Our Policies & Guidelines

Baby Steps shall follow the spirit and intent of all federal, state and local employment law and is committed to equal employment opportunity.  To that end, the Board of Directors and officers of Baby Steps will not discriminate against any employee or applicant in a manner that violates the law.  

Baby Steps is committed to providing equal opportunity for all employees and applicants without regard to race, color, religion, national origin, sex, age, marital status, sexual orientation, disability, political affiliation, personal appearance, family responsibilities, matriculation or any other characteristic protected under federal, state or local law.  Each person is evaluated on the basis of personal skill and merit. Baby Steps’ policy regarding equal employment opportunity applies to all aspects of employment, including recruitment, hiring, job assignments, promotions, working conditions, scheduling, benefits, wage and salary administration, disciplinary action, termination, and social, educational and recreational programs.  The President & CEO shall act as the responsible agent in the full implementation of the Equal Employment Opportunity policy. 

Baby Steps will not tolerate any form of discrimination.  All employees are expected to cooperate fully in implementing this policy.  In particular, any employee who believes that any other employee of Baby Steps may have violated the Equal Employment Opportunity policy should report the possible violation to the President & CEO.   

If Baby Steps determines that a violation of this Equal Employment Opportunity policy has occurred, it will take appropriate disciplinary action against the offending party, which can include counseling, warnings, suspensions, and termination.  Employees who report, in good faith, violations of this policy and employees who cooperate with investigations into alleged violations of this policy will not be subject to retaliation.  

Baby Steps is also committed to complying fully with applicable disability discrimination laws, and ensuring that equal opportunity in employment exists at Baby Steps for qualified persons with disabilities.  All employment practices and activities are conducted on a non‐discriminatory basis.  Reasonable accommodations will be available to all qualified disabled employees, upon request, so long as the potential accommodation does not create an undue hardship on Baby Steps.  Employees who believe that they may require an accommodation should discuss these needs with the President & CEO.  

If you have any questions regarding this policy, please contact the President & CEO.

Baby Steps is committed to providing a work environment for all employees that is free from sexual harassment and other types of discriminatory harassment.  Employees are expected to conduct themselves in a professional manner and to show respect for their co-workers. 

Baby Steps’ commitment begins with the recognition and acknowledgment that sexual harassment and other types of discriminatory harassment are, of course, unlawful. To reinforce this commitment, Baby Steps has developed a policy against harassment and a reporting procedure for employees who have been subjected to or witnessed harassment. This policy applies to all work‐related settings and activities, whether inside or outside the workplace, and includes business trips and business‐related social events. Baby Steps’ property (e.g. phones, copy machines, facsimile machines, computers, and computer applications such as e‐mail and Internet access) may not be used to engage in conduct that violates this policy.  Baby Steps’ policy against harassment covers employees and other individuals who have a relationship with Baby Steps which enables Baby Steps to exercise some control over the individual’s conduct in places and activities that relate to Baby Steps’ work (e.g. directors, officers, contractors, vendors, volunteers, etc.).   

Prohibition of Sexual Harassment: Baby Steps’ policy against sexual harassment prohibits sexual advances or requests for sexual favors or other physical or verbal conduct of a sexual nature, when: (1) submission to such conduct is made an express or implicit condition of employment; (2) submission to or rejection of such conduct is used as a basis for employment decisions affecting the individual who submits to or rejects such conduct; or (3) such conduct has the purpose or effect of unreasonably interfering with an employee’s work performance or creating an intimidating, hostile, humiliating, or offensive working environment. 

While it is not possible to list all of the circumstances which would constitute sexual harassment, the following are some examples:  (1) unwelcome sexual advances, whether they involve physical touching or not, including those made digitally or online; (2) requests for sexual favors in exchange for actual or promised job benefits such as favorable reviews, salary increases, promotions, increased benefits, or continued employment; or (3) coerced sexual acts, including those coerced through digital means.     

