Upenn International

“Form 990 review process information related to this organization's form 990 filing is gathered by finance staff and provided to pricewaterhousecoopers llp for review and return preparation. A draft copy of the 2018 form 990 was reviewed by various senior financial management officials before it was submitted to the board for their review. A copy of the final 2018 form 990 was then made available to each board member prior to the filing deadline. ------------------------------”

“Conflict of interest policy this organization is an affiliate of the trustees of the university of pennsylvania ("university"). Each covered person* annually shall complete a conflict of interest questionnaire provided by the university and shall update such questionnaire promptly as necessary to reflect changes during the course of the year. Former board members who are not trustee emeriti are encouraged but not required to complete the questionnaire during the five-year period following completion of their terms. Completed questionnaires shall be returned to the office of the secretary and shall be subject to review by such office and the office of the general counsel, as well as by any outside legal counsel and/or auditors who may be appointed to advise the compensation committee of the board of trustees appointed to oversee this policy. Completed questionnaires also shall be available for inspection by any board member. *covered persons include: (1) voting members of the board of trustees (including charter trustees, term trustees, alumni trustees, and commonwealth trustees); (2) trustee emeriti who have served in that capacity for five years or less; (3) other former voting trustees for a period of five years from the end of their term as such; (4) officers as defined in the statutes; and (5) members of the investment board. Each covered person (except former board members who are not trustees emeriti) shall be required to acknowledge, not less than annually, that he or she has read and is in compliance with this policy. ------------------------------”

“Compensation review and approval this organization is an affiliate of the trustees of the university of pennsylvania ("university"). Compensation arrangements involving any of our officers and/or key employees are established by the university pursuant to a process that satisfies the rebuttable presumption procedure available for section 4958 excess benefit transaction tax purposes (which requires a review of compensation determinations by disinterested persons, use of appropriate comparability data, and contemporaneous documentation of the process). ------------------------------”

“Documents available to public our forms 1023 and 990, governing documents, audited financial statements, and conflict of interest policy are available to the public upon request.”