Disclosure Policy

1. This Executive Directive establishes the Information Disclosure Policy of Sustainable Living Academy, Inc. (‘SLA’).

Purpose

2. SLA is committed to making information about its programs and operations available to the public. SLA considers public access to information a key component in the achievement of its mandate. SLA recognizes that there is a positive correlation between transparency, including through information-sharing, and public trust in SLA-supported development work and humanitarian response.

3. SLA management is accountable to the SLA Executuve Board. SLA management considers that public access to SLA information further facilitates SLA’s transparency and accountability.

4. This Information Disclosure Policy (this ‘Policy’) is intended to ensure that information concerning SLA programs and operations is available to the public, subject to the limitations set out in this Policy.

Definition of ‘information’

5. For purposes of this Policy, ‘Information’ means any produced content, whatever its medium (paper, electronic or sound, visual or audiovisual recording), concerning a matter relating to the policies, activities and decisions of SLA.

Scope of this policy

6. This Policy applies to all Information in the possession of SLA.

General principle of access to information

7. Information should be accessible and disclosed, subject to the limitations set forth in this Policy.

Accessibility of information

8. Information accessible to the public shall be made available, as much as possible, reasonable and practical, on one or more of the SLA public-access websites. A selected list of Information publicly presently available (or being made available on an on-going basis) through various means through the SLA website is listed in Annex A.

Restricted access to information

9. The Policy excludes data that exist in raw form, either physically or electronically. SLA is not in a position to respond to requests that require the selection and/or manipulation of data to produce content.

10. Confidential Information is not subject to disclosure and requires the following categories of information to be classified as ‘Confidential Information’:

1. Information received from or sent to third parties, with an expectation of confidentiality;
2. Information whose disclosure is likely to endanger the safety or security of any individual, violate his or her rights, or invade his or her privacy;
3. Information whose disclosure is likely to endanger the security or prejudice the security or proper conduct of any operation or activity of the organization;
4. Information covered by legal privilege or regulatory proceedings, or that subjects the organization to an undue risk of litigation, or is related to internal audits and investigations;
5. Internal inter-office or intra-office documents, including e-mails and draft documents;
6. Commercial information, if disclosure would harm either the financial interests of the organization or those of other parties involved;
7. Information which the organization believes would, if disclosed, seriously undermine a policy dialogue with an implementing partner; and
8. Other kinds of Information which, because of its content or the circumstances of its creation or communication, must be deemed confidential.

The definition of ‘Confidential Information’ should be understood in a way that favors disclosure as much as possible without contravening this Policy.

11. If only a part of the Information that is responsive to a particular request for disclosure is subject to one of the limitations set out in this Policy, SLA may decide, at its discretion, that the remaining part of the Information, responsive to that request, will be disclosed, and will take appropriate measures to preserve the confidentiality of the Information that is not disclosed.

12. Decisions of the SLA Executive Board and other SLA policies, procedures or practices, may contain Information disclosure limitations. This includes but is not limited to SLA Executive Board decision on disclosure of SLA internal audit reports only to official agencies. Nothing in or relating to this Policy will be deemed in any way to abridge, modify or abolish the application of those SLA Executive Board decisions or other SLA policies, procedures or practices.

Privileges and immunities of SLA

13. Nothing in or relating to this Policy will be deemed a waiver, express or implied, of any of the privileges and immunities of FLS, including its subsidiary organs, pursuant to the Convention on the Privileges and Immunities of the United Nations, 1946, or otherwise. Without limiting the generality of the previous sentence, the disclosure of Information in response to a request for disclosure, will not constitute a waiver, express or implied, of any of the privileges and immunities of SLA, including its subsidiary organs, pursuant to the Convention on the Privileges and Immunities of the United Nations, 1946, or otherwise.

Processing of information requests

14. Any person or organization may request the disclosure of SLA’s non-Confidential Information that is not otherwise available through SLA public-access websites.