Depending on the circumstances, the following conduct may also constitute sexual harassment:  (1) use of sexual epithets, jokes, written or oral references to sexual conduct, gossip regarding one’s sex life; (2) sexually oriented comment on an individual’s body, comment about an individual’s sexual activity, deficiencies, or prowess; (3) displaying sexually suggestive objects, pictures, cartoons; (4) unwelcome leering, whistling, deliberate brushing against the body in a suggestive manner; (5) sexual gestures or sexually suggestive comments; (6) inquiries into one’s sexual experiences; or (7) discussion of one’s sexual activities.   

While such behavior, depending on the circumstances, may not be severe or pervasive enough to create a sexually hostile work environment, it can nonetheless make co‐workers uncomfortable.  Accordingly, such behavior is inappropriate and may result in disciplinary action regardless of whether it is unlawful. 

It is also unlawful and expressly against Baby Steps policy to retaliate in any way against an employee for filing a complaint of sexual harassment or for cooperating with an investigation of a complaint of sexual harassment. 

Prohibition of Other Types of Discriminatory Harassment:  It is also against Baby Steps policy to engage in verbal or physical conduct that denigrates or shows hostility or aversion toward an individual because of his or her race, color, gender, religion, sexual orientation, age, national origin, disability, or any other category protected under applicable local, state, or federal laws (or that of the individual’s relatives, friends, or associates) that:  (1) has the purpose or effect of creating an intimidating, hostile, humiliating, or offensive working environment; (2) has the purpose or effect of unreasonably interfering with an individual’s work performance; or (3) otherwise adversely affects an individual’s employment opportunities.   

Depending on the circumstances, the following conduct may constitute discriminatory harassment, whether it occurs in person or through digital means:  (1) epithets, slurs, negative stereotyping, jokes, or threatening, intimidating, or hostile acts that relate to race, color, gender, religion, sexual orientation, age, national origin, or disability; and (2) written or graphic material that denigrates or shows hostility toward an individual or group because of race, color, gender, religion, sexual orientation, age, national origin, or disability and that is circulated in the workplace, including through digital means, or placed anywhere in 

Baby Steps’ premises such as on an employee’s desk or workspace, on Baby Steps’ equipment or bulletin boards, or within digital spaces associated with the workplace such as company email or messaging platforms.  Other conduct may also constitute discriminatory harassment if it falls within the definition of discriminatory harassment set forth above. 

It is also against Baby Steps’ policy to retaliate in any way against an employee for filing a complaint of discriminatory harassment or for cooperating in an investigation of a complaint of discriminatory harassment. Retaliation can take many forms, including but not limited to adverse employment actions, exclusion, or creating a hostile work environment. 

Reporting of Harassment:  If you believe that you have experienced or witnessed sexual harassment or other discriminatory harassment by any employee of Baby Steps, you should report the incident immediately to your supervisor or to the President & CEO. If the alleged harasser is your supervisor or the President & CEO, you should report the incident to the designated grievance officer. Possible harassment by others with whom Baby Steps has a business relationship, including donors and vendors, should also be reported as soon as possible so that appropriate action can be taken.   

Baby Steps will promptly and thoroughly investigate all reports of harassment as discreetly and confidentially as practicable.  The investigation would generally include a private interview with the person making a report of harassment.  It would also generally be necessary to discuss allegations of harassment with the accused individual and others who may have information relevant to the investigation. Baby Steps’ goal is to conduct a thorough investigation, to determine whether harassment occurred, and to determine what action to take if it is determined that improper behavior occurred.   

If Baby Steps determines that a violation of this policy has occurred, it will take appropriate disciplinary action against the offending party, which can include counseling, warnings, suspensions, and termination.  Employees who report violations of this policy and employees who cooperate with investigations into alleged violations of this policy will not be subject to retaliation.  Upon completion of the investigation, Baby Steps will inform the employee who made the complaint of the results of the investigation. 

Compliance with this policy is a condition of each employee’s employment, and failure to comply may result in disciplinary action up to and including termination.  Employees are encouraged to raise any questions or concerns about this policy or about possible discriminatory harassment with the President & CEO.  In the case where the allegation of harassment is against the President & CEO, please notify the staff member designated as grievance officer. 

