Exhibit E
SHAREALEDGER, NFP
DOCUMENT RETENTION & DESTRUCTION POLICY
Last Revised April 30, 2021
This is the Document Retention & Destruction Policy of SHAREALEDGER, NFP, an Arizona nonprofit corporation (the “Corporation”) adopted by the Board of Directors of the Corporation on April 30, 2021.
The Corporation takes seriously its obligations to preserve information relating to litigation, audits, and investigations. In accordance with the Sarbanes-Oxley Act, which makes it a crime to alter, cover up, falsify, or destroy any document with the intent of impeding or obstructing any official proceeding, this policy provides for the systematic review, retention, and destruction of documents received or created by Corporation in connection with the transaction of corporate business. Failure on the part of employees to follow this policy can result in possible civil and criminal sanctions against the Corporation and its employees and possible disciplinary action against responsible individuals (up to and including termination of employment). Each employee has an obligation to contact the President or a member of the Board of Directors of a potential or actual litigation, external audit, investigation, or similar proceeding involving Corporation.
The information listed in the retention schedule below is intended as a guideline and may not contain all the records Corporation may be required to keep in the future. Questions regarding the retention of documents not listed in this policy should be directed to the President of the Corporation.
From time to time, the President may issue a notice, known as a “legal hold,” suspending the destruction of records due to pending, threatened, or otherwise reasonably foreseeable litigation, audits, government investigations, or similar proceedings. No records specified in any legal hold may be destroyed, even if the scheduled destruction date has passed, until the legal hold is withdrawn in writing by the President.
This policy covers all records and documents, regardless of physical form, contains guidelines for how long certain documents should be kept, and how records should be destroyed (unless under a legal hold). The policy is designed to ensure compliance with federal and state laws and regulations, to eliminate accidental or innocent destruction of records, and to facilitate Corporation’s operations by promoting efficiency and freeing up valuable storage space.
Document Retention
The Corporation document retention procedures are set forth below. Documents that are not listed, but are substantially similar to those listed in the schedule, will be retained for the appropriate length of time.
Electronic Documents and Records
Electronic documents will be retained as if they were paper documents. Therefore, any electronic files, including records of donations made online, that fall into one of the document types on the above schedule will be maintained for the appropriate amount of time. If a user has sufficient reason to keep an e-mail message, the message should be printed in hard copy and kept in the appropriate file or moved to an “archive” computer file folder. Backup and recovery methods will be tested on a regular basis.
Emergency Planning
The Corporation’s records will be stored in a safe, secure, and accessible manner. Documents and financial files that are essential to keeping the Corporation operating in an emergency will be duplicated or backed up periodically and maintained off-site.
Document Destruction
The Corporation’s President shall appoint an officer of the Corporation who will be responsible for the ongoing process of identifying the Corporation’s records that have met the required retention period, and overseeing their destruction. Destruction of financial and personnel-related documents will be accomplished by shredding. Document destruction will be suspended immediately, upon any indication of an official investigation or when a lawsuit is filed or appears imminent. Destruction will be reinstated upon conclusion of the investigation.
Compliance
Failure on the part of employees to follow this policy can result in possible civil and criminal sanctions against the Corporation and its employees and possible disciplinary action against responsible individuals. The President and Board of Directors will periodically review these procedures with legal counsel or the Corporation’s certified public accountant to ensure that they are in compliance with new or revised laws and regulations.
SECRETARY’S CERTIFICATE
I, the undersigned officer of SHAREALEDGER, NFP, an Arizona nonprofit corporation (the “Corporation”), do hereby certify that the foregoing Document Retention & Destruction Policy is a true and correct copy of the Document Retention & Destruction Policy of the Corporation adopted by the affirmative vote of the Directors of the Corporation on April 30, 2021.
IN WITNESS WHEREOF, I have hereunto set my hand on April 30, 2021. [Signed] Kip M. Twitchell
Kip Mack Twitchell, Secretary