Covenant Journey Inc.

“Anita Staver and Mathew Staver have a family relationship.”

“The Organization's sole voting member is Covenant Journey Mission Trust.”

“The Organization's member has the power to appoint the Organization's Board of Directors.”

“The Organization's member has the power to amend the Organization's governing documents.”

“The Organization's top management official and top financial official each review the Form 990 prior to its filing with the IRS. A copy of the final Form 990 is also provided to the voting members of the Organization's governing body prior to its filing with the IRS.”

“The Organization's conflict of interest policy is distributed to each member of the Organization's governing body, its officers and its key employees on an annual basis. Each such individual provides an annual disclosure statement indicating that they have received, read, understood and agreed to comply with the policy, certifying that: (1) they have no relationships or interests that present a conflict of interest, (2) they have one or more conflicts of interest that have been fully disclosed as required by the policy and have been properly administered in conformity with the policy, or (3) they have previously undisclosed conflicts of interest and disclosing the details of such conflicts. Any disclosure statements with previously undisclosed conflicts of interest are forwarded to appropriate Organization officials to take appropriate actions as required by the policy.”

“The Organization did not compensate any individuals during the tax year. The salaries reported in Form 990, Part VII were paid by related organizations, which have adopted executive compensation setting policies applicable to all disqualified persons, including their CEOs, officers, and key employees. The Organization has also adopted an executive compensation setting policy applicable to all disqualified persons, including the Organization's CEO, officers and key employees. Under the policy, an independent committee of the Board of Directors annually reviews and approves the compensation levels of all individuals subject to the policy. The deliberations and decisions of the committee are documented in the committee minutes. In its deliberations, the committee utilizes appropriate information regarding compensation amounts paid for comparable positions in comparable organizations. These procedures are followed to ensure that compensation arrangements for the Organization's key leaders are reasonable and appropriate. Mathew Staver and Anita Staver are both attorneys who actively lead and manage the related organizations. A committee of independent members of the Board of Directors without a conflict of interest set the salaries for the leadership of the related organizations after evaluating comparative data regarding compensation for similar positions, including a review of salary information from the IRS Form 990s of other nonprofit legal organizations, and concluded that Mathew and Anita Staver have been consistently paid less than attorneys of other nonprofit legal groups. Their salaries were raised effective July 2013, based on a review indicating a total compensation range of $151,000 to more than $369,000 for attorneys who lead legal organizations, and a range of $200,363 to $311,674 for attorneys who manage litigation. Individual leaders of groups with much smaller budgets than Liberty Counsel (under $2.5 million) are compensated between $151,000 to $270,500. In addition, some Form 990s show that their nonprofit legal organization leaders are compensated by several separately incorporated entities, while other salaries are unverifiable because the groups compensate their leaders with multi-million dollar payments to their own for-profit law firms. Even with the new salaries, their compensation remains lower than similar organizations, and in addition, the Stavers donated $49,000 (10% of their combined income) back to the related organizations.”

“The Organization provides, upon request, copies of its Articles of Incorporation, bylaws, conflict of interest policy, and its financial statements.”

“Candice McGuire was compensated as an employee of a related organization through May 2016. As such, she received reportable compensation during 2016 which has been reported at Part VII, Section A. Because her employment with the related organization terminated prior to the beginning of the June 30, 2017 tax year, Ms. McGuire did not receive compensation from the related organization during the Organization's tax year. Therefore, Ms. McGuire is considered an independent voting Board member of the Organization in accordance with the Form 990 instructions as she did not receive compensation during the Organization's tax year. The hours reported in Column (B) for Candice McGuire represent the average hours of service performed during the tax year.”