2024-11-19T09:43:48-06:00 2023-12-31 881478669 CBIZ ADVISORS LLC 1899 L STREET NW 850 WASHINGTON DC 20036 990 2023-01-01 271661997 GIVEDIRECTLY INC GIVE 6465044837 PO BOX 3221 NEW YORK NY 10008 NIKOLAS ALLARDICE PRESIDENT 6465044837 2024-11-18 1 0 AARON M FOX P01365820 2022274000 2024-11-18 2023 2024-10-15 13:58:12Z NIKOLAS ALLARDICE PO BOX 3221 NEW YORK NY 10008 148457056 0 X WWW.GIVEDIRECTLY.ORG X 2009 MA TO REDUCE POVERTY BY PROVIDING FINANCIAL ASSISTANCE DIRECTLY TO THOSE IN NEED. 5 4 107 5 0 0 168006805 125494389 0 0 1205285 2317825 6501254 12531081 175713344 140343295 217034471 83181937 0 0 27230815 31116596 0 135175 7036806 17042509 15826583 261307795 130260291 -85594451 10083004 240039533 203098602 126223824 79756067 113815709 123342535 X THE ORGANIZATION'S MISSION IS TO REDUCE POVERTY BY PROVIDING FINANCIAL ASSISTANCE DIRECTLY TO THOSE IN NEED. 0 0 115859966 83181937 GIVEDIRECTLY OFFERS A SERVICE ALLOWING INDIVIDUAL DONORS, FOUNDATIONS, AND OTHERS TO DELIVER UNCONDITIONAL DIRECT CASH TRANSFERS TO THOSE IN NEED. THE ORGANIZATION'S PROPRIETARY MODEL RE-ENGINEERS FIELDWORK FOR THE DIGITAL ERA, ALLOWING IT TO DELIVER THESE TRANSFERS SECURELY, EFFICIENTLY AND TRANSPARENTLY. USING THE LATEST TECHNOLOGY AT EVERY STEP, GIVEDIRECTLY LOCATES RECIPIENTS, INTEGRATES THEM INTO ELECTRONIC PAYMENTS NETWORKS, AND MONITORS TRANSFERS END-TO-END. THE ORGANIZATION'S PROPRIETARY MODEL RE-ENGINEERS FIELDWORK FOR THE DIGITAL ERA, ENSURING SECURITY, EFFICIENCY, AND TRANSPARENCY. SINCE 2009, GIVEDIRECTLY HAS REACHED MORE THAN 1.5M RECIPIENTS IN 15 COUNTRIES.IN 2023, GIVEDIRECTLY DELIVERED OVER $117.6M TO OVER 200K RECIPIENTS IN 13 COUNTRIES VIA 27 DIFFERENT PROGRAMS. HIGHLIGHTS FROM 2023 INCLUDE:- LAUNCHING OUR MOST AMBITIOUS ANTI-POVERTY PROGRAMS YET IN PARTNERSHIP WITH THE GOVERNMENTS OF MALAWI AND RWANDA.- RELEASING FINDINGS FROM THE WORLD'S LONGEST UNIVERSAL BASIC INCOME (UBI) STUDY, WHICH FOUND THAT A SINGLE LARGE LUMP SUM OFTEN HAS MORE IMPACT THAN SMALLER MONTHLY PAYMENTS IN LINE WITH WHAT RECIPIENTS TELL US THEY PREFER. - WE LAUNCHED EMERGENCY CASH RELIEF PROGRAMS IN RESPONSE TO EARTHQUAKES IN TURKEY & MOROCCO, CYCLONE FREDDY IN MALAWI & MOZAMBIQUE, AND SEASONAL FLOODING IN NIGERIA.