Sanctuary Golf Club Foundation Inc.

“No review was or will be conducted.”

“3.procedures for addressing the conflict of interest. (a)an interested person may make a presentation at the board, 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 board, if appropriate, shall appoint a disinterested person or committee to investigate alternatives to the proposed transaction or arrangement. (c)after exercising due diligence, the board shall determine whether the corporation 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 under circumstances not producing a conflict of interest, the board shall determine by a majority vote of the disinterested governors whether the transaction or arrangement is in the corporation's 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.”

“No documents available to the public”

“The sanctuary golf club foundation, inc. Is organized exclusively for charitable purposes. The principal purpose for which the corporation is organized is to receive and administer funds for charitable purposes within the sanibel and captiva island, florida community, including making distributions to organizations that qualify as exempt organizations under section 501(c)(3) of the united states internal review code of 1986, as amended (or corresponding provision of any future law of the internal revenue service or department of treasury) (the "code"). To provide needs based assistance to individuals and families in accordance with a program, policies and procedures adopted by the board of directors from time to time. In addition, to provide scholarships to those who qualify in accordance with the program adopted by the board of directors.”