Any information that an employee learns about Baby Steps, or its members or donors, as a result of working for Baby Steps that is not otherwise publicly available constitutes confidential information. Employees may not disclose confidential information to anyone who is not employed by Baby Steps or to other persons employed by Baby Steps who do not need to know such information to assist in rendering services. 

The protection of privileged and confidential information, including trade secrets, is vital to the interests and the success of Baby Steps.  The disclosure, distribution, electronic transmission or copying of Baby Steps’ confidential information is prohibited.  Such information includes, but is not limited to the following examples: 

• Compensation data. 

• Program and financial information, including information related to donors, and pending projects and proposals. 

As a condition of employment, employees are required to sign a non-disclosure agreement, which primarily obligates them to maintain the confidentiality of Baby Steps' information and imposes penalties for any breach of this obligation. Any employee who discloses confidential Baby Steps information will be subject to disciplinary action (including possible separation), even if he or she does not actually benefit from the disclosure of such information.   

Discussions involving sensitive information should always be held in confidential settings to safeguard the confidentiality of the information.  Conversations regarding confidential information should not be conducted on cellular phones while in public places, or in elevators, restrooms, restaurants, or other places where conversations might be overheard. 

Employees are prohibited from soliciting (personally or via electronic mail) for membership, pledges, subscriptions, the collection of money or for any other purpose not directly related to their job duties or without explicit permission from management, anywhere on Baby Steps property during work time, especially those of a partisan or political nature.  “Work time” includes time spent in actual performance of job duties but does not include lunch periods or breaks.  Non-working employees may not solicit or distribute to working employees.  Persons who are not employed by Baby Steps may not solicit or distribute literature on Baby Steps’ premises at any time for any reason.

Employee Nondiscrimination Policy:

Baby Steps will not tolerate any form of discrimination.  All employees are expected to cooperate fully in implementing this policy.  In particular, any employee who believes that any other employee of Baby Steps may have violated the Equal Employment Opportunity policy should report the possible violation to the President & CEO.   

Who We Serve Nondiscrimination Policy:

Baby Steps does not intend to discriminate. However, this organization's exempted charitable services shall only extend to pregnant women between the ages of 18-25, enrolled as students at any Baby Steps university Hub location. Too, pregnant students will have to complete an enrollment form for services, as well as pass any requested drug-screening tests. Beyond these limits, however, Baby Steps will not discriminate on the basis of any state recognized category, including race, color, national origin, physical or mental disability or religion. 

Baby Steps requires directors, officers, and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of Baby Steps, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations. 

Reporting Responsibility: 

This Whistleblower Policy is intended to encourage and enable current and former employees, board members, interns, contractors, vendors, volunteers and any individuals who report concerns related to misconduct, violations of law or organizational policy related to financial misconduct, harassment of any kind, or safety violations. It is the responsibility of all board members, officers, employees, and volunteers to report concerns about violations of Baby Steps’ code of ethics or suspected violations of law,regulations or policies that govern Baby Steps’ operations. 

No Retaliation: 

It is contrary to the values of Baby Steps for anyone to retaliate against any board member, officer, employee or volunteer who in good faith reports concerns of any violation of the above-referenced laws or policies governing the operations of Baby Steps. 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. 

Reporting Procedure: 

Baby Steps has an open door policy and suggests that employees share their questions, concerns, suggestions, or complaints with their supervisor. If you are not comfortable speaking with your supervisor or you are not satisfied with your supervisor’s response, you are encouraged to speak with the CEO/President. Supervisors and managers are required to report complaints or concerns about suspected ethical and legal violations in writing to Baby Steps’ CEO/President, who has the responsibility to investigate all reported complaints. Employees with concerns or complaints may also submit their concerns in writing directly to their supervisor, the Executive Director, or the organization’s Compliance Officer. 

Compliance Officer: CEO/President 

Baby Steps’ CEO/President is responsible for ensuring that all complaints about unethical or illegal conduct are investigated and resolved. The Compliance Officer will advise the Board Chair and/or the Board of Directors of all complaints and their resolution and will report at least annually to the Chair of Finance & Audit Committee on compliance activity relating to accounting or alleged financial improprieties. If the complaint is to be made against the CEO/President, it may be submitted to the Chairman of the Board of Directors, Michelle Schultz at Michelle.Schultz@babysteps.org. 

