[Chapter-delegates] Follow-up on Chapters Advisory Council Meeting of 17 September 2024

Olivier MJ Crépin-Leblond ocl at gih.com
Tue Oct 15 02:56:36 PDT 2024


Dear Ilona,

thank you for your email dated 10 October 2024.

I am disappointed to note that you have still not provided a response 
with the information requested in my emails appended in the email thread 
below. You will note the extract below from my email dated 8 October 2024:

QUOTE:
"Responding to your note: "/All necessary legal documents, including 
agreements, have been put in place to respect the separate nature of the 
two organizations./

All I am asking is for them to be shared. If that is not possible, even 
in a redacted manner, for whatever reason, then please provide a list of 
the agreements to which you refer, including the date of the agreement, 
the name of the agreement, the signatory parties, and a brief 
description of each agreement."

I reiterate this request and would be grateful if you could provide the 
information requested without further delay.

I very much appreciate (and draw your attention to) the input and 
support for this information request from my fellow "Chapter Delegates".

As a reminder, in U.S. company law, a "supporting organisation" and a 
"merged organisation" are not legally the same.

I am pleased that we all appear to agree that the Internet Society 
Foundation is formally a "Section 509(a)(3) Supporting Organisation" 
under United States Non Profit Tax Law.
The information from the IRS links below provide helpful "Official 
Guidance":

https://www.irs.gov/charities-non-profits/section-509a3-supporting-organizations
https://www.irs.gov/charities-non-profits/charitable-organizations/supporting-organizations-requirements-and-types

I look forward to your prompt response.

