The Olympic Club Foundation

“The taxpayer's accounting firm forwarded the form 990 to the executive director who then forwarded the form 990 to the finance committee, which included all members of the executive committee, for their review prior to filing. Members of the executive committee were encouraged to review the form 990 and to forward their questions to the executive director. Either the executive director or the accounting firm addressed the questions from the executive committee. The draft 990 was electronically available to all board members to review. The board president and the board treasurer approved the form 990 prior to filing.”

“The foundation's conflict of interest policy applies to any director, officer, or member of a committee to which the board has delegated powers who has a direct or indirect financial interest in any transaction with the foundation. Interested persons must disclose the existence of the financial interest, including all material facts, to the board of directors (or its duly designated committee). The remaining disinterested board or committee members determine whether a conflict of interest exists with regard to the transaction or arrangement. If a conflict of interest is determined to exist, the person with the conflict must recuse themselves from deliberation and voting on the transaction, and the remaining disinterested board or committee members shall determine whether the foundation 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. If not, the disinterested board or committee members determine by majority vote whether the transaction or arrangement is in the foundation's best interest and whether it is fair and reasonable. To ensure that the foundation operates in a manner consistent with its charitable purposes and does not engage in activities that could jeopardize its tax-exempt status, periodic reviews of compensation arrangements and partnerships, joint ventures, and arrangements with management organizations shall be conducted. The board may, at its discretion, engage outside experts to assist in evaluating whether such arrangements conform to the foundation's written policies, reflect arm's length negotiations, and do not result in private inurement or impermissible private benefit. The board retains ultimate responsibility for monitoring and enforcement of the conflict of interest policy.”

“The foundation uses market comparison and experience in determining and approving compensation and benefit payments to officers, directors and key employees. The foundation employees completed self evaluations that were submitted to the executive committee. The committee solicited employee reviews from committee chairs. Compensation was voted on in an executive session of a board of directors meeting.”

“The foundation makes its governing documents, conflict of interest policy and financial statements available upon request for the same period of time set forth in sec. 6104(d).”