Circular Action Alliance

“The organization has one class of members, the founding members. Founding members are those companies who have been approved by the board to be a founding member, agreed to support the purposes of the organization, and entered into a membership agreement.”

“Founding members are eligible to appont one director to serve on the board.”

“The form 990 is prepared by an independent accounting firm. The return is reviewed by the organization's financial staff, including the chief financial officer, and the finance, audit, and investment committee of the board of directors. A copy of the form 990 is distributed to the board of directors prior to filing.”

“The organization is committed to following the procedures set out in its conflict of interest policy. The conflict of interest policy is distributed to all covered officials, which includes caa officers, caa national board members, state board members, and key employees as defined by irs form 990. Covered officials are asked to sign and return a disclosure statement identifying any conflicting interests and to update the statement upon any change in circumstances. Disclosure forms are reviewed, and if a possible conflict is noted, disinterested officials of the organization's national board or a committee of the national board would consider whether a conflict of interest exists, and the procedures for addressing any conflict of interest. Covered officials with a potential conflicting interest under consideration are not permitted to participate in the national board or national board committee's deliberating and voting on the existence of any conflicting interest or transactions relating to their conflicting interest, but may disclose material facts and respond to questions.”

“In reviewing and approving the compensation of any covered individuals, the corporation's board of directors, or a delegated committee of the board (referred to as the "approval body" below), will utilize the following process: 1. Impartial decision makers. The compensation arrangement must be approved in advance (before any payment is made) by the approval body of the corporation composed entirely of individuals who do not have a conflict of interest with respect to the compensation arrangement (example: neither the executive whose compensation is being determined nor any of his/her family members may be present during the discussion/debate or participate in the vote). 2. Comparability data. When the approval body is considering compensation to covered individuals, it must rely on comparability data that demonstrate the fair market value of the compensation in question. For example, when crafting compensation packages, the approval body must secure data that documents compensation levels for similarly qualified individuals in like positions at like organizations. This data may include the following: a) expert compensation studies by independent firms; b) written job offers for positions at similar organizations; c) documented telephone calls about similar positions at both nonprofit and for-profit organizations; and d) information obtained from the irs form 990 filings of similar organizations. 3. Concurrent documentation. The approval body must document how it reached its decisions, including the data on which it relied. To qualify as concurrent documentation, written or electronic records of the approval body (such as meeting minutes) must note: a) the terms of the compensation and the date it was approved; b) the members of the approval body who were present during the debate on the compensation that was approved and those who voted on it; c) the comparability data obtained and relied upon and how the data was obtained; and d) any actions taken with respect to consideration of the compensation by anyone who is otherwise a member of the approval body but who had a conflict of interest with respect to the decision on the compensation.”

“The organization's governing documents, conflict of interest policy, and financial statements may be made available upon request.”

“Consulting: program service expenses 7,171,990. Management and general expenses 3,805,818. Fundraising expenses 1,003,947. Total expenses 11,981,755.”

“Circular action alliance has not changed it's audit oversight or selection process from the prior year.”