- WE TIGHTENED CONTROLS, BUILT NEW SYSTEMS, AND INSTITUTED BACK-END MACHINE LEARNING FLAGS TO PREVENT MAJOR FRAUD LOSS IN RESPONSE TO A 2022 INCIDENT IN THE DRC. 115859966 1 1 0 0 0 0 0 0 0 0 1 1 0 0 0 1 1 0 0 1 1 1 1 1 0 0 0 0 1 1 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 0 0 1 X 25 0 1 107 1 0 1 KE UG MI MO LI UK CG RW MZ EN YM 0 0 0 0 0 0 0 0 0 0 X 5 4 0 0 0 1 1 1 1 1 1 0 0 1 1 1 1 1 1 1 1 0 AL AK AR CA CO CT FL GA HI IL KS KY MA MD MN MS MI NC ND NH NJ NM NY NV OH OR PA RI SC TN UT VA WA WV WI X X NIKOLAS ALLARDICE 6465044837 PO BOX 3221 NEW YORK NY 10008 MICHAEL FAYE EXECUTIVE CHAIR 30.00 X X 151669 0 0 ALY JEDDY CHAIR 1.00 X X 0 0 0 ROHIT WANCHOO TREASURER 1.00 X X 0 0 0 JACQUELLINE FULLER DIRECTOR - UNTIL 9/23 1.00 X 0 0 0 PAUL NIEHAUS DIRECTOR 1.00 X 0 0 0 RORY STEWART PRESIDENT - UNTIL 10/23 40.00 X 314400 0 2343 SAMUEL MWAMBURI MWALE INTERIM PRESIDENT AS OF 09/2023 40.00 X 187810 0 11651 JOSEPH HUSTON MANAGING DIRECTOR - UNTIL 12/23 40.00 X 363872 0 20362 JASON WATTERS CHIEF FINANCE COMP & DATA PROTEC. OFFICER UNTIL 12/23 40.00 X 344688 0 14039 DOUGLAS RICHARD KIRKE-SMITH VICE PRESIDENT, PROGRAMS 40.00 X 179210 0 9408 BECCA FRANK DIRECTOR, TECHNOLOGY 40.00 X 269957 0 23456 SARAH MORAN VICE PRESIDENT, DEVELOPMENT 40.00 X 264681 0 32 SAMUEL KRETER SENIOR PROGRAM ENGINEER 40.00 X 249586 0 10490 ALEX NAWAR REGIONAL DIRECTOR 40.00 X 220976 0 32 JULIE XIA SENIOR PROGRAM ENGINEER 40.00 X 210827 0 11986 2757676 0 103799 94 0 1 0 AIDKIT 383 CORONA STREET UNIT 814 DENVER CO 80218 PAYMENT GATEWAYS 423976 IDINSIGHT INC 44 TEHAMA STREET SAN FRANCISCO CA 94105 IMPACT EVALUATION 404104 SALESFORCE 524 BROADWAY NEW YORK NY 10012 PAYMENT GATEWAYS 344132 THE REGENTS OF THE UNIVERSITY OF CALIFOR 1608 FOURTH STREET SUITE 201 BERKELEY CA 947101103 DATA ANALYSIS 295991 PEAK SUPPORT LLC 13 FAIRMONT AVE CAMBRIDGE MA 021394422 CALL CENTRE SERVICES 226500 20 12382 11793182 113688825 2705102 125494389 1898517 1898517 8533069 8113761 419308 419308 419308 FOREIGN EXCHANGE TRANS. 900099 12460476 12460476 OTHER INCOME 900099 70605 70605 12531081 140343295 0 0 14848906 1427925 1427925 81754012 81754012 1598399 67954 1396898 133547 24719567 17351943 2472045 4895579 2722634 1957433 278486 486715 2075996 1474535 299150 302311 350691 193160 157531 504520 77443 427077 135175 135175 153720 153720 3633893 3297148 214232 122513 139582 26635 1250 111697 585099 560859 14650 9590 2790292 1707346 892923 190023 1053604 682837 370498 269 4352739 3766190 362839 223710 167154 150815 6826 9513 346792 142448 