The Lutheran University Association Inc.

“Administration of the Policy - (Conflicts of Interest) The policy for the disclosure of existing or potential conflicts of interest, shall be administered in the following manner: 1. Current and certain former directors, officers, and key employees shall annually receive a copy of the Policy Statement on Conflicts of Interest and be asked to complete a questionnaire as to their interests. The Board Chair and the President shall have discretion to apply this requirement to other employees (such as employees with significant procurement responsibilities). 2. Any existing or potential conflict of interest on the part of a director is to be disclosed to the Chair of the Governance Committee of the Board. The Chair of the Governance Committee, in consultation with the Board Chair and the President, will discuss with the director options for resolving the conflict. A conflict of interest may be waived if the Chair of the Governance Committee, in consultation with the Board Chair and the President, determines that the transaction or circumstance is in the best interests of the University. Whether or not a conflict is waived, a director who has an existing or potential conflict of interest on any matter should not vote or use his or her personal influence on the matter, nor should the director be counted in determining a quorum, even where permitted by law. The minutes of any meeting should reflect that the director disclosed the conflict, abstained from voting, and that a quorum existed even though the director is not counted toward that quorum. This requirement does not prevent a director from stating his or her position on the matter or from answering pertinent questions of other directors where the director's knowledge may assist the other directors. 3. Any existing or potential conflict of interest on the part of an officer, key employee, or other designated employee is to be disclosed to the University Counsel and brought to the attention of the President. The University Counsel, in consultation with the President, will discuss with the officer or employee options for resolving the conflict. A conflict of interest may be waived if the University Counsel, in consultation with the President, determines that the transaction or circumstance is in the best interests of the University. The University Counsel shall report to the Chair of the Governance Committee any conflicts of interest and the resolution or waiver of same. 4. At least annually, the Chair of the Governance Committee shall submit reports to the Governance Committee concerning any conflicts of interest and the resolution or waiver of same.”

“The Executive Committee of the Board of Directors is responsible for an annual review of compensation for compensated officers and other key employees of the University. The review was last undertaken Spring of 2014. Information from outside consultants as well as peer and industry data was reviewed to determine equitable, competitive compensation packages.”

“Valparaiso University currently does not provide governing documents or the conflict of interest policy to the public. Financial statements are available upon request and may be obtained from the Office of the Senior Vice President for Finance and Administration.”

“Valparaiso University provides additional services to students including housing and Division I athletics opportunities. Also, the University supports theatre, music and visual arts programs beneficial to students as well as the general public. PART VI, LINE 1B MARK F. HAGERMAN and HARLEY W. SNYDER ARE CONSIDERED NON-INDEPENDENT BOARD MEMBERS DUE TO TRANSACTIONS LISTED ON SCH. L. PART VI, LINE 2 ROBERT HANSEN AND N. CORNELL BOGGS, III HAVE A BUSINESS RELATIONSHIP. FRED KRAEGEL, BONNIE RAQUET AND N. CORNELL BOGGS, III HAVE A BUSINESS RELATIONSHIP. PART VI, LINE 11B Consistent with its fiduciary responsibilities, the Board of Directors of The Lutheran University Association, Inc d/b/a Valparaiso University adopted the following procedure for annual review of the University's responses to Internal Revenue Code Form 990: (1) Thirty days before filing with the Internal Revenue Service, or a soon as practicable prior to filing, the Audit Committee will review and comment on the Form 990 (2) Following review by the Audit Committee and prior to filing with the Internal Revenue Service, the final Form 990 shall be transmitted to all Board members. The most expeditious method of transmission, whether in paper form or electronic will be determined in the discretion of the University administration.”