| FORM 990, PART III, LINE 4 |
THE AMOUNTS PRESENTED ON PART III LINE 4A REPRESENT THE TOTAL FOR ALL OF THE PROGRAMS. |
| FORM 990, PART VI, SECTION B, LINE 11B |
THE FORM 990 IS PREPARED BY COHN REZNICK, BASED ON FINANCIAL STATEMENTS AUDITED BY PRICEWATERHOUSECOOPERS, AND OTHER INTERNALLY GENERATED INFORMATION BY THE CONSERVANCY'S TAX SERVICES TEAM. THE PREPARED 990 FORM IS REVIEWED BY THE CONSERVANCY'S TAX SERVICES TEAM AND MEMBERS OF SENIOR MANAGEMENT. THE BOARD AUDIT COMMITTEE THEN REVIEWS FOR ANY SIGNIFICANT ISSUES OR JUDGMENTS RELATING TO DISCLOSURES. COPIES ARE PROVIDED TO THE FULL BOARD OF DIRECTORS PRIOR TO FILING WITH THE IRS. |
| FORM 990, PART VI, SECTION B, LINE 12C |
THE NATURE CONSERVANCY'S MONITORING AND ENFORCEMENT OF ITS CONFLICTS POLICY IS GOVERNED BY ITS CONFLICT OF INTEREST STANDARD OPERATING PROCEDURE ("SOP") WHICH IS EXCERPTED AS FOLLOWS: BEFORE ENGAGING IN ANY ACTIVITY ON BEHALF OF THE CONSERVANCY, STAFF MUST DETERMINE (A) WHETHER THE ACTIVITY COULD GIVE RISE TO A CONFLICT OF INTEREST OR THE APPEARANCE OF A CONFLICT OF INTEREST, AND, IF SO, (B) WHETHER THE CONFLICT CAN OR SHOULD BE AVOIDED TO PROTECT THE BEST INTERESTS OF THE CONSERVANCY. IF IT IS NOT REASONABLY POSSIBLE TO AVOID A CONFLICT OF INTEREST OR THE APPEARANCE OF A CONFLICT OF INTEREST, OR IT IS NOT IN THE CONSERVANCY'S BEST INTEREST TO DO SO, STAFF MUST DETERMINE APPROPRIATE STRATEGIES TO MITIGATE AND MANAGE THE POTENTIAL ADVERSE CONSEQUENCES OF THE CONFLICT AND OBTAIN APPROVAL, AS DESCRIBED BELOW, PRIOR TO ENGAGING IN THE ACTIVITY. A CONFLICT OF INTEREST EXISTS WHEN AN INDIVIDUAL WHO IS RESPONSIBLE FOR ACTING IN THE BEST INTERESTS OF THE CONSERVANCY HAS ANOTHER INTEREST OR LOYALTY THAT COULD INFLUENCE OR IMPAIR, OR MAY APPEAR TO INFLUENCE OR IMPAIR, THE INDIVIDUAL'S ABILITY TO ACT IN THE BEST INTERESTS OF THE CONSERVANCY. AS USED THROUGHOUT THE SOP, THE TERMS "CONFLICT AND "CONFLICT OF INTEREST" INCLUDE: 1. ACTUAL CONFLICTS OF INTEREST; 2. POTENTIAL CONFLICTS OF INTEREST (SITUATIONS THAT COULD BECOME ACTUAL CONFLICTS IN THE FUTURE BASED UPON FORESEEABLE EVENTS OR THE PASSAGE OF TIME); AND 3. PERCEIVED CONFLICTS OF INTEREST (SITUATIONS THAT OTHERS COULD REASONABLY PERCEIVE TO BE, OR HAVE THE APPEARANCE OF, A CONFLICT OF INTEREST). GENERALLY, CONFLICTS CAN ARISE FROM RELATIONSHIPS BETWEEN THE CONSERVANCY AND STAFF, BOARD MEMBERS, TRUSTEES AND ADVISORS, AND THE FAMILIES OF ALL THOSE GROUPS. THERE ARE VERY SPECIFIC RULES REGARDING WHO IS A "COVERED PERSON" THAT ARE GOVERNED, IN GREAT PART, BY THE U.S. INTERNAL REVENUE SERVICE REQUIREMENTS FOR PUBLIC CHARITIES. IF A CONFLICT OF INTEREST IS IDENTIFIED WHICH CANNOT REASONABLY BE AVOIDED OR IT IS NOT IN THE BEST INTEREST OF THE CONSERVANCY TO DO SO, BEFORE PROCEEDING WITH THE PROPOSED ACTIVITY, REVIEW AND APPROVAL TO PROCEED MUST BE OBTAINED AS DESCRIBED IN THIS SECTION. WHILE A REQUEST FOR APPROVAL OF A PROPOSED COURSE OF ACTION IS PENDING OR BEING CONSIDERED, THE TRANSACTION OR ACTIVITY CANNOT PROCEED. A. BOARD AND KEY EMPLOYEE CERTIFICATIONS. ALL CONSERVANCY BOARD MEMBERS AND KEY EMPLOYEES SHALL ANNUALLY CERTIFY THAT THEY HAVE READ THE CONFLICTS OF INTEREST POLICY AND HAVE DISCLOSED ALL CONFLICTS. B. SUPERVISOR APPROVAL REQUIRED. IN THE CASE OF STAFF, PRIOR TO SUBMISSION FOR REVIEW AND APPROVAL TO THE CONFLICTS COMMITTEE THE CONFLICT OF INTEREST MUST BE RAISED TO THE INDIVIDUAL'S