Center for Popular Democracy

“The draft form 990 is reviewed by the director of finance, in consultation with the general counsel, and chief operating officer, and circulated to the board of directors prior to filing with the internal revenue service.”

“In connection with any actual or possible conflicts of interest, an officer, director, or employee must disclose the existence of his or her financial interests in the organization, including business and family relationships in the organization. Each officer, director, and key employee is required to complete a conflict-of-interest disclosure questionnaire on an annual basis. Any possible disclosed financial interest, or business and family relationship, is reviewed by the director of legal compliance to determine if a conflict of interest exists. (note that a financial interest or business and family relationship does not necessarily constitute a conflict of interest.) if such a conflict is found to exist, a meeting of the independent directors is held, and a decision is made as to how to avoid the relevant conflict. In most cases, this involves requiring the conflicted director not to participate in discussion or decision making where the conflict may arise. If the person disclosing the financial interest or existing business and family relationship is a current member of the executive committee, said member shall leave the meeting during the discussion of, and the vote on, whether a conflict of interest exists. If the executive committee determines a conflict of interest exists, the executive committee shall take appropriate corrective or disciplinary actions.”

“A board of directors subcommittee composed of executive committee members conducted an analysis of comparable executive compensation in 2024 as a part of its process for determining executive compensation for cpd co-executive directors. The full board voted on and approved compensation for the co-executive directors twice during 2024.”

“Cpd makes its governing documents, conflict of interest policy, and financial statements available to the public upon request.”

“Cpd shares staff and other resources with a partner organization, center for popular democracy action fund, inc. (cpda) through a resource sharing agreement. Cpda is a tax-exempt organization under 501(c)(4) that is unrelated to cpd for 990 purposes.”

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