Policies
Comprehensive policy hub for Feed America (EIN 92-1761881). Foundation due-diligence teams: this page lists every documented governance and donor-protection policy, with the public reference where the policy lives.
Bylaws
Feed America Inc. is a Texas nonprofit corporation governed by adopted bylaws. The bylaws cover: governing-body composition + officer roles + meeting frequency + quorum + voting + amendment procedure + dissolution clause (per IRC 501(c)(3)).
Public reference: Form 990 Part VI Section A (governing body) + Schedule O (additional disclosures). Verifiable on ProPublica\u0027s 990 mirror.
Full bylaws available on request to corporate@feedam.org.
Conflict of Interest Policy
Feed America has adopted a written conflict-of-interest (COI) policy modeled on the IRS-published sample policy in Form 1023 Appendix A. The policy:
- Applies to all directors, officers, and key employees
- Requires annual written disclosure of potential conflicts
- Establishes recusal procedure when a conflict exists
- Documents board action and rationale on conflict-affected transactions
- Is reviewed annually by the board governance committee
Public reference: Form 990 Part VI line 12a–c. Filed and disclosed publicly each year.
Whistleblower Policy
Feed America has adopted a written whistleblower policy that:
- Provides anonymous reporting channels (ethics@feedam.org + voicemail)
- Prohibits retaliation against reporters
- Establishes investigation + escalation procedure
- Mandates board notification of substantiated reports
- Is reviewed annually
Public reference: Form 990 Part VI line 13.
Document Retention + Destruction Policy
Feed America has adopted a written document retention + destruction policy compliant with the Sarbanes-Oxley Act (which applies to nonprofits via the records-destruction provisions). The policy specifies retention periods for: Form 990 + audit (permanent), bank records (7 years), donor records (7 years), grant records (7 years post-grant-end), IT logs (1-3 years).
Public reference: Form 990 Part VI line 14.
Executive Compensation Review Policy
Executive compensation is reviewed annually by the board\u0027s compensation committee against IRS-published comparable-data benchmarks for similar 501(c)(3) hunger-relief organizations. The review establishes presumption of reasonableness under IRC 4958.
Public reference: Form 990 Part VI line 15a–b + Schedule J (where applicable).
Financial Reserves Policy
Feed America commits to maintaining at least 3 months of operating reserves. The reserve is held in cash, US Treasury bills, and FDIC-insured deposits. No equities, no derivatives, no crypto.
Public reference: Audited Statement of Financial Position + Form 990 Schedule O.
Program-Spending Ratio Commitment
Feed America commits to a program-spending ratio of ≥85% — top-quartile of US hunger-relief 501(c)(3)s. The ratio is calculated from the audited Statement of Functional Expenses and disclosed annually.
Public reference: Audited financial statements + Form 990 Part IX.
Gift Acceptance Policy
Feed America has adopted a written gift acceptance policy. The policy:
- Identifies acceptable gift forms: cash, ACH, wire, check, stock, mutual funds, real property (with case-by-case review), donor-advised fund grants, IRA qualified charitable distributions, planned-gift instruments
- Identifies gift forms requiring board pre-approval: real property, restricted gifts >$50K, in-kind gifts of services, gifts with naming-rights provisions
- Identifies gift forms NOT accepted: gifts that would jeopardize 501(c)(3) status, gifts inconsistent with mission, gifts from sources whose business activities materially conflict with anti-hunger work
- Establishes acknowledgement procedure (IRS-compliant gift letter within 5 business days)
- Establishes valuation procedure for non-cash gifts (independent qualified appraisal where IRS requires)
Public reference: Available on request to finance@feedam.org.
Donor Privacy Policy
Per the Donor Bill of Rights at /donor-rights:
- Donor information stored encrypted at rest
- No donor list sales, trades, rentals, or sharing
- Individual donor identities kept confidential except where required by law (Form 990 Schedule B for gifts ≥$5,000)
- Mailing list removal within 1 business day, permanent
- Public donor recognition only with explicit written consent
Public reference: /donor-rights + /privacy.
Anti-Discrimination Policy
Feed America serves all individuals regardless of race, color, religion, sex (including pregnancy, sexual orientation, gender identity), national origin, age, disability, genetic information, marital status, military / veteran status, or any other protected characteristic. We comply with all applicable federal anti-discrimination laws including Title VII of the Civil Rights Act of 1964, the Age Discrimination Employment Act, and the Americans with Disabilities Act.
Feed America also serves all food-insecure individuals regardless of immigration status — federal food-assistance directories serve everyone. Concerns about discrimination in our directory data or service: ethics@feedam.org.
Child Safety Policy
Where Feed America\u0027s programs intersect with children (school meals data, summer meals, WIC clinics, family pantries), we observe the following:
- No collection of personally-identifiable data on minors
- No images of minors without parent / legal-guardian written consent
- Compliance with COPPA and applicable state child-protection laws
Data License + Attribution Policy
Feed America\u0027s aggregated directory data is released under Creative Commons BY 4.0. Source data from federal agencies is in the public domain; nonprofit-partner data carries the originating organization\u0027s attribution.
Attribution required: "Data from Feed America, feedam.org, EIN 92-1761881."
Security Policy + Responsible Disclosure
See /security for the full security policy. RFC 9116 contact at /.well-known/security.txt.
Related
- /financials — financial transparency hub
- /donor-rights — AFP Donor Bill of Rights
- /grants — foundation officer landing
- /reports — annual reports + open-data catalog
- /transparency — sister-entity transparency hub
- /security — security + responsible disclosure
Contact
Policy questions: corporate@feedam.org · Ethics / whistleblower: ethics@feedam.org (anonymous accepted) · Board: board@feedam.org
Last reviewed 2026-04-29. Page maintained by Feed America Inc. (EIN 92-1761881). All policies reviewed annually by the board.