GREAT WALL/CAN HAGUE POLICIES & PROCEDURES

MANUAL

2012

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TABLE OF CONTENTS

Donations Policy ......................................................................................................................... - 3 - Compensation Policy .................................................................................................................. - 4 - Ethical Practice Policy ................................................................................................................ - 5 - Prohibition Against Child Buying Policy ................................................................................... - 7 - Social Service Employee Training Policy .................................................................................. - 7 - Continuing Education Policy .................................................................................................... - 10 - Policy prohibiting preferential treatment .................................................................................. - 12 - Policy for use of fees for special services ................................................................................. - 12 - Waivers of Liability .................................................................................................................. - 12 - Policy for Charging Additional Expenses ................................................................................. - 17 - Refund Policy............................................................................................................................ - 17 - Grievance Policy and Procedure ............................................................................................... - 18 - Policy for Disclosing Information ............................................................................................ - 18 - Policy for Acting as Primary Provider ...................................................................................... - 21 - Policy for Withdrawing or Declining a Referral ....................................................................... - 25 - Disruption Policy ...................................................................................................................... - 25 - Dissolution Policy ..................................................................................................................... - 30 - Policy for Returning a Child to Country of Origin ................................................................... - 31 - Policy for informing Central Authority and Secretary about the Adoption Process ................ - 32 - Policy for Returning the Home Study ....................................................................................... - 32 -

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Licensing and Corporate Governance (96.30) Great Wall China Adoption dba Children of all Nations is a non-profit, Hague Accredited, Licensed Child Placing Agency in the state of Texas and Florida. Great Wall/CAN follows all applicable state and regulatory requirements in all jurisdictions where services are rendered.

Corporate Structure (96.31) Great Wall China Adoption dba Children of all Nations is a qualified nonprofit 501 (c) (3) per the Internal Revenue Code.

Internal Structure and Oversight (96.32)

Great Wall China Adoption dba Children of All Nations has a President/CEO who is qualified by education, adoption service, experience, and management credentials to ensure effective use of resources and responsibility for management and oversight of the staff and any exempt or supervised provider in carrying out the adoption-related functions of GREAT WALL/CAN. Great Wall China Adoption dba Children of All Nations has a board of directors that establishes and approves its mission, policies, budget and programs; provides leadership to secure the resources needed to support its programs; includes one or more individuals with experience in adoption, including but not limited to, adoptees, birth parents, PAP(s), and adoptive parents; and appoints and oversees the performance of its President. Great Wall China Adoption dba Children of All Nations has a very committed board of directors providing leadership and direction for the agency by establishing and approving its missions, policies, budget, and programs. The Board members provide oversight of GREAT WALL/CAN's President, Snow Wu, with guidance on staff management, service delivery, and program development. Great Wall China Adoption dba Children of All Nations keeps permanent records of Board meetings and deliberations, including any major decisions affecting the delivery of adoptions services.

Donations Policy (96.33) (f) Great Wall CAN China Adoption dba Children of All Nations is a not-for-profit, 501 (c) 3 organization. It accepts donations from the public for its Charity Mission programs.

Great Wall China Adoption dba Children of All Nations as an organization, its board m embers, officers, an d em ployees are strictly prohibite d from accepting any donation fo r the pu rpose of influencing a child placem ent decision. GREAT WALL/CAN certifies that child placem ent decisions will never be influenced by any donation fro m anyone . If som eone is found to have violated this policy, the person will be terminated immediately. Safeguards are in place to ensure that donations do not influence child placement decisions:

Employees responsible for answering inquiries and handling donations are trained on GREAT WALL/CAN donation p olicy - charitab le donations do not influence any child placem ent

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decisions. T hey are ready to answer questions and inform the potential donors if such an issue arises.

GREAT WALL/CAN does not accept any donation if the donor expresses that he/she intends to influence GREAT WALL/CAN’s child placing decisions with the donation.

Upon receipt of donation $1,000 or higher, GREAT WALL/CAN ’s President is notif ied and informed for Quality Assurance purposes.

All child-placing employees are trained on this policy in order to prevent decision-m aking which is influenced by a donation.

Great Wall/CAN certifies that ch ild placement decisions will never be in fluenced by any donatio n. If someone is found to have violated this policy, the person will be terminated immediately.

Compensation Policy (96.34)

Great Wa ll China Ado ption dba Children o f All Nation s does not provide incentive fees or compensation for any child placed for adoptio n or on a sim ilar contingent fee basis. GREAT WALL/CAN shall provide appropriate com pensation to em ployees and supervised providers providing inter-country adopti on services as m ay be dete rmined by the Board and/or President/CEO from time to time in a manner consistent with GREAT WALL/CAN’s not-for-profit status and an “accredited agency” under the IAA and Regulations.

Great Wall China Adoption dba Children of All Nations em ployees are salaried em ployees. Employees’ salary is determined based on education level, work experience, knowledge and skills, workload, licensure, and market-competitiveness. Employee will never be paid an incentive fee or contingent fee for locating or placing a child for adoption.

GREAT WALL/CAN will review the perform ance of e mployees on an annual or qu arterly bas is with an evaluation of performance against stated, and mutually agreed upon goals. Based upon the results of this evaluation of pe rformance, e mployees will be c onsidered for m erit increas es o r bonus. Promotional increases will typically be given to em ployees whose work efforts and contributions to business objectives warrant an e xpanded role in their job duties or organizational responsibilities. It is not the intention of GREAT WALL/CA N to issue "Cost of Living" or other such entitlement increases on any periodic basis.

Compensation for staff members will be the responsibility of the President/CEO with the exception of the President/CEO's compensation, which will be the responsibility of the Board of Directors. If the President/CEO of GREAT WALL/CAN deems it necessary, interim equity adjustments may be made to reflect changes in market conditions so as to en sure the retention of and ability to a ttract key talent.

Great Wall China Adoption dba Children of All Nations has a Board of Direct ors that consists of volunteers whose service as Board members are not compensated.

For each S upervised and Exem pt Provide r that works in collabo ration with Great Wall China Adoption dba Children of All Nations , there is a Provider Agreem ent in place tha t outlines th e compensation by using a breakdown of fees for servic es for that Supervised or Exempt Provider.

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At this time, GREAT WALL/CAN does not collaborate with Foreign Supervised Providers; however, in the event that we do in the future, our Foreign Supervised Provider Agreem ent also provides an outline for compensation using a breakdown of fees for services.

Fees, wages, or salaries paid to the directors, officers, em ployees, and supervised, foreign and exempt providers of Great Wall China Adoption dba Children of All Nations are not unreasonably high in rela tion to th e servic es a ctually re ndered, taking into account the location, num ber and qualifications of staff; workload requirements; budget; size and non-profit status of the agency.

No payments, promises of paym ent or other consid eration are given to any individual directly or indirectly involved in the provision of adop tion services in a pa rticular case through Great Wall China Adoption dba Children of All Nations , except for salaries or fees for services actu ally rendered and reimbursement for costs incurred.

GREAT WALL/CAN has not made in-kind or other donations to agencies or individuals directly or indirectly involved in the provision of adoption services. Should GREAT WALL/CAN make in-kind or other donations to agen cies or individuals dire ctly or in directly inv olved in the provis ion o f adoption service in the f uture, GREAT WALL/CAN shall keep records of all such in -kind or o ther donations.

Ethical Practice Policy (96.35)

Great Wall China Adop tion dba Children of All Nations (GREAT WALL/CAN) provides adoption services ethically and in the best interests of children while preventing the abduction, exploitation, sale or trafficking of children. GREAT WALL/CAN has policies and procedures in place to ensure all parties are acting in accordance with local, state, natio nal and in ternational regulations. Each employee and supervised provider provides a signed statement and/or acknowledgement that they will not and have not participated in the trafficking, exploitation or abduction of children. Key Ethical Practices: Fees and Services Great Wa ll China Adoption dba Children of All Nation s outlines all f ees and ser vices prov ided to Prospective Adoptive Parents prior to beginning the adoption proces s. The fees and services are outlined in the Great Wall China A doption dba Children of All Nations client service agreem ent and information packet GREAT WALL/CAN provides to the Prospective Adoptive Parents upon initial inquiry, general inform ation is al so available to the pub lic on our website. W ith such transparency, Great Wall China Adoption dba Children of All Nations is ab le to provide f amilies with grea t assurance that their ado ption is predictab le and ethical. Great Wall China Adoption dba Children of All Nations works to ensure fam ilies adoptio n costs st ay within th e param eters of the service agreement and fees listed in our inform ation packet. In the event that an extra se rvice is needed , the Prospective Adoptive Parents are made fully aware of the costs of said service as GREAT WALL/CAN provides th e infor mation in writing to the Prospectiv e Adoptive Paren t. The Prospectiv e Adoptive Parents’ prior approval for the extra service fees is obtained by having them sign either another

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contract or sign an authorization form before it is charged. The family will be presented with a detailed account statement upon request.

Compensation Great Wall China Adoption dba Children of A ll Nations has a Board of Directo rs that consists of volunteers whose only compensation is the reimbursement of meeting or travel expenses for company business. For each Foreign, Supervised and Exempt Provider that works in collaboration with Great Wall China Adoption dba Children of All Nations, there is a Provid er Agreem ent in place that outlin es th e compensation by using a breakdown of fees for serv ices for that Foreign, Supervised or Exem pt Provider. Employees of Great Wall China A doption dba Children of All Nations are salaried; their salaries are not contingent on their ability to place children.

Donations Great Wall China Adoption dba Children of All Nations as an organization, its board m embers, officers, an d em ployees are strictly prohibite d from accepting any donation fo r the pu rpose of influencing a child placem ent decision. GREAT WALL/CAN certifies that child placem ent decisions will never be influenced by any donation fro m anyone . If som eone is found to have violated this policy, the person will be terminated immediately. Safeguards are in place to ensure that donations do not influence child placement decisions:

Employees responsible for answering inquiries and handling donations are trained on GREAT WALL/CAN donation p olicy - charitab le donations do not influence any child placem ent decisions. T hey are ready to answer questions and inform the potential donors if such an issue arises.

GREAT WALL/CAN does not accept any donation if the donor expresses that he/she intends to influence GREAT WALL/CAN’s child placing decisions with the donation.

Upon receipt of donation $1,000 or higher, GREAT WALL/CAN ’s President is notif ied and informed for Quality Assurance purposes.

