SCHEDULE O
(Form 990)

Department of the Treasury
Internal Revenue Service
Supplemental Information to Form 990 or 990-EZ

Complete to provide information for responses to specific questions on
Form 990 or 990-EZ or to provide any additional information.
MediumBullet Attach to Form 990 or 990-EZ.
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OMB No. 1545-0047
2021
Open to Public
Inspection
Name of the organization
Alliance Defending Freedom
 
Employer identification number

54-1660459
Return Reference Explanation
Form 990, Part VI, Section A, line 8b The organization does not have any committees that have authority to act on behalf of the governing body. Therefore, this line is answered no in accordance with the instructions.
Form 990, Part VI, Section B, line 11b The Form 990 is prepared by an independent CPA firm. Upon completion, the organization's Finance Team reviews the Form 990 through the following process: 1) The VP of Finance and accounting team members compare the Form 990 to the annual corporate audit and internal financial reports. 2) The VP of Finance assigns accounting team members to review content, check math totals, and check spelling. 3) A final review of content is completed by the Executive Vice President. 4) Following the above, the Form 990 is distributed to: A. President and CEO B. Chairman of the Finance and Audit Committee (FAC) which is responsible for oversight of finance, audit, and tax matters. C. The Chair of the FAC ensures committee members review the Form 990 for material edits and compliance. D. Upon acceptance and approval, the Chairman of the FAC then instructs the VP of Finance to post it on the Board website so the full Board can view the 990. Based on the FAC's recommendation, the Board approves and accepts the 990 at the next regularly scheduled Board meeting. 4) Changes and corrections from the above are addressed at each step. 5) Following the above, the Executive Vice President signs and instructs the Form 990 to be filed with the IRS. 6) Upon filing with the IRS, ADF's Form 990 is available for public inspection and distribution to the state governing bodies, foundations, and other requesting entities.
Form 990, Part VI, Section B, line 12c The conflict of interest policy covers any Director, Principal Officer, Key Employee, or member of a committee with governing board delegating powers, who has a direct or indirect financial interest. The organization also conducts periodic reviews to ensure operations are consistent with its charitable purposes. Directors shall report possible conflicts of interest to the Chairman of the Board of Directors prior to any action on the transaction by the organization. Upon report of a possible conflict, the Board of Directors shall conduct an investigation and determine whether a conflict of interest does exist and whether it is substantial. If the Board determines that a substantial conflict of interest exists, the interested individual shall not vote on the transaction presenting the conflict. The interested individual may vote only if the Board determines that no conflict exists or the conflict is not substantial. No investigation or determination by the Board shall be required if the interested individual voluntarily agrees to refrain from voting on the transaction presenting the potential conflict of interest. The interested individual may be counted in determining the presence of a quorum. The remaining Board or committee members shall decide if a conflict of interest exists. The minutes of the governing Board and all committees with Board delegated powers shall contain: A. The names of the persons who disclosed or otherwise were found to have a financial interest in connection with an actual or possible conflict of interest, the nature of the financial interest, any action taken to determine whether a conflict of interest was present, and the governing Board's or Committee's decision as to whether a conflict of interest in fact existed. B. The names of the persons who were present for discussions and votes relating to the transaction or arrangement, the content of the discussion, including any alternatives to the proposed transaction or arrangement, and a record of any votes taken in connection with the proceeding.
Form 990, Part VI, Section B, line 15 Alliance Defending Freedom maintains a compensation system. CEO compensation is set by the organization's independent Board, and the CEO's compensation is in accordance with the ADF compensation system. Job descriptions are evaluated against independent market sources and compensation data as provided by independent third party resource providers. The management compensation committee approves position grades and pay ranges of all other positions. Annually, ADF also prepares compensation data for the Board's Finance and Audit Committee in accordance with the IRS recommended "rebuttable presumption of reasonableness" process to substantiate the compensation of ADF key employees. The FAC reviews and approves key employee compensation once a year. The ADF Comp Team (comprised of the EVP Finance & Administration, Director of HR, and the Sr. HR Generalist) review benchmark data provided by Payscale, Mercer, and other compensation resources to determine the appropriate compensation for all positions in accordance with the ADF compensation philosophy. Compensation above the 60th percentile but less than the 75th percentile of a pay grade requires that the CEO be informed; at or above the 75th percentile requires CEO approval; and above the maximum of the grade requires Board approval. Discussions, decisions, and approvals are recorded in writing, typically via e-mail.
Form 990, Part VI, Section C, line 19 The organization's audited financial statements and Form 990 are available on its website. Governing documents and conflict of interest policy are available to the public upon request.
Form 990, Part XI, line 9: 15100 Solar net loss as change in investment -1,773. Loss on foreign currency translation -272,293.
For Paperwork Reduction Act Notice, see the Instructions for Form 990 or 990-EZ.
Cat. No. 51056K
Schedule O (Form 990) 2021


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