Accounting and Auditing Matters: 

Baby Steps’ CEO/President shall immediately notify the Audit Committee/Finance Committee of any concerns or complaints regarding corporate accounting practices, internal controls or auditing and work with the committee until the matter is resolved. 

Acting in Good Faith: 

Anyone filing a written complaint concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. 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/Anonymity: 

Violations or suspected violations may be submitted on a confidential basis by the complainant. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation. While we encourage individuals to identify themselves to facilitate investigation, reports may be submitted anonymously by email in writing at HRReports@babysteps.org. Baby Steps will take all reports seriously regardless of the reporting party’s identity. 

Handling of Reported Violations:

The Baby Steps’ CEO/President will notify the person submitting the complaint and acknowledge receipt of the reported violation or suspected violation within five business days. All reports will be promptly investigated, and appropriate corrective action will be taken if warranted by the investigation. Baby Steps will seek to resolve all reports and investigations within thirty (30) days of receipt.

Compliance Officer: 

Cary Chandler 

President & CEO 

Cary.Chandler@babysteps.org 

It is important for Baby Steps directors, officers, and staff to be aware that both real and apparent conflicts of interest or dualities of interest sometimes occur in the course of conducting the affairs of the corporation and that the appearance of conflict can be troublesome even if there is in fact no conflict whatsoever. Conflicts Occur because the many persons associated with the corporation should be expected to have, and do in fact generally have multiple interests and affiliations and various positions of responsibility within the community. In these situations a person will sometimes owe identical duties of loyalty to two or more corporations. The purpose of the conflict of interest policy is to protect the corporation's tax-exempt interest when it is contemplating entering into a transaction or arrangement that might benefit the private interest of an officer or director of the corporation or might result in a possible excess benefit transaction. The policy is intended to supplement but not replace any applicable state and federal laws governing conflict of interest applicable to nonprofit and charitable organizations. Conflicts are undesirable because they potentially or eventually place the interests of others ahead of the corporation's obligations to its charitable purposes and to the public interest. Conflicts are also undesirable because they often reflect adversely upon the person involved and upon the Institutions with which they are affiliated, regardless of the actual facts or motivations of the parties. However, the long-range best interests of the corporation do not require the termination of all association with persons who may have real or apparent conflicts that are harmless to all Individuals or entities involved, 

Each member of the board of directors and the staff of the corporation has a duty of loyalty to the corporation. The duty of loyalty generally requires a director or staff member to prefer the interests of the corporation over the director's/staff's interestsor the Interests of others. In addition, directors and staff of the corporation shall avoid acts of self-dealing which may adversely affect the tax-exempt status of the corporation or cause there to arise any sanction or penalty by a governmental authority. 

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.

DEFINITIONS 

2.1 Interested Person 

Any director, 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. 

2.2 Financial Interest 

A person has a financial interest if the person has, directly or indirectly, thorough business, investment, or family: (a) An ownership or investment interest in any entity with which the corporation has a transaction or arrangement, 

(b) A compensation arrangement with the corporation or with any entity or individual with which the corporation has a transaction or arrangement, or 

(c) A potential ownership or investment interest in, or compensation arrangement with, any entity or individual with which the corporation is negotiating a transaction or arrangement, 

Compensation includes direct and indirect remuneration as well as gifts or favors that are not insubstantial. A financial interest is not necessarily a conflict of interest. Under Article III, Section 2, a person who has a financial işterest may have a conflict of interest only if the appropriate governing board or committee decides that a conflict of interest exists. 

PROCEDURES 

3.1 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 

3.2 Determining Whether a Conflict of Interest Exists Aller disclosure of the 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. 

3.3 Procedures for Addressing the Conflict of Interest (a) 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 (b) 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, (c) After exercising due diligence, the governing board or committee shall determine whether the corporation 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 (d) 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 a majority vote of the disinterested directors whether the transaction or arrangement is in the corporation'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 arrangements 

3.4 Violations of the Conflicts of Interest Policy 

(a) 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. (b) 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.