Peirce College

“FORM 990, PART VI, LINE 11B THE FORM 990 WAS PREPARED BY A NATIONALLY RENOWNED ACCOUNTING FIRM IN CONJUNCTION WITH THE ORGANIZATION'S FINANCIAL DEPARTMENT. THE FORM IS THEN SUBMITTED TO THE AUDIT, RISK & COMPLIANCE MANAGEMENT COMMITTEE OF THE BOARD FOR APPROVAL. A COPY OF THE DRAFT 990 IS THEN CIRCULATED TO THE FULL BOARD OF TRUSTEES FOR DISCUSSION AND COMMENT ON THE INFORMATION CONTAINED IN THE 990 PRIOR TO ITS FILING WITH THE INTERNAL REVENUE SERVICE. Conflict of Interest Policy Monitoring & Enforcement Form 990, Part VI, Line 12c THE COLLEGE REQUIRES EACH EMPLOYEE INCLUDING THE PRESIDENT/CEO AND OTHER KEY EMPLOYEES TO COMPLETE AND SIGN A WRITTEN CONFLICTS OF INTEREST STATEMENT THAT INCLUDES QUESTIONS THAT CAN DETERMINE IF THE EMPLOYEE HAS A RELATIONSHIP, FINANCIAL INTEREST OR BUSINESS AFFILIATION THAT RESULTS IN A CONFLICT OF INTEREST. THESE STATEMENTS ARE COMPLETED ANNUALLY BY THE EMPLOYEE AND AT ANY TIME AN EMPLOYEE BECOMES AWARE OF FACTS WHICH REQUIRE AN ADDITIONAL OR UPDATED DISCLOSURE. THESE STATEMENTS ARE RETURNED TO HUMAN RESOURCES FOR REVIEW AND IF NECESSARY FURTHER ACTION MAY BE REQUIRED. THE COLLEGE ALSO REQUIRES EACH TRUSTEE INCLUDING TRUSTEE OFFICERS TO COMPLETE AND SIGN A CONFLICT OF INTEREST QUESTIONNAIRE THAT CAN DETERMINE IF THE TRUSTEE HAS A RELATIONSHIP, FINANCIAL INTEREST OR BUSINESS AFFILIATION THAT RESULTS IN A CONFLICT OF INTEREST. THESE QUESTIONNAIRES ARE COMPLETED ANNUALLY BY EACH TRUSTEE AND RETURNED TO THE BOARD SECRETARY AND ARE REVIEWED BY THE OFFICE OF THE PRESIDENT AND IF NECESSARY FURTHER ACTION MAY BE REQUIRED. IF A CONFLICT OF INTEREST IS IDENTIFIED, THE FOLLOWING PROCEDURES ARE FOLLOWED: (A) AN INTERESTED PERSON MAY MAKE A PRESENTATION AT THE BOARD OR COMMITTEE MEETING, BUT AFTER THE PRESENTATION, HE/SHE SHALL LEAVE THE MEETING DURING THE DISCUSSION OF, AND THE VOTE ON, THE BUSINESS RELATIONSHIP INVOLVING THE POSSIBLE CONFLICT OF INTEREST. (B) THE CHAIRPERSON OF THE BOARD OR COMMITTEE SHALL, IF APPROPRIATE, APPOINT A DISINTERESTED PERSON OR COMMITTEE TO INVESTIGATE ALTERNATIVES TO THE PROPOSED BUSINESS RELATIONSHIP. (C) AFTER EXERCISING DUE DILIGENCE, THE BOARD OR COMMITTEE SHALL DETERMINE WHETHER THE COLLEGE CAN OBTAIN WITH REASONABLE EFFORTS A MORE ADVANTAGEOUS BUSINESS RELATIONSHIP FROM A PERSON OR ENTITY THAT WOULD NOT GIVE RISE TO A CONFLICT OF INTEREST. (D) IF A MORE ADVANTAGEOUS BUSINESS RELATIONSHIP IS NOT REASONABLY POSSIBLE UNDER CIRCUMSTANCES NOT PRODUCING A CONFLICT OF INTEREST, THE BOARD OR COMMITTEE SHALL DETERMINE BY A MAJORITY VOTE OF THE DISINTERESTED TRUSTEES WHETHER THE BUSINESS RELATIONSHIP IS IN THE COLLEGE'S BEST INTEREST, FOR ITS OWN BENEFIT, AND WHETHER IT IS FAIR AND REASONABLE. IN CONFORMITY WITH THE ABOVE DETERMINATION, IT SHALL MAKE ITS DECISION AS TO WHETHER TO ENTER INTO THE BUSINESS RELATIONSHIP. DECISION AS TO WHETHER TO ENTER INTO THE BUSINESS RELATIONSHIP.”

