Center for American Progress

“Glenn hutchins and jonathan lavine are business partners. Additionally, john podesta has consulting agreements with both hansjorg wyss and susan sandler.”

“The finance department worked directly with an independent accounting firm to prepare the federal form 990 on behalf of cap. The finance department manages the process, with close coordination with the legal department. The accounting firm provided a draft federal form 990, which was then reviewed and commented on by the finance department, the legal department and the corporate officers. The updated draft federal form 990 and summary materials were then provided to the audit committee of the board of directors for review and consideration on behalf of the full board of directors. The audit committee was offered the opportunity to discuss the materials with cap's staff and the accounting firm that prepared the federal form 990. The audit committee approved the draft federal form, and the full board of directors received the approved version of the form before filing with the internal revenue service.”

“Cap is committed to preventing outside financial interests of its board members, officers or employees from influencing its activities. To that end, it has adopted and enforces policies to prevent conflicts of interest and the appearance of conflicts of interest, including separate policies governing (1) officers, directors, and key employees; and (2) all employees. Compliance with policies governing officers, directors and key employees. Officers, directors and key employees (if any) receive a copy of the conflict of interest policy annually, and are asked to review the policy and sign an acknowledgement affirming receipt, review and agreement to comply with the policy, as well as understanding that cap is a charitable organization. In addition, officers, directors and key employees are asked to complete an annual independence questionnaire, which seeks disclosure of certain relationships, arrangements and transactions in order to determine independence and the existence of conflicts of interest. These policies describe potential conflicts, provide means for disclosure, and provide processes for investigating and resolving potential conflicts.”

“It is the policy of cap that the president submits his or her recommendations for compensation of newly hired senior managers at cap to the compensation committee of the board of directors for approval when, among other things, the recommended salary equals or exceeds an inflation adjusted threshold. For fellows, the board of directors approves a range of compensation, adjusted annually for inflation. Salaries for half-time and full-time fellows and for other employees are proportional to this pay scale. The president submits recommendations for any fellow to be compensated outside of this range. To avoid paying excessive compensation to employees, it is the policy of cap that the president submits his or her recommendations for compensation of newly hired senior employees at cap to the compensation committee of the board of directors for approval when, among other things, the recommended salary equals or exceeds $150,000. The recommendation includes a job description, information about the qualifications of the candidate, and information about what comparable organizations are paying for similar services. The compensation committee will consider and may approve these recommendations. The committee documents the basis for its decision with a contemporaneous record that is kept in the corporation's books and records. The compensation committee is comprised of independent directors; only members without a conflict of interest vote for each recommendation. Once compensation is approved by the board of directors, the president is authorized to adjust the salary levels of certain highly compensated employees and fellows without approval by the compensation committee when (1) the relevant supervisor has completed an evaluation of the employee's or fellow's work and it was determined that his or her work "met or exceeded expectations" for that position; (2) the president has reviewed recent data as to what comparable organizations are paying for similar services and determined that the adjusted salary would be reasonable and appropriate; (3) the president has determined that the adjustment would be commensurate with other highly compensated employees or fellows with similar responsibilities, authority, and performance within cap; and (4) the salary increase is not more than 20% of the senior staff or fellow's per annum salary, and that the total increases over three years not exceed 35%. The compensation committee is comprised of independent directors; only members without a conflict of interest vote for each recommendation.”

“Cap makes its governing documents, conflicts of interest policy, and financial statements available to the public. Cap's governing documents are included in its form 1023, application for recognition of exemption under section 501(c)(3). Changes to its governing documents are filed with its annual federal form 990. Both forms are made available to the public upon request. Cap's annual federal form 990 is also made available to the public by way of the online information service, guidestar.org, as well as by some of the states where the federal form 990 is a required submission for registration. Cap's audited financial statements are made available to the public through guidestar.org and upon request.”