192993 11351 MOBILE MONEY & BANKING 1190064 769932 29087 391045 EQUIPMENT 339832 304896 30411 4525 MISCELLANEOUS 218601 146455 62903 9243 130260291 115859966 7363519 7036806 74721370 67347842 39307228 35576124 4152014 26630005 48496943 4289033 1249133 933518 913644 1015689 916017 603572 244029 312445 4783368 4232587 60602168 59281094 347323 42418 5222313 3437847 240039533 203098602 3323591 5313973 121829037 74442094 1071196 126223824 79756067 X 93706161 80097670 20109548 43244865 113815709 123342535 240039533 203098602 10083004 -556178 0 X 0 1 X 1 1 1 X 42143391 303155869 249227004 168006805 125494389 888027458 42143391 303155869 249227004 168006805 125494389 888027458 33914821 854112637 2288581 2078066 2072199 1929056 1898517 10266419 119075 1131 49969 70605 240780 898534657 0.95060 0.95760 X RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 203940 132786 71154 712077 470786 241291 312445 US GOV'T AGENCIES OBLIG. 48788620 F FRGN. GOV'T AGEN. OBLIG. 5301724 F PRIVATE INVESTMENT FUND 5190750 F 59281094 X 139703234 -556178 69837 -486341 140189575 153720 153720 140343295 130176408 69837 69837 130106571 153720 153720 130260291 PART X, LINE 2: GIVEDIRECTLY PERFORMED AN EVALUATION OF UNCERTAINTY IN INCOME TAXES FOR THE YEARS ENDED DECEMBER 31, 2023 AND 2022, AND DETERMINED THAT THERE WERE NO MATTERS THAT WOULD REQUIRE RECOGNITION IN THE FINANCIAL STATEMENTS OR THAT MAY HAVE ANY EFFECT ON ITS TAX-EXEMPT STATUS. 1 SUB-SAHARAN AFRICA - ANGOLA, BENIN, BOTSWANA, BURKINA FASO, 25 828 PROGRAM SERVICES CASH TRANSFERS TO RECIPIENTS LOCATED IN THE REGION 75037348 SUB-SAHARAN AFRICA - ANGOLA, BENIN, BOTSWANA, BURKINA FASO, 0 73 PROGRAM SERVICES ADMIN SUPPORT TO PROGRAMS 21152402 SUB-SAHARAN AFRICA - ANGOLA, BENIN, BOTSWANA, BURKINA FASO, 0 3 FUNDRAISING 456449 MIDDLE EAST AND NORTH AFRICA - ALGERIA, BAHRAIN, DJIBOUTI, EGYPT, 1 44 PROGRAM SERVICES CASH TRANSFERS TO RECIPIENTS LOCATED IN THE REGION 5563398 MIDDLE EAST AND NORTH AFRICA - ALGERIA, BAHRAIN, DJIBOUTI, EGYPT, 0 1 PROGRAM SERVICES ADMIN SUPPORT TO PROGRAMS 1683223 SOUTH ASIA - AFGHANISTAN, BANGLADESH, BHUTAN, INDIA, MALDIVES, NEPAL, 0 9 PROGRAM SERVICES CASH TRANSFERS TO RECIPIENTS LOCATED IN THE REGION 977303 SOUTH ASIA - AFGHANISTAN, BANGLADESH, BHUTAN, INDIA, MALDIVES, NEPAL, 0 1 PROGRAM SERVICES ADMIN SUPPORT TO PROGRAMS 98640 SOUTH ASIA - AFGHANISTAN, BANGLADESH, BHUTAN, INDIA, MALDIVES, NEPAL, 