All child-placing employees are trained on this policy in order to prevent decision-m aking which is influenced by a donation.

Prohibition on Child-Buying Each em ployee, coun try rep resentative, and sup ervised provider provides a signed statem ent and/or acknowledgement that they will n ot and have not pa rticipated in th e traffickin g, exploitation or abduction of children. Any e mployee or supervised provider who commits such an infraction will be terminated immediately. Where appropriate, such an infraction from this policy shall be reported to the proper authorities, which m ay include, but not be limited to local, state licensin g, police, Federa l Bureau of Investigations, Council on Accreditation, Department of Homeland Security, Department of State, and /or Citiz enship and Imm igration Ser vices and the Foreign G overnment/Foreign Ce ntral Authority.

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Employee Training Great Wall China Adoption dba Children of A ll Nations also ensures that its em ployees are w ell-trained and have an underst anding of the ethical issues involved in international adoption. This is a part of the initial training or ientation, ongoing training as we ll as the Em ployee Manual. All employees that provide social services are properly qualified with either Bachelors or Masters Degree in a social science and / or p revious experien ce in adoption services or in fam ily and children’s services. A well qualified and traine d staff ens ures that ou r clients are provided with professional, ethical service in the best interests of children. Each employee is required to sign an agreement that he/she will abide by Ethical Practices outlined in Chapter 4 of GREAT WALL/CAN Employee Manual upon hire. Adherence to State, Federal and International Rules and Regulations Great Wall China Adoption dba Children of All Nations is a non-profit 501(c) 3 agency and adheres to all s tate and f ederal as well as intern ational guide lines. Intern ational Adoptio ns are f acilitated through the Foreign Governm ent/Foreign Central Authority. Each Foreign Governm ent/Foreign Central Authority has rules and reg ulations in place to assu re that adoptions are completed according to strict ethical guidelines. Children must be legally defined as orphans according to the country’s law to be placed for adoption. The Foreign Govern ment/Foreign Central Authority m ust provide documentation regarding the parental relinquishm ent or abandonment of a child as legal evidence that the child was not obtained through e xploitation, abduction or other il legal child trafficking m ethods. GREAT WALL/CAN does not offer gifts or money in exchange for child placements.

Prohibition against Child Buying Policy (96.36) Great Wall China Adoption dba Children of All Nations strictly prohibits its employees and ag ents from giving m oney or other consideration, directly or indirectly, to a child' s parent(s), other individual(s), or an enti ty as payment for the ch ild or as an inducement to release th e child. If permitted or required b y the child' s country of origin, an agency or person m ay rem it reasonable payments for activities related to the adoption proceed ings, pre-birth and birth medical costs, the care of the child, the care of the birth m other while pregnant and immediately following birth of the child, or the provision of child welfare and child prot ection services generally. Perm itted or required contributions shall not be remitted as payment for the child or as an inducement to release the child. Any employee that is found to have offered m oney or other consideration, direct ly or indirectly, to a child’s parents or othe r individua ls or an entity as paym ent for a child or to re lease a child will be terminated immediately. This policy is strictly enforced. Reporting Suspected Violations Any allegation of violation of the Great Wall China Adoption dba Children of All Nation’s ethical practice policies and the basis for the allegation shall be communicated , confidentially and in writing, to an adm inistrator in th e supervisory line of the alleged violator. Measures shall be taken to ensure that no adverse action is taken, either directly or indirectly, against a com plainant who m akes allegations in good faith.

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In order to fully adhere to our Policy Prohibiting Paym ent for a Chil d or As Inducem ent to Release, Great Wall China Adoption dba Children of All Nations has implemented the following procedures: The fees of GREAT W ALL/CAN a nd any Supervised, Foreign or Exempt provider are clearly and overtly delineated and accounted f or as evidenced by fee disclosures, invoices, and receipts provided to the PAP(s) upon request. Through this transparency, GREAT WALL/CAN , the Central Authority, COA and PAP(s) are able to assess the appropriateness of each line item which makes up the total fee. GREAT WALL/CAN has inform ation through the Central Authority o f each Convention cou ntry in which GREAT WALL/CAN currently works with regard ing the f ees permitted and/or required in that Convention country, who is allowed to receive fees or donations, and what range of fees is reasonable in the Convention country. For Board Members : Each board m ember has reviewed a nd has docum ented their approval of the policy Prohibiting Payment for a Child or As Inducem ent to Release. This policy is also provid ed in GREAT WALL/CAN’s Board of Directors Manual. In order to prevent any conf lict of inte rest, members of the Board of Dir ectors are prohibited from having a direct or indirect financia l interest in the assets, leases, business transactions, or professional services of the organization. For Employees: All GREAT WALL/CAN employees are trained on th is policy through our Employee Training Program . Employees are also provided this policy through our GREAT WALL/CAN Employee Manual. All GREAT WALL/CAN employees must also sign a statement that they h ave read and understand this policy. This statement is kept in their employee file. For Supervised Providers : GREAT WALL/CAN’s Supervised Pro vider Agree ments reflects the following information with regard to GREAT WALL/CAN’s Policy Prohibiting Payment for a Child or As Inducement to Release:

SUPERVISED PROVIDER fully com plies with the provisions of Section 96.36 (a) and 96.36 (b), a copy of which is attached as part of Attachment A and in corporated herein by this reference, and has enacted and activ ely enforces written policies and procedures that prohibit SUPERVISED PROVIDER e mployees and agents from giving m oney or other consideration as payment for a child. SUPERVISED PROVI DER does not engage in practices conflicting with T he Hague Convention’s principles of furt hering the best interests of ch ildren and preventing the sale, abduction, exploitation, or trafficking of children. SUPERVISED PROVI DER fully com plies with the provisions of Section 96.34, a copy of which is attached as part of Attachment A , and ensures that all com pensation and paym ents made by SUPERVISED PROVIDER related to adoption services ar e lawful under that section and all other applicable law, are for services rendered and not on a contingent fee basis, and are reasonable under the circumstances.

All Supervised Providers must verify their agreement to this policy by signing the Supervised Provider Agreement provided to them by Great Wall China Adoption dba Children of All Nations.

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For Foreign Supervised Providers : GREAT WALL/CAN’s Foreign Supervised Provider Agreem ent reflects the following information with regard to GREAT WALL/CAN’s policy prohibiting payment for a Child or as inducement to release:

The Foreign Supervised Provider prohibits its employees and ag encies from giving money, or other consideration, directly or indirectly, to a child’s parent(s), other individual(s) or an entity as payment for the child or as an inducement to release the child. If perm itted by th e f oreign coun try’s ru les, the Foreign Supervised Provider ma y r emit reasonable paym ents for activities related to the adoptio n proceedin gs, pre-birth and birth medical cos ts, th e care of the child, th e ca re of the b irth m other while p regnant and immediately following birth of the child, or the provision of child welfare and child protection services gen erally, prov ided, however, tha t per mitted or re quired con tributions sha ll not be remitted as payment for the child or as an inducement to release the child. The Foreign Supervised Provider will reinforce the prohibitions discussed herein in em ployee training programs.

All Foreign Supervised Providers must verify th eir agreement to this policy by s igning the F oreign Supervised Provider Agreement provided to them by Great Wall China Adoption dba Children of All Nations. Charitable Donations : Great Wall China Adoption dba C hildren of A ll Nations accepts donations from the public for its Charity Mission program s. Upon receipt of any dona tion, a charitable donation receipt for tax purposes will be sent to the pers on or persons making the donation, up on request. This letter is to be signed by Great Wall China Adoption dba Children of All Nation’s Acco unting Assistant. GREAT WALL/CAN’s Donations P olicy reflects that donations to Great Wall China Adoption dba Children of All Nations do not influence child placement decisions in any way; all decisions in relation to child placem ent are m ade wholly by the Forei gn Government/Foreign Cent ral Authority a nd that GREAT WALL/CAN has no control over this decision making process. If the donor designates the dona tion to be used for a GREAT WALL/CAN Charity Mission P rogram, the donation will be entered into Fam ily Builder, GREAT WALL/CANs adoption software with the donor’s name, donation amount and Charity Mission Program selected. If the donor does not designate a specific program, the donation usage will be determined by GREAT WALL/CAN. To have safeguards in place to en sure the do nations do not influence child p lacement decisions , GREAT WALL/CAN will do the following:

Employees responsible for answering inquiri es and handling donations are trained on GREAT WALL/CAN donation policy - charitable dona tions do not influence any child placement decis ions. They will be ready to ans wer questions and inform the potentia l donors if such an issue arises.

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GREAT WALL/CAN does not accept any donation if the donor expresses that he/she intends to influence GREAT WALL/CAN’s child placing decisions with the donation.

Upon receip t of donatio n $1,000 or higher, GREAT WALL/CAN’s President m ust be notified.

All ch ild-placing em ployees are trained on this po licy in orde r to p revent dec ision-making which is influenced by a donation.

GREAT WALL/CAN provides all f amilies with an invo ice for payments received noting the services provided upon request.

GREAT WALL/CAN again certifies that child placem ent decis ions will never b e influenced b y any donation from anybody. If someone is found to have violated this policy, the person will be terminated immediately. GREAT WALL/CAN will imm ediately notify the appropr iate au thorities if there is r eason to b elieve that any child is being abused, neglected, expl oited, sold, abducted or trafficked. Appropriate authorities m ay include, State Chil d Protectiv e Services, local o r st ate police, Federal Burea u of Investigations, Departm ent of Ho meland Security, Departm ent of State, and/o r Citizensh ip and Immigration Services. Upon m aking such a notification, GREAT WALL/CAN will of ficially suspend all interaction with the agency or individual who is under inv estigation. The suspension will continue until the concerns have been cleared by the appropriate authorities.

