Policies

• Bylaws
• Charity Evaluations: Scope of Consideration
• Donation Policy: Potential conflicts of interest
• Donor Privacy
• Gift Acceptance Policy
• Board of Directors’ Conflict of Interest Policy (from bylaws)
• Employment/Affiliation COI Policy for All Staff and Board
• Charity Evaluation and Movement Grants Committees’ Policies
  • Charity Evaluation Committee Policy
  • Movement Grants Committee Policy
• Social Media Policies
• Respect in the Workplace Policy
• Code of Conduct
• Privacy Policy

Bylaws

Bylaws are rules that an organization creates to regulate itself. They also establish guidelines that govern future choices. The ACE Bylaws provide details about our governance and decision-making process.

Charity Evaluations: Scope of Consideration

We consider for recommendation primarily groups which act on behalf of animals through their own programs. We do not consider foundations or other groups which use a large part of their budget to make grants to other organizations within our scope of consideration. However, the existence of a grant program as part of a group’s activities does not remove it from our consideration if the program a) represents a small portion of the organization’s total expenditures and/or b) primarily distributes small-scale grants to individuals or to groups with overall very low budgets. The intent of this decision is to avoid evaluating organizations which would primarily redistribute donations to other groups that we could evaluate individually while leaving open the possibility of recommending an organization which supports small-scale and early-stage projects through grants, as we could not direct individual donations to such projects accurately or efficiently on our own.

We do not consider ACE as a charity for recommendation, as doing so would create a conflict of interest. Additionally, we do not consider organizations whose primary leadership has donated to ACE. See our donation policy below for more details.

Donation Policy: Potential conflicts of interest

Our donation policy helps ensure that we do not have a conflict of interest between our donors and our recommendations. We include the entire policy below.

Section 1. Definition

A conflict of interest arises when one of the following organizations—or an individual leader at such an organization—offers a donation to ACE for general operating:

1. an ACE-recommended charity
2. a charity ACE is currently evaluating for recommendation
3. a past Movement Grants recipient
4. an organization whose application for an Movement Grant is currently under review
5. a charity previously recommended by ACE

In these contexts, “leader” refers to key decision-making individuals at the organization, such as the Executive Director and Board Chair. If a situation arises where there is uncertainty about whether an individual is considered a leader for the purpose of this policy, ACE’s Director of Philanthropy will decide.

A conflict of interest also arises when one of the following offers a donation to ACE:

6. An individual researcher who has received an Animal Advocacy Research Fund (AARF) grant in the past
7. An individual researcher whose application for an AARF grant is currently under review

A conflict of interest also arises if ACE applied for and is awarded a grant from an organization that was then recommended by ACE.

Section 2. Addressing conflicts of interest

In the donations section of ACE’s website, we link our Gift Acceptance Policy which lists the restrictions we have in place to prevent the type of conflicts of interest described in this policy.

Should ACE receive a donation from an organization listed above (i-v), from an individual leader at such an organization, or from a researcher listed above (vi and vii) and that organization or individual has contributed more than 100 USD that calendar year including their current gift, the donation will be returned and the donor will be directed to our Gift Acceptance Policy for future reference.

Additionally, if an organization applies for a Movement Grant or begins the charity evaluation process and ACE realizes that this organization (or an individual leader at the organization) has made a donation to ACE in the six months prior, ACE will give the organization or individual the option of a refund so that the organization can remain eligible for the grant or evaluation. Similarly, if an individual researcher applies for an AARF grant and ACE realizes that they made a donation to ACE in the six months prior, ACE will give the researcher the option of a refund so that they may remain eligible for an AARF grant.

If an individual who has previously donated to ACE later takes a leadership role at an organization listed above (i-v), or an organization which has previously granted to ACE later becomes an organization listed above (i-v), future donations from the individual or organization which would put their contributions above the annual threshold will not be accepted, but ACE will not be required to return past contributions.

ACE will not apply for grants from charities that could be considered for future recommendation.

