| FORM 990, PAGE 6, PART VI, LINE 11B |
THE TREASURER AND THE EXECUTIVE COMMITTEE INITIALLY REVIEW AND APPROVE THE ENTITY'S FORM 990 AND THEN A COPY IS PROVIDED TO EACH BOARD MEMBER FOR COMMENT. IF NO ISSUES ARE RAISED, THE FORM 990 IS THEN FILED WITH THE APPROPRIATE AGENCY. |
| FORM 990, PAGE 6, PART VI, LINE 12C |
CONFLICT OF INTEREST POLICY COMPLIANCE PROCEDURES: THE ORGANIZATION'S CONFLICT OF INTEREST POLICY MANDATES AS FOLLOWS: THE BOARD OF DIRECTORS SHALL COMPLETE A FINANCIAL DISCLOSURE - CONFLICT OF INTEREST FORM ON AN ANNUAL BASIS TO IDENTIFY POTENTIAL CONFLICTS OF INTEREST. THESE DISCLOSED POTENTIAL CONFLICTS OF INTEREST SHALL BE EVALUATED BY THE CHAIR OF THE BOARD OF DIRECTORS AND THE EXECUTIVE DIRECTOR TO DEFINE A STRATEGY FOR MANAGING THEM IN ACCORDANCE WITH THE PRINCIPLES OUTLINED IN THIS POLICY. HHH DIRECTORS WHO PROPOSE TO CONDUCT AN ACTIVITY OR ENTER INTO A RELATIONSHIP WHICH COULD BE A CONFLICT SHALL FULLY DISCLOSE IN WRITING THE NATURE AND EXTENT OF THE POTENTIAL CONFLICT TO THE CHAIR OF THE BOARD OF DIRECTORS WHO SHALL MAKE A PRELIMINARY DETERMINATION OF THE NECESSARY PROPOSED ACTION TO RESOLVE THE CONFLICT. A COPY OF SUCH DETERMINATION SHALL BE SENT TO THE EXECUTIVE DIRECTOR FOR A FINAL DETERMINATION AS TO WHETHER THE PROPOSED ACTION IS CONSISTENT WITH THIS POLICY AND ANY APPLICABLE LAWS OR REGULATIONS. ALL COMMUNICATIONS REGARDING DISCLOSURES AND DETERMINATIONS OF CONFLICT OF INTEREST SHALL BE RETAINED IN CONFIDENCE. BECAUSE THIS POLICY DOES NOT TREAT ALL POTENTIAL CONFLICTS OF INTEREST BY WAY OF SPECIFIC PROVISIONS, HHH STRONGLY ENCOURAGES ALL DIRECTORS TO SEEK ADVICE ON TRANSACTIONS WHICH PRESENT POTENTIAL CONFLICTS OF INTEREST BEFORE COMMITTING TO SUCH TRANSACTIONS. QUESTIONS CONCERNING THE CONFLICT OF INTEREST POLICY SHOULD BE ADDRESSED TO THE EXECUTIVE DIRECTOR OR THE CHAIR OF THE BOARD OF DIRECTORS. ADMINISTRATION OF POLICY - CONFLICT OF INTEREST SELECT PERSONNEL, AS DETERMINED BY THE BOARD OF DIRECTORS, SHALL COMPLETE A FINANCIAL DISCLOSURE - CONFLICT OF INTEREST FORM ON AN ANNUAL BASIS TO IDENTIFY POTENTIAL CONFLICTS OF INTEREST. THESE DISCLOSED POTENTIAL CONFLICTS OF INTEREST SHALL BE EVALUATED BY THE CHAIR OF THE BOARD OF DIRECTORS AND THE EXECUTIVE DIRECTOR, TO DEFINE A STRATEGY FOR MANAGING THEM IN ACCORDANCE WITH THE PRINCIPLES OUTLINED IN THIS POLICY. HHH PERSONS WHO PROPOSE TO CONDUCT AN ACTIVITY OR ENTER INTO A RELATIONSHIP WHICH COULD VIOLATE, OR APPEAR TO VIOLATE, THIS POLICY SHALL FULLY DISCLOSE IN WRITING THE NATURE AND EXTENT OF THE PROPOSED ACTION (INCLUDING COMPENSATION AND OTHER BENEFITS RECEIVED) TO HIS OR HER DEPARTMENTAL CHAIR OR HEAD OF HIS OR HER OPERATING