Social Service Employee Training Policy (96.37) Great Wall China Adoption dba Children of All Nations provides all newly hired em ployees who provide ado ption-related social services that inv olve the ap plication of clini cal skills and judgm ent (home studies, child background studies, counseling se rvices, parents preparation, post adoption and other sim ilar serv ices) with a com prehensive So cial Serv ice Em ployee Or ientation and Training Program, that includes training on: 1) The requi rements of the Convention, the IAA, and other applicable Federal regulations; 2) The INA regulations applicable to the immigration of children from a Convention Country; 3) Th e adoption laws of any Convention country where GREAT WALL/CAN provides adoption services; 4) Relevant State Laws; 5) Ethical considerations in inter-country adoption and prohibitions on child-buying; 6) GREAT WALL/CAN’s goals, ethical policies and professional guidelines, organization al lines of accountability, polices, and procedures; and 7) The cultural diversity of the populations served by GREAT WALL/CAN. Great Wall China Adoption dba Children of All Nations provides all newly hired or current employees who provide adoption-related social services that involve the appl ication of clinical skills and judgment (hom e studies, child background studies, c ounseling services, parent preparation, post adoption and other sim ilar services) with a compre hensive Social Serv ice Employee Orientation and Training Program . This includes trai ning on: 1) The factors in the c ountry of origin that lead to children nee ding adoptive f amilies; 2) Feelings of separation and grief and loss ex perienced by the child with r espect to th e f amily of origin; 3) Attachment and post-traum atic stress disorders; 4) Psychological issues facing children who have experienced abuse or neglect and/or whose parents’ rights have been terminated because of abuse or neglect; 5) The impact of institutionalization on child development; 6) Outcom es for ch ildren placed for adoption intern ationally and the benefits of permanent family placements over other forms of government care; 7) The most frequent medical and psychological problem s experienced by children from the country of origin served by GREAT

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WALL/CAN; 8) The process of developing em otional ties to an adoptive fa mily; 9) Acculturation and assimilation issues invo lving those arising from factors such as r ace, ethnicity, religion, and cultu re and the impact of having been adopted internationally; and 10) Child, adolescent and adult development affected by adoption. All Great Wall China Adoption dba Children of All Nations employees who provide adoption-related social services that inv olve the ap plication of clinical sk ills and jud gment (hom e studies, child background studies, counseling services, parents preparation, post adoption and other similar services) are required to receive, in addition to an orientation and initial trai ning, no less than thirty (30) hour s of training every two years on current and em erging adoption practice is sues through participation in seminars, conferences, distance lear ning courses, and other sim ilar programs. In addition, all Texas social service employees will receive 30 hours traini ng the first year, and 20 hours annually th ereafter to meet Texas licensing requirem ents. All F lorida social service employees will re ceive 15 hours of orientation, and 15 hours annually thereafter to m eet Florida state licensing requirem ents. GREAT WALL/CAN will combine both Hague and state licens ing required training hours to m eet both Hague and state licensing training requirements. Great Wall China Adoption dba Children of All Nations strongly believes that all newly hired and current adoption services related employees that involve the application of clinical skills and judgment (home studies, child background studies, counseling services, parent prepar ation, post adoption and other similar services) must com plete the or ientation and initial training regardless of past experience in intercountry adoption. However, e mployees may be exempt from elements of the orientation and training only if the em ployee has demonstrated experience with in tercountry adoption and knowledge of the Convention and IAA along with the approval of the President of the agency.

Continuing Education Policy

All Great Wall China Adoption dba Children of All Nations employees who provide adoption-related social services that inv olve the ap plication of clinical sk ills and jud gment (hom e studies, child background studies, counseling services, parents preparation, post adoption and other similar services) are required to receive, in addition to an orientation and initial trai ning, no less than thirty (30) hour s of training every two years on current and em erging adoption practice is sues through participation in seminars, conferences, distance lear ning courses, and other sim ilar programs. In addition, all Texas social service employees will receive 30 hours traini ng the first year, and 20 hours annually th ereafter to meet Texas licensing requirem ents. All F lorida social service employees will re ceive 15 hours of orientation, and 15 hours annually thereafter to m eet Florida state licensing requirem ents. GREAT WALL/CAN will combine both Hague and state licens ing required training hours to m eet both Hague and state licensing training requirements. Employee training hours and course com pletion information is docum ented in the employee file and monitored in the employee training spreadsheet. An employee is provided with training opportunities throughout each year and em ployee’s supervis or will no tify each em ployee on an annual bas is the amount of hours required to complete within that year.

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Policy prohibiting preferential treatment (96.39 ©)

It is the policy of Great Wall China Adoption dba Children of A ll Nations to not give preferential treatment to board m embers, contributors, volunteer s, employees, agents, consultants, or independent contractors with respect to the placem ent of children for adoption. GREAT WALL/CAN requires all individuals to comply with the established intercountry adoption policies and procedures regardless of the ind ividual’s cu rrent or previou s rela tionship with GREAT WALL/CAN . In addition, Great Wall China Adoption dba C hildren of All Nations cannot provide preferential treatment regarding the placement of the child due to the pro cedure that the placing of children is regulated and final approval is provided through the c ountries Central Authority. Great Wall China Adoption dba Children of All Nations has no influence or impact in the f inal approval/placement decisions. Regarding the W aiting Child Program, the decisions are based solely on the n eed of the child and the suitability of the parent applying to adopt that child. N o board m embers, contributors, volunteers, em ployees, agents, consultants, or independent contr actors will be given a ny preferential treatm ent with respec t to the placement of any waiting child. .

Policy for use of fees for special services (96.40(e))

Great Wall China Adoption dba Children of All Nations does not use m oney provided by prospective adoptive parents with the signed ad option services agreem ent for progr ams or services outside of the services noted in th e signed agreem ent between Great Wall China A doption dba Children of All Nations and the prospective adoptive parent. Should Great Wall China Adoption design a cultural program, scholarships or other adoption related program that is funded by a portion of the fees charged by Great Wall China Adoption dba Children of All Nation s, GREAT WALL/CAN will outlin e the amount, program and services provided and disclose it in advance to Prospective adoptive parents. The prospective adoptive parents are in formed of this policy in the Ha gue disclosure section of our information packet.

Waivers of Liability Great Wall China Adoption dba Children of All Nations provides all prospective adoptive parents with a sample waiver of liability located within the sam ple contract as well as with the Adoption Se rvice Agreement that is s igned and submitted at th e tim e of the initial p rogram f ee. GREAT WALL/ CAN enlists legal counsel to prepare al l waivers of liability. Th e waivers of liab ility are based on local, state, federal and international policy and procedures. The w aiver of liability is limited and specific to the applicable adoption program. The information is listed below. Risks Associated with International Adoptions: Risks Asso ciated w ith Internatio nal Adoptions: The international adopti on process contains a number of inherent risks that are outside the co ntrol of GREAT WALL, incl uding, without limitation, the risks described below. These ri sks may impact the inte rnational adoption process in the form of delays, emotional frustration, additional expense and/or failure of the ability to complete the adoption process. Further, som e of the risks can im pact the long-term health and well-being of the adopted

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child(ren) in the f uture. GREAT W ALL will do ev erything in its p ower to m inimize thes e risks. However, Clien t(s) m ust be aware of these possi bilities before deciding whether an international adoption is the m eans they wish to pursue to grow their fam ily. The Client(s) agrees and understands that the completion of this Agreement does not assu re the adoption of a child (ren) nor does it as sure a successful outcome and that the Client(s) assumes all such risks. GREAT W ALL does not guarantee that a ch ild(dren) will be placed with the Client(s ). Clien t(s) her eby agrees tha t if an in ternational adoption risk event oc curs with res pect to Client(s)’ adoption case p rocessing or with resp ect to the long-term health of their adopted child(ren), Client(s) a ssumes the risk and the consequences of that outcome. Client(s) agrees to hold GREAT WALL harmless for any of the costs incurred during or after the adoption process as a result of the occurrence of an international adoption risk. Client(s) hereby agrees to waive liab ility against, and hold harm less, each of GREAT WALL and its successors, assigns, officers, directo rs, e mployees, owners, agents, volunteers, attorneys, representatives and corporat e affiliates (co llectively the “Releas ed Parties”), and t o ful ly and forever release the Released Parties from any and all claims, counterclaims, and demands whatsoever, whether arising in co ntract or in tort, in cluding claims for negligence, and wh ether in law or in equity, which Client(s) had, now have, or hereafter can, shall, or m ay have fo r, upon, or by reason of any m atter, cause, or thing whatsoever arising out of or relati ng to an international adoption risk, and, including without limitation,

(i) the political, governmental and administrative conditions in the foreign country, (ii) any problems, delays, or failures relating to U.S.-International relations, (iii) the medical, mental, social, emotional, and developmental condition of the child(ren), (iv) the Client(s) background, prior history and care and previous experiences of the child(ren), (v) any changes in the laws, regul ations, policies, or adm inistrative requirem ents of the

international placing country, the United States, or the adoptive parent(s) country, (vi) any failure of any governmental or administrative judge, agency, official, employee, or agency

to approve or promptly process the adoption, (vii) war, terrorism, crime, acts of God, natural di sasters, or any othe r condition, matters, or

causes beyond the control of GREAT WALL, and any or all of the risks set forth in this Agreement.

The Client( s) f urther a grees to ind emnify and hol d each of the Released Parties harm less f or any claims, costs, dam ages, or expenses incurred re lating to , or ar ising f rom, the occurrence of an international adoption risk, including without limitation, unknown medical conditions of the child(ren). Risks that Impact the Process: A. LENGTH OF STAY IN THE FOREIGN COUNTRY. GREAT WALL will provide to Client(s ) a best estim ate of the length of st ay Client(s) should expe ct while in the fore ign country. However , GREAT WALL cannot guarantee that the estimated timetable can be precisely met. Travel time can be extended or delayed f or a num ber of reasons such as strikes in th e f oreign off ices, illn esses, unavailability or vacations of foreign governm ent authorities such as a judge, an official and/o r social workers, holidays in the foreign country, requirem ents imposed by the courts, etc. Each case is individual and cannot be com pared to others. The length of stay may vary from the estimate given by GREAT WALL at the beginning of the process. B. POLITICAL AND SOCIAL CLIMATE INTERNATIONALLY. Countries that permit international adoption pr ograms as a m eans to f ind f amilies f or ch ildren of ten rely on this option due to volatile political and/or social conditions and lack of financial/economic resources. These same conditions may impact the interna tional adoption process itself, causing delays or stoppages in the adoption process.

