Stevenson University Inc.

“Form 990 Part VI Line 11b THE 990 INFORMATION IS COMPILED BY THE UNIVERSITY'S FINANCE OFFICE AND REVIEWED BY THE INDEPENDENT ACCOUNTING FIRM OF KPMG. THE DRAFT RETURN IS THEN PRESENTED TO AND REVIEWED BY THE EXECUTIVE COMMITTEE. THE EXECUTIVE COMMITTEE IS COMPRISED OF 7 MEMBERS SELECTED FROM THE UNIVERSITY'S CURRENT BOARD OF TRUSTEES. A COMPLETE COPY OF THE FORM 990 IS THEN EMAILED TO ALL MEMBERS OF THE BOARD OF TRUSTEES VIA A PASSWORD PROTECTED DOCUMENT. THE COMMITTEE MEMBERS HAVE A TEN DAY PERIOD OF TIME WHERE THEY ARE ENCOURAGED TO REVIEW AND COMMENT ON THE DOCUMENT PRIOR TO ITS FILING.”

“Form 990 Part VI Line 12c IT IS THE POLICY OF STEVENSON UNIVERSITY THAT THE MEMBERS OF ITS BOARD OF TRUSTEES AVOID ETHICAL, LEGAL, FINANCIAL AND OTHER CONFLICTS OF INTEREST AND TO ENSURE THAT THEIR ACTIVITIES AND INTERESTS DO NOT CONFLICT WITH THEIR OBLIGATIONS TO THE UNIVERSITY AND ITS WELFARE. THIS POLICY COVERS MATTERS RELATING TO THE BOARD MEMBER OR ANY RELATED PERSON. A RELATED PERSON IS DEFINED AS A MEMBER OF THE IMMEDIATE FAMILY OF THE BOARD MEMBER, ANY ENTITY OF WHICH THE BOARD MEMBER IS AN OFFICER, DIRECTOR OR TRUSTEE OR WITH RESPECT TO WHICH THE BOARD MEMBER HOLDS A SIMILAR POSITION, ANY ENTITY IN WHICH THE BOARD MEMBER HAS A MATERIAL FINANCIAL INTEREST; AND ANY OTHER PERSON OR ENTITY WITH WHOM THE BOARD MEMBER HAS A PERSONAL RELATIONSHIP THAT MIGHT REASONABLY BE EXPECTED TO AFFECT THE BOARD MEMBER'S JUDGMENT IN THE PARTICULAR MATTER. ON AN ANNUAL BASIS EACH MEMBER OF THE BOARD OF TRUSTEES WILL SUBMIT TO THE SECRETARY OF THE BOARD, AN ANNUAL SIGNED CONFLICT OF INTEREST REPORT. IF DURING THE COURSE OF THE YEAR, AN ACTUAL OR POTENTIAL CONFLICT ARISES, BOARD MEMBERS ARE REQUIRED TO DISCLOSE THEM TO THE SECRETARY OF THE BOARD BEFORE ANY BOARD ACTION WITH RESPECT TO THE MATTER IS TAKEN. ANY BOARD MEMBER WHO IS AWARE OF AN EXISTING OR POTENTIAL CONFLICT OF INTEREST WITH RESPECT TO A MATTER COMING BEFORE THE BOARD OR COMMITTEE OF THE BOARD SHALL NOT BE PRESENT FOR ANY DISCUSSION OR VOTE IN CONNECTION WITH THE MATTER, AND THE AFFIRMATIVE VOTE OF A MAJORITY OF THE DISINTERESTED BOARD MEMBERS OR COMMITTEE MEMBERS, AS THE CASE MAY BE, SHALL BE REQUIRED IN ORDER TO APPROVE, RATIFY OR AUTHORIZE THE MATTER. THE BOARD MEMBER WHO HAS AN INTEREST IN THE MATTER SHALL NOT BE COUNTED FOR THE PURPOSE OF DETERMINING THE PRESENCE OF A QUORUM AT THE MEETING AT WHICH THE MATTER IS CONSIDERED.”

“Form 990 Part VI Line 15a ON AN ANNUAL BASIS THE EXECUTIVE COMMITTEE, WHICH IS COMPRISED OF SIX INDEPENDENT MEMBERS SELECTED FROM OUR CURRENT BOARD OF TRUSTEES, MEETS TO EVALUATE THE PERFORMANCE OF THE PRESIDENT, CHIEF FINANCIAL OFFICER, EXECUTIVE VICE PRESIDENT FOR ACADEMIC AFFAIRS AND VICE PRESIDENT FOR UNIVERSITY ADVANCEMENT. DURING THIS MEETING, THE SALARIES ARE EVALUATED BY REVIEWING RESULTS OF COMPENSATION STUDIES PERFORMED BY AN INDEPENDENT ORGANIZATION. THE ORGANIZATION COMPILES THE WAGE INFORMATION OF TEN PEER COLLEGES AND UNIVERSITIES FROM THEIR FORM 990S FILED WITH THE IRS. THIS ENSURES THAT COMPENSATION LEVELS AT STEVENSON UNIVERSITY ARE WITHIN REASONABLE LEVELS TO OTHER INSTITUTIONS. MEETINGS OF THE EXECUTIVE COMMITTEE TAKE PLACE FOUR TIMES A YEAR. MINUTES ARE TAKEN AND RETAINED BY THE OFFICE OF THE PRESIDENT. IN JUNE OF EACH YEAR, THE COMMITTEE MEETS TO DISCUSS AND AUTHORIZE EXECUTIVE COMPENSATION FOR THE KEY EMPLOYEES LISTED ABOVE. FOR ALL OTHER ADMINISTRATIVE PERSONNEL EACH POSITION OR STATUS CHANGE IS BENCHMARKED AGAINST CUPA SALARY SURVEY COMPENSATION STANDARDS BY THE VICE PRESIDENT OF HUMAN RESOURCES TO ENSURE REASONABLE LEVELS OF COMPENSATION.”

“Form 990 Part VI Line 19 THE UNIVERSITY MAKES ITS GOVERNING DOCUMENTS AND CONFLICT OF INTEREST POLICY AVAILABLE TO THE PUBLIC VIA ITS WEBSITE. COPIES OF THE AUDITED FINANCIAL STATEMENTS ARE MADE AVAILABLE TO THE PUBLIC UPON REQUEST.”