The Devereux Foundation

“Form 990 is provided in hard-copy or electronically to all Board members in advance of the filing deadline. Board members are requested to provide comments or questions to the CFO. The comments are reviewed by the CFO, who directs the response to all Board questions, and where appropriate, directs changes to be made to the Form 990.”

“Representatives of Devereux dealing with clients, parents, guardians, vendors, competitors or anyone who does or seeks to do business with Devereux are required to act in Devereux's best interests, disregarding any personal preference or advantage. Representatives shall make prompt and full disclosure to his/her manager and to the Internal Audit Department (and, in the case of Trustees and senior managers, to the Board's Audit and Compliance Committee) via the Devereux Conflict of Interest form of any prospective or actual situation that involves, may involve, or might appear to involve a conflict of interest. Members of the same family or living within the same domicile may be employed by Devereux in the same center or department unless the center Director or department head determines such employment is not in Devereux's best interest. Relatives of senior management or trustees, as well as those working in Human Resources, Payroll, and Internal Audit, shall not be hired by Devereux in any capacity unless approved in advance by the President/CEO. Each Devereux employee has the responsibility to report any actual or perceived conflicts of interest to management, People Operations, Chief Risk and Safety Officer, or the Employee Helpline. The Helpline is an anonymous "whistleblower service", where complaints are processed by an independent third party retained by Devereux for this purpose and subsequently referred to the Chief Risk and Safety Officer. Annually, a copy of Devereux's business ethics policy is mailed or e-mailed to trustees, officers, directors and key personnel along with the annual Conflict of Interest Disclosure Statement, which must be signed and returned to the Chief Risk and Safety Officer within 30 days. The annual disclosure requires an acknowledgement of understanding Devereux's business ethics policy, as well as disclosure of any conflict, or appearance of a conflict, between personal interests and the interests of Devereux. Failure to comply or falsification of disclosure may result in disciplinary action, including possible dismissal. Newly-hired employees in the categories identified above are given this policy on the first day of their employment and are required to complete the annual Conflict of Interest Disclosure Statement immediately. All employees disclosing a conflict or potential conflict must have the Disclosure Statement reviewed and signed by the Executive Director at their location (President/CEO for Corporate staff) prior to sending it to Audit Services. All Annual Conflict of Interest Disclosure Statements identifying a conflict or potential conflict are reviewed by the Chief Risk and Safety Officer and any other officers or senior management determined to be appropriate, and submitted to the Audit & Compliance Committee of the Board of Trustees for review. No Disclosure Statement may be reviewed by the person submitting it or by a person directly supervised by the person submitting the report.”

“Devereux reviews officersExecutive Directors' salaries against the market on an annual basis. Oversight of this process is by the People Operations Committee of the Board of the sole member. During this benchmarking process, the Senior Vice President of People Operations conducts a review of salaries for benchmark positions for which there is sufficient market survey data and is focused on nonprofit competitors. Additionally, Form 990s of other comparable organizations are also reviewed on an annual basis from an analysis compiled by the Controller. Devereux's market for this salary review is primarily focused on similarly sized organizations (budget, number of employees, revenue) in the behavioral health industry and structure (system vs. single entities). The results of the review conducted are periodically validated by an outside compensation consultant.”

“Devereux's Form 990 is available to the public through posting on Guidestar (www.guidestar.org). It is also available upon request. The Audited Financial Statements are available through public disclosure websites since the organization has publicly traded debt. Devereux does not make its governing documents or conflict of interest policy available to the general public outside of this Form 990.”

“The sole member of The Devereux Foundation (TDF) is Devereux Corporation (DC). DC has the ability to appoint trustees/directors of TDF. Certain governance decisions of TDF need to be ratified by DC. Additionally, the Audit and Compliance Committee of DC oversees the audit of the entire consolidated organization.”

“The other changes in net assets or fund balances are due to intercompany net asset transfers.”