0 0 FUNDRAISING 2945 EUROPE (INCLUDING ICELAND & GREENLAND) 2 11 PROGRAM SERVICES ADMIN SUPPORT TO PROGRAMS 91284 EUROPE (INCLUDING ICELAND & GREENLAND) 5 FUNDRAISING 47761 26 959 2 16 28 975 104971708 139045 105110753 SUB-SAHARAN AFRICA - ANGOLA, BENIN, BOTSWANA, BURKINA FASO, THE GRANTEE PROVIDED "CLIMATE SMART AGRICULTURE" TRAINING TO RECIPIENTS OF THE CASH4CLIMATE PROJECT. 54062 BANK WIRE 0 SUB-SAHARAN AFRICA - ANGOLA, BENIN, BOTSWANA, BURKINA FASO, DEVELOP A COMMCARE-BASED HEALTH APPLICATION AIMED AT INFORMING 5,000 CASH RECIPIENTS ABOUT NUTRITION AND FOOD SECURITY BEHAVIORS 30244 BANK WIRE 0 MIDDLE EAST AND NORTH AFRICA DELIVER RAPID CASH ASSISTANCE TO RECIPIENTS WHOSE LIVES AND LIVELIHOODS HAVE BEEN AFFECTED BY THE EARTHQUAKES. 91658 BANK WIRE 0 2 1 DIRECT CASH ASSISTANCE SUB-SAHARAN AFRICA - ANGOLA, BENIN, BOTSWANA, BURKINA FASO, 121617 75037348 MOBILE MONEY DIRECT CASH ASSISTANCE MIDDLE EAST AND NORTH AFRICA - ALGERIA, BAHRAIN, DJIBOUTI, EGYPT, 4402 5563398 MOBILE MONEY DIRECT CASH ASSISTANCE SOUTH ASIA 7090 977303 MOBILE MONEY 0 0 1 0 0 1 PART I, LINE 2: TO MONITOR THE USE OF GRANTS, GIVEDIRECTLY COMPLETES A MULTI STAGE ENROLLMENT PROCESS PRIOR TO SENDING TRANSFERS AND FOLLOWS UP VIA PHONE CALL OR IN PERSON ON A SAMPLE BASIS AFTER EACH TRANSFER IS SENT TO ENSURE IT WAS RECEIVED AND THERE WERE NO ADVERSE EVENTS. IT ALSO PARTICIPATES IN RANDOMIZED CONTROLLED TRIALS TO MEASURE THE IMPACT OF THE GRANTS. PART I, LINE 3: THE ORGANIZATION REPORTED THE EXPENDITURES BASED ON THE ACCOUNTING METHOD USED IN ITS AUDITED FINANCIAL STATEMENTS WHICH IS ACCRUAL BASIS. X 1 GRAHAM-PELTON ASSOCIATES INC 39 BEECHWOOD ROAD SUMMIT NJ 07901 DONOR ASSESSMENTS, GROWTH STRATEGY AND PLANNING 0 0 73575 -73575 CAITLIN COSGROVE PO BOX 3221 NEW YORK NY 10008 PLANNING AND FEASIBILITY STUDY OF FUNDRAISING STRATEGY 0 0 61600 -61600 135175 -135175 LA MO TX UT AL AK AR CA CO CT DC FL GA HI IL KS KY ME MD MA MI MN MS NV NH NJ NM NY NC ND OH OK OR PA RI SC TN VA WA WV WI 1 GUARANTEED INCOME DIRECT CASH ASSISTANCE PROGRAMS 220 1427925 PART I, LINE 2: TO MONITOR THE USE OF GRANTS, GIVEDIRECTLY AIMS TO SEND AN SMS TEXT MESSAGE TO ALL RECIPIENTS AND ALSO FOLLOWS UP VIA PHONE CALL ON A SAMPLE BASIS AFTER EACH TRANSFER IS SENT TO ENSURE IT WAS RECEIVED AND THERE WERE NOT ANY ADVERSE EVENTS. IT ALSO PARTICIPATES IN RANDOMIZED CONTROLLED