WHISTLEBLOWER POLICY

PURPOSE

ICS expects its directors, officers, and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities on behalf of ICS. As representatives of the ICS, such directors, officers, and employees must practice honesty and integrity in fulfilling their responsibilities and must comply with all applicable laws and regulations and all policies of ICS.

Wrongful Conduct, as defined in this Whistleblower Policy (the "Policy"), of any kind is prohibited.

REPORTING RESPONSIBILITY

It is the responsibility of all directors, officers, and employees to report Wrongful Conduct to an appropriate representative of ICS in accordance with the provisions of this Policy.

"Wrongful Conduct" is any activity in violation of any state, federal, or local law or regulation or of any ICS policy undertaken by a director, officer, or employee in the performance of such individual's official duties, whether or not such activity is within the scope of his or her intended responsibilities on behalf of ICS. This includes, but is not limited to, corruption, bribery, theft, fraud, coercion, conversion, harassment, or misuse of the ICS's property and facilities.

NO RETALIATION

No director, officer, or employee who reports Wrongful Conduct in good faith in accordance with this Policy (see REPORTING VIOLATIONS of this Policy) shall suffer harassment, retaliation, or adverse employment consequence. An employee who retaliates against someone who has reported Wrongful Conduct in good faith is subject to discipline up to and including termination of employment. A director or officer who retaliates against someone who has reported Wrongful Conduct in good faith is subject to discipline, up to and including removal from service as a director or officer. This Policy is intended to encourage and enable directors, officers, employees, and others to raise serious concerns with ICS.

Directors, officers, and employees are also protected against retaliation for providing information to, or otherwise assisting in an investigation by, a regulatory authority or law enforcement agency, any member of Congress or committee of Congress, or any person with supervisory authority over an employee or who has authority to investigate, discover, or terminate Wrongful Conduct where such information or investigation relates to any conduct of ICS that the reporting individual believes constitutes Wrongful Conduct within the meaning of this Policy. Any director, officer, or employee who files, testifies, participates in, or otherwise assists in a proceeding relating to alleged Wrongful Conduct is also protected against retaliation. Acts of retaliation by any director, officer, or employee are prohibited.

REPORTING VIOLATIONS

A director, officer, or employee who wishes to report Wrongful Conduct is asked to make such report to a member of the Board of Directors in the following order:

1. The Chair, but if unavailable or implicated,
2. any other member of the Executive Committee of the Board (i.e.; any officer), but if unavailable or implicated,
3. any available non implicated Board member.

The Board Member to whom the Wrongful Conduct is reported has a specific responsibility to communicate all reports of Wrongful Conduct to non implicated members of the Executive Committee of the Board of Directors, which will investigate all reported Wrongful Conduct. If an investigation substantiates that Wrongful Conduct has taken place, the Executive Committee will report such conduct to non implicated administrators and to non implicated members of the board of Directors.

ACTING IN GOOD FAITH

Anyone filing a report concerning a violation or suspected violation of law or other Wrongful Conduct must be acting in good faith and have reasonable cause for believing the information disclosed indicates a violation of law or other Wrongful Conduct. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.

CONFIDENTIALITY

Reports of Wrongful Conduct may be submitted on a confidential basis by the complainant or may be submitted anonymously. Such reports will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

HANDLING OF REPORTED WRONGFUL CONDUCT

Unless a report has been made anonymously, the person who provided a Report of Wrongful conduct to a Board Member shall be sent written acknowledgement of the Report within five (5) business days after its receipt. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.

BUILDINGS AND GROUNDS USE POLICY

Printable Copy of this Policy

Building and Ground Usage Form

The Indian Community School Mission Statement

The Indian Community School Core Values

1. To use the spaces in keeping with its sacred Mission.
2. To treat visitors as honored guests in keeping with its Core Values.

General Criteria for Using the Buildings and Grounds:

The proposed activity:

• fits within ICS's purpose and beliefs,
• can be appropriately accommodated in available space,
• does not conflict with uses by ICS's other programs,
• is consistent with ICS's requirements for safety issues,
• is in keeping with all applicable federal, state and local laws and regulations, and
• is planned in such a way that it shows respect for the property.

Statement of Policy:

The buildings and grounds (the "Facility") in Franklin, Wisconsin of the Indian Community School were developed to provide for activities that further the expansive educational goals set forth in the Mission Statement; especially those related to each child's spiritual, social and emotional development that naturally occurs through healthy interaction with the broader communities of which they are or may become members. This policy is written to ensure that community use of the Facility is in keeping with ICS's Mission and Values. That can only be accomplished if users of the Facility use it properly, carefully, safely and lawfully. Among other things, this policy is intended to protect the Facility against personal and property losses caused through any type of misuse or neglect. It is expected that all uses of the Facility will be conducted in a way to ensure the safety and conservation of the Creator's gifts of life, well being and sustenance.

