The Period Pantry.

1. Purpose

The Period Pantry (“Organization”) is recognized as a tax-exempt organization under Section 501(c)(3) of the Internal Revenue Code. Federal law absolutely prohibits the Organization from directly or indirectly participating in, or intervening in, any political campaign on behalf of, or in opposition to, any candidate for public office. This Political Activity Restriction Policy establishes clear standards for the Organization and the people who represent it, protects the Organization’s tax-exempt status, and ensures that its charitable resources and communications remain focused on its mission.

The Organization may educate the public and advocate on issues related to its charitable purpose, but it must remain nonpartisan. No action, communication, expenditure, endorsement, or use of Organization resources may be made in a way that causes the Organization to support or oppose a candidate or political party.

2. Scope

This policy applies to all political activity undertaken in connection with the Organization, and to all individuals acting for, representing, or using the resources of the Organization, including:

• the Board of Directors and board officers;
• employees, officers, and paid staff;
• volunteers and event volunteers;
• interns and student ambassadors;
• committee members and task-force members;
• independent contractors, consultants, and professional advisors;
• agents, representatives, and spokespersons;
• program participants or other individuals when acting on behalf of or representing the Organization; and
• any other person who uses Organization funds, facilities, equipment, accounts, name, logo, mailing lists, or other resources.

This policy applies whether activity takes place in person, by telephone, in writing, through email, on a website, on social media, at an event, or through any other communication channel.

3. Prohibited Organizational Political Activity

The Organization, and no person acting in an official capacity for the Organization, may:

1. endorse, oppose, support, or criticize a candidate for public office;
2. make or publish a statement, including a statement made through social media, that favors or disfavors a candidate or political party;
3. make contributions, donations, loans, grants, or other payments of money or property to, or for the benefit of, a candidate, political party, political action committee, or campaign;
4. solicit, receive, or direct contributions for a candidate, political party, political action committee, or campaign;
5. allow the Organization’s name, logo, letterhead, website, email accounts, mailing lists, facilities, equipment, staff time, funds, or other resources to be used for a political campaign or partisan political activity;
6. rate, rank, compare, or otherwise evaluate candidates in a manner that communicates approval or disapproval;
7. distribute campaign literature, candidate questionnaires, partisan voting guides, or other campaign materials;
8. invite or provide a platform to a candidate in a manner that favors or disfavors any candidate or political party;
9. pay for, reimburse, or provide in-kind support for political campaign activity;
10. coordinate Organization activities or communications with a candidate, campaign, political party, or political committee; or
11. use Organization events, programs, or communications to encourage or discourage voting for or against any candidate or political party.

These restrictions apply regardless of whether the activity occurs during or outside normal working hours and regardless of whether an individual is compensated by the Organization.

4. Political Parties and Campaign Materials

The Organization must remain independent of political parties and candidate campaigns. Accordingly:

• Organization communications, publications, websites, social media accounts, and events must not identify the Organization with a political party or campaign.
• Campaign signs, buttons, banners, flyers, stickers, apparel, and other partisan campaign materials may not be displayed, distributed, or worn while an individual is acting on behalf of the Organization or while using Organization facilities or resources.
• Organization mailing lists, email lists, databases, contact information, and social media audiences may not be shared with or used for a candidate, campaign, political party, or political committee.
• The Organization may not link to a candidate’s campaign website, solicit campaign volunteers, or promote a campaign through an Organization-controlled channel.
• Nonpartisan voter registration, voter education, and get-out-the-vote activities may be conducted only when approved in advance and designed and administered without favoring or opposing a candidate or political party.
• Questions about whether a proposed item, event, or communication is partisan must be referred to the Executive Director or Board of Directors before it is distributed or used.

5. Nonpartisan Issue Advocacy

The Organization may engage in nonpartisan education and advocacy about public issues related to its charitable mission, including menstrual equity, access to menstrual products, and period poverty. Issue advocacy must be presented in a neutral manner and may not express support for or opposition to a candidate or political party.

When discussing an issue, the Organization may state its position, provide educational information, describe the impact of proposed legislation or public policy, and ask the public to contact policymakers about pending legislation. Communications must not identify a candidate’s position for the purpose of supporting or opposing that candidate, compare candidates, or include an explicit or implicit call to vote for or against a candidate.

6. Lobbying and Legislative Advocacy

Lobbying is different from prohibited campaign intervention. The Organization may engage in a limited amount of lobbying that furthers its charitable purpose, subject to applicable federal and Maryland law, its budget, and Board oversight.

For purposes of this policy, lobbying generally includes communicating with legislators or their staff about specific legislation, or asking the public to contact legislators about specific legislation. The Organization will monitor its lobbying activities and expenditures and will comply with the applicable limitations under Section 501(c)(3) of the Internal Revenue Code. If the Organization elects the expenditure test under Section 501(h), lobbying must be tracked and reported in accordance with the Section 501(h) rules and applicable Form 990 reporting requirements.

Lobbying must be authorized by the Executive Director or Board of Directors. No lobbying activity may be conducted with restricted funds or other resources when the applicable funding terms prohibit it. Nothing in this section permits campaign intervention or any other activity prohibited by Section 3 of this policy.

