The American Coalition Against a Nuclear Iran Inc

“Form 990 will be completed annually, and copies will be provided to the entire governing board. At that time, the chief executive officer will review form 990 with the designated committee. Any necessary changes will then be updated on form 990. Once all necessary changes are made and the chief executive officer is in agreement with the committee on the finished form 990, a copy of the approved form 990 will be provided to all of the officers and directors before the return is filed. The form 990 will be signed by the chief executive officer, dated, and submitted by the filing deadline.”

“The organization's conflict of interest policy is applicable to all directors, officers and key employees (if any). In connection with any actual or possible conflict of interest, an interested person must disclose on an ongoing basis the existence of any potential conflict and be given the opportunity to disclose all material facts to the directors and members of committees with board of directors delegated powers considering the proposed transaction or arrangement. After disclosure of the financial interest and all material facts, and after any discussion with the interested person, he/she shall leave the board of directors or committee with board of directors delegated powers meeting while the determination of a conflict of interest is discussed and voted upon. The remaining board or committee members shall decide if a conflict of interest exists. After exercising due diligence, the board of directors or committee with board of directors delegated powers shall determine whether the corporation can obtain with reasonable efforts a more advantageous transaction or arrangement from a person or entity that would not give rise to a conflict of interest. If a more advantageous transaction or arrangement is not reasonably possible under circumstances not producing a conflict of interest, the board of directors or committee with board of directors delegated powers shall determine by a majority vote of the disinterested directors whether the transaction or arrangement is in the corporation'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 transaction or arrangement. Each director, principal officer and member of a committee with board of directors delegated powers shall annually sign a statement which affirms such person has received a copy of the conflict of interest policy, has read and understands the policy and has agreed to comply with the policy. All decisions and deliberation are documented in the minutes of the board.”

“This compensation review policy applies to the organization's chief executive, officers and key employees (if any). The compensation of the chief executive and each officer, key employee or disqualified person was reviewed and approved by the board of directors or compensation committee of the corporation, provided that directors or other persons with conflicts of interest with respect to the compensation arrangement at issue shall not be involved in this review and approval. The compensation of the chief executive and each officer, key employee or disqualified person was reviewed and approved using data as to comparable compensation for similarly qualified persons in functionally comparable positions at similarly situated entities. There is contemporaneous documentation and recordkeeping with respect to the deliberations and decisions regarding the compensation arrangement. The board of directors or compensation committee evaluating such compensation arrangement may, but shall not be required, to use the "rebuttable presumption checklist or other tools set forth in the introduction to i.r.c. 4958. This process last occured in 2019.”

“The governing documents, conflict of interest policy, and financial statements are available on acani's website or upon request.”

“Compensation reported to robert benton on part vii, column (e) was for legal services provided and not for services in his capacity as secretary of the organization.”

“Consulting and outside services: program service expenses 1,735,588. Management and general expenses 0. Fundraising expenses 0. Total expenses 1,735,588. Payroll service fees: program service expenses 1,640. Management and general expenses 3,330. Fundraising expenses 0. Total expenses 4,970. Strategic consultants: program service expenses 405,000. Management and general expenses 0. Fundraising expenses 0. Total expenses 405,000.”

“Acani has a finance committee that is responsible for the oversight of the audit and selection of the independent auditor.”