Stewart Welfare Benefit Trust

“The organization's process for review of the form 990 is as follows: a drafted version of the form 990 is completed by a third party paid preparer based on information provided. Upon completion, the draft version is reviewed by the governing body of trustees of the organization for comments or changes. Once approved, the form 990 is signed by the delegated trustee of the organization.”

“During 2009, the board of trustees formally approved and adopted the "sisco" conflict of interest policy (as it may be amended from time to time) retroactive back to january 1, 2009. "swbt" has made the "sisco" conflict of interest policy available to all its employees and the governing body of trustees of the organization via the stewart code of business conduct and ethics policy. This policy is monitored and enforced through "sisco's" quarterly sarbanes oxley compliance procedures.”

“Swbt did not pay compensation from trust assets to any of the members of the governing board of trustees or to "sisco" or to the "company's" ceo, executive directors, top management officials, officers, or key employees. Part vi, section b, line 16a and b although sisco invests in affiliated business arrangements with taxable entities, the swbt did not invest in, contribute assets to, or participate in a joint venture or similar arrangement.”

“The organization's governing documents, conflict of interest policy, and financial statements are available upon request via the following address: wanda johnson, stewart welfare benefit trust c/o stewart title guaranty co, 1980 post oak blvd ste 900 houston, tx 77056”

“Stewart welfare benefit trust ("swbt") is a health and welfare benefit program sponsored by stewart title company and its participating affiliates (collectively the "company"). Under the terms of the agreement with the company, the program has been designed to provide and maintain health and welfare benefits for enrolled employees of the company and certain members of their families. The company has appointed trustees and an employee benefits committee. The trustees have the responsibility for the administration of the trust and working with the company in the trust's operations. The employee benefits committee assists with reviewing claims for benefits. The company is wholly owned by stewart information services corporation ("sisco"), a pubicly traded company. References to policies of sisco will be made throughout this return.”

“The organization does not have a committee that assumes responsibility for oversight of the audit, review, or compilation of its financial statements and selection of an independent accountant. The trustees oversee the audit.”