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Goals of financial review
The purpose of the financial review is to verify compliance with the grant agreement and adherence to minimum standards in good practices, in order to (1) fulfill our regulatory requirements and good practices as grant makers, and; (2) ensure grantees are adequately supported to identify and improve good practices in these areas.
Who receives financial review
All annual plan grantees will be reviewed by the grants compliance team for an on site financial review as part of a site visit or by a designated local third party. This review should be conducted within 2-3 years of the initial APG grant.
Criteria for passing financial review
In order to pass the financial review, each grantee should demonstrate compliance with their agreements with WMF, and must meet WMF’s standards for good practice. If the organization does not pass, a correction plan will be developed by the grantee and WMF, with a timeline for implementation. If a grantee fails the review, future funding may be contingent on the correction plan.
- Adherence to all agreements with WMF, including grant agreements, affiliate agreements, fundraising agreements and any other agreements. Adherence to agreements with parties other than the WMF (e.g. external grants) may also be evaluated as part of this criterion.
- Assurance of appropriate use of funds, including (a) conflict of interest policy in place and enforced; (b) use of funds only for charitable purposes; (c) funds used in a manner consistent with the organization’s bylaws; (d) no grant funds are used for purposes outside the grant agreement; (e) no inappropriate compensation of board members or volunteers.
- Adequate financial controls, including (a) accountability for equipment and fixed assets; (b) controls for cash disbursements; (c) segregation of duties and review of financial transactions; (d) account and record access.
- Complete, accurate, timely, and available financial reports for every fiscal year, with adequate transaction detail and including making adequate documentation of expenses available.
- Accounting procedures meet standards for local nonprofits, including controlled access to the accounting system and general ledger transaction integrity.
- Appropriate risk management, including (a) adequate insurance; (b) responsible management of grants and reimbursements, including compliance with anti-terrorist and anti-money laundering laws or requirements.
- Adequate payroll management, including management of payroll taxes.
- Adherence to relevant laws and regulations not otherwise addressed in these criteria.
Compliance with grant agreements
- Have grant reports been submitted on time?
- Have grant reports included complete financial documentation including receipts as required?
- Have submitted grant reports been deemed accurate and complete by WMF staff or the agency reviewing the reports?
- If past grant reports were not submitted on time, what steps has the grantee taken to ensure future compliance with grant agreements?
- Are there any past due reports still outstanding at the time of this review?
- If any past due reports are still outstanding at the time of this review, what steps has the grantee taken to remedy this situation?
- Is the grantee is the grantee now or has the grantee in the past been in possession of any remaining funds from a grant that has been completed?
- Is the grantee in possession of any remaining grant funds due to be returned to the grantor?
- If the grantee in possession of any remaining grant funds due to be returned to the grantor, is there a plan in place for speedy transfer of such funds to the grantor?
- Is the grantee in possession of any remaining grant funds due to be returned to the grantor beyond the period permitted by the grant agreement?
- If the grantee now in possession of any remaining grant funds due to be returned to the grantor beyond the period permitted by the grant agreement, and does the grantee have permission from the grantor to retain these funds past the agreed upon date?
- Has the grantee in the past been in possession of any remaining grant funds due to be returned to the grantor beyond the period permitted by the grant agreement, and did the grantee have permission from the grantor to retain these funds past the agreed upon date?
- Are there local laws or regulations in place that may prevent the grantee from speedily transferring remaining grant funds back to the grantor?
- Does the grantee have proper permissions from local regulatory agencies and under local law to receive grant funds, and is the grantee receiving disbursements in accordance with local regulations and laws?
- Is the financial information in the grantee’s grant reports consistent with other financial information provided by the grantee?
- Have grant funds been used in accordance with the purposes outlined in the grant agreement, and for no prohibited or questionable purposes?
- For restricted grants, has the grantee made significant changes to the grant budget after the time approval?
- For restricted grants, if the grantee has made significant changes to the grant budget after the time of approval, has the grantee requested permission for any significant changes to the grant budget in advance of making such changes, as instructed in the grant agreement?
- Are grant funds maintained in a separate account, or comingled with other funds?
- At a minimum, is a separate bookkeeping maintained to track grant funds?
- For general support grants, is adequate funds accounting in place?
- Has the grantee duly notified the WMF of significant changes that may affect the grantee’s performance, as required or recommended by the grant agreement?
- Have there been changes to the grantee’s overall financial health, and has WMF been promptly notified with these changes in accordance of the grant agreement?
- Have there been changes to the grantee’s board of trustees, senior management or other key personnel, and has WMF been promptly notified of these changes in accordance with the grant agreement?
- Has there been any change with respect to the identity of those individuals who have control of or access to the bank account dedicated to the administration and handling of the Grant funds, and has WMF been promptly notified of these changes in accordance with the grant agreement?
- Have there been any actual, potential, or threatened legal or regulatory actions; any claims or charges of impropriety; or any alleged regulatory or legal violations relating to Grantee’s operations or organization, and has WMF been promptly notified of these claims, charges, or accusations in accordance with the grant agreement?
- For general support grants, has the chapter complied with best organizational practices outlined by the WMF board of trustees?
- Does the organization have an annual plan in place that includes goals and planned program activities?
- Does the organization have a multi-year strategic plan in place?
- Does the organization have core governance policies in place, such as a Code of Conduct for the Board?
- Does the organization promptly publish minutes of board meetings within 30 days after the session?
- Does the organization publish information on major donations, grants, and partnerships annually?
- Does the organization conduct regular reviews of its impact on an annual basis?
