Case Western Reserve University

“The information to prepare the form 990 for the university is gathered by the controllers office and the form prepared. All information is provided to its accounting firm who reviews the return. Senior management then reviews the return prior to filing. The form 990 is also made available to the university's board of trustees prior to filing. Trustees may raise their questions and comments with finance staff.”

“The university's conflict of interest policy apples to the members of the board of trustees; all university officers; senior officials of the university; all university faculty except volunteer faculty in the school of medicine and except special faculty members who are not paid by the university (unless engaged in sponsored research); emeritus faculty who have an ongoing relationship with the university or who are engaged in sponsored research; post-doctoral fellows, all employees; students; and trainees. Individuals covered by this policy must report any financial interest and the acceptance of any gifts, favors, or anything of value, by the individual or the individual's spouse, dependent children, domestic partner, or any other dependent person who is a member of the same household as the individual, that directly or indirectly might influence or appear to a reasonable person to influence the individual's responsibilities as a member of the university. Individuals covered by the policy who engage in research must report any financial interest, no matter how small, that the individual or the individual's spouse, dependent children, domestic partner, or any other dependent person living in the same household as the individual, has in any entity that sponsors or supports the research or that holds a financial interest in the subject of the research, and also must report the acceptance of any gift, favor, or anything of value from an entity that sponsors the research or that holds a financial interest in the subject of the research. Individuals covered by the policy also must report whenever a previously reported conflict of interest is eliminated. The university's reporting process is administered by the university's conflict of interest office, except that reporting by members of the board of trustees, the president, the provost, all senior officials of the university, as well as the chair of the conflict of interest committee, is administered by the office of general counsel. Each year, individuals covered by the policy must report in writing any activities listed above. Reports called for by the conflict of interest committee are submitted to that committee. Reports called for by the office of general counsel are submitted to that office. The reports received by the conflict of interest committee are shared with the deans and department chairs of the reporting faculty. Individuals covered by this policy who are not required to report to the conflict of interest committee (other than those described above who must report to the office of general counsel or the president) must report any financial interest that relates to their university responsibilities to their supervisors at their annual review. Supervisors who determine that an individual may have a conflict of interest must report this to the conflict of interest office for further review. Individuals also must report to the conflict of interest office or the office of general counsel, as appropriate, within 10 days after they become aware of a reportable interest or after a conflict of interest has been eliminated. Individuals who have no reportable interests must still submit an annual report to be in compliance with this policy. The office of general counsel conducts an initial review of all the reports it receives. The conflict of interest office conducts an initial review of all reports it receives. If necessary, they obtain additional information from the individual covered by the policy and from other individuals who possess relevant information. The office of the general counsel or the conflict of interest office, as appropriate, then identifies those activities that must be reviewed and approved by the conflict of interest committee, and those activities that may proceed without review by the conflict of interest committee. The office of the general counsel or the conflict of interest office, as appropriate, notifies the conflict of interest committee or the b”

“This is in response to questions 15a and 15b. The university has adopted an executive compensation and intermediate sanctions policy to ensure that its compensation arrangements with related parties are evaluated and compensation that is paid to a related party is reasonable and reflects fair market value. The policy applies for determining the financial arrangements with individuals that are determined to be disqualified persons with respect to the university. "disqualified person" means a person who is or has been in a position to exercise substantial influence over the affairs of the university during the five years ending on the date of the transaction, a member of his or her family, or an entity in which the disqualified person has in excess of thirty-five (35%) percent control. Persons holding the following powers and responsibilities are deemed to be in a position to exercise substantial control over the organization: voting members of the board, the president, the chief executive officer, the chief operating officer, the treasurer and the chief financial officer. Others may be in a position to exercise substantial control over the university if the facts and circumstances justify such a conclusion. The compensation committee of the board of directors of the university endeavors to establish the rebuttable presumption of reasonableness by reviewing transactions which raise the risk of conferring an excess benefit. The committee will accomplish this by complying with the following procedures whenever a potential risk is identified: a. The transaction shall be approved in advance by the compensation committee of the board, or other parties authorized by the board to act on its behalf composed entirely of individuals who do not have a conflict of interest with respect to the transaction. B. A person has a conflict of interest if that person: (1) is a disqualified person or a family member thereof; (2) is in an employment relationship subject to the direction or control of a disqualified person; (3) receives compensation subject to approval by a disqualified person; (4) has a material financial interest affected by the transaction; or (5) has previously received an economic benefit through a transaction approved by the disqualified person. C. The compensation committee of the board shall obtain and rely upon appropriate data as to the comparability of the terms of the transaction prior to making its decision. I. The compensation committee of the board of trustees has appropriate comparability data if, considering the knowledge and expertise of its members, it has sufficient information to determine that the transaction in its entirety is reasonable or at fair market value. Ii. Relevant information with respect to a compensation transaction includes: (1) compensation paid by similar organizations for functionally comparable positions; (2) the availability of similar services within the geographic area; (3) current compensation surveys performed by independent firms; and (4) written offers from competing entities for the services of the disqualified person. Iii. Relevant information with respect to a property transaction includes: (1) current independent appraisals; and (2) offers received in a competitive and open bidding process. D. The compensation committee or other parties authorized by the board shall adequately document the basis for its determination concurrently with making that decision. Adequate documentations must include: i. The terms of the transaction approved; ii. The date the transaction is approved; iii. The members of the decision making body present during debate and who participated in voting; iv. The comparability data obtained and relied upon and how it was obtained; and v. Any actions taken by anyone who had a conflict of interest with respect to the transaction (persons with a conflict of interest must not be present at the time of a vote and this must be documented in the minutes).”

“SEE ABOVE”

“These documents are made available upon request.”

“Life income actuarial adjustments - -3633248; loss on disposal of plant assets - -437838; pension plan changes - -7012345;”

“The number of contributions received”

“Other=events and services : the number of contributions received.”

“The number of contributions received”

“The number of contributions received”

“The number of contributions received”

“Other=equipment : the number of contributions received”

“The number of contributions received”

“Other=events and services : the number of contributions received.”