Webster University

“The form 990 has been reviewed by the assistant controller, and the vice president/cfo. The form was made available to board members on the university's intranet before filing.”

“The university has an ethics/code of conduct policy located on the university website. Employees sign their acknowledgement of the policy and their adherence at new employee orientation. Managers and supervisors are responsible for implementing and monitoring compliance with the policy. Employees violating the letter or spirit of the ethics/code of conduct policy are subject to disciplinary action. The conflict of interest policies apply to all trustees and employees of the university defined within the policy as covered persons. Certain covered persons annually complete a conflict of interest questionnaire provided by the university to 1) confirm one's understanding of the conflict of interest policy and 2) to disclose any possible covered transaction which could be or could appear to be a conflict. The university regularly and consistently monitors and enforces compliance of the conflict of interest policy by constant review of a written policy, which contains details of the following: 1) a policy statement 2) details of the policy application 3) definitions of: a) conflict of interest b) covered persons c) related persons d) business partners e) transacting party 4) guidance for avoiding conflicts of interests in regards to: a) business decisions b) use of university resources and name c) gifts and gratuities d) financial interests and relationships with transacting parties e) receipt of items of monetary value from transacting party 5) standards for approval of transactions involving conflicts of interest, notably: a) actual conflicts of interest b) apparent and potential conflicts of interest c) substantial and material benefit 6) administration of policy including: a) reviewing reports regarding the conflict of interest questionnaire b) receiving disclosures of proposed transactions involving a conflict of interest c) reviewing proposed transactions as compared to the standards d) maintaining documentation e) reviewing operations to make changes to policy as deemed appropriate”

“The university continues to meet the rebuttable presumption requirements. The university maintains competitive compensation practices designed to attract and retain high-quality experienced leadership talent needed to manage in a complex global environment. External independent compensation consultants are engaged periodically to review and advise the board on executive compensation. Pearl meyer, an external compensation consultant, was used in the last fiscal year to assess chancellor compensation. In accordance with the by-laws of webster university and the charters of the board of trustees executive and compensation committees, the elements of compensation and total compensation are recommended by the board compensation committee and approved by the executive committee. Changes in compensation of the chancellor and the president are recommended by the board compensation committee and approved by the board executive committee. Executive committee and compensation committee meeting minutes are maintained.”

“The process for other officers follows the same principles of benchmarking as that for the top management official.”

“The organization makes its governing documents, conflict of interest policy, and financial statements available upon request.”

“CONTRACTED PROFESSIONAL SERVICES - Total Expense: 7740279, Program Service Expense: 4083244, Management and General Expenses: 3627877, Fundraising Expenses: 29158; STUDENT RECRUITMENT - Total Expense: 11563412, Program Service Expense: 11542916, Management and General Expenses: 20496, Fundraising Expenses: ; OTHER FEES FOR SERVICES - Total Expense: 722559, Program Service Expense: 662688, Management and General Expenses: 58378, Fundraising Expenses: 1493;”

“Change in value of split interest agreements - 3572; foreign currency translations - -33981; consolidating entries/indirect costs - 1067392; endowment funds transfer - -3933044;”