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The political and social clim ate abroad is volatile and may change at any tim e in ways that negatively impact upon the adoption of children by citizens of other countries, either directly or through a change in inte rnational relatio ns. GREAT W ALL will stay ab reast of political dev elopments and keep Client(s) advised to the best of its ability. However, GREAT WALL cannot guarantee that foreign countries will continue to perm it the adoption of child ren by United States citize ns or citizens of other countries, or that they will not change laws or procedures during the course of Client(s)’ adoption case, causing Client(s) delays, additional expenses or foreclosing Client(s)’ adoption from completing. C. CHANGES TO LAWS OR PROCEDURES. Adoption laws and procedures of the foreign country, the United States, or other applicable foreign or do mestic laws m ay change at any tim e in ways that may negatively im pact the adoption of a child (ren) from abroad. GR EAT WALL cannot control whether changes in laws and procedures may in the future prevent or delay the adoption of a child(ren) from any foreign coun try, or m ay require prepar ation, s ubmission and approval of additio nal or modified documentation. D. APPR OVAL OF C LIENT(S) BY GOVE RNMENTAL OFFICIALS. The approval of Client(s)’ adoption lies solely within the di scretion of the governm ental and ju dicial officials of the child’s adoptive country. GREAT WALL will make diligent efforts to advise Client(s) about the government’s goals for prospective adoptive parents who adopt children from their country, and to advocate appropriately for Client(s)’ candidacy. However, GREAT WALL cannot guarantee that the foreign government officials will approve Client(s) to adopt a child(ren). E. CULTURAL DIFFERENCES IN COMMUNICATION. The people involved in Client(s)’ adoption will likely h ave different languages, culture, an d customs. While GREAT WALL will m ake diligent efforts to minim ize the risk of these issues im pacting Client(s)’ adoption, th e possibility exists for language misinterpretation, cultural or custom differences, and miscommunication. F. REEMERGENCE OF BIRTH FAMILIES/LOSS OF ASSIGNED CHILD(REN). Adoption policy generally favors children remaining in their birth f amilies as a top pr iority, and often favors retaining children in their country of origin as the second best option. Each of these policies is often considered preferable to placing children in foreign countries. The risk exists that birth family members may come forward at any tim e during the process of the Clie nt(s)’ case, and m ay com plicate or preven t the adoption of the child(ren) whom Client(s) wishes to adopt. It is also possible that during the course of time while Client(s) is pr eparing to adopt a child(ren), the foreign government officials may determine that siblings m ay be re quired to be adopted in or der for Client(s) to adopt the originally referred child(ren). Further, adoptive families within the country of origin may also express their desire to adopt a child(ren), even if this child(ren) has been referred to a family from abroad. In addition, a child(ren) may also be assigned to Client(s), and then a situati on occurs or is learned th at renders the child(ren) unadoptable, either under foreign la w or U.S. i mmigration law. Any of these events m ay complicate the process, or prevent the adoption from being completed. However, these events are possibilities and Client(s) should be prepared for the possibility of an emotional loss. G. W AR/ACTS OF GOD/MAN-MADE OR NATURAL DISASTE RS OR HEAL TH EMERGENCIES. An adoption case can be im pacted by events such as war, m an-made disasters (such as terrorist activities), natural disasters (such as hurricane/tsunami, etc), or health em ergencies (such as the SARS outbreak in China). These ev ents are ou tside the control of GREAT WALL, but could im pact the length of time to com plete an adoption case, or the a bility to complete it at all. H. ABSENCE OF RELIABLE INFORMATION ABOUT THE CH ILD(REN). GREAT W ALL will provide Client(s) with all the information in our physical posse ssion regarding the m edical and

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developmental condition of the child(ren) referred for the pur pose of adoption. H owever, GREAT WALL cannot guarantee the accuracy of such records. Examples are: i. If a child(ren) is abandoned, it may be difficult to determine the child(ren)’s birth date with complete accuracy. Accordingly, a birth date may later prove to be incorrect. ii. Further m edical, social and background infor mation provided to the adoptive parent(s) is often furnished and collected by independ ent and third parties, including the foreign governm ent offi cials, orphanage staff and birth m others, who provide this inform ation, according to local policy and procedure. Many tests adm inistered in foreign c ountries are unreliable at best, or m ay not m atch western standards or m ethods. Further, the m edical and/or development information provided may not provide a complete description of the m ental, emotional, physical and/or developmental characteristics of the child(ren). GREAT W ALL encourages Client(s) to seek an i ndependent medical evaluation of the child(ren) and will provide a list of physicians familiar with and specializing in reviewing social and medical reports for international adoptions. GR EAT WALL is not able to guarantee the accuracy of child(ren ) backgroun d records, and Client(s) unde rstands and accep ts the risk of those records containing errors or omissions. I. TIME FRAMES TO COMPLETE ADOPTI ON SERVICES. One of the main areas of uncertainty in respect to in ternational adoptions is the tota l length of time it takes to co mplete the a doption process from dossier subm ission to adoption . GREAT WALL maintains constant and re gular contact with in-country representatives if any and seeks information at all levels of governm ent authority to stay as current as possible with the day-to-day change s in country adoption la w, philosophy and overall political climate. It has been GREAT WALL’s experience that there is no way to predict the timeframe from application to completion of an adoption. GREAT WALL has no control over the length of tim e for referral of a child(ren) or how long it will take from referral un til the adoption is finalized in country or, in certain countries, the court issuance of a de cree providing custody of the child to the Prospective Adoptive Parent(s) u ntil all ado ption re quirements have been m et for that country’s adoption process. Extended wait times means that time-sensitive documentation expires and will need to be updated or renewed. These processes all have fees attached to them either by GREAT WALL, and/or by third party provide rs. It is critically im portant that the Client(s) understands this area of uncertainty from the very beginning of the adoption process and adjusts their expectations accordingly. J. LEGAL RISK. The Client(s) unde rstands that although a child(ren) referred internationally m ay be considered available for adoption, the United States governm ent or foreign politics m ay interrupt, delay, hinde r or obstruc t the adoption process. Fees paid f or inte rnational adoption service s will be refunded as defined in this Agreem ent in the event a country suspends or stops inter-country adoption. International adoptions are in great part controlled by the foreign government, its political infrastructure, and its relationship with the United States. The Client(s) assumes all such risks. Risks that May Impact the Adoptive Child’s Health and Well Being in the Future: Countries that permit international adoption programs as a means of finding families for children often need to rely on this option due to lack of financ ial/economic resources. This sam e lack of financial resources m ay impact the social and medical care that the pros pective adoptive child(ren) has received in the past and the availability of m edical bac kground on the child(ren) and child(ren )’s birth family. For instance, many children identified for possible adoption are cared for in institutions or hospitals. These facilities may be operated below the standards of care typica lly provided in western c ountries. The absence of equipment, supplies, nutritiona l food, toys and age appropriate developmental stim ulus and the shortage of adequate or prope rly trained medical personnel and child care providers in these

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institutions and hospitals can re sult in any ch ild(ren)’s higher risk o f illness, d elayed phys ical, psychological and m ental growth, and im pairment. C lient(s) should be aware that the international adoption process carries an inheren tly increased risk of medical, social, and e motional special needs and deficits. Some examples of these risks include the following: *Abuse: physical, psychological, emotional and sexual *Exposure to nuclear contamination *Adjustment disorders *Fetal Alcohol Syndrome (FAS) *Attachment disorders *Respiratory problems *Salmonella *Anemia *Scabies/Lice *Sensory integration problems *Hepatitis A, B, or C *HIV/AIDS *Autism *Infectious diseases *Tuberculosis *Intestinal parasites *Chronic infections *Delayed physical development *Undiagnosed genetic disorders *Delayed emotional development *Complications of prematurity *Lactose Intolerance *Delayed psychological development *Dental problems and tooth decay *Vision and hearing problems *Depression *Learning disabilities *Drug exposure *Malnutrition *Mental insufficiency *Eating disorders *Permanent disabilities *Effects of institutionalization and under-stimulation *Vitamin deficiencies GREAT W ALL will p rovide C lient(s) with all inf ormation prov ided on th e s ocial and m edical background of a child(ren) referred to Client(s ) for adoption. Further, GREAT WALL encourages Client(s) to take all information provided to an international adoption medical specialist for review and consultation. Again, the decision to adopt a partic ular child(ren) is the Client(s)’s. GREAT WALL cannot guarantee the absence of any medical, emotional or social challe nges, issues or disorders. The future medical, emotional and social health status of a child adopted internationally is not guaranteed.

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Policy for Charging Additional Expenses

Great Wall China Adoption dba Children of All Nations will no t charge for se rvices outs ide o f the adoption service agreement. Should unexpected expenses arise in the Convention country; Great Wall China Adoption dba Children of All Nations will adhere to the following policy:

Notify the client in writing of the updated fees and expenses via email and/or mail. Obtain written consent prior to expending a ny funds regardless of whether the fund in

excess of $1000.00, that is standard with the Hague requirements. Great Wall China Adoption dba Children of A ll Nations will not charge any additional fees

without obtaining a written consent. Great Wall China A doption dba Children of All Nations will not ask for waiver from the prospective ad optive pare nts because written consent from the prospective adoptive parent ensures that prospective adoptive parents are fully aware of the additional fees, and agree to the additional fees.

Great Wall China Adoption dba Children of All Nations will provide written receip t upon request to prospective adoptive parents fo r fees and expenses paid directly by Great Wall China Adoption dba Children of All Nations in the convention country and retain copies of the receipts.

The prospective adoptive parents are inform ed of this p olicy in th e Hague dis closure section of our information packet.

Refund Policy

Great Wall China Adoption dba Children of All Nations provides refunds according to the agreem ent signed betw een Great Wall China Adoption d ba Children of All Nations and pro spective ad optive family (please reference to sa mple adoption serv ice contract listed under th is self-study 96.40 (d) for detailed refund policies). Any fe es applicable to refund for any Great Wall China Adoption dba Children of All Nations client is provided within 60 days of co mpletion of the delivery of services or per written withdraw by the family from the program. Upon receipt of the written notifi cation of withdraw or the com pletion of services, the file is appropriated to the Office Manager for review and confirm ation of designated refund. Upon confirmation of designated refund, a request is submitted to accounting and the check is processed and mailed within the 60 day time frame. Refund procedures are as follows: Requesting a Refund upon completion of service:

Case m anagers should send all refund inquiries from fam ilies directly to th e accounting department.

The Accounting Departm ent will review th e refund inquiry to m ake sure that the refun d requested is due to the family.

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For all app roved refun ds, the Office Man ager will em ail the Acc ounting Assistant the following information:

o First and Last Name of the Family o Reason for Refund o Date, amount and check number/CC for original payment o Refund amount

The Accounting Department reviews refund requests and issue refund checks. The Accounting Departm ent docum ents the refund in the fam ily’s record and accounting

system. Refund Due to Withdrawal:

Family is required to notify thei r case manager in writing if they choose to withdraw from the adoption process.

