2024-11-26T09:30:51-06:00 2023-12-31 521073331 DEMBO JONES PC 6116 EXECUTIVE BLVD SUITE 500 NORTH BETHESDA MD 20852 990 2023-01-01 923197259 CIRCULAR ACTION ALLIANCE CIRC 2624977712 20 F STREET NW 7TH FLOOR WASHINGTON DC 20001 KASHIF ALI CHIEF FINANCIAL OFFICER 2624977712 2024-11-25 1 1 DAVID J SHERDEL CPA P01306021 3017705100 2023 2024-10-15 13:58:12Z X KASHIF ALI 20 F STREET NW 7TH FLOOR WASHINGTON DC 20001 0 0 X CIRCULARACTIONALLIANCE.ORG X 2022 DC IMPLEMENTING PRODUCER RESPONSIBILITY OBLIGATIONS UNDER STATE EPR LAWS 20 20 0 20 0 0 130000 0 0 0 0 0 0 0 130000 0 0 0 0 0 0 0 0 0 1382260 562296 8864405 562296 8864405 -432296 -8864405 750000 15986370 1182296 25283071 -432296 -9296701 CAA'S VISION IS TO BE AN APPROVED PRO IN ALL STATES THAT HAVE ENACTED EPR LAWS FOR PAPER AND PACKAGING TO DELIVER HARMONIZED BEST-IN-CLASS COMPLIANCE SERVICES, SCALE INNOVATION, AND BUILD SYSTEMS THAT HELP BOTH COMPANIES AND CONSUMERS WASTE LESS AND RECYCLE MORE. 0 0 5271174 CIRCULAR ACTION ALLIANCE (THE ORGANIZATION) IS A NATIONAL NONPROFIT THAT HAS BEEN SET UP ON BEHALF OF PRODUCERS AS A PRODUCER RESPONSIBLITY ORGANIZATION (PRO) TO IMPLEMENT EFFECTIVE EXTENDED PRODUCER RESPONSIBILITY (EPR) LAWS FOR PAPER AND PACKAGING. THE ORGANIZATION IS CURRENTLY BUILDING COMPLIANCE PROGRAMS ACROSS MULTIPLE STATES TO FULFIL THE OBLIGATIONS OF THESE EPR LAWS PRIOR TO IMPLEMENTATION.THE ORGANIZATION WAS FORMED BY LEADING COMPANIES FROM THE FOOD, BEVERAGE, CONSUMER GOODS, AND RETAIL INDUSTRIES IN RESPONSE TO THE PASSAGE OF EPR LAWS IN CALIFORNIA, COLORADO, MAINE AND OREGON. 5271174 1 0 0 1 0 0 0 0 0 0 0 0 0 0 0 1 1 0 0 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 X 20 20 0 0 1 0 1 1 0 1 1 0 0 1 1 1 1 1 1 1 1 0 OR X THE ORGANIZATION 2624977712 20 F STREET NW 7TH FLOOR WASHINGTON DC 20001 X CHARLIE SCHWARZE CHAIR 18.00 X X 0 0 0 NEIL MENEZES VICE CHAIR 12.00 X X 0 0 0 JEFF BEZZO TREASURER 10.00 X X 0 0 0 JOHN BREEDLOVE SECRETARY 10.00 X X 0 0 0 JON HANSTED DIRECTOR 5.00 X 0 0 0 KARA RUECKER DIRECTOR 5.00 X 0 0 0 KIRSTEN WITT DIRECTOR 5.00 X 0 0 0 ANKE BOYKIN DIRECTOR 5.00 X 0 0 0 PAT HAYES DIRECTOR 5.00 X 0 0 0 ANNE BEDARF DIRECTOR 5.00 X 0 0 0 KELLY SMITH DIRECTOR 5.00 X 0 0 0 JOHN CATURANO DIRECTOR 5.00 X 0 0 0 CORI HERBIG DIRECTOR 5.00 X 0 0 0 ABBY DONOVAN DIRECTOR 5.00 X 0 0 0 ROBERT SCOTT DIRECTOR 5.00 X 0 0 0 STEFANI MILLIE DIRECTOR 5.00 X 0 0 0 KELLY MOLINARI DIRECTOR 5.00 X 0 0 0 ALEX SCHENCK DIRECTOR 5.00 X 0 0 0 SAM HARRINGTON DIRECTOR 0.00 X 0 0 0 MARK BESCHER DIRECTOR 0.00 X 0 0 0 0 0 0 0 0 0 0 CLEAR STRATEGY INC 189 GLEN CEDAR ROAD TORONTO ON