Yeshiva Endowment Foundation Inc.

“The yeshiva endowment foundation's form 990 was reviewed and signed by an independent accounting firm based on a draft prepared by yeshiva university's finance department and director of tax. The draft return was reviewed by the yeshiva university's audit committee and the foundation's cfo and general counsel. The final version of the form 990 was made available to the foundation's board of trustees prior to filing with the internal revenue service. The form 990, as filed, is made available to the public in accordance with internal revenue service rules and regulations.”

“The foundation's conflict of interest policy applies to all members of the foundation's board of trustees, board committee members and its officers and employees ("covered persons"). The policy provides that covered persons are to act at all times in a manner consistent with their responsibilities to the foundation and yeshiva university and avoid circumstances in which their financial or other ties to outside entities could present an actual, potential or apparent conflict of interest or impair the foundation or the university's reputation. Further, all covered persons are not to engage in business with the foundation or the university. In the case of a rare exception, a governance committee has been established to review the facts and, if it is in the foundation or the university's best interests, approve such exceptions. Conflict waiver requests considered by the committee, whether or not approved, are reported to the board of trustees. Questions as to whether a transaction constitutes a related party transaction with respect to covered persons are resolved by the governance committee and the president of the university in consultation with the general counsel. Covered persons are required to complete, sign and submit to the general counsel an annual disclosure statement; to promptly notify the general counsel of any change in the information previously reported on such person's disclosure statement; and to furnish supplemental information and/or confirm the continued accuracy of the current disclosure statement, if requested by the general counsel. The board, in consultation with the general counsel, has the authority to address non-compliance with the disclosure requirements or any other provision of the conflict of interest policy; and may recommend the removal of such non-complying covered person or other appropriate sanction. In addition, a covered person who believes a current, pending or proposed transaction would constitute a realted party transaction or otherwise constitute an actual, potential or apparent conflict of interest, is required to promptly disclose to the general counsel and to the chair of each board and committee of which the covered person is a member, the existence of the conflict (or appearance of conflict) and other material information that the covered person may have regarding the transaction. New covered persons are provided with a copy of the conflict of interest policy and disclosure statement. The details of the policy and its requirements are reviewed with them. The general counsel maintains a database of disclosure statements and a system for monitoring current, pending and proposed transactions for potential interested transactions based on the disclosures made in each covered person's annual disclosure statement and any periodic updates submitted pursuant to the policy. In addition to the conflict of interest policy above for covered persons, any foundation employees would also be subject to additional conflict of interest reporting requirements as set forth in the employee handbook.”

“The yeshiva endowment foundation has no paid officers, employees or board members. However, its officers are paid by yeshiva university, a related entity. Their compensation is reviewed in accordance with the following yeshiva university procedures: the compensation of all employees earning in excess of a specified threshold salary level, as well as all of yeshiva university's officers and key employees, is reviewed by yeshiva university's compensation committee of the board of trustees. The independent members of the committee conduct a detailed review and approval of such compensation utilizing comparability data from third party salary surveys, form 990 salary disclosures from other organizations, and/or compensation studies prepared by an independent third party consulting firm. Contemporaneous documentation of the committee's deliberations and decisions are included in the committee's written minutes. In addition, in accordance with irs rules and regulations, the university received opinions from independent third party compensation consultants that the compensation of the yeshiva's officers and key employees are reasonable.”

“The foundation does not currently make its governing documents or conflict of interest policy available to the public. The foundation does make its form 990 available to the public in accordance with internal revenue service rules and regulations.”

“The eight life members of the foundation have the power to elect the foundation's board of directors.”