Beacon House

“The board's finance committee shall have the responsibility for reviewing the organization's form 990 (including all pertinent schedules) before it is filed with the internal revenue service. A draft of the form 990 should be ready for review by the finance committee no later than one month prior to the filing deadline. After the draft of the form 990 has been obtained by the finance committee, they will have no more than two weeks to complete their review. In conducting their review of the draft of the form 990, it is preferred that the finance committee shall conduct a top-level or big-picture type of review, however, if the finance committee desires or deems it necessary to conduct a more detailed review of the form 990, then they should contact the preparer of the form 990 to request copies of the relevant detailed tax return workpapers which they would like to see. Once the finance committee has completed their initial review of the form 990, a meeting or conference call will be scheduled with the preparer of the form 990 (regardless of whether the form 990 is externally or internally prepared) to discuss any questions, comments, and suggested revisions identified by the finance committee. The preparer of the form 990 should make any revisions to the form 990 as soon as feasibly possible to ensure that the form 990 is filed with the internal revenue service on a timely basis. All of the questions, comments, and suggested revisions set forth by the finance committee should be documented, along with any responses from the preparer of the form 990, if applicable. After the form 990 has been reviewed by the finance committee and filed with the internal revenue service, the finance committee will make a presentation at the next full board of directors meeting to update the full board regarding their review of the form 990; at this meeting with the full board of directors, it is not required for the finance committee to review all of their questions, comments, and suggested revisions; a summary of their more important points will be sufficient.”

“Procedures 1. Duty to disclose in connection with any actual or possible conflict of interest, an interested person must disclose the existence of the financial interest and be given the opportunity to disclose all material facts to the directors and members of committees with governing board delegated powers considering the proposed transaction or arrangement. 2. Determining whether a conflict of interest exists after disclosure of the financial interest and all material facts, and after any discussion with the interested person, he/she shall leave the governing board or committee meeting while the determination of a conflict of interest is discussed and voted upon. The remaining board or committee members shall decide if a conflict of interest exists. 3. Procedures for addressing the conflict of interest a. An interested person may make a presentation at the governing board or committee meeting, 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 governing board or committee shall, if appropriate, appoint a disinterested person or committee to investigate alternatives to the proposed transaction or arrangement. C. After exercising due diligence, the governing board or committee shall determine whether beacon house 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 governing board or committee shall determine by a majority vote of the disinterested directors whether the transaction or arrangement is in the organization'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. 4. Violations of the conflicts of interest policy a. If the governing board or committee has reasonable cause to believe a member has failed to disclose actual or possible conflict. Each board member and employee must annually complete a conflict interest statement to properly disclose any potential conflicts.”

“When determining the annual compensation for any insider, the organization shall always undertake and satisfy all three prongs of the rebuttable presumption set forth in the internal revenue code regarding intermediate sanctions (4958). 1.compensation arrangement approved in advance by independent members of the organization's governing body (board of directors or a subcommittee thereof) that is composed of persons who do not have a conflict of interest with respect to the compensation arrangement. 2.before making the reasonable compensation determination, the governing body (or subcommittee thereof) relied upon comparability data (comparability data includes compensation paid by comparable and similarly situated entities) in deciding whether to approve the compensation. 3.governing body contemporaneously documents their basis for making its reasonable compensation determination, as follows: a.terms of the approved compensation and the date approved by the board b.members of board present during debate on the compensation amount and those who voted on it and how they voted on it c.description of the comparability data obtained and relied upon and how such data was obtained d.any actions by board member having a conflict of interest (e.g. Disclosure of the conflict of interest; recusal from the discussion) e.documentation of the basis for the compensation determination before the later of the next board meeting or 60 days after the final actions of the authorized body are taken form 990, part vi, section b, line 15b: when determining the annual compensation for any insider, the organization shall always undertake and satisfy all three prongs of the rebuttable presumption set forth in the internal revenue code regarding intermediate sanctions (4958). 1. Compensation arrangement approved in advance by independent members of the organization's governing body (board of directors or a subcommittee thereof) that is composed of persons who do not have a conflict of interest with respect to the compensation arrangement. 2. Before making the reasonable compensation determination, the governing body (or subcommittee thereof) relied upon comparability data (comparability data includes compensation paid by comparable and similarly situated entities) in deciding whether to approve the compensation. 3. Governing body contemporaneously documents their basis for making its reasonable compensation determination, as follows: a. Terms of the approved compensation and the date approved by the board b. Members of board present during debate on the compensation amount and those who voted on it and how they voted on it c. Description of the comparability data obtained and relied upon and how such data was obtained d. Any actions by board member having a conflict of interest (e.g. Disclosure of the conflict of interest; recusal from the discussion) e. Documentation of the basis for the compensation determination before the later of the next board meeting or 60 days after the final actions of the authorized body are taken it is essential that the individuals whose compensation is being discussed not be present during such discussions. All identified payments of unreasonable compensation to an insider should be corrected (undoing of the unreasonable compensation to the extent possible) as soon as feasibly possible; for example, the insider should payback to the organization the unreasonable compensation amounts plus interest to put the organization in a financial position no worse than that in which it would be if the insider were dealing under the highest fiduciary standards. The reasonable compensation discussion should be undertaken by the board at least annually; the reasonable compensation binder maintained for each insider should also be prepared, or at least updated, annually. The organization shall refrain, whenever possible, from paying contingent compensation to insiders and also avoid the payment of golden parachute payments to insiders.”

“AVAILABLE UPON REQUEST.”