CA M6C-3G9 CONSULTING 4060006 HDR ENGINEERING INC 315 S CALHOUN ST SUITE 800 TALLAHASSEE FL 32301 CONSULTING 1280035 PRICEWATERHOURSECOOPERS ADVISORY SERVICE 300 MADISON AVENUE NEW YORK NY 10017 CONSULTING 1064405 THE RECYCLING PARTNERSHIP INC 20 F STREET NW 7TH FLOOR WASHINGTON DC 20001 CONSULTING 714925 KORN FERRY 1700 K STREET NW SUITE 700 WASHINGTON DC 20006 CONSULTING 454134 8 0 0 0 0 X 701793 385986 210538 105269 111884 111884 32637 32637 6203726 3587999 1511025 1104702 26000 26000 1742686 1231549 340758 170379 12733 7003 3820 1910 14646 14646 DUES & SUBSCRIPTIONS 18300 18300 8864405 5271174 2210971 1382260 12835203 750000 3100000 51167 750000 15986370 432296 1633071 23650000 750000 1182296 25283071 X -432296 -9296701 -432296 -9296701 750000 15986370 -8864405 0 X X 0 1 X 1 0 X 130000 130000 130000 130000 0 0 0 130000 130000 130000 X 0 0 0 0 0 0 0 0 1 32637 32637 0 PART II-B, LINE 1: THE ORGANIZATION WAS REGISTERED TO LOBBY IN CALIFORNIA AND COLORADO IN 2023. CONSULTANTS WERE PAID TO SUPPORT INITIATIVES ON BEHALF OF EPR LAWS AND REGULATIONS. $29,083 WAS SPENT IN CALIFORNIA, AND $3,554 IN COLORADO. 0 X 0 0 0 0 0 8864405 0 8864405 0 8864405 PART X, LINE 2: CIRCULAR ACTION ALLIANCE IS EXEMPT FROM THE PAYMENT OF INCOME TAXES ON ITS EXEMPT ACTIVITIES UNDER THE PROVISIONS OF SECTION 501(C)(3) OF THE INTERNAL REVENUE CODE. UNDER THESE PROVISIONS, NO TAX IS IMPOSED ON ANY INCOME RELATED TO THE ORGANIZATION'S TAX-EXEMPT PURPOSE. THE ORGANIZATION HAS DETERMINED THAT IT DOES NOT HAVE ANY MATERIAL UNRECOGNIZED TAX BENEFITS OR OBLIGATIONS AS OF DECEMBER 31, 2023. THE ORGANIZATION IS SUBJECT TO ROUTINE AUDITS BY TAXING JURISDICTIONS; HOWEVER, THERE ARE CURRENTLY NO AUDITS FOR ANY TAX PERIODS IN PROGRESS. THE ORGANIZATION'S FEDERAL AND STATE INCOME TAX RETURNS ARE SUBJECT TO EXAMINATION BY THE INTERNAL REVENUE SERVICE AND STATE TAX AUTHORITIES, GENERALLY FOR A PERIOD OF THREE YEARS AFTER THE RETURNS ARE FILED. CANADA 0 2 VARIOUS MANAGERIAL TASKS 4185028 0 2 0 0 0 2 4185028 0 4185028 0 0 0 0 0 0 FORM 990, PART VI, SECTION A, LINE 4 THE ORGANIZATION AMENDED AND RESTATED ITS ARTICLES OF INCORPORATION TO CHANGE ITS CORPORATE NAME FROM CIRCULARITY ALLIANCE TO CIRCULAR ACTION ALLIANCE AND TO MAKE TECHNICAL AND CLARIFYING REVISIONS TO VARIOUS PROVISIONS TO BETTER REFLECT INTENT. THE ORGANIZATION ADOPTED BYLAWS IN MARCH 2023. THE RESTATED ARTICLES OF INCORPORATION AND BYLAWS WERE ATTACHED TO THE FORM 1023, APPLICATION FOR RECOGNITION OF EXEMPTION, ON WHICH THE IRS ISSUED A FAVORABLE DETERMINATION RULING IN MAY 2023. FORM 990, PART VI, SECTION