2019-12-17T14:48:17-06:00 2019-03-31 381357951 PLANTE & MORAN PLLC 10 S RIVERSIDE PLAZA 9TH FLOOR CHICAGO IL 60606 990 2018-04-01 362167832 WESTMINSTER PLACE WEST 8479793900 8707 SKOKIE BOULEVARD NO 400 SKOKIE IL 60077 TODD F SWORTZEL CHIEF EXECUTIVE OFFICER 8479793900 2019-12-06 1 DAVID LOWENTHAL P00378651 3122071040 2019-12-06 67.59.56.30 2019-12-06 11:46:44 CS P CE116CF1B5FDB7DAD0437E80FEFE64DA22EB8A24 23D9C3BAD3C11415BCA5E3AEE50D281DF37E870F 2018 2020-04-17 16:48:07Z TODD F SWORTZEL 8707 SKOKIE BOULEVARD NO 400 SKOKIE IL 60077 61263774 0 X WWW.PRESBYTERIANHOMES.ORG X 1904 IL WESTMINSTER PLACE, A FAITH BASED NOT FOR PROFIT, CREATES VIBRANT COMMUNITIES FOR OLDER ADULTS THAT INSPIRE WELLNESS, INDEPENDENCE, JOY AND SECURITY - ENRICHING THE LIVES OF RESIDENTS AND THEIR FAMILIES. 15 15 610 206 0 0 5524173 3146539 46109616 48168158 15702918 788351 45227 103697 67381934 52206745 0 0 0 0 23328641 22665915 0 0 0 32674157 27138815 56002798 49804730 11379136 2402015 106123779 114576799 95032826 101424100 11090953 13152699 X WESTMINSTER PLACE, A FAITH BASED NOT FOR PROFIT, CREATES VIBRANT COMMUNITIES FOR OLDER ADULTS THAT INSPIRE WELLNESS, INDEPENDENCE, JOY AND SECURITY - ENRICHING THE LIVES OF RESIDENTS AND THEIR FAMILIES. 0 0 15880118 0 14823115 WESTMINSTER PLACE IS A NOT FOR PROFIT INDEPENDENT LIVING, LIFE PLAN COMMUNITY (FORMERLY KNOWN AS CONTINUING CARE RETIREMENT COMMUNITY). THE INDEPENDENT LIVING FACILITY IN WESTMINSTER PLACE CONSISTS OF 254 APARTMENTS, TOWNHOUSES AND COTTAGES. SERVICES PROVIDED BY WESTMINSTER PLACE INCLUDE FLEXIBLE DINING OPTIONS, HOUSEKEEPING AND COMPLETE MAINTENANCE SERVICES, TRANSPORTATION AS WELL AS PLANNED SOCIAL AND EDUCATIONAL ACTIVITIES AND PROGRAMS. DURING THE FILING YEAR, WESTMINSTER PLACE SERVED 320 INDEPENDENT LIVING RESIDENTS. 7044730 0 7438510 THE ASSISTED LIVING FACILITY AT WESTMINSTER PLACE PROVIDES ASSISTED LIVING FOR OLDER ADULTS WHO NEED ASSISTANCE WITH PERSONAL CARE AND DAILY ACTIVITIES. IT CONSISTS OF 92 STUDIO, ONE AND TWO-BEDROOM APARTMENTS. DURING THE FILING YEAR, WESTMINSTER PLACE ASSISTED LIVING FACILITY SERVED 123 RESIDENTS. 20604167 0 25758870 WESTMINSTER PLACE HEALTH CARE CENTERS PROVIDE INTERMEDIATE AND SKILLED NURSING FOR BOTH SHORT AND LONG TERM STAYS. RESPITE, REHABILITATION, AND PROGRAMS TO CARE FOR THOSE WITH ALZHEIMER'S DISEASE AND OTHER COGNITIVE IMPAIRMENTS ARE ALSO AVAILABLE. THE HEALTH CARE CENTERS INCLUDE 100 SKILLED, MEDICARE-CERTIFIED BEDS AND 95 INTERMEDIATE AND MEMORY CARE BEDS. DURING THE FILING YEAR, THE HEALTH CARE CENTERS SERVED A TOTAL OF 519 RESIDENTS. 0 0 147663 REVENUE RELATED TO LEASE INCOME FROM RELATED ORGANIZATIONS AND OTHER INCOME. 