Nebraska Student Loan Program Inc.

“Members the foundation for educational services, inc. (fes), a not-for-profit corporation, serves as the sole member of nebraska student loan program, inc. (nslp) and elects nslp's board of directors.”

“Review of the form 990 the 990 is prepared by kpmg, reviewed by staff and mailed to all board members. The 990 is presented to the audit committee and the board before it is filed.”

“Conflict of interest policy nslp maintains a comprehensive conflicts of interest policy for directors and officers. The policy exists to identify potential instances in which an individual could obtain a direct or indirect personal gain or advantage to the detriment of the organization, or where an individual's conduct could have an adverse or potentially adverse effect on the interests of the organization. The policy contains an affirmative duty to disclose, as well as a specific process for disclosures of potential conflicts of interest, a protocol in which independent, outside legal counsel is used to evaluate whether a conflict exists, procedures for addressing actual conflicts of interest, and consequences for violations of the conflicts policy. The policy requires all directors and officers to complete and submit an annual conflicts disclosure form to outside legal counsel. In addition, the conflict of interest policy is included in the employee handbook which all employees must acknowledge and agree to abide by.”

“Process for determining compensation outside legal counsel undertakes a comprehensive evaluation of the compensation and benefit packages for officers and other affected employees of the organization, comparing the same relevant industry and other market comparables. Counsel then provides to the board of directors a summary of the comparability data, an analysis of the data relative to the organizational employees, and a reasoned opinion concerning this conclusion. The board of directors then confirms and ratifies all compensation/benefits packages, with the decision process properly documented as required by the regulations. On a routine basis, nslp engages an independent compensation specialist to provide data for key positions.”

“Public availability of documents, policies, and financial statements nslp does not make their governing documents, conflict of interest policy, or financial statements available to the public.”