Altria Companies Employee Community Fund

“A copy is emailed to each of the board members. The treasurer reviews the 990 independently. The chairperson then reviews the 990.”

“Upon becoming a director, officer or a member of a committee to which the board has delegated powers and each year thereafter, an individual shall become an insider and shall complete a conflict of interest declaration form providing (i) the name(s) of any entity in which the insider or the insiders family has a significant ownership or investment interest, or with which the insider or the insiders family has a relationship as a director, officer, staff member, committee member or consultant, and (ii) the name(s) of any person with whom the insider or the insiders family has a compensation arrangement. The insider shall also sign a statement affirming that he or she: a. Has received a copy of this conflict of interest policy, b. Has read and understands the policy, c. Has agreed to comply, and, if part of an annual certification, has previously complied, with the policy, and d. Understands that the corporation is a charitable organization and that, in order to maintain its federal tax exemption and preserve the corporation's valuable reputation, the corporation must engage primarily in activities that accomplish its tax-exempt purposes. To ensure that the corporation operates in a manner consistent with its charitable and educational purposes, and does not engage in activities that could jeopardize its tax-exempt status, the board or a committee appointed by the board shall conduct an annual review that shall include, at a minimum, findings on the following subjects: a. Whether the corporation's compensation arrangements and benefits, if any, are the result of arms length bargaining and, based on competent survey information, are reasonable. B. Whether partnerships, joint ventures, and arrangements with management organizations in which the corporation participates, if any, conform to the corporations written policies, are properly recorded, reflect reasonable investment criteria or payments for goods and services, further the corporations exempt purposes and do not result in private inurement, impermissible private benefit or an excess benefit transaction under the code.”

“Part vi, section b, line 15 a and b are answered no because there are no employees and no compensation set by the organization.”

“The 990 is available via guidestar and all other documents are available upon request.”

“The process has not changed from the prior year.”