Butler University

“Process to review form 990: butler university's board of directors has formally delegated authority for the review of its form 990 to the butler university stewardship committee. In addition, butler's outside accounting firm reviewed the form 990 prior to filing. Butler utilized this process to ensure that its form 990 received substantive review by directors and professionals with specific knowledge of butler's activities and extensive financial, accounting and tax expertise. Butler provided a complete copy of the return to the entire board prior to filing the tax return.”

“Monitoring & enforcement of compliance with conflict of interest policy: butler university has adopted a conflict of interest policy that requires directors, officers and key employees to submit an annual conflict of interest disclosure. The annual disclosure requires directors, officers and key employees to disclose, in writing, any known financial interest that the individual (together with family members) has in any business entity that transacts business with butler university. In addition, directors, officers and key employees are required to immediately disclose any possible conflict of interest that arises mid-year in relation to a proposed transaction. The conflict of interest policy requires that any individual with a conflict be recused from the decision-making process, that independent directors or committee members determine that the proposed transaction is in the best interests of butler university, and the transaction must be approved by a vote of the independent directors or committee members without the participation of any interested individual. The annual conflict disclosure statements are submitted to and reviewed by the stewardship committee, composed of independent outside directors. In addition, the executive staff is responsible for monitoring any possible conflict transactions that arise and managing them to ensure that all transactions represent arms' length, fair market value terms for the benefit of butler university.”

“Process to determine president and officer compensation: butler university has adopted an executive compensation and intermediate sanctions policy that ensures that all compensation arrangements with related parties are evaluated and entered at arms' length and that any compensation that is paid to a related party is reasonable and reflects fair market value. The policy encourages the application of the rebuttable presumption standard of code section 4958 and the related treasury regulations by (a) excluding any interested party from the decision making process; (b) requiring disinterested board or committee members to obtain and rely upon comparability data when setting the proposed compensation terms; (c) requiring approval of the transaction in advance by disinterested directors or committee members; and (d) requiring contemporaneous documentation (i.e., minutes) reflecting the decision and the process by which it was made. Butler university has delegated authority regarding executive compensation matters to the executive compensation committee, composed of independent outside directors. The committee is responsible for applying the terms and process of the executive compensation and intermediate sanctions policy as outlined above. The executive compensation committee of the board of trustees reviewed the compensation in 2021. Compensation review of other officers was conducted as part of the annual performance review process.”

“Availability of governing documents, coi policy, form 990, and fs: the university makes the form 990, governing documents, conflict of interest policy, and financial statements available upon request at the university's business office. The form 990 is also available at www.guidestar.org.”