Kindest regards,

Olivier Crépin-Leblond


On 10/10/2024 17:04, Ilona Levine wrote:
>
> Hi Olivier,
>
> Thank you for your follow up email. I think the use of the term 
> "outsourcing" in the email below might have caused some confusion.  
> You mentioned you are familiar with the “supporting organizations” and 
> how they operate, but it might also be helpful for me to provide 
> some additional background for others.
>
> As you know, the relationship between supporting and supported 
> organizations is not a vendor or contractor relationship. Though 
> the Foundation is a separate corporation, it is a controlled 
> subsidiary of ISOC, not a third-party service provider or outside 
> contractor.  So ISOC is not “outsourcing” to the Foundation but 
> instead, the two entities cooperate to achieve the mission of the 
> Internet Society.  In other words, as a supporting organization, the 
> Foundation’s purpose is to operate for the benefit of, and to support, 
> ISOC. In furtherance of that purpose, the Foundation conducts programs 
> and activities that benefit ISOC and furthers ISOC’s mission. For 
> example, the Foundation engages in communications activities at the 
> direction of and to the benefit of ISOC.
>
> As you also know based on your extensive experience with nonprofits, 
> the Internet Society Board develops the overall strategy for 
> ISOC. Internet Society management then develops its action plan and in 
> turn, works with the Foundation to ensure that it, as a 
> supporting organization, provides the support necessary to achieve 
> ISOC’s goals. The Foundation does that through its own action plan, 
> which sets out objectives for all of its functions, including 
> the communications function.  So the Board sets the strategy, Internet 
> Society management creates the action plans, and the Foundation 
> management allocates resources to support those plans as necessary.
>
> After the approval of the 2025 action plans, ISOC will share them with 
> the community.  As discussed earlier, part of that will be Chris 
> presenting to this community how the communications group will be 
> tackling its work in the upcoming year.
>
> Best regards,
>
> Ilona
>
> *From: *Olivier MJ Crépin-Leblond <ocl at gih.com>
> *Date: *Tuesday, October 8, 2024 at 8:47 AM
> *To: *Ilona Levine <levine at isoc.org>, Ted IETF <ted.ietf at gmail.com>
> *Cc: *Chapter Delegates <Chapter-delegates at elists.isoc.org>, Sally 
> Wentworth <wentworth at isoc.org>
> *Subject: *Re: Follow-up on Chapters Advisory Council Meeting of 17 
> September 2024
>
> Dear Ilona,
>
> Further to our discussion two weeks ago regarding the definition of 
> the relationship between the Internet Society and the Internet Society 
> Foundation, in the absence of your response, I wish to reiterate the 
> need for a clear outsourcing agreement between these entities. It is 
> recognised as good business practice internationally to establish such 
> agreements to delineate respective liabilities in the execution of 
> these contracts.
>
> Responding to your note: "/All necessary legal documents, including 
> agreements, have been put in place to respect the separate nature of 
> the two organizations./"
>
> All I am asking is for them to be shared. If that is not possible, 
> even in a redacted manner, for whatever reason, then please provide a 
> list of the agreements to which you refer, including the date of the 
> agreement, the name of the agreement, the signatory parties, and a 
> brief description of each agreement.
>
> Looking forward to your prompt response.
>
> Kindest regards,
>
> Olivier Crépin-Leblond
>
>
> On 24/09/2024 17:22, Olivier MJ Crépin-Leblond wrote:
>
>     Dear Ilona,
>
>     Many thanks for your follow-up.
>
>     The thread may not have come all through. During the Chapter
>     Advisory Council call, Ted mentioned the transfer of some
>     responsibilities in relation to Communications from the Internet
>     Society to the Internet Society Foundation. My initial question to
>     Ted was in regards to the outsourcing agreement as follows:
>
>     /"I was previously unaware of this change. Although the Internet
>     Society Foundation may have been designated by the Internet
>     Society as a "supporting organisation" of the Internet Society, it
>     remains a distinct and separate legal entity. Therefore, I assume
>     that any "outsourcing" of responsibilities such as Marketing
>     and/or Communications would be defined in a written "contract for
>     services" between the Parties setting out (inter-alia) the terms,
>     rights, and obligations of each Party. Could you please provide
>     the terms for such an agreement and any limitations therein?
>
>     My principal concern lies in distinguishing between executing the
>     Communications Plan and drafting the Communications Plan. These
>     are fundamentally different tasks and would undoubtedly be
>     included in the "contract for services""./
>
>     The top level responsibility of the strategy of the Internet
>     Society remains within the Internet Society. I find it surprising
>     that an outsourcing entity would be able to dictate that strategy
>     without it being agreed by the Internet Society itself.
>     The Internet Society has the opportunity to outsource the
>     execution of its Communications Plan to a supporting organisation
>     on the basis of terms and conditions agreed between the parties.
>     This requires outsourcing agreement(s) in order to know where the
>     boundaries and responsibilities are between the two organisations,
>     including their respective liabilities in the execution of these
>     agreement(s).
>
>     For example:
>
>
>           Key Components of an Outsourcing Communications Agreement
>
>      1. *Introduction and Definitions*:
>
>           * Clearly define the parties involved.
>           * Provide definitions for key terms used throughout the
>             agreement.
>
>      2. *Scope of Services*:
>
>           * Detail the specific services to be outsourced.
>           * Include service level agreements (SLAs) to set performance
>             standards.
>
>      3. *Term and Termination*:
>
>           * Specify the duration of the agreement.
>           * Outline conditions for termination by either party.
>
>      4. *Pricing and Payment Terms*:
>
>           * Define the pricing structure and payment schedule.
>           * Include any penalties for late payments or performance
