Wheaton College

“Austin Simko and Benjamin Clark White have a business relationship.”

“The college's Form 990 is prepared by the Finance Office of the college and reviewed by the Executive Vice President for Finance and Administration. In addition, the Form 990 is reviewed and signed by an independent accounting firm. The first draft is reviewed by the Audit Committee of the Board of Trustees and any changes are incorporated into the final draft. The final draft is distributed to the full Board of Trustees via their secure website for final review prior to submission to the IRS. The draft provided to the Audit Committee of the Board of Trustees and to the full Board agrees to what was filed with the IRS with the exception of Schedule B, which was omitted. Schedule B is reviewed by the Chair of the Board, the Chair of the Audit Committee and the Chair of the Philanthropy Committee.”

“All trustees and officers of the college are covered in the Wheaton College Conflict of Interest Policy for Trustees and Officers. The policy and conflict of interest disclosure statement is sent to all officers and trustees on an annual basis. The completed forms are reviewed by the Chair of the Board of Trustees, the Executive Vice President for Finance and Administration and the President, who determine if an actual or potential conflict exists. Officers and trustees recuse themselves from discussion and voting on any matters where a conflict exists.”

“The Wheaton College Executive Committee, a subcommittee of the Board of Trustees, is composed independent members and establishes compensation for the President and other officers to ensure that the Internal Revenue Code provision of "rebuttable presumption of reasonableness" is met and "intermediate sanctions" are not incurred. The Executive Committee obtains and relies upon appropriate data regarding comparability of the compensation package prior to making its determination. Appropriate data includes compensation levels paid by similarly situated organizations, independent compensation surveys by nationally recognized independent firms, and written offers from similar institutions competing for the services of the individual. The Executive Committee documents the basis for its determinations including: the terms of the approved transaction and date approved; the members of the committee who were present during the discussions; and the data obtained and relied upon.”

“The employee conflict of interest policy is contained in the Staff Handbook, which is posted to the college's Human Resources website and available to the public. The college's audited financial statements are posted to the college's Finance website, which is available to the public. In addition, the Form 990 and the audited financials are available via the Massachusetts Attorney General's website. The governing documents and trustee conflicts of interest policy are available to the public upon request.”

“In regards to the non-independent individuals identified: The President of the college is an ex officio member of the Board of Trustees and enjoys all rights and privileges, including voting, of term trustees except that his vote shall not be counted if such vote would have been the deciding vote for matters brought before the Board of Trustees for actions.”

“The total number of employees includes faculty and staff of 745 and student employees of 1,047.”