Claremont Graduate University

“CGU utilizes a process for review of the IRS Form 990 Return of Organization Exempt from Income Tax that involves multiple layers of management as well as governing board members. CGU has engaged an outside accounting firm to prepare the 990 using information provided by the Office of Financial Services, the Office of Human Resources, and the Treasurer's Office, and changes are made as needed. Once a revised draft is available, it is reviewed by the Controller and the Associate Vice President of Finance and Administration. After this review and any resulting changes are complete, the revised draft is provided to members of the CGU Audit Committee for questions and comments. Once questions and comments from the Audit Committee are fielded and issues resolved, the Audit Committee accepts the 990 and the 990 is provided to all voting members of the Board of Trustees prior to filing.”

“The University maintains a policy that any Board member, Senior Management personnel, and such other persons designated by the President, or persons who exercise discretionary authority on behalf of Claremont Graduate University (CGU or University), defined collectively as fiduciary personnel, may not use this authority for his or her own benefit. It is University policy that all such personnel have a fiduciary duty to be free from the influence of any conflicting interest when acting on behalf of CGU. All dealings are conducted on the sole basis of what is in the best interest of the University without favor or preference to third parties based on personal considerations. To this end CGU enforces the following four guidelines concerning conflict of interest: 1. No fiduciary of the University shall accept from any person, directly or indirectly whether by himself or herself or through a family member or through any business or professional associate, any gift, favor, service, employment, or any other thing of value, which he or she knows or has reason to believe is made or offered to him or her with the intent to influence him or her in the performance of his or her fiduciary duties to the University. 2. No fiduciary, who is a partner, officer, or employee of a partnership, firm, or corporation or who owns or controls a significant financial interest in such organization, shall represent, appear for, or negotiate on behalf of the University in connection with the acquisition or sale by CGU of any interest in real or personal property, tangible or intangible, to or from such partnership, firm, or corporation. 3. No fiduciary shall participate by discussion, voting, or by any other action taken by the Board of Trustees or any committee thereof, in the enactment of or defeat of a motion which relates to any transaction with any party referred to in paragraph 2 above. In case any such matter is discussed at any meeting where any fiduciary who has such an interest is present, he or she shall promptly disclose his or her interest in the matter to be voted on to the chairman of the meeting or the Vice President for Finance & Administration/Treasurer (VP/Treasurer) of CGU. He or she shall not vote on the matter and at the discretion of the disinterested members present may be required to leave such meeting. 4. In addition to the foregoing, all fiduciary personnel shall disclose to the VP/Treasurer the existence of any relationship that may be deemed a direct or indirect conflict of interest with Claremont Graduate University. For this purpose, a "direct or indirect conflict of interest" means: a) Any situation in which fiduciary personnel have or may be construed to have a direct or indirect personal or financial interest in any business affairs of the University, whether related to a proposed contract or transaction to which the University may be a party or may be considering or, b) Because of a similarity of business interests or affairs, it may be construed that the University is competing with the personal or financial interest of the fiduciary personnel. The Board Chairperson and VP/Treasurer monitor for conflict of interest throughout the calendar year. On an annual basis the VP/Treasurer polls all Board members and Senior Management personnel for conflict of interest in writing. The written disclosures are reviewed, and disclosed in accordance with the University's Conflict of Interest Policy.”

“The Assistant Vice President for Human Resources collects and analyzes published compensation data from peer group institutions, local surveys, and the other members of the Claremont Colleges for the position of the President. This information is reviewed by the Vice President for Finance and Administration and then forwarded to the Board Chair, who also reviews the data. The Board Chair presents a recommendation of compensation for the President to the Board of Trustees for approval. After review and discussion, the Board of Trustees determines and approves compensation for the President. Minutes of the Committee meetings and the analyses are kept confidential, limited to the Board of Trustees, the president, Vice President for Finance and Administration, and the Assistant Vice President for Human Resources. The University employs the President via an employment contract approved by the Board of Trustees. The Assistant Vice President for Human Resources also collects and analyzes published compensation data from peer group institutions, local surveys, and the other members of the Claremont Colleges for each senior administrator and other key employee positions. The Vice President for Finance and Administration reviews the data. Then, it is forwarded to the President along with performance evaluations and salary recommendations. After review and discussion, compensation is determined and approved for each senior administrator and other key employees.”

“CGU posts the governing bylaws, conflict of interest policy, and audited financial statements to the CGU website.”

“Actuarial adjustment 268,903. Income from K-1s Adjustment to contributions received -15,000.”