Compliance with affiliate agreement (if applicable)
- Does your organization have a valid, signed affiliate agreement in place with WMF
- Has the organization submitted a complete and acceptable annual financial report covering your entire fiscal year on Meta within 4 months of the end of your organization’s fiscal year, according to the instructions in the chapter agreement?
- Has your organization submitted a complete and acceptable annual activity report covering your entire fiscal year on Meta within 4 months of the end of your organization’s fiscal year, according to the instructions in the chapter agreement?
- Has your organization advised the WMF of any changes to your bylaws which may affect your chapter’s status or relationship to WMF?
- Has your organization engaged in any activity which might negatively affect the Wikimedia Foundation or the Wikimedia movement?
- Has your organization engaged in any illegal activity?
- Has your organization respected the Wikimedia visual identity guidelines?
- Is your organization otherwise in compliance with the terms of your affiliate agreement?
Compliance with Fundraising Agreement with WMF (if applicable)
- Are you in compliance with your fundraising agreement with WMF? (Review fundraising agreement together)
Appropriate use of funds
- Are all of the organization’s funds used exclusively for charitable purposes?
- Does the organization have nationally recognized not-for-profit charitable status? 501c3 equivalency.
- Does your organization compensate volunteers for work normally done without pay in other parts of the Wikimedia movement? Please list the names and amounts of those compensated.
- Does your organization compensate volunteers or other individuals for contributing content to Wikimedia projects? Please list the names and amounts of those compensated.
- Are the roles and responsibilities of your board documented?
- Are the roles and responsibilities in your bylaws followed by Board officers and members?
- Does your organization pay any of its board members?
- If your organization compensates any of its board members, please list the board members compensated and the amounts paid. Honorariums paid to board members are not a norm in the Wikimedia movement, and will be subject to intense scrutiny. You must prove that these amounts were not paid from WMF grant funds.
- Does your organization have a conflict of interest policy in place?
- Are all board members and key decision makers aware of this policy?
- Is this conflict of interest policy used and enforced?
- Please report all relevant incidents related to conflict of interest violations in the past 4 years.
Fixed assets - Records and Controls
- What are your fixed assets?
- How do you record and track these fixed assets?
- How do you report your fixed assets?
- Please report any losses in fixed assets in the past 4 years.
- How are your fixed assets stored and secured?
- Do you have fixed assets (such as equipment) that are available for loan?
- Where are your policies for equipment lending documented publicly?
- How do you track equipment that has been loaned?
- What policies do you have in place to ensure the timely return of loaned equipment?
- What policies do you have in place to determine who is eligible to borrow equipment?
- What policies do you have in place to determine the amount of time equipment may be loaned out to an individual or group?
- Segregation of Duties: Who in the organization and the board does what?
- Expenditure approvals: Walk us through the process once an invoice is submitted.
- Transaction review: Who reviews what transactions and how?
Cash Disbursement Controls
- Who has access to petty cash and checks?
- How are records of withdrawals from petty cash recorded?
Bank Controls and Records
- Access to bank accounts: How many bank accounts does the organization have, and who has access?
- How are financial records stored and maintained?
- Who has access to your financial records?
Accounting and Financial Records
- Do you have an accounting system in place that meets local standards for nonprofit organizations of your size?
- Does your accounting system allow you to track who makes changes in the system?
- Is your system customized to meet the needs of nonprofit organizations in your context?
Financial Statements and Bank Statements
- Where, how, and when do you post your organization’s financial statements?
- Are your financial statements audited by an independent auditor or accountant at least once a year?
- Do your financial statements balance?
- Are financial statements approved by your board or governing body?
- Do you make versions of your financial statements in English as well as your local language?
- Do you review your financial reports against your budget for each year to determine how you spent against your plan? Do you have checks in place to understand your spending throughout the year?
- Review balance sheets.
- When recording transactions, do you maintain detailed records of each transaction, which give a sufficient idea of how funds were spent or where they came from?
- How often do you review your organization’s bank statements?
- Do your bank statements match your internal records?
- Have you retained receipts for your expenses for the past four years, or longer as may be required by local laws and regulations.
- Have you filed appropriate documents with the local authorities in a timely way?
- Have you paid all taxes due this current and previous years?
- How does the organization assess and address risks?
- Is there any insurance required for the organization?
- If insurance is required, does the organization have the required insurance?
- Are board members covered by any liability insurance, if say, a community member falls and trips at an event?
Microgrants, reimbursements, and scholarships
- Does the organization give grants, microgrants, reimbursements, scholarships, or other funds to individuals?
- Does the organization give grants, microgrants, reimbursements, scholarships, or other funds to groups or organizations?
- For any grants given to organizations, does the grantee have proper documentation to ensure the appropriate use of funds for qualifying charitable purposes as outlined in Appendix 3 of the grant agreement?
- For all grants, does the organization have a written record setting forth the terms and conditions of the grant?
- Is the organization in compliance with good practices outlined in Appendix 3 of the grant agreement on regranting?
- Does the organization require written reports at least annually?
- How does the organization oversee appropriate use of funds by grantees?
- Has the organization had to address misuse of grant funds by any grantee?
- What policies are in place to prevent misuse of funds?
- Does the organization offer any funding to individuals, groups, or organizations they do not yet know (e.g. does the organization conduct any open calls for grants)?
- Does the organization have a clear record of funding given to individuals, groups, or organizations? Please provide these records.
- Does the organization appropriately screen funds recipients to ensure they are not on any OFAC anti-terrorism list?
Payroll Management and Taxes
- How does payroll for your organization get disbursed?
- What controls does the organization have in place around disbursing payroll?
- How are your organization’s government payroll taxes paid?
- Have government payroll taxes always been paid in full and on time?