Section 3. Potential exceptions

Potential exceptions—situations in which we would accept the donation—include but are not limited to:

1. A donation from a previously-recommended charity (v), or from an individual leader at that charity, if they have not been recommended for at least three years
2. A donation from an organization listed above (i-v), or from an individual leader at such an organization, if the organization surrenders its potential to be evaluated by ACE for the next three years and surrenders its potential to receive a grant from ACE in the next three years. E.g. if the organization donated in January, 2021, they would next be eligible for evaluation in 2024.
3. A donation from an organization listed above (i-v), or from an individual leader at such an organization, if ACE was not aware of the affiliation creating a conflict of interest at the time of receipt. ACE may choose to keep the donation even if we become aware of such an affiliation at a later time, because no undue influence would have been conferred at the time the donation was accepted.
4. A donation from a researcher (vi and vii), if that researcher surrenders their potential to receive a grant from ACE in the next three years.
5. If an organization has surrendered its potential to be considered in relation to a donation from an individual leader at an organization listed above (i-v), and that individual is no longer associated with the organization, we can reinstate the organization’s potential to be considered for recommendation or a grant without waiting the full three years.

Donor privacy

Our commitment to respect the privacy of our supporters extends to how we obtain, use, protect, and share information about them. For any personal identifying information that is shared with ACE, either by making a donation or signing up to receive email updates from ACE, it will be stored in our database and protected as follows:

We do not share, sell, or trade the names or contact information of our donors or email subscribers with any other entities, except as described below.

For people who make a donation to a Recommended Charity through ACE, their name and contact information will be shared only with the charity/charities to which they made a donation. Our Recommended Charities are required not to share these donors’ information with any other entities without first obtaining the donor’s permission. If a donor prefers for their gift to be reported anonymously to our Recommended Charities, they can let us know.

For any published names (for example, in our Year in Review, on our Top Donors web page, or on our Testimonials web page), we have obtained explicit permission from the supporters to publish their names and any accompanying information.

Gift Acceptance Policy

For more details on what types of donations we accept, view our Gift Acceptance Policy.

Board of Directors’ Conflict of Interest Policy

Our conflict of interest policy helps ensure that board members are not influencing decisions where they, their family, or their business interests could benefit or be harmed financially. We include the entire policy below. It can also be found in our bylaws.

Section 1. Definition

A conflict of interest arises whenever an individual is in a position to approve or influence corporation policies or actions which involve or could potentially benefit or harm financially:
(a) the individual;
(b) any member of the individual’s immediate family (spouse, parents, children, brothers or sisters, and spouses of these individuals); or
(c) any corporation in which the individual or an immediate family member is a director, officer, member, or partner.

Section 2. Disclosure of conflicts of interest

A director or officer shall disclose to the President, secretary, or board a conflict of interest:
(a) prior to voting on or otherwise discharging any duties with respect to any matter involving the conflict;
(b) prior to the corporation entering into any contract or transaction involving the conflict;
(c) as soon as possible after the director or officer learns of the conflict; and
(d) on any conflict of interest disclosure form required by the corporation. The Board of Directors, by a two-thirds vote of all disinterested directors then in office, may remove a director or officer for failure to promptly disclose a known conflict of interest.

Section 3. Actions involving potential conflicts of interest

Following receipt of information concerning a contract or transaction involving a potential conflict of interest, the board shall consider the material facts concerning the proposed contract or transaction including the process by which the decision was made to recommend entering into the arrangement on the terms proposed. The board shall approve only those contracts or transactions in which the terms are fair and reasonable to the corporation and the arrangements are consistent with the best interests of the corporation. Fairness includes, but is not limited to, the concepts that the corporation should pay no more than fair market value for any goods or services which the corporation receives and that the corporation should receive fair market value consideration for any goods or services that it furnishes others. The board shall set forth the basis for its decision with respect to approval of contracts or transactions involving conflicts of interest in the minutes of the meeting at which the decision is made, including the basis for determining that the consideration to be paid is fair to the corporation. The interested director or officer should not be present for the discussion and decision concerning the authorization of such contract or transaction; however, interested directors may be counted in determining the presence of a quorum at a meeting of the Board of Directors or committee which authorizes such contract or transaction.

Section 4. Compensation of directors and officers

No director or officer of the corporation shall receive, directly or indirectly, any compensation or other payment from the corporation, unless authorized by the concurring vote of two-thirds (2/3) of all the directors then in office and in no event shall any compensation or payment be paid or made, except reasonable compensation for services actually rendered or reimbursement for disbursements actually incurred.

