Valeo Foundation

“The CFO reviews the 990 before submission. The CEO and Board of Directors are provided a copy of the 990 for review before submission.”

“All new Board Members are required to review and sign a "Conflict of Interest" policy. On an annual basis, all Board members are required to review and complete an "Officer, Director and Key Employee Relationship Questionnaire." All Valeo employees are required to review and sign the Code of Ethics policy, which addresses conflicts of interests. Conflicts of interests are reported to the Risk Management team through Human Resources or Valeo's complaint process. The Risk Management team investigates the conflict and appropriate disciplinary action up to termination may occur.”

“The Board of Directors hired an independent HR consulting firm in 2008 to conduct a salary survey for comparable compensation for similarly qualified person in functionally comparable positions at similarly situated organizations. The compensation arrangement is evaluated by the Valeo BHC Board during the annual performance review period which coincides and is in accordance with Valeo's HR Practices for all employees. The CEO and/or Human Resources department determined the CFO salary based on both internal and external information for comparable compensation for similarly qualified person in functionally comparable positions at similarly situated organizations. The compensation arrangement is evaluated during the annual performance review period which coincides and is in accordance with Valeo's HR Practices for all employees.”

“Valeo makes its governing documents, conflict of interest policy and financial statements available to the public upon request to the Chief Financial Officer at 785-228-3077.”