Marines' Memorial Foundation

“The tax return is reviewed by the chief financial officer and chief executive officer before a final copy is provided to the board of directors for final approval. Once approved the return is submitted to the chief executive officer for signature.”

“Prior to board or committee action on a contract or transaction involving a conflict of interest, any director or committee member having a conflict of interest and who is in attendance at the meeting shall disclose all facts material to the conflict of interest. Such disclosure shall be reflected in the minutes of the meeting. If board members are aware that staff or other volunteers have a conflict of interest, relevant facts should be disclosed by the board member or by the interested person himself or herself if invited to the meeting as a guest for purposes of disclosure. A person who has a conflict of interest shall not participate in or be permitted to hear the board's or committee's discussion of the matter except to disclose material facts and to respond to questions. Such person shall not attempt to exert his or her personal influence with respect to the matter, either at or outside the meeting. A person who has a conflict of interest may not vote on the contract or transaction and shall not be present in the meeting room when the vote is taken, unless the vote is by secret ballot. Such person's ineligibility to vote shall be reflected in the minutes of the meeting. In the event it is not clear whether a conflict of interest exists, the individual with the potential conflict shall disclose the circumstances to the chair or the chair's designee, who shall determine whether full board discussion is warranted or whether there exists a conflict of interest that is subject to this policy. Each director, officer, employee and volunteer shall be provided with and asked to review a copy of this policy and to acknowledge in writing that he or she has done so. Each director, officer and employee shall annually complete a disclosure form identifying certain relationships, positions or circumstances in which she or he is involved, and whether she or he believes any such relationships, positions or circumstances could contribute to a conflict of interest. This policy shall be reviewed annually by each member of the board of directors. Any changes to the policy shall be communicated to all staff and volunteers.”

“Marines' memorial foundation's top management officials, officers and key employees are compensated by its related organization, the marines' memorial association. The foundation does not compensate these management officials. The human resources director of the related organization is responsible for making recommendations for evaluating all employees. The compensation of officers, directors, and key employees is compared with executive compensation of similar organizations.”

“The public can request and receive copies of the articles of incorporation, the by-laws, the conflict of interest policy, and the audited financial statements for the same period of time as set forth in the internal revenue code section 6104(d).”

“The theatre is a union house operation and is staffed by the union with 3-6 employees per event that are assigned to operate the sound, lights and projectors for each performance. To ensure they are paid appropriately, with appropriate local benefits, the union assigns them to the marines' memorial association. Neither the theatre nor the foundation have the administrative or accounting capabilities to pay wages and therefore these wages had to be paid through the association. The association then invoiced the theatre for the work performed, resulting in the expenses listed.”