Employment/Affiliation COI Policy for All Staff and Board

Scope

Our employment/affiliation conflict of interest (COI) policy applies to all ACE employees, select contractors, and fellows (together referred to as “staff members”) and ACE board members. Advisory board members are not subject to the confines of this policy given their infrequent involvement and lack of decision-making authority. This policy supplements the COI policies specific to our recommendation and granting programs (Charity Evaluations, Movement Grants, and Animal Advocacy Research Fund), which have procedures for those on the respective committees. Collectively, all staff and board are referred to as “ACE team members”.

Affiliations with Evaluated Charities

A COI may arise when an ACE staff or board member has a strong tie to an organization eligible for ACE’s recommendation. There are different types of affiliations that our staff and board could have with the charities we evaluate for potential recommendation, some of which may be considered a conflict of interest.

A COI may also arise when a former staff member takes a position at an organization eligible for ACE’s recommendation, since they may have direct experience in conducting evaluations while at ACE.

This table lists different types of affiliations between ACE staff and board members and charities that we are currently evaluating or currently recommend. For each type of affiliation, we indicate whether it is allowed, and what restrictions apply to the possible COI. Staff and board involved in charity evaluations must also follow the Charity Evaluation Committee Policy.

In addition, a COI could arise when ACE is working on a project with a charity that is currently being evaluated or is currently recommended by ACE. ACE attempts to limit extensive or repeated collaboration with any given charity that is eligible for a recommendation.

Disclosure

Should a COI such as those listed above (or others) arise or be discovered, a board member must disclose it to the Chair of the Board, and a staff member must disclose it to the Executive Director or a research Lead (see org chart):

1. prior to engaging in any duties with respect to any matter involving the conflict;
2. as soon as possible after the board member or staff member learns of the conflict; and
3. on any conflict of interest disclosure form required by ACE.

Team members aware of potential COI(s) due to another team member’s affiliation with an evaluated charity are encouraged to bring their concerns directly to a research Lead or the Executive Director first, rather than to the party with the COI. The identity of an individual who brought up a concern should not be disclosed to the party with the COI without prior consent.

Team members’ affiliations with reviewed charities must be listed in the charity reviews, while specifying whether or not they were involved in the recommendation decisions.

Additionally, if ACE as an organization is working on a project with a charity that is currently being evaluated or currently recommended, we disclose that relationship on the charity review.

Procedures addressing employment/affiliation COIs

Should ACE realize an external relationship that does not adhere to this policy, said individual will be directed to resolve their relationship to be in compliance with this policy. If such a relationship is unable to be resolved, ACE will take action to remedy the situation, which may include restructuring or termination of the ACE team member, or refraining from evaluating the affiliated charity for a period of time, as appropriate.

Affiliations with Grant Applicants (Movement Grants, Research Fund)

If the position of Executive Director (or equivalent) or Board Chair (or equivalent) at a grant applicant is held by a current ACE team member, the applicant is not eligible for a grant.

ACE team members may accept travel and lodging compensation when speaking at events, including those organized by grant applicants. However, they may not accept honoraria or other gifts from a grant applicant or previous grantee (from the last 3 years). If an organization that has never received a grant from ACE gives an honorarium or a gift to an ACE team member, ACE may return the gift or honorarium within six months in order for the organization to be eligible for consideration for a grant.

If a former ACE board member (who was on the board for any length of time) or long-term employee or contractor (long-term meaning someone who worked with ACE longer than six months for at least 8h/week) becomes the Executive Director (or equivalent) or Board Chair (or equivalent) of an organization, the organization is not eligible for a grant until one calendar year after the former staff member ends their employment at ACE. If a fellow or medium-term employee or contractor (someone who worked at least three months at ACE for at least 8h/week, or one month for at least 20h/week) takes on such a leadership role, the time period is 6 months. This policy does not apply to short-term employees or contractors. The relevant date for Movement Grants is the closing date of the applications.

Disclosure

When an ACE team member (including board and fellows) who is not on the relevant granting committee (AARF or Movement Grants) has an affiliation with one of the tentatively proposed grantees, they must refrain from commenting about that proposed grantee and must notify the relevant Program Officer of their potential COI, who will share that information with the committee.

