Start Early

“The form 990 is prepared by a national public accounting firm based on information provided by management. After management review, the finance committee of the board of directors reviews and comments on the draft form 990. The full board subsequently receives the draft form 990 prior to its electronic filing with the irs.”

“Start early's regular and consistent conflict monitoring and enforcement process includes: 1.duty to self-disclose (ongoing, not annual): employees must disclose actual or potential conflicts when they arise and promptly report changes in circumstances or new interests. Disclosures include current and anticipated future affiliations. 2.recusal requirement: employees involved in procurement or other decision-making may not participate in the selection, award, or administration of a contract where a real or apparent conflict exists and must recuse as applicable. 3.review and decision-making controls: disclosures are evaluated by the designated official(s) (director, compliance & risk management; people & culture; and/or other designees as appropriate), and employees are not expected to determine unilaterally whether a conflict exists. 4.documentation and retention: determinations include whether a conflict exists and any mitigation steps (recusal, firewalls, independent review, etc.) and are maintained in writing in the employee's personnel record. 5.enforcement and corrective action: if there is reasonable cause to believe an interested person failed to disclose a conflict, the policy provides for review and investigation and corrective action, including removal from decision-making roles or disciplinary action.”

“Whistleblower policy this policy aims to provide an avenue for employees to raise concerns and reassurance that they will be protected from reprisals or victimization for whistleblowing in good faith. The whistleblowing policy is intended to cover serious concerns that could have a large impact on start early, such as actions that: may lead to incorrect financial reporting; are unlawful; are not in line with organization policy; or, otherwise amount to serious improper conduct. Document retention policy any records that are essential to operations during an emergency and any records requiring permanent retention should be backed up with a copy maintained at an offsite record storage facility. Each division is responsible for the continuing process of identifying records that have met its required retention period and supervising the destruction process. The destruction of confidential paper records must be conducted by shredding. The destruction of electronic records must be coordinated with the it department and must be cleared according to nist publication 800-88 standards so that data cannot be retrieved. A record destruction log must be completed to maintain an inventory of offsite or destroyed records. The log should be maintained by site facility managers or a designee. Compensation in preparation for the budget each year, the performance and compensation committee, an independent committee of the board of directors, reviews and approves the proposed compensation for start early president, coo, and all other key employees using contemporaneous documentation which is measured against comparable data from the market. An independent compensation firm provided market data to assist start early in determining the reasonableness of the compensation provided to members of start early's executive team, consistent with guidance in treasury regulations under internal revenue code (irc) section 4958. The process described here was last completed in 2025.”

“The annual report, which includes audited financial statements, is posted on start early's website. The articles of incorporation, bylaws, and conflict of interest policy are available upon request.”

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