A, LINE 6 THE ORGANIZATION HAS ONE CLASS OF MEMBERS, THE FOUNDING MEMBERS. FOUNDING MEMBERS ARE THOSE COMPANIES WHO HAVE BEEN APPROVED BY THE BOARD TO BE A FOUNDING MEMBER, AGREED TO SUPPORT THE PURPOSES OF THE ORGANIZATION, AND ENTERED INTO A MEMBERSHIP AGREEMENT. FORM 990, PART VI, SECTION A, LINE 7A FOUNDING MEMBERS ARE ELIGIBLE TO APPONT ONE DIRECTOR TO SERVE ON THE BOARD. FORM 990, PART VI, SECTION B, LINE 11B THE FORM 990 IS PREPARED BY AN INDEPENDENT ACCOUNTING FIRM. THE RETURN IS REVIEWED BY THE ORGANIZATION'S FINANCIAL STAFF, INCLUDING THE CHIEF FINANCIAL OFFICER, AND THE FINANCE, AUDIT, AND INVESTMENT COMMITTEE OF THE BOARD OF DIRECTORS. A COPY OF THE FORM 990 IS DISTRIBUTED TO THE BOARD OF DIRECTORS PRIOR TO FILING. FORM 990, PART VI, SECTION B, LINE 12C THE ORGANIZATION IS COMMITTED TO FOLLOWING THE PROCEDURES SET OUT IN ITS CONFLICT OF INTEREST POLICY. THE CONFLICT OF INTEREST POLICY IS DISTRIBUTED TO BOARD MEMBERS. BOARD MEMBERS ARE ASKED TO SIGN AND RETURN A DISCLOSURE STATEMENT IDENTIFYING ANY CONFLICTING INTERESTS AND TO UPDATE THE STATEMENT UPON ANY CHANGE IN CIRCUMSTANCE. DISCLOSURE FORMS ARE REVIEWED, AND IF A POSSIBLE CONFLICT IS NOTED, THE DISINTERESTED BOARD MEMBERS WOULD CONSIDER WHETHER A CONFLICT OF INTEREST EXISTS, AND THE PROCEDURES FOR ADDRESSING ANY CONFLICT OF INTEREST. BOARD MEMBERS WITH A POTENTIAL CONFLICTING INTEREST UNDER CONSIDERATION ARE NOT PERMITTED TO PARTICIPATE IN DELIBERATING AND VOTING ON THE EXISTENCE OF ANY CONFLICTING INTEREST OR TRANSACTIONS RELATING TO THEIR CONFLICTING INTEREST, BUT MAY DISCLOSE MATERIAL FACTS AND RESPOND TO QUESTIONS. FORM 990, PART VI, SECTION B, LINE 15 IN REVIEWING AND APPROVING THE COMPENSATION OF ANY COVERED INDIVIDUALS, THE CORPORATION'S BOARD OF DIRECTORS, OR A DELEGATED COMMITTEE OF THE BOARD (REFERRED TO AS THE "APPROVAL BODY" BELOW), WILL UTILIZE THE FOLLOWING PROCESS: 1. IMPARTIAL DECISION MAKERS. THE COMPENSATION ARRANGEMENT MUST BE APPROVED IN ADVANCE (BEFORE ANY PAYMENT IS MADE) BY THE APPROVAL BODY OF THE CORPORATION COMPOSED ENTIRELY OF INDIVIDUALS WHO DO NOT HAVE A CONFLICT OF INTEREST WITH RESPECT TO THE COMPENSATION ARRANGEMENT (EXAMPLE: NEITHER THE EXECUTIVE WHOSE COMPENSATION IS BEING DETERMINED NOR ANY OF HIS/HER FAMILY MEMBERS MAY BE PRESENT DURING THE DISCUSSION/DEBATE OR PARTICIPATE IN THE VOTE). 