Last week on our 411 on International Giving post, we covered how one goes about setting a strategy for a global CSR program. Today in part two, we will address the other major concern that the 2013 Giving Beyond Borders study raised as being of significant concern to those embarking on developing an international employee engagement program.
PART TWO: INTERNATIONAL VETTING AND COMPLIANCE
After mastering international employee engagement program design and implementation, the next step is to determine how to perform international vetting and disbursements. The following recommendations are for companies who are disbursing funds from the USA.
According to the study conducted by LBG Associates:
- 43% of companies surveyed utilize both company resources and vendor resources to perform vetting.
- 39% of companies utilize the vendor only to perform vetting.
- 18% of companies rely solely upon themselves to perform vetting.
This statistic is not surprising, as vetting international organizations is expensive and time intensive. Imagine the difficulties in communicating in a foreign language with a small NGO in a remote area of the world. They may not have an Executive Director or contact listed on their website, or even a website for that matter! You can attempt to contact them via postal mail, but your multiple attempts may go unanswered.
Several companies utilize workaround solutions in order to avoid the hassle and expense of international vetting by implementing lower standards for vetting volunteer or matching gift donations. Some companies only allow employees to donate to non-profits supported by the corporate grant program. Lastly, some companies will only work with US 501(c)(3)s that have an international program or affiliates.
Depending upon your corporate structure, you may only need to comply with certain laws. If your CSR department is a corporate foundation, you must complete equivalency determinations for each international non-profit you wish to support. This process determines the non-profit’s equivalent status in the United States and maintains the corporate foundation’s charitable status.
If your CSR giving is solely corporate contributions, you must concern yourself with FCPA (Foreign Corrupt Practices Act). Compliance with FCPA ensures that the recipient organization is a NGO and prevents bribery or other illegal activities. And don’t forget Patriot Act compliance! This ensures that your corporate dollars do not support terrorist organizations.
You may need support in completing these processes, and a variety of partners exist to assist you in ensuring that you are abiding by these laws. TechSoup Global is a non-profit with an international network of NGOs that provides technology and other services to the social sector. TechSoup offers two services for vetting international NGOs including NGOSource and NGOk. NGOSource is a membership service and provides members with a database of Equivalency Determinations. NGOk is global validation service ensuring that an organization is recognized as an NGO in their country of origin.
GlobalGiving is yet another organization which provides vetting services. This non-profit organization has boots on the ground in the most remote areas of the world performing vetting at both the project level and organization level. With this type of service, you can ensure that the non-profit organization is fully compliant with national/international law and corporate goals.
No one said going global would be easy, but with the proper support from partner organizations and your international staff, you can ensure that your programs will be a success from design to implementation. Imagine your global philanthropy impact!