Harlem Commonwealth Council Inc.

“The Form 990 is prepared with direct input from the CFO and president and is reviewed by the audit committee and distributed to each board member before filing. Questions or comments are to be brought to the attention of the President and the Form 990 paid preparer.”

“The organization's written conflict of interest policies and annual updates apply to officers, directors and employees. Compliance is monitored through internal control procedures on an ongoing basis by the CFO and President. Restrictions are imposed on voting rights of board members or officers where participation in the governing body's deliberations and decisions could result in conflicts of interest.”

“Compensation of the Chief Executive Officer and President is reviewed and approved by the board of directors, and the compensation and finance committee. The organization refers to compensation data for similarly qualified persons in functionally comparable positions. Outside legal counsel's analysis/study of comparable salary levels is used. Contemporaneous documentation of deliberations and decisions regarding compensation contracts is maintained. There are employment contracts for the CEO/President. No other officers or employees receive annual compensation in excess of $75,000 from the organization, including related entities.”

“The organization makes its governing documents, conflict of interest policy and financial statements available to the general public upon request. Audited financial statements are provided to donors, potential donors and funding sources. All documents are available at the organization's executive office. Financial and program information is published on the organizations website.”

“The organization decided to redefine the method for delivering program services to the community within the Harlem area. All program services pertaining to (i) the training of entrepreneurs, (ii) granting of micro loans to small businesses (iii) mentoring youths to enter the workforce, and (iv) providing general and technical educational services to youths would be provided by HCC and HEF. The provision of services to the community in the form of making available land and building space to facilitate business ventures, with the objective of creating employment and promoting economic development, would be carried out by HCCs subsidiaries, which are more equipped to deal with leases and contracts through their own management and board of directors.”