15. Information requests should be handled by the head of the relevant SLA regional office, or headquarters Division or office. All media inquiries should be handled by the SLA communications staff.

16. The SLA official responsible for handling a request for Information that may be Confidential should seek guidance from the SLA Legal Counsel in the Office of the Executive Director, Utah Headquarters or the Director, Division of Human Resources Utah Headquarters (where the request relates to human resource issues).

17. All Information requests will be handled promptly. The requester should expect to receive an acknowledgement of receipt of the request within ten (20) working days (in Utah). Depending on the complexity of the request, SLA will endeavor to handle all requests within thirty (45) days after the acknowledgment of receipt is sent. For information requests that involve the reproduction of material, SLA may charge a fee for material and labor cost, which will be communicated to the requester and will need to be paid in advance.

18. SLA may partially or wholly deny a request, as follows:

1. In accordance with the limitations set out or referred to in this Policy;
2. If the request is deemed by SLA to be an excessive demand upon SLA’s resources; or
3. If the request, in the judgment of SLA, appears to be frivolous.

19. If a request is denied, the requester may seek the review of the decision by addressing a letter to the SLA Deputy Executive Director for Management. The Deputy Executive Director for Management will review the handling of the request for Information and make a determination on how to proceed. That review should normally be completed within sixty (60) days of being requested. The outcome of the review will be communicated to the requester and there will be no requirement for providing a detailed explanation of the outcome of the review.

Reproduction of information

20. The implementation of this Policy will be subject to existing rules on intellectual property and other proprietary rights including, but not limited to, patents, copyrights, and trademarks, which may, inter alia, limit a third party’s right to reproduce or exploit information.

Languages

21. This document will be available in English as the working language of SLA. This document may also be made available in the other languages at a later time.

Disclaimer

22. No representation is made or warranty given, express or implied, as to the completeness or accuracy of Information made available by SLA. The requester shall apply discretion when using the Information made available by SLA. SLA will not be liable for any direct or indirect loss arising from the use of the Information.

Final provisions

23. The Policy shall enter into force on the date this Executive Directive it is issued.

ANNEX A

Overview of SLA information available on dedicated SLA Internet websites

A great deal of information about SLA’s governance, programs and operations is available on the SLA website (www.sustainablelivingacademy.org) and on the individual websites of SLA affiliates and regional offices. A selected list of such information, including information that is progressively being made available, is set out below.

I. Information about SLA programs

1. The SLA Medium-Term Strategic Plan is available on the SLA website.
2. Program Documents. Program Documents are public documents of the SLA Executive Board and are available on the SLA website under ‘Programs’.
3. Regional Office, and Headquarters Divisional Annual Reports. Annual Reports prepared by SLA Regional Offices and Headquarters Divisions (where these are prepared), are being made available on SLA’s public websites.
4. Evaluation Reports. An overview of the SLA evaluation activities is prepared annually and presented to the SLA Executive Board. These reports are public documents of the SLA Executive Board and are available on the SLA website under ‘Executive Board documents’.

II. Information about SLA operations

1. SLA Executive Board. Information relating to the work of the SLA Executive Board and its meetings (including background documentation and decisions) is available on the SLA website under ‘Executive Board documents’.
2. SLA Executive Office. Statements and speeches by the Executive Director are available on the SLA website.
3. SLA Financial Information. All relevant documentation on the SLA budget as approved by the SLA Executive Board, including the financial report and audited financial statements, the annual review of the financial situation including source of funding, and the annual report of SLA’s Office of Internal Audit, are available on the SLA website under ‘Executive Board documents’.
4. SLA Procurement. SLA makes public (a) its major international procurement solicitation notices issued; and (b) its contracts awarded. These are made public at SLA Supply Division website. The SLA Supply Division website also provides annual procurement data by vendor, amount, type of services/goods, etc.
5. SLA Policies and Procedures. SLA’s policies and procedures are progressively being made available on the SLA website.