Case m anager forwards their file along with the withdrawal letter to the Accounting Department for processing.

Accounting Department will determ ine if a ref und is due per the sign ed adoption agreem ent with the family.

If a refund is due, the Accounting Department will issue refund checks. If a refund request is outside the signed a doption agre ement with th e f amily, Accountin g

Department will submit a refund request via email the President. The Preside nt will appr ove the req uest and th e Accounting Departm ent will issu e ref und

checks The refund is docum ented in fam ily’s record and an office notice of withdr awal is sent to the

family along with the refund check(s). All records are noted and kept in client file and in our accounting system.

Grievance Policy and Procedure Great Wall China Adoption dba Children of All Nations provides written complain t policies and procedures that incorpo rate the stan dards in 96.41 (b th rough h) in the Great Wa ll/CAN adoption service ag reement. Below com plaint policie s a nd procedu res are also listed in GREAT WALL/CAN websites, and included in Hague Disclosure section of our information packet. Complaints by any Birth Parent, any Prospective A doptive Parent(s), adoptive parent(s) or adoptee about any services or activities of the agency or person, including supervised providers, that he or she believes raises an issue of com pliance with the Conventi on, the Intercountry Adoption Act (IA A) or the regulations implementing the IAA are initially discussed and mediated between the assigned Great Wall China Adoption DBA Children of All Nations case manager and aggrieved party. The following level of staff will add ress the complaint before a wr itten complaint is f iled: Assigned Case Man ager, Case Manager Supervisor, and Client Service & Relations Director. If the com plaint is not r esolved amicably or to th e satisfaction of the aggrie ved party, the com plaint, signed and dated, m ay be filed by any prospective a doptive parent(s), adoptiv e parent(s) or adoptee directly with GREAT WALL/CAN about any services or activities of the agency or person, including

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supervised providers, that he or she believes rais es an issue of com pliance with the Convention, the Inter-country Adoption Act (IAA) or the regulations im plementing the IAA. GREAT WALL/CAN provides a Com plaint/Grievance Form on the Fa mily Only section of our website. This form is also sent to families upon request. Complaints may be submitted online or registered in writing by mail to: Children of All Nations, Attn: Clie nt Service & Relations Director , 248 Addie Roy Rd, A104, Austin, Texas 78746. Unresolved com plaints m ay also be filed by any Prospective Adoptive Parent(s), adoptive parent(s) or adoptee dire ctly with the U.S. State Depa rtment via the Hague Complaint Registry (http://adoptionusca.state.gov/HCRWeb/WelcomeForm.aspx), about any services or activities of the agency or person, including supervised providers, that he or she believes raises an issue of compliance with the Conventio n, the Inter-country Adoption Ac t (IAA) or the regulations implementing the IAA. All formal complaints received by G reat Wall China Adoption DBA Children of All Nations will be reviewed by the Grievance committee and responded to in writing within 30 days. Grievances alleging fraud or deemed time sensitive by the committee will be expedited. In addition, GREAT WALL/CAN will maintain a written record of complaints received, and follow the steps outlined in the above section to investiga te the complaint, and provide response per tim e frame specified in this policy and pr ocedure. All com plaints will be m ade available to Council on Accreditation or the Secretary upon request. GREAT WALL/CAN will not take any action to discourage a client or prospective c lient from , or retaliate again st a c lient or pro spective c lient f or: making a com plaint; e xpressing a grievan ce; provi ding in formation in writing or inte rviews to an accrediting entity on o ur agency ’s perform ance; or questioning th e conduct of o r expressing an opinion about the performance of our agency. GREAT WALL/CAN will provide to Council on Accreditati on and the Secretary, o n a sem i-annual basis, a su mmary of all com plaints received d uring the preceding six months with infor mation on number of com plaints received an d how each co mplaint was resolved and an assessm ent of any discernible patterns in com plaints received against our agency, al ong with inform ation about what systemic changes, if any, were m ade or are planned by our agency in response to such patterns. Upon request by Council on Accred itation or the Secretary, GREAT WALL/CAN will p rovide any information about complaints received. GREAT WALL/CAN has a quality improvem ent program to system atically im prove our service s by providing client satisfaction surveys to the client(s ), conducting regular sta ff m eetings to review practices and improve procedures, reviewing complaint data and evaluating employees performance. Complaint Procedures: The procedures for the complaints and grievances are as follows:

1. Great Wall China Adoption dba Children of All Nations receives a written complaint via email, fax or mail.

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2. The complaint is direc ted to the ap propriate st aff member to address th e grievan ce initially. Birth parent, Prospective adoptive parent, adoptiv e parent or adoptee contacts their assigned case manager. If no case m anager is assigned, the complainant is forwarded to the supervisor or management team.

3. If the com plaint is not resolved be tween the complainant and the assigned staff, the staff

supervisor reviews and mediates the complaint. 4. If the com plaint is not then reso lved with the staff supervisor, the sup ervisor meets with the

Management team who then provides consulting or mediates the complaint as needed. 5. Should the com plaint not becom e resolved afte r all steps and procedur es listed above are

completed, the complainant may write a formal letter outlining the complaint and/or the initial Complaint/Grievance form will be sent for review by the Grievan ce Committee at Great Wall China Adoption dba Children of All Nations, 248 Addie Roy Rd, A102, Austin Texas, 78746.

6. Upon receipt of the written complaint/Grievance form, the Grievance Committee completes an

investigation by assessing the si tuation, talking to the parties involved in the incident or concern, reviewing relevant docum entation, a nd exam ining any other relevant source of information. This asses sment will occur with in a tim ely m anner, one which will allow a response to the com plainant within 30 days. If the complaint involves a serious ethics violation, p olicy b reach or oth er significant o r timely offense, th is in vestigation will beg in within one business days and will be com pleted within five business days. The committee will keep the President appraised daily in such a situation.

7. If the complaint against an employee appears to have merit after the investigation is completed

by the committee, this issue will be addressed with the employee by the employee’s supervisor. The appropriate warning and/or disciplinary ac tion will be enforced up to, and including, termination.

8. If the com plaint against a Great Wall/CAN exempt or supervised prov ider has m erit after the

investigation is com pleted by the co mmittee, a staff designated by the managem ent team will address the issue with exem pt provider. The appropriate action taken includes warning to exempt or supervised provider, or termination of the relationship with the provider.

9. The complaint is reviewed by the Grievance Committee and a response is provided in writing

within 30 days.

10. Great Wall China Adoption dba Children of All Nations maintains a r ecord o f all f ormal written complaints registered by birth parent, prospective adoptive parent, adoptive parent or adoptee related to an issue of compliance with the Convention, the Inter-country Adoption Act (IAA) or the regulations implementing the IAA. The records detail, in writing, the steps taken to resolve the complaint.

11. Complaints may also be filed by any birth parent, prospective adoptive parent, adoptive parent

or adoptee directly with the U.S. State Department via the Hague Complaint Registry, about

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any services or activities of the agency or person, including supervised providers, that the complainant believes raises an issue of compliance with the Convention, the Inter-country Adoption Act (IAA) or the regulations implementing the IAA.

Policy for Disclosing Information Great Wall China Adoption dba Children of All Nations provides all infor mation received from the Central Authority of the sending country with regard to the health history and background of the adoptive child to the ad optive parents at the tim e of referral and in a ccordance with the Provision of Medical and Social Information Policy/Procedures outlined in Section 96.49. Electronic a nd hard cop ies a re m aintained and w ill again be provid ed to th e ado ptee o r ado ptive parent(s) upon request. Should the adoptee or adoptive pa rent(s) request information, Great Wall/CAN will make available all non-identifying information it has regarding the adoptee’s health or background. Should an adoptee or adoptive parent request inform ation from their file , the request will be di rected to the em ployee overseeing the case. The adoptee or a doptive parent will be asked to pu t the request in writing so that Great Wall/CAN may maintain a r ecord of the request. Within 10 business days (if the client f ile is closed or housed off site) or 5 business days (if the file is on site) the e mployee overseeing the case will gather the requested information and make copies for the adoptee or adoptive parent. In the event of a medical emergency, the staff m ember can request or gather the information within 24 hou rs. The employee overseeing the case will black out an y identifying information on the copies bef ore giving the information to the adoptee or adoptive parent, unl ess the inform ation was part of the inform ation originally provided to the adoptive parent as part of the Provision of Medical and Social Inform ation Policy/Procedures. The requested information will then be mailed to the adoptee or adoptive parent(s) unless they choose to pick the information up at the office. Great Wall China Adoption dba Children of All Nations ensures that all personal data gathered by Great Wall/CAN, the supervised provider or any other out side source during th e application, dossier, referral and post-adoption phase of the adoption is used only for the designated purpose. The designated purpose includes assessi ng eligibility; reporting and re laying inform ation to both the Department of Homeland Security, any required State entity and the China Center of Adoption Affairs; and to ensure that the best intere sts of the child are being m et. All information gathered in connection with an adoption is safeguarded and conf idential. Saf eguards include secure d computer systems , secured passwords, and secured bui lding. All staff is required to read, sign an d maintain the Great Wall China Adoption dba Children of All Nations confidentiality policy. This signed policy is o n file in the employee file.

Policy for Acting as Primary Provider

As a prim ary provider, Great Wall China Adoption dba Children of All Nations adheres to Section 96.14 (b) through (e), 96.45 and 96.46. Great Wall China Adoption d ba Children of All Nations maintains a service plan for providing all adoption services and provides all such services, either

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directly or through arrangem ents with Supervised Providers, Exempt Providers, Foreign Supervised Providers, public domestic authorities, co mpetent authorities, Central Au thorities, or other foreign providers (agencies, persons, or other non-governmental entities). Great Wall/CAN has an organizational structure, financia l and personnel resources, and policies and procedures in place that dem onstrate Great Wa ll/CAN is capable of acting as a prim ary provider, provides appropriate supervision to Supervised/Exempt/Foreign Provider s and verifies the work of other foreign providers in accordance with Section 96.45 and 96.46. As Primary Provider Great Wall: complies with the requirements and standards set forth by Hague Regulations; confirms that it satisfies all personnel qualifications required for a Primary Provider; confirms that it has in place po licies to lim it the use of an d safeguard personal data gathered o r

transmitted in connection with an adoption; confirms that it m eets the suitability require ments set forth by Hague Regulations and m akes

immediate and specific disclosure in writing for any deviation; confirms that it m eets all r equirements f or upk eep and m aintenance of all app ropriate s tate

licensing entities in which Great Wall/CAN operates and holds such license(s). In acting as Prim ary Provider to provide adopti on services to Prospective Adoptive Parent(s), Great Wall/CAN will provide the following: Great Wa ll/CAN will g uide the Prospective A doptive Parent s to ob tain all m aterials and ass ist

them in the completion, organization, and finalization of all documentation necessary to receive a referral of a child(ren) from the applicable adoption program.