Buildings and Grounds Eligibility Guidelines

The Facility and equipment of the Indian Community School exist for the primary purpose of serving its Mission through its direct use by its students, staff, the board of directors and others involved in the day-to-day activities of ICS. There are times when the Mission is also served by persons who propose to use the Facility for activities that may or may not be related to the direct educational activities of ICS. Eligibility to use the Facility is governed by these policies. Eligibility is determined as follows:

• A "Facility Usage Request Form" is completed and approved.
• A "Buildings and Grounds Use Policy" is read and signed.
• If the proposed Facility use is for, fund raising (not related to ICS activities or programs), profit making or political activities, a majority of the Indian Community School Board of Directors must pre-approve such a request at a duly called meeting.
• If the proposed Facility use includes consumption of alcohol, a majority of the Indian Community School Board of Directors must pre-approve such a request at a duly called meeting.
• When the proposed use is by an unrelated person or organization, A Certificate of Insurance for Liability and Property damage coverage, naming the Indian Community School of Milwaukee, Inc. as an additional insured, MUST be on file and approved by ICS prior to the date of the event.

The Priority of Use Shall Be As Follows:

1. Activities organized by persons or organizations related to ICS; e.g.
   1. parent meetings,
   2. teacher events,
   3. extracurricular sports events,
   4. spiritual ceremonies,
   5. Boy or Girl Scouts,
   6. etc.
2. Non ICS related use of the Facility by students, staff, parents, board members, and other people associated with the functioning of ICS as a school.
   1. weddings,
   2. anniversaries,
   3. naming ceremonies,
   4. family reunions, and
   5. school reunions
   6. other celebrations, get-togethers and receptions.
3. Outside persons or groups whose proposed use of the Facility is not sponsored by ICS, but whose proposed use is in keeping with the ICS's Buildings and Grounds Use philosophy, its Mission and its Core Values.

RESERVATIONS

Reservation requests to use the Facility/equipment should be made as far in advance as possible. Regardless as to when application has been made, the ICS Facility/equipment will not be available to a requester until notice of approval has been issued, and where applicable, pre-payment for anticipated use has been received. Therefore, no notice of any activity that is subject to this policy may be given until such approval has been received by the requester.

No later than two (2) weeks in advance of the proposed date(s) of use, a Facility Usage Request Form, (the "Form") must be completed and submitted to the ICS Chief Operating Officer or that person's designee, by a requester representing the persons or entities proposing to use ICS's Facility and/or equipment. Among other things, the Form must detail the requester's intended use of:

1. Interior and exterior spaces on the grounds, including the corresponding time periods for such use,
2. ICS equipment,
3. ICS property proposed for posting notices and signs,
4. ICS consumables (i.e. supplies, cleaning equipment, etc.),
5. ICS personnel.

The requester must also specifically state the:

1. Manner and times of set up and clean up,
2. Special accommodations needed,
3. Plans for food/beverage services,
4. Methods for providing entertainment, presentations or information (particularly the requested use of any equipment for audio visual needs),
5. The manner by which any and all heavy items will be moved so as not to damage floors or other interior or exterior surfaces,
6. Insurance that will cover both ICS and the proposed Facility/equipment user for both property and personal injury damages allegedly arising out of the use of ICS's Facility,
7. Manner in which applicable laws and the fire code will be enforced.

The COO or that person's designee will clarify with the representative any information needed to make a decision about the Facility/equipment requested usage.

If the Facility is deemed by the COO (or the ICS Board, if applicable) to be eligible for a Non ICS related purpose, the requester will be provided with an invoice detailing the fees that must be prepaid as reasonable reimbursement to ICS for its actual direct and indirect costs for the requester's proposed use of the Facility. The pre-paid fees charged by ICS will not exceed the reasonable costs for the anticipated use of the buildings, grounds, equipment, personnel and wear and tear. The requester agrees to personally guarantee that payment will be made within ten (10) days of the subsequent invoice date.

If the actual use, damages or excessive wear and tear exceeds that for which charges were prepaid, the requester agrees to immediately reimburse ICS for the damages and excessive wear and tear as determined by ICS upon notification of such. In the event there are any outstanding un-paid invoices from a previous use, the requester will not be considered eligible for future use.

No date is placed on the ICS calendar until the form has been submitted and approved by ICS.

PUBLICITY AND PROMOTION

• Any advertisement for an activity authorized to occur at the Facility must be pre-approved by ICS through the Chief Operating Officer.
• The sale of admission tickets to an approved event must be first approved by the Chief Operating officer.
• There will be no postings or decorations of any kind adhered to the walls or other surfaces of any part of the Facility or equipment.
• Postings and/or decorations may be placed on easels and on the property of the Facility user.

FACILITY USE GUIDELINES

Use of the Facility/equipment may only be approved for times when appropriate Security and Buildings and Grounds staff are available to be on duty. It is totally within ICS's discretion to determine which and how many of its staff should be present for the use of its Facility and/or equipment. If the requester's use of the Facility causes ICS to incur labor charges that it would not ordinarily have incurred during the time period the requester uses the buildings or grounds, the requester agrees to pay the costs associated with the staff on site, regardless as to whether such costs include overtime pay. The staff person designated as ICS's on site representative is the person to whom questions or needs should be addressed during a Facility use that takes place outside of normal weekday working hours (7:30 A.M.- 4:30 P.M.). ICS staff may also require the requester to meet during normal weekday working hours in advance of any proposed Facility use.