>             failures.
>
>      5. *Confidentiality and Data Protection*:
>
>           * Ensure compliance with data protection laws.
>           * Include confidentiality clauses to protect sensitive
>             information.
>
>      6. *Intellectual Property Rights*:
>
>           * Clarify the ownership of any intellectual property created
>             during the agreement.
>
>      7. *Warranties and Liability*:
>
>           * Outline the warranties provided by the service provider.
>           * Define the liability limits for both parties.
>
>      8. *Monitoring and Reporting*:
>
>           * Establish how performance will be monitored and reported.
>           * Include provisions for regular review meetings.
>
>      9. *Dispute Resolution*:
>
>           * Specify the process for resolving disputes.
>           * Include mediation or arbitration clauses if applicable.
>
>     10. *Exit Management*:
>
>           * Plan for the transition of services back to the company or
>             to another provider.
>           * Include provisions for the transfer of data and assets.
>
>
>
>     I trust that you mentioned: "All necessary legal documents,
>     including agreements, have been put in place to respect the
>     separate nature of the two organizations."
>     Thus I would be interested in its details as explained in my email.
>
>     Kindest regards,
>
>     Olivier
>
>     On 23/09/2024 18:36, Ilona Levine wrote:
>
>         Dear Olivier,
>
>         I understand that the nature of your request is to assist the
>         Chapters Advisory Council and Chris Locke in preparation to
>         his session on the communication plan. The agreement in place
>         since 2018 between the Foundation and Internet Society focuses
>         on the legal obligations in line with the Foundation's role as
>         a 509(a)(3) and therefore, won’t be useful for that purpose.
>
>         Best regards,
>
>         Ilona
>
>         *From: *Olivier MJ Crépin-Leblond <ocl at gih.com>
>         <mailto:ocl at gih.com>
>         *Date: *Sunday, September 22, 2024 at 8:52 AM
>         *To: *Ilona Levine <levine at isoc.org> <mailto:levine at isoc.org>,
>         Ted IETF <ted.ietf at gmail.com> <mailto:ted.ietf at gmail.com>
>         *Cc: *Chapter Delegates <Chapter-delegates at elists.isoc.org>
>         <mailto:Chapter-delegates at elists.isoc.org>, Sally Wentworth
>         <wentworth at isoc.org> <mailto:wentworth at isoc.org>
>         *Subject: *Re: Follow-up on Chapters Advisory Council Meeting
>         of 17 September 2024
>
>         Dear Ilona,
>
>         thank you for clarifying that all necessary legal documents,
>         including agreements, have been duly executed to respect the
>         separate nature of the two organisations.
>
>         I am aware of the publication of the original IETF
>         Administration LLC agreements with the Internet Society,
>         specifically:
>         IETF-ISOC Funding Agreement (2020)
>         <https://www.ietf.org/media/documents/IETF_Funding_Agreement_-_Executed_-_20201123.pdf>
>         IETF-ISOC Funding Agreement Amendment (2020)
>         <https://www.ietf.org/media/documents/IETF_ISOC_Funding_Amendment_Amendment_-_20201222.pdf>
>         IETF-ISOC Funding Agreement Amended and Restated (2024)
>         <https://www.ietf.org/media/documents/ISOC-IETF_Amended_Funding_Agreement_-_20240103_-_Redacted_Executed.pdf>
>
>         These documents are accessible on the IETF Administration
>         LLC’s website at https://www.ietf.org/administration/overview/.
>
>         Could you kindly confirm whether the agreements between the
>         Foundation and the Internet Society are also publicly
>         available? I have been unable to locate them on either website.
>
>         I would appreciate it if you could provide a list of the
>         agreements to which you refer, including the date of the
>         agreement, the name of the agreement, the signatory parties,
>         and a brief description of each agreement.
>
>         I look forward to your kind response.
>
>         Kindest regards,
>
>         Olivier
>
>
>         On 20/09/2024 19:48, Ilona Levine wrote:
>
>             Hi Olivier, thank you for your follow up email.  You noted
>             that you are aware of the tax requirements that apply to
>             supporting organizations.  Mainly, those requirements
>             relate to supporting the mission of its supported
>             entities.  In this case, the Internet Society.
>
>             As part of that support, the Foundation provides grants to
>             other organizations that have missions consistent with the
>             Internet Society’s in order to fund programs that further
>             the Internet Society’s purposes. The Foundation also
>             engages in activities that support Internet Society
>             directly. For example, the Foundation engages in
>             fundraising and communication activities for the benefit
>             of the Internet Society.
>
>             As you also pointed out, the Foundation is a separate
>             legal entity.  It is a controlled subsidiary of Internet
>             Society.  All necessary legal documents, including
>             agreements, have been put in place to respect the separate
>             nature of the two organizations.
>
>             I trust this answers your question.
>
>             Best regards,
>
>             Ilona
>
>             *Ilona Levine,* SVP, General Counsel and Corporate Secretary
>
>             levine at isoc.org <mailto:levine at isoc.org>|
>             internetsociety.org | @internetsociety
>
>             Donate today. <https://bit.ly/3nUsQmJ>
>
>             *Help protect the Internet for everyone.*
>
>             https://backchannel.internetsociety.org/wp-content/uploads/2020/01/image001.png
>
>             This communication is the property of the Internet Society
>             and may contain confidential or privileged information. 
>             Unauthorized use of this communication is strictly
>             prohibited.  If you have received it in error, please
>             notify the sender by reply e-mail and destroy all copies
>             of the communication and any attachments.
>
>             *From: *Olivier MJ Crépin-Leblond <ocl at gih.com>
>             <mailto:ocl at gih.com>
>             *Date: *Friday, September 20, 2024 at 11:38 AM
