IL Circolo Inc.

“ROBERT DE ANGELIS - Exec DirROSE DE ANGELIS - Director”

“The president reviews the form 990 prior to filing.”

“1. Interested PersonAny director, principal officer, or member of a committee with governing board delegated powers, who has a direct or indirect financial interest, as defined below, is an interested person.2. Financial InterestA person has a financial interest if the person has, directly or indirectly, through business, investment, or family:a. An ownership or investment interest in any entity with which the Organization has a transaction or arrangement,b. A compensation arrangement with the Organization or with any entity or individual with which the Organization has a transaction or arrangement, orc. A potential ownership or investment interest in, or compensation arrangement with, any entity or individual with which the Organization is negotiating a transaction or arrangme Compensation includes direct and indirect remuneration as well as gifts or favors that are not insubstantial. A financial interest is not necessarily a conflict of interest. Under Article III, Section 2, a person who has a financial interest may have a conflict of interest only if the appropriate governing board or committee decides that a conflict of interest exists. 1. Duty to DiscloseIn connection with any actual or possible conflict of interest, an interested person must disclose the existence ofthe financial interest and be given the opportunity to disclose all material facts to the directors and members ofcommittees with governing board delegated powers considering the proposed transaction or arrangement. 2. Determining Whether a Conflict of Interest ExistsAfter disclosure of the financial interest and all material facts, and after any discussion with the interestedperson, he/she shall leave the governing board or committee meeting while the determination of a conflict ofinterest is discussed and voted upon. The remaining board or committee members shall decide if a conflict ofinterest exists. 3. Procedures for Addressing the Conflict of Interesta. An interested person may make a presentation at the governing board or committee meeting, but after the presentation, he/she shall leave the meeting during the discussion of, and the vote on, the transaction or arrangement involving the possible conflict of interest.b. The chairperson of the governing board or committee shall, if appropriate, appoint a disinterested person or committee to investigate alternatives to the proposed transaction or arrangement.c. After exercising due diligence, the governing board or committee shall determine whether the Organization can obtain with reasonable efforts a more advantageous transaction or arrangement from a person or entity that would not give rise to a conflict of interest. d. If a more advantageous transaction or arrangement is not reasonably possible undercircumstances not producing a conflict of interest, the governing board or committee shalldetermine by majority vote of the disinterested directors whether the transaction or arrangement is in the Organizations best interest, for its own benefit, and whether it is fair and reasonable. In conformity with the above determination it shall make its decision as to whether to enter into the transaction or arrangement. 4. Violations of the Conflict of Interest Policya. If the governing board or committee has reasonable cause to believe a member has failed todisclose actual or possible conflicts of interest, it shall inform the member of the basis for such belief and afford the member an opportunity to explain the alleged failure to disclose.b. If, after hearing the members response and after making further investigation as warranted by the circumstances, the governing board or committee determines the member has failed to disclose an actual or possible conflict of interest, it shall take appropriate disciplinary and corrective action. Article IVRecords of ProceedingsThe minutes of the governing board and all committees with board delegated powers shall contain:a. The names of the persons who disclosed or otherwise”

“ARTICLE NINESalariesThe Board of Directors shall hire and fix the compensation of any and all employees that they, in theirdiscretion, may determine are necessary in the conduct of the Corporations business.”

“ARTICLE NINESalariesThe Board of Directors shall hire and fix the compensation of any and all employees that they, in theirdiscretion, may determine are necessary in the conduct of the Corporations business.”

“Documents are available on our website”

“Answers to questions to Part VI were incorrect. We are amending the return to correct those answers and provide additional information via sch O.”