On June 4, 2000, the National Board of Directors adopted the following:
Internet Sales: Sales on a Web site on the Internet* of any products sold in "council-sponsored product sales" such as Girl Scout cookies, candy, nuts, publications, and equipment, may only be conducted by duly authorized and licensed Girl Scout councils, council shops, retail agencies, and/or GSUSA licensed vendors. Permission to sell on the Internet must be obtained from GSUSA.
For safety and security reasons, sales on the Internet* for any Girl Scout "troop/group money earning activities" may not be conducted by individual girls, parents, or other adults.
*Sales on the Internet include on-line auctions, broadcast e-mail messages, and/or posting on individual Girl Scout troop/group or Girl Scout Web sites.
Rational: As we move into the future, GSUSAs' concern regarding "restraint of trade" issues and the integrity of Girl Scout council boundaries have not gone away. Those issues have, however, been superceded by this increase in sales activities on the Internet, bringing an increase concern for
1. The personal safety and security of girls
2. The potential for fraud inherent in the technology
3. The public's perception of the "commercialization" of the councils' cookie sales
4. The impact of our tax-exempt status
Safety: We must protect the identity of all our girl members. Because of the scope of the Internet, there is no way to control who sees the solicitation for cookie sales and therefore who can contact the girl. Since girls do not have secure means of contacting strangers and exchanging funds over the Internet, GSUSA considers these kinds of activities to be a significant safety risk to girls.
Fraud: The potential for fraud is inherent in the technology. There is no way to verify that the order for cookies goes to an actual Girl Scout…as anybody can set up a Web site and sell cookies. The public does not distinguish one Girl Scout council's sale from another, one case of fraud could have a ripple effect that impacts all of us in Girl Scouting.
Tax-exempt Status: Internal Revenue Service scrutiny of how local Girl Scout cookie sales are conducted is ever present. Selling on the Internet could easily be viewed as a commercial activity. We have been advised on numerous occasions to avoid any activity that could be construed as commercializing the cookie sale. If the IRS believes that the cookie sale is being carried on as a commercial activity, it could take the position that income from the cookie sale is unrelated to the mission of Girl Scouting and therefore revenue from it would be taxable.
Our collective challenge at this point in time is how to manage cookie sales and other money-earning activities in a manner that reduces risk to our girl members and to our volunteers, Girl Scout councils, and GSUSA. Having an official policy statement strengthens our position when trying to take action against unauthorized uses of the Girl Scout name.
The policy on Internet sales has been developed to protect our membership, limit the risk of fraud, and ensure that we can defend our tax-exempt status.
The primary purpose of selling Girl Scout cookies, or of any money-earning activity, is first and foremost to provide a valuable program experience for girls. Generating income for Girl Scout councils and troops/groups is its secondary purpose. This policy clearly supports the primary purpose of these activities and will support the mission of Girl Scouting.
Please send any questions or comments to Carol McPhillips [greenhls@mwci.net].
