Acton School of Business

“Jeff sandefer and john lawson have a business relationship.”

“The form 990 is provided to board members for review prior to filing. The board members direct any questions or comments to a designated staff member prior to a designated time.”

“Each fiscal year, all corporation representatives shall file with the secretary of the corporation a statement listing for the corporation representative and his or her spouse all directorships, memberships, or other relationships which might cause the individual to be biased or otherwise partial in any business or charitable matter involving the corporation. Such statements shall be filed within 30 days after the beginning of each fiscal year. The information provided in such statement will be used solely in the internal management of the corporation to effect the administration of its conflict of interest policy, and by providing the requested information, each corporation representative acknowledges understanding of this requirement and consents to this (and no other) use. All potential conflicts of interest shall be disclosed at the earliest possible time during any meeting or other proceeding at which a matter is to be considered involving an organization in which such a personal interest is held. When a conflict or potential conflict exists, the affected person shall abstain from voting or acting upon the pertinent item, withdraw from the meeting, and abstain from participating in or informally influencing the decision-making process except to provide factual information upon request. The corporation's president and executive director will monitor proposed or ongoing transactions for conflicts of interest and disclose them to the board of trustees.”

“1) independent review and approval: the compensation of the person is reviewed and approved by the board of trustees or compensation committee of the organization, provided that persons with conflicts of interest with respect to the compensation arrangement at issue are not involved in this review and approval. 2) comparability data: the compensation of the person is reviewed and approved using data as to comparable compensation for similarly qualified persons in functionally comparable positions at similarly situated organizations. 3) contemporaneous documentation and recordkeeping: there is contemporaneous documentation and recordkeeping with respect to the deliberations and decisions regarding the compensation arrangement.”

“The governing documents, conflict of interest policy, and financial statements are made available to the public upon request.”