SUPERVISOR AND THE SUPERVISOR MUST MAKE THE DETERMINATION THAT HE OR SHE (A) WISHES TO PURSUE THE PROPOSED ACTIVITY AND (B) APPROVES THE RECOMMENDED COURSE OF ACTION AND PROPOSED MITIGATION AS SUFFICIENT. SIGNATURE ON THE APPROVAL FORM INDICATES THIS APPROVAL. REGIONAL LEVEL APPROVAL ALSO IS REQUIRED. C. CONFLICTS COMMITTEE REVIEW REQUIRED. THE CONFLICTS COMMITTEE REVIEWS AND MAKES DETERMINATIONS ABOUT CONFLICTS OF INTEREST INVOLVING THE CONSERVANCY, UNLESS EXCEPTED BY THIS SOP. SEE CONFLICTS OF INTEREST FOR THE CONFLICTS COMMITTEE CHARTER, MEETING SCHEDULE AND LIST OF COMMITTEE MEMBERS. STAFF MUST SUBMIT A REQUEST FOR CONFLICTS COMMITTEE APPROVAL FORM TO THE CONFLICTS COMMITTEE WHEN SEEKING REVIEW AND APPROVAL. THE FORM SHOULD EXPLAIN WHY THE CONFLICT CANNOT OR SHOULD NOT BE AVOIDED AND RECOMMEND A COURSE OF ACTION DESIGNED TO MINIMIZE THE CONFLICT'S POTENTIAL ADVERSE CONSEQUENCES. BY SUBMITTING THE FORM, BOTH THE PERSON SUBMITTING THE FORM AND HIS/HER SUPERVISOR (A) ARE RESPONSIBLE FOR ENSURING THAT THE FORM MAKES A THOROUGH DISCLOSURE OF THE RELEVANT INFORMATION, AND (B) ARE DEEMED TO SUPPORT AND BE RESPONSIBLE FOR THE RECOMMENDED COURSE OF ACTION. THE APPROPRIATE CONSERVANCY ATTORNEY MAY BE CONSULTED TO ASSIST IN ANALYZING THE CONFLICT. BOARD MEMBERS AND TRUSTEES SHOULD CONTACT THE CONSERVANCY'S CHIEF COMPLIANCE OFFICER TO REQUEST A REVIEW BY THE CONFLICTS COMMITTEE. D. REVIEW BY THE AUDIT COMMITTEE OF THE BOARD OF DIRECTORS. ALL CONFLICTS OF INTEREST INVOLVING A MEMBER OF THE BOARD OF DIRECTORS, A DIRECTOR'S FAMILY MEMBERS, A DIRECTOR'S CONTROLLED ENTITIES, OR A SUBSTANTIAL CONTRIBUTOR SHALL BE SUBMITTED TO THE AUDIT COMMITTEE OF THE BOARD OF DIRECTORS FOR REVIEW AND DISPOSITION. REFERRAL TO THE AUDIT COMMITTEE IS MADE BY THE GENERAL COUNSEL OR CHIEF COMPLIANCE OFFICER ON BEHALF OF THE CONFLICTS COMMITTEE ALONG WITH THE RECOMMENDATION FOR DISPOSITION MADE BY THE CONFLICTS COMMITTEE. |
| FORM 990, PART VI, SECTION B, LINE 15 |
THE PRESIDENT AND CHIEF EXECUTIVE OFFICER'S, AS WELL AS, MEMBERS OF THE EXECUTIVE TEAM'S PERFORMANCES AND COMPENSATION ARE REVIEWED ANNUALLY BY THE BOARD OF DIRECTORS. THE PERFORMANCE AND COMPENSATION OF ALL OTHER KEY EMPLOYEES IS REVIEWED ANNUALLY BY THEIR DIRECT SUPERVISOR. ALL COMPENSATION AMOUNTS ARE BASED ON INFORMATION PROVIDED BY AN INDEPENDENT COMPENSATION CONSULTANT WHO UTILIZES COMPARABLE DATA FROM FORM 990'S FROM OTHER ORGANIZATIONS AND COMPENSATION SURVEY'S AND STUDIES TO ENSURE REASONABLENESS. |
| FORM 990, PART VI, SECTION C, LINE 19 |
THE NATURE CONSERVANCY'S GOVERNING DOCUMENTS, CONFLICT OF INTEREST POLICY AND FINANCIAL STATEMENTS ARE AVAILABLE TO THE PUBLIC VIA OUR WEBSITE: NATURE.ORG. |
| FORM 990, PART IX, LINE 11G |
CONTRACT/PROFESSIONAL FEES: PROGRAM SERVICE EXPENSES 103,308,786. MANAGEMENT AND GENERAL EXPENSES 10,597,968. FUNDRAISING EXPENSES 2,473,933. TOTAL EXPENSES 116,380,687. |
| FORM 990, PART XI, LINE 9: |
CONSOLIDATED ENTITIES ADJUSTMENT -35,507,180. SPLIT INTEREST CHANGE IN VALUATION 20,528,054. FOREIGN EXCHANGE GAIN/LOSSES -618,273. DISTRIBUTIONS FROM NONCONTROLLING INTERESTS -400,000. |
| FORM 990 FILING |
THE FORM 990 WAS PREPARED BASED ON THE BEST AVAILABLE INFORMATION AVAILABLE AT THE TIME OF FILING. SHOULD ADDITIONAL INFORMATION BECOME AVAILABLE THAT MATERIALLY IMPACTS THE ACCURACY OF THE FILING, IT WILL BE AMENDED. |
Attach to Form 990 or 990-EZ.