The American Coalition Against a Nuclear Iran Inc

“The organization has its form 990 prepared by an independent accounting firm. It is then reviewed by the executive director and a complete copy is provided to all members of the organization's governing body for their review prior to filing.”

“The organization has a conflict of interest policy applicable to all directors, officers and key employees. 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 leaves 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 decide if a conflict of interest exists. After exercising due diligence, the board of directors or committee with board of directors delegated powers determines whether the organization 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 determines by a majority vote of the disinterested directors whether the transaction or arrangement is in the organization's best interest, for its own benefit, and whether it is fair and reasonable. In conformity with the above determination, the board or committee then makes 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 annually signs 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 deliverations are documented in the minutes of the board.”

“The organization has a compensation review policy which applies to the organization's chief executive, officers and key employees. The compensation of the chief executive and each officer and key employee is reviewed and approved by the board of directors or compensation committee of the organization, excluding those persons with conflicts of interest with respect to the compensation arrangement. The compensation of the chief executive and each officer and key employee is reviewed and approved using comparable compensation data of similarly qualified persons in functionally comparable positions at similarly situated entities. The deliverations and decisions are contemporaneously documented. The process last occured in 2021.”

“The organization's governing documents, conflict of interest policy, and financial statements are available on third party websites (such as guidestar.com) or upon request.”

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

“The organization contracted with a professional employer organization (peo) for services, including but not limited to, payroll, timekeeping, employee benefits, hr administration and workforce regulatory compliance needs. As the employer of record for tax purposes, forms w-2 and w-3 are issued by the peo and filed under the peo's federal ein. In this co-employment arrangement, the organization is the common law employer and, accordingly, compensation is reported on form 990, part vii, section a and part ix, lines 5-10.”

“Consulting and outside services: program service expenses 1,333,250. Management and general expenses 0. Fundraising expenses 0. Total expenses 1,333,250. Payroll service fees: program service expenses 9,314. Management and general expenses 18,907. Fundraising expenses 0. Total expenses 28,221. Strategic consultants: program service expenses 348,750. Management and general expenses 0. Fundraising expenses 0. Total expenses 348,750.”

“The organization has a finance committee responsible for the oversight of the audit of its financial statements and the selection of an independent accountant. The process has not changed from prior year.”