The Harold Hunter Foundation

“The organization's form 990 was provided to each voting member of its governing body, its board of directors, prior to filing with the internal revenue service ("irs"). The organization's board of directors has been delegated the responsibility to oversee and coordinate the form 990 preparation, review and filing process for the organization and its affiliate. As part of the tax return preparation process, the organization hired a professional cpa firm with experience and expertise in nonprofit tax return preparation to prepare the form 990. The cpa firm prepared a draft form 990 and furnished it to the organization's internal working group for review. The internal working group reviewed the draft form 990 and discussed questions and comments with the cpa firm. Revisions were made to the draft form 990 where necessary and a final draft was furnished by the cpa firm to the organization's internal working group for final review and approval. Following the internal working group's review and approval of the form 990, the form 990 was provided to each voting member of the organization's board of directors for review prior to filing with the irs.”

“The organization's 990 is available to the public upon request.”

“The organization has a written conflict of interest policy with which it regularly monitors and enforces compliance. The purpose of the policy is to protect the interests of the organization when it has entered into or is contemplating entering into a transaction or arrangement that might benefit a private interest of an interested person. Interested persons must disclose all conflicts of interest as defined in the policy, including those that might influence or be perceived to influence the actions or decisions of the interested person. Each interested person shall complete a conflict of interest disclosure form annually; however, such annual disclosures shall be supplemented promptly by additional written disclosures as required by this policy, i.e., when an actual or potential conflict of interest arises. All interested persons shall bring to the attention of/disclose to the organization any actual or perceived conflict of interest involving any other interested person, and any necessary mitigating behavior is taken at that time.”

“The organization's board of directors has a compensation committee ("committee") which is a standing committee. The committee reviews the "total compensation" of the organization's president/chief executive officer ("ceo") and other members of the senior management team which is intended to include both current and deferred compensation and all employee benefits, both qualified and non-qualified. The committee ensures that the "total compensation" of the president/ceo and members of senior management of the organization is reasonable by obtaining and relying upon "appropriate data as to comparability" prior to making its determination. The committee is comprised of members of the board of directors, each of whom are independent and are free from any conflicts of interest. The compensation committee shall determine the compensation of the president/ceo , it shall approve the compensation of staff officers and staff directors and it shall review and approve the compensation policies and practices for other staff personnel. The president shall participate in all matters that come before the compensation committee, except matters that relate to the president/ceo's compensation. The actions taken by the committee enable the organization to receive the rebuttable presumption of reasonableness for purposes of internal revenue code 4958 with respect to the total compensation of the president/ceo and the senior management team. The three factors which must be satisfied in order to receive the rebuttable presumption of reasonableness are the following: 1. The compensation arrangement is approved in advance by an "authorized body" of the applicable tax-exempt organization which is composed entirely of individuals who do not have a "conflict of interest" with respect to the compensation arrangement; 2. The authorized body obtained and relied upon "appropriate data as to comparability" prior to making its determination; and 3. The authorized body "adequately documented the basis for its determination" concurrently with making that determination. The committee is comprised of members of the board of directors each of who are independent and are free from any conflicts of interest. The committee relied upon appropriate comparable data; specifically the committee worked with a management consulting firm specializing in strategic planning, organizational development and human resource systems. Salary grades, which set compensation ranges, are periodically reviewed by this independent consultant, who compares those grades to industry averages for not-for-profits. Compensation for the president/ceo and the senior management personnel are set within the appropriate salary grades. The committee reports directly to the board of directors wherein all discussions at the committee level are documented in written meeting minutes of the full board of directors.”