Great Wall/CAN will coordinate the delivery of all Prosp ective Adoptive Parent (s) d ocuments in

the foreign country to appropria te coordinators, governm ents and/ or officials and subm it to the foreign country all documentation necessary for the adoptive parent(s) to complete the adoption of the child/children from the foreign country.

Great Wall/CAN will present all referral documentation to the adoptive parent(s), and will provide

the adoptive parent(s) with all information on the child(ren) referred to them in Great Wall/CAN’s possession.

Upon acceptance by the adoptive parents of a referral of the child(ren), Great Wall/CAN will work

with the adoptive parent(s) to advise on what is needed for com pletion, organization, and finalization of all docum entation necessary to com plete the adoption of the child (ren) f rom the placing country.

Great Wall/CAN will assist the ado ptive parent(s) in co mpleting all documentation necessary for

the child(ren) to apply for and acquire an exit visa for gaining admission to the United States. Great Wall/CAN will handle, throu gh its coord inators and facilitato rs, all ac tivities necessary to

meet legal requirements relating the finalization of adoption proceedings in the placing country.

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When working with Supervised Provider s, Great Wall/CA N will exec ute an ag reement with each Supervised Provider in order to define the responsibilities and relationship, as we ll as identify and outline expectations and restrictions for each party. As a primary provider, Great Wall/CAN will also provide oversight and monitor each Supervised Provider to ensure that the standards of The Hague are being carried out and upheld. In acting as Prim ary Pr ovider in coordination to the Supervised Provider , Great Wall/CAN will provide the following functions relative to the adoptive parent(s) case: Great Wall/CAN will provide any Supervised Provider with guidelines, outlines, and all necessary

documentation for the completion of an acceptable homestudy. Upon com pletion of the draft of the hom estudy report, Great Wall/CAN will review th e

homestudy draft and provide specif ic comments and/or changes to conform to Great Wall/CAN’s policies and practices and those of China Center of Adoption Affairs.

Great Wall/CAN will advise Supervised Provider of details to permit Great Wall/CAN to comply

with all applicable re quirements for post adoption reporting on the follow-up of the adoption. During the post adoption phase, Great Wall/CAN Post adoption Counselor will regularly monitor the ch ild’s placem ent in coordin ation with the homestudy agency to ensure that the placem ent remains in the best inte rest of the child and to al so ensure that at least the number of home visits required by State law or the tw o hom e visits required by Chin a are perform ed, whichever is greater.

Great Wall/CAN will notify Supervised Provider of any of the following events:

A. Changes to state law, regulations or status. B. The Prospective Family’s receipt of a referral of a child(ren) C. The dates the post adoption reports are due to the Central Authority of the placing

country Great Wall/CAN does not currently work with foreign prov iders. All adoptions an d placem ents are managed by each country’s Central Authority. However, in the event that a relationship with a foreign provider will form , Great Wall/CA N has policies and pro cedures in place when working with both supervised and non-supervised foreign providers to verify the work that th ey do on behalf of the referred child and the prospective adoptive parent(s). When working with a Foreign Supervised Provider, Great Wall/CAN will execute an agreement with each Foreign Supervised Provider in order to define the responsibil ities and relations hip, as well as identify and outline ex pectations a nd restrictio ns for each party. As a prim ary provider, Great Wall/CAN will also p rovide overs ight and m onitor each Foreign Supervised Provider to ensur e that the standards of The Hague are being carried out and upheld. It is Great Wall/CAN’s policy that we will only work with FSP who:

comply with the laws of the Convention Country;

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have the best interest of the child in their pr actice, and do not engage in the sale, abduction, exploitation, or trafficking of children;

disclose that they meet the suitability information listed in Section 96.35; do not have a pattern of licensing suspensions or other sanctions a nd have not lost the right to

provide adoption services; and are accredited if the Convention Country law requires accreditation.

It is Great Wall/CAN’s policy to include all the requirem ents in Section 96.46(b) in our agreem ent with FSP. A sample Foreign Supervised Provider agreement is listed in 96.46 (b) below. It is also Great Wall/CAN’s policy to adhere to Section 96.46 (c) when acting as the prim ary provider using non supervised foreign providers to verify the following:

any necessary consent to term ination of parental rights or to adopti on obtained by the foreign provider was obtained in acco rdance with app licable fo reign law and Article 4 of the Convention;

any background study and report on a child in a case involvi ng imm igration to the United States performed by the foreign pro vider was conducted in accordance with applicable foreign law and Article 16 of the Convention; and

any hom estudy and report on prospective adoptiv e parent(s) in a case involving em igration from the United States perform ed by the fore ign provider was perform ed in accordance with applicable foreign law and Article 15 of the Convention.

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Policy for Withdrawing or Declining a Referral (96.49(k))

In order to serve the best interest of the adoptive child, Great Wall China Adoption dba Children of All Nations feels that it is the right of every prospective adoptive parent to accept or decline the referral of an adoptive child. At no tim e ever, will a GREAT WALL/CAN em ployee p ressure or coe rce th e prospective adoptive p arent(s)’ into m aking the decisi on to proceed with an adoption of a child. In order to effectiv ely serve the best interest of a ll parties, it is the in tent of each GREAT WALL/CAN employee to advocate, educate and support all Prospective Adoptive Parent(s) (PAP(s)). All PAP(s) are provided the m inimum two week period and in m ost cases longer, to review a child’s file and m ake the decision to acc ept or decline the ref erral. This inf ormation is outlined in each country’s Great W all/CAN referral agreem ent. If GREAT WALL/CAN does not receive notification from the PAP(s) within a reasonable period after the two weeks, GREAT WALL/CAN has the authority to notify the Central Authority and authorizes them to close the prospective adoptive parent(s)’ file, effectively ending the adoption process. GREAT WALL/ CAN referral counselo rs will contact th e families to provide cou nseling and support p rior to any designated deadline and will notify PAP(s) if the deadline is not m et and prior to subm itting a re quest to close the adoption file in the placing country. In the event that the Prospective Adoptive Parent(s) chooses to decline a referral or withdraw from the process, Great Wall China Adoption dba Children of All Nations will follow the course of action listed below. The family has two options once they receive a referra l for an adoptive child: Accep t or Decline. This decision m ust be indicated on th e appropriate paperwork for Great Wall/CAN and any applicable Central Authority docum entation. For exam ple, China provides a Letter Seeking Confir mation from Adopter that is sent to and si gned by the P rospective Adoptive Pare nt(s), dated and returned by the PAP(s) to GREAT WALL/CAN . GREAT WALL/CAN m ails the sign ed and da ted Letter Se eking Confirmation f rom Adopter to the China Center of Children’s Welfare and Adoption (CCCWA) to inform them of the PAP(s) decision. After reviewing the adoptiv e child’s referral infor mation, should the fa mily decide to decline the referral of this ch ild; a GREAT WALL/CAN Referral Counselor will a dhere to the following procedures:

Inquire as to the reason for declining the child. Provide c ounseling, education and information as needed and approp riate that m ight a ssist the Prosp ective Adoptive Paren t(s) in their decision-making process. Refer an outside resource such as a pedi atrician that sp ecializes in International Adoption. A list of recommended physicians can be provided to the fa mily in these circumstances.

Inform the Prospective Adoptive Parent(s) that the decision to issue a second referral is completely and ultim ately m ade by the Off icials of the Central Authority and Great Wall China Adoption dba Children of All Nations has no control over this decision making process.

Inform the Prospective Adoptive Pa rent(s) that the m ost placing countries must feel that there is a legitimate reason for declining the child in order to issue a second referral of an adoptive

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child. Be s ure to inf orm them that if the Central Authority does not agree that there is a legitimate reason for declining the child, the Prospective Adoptive Parent(s) will not be issued a second referral.

For example, if the family feels the child has a medical concern and they are e ligible for a child with no special needs, the Central Authority must also agree that the child does have a medical concern o r that the ch ild is at risk for a possible medical concern. If they do not feel that there is a medical concern, they may not issue a second referral.

Offer inform ation and education and seek the advice of our in country representatives if necessary. Advocate to the Central Authority on behalf of the f amily to clearly communicate their reasoning for decl ining the ch ild. Inf orm the f amily of any inform ation received from GREAT WALL/CAN representatives that will assist in the family’s decision making process.

After completing the ste ps listed ab ove, if it is still the dec ision of the Prospective Adoptive Parent(s) to declin e the child, r equest they r eturn the appro priate signed paperwork indicating their decision to decline the referral.

The documentation must include a reason for dec lining the child. This must be written by the Prospective Adoptive Parent(s). GREAT WALL/CAN recommends that th e family submit their reasoning in letter form in order to fully explain their decision.

The f amily must also r eturn all original a nd transla ted referra l documents for the referred adoptive child, including photos, to Great Wall China Adoption dba Children of All Nations .

Once received by GREAT WALL/CAN, the documentation for decline and a copy of the referral documents will be kep t on f ile at Great Wall China Adoption dba Children of All Nation . All original documents are returned to the Central Authority as applicable.

The information is noted in Fam ily Builder th at the P rospective Adoptive Parent(s) declined the child. This will also be noted in the file na me of the child’s photos which have been saved to our server.

We will maintain correspondence with our country representatives in ord er to follow up on the Central Authorities decision and the status of the second referral.

Should the Central Authority issue the Prospective Adoptive Parent(s) a se cond referral for an adoptive child, we will follow all standard procedures out lined for obtaining and providing social and medical information to the Prospective Adoptive Parent(s).

If the Central Authority does not issue the Prospective Adoptive Parent(s) a second referral for an adoptive child, the Central Authority ’s d ecision will then be comm unicated to th e Prospective Adoptive Parent(s). A R eferral Counselor at GREAT WALL/CAN will advocate as needed to the Central Authority and the family to fully understand this decision and to see how we can assist the family, however, the family will again be reminded that the decision to issue a second referral is completely and u ltimately made by the Officials at the Central Authority and Great Wall China Adoption dba Children of All Nations has no control over this decision making process.

