Franklin University

“Upon completion of the Form 990 and all supporting schedules (the "return") by the Director of Accounting, the return was first reviewed by the Chief Financial Officer and the University President, with consultation of tax experts where considered necessary. The return was then provided to the Chairman and Vice Chairman of the Board of Trustees and the Chair of the Finance Committee for their review. Questions arising from this review were addressed as appropriate, with any necessary changes made to the 990.”

“Each year a copy of the University's Employee Ethics (Conflict of Interest) Policy is provided to each Trustee, the President and other officers of the University, along with a questionnaire related to the policy. Responses to the questionnaire, which are summarized for review by the President of the University, will identify any potential conflicts of interest. Should business come before the Board or Committee thereof that presents a potential conflict, the affected Board member would be asked to abstain from any Board action on that business.”

“Reviews, as prepared by an independent compensation consulting firm (the "consultants"), were conducted in fiscal year 2008-2009 on all University officers, including the President, via a thorough examination of external documented pay data (published surveys and 990 filings) for comparable positions at peer institutions (as mutually agreed upon by Franklin University and the consultants). Compensation levels were reviewed for market competitiveness and reasonableness and were compared for all components of pay including cash compensation, benefits and perquisites. In preparation for such reviews, the consultants interviewed a number of University officers and members of the Board of Trustees to gain perspective on the University's work environment mission, pay philosophies and pay program effectiveness. The results included individual market reports as well as an aggregate perspective. The Compensation Committee of the Board of Trustees approved the resulting reviews and compensation levels of the President and his direct reports and proposed the adoption of a related executive compensation philosophy which was ultimately approved in January of 2010 by the full Board. The compensation reviews covered all senior employees (earning over $100,000), including individuals not reporting directly to the President. These reviews, although conducted in a previous fiscal year, were fully vetted by the Compensation Committee and full Board in fiscal year 2015-2016. All such actions were reflected in the minutes of both the Compensation Committee and the Board of Trustees. Any compensation changes made were relative to the independent market review. During fiscal year 2014-2015 a full external review of the President's compensation was conducted consistent with specifications outlined above in the prior review. The review was conducted and results were prepared by consulting firm, Findley Davies in preparation for the renewal of the President's contract. The Compensation Committee of the Board and ultimately the full Board voted to approve the new contract including the fully vetted new compensation levels. The Board was given a deep and thorough view into the compensation studies as prepared by Findley Davies, all of which is reflected in Board minutes. A new independent review is currently under way and will be completed in July 2017 and will include all highly compensated individuals and all officers and executives.”

“Financial statements, governing documents, and conflict of interest policies are not required disclosures pursuant to Internal Revenue Code (IRC) Section 6104. These documents are not available to the public at this time.”

“Inherent contribution recognized for financial reporting under generally accepted accounting principles, but not recognizable as a contribution for tax reporting purposes.”