Covenant Foundation Inc.

Schedule O Disclosures

“IRS Form 990 Part VI Section A Lines 6-7b: Covenant Foundation, Inc. has one member which holds several reserved powers over Covenant Foundation, Inc. These reserved powers include, but are not limited to, the election of members of the governing body and election of officers, approval of certain financial expenditures in accordance with policy, and approval of budgets and strategic plans; these approvals are based on recommendations from the governing body. IRS Form 990 Part VI Section B Lines 11a and 11b: Affiliates of Wheaton Iowa during the fiscal year ending June 30, 2018 used a multiple-level review process on all IRS Forms 990 to ensure accurate and timely filing for all organizations. Under the direction of the Chief Financial Officer, the Accounting Department prepares Forms 990 and any applicable 990-T and associated state filings. When complete, the return is first reviewed by a Senior-Level (or higher) associate in the Finance Department, who focuses on the income statement and balance sheet items, and schedules where transactions of this type might be reported. If discrepancies are found, the item will be corrected prior to the next step in the review process. Once cleared through Finance, the return is provided to the Tax Department of the Wheaton Iowa sponsor organization, where the tax director concentrates primarily on consistency of reporting between all returns, accuracy of tax related information, and explanation and understanding of any outliers. Again, any problems or questions are investigated and corrected. Depending on the level of complexity of the year in question, as well as the individual issues specific to that filing, certain returns may be selected for outside review by a public accounting firm. This decision will vary from year to year based on many factors, and sometimes outside review is not utilized at all. Also, certain schedules, such as Schedule H or Schedule J may be reviewed by committees, such as the Community Benefit Team or the Compensation Committee in selected years. The board has asked for formal presentations on various 990 topics over the years. This decision will vary from year to year, again based on many factors. Once all levels of review have been completed, a designated Finance and Accounting employee will schedule an appointment with the signer of the 990. The signer, the Vice President-Finance and CFO, will perform an additional, normally high level review prior to signing the return. Once signed, the return is cleared to provide to members of the Board of Directors, who at a later date but prior to efiling, are provided access to all 990's throughout their assigned region. IRS Form 990 Part VI Section B Lines 12a - 12c: Covenant Foundation, Inc. has adopted a Conflict of Interest policy which applies to all "interested persons" of Covenant Foundation, Inc. including directors, principal officers, key employees, and members of committees with board-delegated powers. Interested persons are expected to discharge their duties in a manner the person reasonably believes to be in the best interests of Covenant Foundation, Inc. and to avoid situations involving a conflict of interest. On an annual basis, interested persons are required to complete a conflict of interest disclosure statement and to affirm their receipt of the conflict of interest policy, compliance with its requirements, and agree to notify the organization of changes impacting their annual disclosure in accordance with the policy. The annual disclosures are provided to internal legal counsel and the integrity and compliance officer, from which legal counsel prepares a report for the board chair and CEO. A summary of potential conflicts is reviewed with the board of directors of Covenant Foundation, Inc. (or a delegated committee of the board) on a yearly basis. Interested persons are required to make full disclosure to Covenant Foundation, Inc. of any financial or business interests that might result in or have”