All ACE team members—not only those the granting committees—aware of potential COI(s) involving another team member (e.g. those described in the Movement Grants committee policy and the Animal Advocacy Research Fund (AARF) policy) are encouraged to bring their concerns directly to:

• The AARF Program Officer or the Executive Director, for potential COIs involving AARF proposal reviewers
• The Movement Grants Program Manager or the Executive Director, for potential COIs involving someone on the Movement Grants committee

The identity of an individual who brought up a concern should not be disclosed to the party with the potential COI without prior consent. Team members should bring their concerns to the people listed above first, rather than to the party with the potential COI.

Team members’ affiliations with grantees must be listed in the public announcement of the grants, while specifying whether or not they were involved in the grant decisions.

Additionally, if ACE as an organization is working on a project with a charity that is currently being considered for a grant, we disclose that relationship in the grant announcement.

<sup>1. Although the formality of a position will be determined on a case-by-case basis, we generally consider a position to be formal if it is both ongoing (i.e. not volunteering for a one-day event) and one where the team member would feel obligated to notify the organization in advance if they planned to leave the position.
2. Both staff and board members may accept travel and lodging compensation when speaking at events, including those organized by evaluated or recommended charities.
3. Though we list this as a potential COI, we believes that having a former ACE staff member at a considered charity would not provide much advantage over other charities, since we make our review process and criteria publicly available and try to help all evaluated charities understand what aspects of their work we are most interested in learning about.</sup>

Charity Evaluation and Movement Grants Committees’ Policies

While ACE tries quite hard to avoid conflicts of interest (COIs) with charities we evaluate for recommendation and with organizations we consider for a Movement Grant, it is difficult to avoid individual COI situations entirely. We have developed the following policies to address COIs as they arise in these two contexts.

Charity Evaluation Committee COI Policy

Of particular concern are COI situations involving team members directly involved in the evaluations process and recommendation decisions, including board members who sit on the research committee. Collectively, the staff and board members involved in evaluations are referred to as “committee members” throughout this policy.

Individual COIs could take multiple forms, for example:

• Close personal (e.g., marriage, family, close friendship) relationship with a staff member of a charity being evaluated or considered for evaluation
• Past employment with a charity being evaluated or considered for evaluation
• Serving on the Board of Directors of a charity being evaluated or considered for evaluation
• Volunteer involvement with a charity being evaluated or considered for evaluation

These COIs are not all equal in weight. While committee members are expected to disclose all relevant COIs, how we handle each COI depends on its seriousness.

• Serious COIs (e.g. employment within the last three years, presently serving on the Board of Directors, close personal relationship with a staff member, currently applying to work for a charity ACE is evaluating) disqualify a committee member from being involved in evaluating the particular charity in the normal way. Replacement procedures are outlined below.
• Minor COIs (e.g. volunteering informally with the charity) must be acknowledged, and the committee member must let the research Lead(s) (see org chart) know if, under the circumstances, they feel they cannot impartially contribute to the charity evaluation. But in general, we expect it will be possible for those with minor COIs to continue with evaluation procedures in the normal way.

Some conflicts may fall between the outlined serious and minor levels, particularly those involving a personal relationship between a committee member and a staff or board member of the evaluated charity that is not close enough to be definitively classed as a serious COI. In these cases, we expect the committee member involved to work with the research Lead(s) and/or the Executive Director to find an appropriate level of involvement for the situation, defaulting to the procedures for a serious COI if they are unsure of the appropriate course of action. If the Executive Director has a possible COI, the Chair of the Board will decide whether and how they can be involved.

If any committee member has a COI with an evaluated charity that is determined to be above the minor level, ACE will list that conflict on the relevant charity’s review page.

Staff members on the charity evaluation committee

If a staff member on the committee has a serious COI with a charity they would otherwise participate in evaluating…

• They must:
• • Formally abstain from suggesting a course of action for this charity when asked in general what charities should be reviewed or recommended
  • Leave discussions or calls about the evaluation process while the charity in question is being discussed
  • Treat any information they have about ACE’s process as highly confidential and refrain from sharing it outside of the team unless they have specific permission to do so
    • If they feel this will present undue difficulty for them, they should not read draft reviews.

