Saint Leo University Inc.

“Description of process used to review Form 990 THE BOARD WILL RECEIVE A "FINALIZED" DRAFT COPY OF THE 990 AHEAD OF THE FEBRUARY BOARD MEETINGS. DURING THE BOARD MEETING THE MANAGEMENT TEAM WILL BRIEFLY DISCUSS AND DESCRIBE THE 990 AND WILL TAKE COMMENTS AND QUESTIONS RELATED TO THE DRAFT. THE BOARD WILL GET TO VOTE ON APPROVAL, AND ONCE APPROVED, SAINT LEO UNIVERSITY WILL SUBMIT THE 990 TO THE IRS.”

“Description of process to monitor transactions for conflicts of interest UNIVERSITY MEMBERS SHALL AVOID FAVORITISM AND ANY POTENTIAL CONFLICT OF INTEREST OR APPEARANCE OF A CONFLICT OF INTEREST THROUGH THE FOLLOWING REQUIREMENTS: A. TRUSTEES DUTIES: ELEMENTS OF A CONFLICT. A TRUSTEE HAS A CONFLICT OF INTEREST WHENEVER THE TRUSTEE OR A FAMILY MEMBER OR A BUSINESS ASSOCIATED WITH A TRUSTEE OR A FAMILY MEMBER (INSOFAR AS MAY BE KNOWN TO THE TRUSTEE) HAS AN EXISTING OR POTENTIAL FINANCIAL OR OTHER INTEREST IN A MATTER PENDING BEFORE THE BOARD OF TRUSTEES THAT MIGHT REASONABLY BE EXPECTED TO IMPAIR THE TRUSTEE'S INDEPENDENCE OF JUDGMENT OR OBJECTIVITY IN THE DISCHARGE OF GOVERNANCE RESPONSIBILITIES. "BUSINESS ASSOCIATES WITH A TRUSTEE" MEANS AN ORGANIZATION, CORPORATION, PARTNERSHIP, PROPRIETORSHIP OR OTHER BUSINESS ENTITY WITH RESPECT TO WHICH EITHER THE TRUSTEE OR (INSOFAR AS MAY BE KNOWN TO THE TRUSTEE) A MEMBER OF THE TRUSTEE'S FAMILY: A) RECEIVES COMPENSATION IN EXCESS OF $500 IN ANY MONTH OR HAS ANY CONTRACTUAL RIGHT TO FUTURE INCOME IN EXCESS OF $6,000 PER YEAR EXCLUDING COMPENSATION FROM THE UNIVERSITY, ANY GOVERNMENTAL SOURCE, INVESTMENT OR SAVINGS INCOME, RETIREMENT OR INSURANCE BENEFITS OR ALIMONY; B) SERVES AS AN OFFICER, DIRECTOR, PARTNER, OR EMPLOYEE; C) HOLDS A FINANCIAL INTEREST VALUED IN EXCESS OF $10,000. B. BOARD RECUSAL: IMPLICATIONS OF RECUSAL. CONFLICT OF INTEREST COMES IN MANY FORMS AND CANNOT BE AVOIDED ENTIRELY. RECUSAL ON A PARTICULAR MATTER BECAUSE OF A CONFLICT DOES NOT REFLECT ADVERSELY ON THE INVOLVED TRUSTEE. RATHER, IT IS SIMPLY RECOGNITION THAT, IN A COMPLEX AND INTERCONNECTED SOCIETY, CONFLICTS WILL OCCUR. WHEN THIS HAPPENS, RECUSAL IS NECESSARY TO ASSURE THAT A TRUSTEE'S INDEPENDENCE OF JUDGMENT IS NOT COMPROMISED, THAT THE PUBLIC'S CONFIDENCE IN THE INTEGRITY OF THE BOARD OF TRUSTEES IS PRESERVED, AND THAT THE UNIVERSITY'S PUBLIC MISSION IS PROTECTED. C. CONFLICT OF INTEREST AND RECUSAL PROCEDURES: REVIEW OF PROCEDURES: THE BOARD OF TRUSTEES, WITH THE ASSISTANCE OF THE UNIVERSITY COUNSEL, SHALL REVIEW ANNUALLY AT A BOARD MEETING THE REQUIREMENTS AND PROCEDURES PROVIDED IN THIS POLICY. EACH TRUSTEE SHALL SIGN A RECEIPT INDICATING THE DATE THE CODE WAS RECEIVED AND ACKNOWLEDGING THAT THEY ARE RESPONSIBLE FOR READING THE CODE AND IS BOUND BY IT. TRUSTEES CAN SEEK CLARIFICATION OF THE CODE'S PROVISIONS FROM THE UNIVERSITY COMPLIANCE OFFICER. RECUSAL: A TRUSTEE MUST SELF RECUSE FROM