Legacy Community Pharmacy Services

“990 review policy: the form 990 is prepared by an independent accounting firm based on the audited financial statements and information provided by the accounting department of the organization. A draft of the organization's form 990 is first reviewed in detail by top management and the finance committee of the board of directors. Once all changes are made, a final draft is distributed to the entire board for comment.”

“Conflict of interest policy: each board member is required to annually sign a conflict of interest policy which requires them to disclose any potential conflicts of interest. The chairman of the board, along with the executive director, reviews any potential conflict. If the conflict is pertinent to a vote, the member is required to excuse themselves from the vote. Members of the board may not be an employee or independent contractor, or the spouse, spousal equivalent, child, parent, brother or sister by blood or marriage of an employee or independent contractor of the corporation. Members of the board, employees and independent contractors of the corporation, who also work for a corporation which is doing business with the corporation must disclose that relationship to the executive director, or, in the case of a board member, to the board chair. The corporation retains the right to take steps to protect its interest in such circumstances. No board member of employee may participate in the selection, award or administration of a contract in which he/she or his/her immediate family has a financial interest or a prospective financial arrangement. This policy does not prohibit outright the awarding of a contract to any agency or firm meeting the condition cited above. Rather this policy calls for the full prohibition of the employee or board member from participating in this award, selection or administration of such a contract. Board members should take caution not to create the appearance of a conflict of interest if in the performance of their duties at their regular place of employment they are called upon negotiate with the corporation on the behalf of their employer. Board members should, whenever possible, abstain from such activities. The corporations will be sensitive to, and will seek to avoid, organizational conflicts of interest and non-competitive practices in the procurement of goods and services. In addition, corporate officers and key employees are required to annually disclose potential conflicts of interest.”

“Executive director compensation review: a committee of the board of directors is responsible for the review process of the executive director, who receives compensation from legacy community health services, a related organization. The compensation review was started in may 2018 utilizing an outside consultant - gallagher. The committee then recommends the compensation package to the board who approves it. This review is documented in the board of director committee minutes.”

“Document disclosure: governing documents, conflict of interest policy, and financial statements are made available upon request for a legitimate business purpose, as determined by top management. Copies will be mailed if a business purpose is determined.”