St. Francis College

“Relationship Disclosure William F. Dawson and Mary Beth Dawson have a family relationship.”

“Form 990 Review process The form 990 is prepared and reviewed internally by the finance department and forwarded to an independent accounting firm for external review. Once the review process is complete, the full 990 is provided to the audit committee for review and approval. Upon approval, a copy of the full 990 is provided to all board members prior to filing.”

“Conflict of interest policy enforcement and monitoring THE CONFLICT OF INTEREST POLICY IS DISTRIBUTED TO ALL FACULTY, STAFF, AND ADMINISTRATION EVERY YEAR. CERTAIN EMPLOYEES ARE REQUIRED TO SIGN THE QUESTIONNAIRE AND DISCLOSE ANY CONFLICTS. ALL MEMBERS OF THE BOARD OF TRUSTEES ARE REQUIRED TO REVIEW THE POLICY AND SIGN AND COMPLETE A QUESTIONNAIRE ON AN ANNUAL BASIS, DISCLOSING POTENTIAL CONFLICTS. THE EXECUTIVE COMMITTEE OF THE BOARD MONITORS AND ENFORCES COMPLIANCE. In the event a trustee, officer or key employee plans to initiate or participate in a transaction, arrangement or activity with or on behalf of the College in which he has a material financial interest of any nature, such person must disclose such interest to the Audit Committee of the College Board of Trustees (the "Committee") before commencing such activity. After disclosure of all relevant information, the disclosing person may make a presentation at the Committee meeting. After such presentation, the Committee shall, in absence of the disclosing person, discuss and vote on, the transaction, arrangement or activity and determine whether a conflict of interest exists. If the disclosing person is a member of the Committee, such person shall abstain from deliberations and voting, and the disinterested members of the Committee shall make the determination in absence of such person. The disclosing person shall not in any way improperly influence the deliberation or voting on the transaction, arrangement or activity giving rise to a potential conflict. The Committee will review all relevant information. The review process will be designed to protect confidential information to the degree permitted by law. The Committee will make a determination as to whether a situation is permissible or a conflict of interest exists, which shall be final, subject to ratification by the entire Board at its next meeting. If the Committee has reasonable cause to believe that a trustee, officer or key employee has knowingly failed to disclose an actual or possible conflict of interest, it shall inform such person of the basis for such belief and afford such person an opportunity to explain the alleged failure to disclose. If, after receiving the response of the individual and making such further investigation as may be warranted in the circumstances, the Committee determines that the trustee, officer or key employee has in fact knowingly failed to disclose an actual or possible conflict of interest, it shall take appropriate disciplinary action which may include a recommendation to the entire Board for the removal of the trustee or officer for the discharge of the key employee in accordance with the Bylaws and policies and procedures of the College and the laws of the State of New York.”

“Process for determining compensation Every two years The college engages an independent consultant to review and compare the compensation of top management to similar institutions in a compensation study. A compensation survey was performed regarding compensation of other officers. Compensation decisions and reports are contemporaneously documented in the board minutes when the decisions are made.”

“Public Disclosure of Documents THE AUDITED FINANCIAL STATEMENTS ARE AVAILABLE ON THE COLLEGE'S WEBSITE AT WWW.SFC.EDU. GOVERNING DOCUMENTS AND the CONFLICT OF INTEREST POLICY WILL BE MADE AVAILABLE UPON REQUEST at management's discretion.”