A MATTER IF THE TRUSTEE HAS: A) ANY FINANCIAL INTEREST, DIRECT OR INDIRECT, THAT IS INCOMPATIBLE WITH THE DISCHARGE OF THE TRUSTEE'S PUBLIC DUTIES, OR B) ANY PERSONAL INTEREST, DIRECT OR INDIRECT, THAT IS INCOMPATIBLE WITH THE DISCHARGE OF THE TRUSTEE'S PUBLIC DUTIES. D. UNIVERSITY MEMBERS EXPECTED BEHAVIOR: NO EMPLOYEE SHALL HAVE ANY INTEREST, FINANCIAL OR OTHERWISE, DIRECT OR INDIRECT, OR ENGAGE IN ANY BUSINESS TRANSACTION OR PROFESSIONAL ACTIVITY, THAT IS IN SUBSTANTIAL CONFLICT WITH THE PROPER DISCHARGE OF THE EMPLOYEE'S DUTIES. E. ADDITIONAL OBLIGATIONS: TRUSTEE AND SENIOR ADMINISTRATIVE PERSONNEL HAVE A DUTY TO THE UNIVERSITY TO ALWAYS ACT IN GOOD FAITH, WITH THE CARE AN ORDINARY PRUDENT PERSON IN A LIKE POSITION WOULD EXERCISE UNDER SIMILAR CIRCUMSTANCES, AND IN A MANNER REASONABLY BELIEVED TO BE IN THE BEST INTERESTS OF THE UNIVERSITY. PERSONS OCCUPYING THESE POSITIONS OF TRUST SHALL COMPLETE AND SUBMIT, ON AT LEAST AN ANNUAL BASIS, A CONFLICT OF INTEREST DISCLOSURE FORM ("FORM"). THE FORM SHALL BE AMENDED FOR FREQUENTLY, AS NEEDED, WHENEVER THERE IS A MATERIAL CHANGE IN THE CIRCUMSTANCES OF THE REPORTING PERSON THAT WOULD MAKE THE FORM THEN ON FILE MATERIALLY FALSE OR MISLEADING. IN ADDITION, ALL TRUSTEES MUST AGREE AND SIGN A STATEMENT OF RESPONSIBILITIES ("STATEMENT") THAT WILL PROVIDE SOME GUIDANCE ON THE SPECIAL RESPONSIBILITIES ATTENDED TO THAT OFFICE. THE FORM AND THE STATEMENT MAY BE CHANGED FROM TIME TO TIME BY THE BOARD.”

“Offices & positions for which process was used & year process began the university hires an independent consultant to review and make recommendations for the president's compensation package based off of industry, trends, etc. The executive committee of the board of directors decides what the president's compensation will be after reviewing the consultant's work and recommendation.”

“Offices & positions for which process was used & year process began the executive committee of the board of directors reviews and approves all salaries and bases their review on salary trending and other compensation related information. The process is used to establish compensation for the following offices and positions: university president vice president of academic affairs vice president of continuing education and student services vice president of business vice president of enrollment vice president of university advancement associate vice president for technology services university general counsel associate vice president of business affairs dean of business dean of arts and sciences dean of education and social services director of the center for online learning”

“How Documents are Made Available to the Public SAINT LEO UNIVERSITY WILL PROVIDE COPIES OF THE POLICIES AND DOCUMENTS UPON WRITTEN REQUEST.”

“Other Changes in Net Assets or Fund Balances Change in Value of Split Interest Agreements (547,489)”