Policies

Intellectual depth, range, and independence from partisan politics are among New America’s most important assets. To protect New America’s commitment to nonpartisanship and intellectual independence, as well as abide by IRS regulations, it is essential that we maintain the highest standards with regard to the public statements and activities of New America staff and our political activity.

Political activity. As a tax-exempt, nonprofit organization governed by Section 501(c)(3) of the IRS Code, New America is prohibited as an institution from political activity. Therefore, New America does not participate in campaigns for candidates for public office, nor does it support or oppose specific candidates or parties. New America’s own purposes, values, and obligations, however, lead it to broader policies regarding engagement in the political process. New America is an important resource for policy development and information, and the audience for our research, ideas, and analysis inevitably includes elected officials and candidates for office of all parties, as well as non-elected policymakers, the media, and the public. In keeping with the organization’s mission, direct or indirect contact with elected officials, candidates, and their staffs is encouraged when it relates to bringing new ideas to the forefront of our nation’s discourse, allowing policymakers and others to better understand the policy challenges ahead.

Nonpartisanship. To protect New America’s commitment to nonpartisanship, staff members should observe the following principles and rules with regard to political activity. In keeping with the organization’s mission, staff may brief or consult with candidates and campaigns on a strictly non-exclusive basis. New America policy advice, research, publications, analysis, and conferences and events are available to government officials, legislators, political candidates, and others regardless of political affiliation. Staff should never make promises of exclusive access or advice. Staff may not appear as surrogates for candidates before the media or the public, and should refrain from representing or counseling them at public events or media appearances.

If staff members advise candidates in a fashion that constitutes or connotes support for those candidates, they must do so in a personal capacity, outside regular business hours, and without the use of New America resources. They must also make explicitly clear that they are acting as individuals and not on behalf of New America. When staff members make such arrangements in a personal capacity, they should discuss and disclose their plans with their supervisor in advance, and must request a leave of absence if their political activities interfere with, or take time away from, their New America obligations.

In the case of Fellows and other part-time employees, it is expected that they will have outside activities and income beyond their commitment to the organization. Employees in these categories are welcome to participate in political activity on their own time and on their own behalf (on both a paid and unpaid basis), but not as representatives of New America. In the case of Fellows with multiple affiliations, when in doubt about participation in a political activity, they should use another of their affiliations or none at all. In the interest of open communication, Fellows should also discuss and disclose political activity with appropriate colleagues in a timely fashion.

All questions regarding political activity should be directed to the CEO, President/Chief Transformation Officer, or Chief Operating Officer. Staff and Fellows wishing to publicly or privately provide exclusive advice to a candidate or a party, or work for a specific candidate, join an advisory council to a campaign, or run for office must seek written approval from the CEO and President/Chief Transformation Officer of New America to reach a mutually agreed upon arrangement in advance of official engagement.

Conflict of interest. New America’s conflict of interest policy is designed to assure the highest level of ethical conduct of persons employed by or involved in the governance of the organization in all that pertains to the organization, and to avoid public perceptions and financial consequences detrimental to New America that could arise from the misuse, or perception of misuse, of an individual’s position or influence. New America’s conflict of interest policy is not designed to eliminate or exclude relationships and activities that might create a duality of interest, but rather to encourage transparency and careful deliberation in those cases where conflicts or perceived conflicts may arise.

A conflict of interest may be defined as an interest that might affect, or might reasonably appear likely to affect, the judgment or conduct of an individual associated with the organization.

A conflict of interest may exist when the interests or concerns—or potential interests or concerns—of any director, officer, fellow, or staff member, or any individual, group, or organization to which one of these people has allegiance, may be seen as competing with the interests or concerns of the organization, or may impair these people’s independence or loyalty to the organization.

For example, a conflict of interest may exist if a director, officer, fellow, or staff member:

• has a business or financial interest in any third party dealing with the organization;
• holds office, serves on a board, participates in management, or is employed by any third party dealing with the organization;
• derives remuneration or other financial gain from a transaction involving the organization (other than salary reported on a W-2 or W-9 or salary and benefits expressly authorized by the Board);
• receives gifts from any third party on the basis of his or her position with the organization (other than occasional gifts valued at no more than $50, or if valued at more than $50, the gift is made available in a team space or common area for others to share—e.g., fruit baskets, boxes of candy.) All other gifts should be returned to the donor with the explanation that the organization policy does not permit the acceptance of gifts. No personal gift of money should ever be accepted;
• engages in any outside employment or other activity that will materially encroach on such person’s obligations to the organization; compete with the organization’s activities; involve any use of the organization’s equipment, supplies, or facilities; or imply the organization’s sponsorship or support of the outside employment or activity.

Conflict of interest disclosure. Whenever any director has a conflict of interest or a possible perceived conflict of interest with the organization, they shall notify the Chair of the Board of Directors of such conflict.

Whenever any staff member or fellow has a conflict of interest or a possible perceived conflict of interest with the organization, they shall consult with their supervisor or another member of the leadership team and, if warranted, notify the CEO or President of such conflict.

When any conflict of interest is relevant to a matter under consideration or requiring action by the Board of Directors, or committee thereof, the interested person shall call it to the attention of the Chair of the Board of Directors and shall not be present during Board or committee discussion or decision on the matter. However, that person shall provide the Board or applicable committee with any and all relevant information on the particular matter.

The minutes of the meeting of the Board of Directors or committee thereof shall reflect that the conflict of interest was disclosed, and that the interested person was not present during discussion or decision on the matter and did not vote.

A copy of this conflict of interest policy shall be furnished to each director, officer, fellow, and staff member who is presently serving this organization or who may hereafter become associated with it. The policy and its application shall be reviewed annually for the information and guidance of directors, officers, and staff members, each of whom has a continuing responsibility to scrutinize their transactions and outside business interests and relationships for potential conflicts and make such disclosures as described herein.

Each director will be asked to complete a Conflict of Interest Policy Disclosure Statement upon their election or re-election to the Board and annually thereafter. Each officer and senior staff member will be asked to complete such a Statement upon their employment and on an annual basis thereafter.

508(c) compliance. New America recognizes its responsibility to develop electronic and information technology (EIT) products and services that are accessible and usable by all people, including those with disabilities and special needs. New America is committed to making its products and services compliant with the accessibility standards of Section 508 (Electronic and Information Technology Accessibility Standards, 36 C.F.R. § 1194). These regulations implement Section 508 of the Rehabilitation Act of 1973 (29 U.S.C.A. § 794d) and the Web Content Accessibility Guidelines 1.0 (WCAG 1.0) published by the Web Accessibility Initiative of the World Wide Web Consortium (W3C). In accordance with Section 508(c), New America’s online content and services are designed to comply with the applicable accessibility standards to the maximum extent practicable. We support the efforts of the federal government and legislature to make electronic information products and web-based products accessible to federal employees and the public.