>             *To: *Ted IETF <ted.ietf at gmail.com>
>             <mailto:ted.ietf at gmail.com>, Ilona Levine
>             <levine at isoc.org> <mailto:levine at isoc.org>
>             *Cc: *Chapter Delegates
>             <Chapter-delegates at elists.isoc.org>
>             <mailto:Chapter-delegates at elists.isoc.org>, Sally
>             Wentworth <wentworth at isoc.org> <mailto:wentworth at isoc.org>
>             *Subject: *Re: Follow-up on Chapters Advisory Council
>             Meeting of 17 September 2024
>
>             Dear Ted,
>
>             thank you for your follow-up on this matter. I am aware of
>             the special tax terms in relation to "supporting
>             organisations".
>
>             That being said, the Internet Society Foundation is a
>             distinct and separate legal entity to the Internet
>             Society, irrespective of the relationship between them. As
>             a result, any outsourcing task undertaken by one, for the
>             other entity, would be defined in a contract, whether
>             written, verbal or otherwise. If not, there is a lack of
>             clarity and expectations about the relationship, which
>             brings potential liability and risk that both entities are
>             subjected to, in relation to the other's actions. Any
>             lawyer would tell you that it is highly advisable to have
>             a written contract, if only for legal protection.
>
>             Thanks for letting me know that you are travelling. I am
>             copying President and CEO Sally Wentworth in case you're
>             unavailable for a length of time.
>
>             Kindest regards,
>
>             Olivier
>
>             On 20/09/2024 13:12, Ted Hardie wrote:
>
>                 Hi Olivier,
>
>                 A supporting organization is a term of art in US tax
>                 law, please see:
>
>                 https://www.irs.gov/charities-non-profits/charitable-organizations/supporting-organizations-requirements-and-types
>
>                 and
>
>                 https://www.irs.gov/charities-non-profits/section-509a3-supporting-organizations
>
>                 Explaining how the two relate is complicated enough
>                 that there are legal briefs on it; I have cc'ed the
>                 Society's chief counsel in case you would like that
>                 level of detail.  The summary, however, is that a
>                 supporting organization is a charity because it
>                 supports the charitable purpose of the main
>                 organization.  As a result, it can provide services to
>                 the main organization under the special tax rules
>                 noted above.
>
>                 Note that I am traveling and will generally be slow to
>                 respond for a few days, but hopefully the links above
>                 will get you started and Ilona can provide more
>                 detailed legal information as needed.
>
>                 regards,
>
>                 Ted Hardie
>
>                 On Fri, Sep 20, 2024 at 6:24 AM Olivier MJ
>                 Crépin-Leblond <ocl at gih.com> wrote:
>
>                     Dear Ted,
>
>
>                     During this week’s Chapters Advisory Council call,
>                     you mentioned that the Internet Society
>                     Foundation, as a "supporting organisation" of the
>                     Internet Society, is managing the communications
>                     department for the Internet Society.
>
>                     Upon seeking clarification, you explained that the
>                     Internet Society Foundation comprises two
>                     elements: one philanthropic (grant-making) and the
>                     other as a "supporting organisation" of the
>                     Internet Society. "This implies that many of the
>                     supporting functions for the Internet Society as a
>                     whole are now part of the Foundation, primarily
>                     because the Foundation can provide these services
>                     to the Internet Society at no cost".
>
>                     You further elaborated that this "arrangement"
>                     allows the Internet Society to allocate its budget
>                     more effectively.
>
>                     I was previously unaware of this change. Although
>                     the Internet Society Foundation may have been
>                     designated by the Internet Society as a
>                     "supporting organisation" of the Internet Society,
>                     it remains a distinct and separate legal entity.
>                     Therefore, I assume that any "outsourcing" of
>                     responsibilities such as Marketing and/or
>                     Communications would be defined in a written
>                     "contract for services" between the Parties
>                     setting out (inter-alia) the terms, rights, and
>                     obligations of each Party. Could you please
>                     provide the terms for such an agreement and any
>                     limitations therein?
>
>                     My principal concern lies in distinguishing
>                     between executing the Communications Plan and
>                     drafting the Communications Plan. These are
>                     fundamentally different tasks and would
>                     undoubtedly be included in the "contract for
>                     services".
>
>                     The "contract for services" (together with any
>                     relevant supporting information) will be helpful
>                     input for both the Chapters Advisory Council and
>                     also for Chris Locke and his Team (including for
>                     the current "branding" presentations) in
>                     preparation for the promised session from Chris
>                     Locke to the Chapters Advisory Council.
>
>                     I look forward to your response and to receiving a
>                     copy of the "contract for services" agreement,
>                     together with any relevant supporting information
>                     as requested above.
>
>                     Kindest regards,
>
>                     Olivier
>
>
>
>
>
>
>
>
>
>
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