Drexel University

“There are several trustees whom have consulting/business relationships with other members of the board.”

“In 2014, the drexel university college of medicine merged into drexel university. In 2017, the university learned that from 2003 to 2017, compensation was paid to an individual who, although classified as an employee, provided no services to the college of medicine or, after the merger in 2014, to the university. Compensation paid for which no services were provided totaled $828,676.98 over the 14-year period. The university terminated the individual after learning of the diversion and is seeking repayment. Key persons believed to have relevant information about this isolated incident have since passed away or are no longer associated with the university. The university has worked with outside counsel and an external audit firm to develop and implement a corrective action plan to ensure that such an incident will not recur in the future. Among other things, the corrective action plan requires a complete assessment of the university's current employee roll, training programs for supervisors, and an annual supervisor's certification as to the valid employment status of each employee.”

“Form 990 is prepared by the tax office and submitted to the executive vice president, treasurer and chief operating officer for review and signing. Prior to filing, form 990 and all required schedules ultimately filed with the internal revenue service were available to each member of the board of trustees for their review and comment.”

“Drexel university's conflict of interest policy applies to all employees (whether a key employee or not), officers, and trustees of the university. The conflict of interest policy is intended to satisfy compliance requirements and guide university personnel in avoiding those situations that can result in a conflict of interest or commitment. The key to avoiding those situations that can result in a conflict of interest or commitment is to make constituents aware of what constitutes a conflict of interest and for them to disclose potential situations before the activity is undertaken. The format for the disclosure is for each employee, officer or trustee to complete a questionnaire annually. The completed questionnaire is submitted to the human resources department in the case of employees reviewed as required by the compliance, privacy and internal audit officer. Completed questionnaires for officers and trustees are submitted directly to the office of the general counsel for review. After review a determination is made as to whether a conflict of interest exists and at what level. Those employee conflicts that are determined to be detrimental to the university are discussed with the employee and the employee is encouraged to terminate the activity. Employees who willingly or otherwise continue to violate the conflict of interest policy are subject to disciplinary action up to and including suspension without pay, demotion or termination of employment. In the case of trustees, a conflict of interest questionnaire is mailed annually. Trustees are required to complete the questionnaire and disclose any interests in any corporation, partnership or other organization in which they own or control 5% or more of the entity. It is the policy of the university not to contract with or enter into a commercial relationship with any trustee or corporation, partnership, proprietorship or other organization in which such trustee has an interest as an officer, director, partner, employee, owner, or controlling stockholder.”

“Drexel is committed to compensating its executive team at a fair and competitive level. To meet this goal, drexel university's human resources department prepares an executive compensation analysis annually using the college and university professional association of human resources (cupa) survey and irs form 990 information as they relate to the university's peer groups. Positions included in the analysis were the president, executive vice presidents, senior vice presidents, and highly-compensated deans. Using the executive compensation analysis, a third-party advisor prepared a report and submitted the report to the executive compensation committee of the board of trustees (the "committee") along with certain performance criteria. The compensation analysis served as the basis for the president's recommendations for university executives. The third-party advisor provided the committee with a letter on the appropriateness of the decision-making process and reasonableness of the proposed compensation. All compensation was approved by the executive compensation committee of the board of trustees prior to becoming effective on july 1, 2017.”

“Drexel university makes its governing documents, conflict of interest policy and financial statements available to the public in a variety of ways. The conflict of interest policy and financial statements are available on its website, and its governing documents are available upon request.”

“The university implemented a written procedure, which was approved by the president's cabinet, for evaluation of joint venture arrangements to ensure that such arrangements are consistent with the university's tax-exempt purpose.”

“NOT APPLICABLE”

“The audit committee of the board of trustees has responsibility for selecting the independent accountant and overseeing the audit. This process has not changed from the prior year.”