CONDUCT

The following guidelines are examples of that which is expected of users of ICS's Facility/equipment:

1. Ensuring that the conduct of all persons in attendance are respectful of ICS's Mission and Core Values,
2. Protecting the integrity of ICS's property by following rules for its use,
3. Maintaining noise levels that respect others in the building,
4. Limiting use of the Facility, equipment and personnel to that which was agreed at the time ICS approval was given,
5. Providing appropriate supervision for minors,
6. Strictly enforcing ICS's policies regarding smoking, the use of alcohol, the possession of illegal substances, and the possession of weapons,
7. Avoiding unruly, verbally and/or physically confrontational behavior,
8. Immediately abating and reporting to law enforcement any unlawful conduct,
9. Limiting food and beverages to pre-approved areas,
10. Cleaning the facility after its use, as agreed,
11. Returning ICS furniture and equipment to its proper place or to the ICS designated staff person, as agreed,
12. Strictly following the instructions of the onsite ICS staff person,
13. Removing all non ICS property from the Facility immediately after use,
14. Assuming liability for damage to or losses of the user's property and personnel, as well as those of its attendees or guests.

PARKING

Parking is restricted to only those areas on the grounds designated by ICS as appropriate vehicular parking.

USE OF FOOD PREPARATION FACILITIES

ICS maintains an institutional kitchen that meets the standards for professional food preparation. The kitchen equipment requires professional instruction for its safe and proper use. Unless the COO is satisfied that a proposed user of the kitchen facilities is competent to use such equipment in a safe and proper way, a request to use the kitchen will be denied. In the event that a user is approved to use the kitchen and its equipment, the following requirements apply:

1. The user must designate a competent kitchen manager who must remain onsite at all times the kitchen is in use.
2. No later than one week before the proposed facility use, the user's kitchen manager must meet with ICS's Food Service Manager for a kitchen tour and briefing on instructions for using the kitchen facilities/equipment.
3. The user's kitchen manager must supervise kitchen operations consistent with the instructions provided by the ICS Food Service Manager, posted instructions, and governmental regulations,
4. All equipment, surfaces, dishes, utensils and other items used for the preparation and consumption of food must be cleaned and stored according to the requirements set by the ICS Food Service Manager.
5. All equipment that was used must be turned off and returned to the settings that existed prior to use.
6. The user must supply and remove its own food service linens and products for preparing, serving and cleaning up after its food service,
7. All leftover food must be removed from ICS.
8. Kitchen waste must be properly bagged and placed into the appropriate dumpster.

THE SPIRITUAL CENTER

No one may use the Spiritual Center without the advance knowledge and consent of the ICS Cultural Coordinator.

The Spiritual Center is intended for use by or under the direct supervision of ICS's Cultural Coordinator. To use the Spiritual Center, a Facility Usage Request Form must be submitted to the COO, but will not be approved unless the Cultural Coordinator agrees to its use and prescribes the manner in which it may be used. If consent is given to use the Spiritual Center the following rules apply:

1. If the Cultural Coordinator is not personally present during an approved use of the Spiritual Center, a designated person must be approved by the Cultural Coordinator to oversee the use of the space for the specific purpose use was requested.
2. Except for the Cultural Coordinator, the Spiritual Center may not be used for meetings or ceremonies between one child and one non custodial adult. If the spiritual well being of a child is the reason for use of the Spiritual Center, other adults approved by the Cultural Coordinator must be present at all times that the child is present.
3. Use of burning materials is limited to the Spiritual Center proper.
4. The number of people contained within the space must comply with the fire code and is therefore limited to 28.
5. Tables, chairs or other furniture is disallowed unless expressly agreed to by the Cultural Coordinator.

THE SWEAT LODGE

No one may use the Sweat Lodge without the advance knowledge and consent of the ICS Principal.

The Sweat Lodge is intended for use by or under the direct supervision of ICS's Cultural Coordinator or Principal. To use the Sweat Lodge, a Facility Usage Request Form must be submitted to the COO, but will not be approved unless the Principal or the Principal's designee agrees to its use and prescribes the manner in which it can be used.

ALCOHOL AND TOBACCO USE

It is the intention of the ICS Board of Directors to limit events held at the Facility where alcohol is served. In the event that any person or entity desires to use or distribute alcohol in the buildings or on any part of the grounds, permission for such use can only be granted if a majority of the ICS Board of Directors pre-approves such a request at a duly called meeting of the Board. In the event that any person or entity seeks permission for its participants or guests to use recreational tobacco products on any part of the ICS Franklin campus grounds, permission for such use may be granted by the Chief Operating Officer upon being satisfied that such tobacco use will take place out of doors on ground level places that do not interfere with non smokers' rights to be free of second hand smoke. The person or entity seeking such permission shall be responsible for supplying or requesting appropriate receptacles for holding smoking waste, shall clean up after smokers, and shall remove the receptacles at the conclusion of the event, as agreed.

Indian Community School of Milwaukee, Inc

Contact Us

10405 W St Martins Rd - Franklin, WI 53132 - (414) 525-6100