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Disruption Policy

The following is an ex cerpt from Great Wa ll/CAN’s adoption services cont ract: A disruption is defined as the decision by the Prospective Adoptive Pa rent(s) to decline a child before the adoption of the referred child has been finalized. Disruption Policy: A disruption is defined as the decision by the Prospec tive Adoptive Pa rent(s) to interrupt the placement of a child for adoption d uring the post-placement period, once they have taken custody of the child and accepted th e referral in writing but before the adoption of the referred child has been finalized. Client(s) understands and agrees that it is the right of all children in a di sruption or dissolution to receive full protection and services and the ch ild is deemed the primary client by GREAT WALL/CAN and Client(s). GREAT WALL/CAN ensures th at all appropriate m easures for the tran sfer of a child take p lace with qualified escorts and in the com pany of the Client(s). This is ensured through the regulations and procedures outlin ed by the child’s country of origin. GREAT WALL/CAN also ensures th is by assigning a bi-lingual guide that travels with the adoptive families throughout the adoption finalization trip. Client(s) understands and agrees that, if they are considering disruption of the child prior to the adoption f inalization, Client(s) m ust inf orm their GREAT WALL/CAN Guide or In-Co untry Representative and/or GREAT WALL/CAN Staff. CAN Staff are available to client(s) 24 hours per day while client(s) are in-country. GREAT WALL/CAN staff m ay provide resour ces and information for pediatric experts, social workers, and child dev elopment specialists as needed to d iscuss professional opinions of client concerns. GREAT WALL/CAN staff cannot provide advice on proceeding with the adoption of the child. Steps to asses s the child will be taken within the scope of available resources, such as assessing the child for physi cal or mental concerns. Please note that should a disruption occur while in-country, the future placement of the adoptive child involved in the disruption and the decision to issue a second referral is com pletely and ultim ately made by the Central Authority of the child’s country of origin. Great W all China Adoption dba Children of All Nations has no control over this decision making process. If the de cision for disruption rem ains, the GREAT WALL/CAN Guide or In-Country Representative and/or GREAT WALL/CAN staff will provid e assistan ce to coordinate with client(s), the Central Authority of the child’s country of origin and the orphanage or local government, the safe return of the child. During the post placement period, th e foreign governm ent adoption au thority will rem ain the legal guardian of the child. Client(s) understands that if there is any disruption, as that term is defined herein, any costs for care, inclu ding m edical treat ment, are the resp onsibility of the Prospective Adoptive Parent until the time the custody of the child is remanded to the orphanage. Client(s) understands and agrees that in the ev ent of an emergency or in the case of a disruption while in-country, at no tim e ever, will a GREAT WALL/CAN Guide or In-C ountry Representative assume custody of the adoptiv e child. Client(s ) understands and agrees that the child will rem ain in the custody of the Prospective Adoptive Parent(s) until the child can be returned to the custody of the

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orphanage. In the event of an em ergency and the Prospe ctive Adoptive Parent(s ) cannot adequately care for the child, local or governm ent officials and the adoptive chil d’s orphanage may be contacted by GREAT WALL/CAN to attem pt to arrang e for an official or a staff m ember of the orphan age to come to the care of the adoptive child, in lo cal governm ent or official’s sole discretion. GREAT WALL/CAN shall not ever assum e responsibility for the child during the in-country post placem ent phase. Client(s) understands and agrees that Client(s ) will not execute any docum ents, in-country or otherwise, without fully understa nding the meaning and consequen ces of such ex ecution. It is Client(s)’ sole responsibility to understand or have all such documents explained. Client(s) understands an d agrees that the adoption docum ents signed in-country are legal documents granting legal rights to Client(s) as the adoptive child’s parent(s ). Completion and signing of the adoption docum ents assigns and form alizes Client(s ) as the child’s legal guardian(s). CLIE NT(S) UNDERSTANDS AND AGREES THESE DOCUME NTS HAVE P ERMANENT AND L ASTING CONSEQUENCES. Client(s) u nderstands that once the adoption is finalized in-coun try and in accordan ce with local/government law, the Prospective Adoptive Pare nt(s) becom e the legal parent/guardian of the child and the child ac quires all the righ ts, priv ileges a nd immunities of a ch ild born to the client(s). The Client(s) understand and agree th ey will then have all responsibilities, legal obligations and duties to the child as though the child was born to the Client(s). GREAT WALL/CAN ca nnot reverse this legal and binding rela tionship. Any child that has been placed for adoption in the United States, cannot return to their c ountry of origin as an orphan without the consent of the Ce ntral Authority of the child’s country of origin . Client(s) understands and agrees that GREAT WALL/CAN shall inform the Central Authority of the child’s count ry of origin and the Secretary of any disruption. GREAT WALL/CAN shall com ply with the all p rocedures required by th e Secretary and the Central Authority of the child’s country of or igin to ensure that all actions are taken in the best interest of the child, without regard to Client(s). If applicable and the adoption in no t finalized in-country, should the fam ily return to the U.S. or their country of residence during the post placem ent phase, GREAT WALL/CAN will continue to m onitor and supervise, with the assistance of the home study agency as applicable, the required hom e visits by the State and the foreign government, and the p lacement of the ch ild prior to the adoption finalization to insu re th at the p lacement rem ains in the b est in terests of the child. During the post pla cement period, the foreign government adoption authority will remain the legal guardian of the child. GREAT WALL/CAN and the Client(s) will seek to avoid disruption of prosp ective adoption during placement period prior to final adoption if that is in the best interests of the child. Client(s ) will notify CAN promptly if there are significant problems in the relationship or situation of the Client(s) and the child during such tim e. To the ex tent it h as k nowledge a nd resou rces, GREAT WALL/CAN shall support and provide resources and appropriate referrals regarding available external assistance such as counseling that Client may engage in at Client’s expense. In the event that counseling and outside resources are not successful in resolving serious d ifficulties and there is a m utual agreement that the continued placement of the child is not in the child’s best

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interest, it shall be expressed in writing that continuing the post placement period and subsequent final adoption of the child are not in th e child ’s be st inte rest. GREAT WALL/CAN and the Client(s) will establish an agreed- upon date to effect a change in the cu stody and physical hom e of the child. The legal responsibility for transfer of custody in a disruption will remain with the Central Authority of the child’s country of origin. GREAT WALL/CAN will cooperatively work with the Secretary of State of the United States and the Central Authority of the child’s country of origin who will place the child as they determine is in the child’s best interest. The child’s age, wishes, length of tim e in the Unite d States and the availabi lity of other suitable matching placements are factors that will be taken into account by the Central Authority of the child’s country of o rigin when they determ ine where to place a ch ild. In considering future placement of the child, GREAT WALL/CAN will consider th e child’s views when a ppropriate in light of the child’s age and m aturity and, when required by State law, obtai n the consent of the chil d prior to change in physical hom e or custody. The Central Authority of the child’s country of origin has sole responsibility to determine what placement is in the ch ild’s best interests. The child m ay not b e returned to their country of origin as an orphan w ithout the Secretary of State of the United States and the Central Authority of the child’ s country of origin gi ving written permission to do so. Returning a child to their country of origin will only be done wh en the Central Authority of the child’s country of origin determines that it is the best suitable option. During any disruption or crisis involving placem ent, the Centra l Authority of the child ’s country of origin and The Secretary of State of the United St ates will be notified in writing using e mail and by telephone contact follo wed up in writing. W hen GREAT WALL/CAN is notif ied by the Client(s ) regarding Client(s) inten t to d isrupt a child or that there are problems that might lead to a d isruption, GREAT WALL/CAN will work with Client(s) to resolve these problems and will notify the Secretary of State of the United States and the Central Authority of the child’s country of origin as immediately as possible and within no more than 3 business days of the problems and of any attempts to resolve them. If a placement is disrupted in an emergency s ituation (where the child or family’s safety appears to be at risk), as assessed by GREAT WALL/CAN and in a state where GREAT WALL/ CAN is lice nsed, GREAT WALL/CAN Staff, will go to the Client(s) home to remove the child. GREAT WALL/CAN Staff will alert the appropriate officials, including, but not limited to, law enforcement, CPS, and emergency medical personnel, if the situation warrants this act ion. If a placem ent is di srupted in a state wher e GREAT WALL/CAN is not licensed but uses a Supervised Provider, the Supervised Provider will provide counseling to the Cl ient(s) and written records and recommendations to the GREAT WALL/CAN Staff, and cooperates in all m anners reasonable and necessary to arra nge for transfer of the custody of the child to a suitable custodian or foster home. If it is in the best interest of the child, the Client(s) will maintain custody until such suitable placement is m ade. Financial and m edical care of the child will r emain the resp onsibility of the Client until custody is transferred per the decision of the Central Authority of the child’s country of origin. Should this not be in the best inte rest of the child, GREAT WALL/CAN and/ or the Client(s)’ hom e study agency will contact Ch ild Pro tective Services or ot her such entity nam ed in the State of Client(s)’ residence for emergency placement of the child. Notwithstanding removal of the child from the Client’s home and custody, the Client(s) shall continue

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to have financial responsibi lity for all costs required for child’s care until such time as CAN is a ble to effect other placement or return of the child to the foreign country as set forth above, and Client(s) will pay such costs upon billing by GREAT WALL/CAN. Client(s) must adhere to the post-placem ent reporting requirements set forth by the Central Authority of the child' s country of origin. Client(s) are required to provide all necessary inform ation for the reports and cooperate with social workers to m eet all state, convention country post-placem ent requirements before the adoption is finalized. GREAT WALL/CAN will supe rvise the pl acement until suc h tim e GREAT WALL/CAN receiv es an order declaring the adoption as final. During the post-placem ent services, GREAT WALL/CAN will send regular reminders to the Clien t(s) regarding the non-finalized status of their ad option and stress the im portance of adop tion finalization. Once GREAT WALL/CAN receives the o rder declarin g the adoption as final, GREAT WALL/CAN Hague Coordina tor will inf orm the Secr etary in any m anner requested by the Secretary within 30 days of receipt of order.

