Asbury Communities Inc.

“The executive committee of the board of directors can act in place of the board between meetings. All members of the executive committee are members of the board of directors.”

“A director provided investment advisory services to the president/ceo at an arms length transaction basis.”

“Asbury communities is the sole member of asbury atlantic, inc., asbury-solomons, inc., inverness village, an oklahoma not for profit corporation and asbury communities hcbs, inc. Asbury communities has a system wide audit committee. The asbury communities board of directors has delegated a review of the form 990 to the system audit committee which performed their review on october 28th. The asbury communities, inc., foundation, asbury atlantic, asbury solomons, asbury communities hcbs, and inverness village board of directors were forwarded a copy of their respective draft form 990 for their review and provided a link to recording of the audit committee meeting if members chose to listen to the meetings as they reviewed any of the form 990s. All directors may pose questions or ask for clarification from the staff and audit committee.”

“The asbury communities conflict of interest policy was approved by the board of directors. The assistant general counsel is responsible for the policy and oversees the implementation of the process. All the entities within the asbury communities system are subject to the policy. Annually, the compliance officer conducts a comprehensive conflict disclosure process covering all members of the governing boards, system wide committees, and individuals in management positions. Each person completes a conflict disclosure form and is advised of their fiduciary obligations. The compliance officer, who had a direct reporting line to the chair of the audit committee and reports quarterly to the audit committee, analyzes all disclosure forms for potential conflicts, and prepares a report for the system-wide audit committee. A summary is then presented to the board of directors at the annual meeting. When a conflict of interest arises, the individual will be required to recuse him or herself from the board deliberations and vote.”

“The system wide compensation committee meets with the independent compensation consultant, and based on information provided to the committee makes recommendations regarding compensation and benefits to the executive committee which is charged by the full board with decisions regarding compensation. The independent compensation consultants and attorney as also present at the meeting of the executive committee at which the executive committee considers the recommendation of the compensation committee. At this meeting the executive committee receives all of the same information which was presented to the compensation committee and has the opportunity to ask questions and evaluate the materials. The full board(s) of asbury communities and asbury atlantic each receive a presentation once a year on executive compensation and benefits. The vice president of human resources is present to give board members an opportunity to ask questions and to provide salaries and grade levels for their review. The system wide compensation committee is composed of 5 voting members, the vice president of human resources (non-voting), a retained attorney (non-voting; records proceedings in minutes), and is advised by towers watson (a compensation consulting firm). The system wide compensation committee holds a minimum of 4 meetings each year. At the fall meeting they review towers watson data and reports in order to make recommendations regarding salaries and benefits. This annual review also ensures compliance with irs intermediate sanctions requirements. The executive committee ultimately reviews/approves/ and or adjusts recommendations from the system wide compensation committee and sets compensation. The process was last reviewed in 2014.”

“Governing documents and conflict of interest policy are available upon request. Audited financial statements are available for public viewing on our website.”

“The compensation of asbury communities' officers and key employees as shown on the form 990, part vii, section a, not only relates to their responsibilities at asbury communities, inc. But also reflects their responsibility to provide executive management functions, as well as policy and overall guidance to its supported and related organizations. These organizations include asbury atlantic, inc., asbury-solomons, inc., inverness village, an oklahmoa not-for-profit corporation, asbury communities hcbs, inc., and asbury foundation, inc. Asbury communities, inc., the supporting parent company alone had 67 employees as of 12/31/2014. The form 990, part vii, section a, has 26 individuals earning $100,000 or more. Asbury has a high percentage of highly compensated individuals since these support positions are not staffed at the affiliate level. These asbury communities, inc. Executives provide guidance and support for all of our supported organizations which have over 2,100 total employees. The 2014 consolidated audited financial statements for asbury communities, inc. Had total revenues of $179.2 million and total assets in excess of $568 million.”

“As a not-for-profit organization, asbury communities, inc. Is committed to being a valued member of the community in the regions where it operates. Our leaders, associates and residents work with community service organizations, health providers and foundations on programs identified as needed in the local community, comport with asbury's mission to "do all the good we can" and that focus on four areas in particular. These broad categories, some of which asbury communities is directly involved in and some of which it supports in its role as a supporting organization in the asbury system, are: benevolent care, training the next generation of leaders in the senior services professions, working with and supporting other senior services organizations, and going green and sustainable. Asbury's community benefit work is focused on improving the lives of those who live in the communities in which the services are provided, regardless of whether the individuals live on or off an asbury campus. To achieve this goal asbury often works with other community organizations. Asbury works hard each year to expand its work in the community in meaningful ways that it can sustain and grow. Examples of asbury's activities are set forth below. Benevolent care: asbury communities provides administrative support to the benevolent care program which provides financial support to residents who outlive their resources through no fault of their own. This support included: -asbury methodist village $1,050,758 -asbury solomons $93,531 -bethany village $954,049 -inverness village $151,154 -springhill $33,100 for a total of $2,282,592 which is mainly supporting seniors in residential living and assisted living for which there is no other source of support. If there was not benevolent care the individual seniors would need to move and most likely rely on government services. Asbury fulfills its commitment to training the next generation of leaders in the senior living professions primarily in two ways: 1) work with the state and national association leadingage, and 2) through individual internships in its communities. - asbury's work with leadingage includes: -24 hours of board service volunteered by an asbury vice president -an asbury executive serving on the audit committee of leadingage -participation by 4 asbury leaders in the leadingage hackfest, an event that challenges teams of participants to "engage with age" by creating technology-driven tools aimed at improving the lives of older adults and their families. Two of the four served as team leaders and mentors to teams, with two asbury-led teams placing high in the competition. -the asbury vice president/chief financial officer provided guidance to other continuing care retirement organizations on financial ratios and benchmarking at the leadingage annual meeting. The asbury vice president chief financial officer lectured to george washington university master's degree candidates on senior living finances and educating the industry's future leaders. Supporting other local senior services: - asbury associates, at all levels of the organization, provide leadership and education to local governments and employees of other senior services organizations. For example, asbury staff presented a program on health care reform to the staff of the calvert county, maryland, office on aging, and worked closely through presentations, board service, as well as program development and implementation with the united methodist association for senior organizations, and leadingage on both state and federal levels. Asbury associates are also actively engaged on the board and as examiners for carf-ccac, a national accrediting organization for senior living communities, and carf international, a non-profit accreditor of health and human services. Going green and sustainable: - asbury solomons' oyster gardening project surpassed 700,000 oysters planted on the community's breakwater, furthering the state of maryland's recovery”

“Transfers to and from supported organizations 3,288,631.”