7. Personal Political Activity

Individuals covered by this policy retain their rights as private citizens to participate in lawful political activity on their own time and with their own resources. An individual may vote, join a political party, support a candidate, attend a campaign event, make a personal contribution, volunteer for a campaign, or express a personal political opinion.

When engaging in personal political activity, individuals must make clear that they are acting personally and not on behalf of the Organization. They may not use Organization time, funds, equipment, facilities, email accounts, mailing lists, title, logo, name, or other resources, and they may not pressure another person to support a candidate or political party because of an Organization role.

8. Personal Social Media Activity

Individuals may use personal social media accounts to engage in lawful political activity, provided that the activity is personal, uses personal time and resources, and does not imply that the individual is speaking for The Period Pantry. Individuals should not use the Organization’s name, logo, photographs, branded materials, or official account credentials in personal political posts.

When there is a reasonable possibility that a personal post could be mistaken for an Organization statement, the individual must include the following disclaimer:

“The views expressed are my own and do not represent the views of The Period Pantry.”

A disclaimer does not cure the use of Organization resources or an otherwise prohibited endorsement. Individuals must also follow the Organization’s separate Social Media Policy, confidentiality requirements, and rules protecting the privacy of the people the Organization serves.

9. Use of Organizational Titles and Identification

An individual may identify their position or affiliation with The Period Pantry in a biographical description, resume, speaker introduction, or similar factual context. An Organization title or affiliation must not be used to endorse, oppose, or lend the appearance of Organization support to a candidate, political party, campaign, or political committee.

Individuals speaking or writing about political matters in a personal capacity must clearly identify themselves as speaking personally. The Organization’s name, logo, letterhead, official email signature, business cards, photographs taken for official use, and other identifying materials may not be used to promote personal political activity.

10. Candidates, Political Campaigns, and Organizational Facilities

A candidate or campaign may appear at an Organization event or use an Organization facility only when the Executive Director or Board of Directors has determined in advance that the activity is permissible and nonpartisan. Any appearance or use must satisfy all of the following conditions:

1. The candidate is invited to participate only for a legitimate non-campaign purpose, such as a public forum or educational program related to the Organization’s charitable mission.
2. All legally qualified candidates for the same office are given an equal opportunity to participate, or the event is conducted without identifying or promoting any candidate.
3. No candidate may be selected, excluded, or featured based on the Organization’s preference for or opposition to the candidate.
4. The event’s format, questions, moderator, publicity, and communications are neutral and do not express or imply support for or opposition to a candidate.
5. No fundraising appeal, campaign contribution request, campaign literature, campaign signage, campaign merchandise, or other campaign activity occurs at or through the event.
6. Any use of Organization facilities or resources is provided on a nonpartisan, reasonable, and consistent basis, and any applicable cost is paid at fair market value.

No candidate, campaign, or political party may use the Organization’s mailing address, telephone number, website, email account, staff assistance, or other resources for campaign purposes.

11. Organizational Statements and Media Communications

Only the Executive Director, Board Chair, or another person expressly authorized by the Board of Directors may issue an official statement on behalf of The Period Pantry. Before publication, official statements concerning candidates, elections, political parties, or legislation must be reviewed for compliance with this policy.

Employees, volunteers, interns, student ambassadors, board members, and other representatives must direct media inquiries about political matters to the Executive Director or designated spokesperson. No one may represent a personal political statement as the position of the Organization or use an Organization title to imply an official endorsement.

12. Reporting Questions or Concerns

Anyone who has a question about this policy or who observes possible political activity by or on behalf of the Organization should promptly contact the Executive Director or Board Chair. A concern may be raised verbally or in writing and should include the date, people involved, communication or activity at issue, and any available documentation.

The Organization will review good-faith questions and reports promptly and will take reasonable steps to protect confidentiality. No person will be retaliated against for raising a concern in good faith, asking for guidance, or participating in a review.

13. Violations

Violations of this policy may expose the Organization and the individuals involved to serious legal, financial, employment, governance, and reputational consequences, including excise taxes or loss of tax-exempt status. The Organization will respond to violations based on the nature and severity of the conduct.

Corrective action may include removal or correction of a communication, repayment or restoration of misused resources, additional training, loss of authorization to speak for the Organization, removal from an event or role, discipline up to and including termination of employment or volunteer service, removal from a board or committee position, and referral to legal counsel or appropriate authorities when necessary. The Organization will document material violations and corrective action.

14. Policy Administration and Review

The Board of Directors is responsible for adopting and overseeing this policy. The Executive Director is responsible for day-to-day administration, providing guidance, maintaining records of approved political and legislative activity, and coordinating review with legal or tax counsel when appropriate.

This policy will be reviewed at least annually and whenever there is a material change in applicable law, the Organization’s activities, or its governance structure. Amendments require approval by the Board of Directors. If any provision conflicts with applicable law, the law controls and the remaining provisions continue in effect.

15. Acknowledgment

I acknowledge that I have read, understood, and agree to comply with The Period Pantry’s Political Activity Restriction Policy. I understand that I am responsible for asking questions before engaging in activity that may implicate this policy and for promptly reporting suspected violations.