DIVISION WHO SHALL MAKE A PRELIMINARY DETERMINATION IN WRITING OF THE PROPRIETY OR IMPROPRIETY OF THE PROPOSED ACTION AND OF HOW ANY POTENTIAL CONFLICTS OF INTEREST MIGHT BE MANAGED. A COPY OF SUCH DETERMINATION SHALL BE SENT TO THE EXECUTIVE DIRECTOR FOR A FINAL DETERMINATION AS TO WHETHER THE PROPOSED ACTION IS CONSISTENT WITH THIS POLICY AND ANY APPLICABLE LAWS OR REGULATIONS. FOR PURPOSES OF THIS POLICY, A GIFT WITH FAIR MARKET VALUE OF LESS THAN 100 WILL BE CONSIDERED TO BE OF NOMINAL VALUE. ALL COMMUNICATIONS REGARDING DISCLOSURES AND DETERMINATIONS OF CONFLICT OF INTEREST SHALL BE RETAINED IN CONFIDENCE. BECAUSE THIS POLICY DOES NOT TREAT ALL POTENTIAL CONFLICTS OF INTEREST BY WAY OF SPECIFIC PROVISIONS, HHH STRONGLY ENCOURAGES ALL CONTRACTED PERSONS TO SEEK ADVICE ON TRANSACTIONS WHICH PRESENT POTENTIAL CONFLICTS OF INTEREST BEFORE COMMITTING TO SUCH TRANSACTIONS. QUESTIONS CONCERNING THE CONFLICT OF INTEREST POLICY SHOULD BE ADDRESSED TO THE EXECUTIVE DIRECTOR OR THE CHAIR OF THE BOARD OF DIRECTORS. IN THE EVENT OF A CONFLICT OF INTEREST, HHH WILL TAKE WHATEVER CORRECTIVE ACTION IS NECESSARY TO PROTECT THE INTEGRITY OF THE INSTITUTION ITSELF AND ITS PROJECTS. IN THE CASE OF AN INTENTIONAL VIOLATION OF THIS POLICY, THE PENALTY FOR SUCH VIOLATION MAY RANGE FROM REPRIMAND TO TERMINATIONS DEPENDING UPON THE SEVERITY OF THE VIOLATION. |
| FORM 990, PAGE 6, PART VI, LINE 15A |
THE EXECUTIVE COMMITTEE HAS RESPONSIBILITY FOR MATTERS CONCERNING SELECTION, EVALUATION, RETENTION, REMUNERATION, AND DISMISSAL OF KEY PERSONNEL INCLUDING THE EXECUTIVE DIRECTOR. THE EXECUTIVE COMMITTEE HAS RELIED ON THE LOCAL UNITED WAY WAGE AND BENEFITS SURVEY, LOCAL WAGE COMPARISONS FROM SALARY.COM, AND AN INFORMAL SURVEY OF AREA NONPROFIT CLINICS AS COMPENSATION GUIDELINES. THE INFORMATION IS REVIEWED BY THE EXECUTIVE COMMITTEE TO BE USED, IN CONJUNCTION WITH AN ANNUAL PERFORMANCE REVIEW, TO DETERMINE THE SALARY OF THE EXECUTIVE DIRECTOR. |
| FORM 990, PAGE 6, PART VI, LINE 15B |
THE EXECUTIVE COMMITTEE HAS RESPONSIBILITY FOR MATTERS CONCERNING SELECTION, EVALUATION, RETENTION, REMUNERATION, AND DISMISSAL OF KEY PERSONNEL INCLUDING THE EXECUTIVE DIRECTOR. THE EXECUTIVE COMMITTEE HAS RELIED ON THE LOCAL UNITED WAY WAGE AND BENEFITS SURVEY, LOCAL WAGE COMPARISONS FROM SALARY.COM, AND AN INFORMAL SURVEY OF AREA NONPROFIT CLINICS AS COMPENSATION GUIDELINES. THE INFORMATION IS REVIEWED BY THE EXECUTIVE COMMITTEE TO BE USED, IN CONJUNCTION WITH AN ANNUAL PERFORMANCE REVIEW, TO DETERMINE THE SALARY OF THE EXECUTIVE DIRECTOR. |
| FORM 990, PAGE 6, PART VI, LINE 19 |
ALL INFORMATION IS AVAILABLE UPON REQUEST. |
Attach to Form 990 or 990-EZ.