TRIALS TO MEASURE THE IMPACT OF THE GRANTS. X X X X 0 0 0 0 0 0 0 1 0 JOSEPH HUSTON MANAGING DIRECTOR - UNTIL 12/23 211793 0 152079 0 0 0 0 0 20362 0 384234 0 0 0 JASON WATTERS CHIEF FINANCE COMP & DATA PROTEC. OFFICER UNTIL 12/23 223481 0 121207 0 0 0 0 0 14039 0 358727 0 0 0 RORY STEWART PRESIDENT - UNTIL 10/23 293882 0 0 0 20518 0 2343 0 0 0 316743 0 0 0 BECCA FRANK DIRECTOR, TECHNOLOGY 226407 0 43550 0 0 0 0 0 23456 0 293413 0 0 0 SARAH MORAN VICE PRESIDENT, DEVELOPMENT 232425 0 32256 0 0 0 0 0 32 0 264713 0 0 0 SAMUEL KRETER SENIOR PROGRAM ENGINEER 206536 0 43050 0 0 0 0 0 10490 0 260076 0 0 0 JULIE XIA SENIOR PROGRAM ENGINEER 174224 0 36603 0 0 0 0 0 11986 0 222813 0 0 0 ALEX NAWAR REGIONAL DIRECTOR 183228 0 37748 0 0 0 0 0 32 0 221008 0 0 0 SAMUEL MWAMBURI MWALE INTERIM PRESIDENT AS OF 09/2023 187810 0 0 0 0 0 0 0 11651 0 199461 0 0 0 DOUGLAS RICHARD KIRKE-SMITH VICE PRESIDENT, PROGRAMS 153020 0 17233 0 8957 0 9408 0 0 0 188618 0 0 0 MICHAEL FAYE EXECUTIVE CHAIR 151669 0 0 0 0 0 0 0 0 0 151669 0 0 0 PART I, LINE 7 FOR THE YEAR ENDED DECEMBER 31, 2023, INDIVIDUALS LISTED ON PART VII RECEIVED NON-FIXED PAYMENTS WHICH WERE BASED ON A PRE-ESTABLISHED INDEX ACCORDING TO THE INDIVIDUALS' LEVELS AND MEETING THE ORGANIZATION'S MISSION WHICH IS BASED ON ENROLLING RECIPIENTS IN CASH TRANSFER PROGRAMS. X 25 1266043 FMV X CRYPTO CURRENCY 1870 1439059 FMV 0 1 0 PART I, LINE 32B: GIVEDIRECTLY WILL SEEK THE ADVICE OF LEGAL COUNSEL IN MATTERS RELATING TO ACCEPTANCE OF GIFTS WHEN APPROPRIATE. REVIEW BY COUNSEL IS RECOMMENDED FOR: - GIFTS OF SECURITIES THAT ARE SUBJECT TO RESTRICTIONS OR BUY-SELL AGREEMENTS. - DOCUMENTS NAMING GIVEDIRECTLY AS TRUSTEE OR REQUIRING GIVEDIRECTLY TO ACT IN ANY FIDUCIARY CAPACITY. - GIFTS REQUIRING GIVEDIRECTLY TO ASSUME FINANCIAL OR OTHER OBLIGATIONS. - TRANSACTIONS WITH POTENTIAL CONFLICTS OF INTEREST. - GIFTS OF PROPERTY WHICH MAY BE SUBJECT TO ENVIRONMENTAL OR OTHER REGULATORY RESTRICTIONS. - RESTRICTIONS ON GIFTS. GIVEDIRECTLY WILL NOT ACCEPT GIFTS THAT (A) WOULD RESULT IN GIVEDIRECTLY VIOLATING ITS CORPORATE CHARTER, (B) WOULD RESULT IN GIVEDIRECTLY LOSING ITS STATUS AS AN IRC 501(C)(3) NOT-FOR-PROFIT ORGANIZATION, (C) ARE TOO DIFFICULT OR TOO EXPENSIVE TO ADMINISTER IN RELATION TO THEIR VALUE, (D) WOULD RESULT IN ANY UNACCEPTABLE CONSEQUENCES WHICH WOULD COMPROMISE GIVEDIRECTLY'S MISSION. - DECISIONS