Society for Integrative Oncology Inc

“Part vi, line 20 - books and records as discussed in the responses to part vi, lines 3 and 5, below, in 2021, the organization was unaware of h&a's malfeasance and, as part of its duties under the services agreement, h&a was given custody of the organization's books and records. Since learning of h&a's misconduct, the organization has taken significant steps to recover its books and records from h&a. The recovered books and records are now in the possession of members of the board of trustees.”

“The organization is staffed by a group of volunteer healthcare providers and patient advocates. For this reason, the organization outsources full time management of its operations to third-party consultancy firms specializing in nonprofit management. Effective january 1, 2021, the organization engaged the washington, d.c. Based consulting firm, hauck & associates ("h&a"), to manage its operations. Pursuant to the written agreement entered into between h&a and the organization ("services agreement"), h&a's management services included, without limitation, finance, accounting, human resources, event planning and legal. In furtherance of its management role, h&a was given custody of the organizations books and records and granted to access to, among other things, the organization's financial accounts, websites, keys and credit cards. As further discussed in the response to part vi, line 5, below, although not discovered until 2023, h&a abused its management position to misappropriate funds from the organization in 2021 and conceal its actions from the organization. It was also discovered in 2023 that h&a charged the organization management fees for services that did not comply with the duties and standards outlined in the services agreement. For these reasons, the organization terminated its relationship with h&a in may 2023.”

“As discussed in the response to part vi, line 3, above, the organization engaged h&a to serve as manager beginning on january 1, 2021. H&a continued in such capacity until on or about may 10, 2023, when the organization learned that graham hauck ("hauck"), the principal manager at h&a, plead guilty in federal court to misappropriation of funds of another nonprofit organization managed by h&a. Immediately thereafter, the organization terminated h&a and implemented various corrective actions. These actions included: (1) securing the organization's assets to prevent further losses; (2) recovering paper and electronic files and financial books and records of the organization; (3) revoking h&a's access to the organization's financial accounts, internet sites, keys, credit cards and the like; (4) identifying a new management company to replace h&a and engaging tad tuttle, cpa as the organization's independent outside accountant; (5) engaging a forensic accountant, chess consulting llc ("chess consulting"), to detect any misappropriation of the organization's funds and determine the amount involved; and (6) retaining experienced outside counsel, namely: (i) zachary r. Hafer, esquire, a partner in cooley llp's white collar defense and investigations practice group and former assistant us attorney, (ii) michael i. Sanders, esquire, a partner in blank rome llp's tax group and professor at georgetown university law center, and an expert in the field of tax-exempt organizations, and (iii) t. Malcolm sandilands, esquire, a partner in blank rome llp's corporate group. Internally, the organization hired nelson lin as its first inside general counsel to coordinate its legal response, which includes crisis management and supervision of the organization's recovery efforts. In addition, since learning of hauck's guilty plea, the executive committee of the board of trustees has worked continuously to ensure that h&a is unable to access or control any aspect of the organization's operations. Following its engagement, chess consulting immediately began its forensic review of the organization's available financial information, including but not limited to, copies of bank statements, year-end balance sheets and income statements, grant and contributions support, certain third-party invoices, and other relevant documentation. Based on this review, chess consulting generated a report (the "forensic report"), a copy of which is available upon request. The forensic report estimates the range of potential misappropriated funds during the period from january 2021 through april 2023 as between 893,088 and 936,167. The low end of the estimated range is based on an analysis of excess payments made by the organization to h&a during the period from january 2021 through april 2023. This includes 263,900 of management fees collected by h&a for services that did not meet the requirements and standards set forth in the services agreement. The high end of the estimated range is based on a comparison of the organization's bank activity to its financial statements during the period from january 2019 through april 2023. The forensic report acknowledges that the analyses therein are based on the best information available because, as mentioned above, h&a was responsible for maintaining the organization's books and records, including transaction support, some of which the organization has been unable to recover to date. The organization is currently working with its outside counsel, malcolm sandilands and former assistant us attorney, zachary hafer, to obtain restitution through co-operation with the department of justice (the "doj") in its continuing investigation of h&a and hauck. At this time, the organization believes that it will be able to recover a substantial portion of the misappropriated funds through the doj. To the extent the restitution received from the doj does not fully cover the misappropriated funds, the organization will discuss with counsel the costs”

“The organization has members that pay dues.”

“The members of the organization elect the governing board.”

“The 990 is provided and reviewed by select executive committee members.”

“Board members are provided with the conflict of interest policy at the annual meeting which includes direction to report conflicts and affiliations at that time and also report conflicts and affiliations relevent to issues as they arise throughout the year. This information is maintained at the association's headquarters.”

“AVAILABLE UPON REQUEST.”

“Total contributions and grants to the organization were reported on schedule b and total 230,000. Due to the misappropriation of funds reporting on schedules l and n, receipts of donations into the bank account were only 157,420. The difference of the amounts actually received into the bank account and those reported on schedule b and part viii are included in the total amount of misappropriated funds. See notes on schedule o, part vi, lines 3 and 5 for additional information.”

“Providing educational opportunities to members and committed to the study and application of integrative and complementary therapies for cancer patients. It provides a convenient forum for presentation, discussion and peer review of evidence based research and treatment.”

“Part iv, line 25a - excess benefit transaction as detailed in the response to part iv, line 3, below, in 2021, hauck & associates was in a position to exercise substantial influence over the organization and thus met the definition of a "disqualified person." accordingly, the misappropriation of the organization's funds by hauck & associates' principal manager, graham hauck, described in the response to part vi, line 5, below, constitutes an excess benefit transaction which is disclosed on schedule l.”

“Theft of funds-see sch l 0 775,228 0”