Spalding University Inc

“It is spalding university's policy that the audit committee will be responsible for the internal review of the internal revenue service form 990 that is to be filed on behalf of spalding university. Upon approval of the audit committee, the form 990 shall be presented to the board of trustees for their review. After distribution to the full board of trustees, the audit committee chair will approve the filing of the form 990 with the irs. The board of trustees is relying on the university's staff, the audit committee and independent accountants to complete and examine the form 990. A board resolution is not required in order for the form 990 to be filed.”

“Individuals are asked to re-affirm the policy each year. The policy is reviewed and new board members sign forms when they join the board. The responsibility of avoiding and managing conflicts of interest begins with the board of trustees and includes all covered persons. Disclosure is required of relationships and business affiliations that reasonably could give rise to conflicts of interest involving the university. The disclosure form shall be furnished annually to report and keep current potential conflict areas. Whenever changes occur, disclosures are to be updated in writing as soon as possible. Whenever possible, covered persons should disclose expected changes or newly anticipated conflicts at least thirty (30) days before they occur. The disclosures shall be reviewed by the reviewer, a subcommittee of the governance committee of the board of trustees or its designate, and an initial determination on whether a conflict exists will be made after a review of all the material facts. If the reviewer determines that no conflict exists, that determination will be made in writing and presented to the full governance committee at its next regularly scheduled meeting for final review and determination. If the reviewer determines there is a conflict, the reviewer shall inform the covered person and indicate that the matter is being referred to the governance committee whose decision shall be final unless the matter is further referred to the full board of trustees, in which event the board's decision shall be final. The governance committee or board of trustees (as applicable) may authorize or approve the conflicting interest transaction under procedures and criteria as specified under applicable kentucky statute. Trustees and committee members who have a conflict of interest in any matter may participate in the discussion of the matter after disclosing any conflict of interest, but shall refrain from voting on the matter.”

“The board of trustees reviews and determines the compensation of the university president using cupa salary scale and other relevant economic and industry data. Documentation of deliberations were retained by the executive committee in meetings notes. Process was last conducted in june 2013, as part of a five-year contract.”

“The university president, provost and human resources manager review and determine the compensation of the other officers and key employees using cupa salary scales and other relevant economic and industry data. Documentation of deliberations were retained in each relevant meeting's notes. Process was last conducted in june 2014.”

“Financial statements, governing documents, and conflict of interest policies are not required disclosures pursuant to internal revenue code (irc) section 6104.”

“Change in value of split interest agree - 2993; change in value of swap agreement - 171528;”