ON THE RESTRICTIVE NATURE OF A GIFT, AND ITS ACCEPTANCE OR REFUSAL, SHALL BE MADE BY THE BOARD, IN CONSULTATION WITH THE PRESIDENT. CERTAIN FORMS OF GIFTS OR DONATED PROPERTIES MAY BE SUBJECT TO REVIEW PRIOR TO ACCEPTANCE. EXAMPLES OF GIFTS SUBJECT TO PRIOR REVIEW INCLUDE, BUT ARE NOT LIMITED TO: TANGIBLE PERSONAL PROPERTY. THE BOARD SHALL REVIEW AND DETERMINE WHETHER TO ACCEPT ANY GIFTS OF TANGIBLE PERSONAL PROPERTY IN LIGHT OF THE FOLLOWING CONSIDERATIONS: DOES THE PROPERTY FURTHER THE ORGANIZATION'S MISSION? IS THE PROPERTY MARKETABLE? ARE THERE ANY UNACCEPTABLE RESTRICTIONS IMPOSED ON THE PROPERTY? ARE THERE ANY CARRYING COSTS FOR THE PROPERTY FOR WHICH THE ORGANIZATION MAY BE RESPONSIBLE? IS THE TITLE/PROVENANCE OF THE PROPERTY CLEAR? FORM 990, PART VI, SECTION A, LINE 5 DURING THE TAX YEAR 2023, GIVEDIRECTLY UNCOVERED A SIGNIFICANT INSTANCE IN 2022 OF OUR EMPLOYEES COLLUDING TO DIVERT MOBILE MONEY PAYMENTS FOR PERSONAL GAIN, RESULTING IN THE LOSS OF 0.8% OF THE CASH TRANSFERS WE DELIVERED GLOBALLY IN 2022. GIVEDIRECTLY INITIATED AN INVESTIGATION UPON DISCOVERING THE FRAUD, RESULTING IN THE IDENTIFICATION OF THE EMPLOYEES RESPONSIBLE. WE HAVE TAKEN DISCIPLINARY AND LEGAL ACTION AGAINST THOSE INVOLVED. APPROPRIATE LEGAL ACTIONS HAVE BEEN PURSUED IN AN EFFORT TO RECOVER THE MISAPPROPRIATED FUNDS TO LIMITED SUCCESS. UPON UNCOVERING THE EMPLOYEE FRAUD, A COMPREHENSIVE FINANCIAL REVIEW HAS BEEN PERFORMED TO DETERMINE THE EXTENT OF THE FRAUD AND EVALUATE THE EFFECTIVENESS OF THE INTERNAL CONTROLS. GIVEDIRECTLY TOOK IMMEDIATE STEPS TO RECTIFY THE SITUATION, INCLUDING: - IMPLEMENTING ENHANCED INTERNAL CONTROLS & FINANCIAL OVERSIGHT - RE-DESIGNED THE AFFECTED PROJECT BEFORE RE-LAUNCHING - HIRING AND TRAINING A NEW STAFF TEAM FOR DRC; AND - REPAYING DEFRAUDED RECIPIENTS. GIVEDIRECTLY IS COMMITTED TO PREVENTING SIMILAR INCIDENTS IN THE FUTURE. IN RESPONSE TO THE FRAUD, THE ORGANIZATION HAS STRENGTHENED ITS FINANCIAL CONTROLS, HIRED AND ONBOARDED NEW EMPLOYEES FOR INCREASED FRAUD PREVENTION AND DETECTION, AND ESTABLISHED A CLEAR PROCESS FOR REPORTING AND ADDRESSING SUSPECTED FRAUDULENT ACTIVITY. GIVEDIRECTLY IS DEDICATED TO TRANSPARENCY AND ACCOUNTABILITY. WE HAVE REPORTED THIS INCIDENT TO THE APPROPRIATE AUTHORITIES AND HAVE TAKEN DECISIVE STEPS TO PREVENT THE RECURRENCE OF EMPLOYEE FRAUD. GIVEDIRECTLY'S LEADERSHIP IS COMMITTED TO