Company Policy

NGO Governance & Policy Pack

Legal form: Registered Association (eingetragener Verein – e.V.)
Jurisdiction: Federal Republic of Germany
Language: English (governing German law)
Board status: Unpaid (expenses reimbursable only)

1. Purpose and Scope

This Governance & Policy Pack sets out the internal rules, standards, and procedures governing Gut für Besser – Good for Better (GFP) e.V. (the “Association”). It is designed to:

  • Ensure compliance with German non-profit law (Gemeinnützigkeit), tax law, labor law, and GDPR
  • Promote transparency, integrity, and good governance
  • Protect the Association, its members, and its Board from legal and reputational risk
  • Meet donor, partner, and audit expectations

All Board members, members, employees, volunteers, and representatives of the Association are required to comply with these policies.

2. Governance Structure

2.1 General Assembly

The General Assembly (Mitgliederversammlung) is the supreme governing body of the Association and exercises the powers granted under the Articles of Association (Satzung).

2.2 Board (Vorstand)

  • The Board manages and represents the Association in accordance with §26 BGB and the Articles of Association.
  • Board members serve on an unpaid basis.
  • Board members may be reimbursed for actual and reasonable expenses incurred in the performance of their duties, subject to this Policy Pack.

3. Code of Conduct & Ethics Policy

3.1 Core Principles

All persons acting on behalf of the Association shall:

  • Act in line with the charitable purpose of GFP e.V.
  • Act honestly, responsibly, and in good faith
  • Avoid personal gain from Association activities
  • Respect diversity, human dignity, and local communities

3.2 Professional Conduct

  • No misuse of funds, assets, or information
  • No discrimination, harassment, or abusive behavior
  • Compliance with applicable laws in Germany and in countries of operation

4. Conflict of Interest Policy

4.1 Definition

A conflict of interest arises when personal, professional, or financial interests interfere or appear to interfere with the interests of the Association.

4.2 Disclosure

  • Board members must disclose any actual or potential conflict of interest promptly.
  • Disclosures must be recorded in the Board minutes.

4.3 Management

  • The affected person must abstain from discussions and decisions relating to the conflict.
  • Any related-party transaction must comply with German non-profit law and arm’s-length principles.

5. Board Remuneration & Expense Reimbursement Policy

5.1 No Remuneration

  • Board members shall not receive salaries, fees, or other remuneration.

5.2 Expense Reimbursement

  • Reimbursement is permitted only for actual, reasonable, and documented expenses, including:
    • Travel (economy class unless approved otherwise)
    • Accommodation (moderate standard)
    • Meals within reasonable limits
    • Official supplies

5.3 Procedure

  • Expenses must be supported by original receipts.
  • Claims must be submitted within 3 months.
  • Approval by a second Board member is required.

6. Financial Management & Internal Controls Policy

6.1 Principles

  • Funds must be used exclusively and directly for the Association’s charitable purposes.
  • No distribution of profits or assets to members or Board.

6.2 Banking & Authorizations

  • Bank accounts shall be held in the Association’s name.
  • At least two authorized signatories shall be appointed.

6.3 Budgeting & Accounting

  • Annual budgets shall be approved by the Board.
  • Proper bookkeeping shall be maintained in accordance with German law.

6.4 Donations

  • Donations shall be recorded transparently.
  • Donation receipts (Zuwendungsbestätigungen) shall be issued in compliance with German tax rules.

7. Anti-Corruption & Anti-Bribery Policy

  • The Association maintains a zero-tolerance policy toward corruption and bribery.
  • No bribes, kickbacks, facilitation payments, or improper advantages may be offered or accepted.
  • This applies to dealings with public officials, partners, suppliers, and beneficiaries.

8. Human Resources & Volunteer Policy

8.1 Volunteers

  • Volunteers support the Association without remuneration.
  • Volunteers must act in line with this Policy Pack.

8.2 Employees (if applicable)

  • Employment contracts must comply with German labor law.
  • Salaries must be reasonable and aligned with non-profit standards.

9. Safeguarding Policy

The Association is committed to protecting vulnerable persons, including children and marginalized communities.

  • Abuse, exploitation, or neglect is strictly prohibited.
  • Safeguarding concerns must be reported immediately to the Board.

10. Data Protection & GDPR Policy

  • Personal data shall be processed lawfully, fairly, and transparently.
  • Data shall be used only for legitimate Association purposes.
  • Data subjects have rights of access, rectification, and erasure in accordance with GDPR.

11. Whistleblower Policy

  • Individuals may report concerns about misconduct confidentially and without fear of retaliation.
  • Reports may be made to the Board or an appointed trusted person.

12. Travel & Expense Policy

  • Travel must be necessary and cost-effective.
  • Economy class travel is the standard.
  • International travel requires prior Board approval.

13. Asset & Property Policy

  • Association assets must be used solely for charitable purposes.
  • Upon dissolution, assets shall be transferred to another charitable organization as defined in the Articles of Association.

14. Policy Review & Amendments

  • This Policy Pack shall be reviewed at least every two years.
  • Amendments require Board approval and, where required, approval of the General Assembly.

15. Adoption

This Governance & Policy Pack shall enter into force upon approval by the Board of Gut für Besser – Good for Better (GFP) e.V. and shall be binding on all members, Board members, employees, and volunteers of the Association.