Wellesley College

“Form 990 review form 990 was prepared by an outside public accounting firm and reviewed by the college's finance office. The audit committee of the board of trustees reviews form 990 and all required schedules prior to filing with the internal revenue service. Form 990 and all required schedules are also distributed to the full board of trustees before filing.”

“Form 990 provided to governing body the college has distributed form 990 to the full board of trustees with the exception of donor information on schedule b. Because of schedule b's private and confidential nature, the college has chosen not to disclose the identities and addresses of its donors. As such, we are required to answer the question on line 11a "no" even though the board receives all of form 990 except for donors' names and addresses.”

“Monitoring and enforcement of conflict policy conflict of interest policies are in place for trustees, officers, external investment committee members, and all employees. Trustees and officers are required to disclose - at least as often as annually and whenever a potential conflict issue arises - financial or personal interests which may give rise to conflicts. The clerk of the board of trustees provides an annual report to the trustees summarizing the conflict or potential conflicts issues. At least annually, the trustees review the college's relationships with significant vendors or service providers serving the college to assure that such relationships are in the best interest of the college and are otherwise consistent with the terms of the conflict of interest policy.”

“Compensation review and approval the compensation of the president and other officers of the college is determined by the compensation committee, a subcommittee of the board of trustees. The compensation committee of the board of trustees utilizes independent external consultants to assist with both the review of compensation guidelines and the gathering of comparability data in determining the reasonableness of compensation and compliance with the procedures described in treasury regulation section 53.4958-6, including contemperaneous documentation of compensation decisions. Key employees are compensated based upon the guidelines the college has for administrative and faculty employees. These guidelines include review of the market by looking at salaries for comparable positions as well as a merit program based on performance. Compensation decisions are made by persons who are independent of the employees for whom the compensation is being determined.”

“Availability of documents a copy of the business conduct policy which includes the conflict of interest policy is given to all new employees upon hire. Both the business conduct policy and the financial statements are available on the college's website. The college's organizing documents are available upon request.”

“Swap gain/loss 6,442,084. Pension related changes 15,612,422.”