UPHOLDING OUR RESPONSIBILITIES OF EXTENSIVE MANAGEMENT AND FINANCIAL CONTROLS TO ENSURE PROFESSIONAL CARE AND DUE DILIGENCE IN ALL ACTIVITIES. FORM 990, PART VI, SECTION A, LINE 6 THE INITIAL MEMBERS OF THE CORPORATION SHALL BE MICHAEL FAYE, JACQUELLINE FULLER, ALY JEDDY, PAUL NIEHAUS, AND ROHIT WANCHOO. FORM 990, PART VI, SECTION A, LINE 7A MEMBERS HAVE THE POWER TO ELECT, REMOVE OR SUSPEND THE DIRECTORS OF THE ORGANIZATION. FORM 990, PART VI, SECTION A, LINE 7B CERTAIN GOVERNANCE DECISIONS ARE SUBJECT TO THE APPROVAL OF STATUTORY MEMBERS. FORM 990, PART VI, SECTION B, LINE 11B QUALIFIED AND AUTHORIZED PERSON SHALL REVIEW THE ANNUAL FORM 990 RETURN, PREPARED BY ITS THIRD PARTY TAX ACCOUNTANTS, UNDER THE DIRECTION OF THE BOARD. THE RETURN SHALL BE PRESENTED TO ALL BOARD MEMBERS FOR APPROVAL, EITHER VIA E-MAIL OR BY PAPER COPY, PRIOR TO ITS FILING. FORM 990, PART VI, SECTION B, LINE 12C EACH DIRECTOR, PRINCIPAL AND OFFICER, SHALL ANNUALLY REVIEW THE CONFLICTS OF INTEREST POLICY AND DISCLOSE ANY KNOWN CONFLICTS. IF THERE IS A POTENTIAL VIOLATION, IF THE BOARD OR COMMITTEE HAS REASONABLE CAUSE TO BELIEVE THAT A MEMBER HAS FAILED TO DISCLOSE ANY ACTUAL OR POSSIBLE FINANCIAL CONFLICT OF INTEREST, THE BOARD MEMBER WILL BE AFFORDED AN OPPORTUNITY TO EXPLAIN THE ALLEGED FAILURE FOR TO MAKE SUCH A DISCLOSURE AND IF DETERMINED TO BE A VIOLATION THE BOARD SHALL TAKE DISCIPLINARY, CORRECTIVE OR OTHER ACTION TO BE DETERMINED BY THE MAJORITY OF THE DISINTERESTED MEMBERS OF THE BOARD. FORM 990, PART VI, SECTION B, LINE 15 THE PROCESS FOR DETERMINING COMPENSATION OF TOP MANAGEMENT AND KEY EMPLOYESS IS COVERED IN GD ORG WIDE COMPENSATION POLICY. ALL TOP MANAGMENTAND KEY EMPLOYEES INCLUDE A REVIEW BY THE TREASURER AND THE REST OF THE BOARD, AS WELL AS A BENCHMARKING USING BIRCHE'S COMPENSATION AGGREGATOR OF SIMILAR POSITIONS AND SALARIES OF OF ORGANIZATIONS OF SIMILAR SIZE. THE BIRCHES DATABASE INCLUDES LEVELS AND SALARY DATA ACROSS ORGANIZATIONS IN 150 DIFFERENT COUNTRIES. FORM 990, PART VI, SECTION C, LINE 19 THE ORGANIZATION MAKES ITS GOVERNING DOCUMENTS, CONFLICTS OF INTEREST POLICY, AND FINANCIAL STATEMENTS AVAILABLE TO THE PUBLIC UPON WRITTEN REQUEST. FINANCIAL STATEMENTS AND FORM 990S ARE AVAILABLE ON THE WEBSITE. ADDITIONALLY THE STATE OF MA HAS PUBLICLY AVAILABLE, ALL WORK FILINGS, INCLUDING ARTICLES OF ORGANIZATION AND ANNUAL REPORTS.