Dissolution Policy

Dissolution Policy : Dissolution is defined as the decision by the Prospectiv e Adoptive Paren t(s) to dissolve the adoption of the referred child after th e adoption has been finalized. In accordance with the standards of The Hague Conve ntion for International Adoption, please review our Dissolution Policy below:

In the even t that d issolution occurs once the adop tion is f inalized in the United State s, th e matte r becomes a domestic matter that would follow U.S. Federal and State guidelines for domestic adoption. In the event of dissoluti on, at no tim e ever will Great Wall China Adoption dba Children of All Nations assume custody of the adoptive child.

Once the adoption is finalized in acc ordance with regulations set forth by the child' s country of origin, the Prospective Adoptive Parent(s) becom e the le gal parent/guardian of the child and the child acquires all the righ ts, privileges and immunities of a child born to the clien t(s). Great W all China Adoption dba Children of All Nations does not and cannot have any influen ce regarding the steps within this legal matter. The act of leaving your newly-adopted child in-country or attempting to return the ch ild to the ir cou ntry of o rigin, af ter y ou have signed the adopti on paperwork, is highly illegal. Failure to com ply could res ult in civ il and crim inal penalties for such behavior and CAN cannot be responsible for the actions of the govern ment officials both in the U.S. and the child' s country of origin. This act would be consider ed second abandonm ent, and action m ay be taken by government officials both in the U.S. and the child' s country of origin for i ndividuals who engage in this activity.

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In the event of dissolution, all post adoption reports MUST still be submitted to the Central Authority of the ch ild's country of orig in on b ehalf of the child. W e request coo peration in subm itting these reports to ensure the well-being of each child.

Disclosure of fees used to provid e specia l services : Great Wall and CAN does not currently have any program s in place for providing special servi ces, such as cultural progra ms for adoptees , scholarships, grant program s or other services which would require the support of the Prospective Adoptive Parent(s). All fees coll ected are used specifically f or adoption services and for orphanage support and maintenance as required by the foreign government policies or law. Additional Fees Charged beyond Disclosed in Contract: Great Wall and CAN will not ch arge for services outside o f the adoption service agreem ent. Should unexpected expenses arise in the Convention c ountry; G reat W all and CAN will adhere to the following policy:

Notify the client in writing of the updated fees and expenses via email and/or mail. Obtain written consent prior to expending any funds regardless of wh ether the fun fund in

excess of $1000.00, that is standard with the Hague requirements. Great W all and CAN will not ch arge any ad ditional fees without o btaining a written

consent. Great Wall and CAN will not ask for waiver from the prospective adoptive parents because written consen t from the prospectiv e adoptive parent ensures that prosp ective adoptive parents are fully aware of the additional fees, and agree to the additional fees.

Great Wall and CAN will prov ide written rece ipt to prospective adoptive parents f or fees and expenses paid directly by Great Wall a nd CAN in the convention country and retain copies of the receipts.

Policy for Returning a Child to Country of Origin For adoptions that are finalized, law does not allow for a child that has been placed for adoption in the United States, to return to the country of placement as an orphan. Once the adoption is finalized in the country of origin, the Pros pective Adoptive Parent(s) become the legal parent/guardian of the child. In the event th at dissolution occurs once the adoption is finalized, this would become a domestic matter that would follow U.S. Federal and State guidelines for domestic adoption. The child may not be returned to their country of or igin as an orphan without the Secretary of State of the United States and the Central Authority of the child’s country of origin giving written permission to do so. Returning a ch ild to their country of orig in will only be done when the Central Authority of the child’s country of origin determines that it is the best suitable option.

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Policy and Procedure for Informing Central Authority and Secretary about the Adoption Process

Great Wall China Adoption dba Children of All Nations will cooperate and provide all information necessary to accrediting en tities o r author ities r egarding all Hague Con vention re lated inte rnational adoption cases facilitated by Great Wall China Adoption dba Children of All Nations. Great Wa ll China Ado ption dba Children o f All Nation s will p rovide any Centra l Authority and Secretary a summary of all adoptions, and the measures taken to complete the adoption process as well as inform ation about the progre ss of the placem ent by providing co pies of post adoption reports through the reporting p rocedures outlined by th e Secretary should the Central Authority or Secretary request the inform ation. Great Wall China Adoption dba Children of All N ations provides all requirement post adoption reports to inform Centra l Authorities of the progr ess of the adoption. GREAT WALL/CAN will provid e this inf ormation and any other inf ormation per all Central Authorities and the Secretary upon request. Great Wall China Adoption dba Children of All Nations will tak e all neces sary and app ropriate measures to perform any tasks in a C onvention adoption case that the Secretary identifies are required to comply with the Convention, the Inter-country Adoption Act (IAA) or the regulations implementing the IAA. ANNUAL REPORT ON INTERCOUNTRY ADOPTIONS. (a) Reports Required. Beginning 1 year after the date of th e entry into force of the Convention for

the United States and each year thereafter, th e Secretary, in consultation with th e Attorney General and other app ropriate agen cies, shall s ubmit a rep ort desc ribing the activ ities of the central authority of the United States under this Act during the preceding year to the Comm ittee on Inte rnational Rela tions, the Co mmittee on Ways and Means, an d the Comm ittee on the Judiciary of the House of Representative s an d the Comm ittee on Foreign Relations, the Committee on Finance, and the Committee on the Judiciary of the Senate.

(b) Report Elements . Each report under subsection (a) sha ll se t f orth with resp ect to the yea r

concerned, the following: (1) The num ber of intercountry adoptions involving imm igration to the United States,

regardless of whether the a doption occurred under the Co nvention, including the country from which each ch ild em igrated, the State to which each child im migrated, and the country in which the adoption was finalized.

(2) The num ber of intercountry adoptions involving em igration from the United S tates,

regardless of whether the adoption occurred under the Convention, including the country to which each child immigrated and the State from which each child emigrated.

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(3) The num ber of Conve ntion placem ents for adoption in the United States that were disrupted, including the country from which the child em igrated, the age of the child, the date of the placem ent for adoption, the reas ons for the disruption, the resolu tion of the disruption, the agencies that handled the pl acement for adoption, and the plans f or the child, and in addition, any inform ation regarding disruption or dissolution of adoptions of children from other countries received pursuant to section 422(b)(14) of the Social Security Act, as amended by section 205 of this Act.

(4) The average tim e required for com pletion of a Convention adoption, set forth by country

from which the child emigrated (5) The current list of agencies accredited and persons approved under this Act to provide

adoption services. (6) The nam es of the agencies and persons tem porarily or perm anently debarred under this

Act, and the reasons for the debarment. (7) The range of adoption fees charged in connection with Convention adoptions involving

immigration to the United Sta tes and the m edian of such fees set forth by the country of origin.

(8) The range o f fees charged for accreditati on of agencies and the approval of persons in the

United States engaged in providing adoption services under the Convention.

Great Wall China Adoption dba Children of All Nations maintains all information requested by the Secretary and Hague Accrediting entity for all Hague Country related cases.

Policy for Returning the Home Study and Child Background

Studies

Policy for Returning Home Study and Child Background Study

The Prospective Adoptive Parent(s) are required to submit a home study to the Central Authority of all adoption programs. The hom estudy is part of several docum ents required by the Central Authority that m ake up what is referred to as the doss ier, which is th e tota l com pilation of these documents. Great Wall China Adoption dba Children of A ll Nations makes every effort to submit the completed dossier to the Central Authority . In the event that, upon review of the dossier docum ents by the reviewing official at th e Central Authority, it is determined that the fa mily’s application for adoption will be rejected, it is GREAT WALL/CAN’s policy to request that the dossier be returned to our agency so that it can be returned to the Prospective Adoptive Parent(s) if that is their desire and it is within the scope of the policies and regulations of the Central Authority .

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Great Wall China Adoption dba Children of All Nations receives child background infor mation in the medical and growth report inform ation, proof of consents for the child’s adoptio n and necessary determination that the prospective placement is in the child’s best interest from the Central Authority. GREAT WALL/CAN sends the Prospective Adoptive Parent (s) child background infor mation upon receipt from the CCCWA. In the event that, the Prospective A doptive Parent(s) decides to decline the child referred, or decides to withdraw the adoption, it is GREAT WALL/CAN’s policy that Prospective Adoptive Parent(s) m ust return any original child background infor mation to the Central Authority through GREAT WALL/CAN 30 days after receiving this infor mation. If the inform ation was only provided via email, the PAP(s) are asked to delete/destroy this information.

Procedure for Returning Home Study

The following steps will be carried out in the ev ent that a Prospective Adoptive Parent(s)’ dossier and therefore, homestudy, is rejected by the Central Authority

A GREAT WALL/CAN Referral/Adoption Counselor will be notified by the Central Authority that upon review of the hom estudy and dossier docum ents, the fam ily’s application for adoption will be rejected.

The GREAT WALL/CAN Referral/Adoption Counselor will advocate for the family to have this decision over turned.

If it is s till the Central Authority’s decision to reject the fa mily, our GREAT WALL/CAN Referral/Adoption Counselor will request that the family’s dossier be returned to our agency, if that is the desire of th e PAP. If it is no t the desir e f or the doss ier to be retu rned, Great Wall/CAN will request the dossier be destroyed.

The family will be notified immediately or within 24 hours of the rejection of their dossier. Upon receipt of the h omestudy/dossier from the Central Authority , a GREAT WALL/CAN

Referral Co unselor will return the f amily’s documents to them via regular m ail within 3 business days. Family will also receive email notification that their homestudy/dossier has been received; this email notification will also include the date the dossier was mailed to the family.

Procedure for Returning Child Background Information to CCCWA The following steps will be carried out in the ev ent that a child transfer does not tak e place, and child background information shall be returned to China Center of Children’s Welfare and Adoption:

Prospective Adoptive Parent(s) are infor med that they are required to r eturn or dele te all th e child background information from the Central Authority af ter they hav e time to re view the information. The Prospective Adoptive Parent(s) ar e given two weeks. If m ore time is needed, the Prospective Adoptive Parent(s) will contact Referral Counselor for additional time to make decisions.

Upon receipt of returned child back ground information, GREAT WALL/CAN will re turn it to the Central Authority within 5 business days.

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If Prospective Adoptive Parent (s) disrupts while in country, GREAT WALL/CAN Referral/Adoption Counselor will c ontact the P rospective Adoptive Pare nt(s) immediately to request that child background information returned to the Central Authority.

GREAT WALL/CAN will docum ent all circum stances su rrounding the aforem entioned in the Prospective Adoptive Parent(s) records.