“Form 990, Part VI, Line 15a THE COMPENSATION FOR THE PRESIDENT OF PEIRCE COLLEGE WAS BASED ON WORK DONE BY AN OUTSIDE CONSULTING FIRM COMMISSIONED BY THE BOARD OF TRUSTEES. THE COMPENSATION DATA WAS COMPILED USING INFORMATION FROM OTHER COLLEGES AND UNIVERSITIES AS A GUIDE IN DETERMINING THE COMPENSATION OF THE PRESIDENT. Process for Determining Compensation Form 990, Part VI, Line 15b THE COMPENSATION FOR THE KEY EMPLOYEES OF PEIRCE COLLEGE WAS DETERMINED BY LOCAL AND REGIONAL MARKET SURVEYS AND INFORMATION AND DATA FROM LOCAL AND REGIONAL PUBLICATIONS AND PAPERS. THIS INFORMATION, ALONG WITH INTERNAL EQUITY, DETERMINED THE BASIS HIRE-IN SALARY OF KEY EMPLOYEES. ANNUALLY, KEY EMPLOYEES ARE EVALUATED BY THE PRESIDENT USING A PERFORMANCE MANAGEMENT DOCUMENT (PMD) WHICH IS A STANDARD REVIEW USED BY ALL MANAGERS AND SUPERVISORS THROUGHOUT THE COLLEGE. THE PMD FOR EACH KEY EMPLOYEE IS ALSO REVIEWED BY HUMAN RESOURCES TO ENSURE EQUITY WITHIN THE COLLEGE. THIS PROCESS ALSO DETERMINES THE PERCENT OF MERIT INCREASES RECEIVED. THE MERIT INCREASE PERCENTAGES ARE DETERMINED AS PART OF THE BUDGET PROCESS AND THE LEVEL OF PERCENTAGE INCREASES GIVEN TO THE KEY EMPLOYEES IS BASED ON THE SCORING OUTCOME OF THEIR PMD. ONCE THE MERIT INCREASES FOR THE KEY EMPLOYEES ARE DETERMINED AND APPROVED BY THE PRESIDENT, THE BOARD OF TRUSTEES IS INFORMED OF THE INCREASES.”

“Form 990, Part VI, Line 19 THE COLLEGE MAKES ITS FORM 990 AVAILABLE TO THE PUBLIC BY RESERVING A COPY AT ITS PLACE OF BUSINESS. THE FORM 990 IS LIKEWISE PUBLISHED ON THE INTERNET AT WWW.GUIDESTAR.ORG. THE ORGANIZATION'S GOVERNING DOCUMENTS AND CONFLICT OF INTEREST POLICY ARE NOT ORDINARILY MADE AVAILABLE TO THE PUBLIC, BUT, IF REQUESTED, WILL BE PROVIDED AT MANAGEMENT'S DISCRETION.”

“Form 990, part XI, line 9 CHANGE IN BENEFICIAl INTEREST IN TRUST HELD BY THIRD PARTY $1,358 REIMBURSEMENT CONTINGENCY FORM 990, PARTS X During fiscal year 2011, the College accrued an amount related to a contingency for a potential reimbursement due to a Commonwealth of Pennsylvania agency. The College is in the process of clarifying the agency's findings and claims. Once they are determined, the College expects to negotiate appropriate settlement terms with the agency. Since the initial accrual, the agency has lowered the expected reimbursement from the college. The College has not remitted any funds to the agency as of the submission date of this tax return and believes it is possible some reimbursement may be required. The accrued contingency can be found in other liabilities in Part X.”