• They might:
• • Vote on what course of action to pursue for other charities and participate in discussions about them.
    • In general, their votes will not affect what will happen to the charity with which they have a COI. (In most stages of the process, including deciding on final recommendations, there is not a specific target number of charities to include, so the team has the flexibility to include or exclude an additional charity if they feel that it is appropriate to do so.)
  • Provide an appropriate contact email for the charity
  • Remind others (at any time) that they are recused from offering an opinion due to a COI

• They must not:
• • Be assigned any aspect of the charity to research
  • Conduct a call with the charity on behalf of ACE
  • Provide additional information to other members of the evaluation committee without first clearing this action with the research Lead(s) and/or the Executive Director
  • Draft any sections of the charity’s evaluation
  • Be present for oral discussion of the charity’s review or recommendation status
  • Contribute to written discussions about the charity’s review or recommendation status
  • Make overall comparisons to other charities, even if they are directly asked
  • Vote on the charity’s recommendation status

If the staff member in question is a research Lead or the Executive Director, additional care is required to ensure that the conflict does not pose a problem for the neutrality of the review. In particular:

• When a conflict for one or more of these parties has been identified, the other parties (research Lead and/or Executive Director) must be involved in deciding how serious the COI is. They also have access to additional neutral parties (e.g. other research staff or board members) for consultation in case of difficulties. Those parties identified with the COI must abide by the decision reached.
• If one of these parties has a serious COI with a charity being evaluated, they must not have access to draft reviews or review materials until these have been edited by all staff participating fully in the evaluation of the charity in question to reflect a consensus viewpoint, thus partially anonymizing the views of any team members who worked on the evaluation. Another committee member will restrict their access to the initial documents created and will provide them with access to copies without comment/edit history at the appropriate time.
• If the Executive Director or research Lead has a serious COI with a charity being evaluated, they must not have access to information about who has drafted each section of the review, in order to further anonymize team member contributions.
• If a research Lead or the Executive Director has any identified COI with a charity being considered for evaluation, a committee member will be designated to create and monitor an anonymous feedback form for staff to use in reporting concerns over the handling of the COI. The designated individual will relay feedback from this form to the Executive Director (if concerning a research Lead) or to the Chair of the Board (if concerning the Executive Director), lightly editing the feedback submission if necessary to preserve anonymity.
• The research Leads and Executive Director are prohibited from applying for employment with any charities we are evaluating during the time we are reviewing them.

Board members on the charity evaluation committee

If a board member has a serious COI with a charity they would otherwise participate in evaluating…

• They must:
• • Formally abstain from suggesting a course of action for this charity when asked in general what charities should be evaluated or recommended
  • Leave discussions or calls about the evaluation process while the charity in question is being discussed
  • Treat any information they have about ACE’s process as highly confidential and refrain from sharing it outside of the team unless they have specific permission to do so
    • If they feel this will present undue difficulty for them, they should not read draft reviews.

• They might:
  • Vote on what course of action to pursue for other charities and participate in discussions about them
    • In general, their votes will not affect what will happen to the charity with which they have a COI. (In most stages of the process, including deciding on final recommendations, there is not a specific target number of charities to include, so the team has the flexibility to include or exclude an additional charity if they feel that it is appropriate to do so.)
  • Provide an appropriate contact email for the charity
  • Remind others (at any time) that they are recused from offering an opinion due to a COI

• They must not:
• • Provide additional information to other members of the evaluation committee without first clearing this action with the research Lead(s) and/or the Executive Director
  • Be present for oral discussion of the charity’s review or recommendation status
  • Contribute to written discussions about the charity’s review or recommendation status
  • Make overall comparisons to other charities, even if they are directly asked
  • Vote on the charity’s recommendation status

Movement Grants (formerly “Effective Animal Advocacy Fund”) Committee Policy

Several staff members, fellows, and board members are involved in the Movement Grants (formerly “Effective Animal Advocacy Fund”) grantee selection process, under the leadership of the Movement Grants Program Manager. Some staff members are involved in reviewing the applicants’ materials and some staff members, board members, and fellows participate by reviewing and/or discussing others’ proposed decisions. In this document, we refer to the staff members, fellows, and board members who are involved in either (a) reviewing applications and/or (b) making final decisions as the Movement Grants committee members.¹ All staff members, current fellows, and board members are invited to give feedback on the decisions of the Movement Grants committee members, but the committee members are responsible for making the final decisions. All applicable COI considerations described above in the Charity Evaluation Committee Policy also apply to Movement Grants decisions.

