Harrison Hotel Inc.

“The corporate controller reviews form 990 before it is filed.”

“All board members, officers, and key employees are required to complete an annual questionnaire which asks them to disclose if they, their family members, any entity where they or their family member owned more than 35% or any profit entity where they or their family member owned more than 5% engaged in any business transactions over $10,000 with rcd or any of its related entities. It also asks whether they had a family or business relationship with any other board member or key employee. Rcd's bylaws and personnel handbook govern how actual or apparent conflicts of interests that may impact the organization's staff or board of directors are handled. Staff are to avoid even the appearance of a conflict of interest, and gifts and renumerative activity related to rcd duties are stictly limited. The bylaws require that no member of the board of directors shall have any financial interest in an organization doing business with rcd without disclosure to the board. At that point, the majority of the board must vote on a finding that the organization could not obtain a more advantegeous arrangement with reasonable effort, to the benefit of the organization, and its at a fair and reasonable price.”

“Rcd has instituted a process to determine fair compensation for its ceo and key employees as follows. The ceo has an annual evaluation meeting with the executive committee of the board of directors. At this meeting, potential adjustments to the ceo's salary are discussed. The ceo provides the committee with information on salaries for comparable positions. The executive committee makes a determination regarding the appropriateness of the proposed salary based on the comparables and independent research it may undertake. The executive committee is also provided with the proposed salary and information on salaries for comparable positions for key employees.”

“The organization does not make public the governing documents, the conflict of interest policy, and financial statements because the organization considers them to be internal documents.”

“There is no change in the process.”