Bellwether Education Partners Inc.

“Once the form 990 is complete, it is sent to mary wells, president, as well as to the board members comprising the audit committee. The 990 is reviewed and notes and questions are discussed. The 990 is then circulated to the full board prior to filing.”

“This question could be answered "yes" for all officers and directors. However, the question was answered "no" because, as noted in question 12c, key employees were not included in the definition of an interested person during the current year, and as such, there was no required annual disclosure of conflicts or potential conflicts by key employees (despite the fact that key employees were covered under a separate conflict of interest policy in the organization's employee handbook). The organization amended the policy described below in question 12c as of october 2014 to include those employees meeting the irs definition of a "key employee", and to require annual disclosure of such conflicts or potential conflicts.”

“In connection with any actual or possible conflict of interest, directors, officers and members of a committee with governing board delegated powers who have a direct or indirect financial interest (i.e. Interested person) have a duty to disclose and shall fully disclose the existence of the financial interest and all material facts to the directors and members of committees with governing board delegated powers considering the proposed transaction or arrangement. Upon disclosure of a possible conflict of interest and all material facts and after discussion with the interested person he or she shall leave the governing board or committee meeting while the determination of a conflict of interest is discussed and voted upon. The remaining board or committee members determine if a conflict of interest exists. The minutes to the governing board and all committees with board delegated powers shall contain the names of persons who disclosed or were found to have a financial interest in connection with an actual or possible conflict of interest, the nature of the interest, any action taken to determine whether a conflict of interest was present and the decision as to whether the conflict of interest exists. Each director, principal officer and member of a committee with governing board delegated powers shall annually sign a disclosure statement which affirms each person has received a copy of the conflict of interest policy, has read, understands and has agreed to comply with the policy.”

“Bellwether education partners hired an outside consulting firm to prepare a compensation study in 2011 (which will be updated in fy15) to ensure that salaries for the president, all partners and treasurer were reasonable and comparable with other institutions in the same industry. Once the salaries were established, the board of directors reviewed and approved. All data, deliberations and decisions were documented contemporaneously. Those members of the board whose salary was being determined did not participate in the review or approval. Current year salary adjustments were approved by the board as part of the budget process.”

“The organization provides copies of the governing documents, conflict of interest policy & financial statements upon request. Contact information is available on the organization's website.”

“Administration/back office support: program service expenses 26,412. Management and general expenses 4,000. Fundraising expenses 0. Total expenses 30,412. Professional services-project subcontractors, writing, consulting: program service expenses 722,723. Management and general expenses 166,828. Fundraising expenses 0. Total expenses 889,551. Payroll services fees: program service expenses 43,092. Management and general expenses 3,881. Fundraising expenses 2,139. Total expenses 49,112.”