Franklin University

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

“A compensation review, as prepared by an independent compensation consulting firm ("the consultants"), was conducted in fiscal year 2016-17 on the President of the University. 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) was conducted. 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 the President and a number of members of the Board of Trustees to gain perspective on the University's work environment, mission, pay philosophies and pay program effectiveness as well as the President's duties. 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, which was then ultimately approved in July of 2017 by the full Board. Additionally the Compensation Committee implemented a new policy around the review of all changes to executive compensation, including COLA adjustment, incentive payments and any increases to pay or benefits prior to such changes taking place. This policy covered all senior employees (earning over $100,000), including individuals not reporting directly to the President. All such actions are reflected in the minutes of the Compensation Committee. Any compensation changes made are relative to an independent market review.”

“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.”