Denver Area Educational Telecommunications Consortium DBA 35 MIL

“The president of the organization appoints two directors.”

“The organization does not have a committee with authority to act on behalf of the governing body.”

“The 990 is reviewed by the organization's accountants,cfo and at least one corporate officer. Additionally the form is presented to the board members after it is filed.”

“Each responsible person who is a director or officer has a duty to disclose to the board (or to any committee of the board that is considering a decision to which the conflict applied) the material facts of any proposed transaction or action of the organization in which such responsible person has any conflicts. Each responsible person who is a staff member has a duty to disclose to the business manager of the organization and his/her immediate supervisor the material facts of any proposed transaction of the organization in which such person has any conflict. Implementation of the conflict of interest policy relies on such disclosure. A responsible person who fails to follow the protocols established in the conflict of interest policy shall be subjected to meaningful disciplinary action by the board of directors up to and including removal from the board or their position within the organization.”

“All services performed are from shared employees of a shared services company. This company has an oversight committee made up of board members of nonprofit organizations that it serves. This oversight committee has been charged by the nonprofit organization boards to oversee personnel matters including executive and staff compensation. Staff prepared a semi- annual salary benchmarking report for all staff positions and an annual ceo salary review that described each position and compared the position to three salary surveys: mountain states employee council 2014 non- profit/foundation compensation, mountain states employees council 2015 colorado benchmark compensation,and 2014 colorado non-profit association salary and benefit survey. In addition, the salary benchmarking report was reviewed by an independent third party contractor to ensure the use of proper methodology and ethical standards. These salaries are effective for the fiscal year 2016. This report, the third party contractor report and supporting documentation was reviewed in depth by the oversight committee which summarized its review to all of the boards.”

“See the explanation shown for form 990, part vi, line 15a.”

“The organization does not makes its governing documents and financial statements available to the public.”

“The corporation is organized and will be operated exclusively for "charitable, scientific and educational- and "social welfare" purposes within the meaning of sections 501(c)(3) and 501(c)(4), respectively, of the internal revenue code. To this end, the nonprofit shall undertake activities to: support the provision of quality and diverse instructional media content and capabilities to educators and students, including, but not limited to, data services and instructional video provided to accredited educational institutions and governmental organizations engaged in the formal education of enrolled students. Foster open, honest and outspoken media that help users to be a popular democratic check on both government power and concentrated private privilege; expand the dissemination of media, and points of view carried by them, that offer dissenting, alternative, or critically constructive information and concepts to the marketplace of ideas in both local and global contexts; engage in additional social welfare, charitable, scientific, and/or educational activites as are consistent with operations that may be undertaken by organizations described in, and thus exempt from taxation under, section 501(c)(4) of the internal revenue code, as now enacted or hereafter amended.”

“Background these additional, voluntary disclosures are intended to give the interested reader greater insight into how and why denver area educational telecommunications consortium, inc. D/b/a voqal denver operates its numerous programs and initiatives, both through its own efforts and through the limited liability companies of which voqal denver is part owner. On behalf of a number of nonprofit organizations, voqal denver's president, john schwartz, led an effort to apply for what were then referred to as instructional television fixed service (itfs ) licenses from the federal communications commission. Those applications were originally submitted in the early 1980s. Mr. Schwartz believed that separate nonprofit organizations with local boards of directors would better serve the schools and communities covered by these licenses. In the end, five nonprofits led by mr. Schwartz applied for and received a total of 11 itfs licenses. Today, mr. Schwartz remains the president of those five nonprofits, which will hereafter be referred to as the voqal nonprofits. Voqal denver is one of those five. For over two decades, voqal denver provided free educational video programming to schools via its fcc-licensed itfs station. While doing so, it shared some of its overhead and administrative costs with the other four voqal nonprofits, which were providing very similar service to their local communities. This approach resulted in significant cost savings, allowing voqal denver to deliver better educational service. The sharing of personnel and other resources among the voqal nonprofits was the beginning of what would later become ebs support services, llc (ebsss) - the umbrella service organization that today provides personnel and operational support to all five voqal nonprofits. To expand their ability to serve education and otherwise benefit the public, the voqal nonprofits entered into various spectrum use agreements with commercial telecommunications operators. Voqal allowed commercial firms to use their itfs, and, later, educational broadband service (ebs) excess spectrum capacity in their wireless networks. In exchange, these agreements provided significant financial benefits through spectrum royalty payments, as well as material in-kind educational benefits such as high- speed broadband internet accounts. The voqal nonprofits' current spectrum agreements are with a sprint subsidiary. With the increased resources afforded by these most recent spectrum agreements, the voqal nonprofits, including voqal denver, expanded the number and reach of their educational programs to include new education ventures, affordable internet service for schools and nonprofits, cash grants, ebs spectrum advocacy, and more. As it expanded, voqal denver continued to share resources with the other voqal nonprofits. For this reason, in 2009 the five voqal nonprofits formed ebs support services, llc. Voqal denver owns 11.14% of ebs support services, llc and reimburses it for the cost of leased personnel, as well as shared office space and equipment. Ebsss, llc, as well as the other limited liability companies listed below, are all owned exclusively by the voqal nonprofits; there are no other owners. In 2013, to extend these relationships and gain better public recognition for shared work, ebsss secured the "voqal" trademark and the five nonprofits, including voqal denver, adopted the voqal brand. Voqal has strived to fulfill the mission of ebs, from its beginnings providing free, itfs video to schools to recent efforts to support change- makers in education. While some voqal denver programs serve what many would consider traditional educational entities like k-12 schools, voqal embraces a broader view of education and aims to ensure equal access to knowledge to foster a stronger, healthier democracy. Our programs are often aimed at the root causes that bar access to knowledge both in and out of traditional brick and mortar institutions. Examples of more traditi”

“The organization participates in the education venture fund as described on schedule o.”

“The organization ceased education on demand in july 2015. This ended the era of the organization providing instructional content to schools.”

“The organization through its investment in an unrelated organization taxable as a partnership undertook activities to expand the dissemination of media, and points of view carried by them, that offer dissenting, alternative, or critically constructive information and concepts to the marketplace of ideas in both local and global contexts.”