Acumen Fund Inc.

“The organization utilizes adp totalsource, a professional employer organization ("peo"). As a professional employer organization, totalsource provides professional employer services to acumen fund, inc. (acumen). In the peo relationship totalsource and acumen share certain responsibilities and allocate other employer responsibilities between each other. Acumen remains an employer of the worksite employees and totalsource is a co-employer of acumen's employees. Acumen has: - direction and control over employees as is necessary to conduct its business, discharge any fiduciary responsibility it may have, or comply with any applicable licensure, regulatory or statutory requirement of acumen. - control over the day to day job duties of employees and over the job sites at which, or from which employees perform services totalsource reserves a right of direction and control over employees as is necessary to fulfill its obligations and provide its services under an agreement between acumen and totalsource. Totalsource and acumen have a right to hire, discipline, and terminate employees as to each one's employment relationship with employees. The total amount of service fee paid to adp totalsource for the tax year ending 12/31/20 is $168,754.”

“The organization's finance staff members prepare the form 990 in conjunction with the organization's external independent accountants. Several senior management and internal legal staff members review the information and a draft form 990 is circulated electronically by e-mail to the board of directors. After soliciting the board's feedback and comments, the form 990 is e-filed with the irs.”

“The organization has a conflict of interest policy which is annually monitored, requiring all of the organization's or its affiliates' board members, members of the investment committee, officers, key employees, and each of their respective relatives to disclose any financial interest that may be an actual or possible conflict of interest to the general counsel, subject to review by the audit & finance committee of the board. Such disclosures involving a transaction or arrangement are reviewed by the general counsel, with oversight by the president, and, if over a certain threshold, referred to the audit & finance committee to determine appropriate action to be taken to address the conflict of interest with respect to the transaction or arrangement. The individual with the conflict of interest is required to disclose the conflict and recuse him/herself from the discussion and not be present during any deliberation or vote on matters where he/she has an actual conflict. A disinterested person may be appointed to investigate alternatives to the proposed transaction or arrangement, and the audit & finance committee shall determine if acumen can obtain with reasonable efforts a more advantageous transaction or arrangement that would not give rise to a conflict of interest, and if not, if the transaction or arrangement is in acumen's best interest for its own benefit and fair and reasonable. Additionally, the organization requires all such individuals to promptly and fully disclose all material facts of any actual or potential conflict of interest that may exist at the time of hire or appointment, as applicable, and as they may arise while the individual is serving or employed in such capacity by the organization. Such disclosures are reviewed by the general counsel, with oversight by the president and/or other members of senior management, and the audit & finance committee, where appropriate, to determine appropriate action to be taken, which, if advisable, may include information firewalls, oversight by disinterested persons and/or discouragement of the activity.”

“The organization annually reviews comparable compensation data for its non-profit peer group and similar organizations in the for-profit private sector. Acumen talent benchmarks against these comparative figures when setting compensation for its chief executive officer and president. The organization will also consider job performance when evaluating ceo compensation. The compensation committee recommends and then the board of directors discusses and approves, in executive session, the compensation information and determines the ceo and president's salaries. The compensation committee is composed solely of board members who do not have a conflict of interest in determining the salary of the ceo. Any board members who are conflicted in determining the ceo's compensation are recused from the portion of the meeting where the ceo's compensation is discussed and determined. Minutes documenting both the activities and actions of the compensation committee and the board of directors, including the materials they used in evaluating compensation, are taken and retained contemporaneously. The ceo, in consultation with the president and director of talent, determines salaries of the other members of senior management of the organization using the same processes as described above.”

“The organization posts its form 990 and audited financial statements on its publicly accessible website www.acumen.org. Current year information is posted as it becomes available and two prior year's results are maintained online. The organization also provides its information to charity navigator and guidestar.org. Public information about acumen is available on the website of the nys attorney general charities bureau, as well as upon request. The form 1023 is made available upon request. The governing documents are made available to the public upon specific request, and a summary of the conflict of interest policy is available on the form 990. The organization makes it governing documents, conflict of interest policy, form 990 and financial statements available to the public upon request for the same period of disclosure as set forth in section 6104(d). In addition, the form 990 without schedule b is available via a link on our website to the profile on guidestar.”

“Foreign currency translation loss 73,517. Change in value of charitable remainder trust 17,451. Asset transfers -361,307.”