2. COMPARABILITY DATA. WHEN THE APPROVAL BODY IS CONSIDERING COMPENSATION TO COVERED INDIVIDUALS, IT MUST RELY ON COMPARABILITY DATA THAT DEMONSTRATE THE FAIR MARKET VALUE OF THE COMPENSATION IN QUESTION. FOR EXAMPLE, WHEN CRAFTING COMPENSATION PACKAGES, THE APPROVAL BODY MUST SECURE DATA THAT DOCUMENTS COMPENSATION LEVELS FOR SIMILARLY QUALIFIED INDIVIDUALS IN LIKE POSITIONS AT LIKE ORGANIZATIONS. THIS DATA MAY INCLUDE THE FOLLOWING: A) EXPERT COMPENSATION STUDIES BY INDEPENDENT FIRMS; B) WRITTEN JOB OFFERS FOR POSITIONS AT SIMILAR ORGANIZATIONS; C) DOCUMENTED TELEPHONE CALLS ABOUT SIMILAR POSITIONS AT BOTH NONPROFIT AND FOR-PROFIT ORGANIZATIONS; AND D) INFORMATION OBTAINED FROM THE IRS FORM 990 FILINGS OF SIMILAR ORGANIZATIONS. 3. CONCURRENT DOCUMENTATION. THE APPROVAL BODY MUST DOCUMENT HOW IT REACHED ITS DECISIONS, INCLUDING THE DATA ON WHICH IT RELIED. TO QUALIFY AS CONCURRENT DOCUMENTATION, WRITTEN OR ELECTRONIC RECORDS OF THE APPROVAL BODY (SUCH AS MEETING MINUTES) MUST NOTE: A) THE TERMS OF THE COMPENSATION AND THE DATE IT WAS APPROVED; B) THE MEMBERS OF THE APPROVAL BODY WHO WERE PRESENT DURING THE DEBATE ON THE COMPENSATION THAT WAS APPROVED AND THOSE WHO VOTED ON IT; C) THE COMPARABILITY DATA OBTAINED AND RELIED UPON AND HOW THE DATA WAS OBTAINED; AND D) ANY ACTIONS TAKEN WITH RESPECT TO CONSIDERATION OF THE COMPENSATION BY ANYONE WHO IS OTHERWISE A MEMBER OF THE APPROVAL BODY BUT WHO HAD A CONFLICT OF INTEREST WITH RESPECT TO THE DECISION ON THE COMPENSATION. FORM 990, PART VI, SECTION C, LINE 19 THE ORGANIZATIONS GOVERNING DOCUMENTS, CONFLICT OF INTEREST POLICY, AND FINANCIAL STATEMENTS ARE MADE AVAILABLE UPON REQUEST. FORM 990, PART IX, LINE 11G CONSULTING: PROGRAM SERVICE EXPENSES 3,587,999. MANAGEMENT AND GENERAL EXPENSES 1,511,025. FUNDRAISING EXPENSES 1,104,702. TOTAL EXPENSES 6,203,726. FORM 990, PART XII, LINE 2C: CIRCULAR ACTION ALLIANCE HAS NOT CHANGED IT'S AUDIT OVERSIGHT OR SELECTION PROCESS FROM THE PRIOR YEAR. AMENDED RETURN THIS AMENDED RETURN IS BEING FILED TO CORRECT OR UPDATE THE FOLLOWING: 1. PROGRAM DESCRIPTION CHANGE: PART III, LINE 4A: THE LAST SENTENCE WAS DELETED. 2. LOBBYING ACTIVITY CHANGE: PART IV, LINE 4: CHANGED FROM "NO" TO "YES". PART IX LINE 11G PROGRAM EXPENSES WAS REDUCED BY $32,637 AND IS REPORTED ON LINE 11D. SCHEDULE C WAS ADDED TO PROVIDE LOBBYING EXPLANATIONS. 4. FOREIGN ACTIVITIES ADDED: PART IV, LINE 14B: CHANGED FROM "NO" TO "YES". SCHEDULE F WAS ADDED TO PROVIDE FOREIGN ACTIVITY DETAILS. 5. CHANGE TO ORGANIZING DOCUMENTS: PART VI LINE 4: CHANGED FROM "NO" TO "YES". SCHEDULE O CONTAINS AN EXPLANATION. 6. SCHEDULE O, PART VI LINE 11B EXPLANATION WAS EXPANDED TO PROVIDE MORE INFORMATION. 7. SCHEDULE O, PART VI LINE 12C EXPLANATION WAS EXPANDED TO PROVIDE MORE INFORMATION. 8. PART VI, LINE 17 WAS UPATED TO LIST OR.