Committee members
Committee members must disclose any level of COI that they have with a Movement Grants applicant to the Program Officer prior to their involvement in the Movement Grants process. The committee members’ conflicts with grantees must be listed in the blog posts announcing the grants.

If a committee member has a serious COI with an applicant (examples included in Charity Evaluation Committee Policy above), the committee member must notify the rest of the committee and recuse themself completely from oral and written discussions about the applicant. It is not necessary for individuals with serious COIs to participate in any parts of the relevant applicant’s review.

If the committee member with a serious COI has information that they believe is useful and relevant to the committee’s decision, they may provide this information to the Program Officer and/or the Executive Director. They should not share information with the rest of the committee without first clearing this action with the Movement Grants Program Manager or Executive Director.

If the committee member has a COI that isn’t definitively classed as a serious COI, the Program Officer will decide whether and how they should be involved in the discussions and process related to that applicant.

If the conflicted committee member is either the Movement Grants Program Manager or Executive Director, the other of these two should be involved in deciding how serious the COI is and how to handle the situation. They have access to additional neutral parties (e.g., other committee members or the Board of Directors) for consultation in case of difficulties. If both the Movement Grants Program Manager and the Executive Director have the same COI, a research Lead (see org chart) or a committee member they appoint will decide how to handle the COI. The party with the COI must abide by the decision reached.

Non-committee members
Each round, after tentative grantee decisions are made, the Program Officer will share that list with all ACE team members for their feedback and to ask about any affiliations which might be COIs. When an ACE team member (including board and fellows) who is not on the committee has an affiliation with one of the proposed grantees, they must refrain from commenting about that proposed grantee and must notify the Program Officer of their potential COI, who will share that information with the committee. Additionally, their affiliation must be listed in the blog posts announcing the grants, while specifying that they were not involved in the grant decisions.

^{1. By default, the staff members who review and discuss the applications are the same staff members who make final decisions, but these two groups may differ due to staff changes during the process. Board members do not participate in the review process but do approve the grantee decisions made by staff members.}

Social Media Policies

Thank you for your interest in participating in Animal Charity Evaluators’ social media page. The purpose of these pages is to create a place where our followers can share their thoughts, opinions, and insights on Animal Charity Evaluators, and on topics relevant to our mission.

By using or accessing our social media pages, you agree to comply with Facebook’s Terms and Conditions, and Twitter’s Terms of Service. As we welcome input from anyone, please note that postings by fans on our social media pages do not necessarily reflect the views of Animal Charity Evaluators, nor do we confirm their accuracy.

We understand that animal advocacy is a subject many of you are passionate about – a passion we share. We welcome all questions and commentary, including constructive feedback. We don’t take decisions on moderating posts lightly, but we do expect that participants post content and commentary that is both relevant and respectful to this community as a whole. Animal Charity Evaluators reserves the right to remove any posts that don’t adhere to our guidelines and to block anyone who violates them repeatedly. Specifically, we do not tolerate these kinds of posts:

• Abusive, harassing, stalking, threatening or attacking others
• Defamatory, offensive, obscene, vulgar or depicting violence
• Hateful in language targeting race/ethnicity, religion, gender, nationality or political beliefs
• Fraudulent, deceptive, misleading or unlawful
• Trolling or deliberate disruption of discussion
• Violations of any intellectual property rights
• Spamming in nature
• Uploading files that contain viruses or programs that could damage the operation of other people’s computers
• Commercial solicitation or solicitation of donations
• Link baiting (embedding a link in your post to draw traffic to your own site)

Thank you for participating in helping us create a respectful environment for our followers. If you have any questions, please email us at contact@animalcharityevaluators.org.

Respective in the Workplace Policy

We make our internal “Respect in the Workplace” Policy available online as a resource for other organizations.

Code of Conduct

Our Code of Conduct applies to all ACE employees, interns, select contractors, and board members.