0 0 147663 43529015 1 1 0 0 0 0 0 0 0 0 1 0 0 0 1 0 0 1 0 0 0 0 0 0 0 0 0 0 0 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0 1 52 0 1 610 1 0 0 0 0 0 0 0 0 0 0 0 0 X 15 15 0 1 0 0 1 1 0 1 1 0 0 1 1 1 1 1 1 1 1 0 IL X MARK HAVRILKA 8479793900 8707 SKOKIE BLVD SUITE 400 SKOKIE IL 60077 X LEE HUTCHINSON BOARD CHAIR 1.00 2.00 X X 0 0 0 MICHAEL KIRBY SECRETARY 1.00 2.00 X X 0 0 0 PAULA NOBLE TREASURER 1.00 2.00 X X 0 0 0 FRAN CARROLL DIRECTOR 1.00 2.00 X 0 0 0 DONALD C CLARK JR DIRECTOR 1.00 2.00 X 0 0 0 CHARLIE DENISON DIRECTOR 1.00 2.00 X 0 0 0 MONICA HEENAN DIRECTOR 1.00 2.00 X 0 0 0 ELINOR HITE DIRECTOR 1.00 2.00 X 0 0 0 VINCENT KELLY DIRECTOR 1.00 2.00 X 0 0 0 DENNIS MARX DIRECTOR 1.00 2.00 X 0 0 0 E DENNIS MURPHY DIRECTOR 1.00 2.00 X 0 0 0 BETSY NICHOLS DIRECTOR 1.00 2.00 X 0 0 0 NEELE STEARNS DIRECTOR 1.00 2.00 X 0 0 0 MARK TOLEDO DIRECTOR 1.00 2.00 X 0 0 0 JANE WESTERN DIRECTOR 1.00 2.00 X 0 0 0 TODD F SWORTZEL CEO 7.50 30.00 X 0 984756 194516 NADIM M ABI-ANTOUN COO 16.00 21.50 X 0 427579 85307 MARK HAVRILKA CFO 11.00 26.50 X 0 371634 91575 NANCY TOLAN VP, FACILITY MANAGEMENT 9.00 28.50 X 0 222062 49704 ANDREW T WISSEL VP, HUMAN RESOURCES 17.00 20.50 X 0 171296 53887 ANDREW REESE-CLAUSON EXEC. DIR. WESTMINSTER PLACE 37.50 0.00 X 206900 0 21135 ROBERT A WERDAN VP, MARKETING&PUBLIC RELATIONS 12.00 25.50 X 0 228067 66141 PETER L JAGGARD MEDICAL DIRECTOR 37.50 0.00 X 214782 0 12254 MARY ANN ANICHINI VP, CQI UNTIL 7/20/2018 13.00 24.50 X 0 194078 6525 DANIEL M WEINBERGER VP, INFORMATION TECHNOLOGY 12.00 25.50 X 0 165585 49519 ROSARIO L ALBA NURSING SUPERVISOR 37.50 0.00 X 152286 0 17252 KEITH STOHLGREN FORMER VP /EXEC. DIR. 37.50 0.00 X 190358 0 0 764326 2765057 647815 34 1 1 0 ILLINOIS CONSTRUCTION SERVICES INC 1733 N 33RD STREET STONE PARK IL 60165 CONSTRUCTION 2262894 UNIDINE CORPORATION 1000 WASHINGTON STREET SUITE 510 BOSTON MA 02118 DINING/FOOD SERVICES 1735173 HEALTHPRO REHABILITATION 536 OLD HOWELL ROAD GREENVILLE SC 29615 THERAPY MANAGEMENT AND CONSULTING SERVIC 1299391 S&S CUSTOM CABINETRY 6733 N LINCOLN AVE LINCOLNWOOD IL 60712 CABINET CONTRACTORS 1286965 ATOMATIC MECHANICAL SERVICES INC 3733 N VENTURA DR ARLINGTON HEIGHTS IL 60004 HVAC MECHANICAL CONTRACTOR 1186742 24 3146539 3146539 HEALTH CARE FEES 623311 25758870 25758870 INDEPENDENT LIVING FEES 623311 10073788 10073788 ASSISTED LIVING FEES 623311 7438510 7438510 DEFERRED ENTRANCE FEE INCOME 623311 4749327 4749327 ALL OTHER 623311 147663 147663 48168158 544007 544007 69974 0 69974 69974 69974 9055000 8810656 244344 244344 244344 280096 246373 33723 33723 52206745 48168158 0 892048 224117 224117 17590249 16432798 1157451 740739 692329 48410 2845188 2668993 176195 1265622 1185649 79973 3289200 3289200 74938 74938 35914 35914 4459120 4288045 171075 570016 570016 177882 45361 132521 428188 406862 21326 245 141 104 442269 424926 17343 8349583 8349583 479791 479791 BUILDING SERVICES & UTI 3123741 3123741 EXTRAORDINARY ITEM - LO 1911470 1911470 FOOD COSTS AND DINING S 1556904 1556904 PHARMACY AND MEDICAL SU 795653 759923 35730 1443901 1202499 241402 49804730 43529015 6275715 0 9123331 8488757 0 9045723 1981586 1818403 316108 608713 191550255 115222628 78263334 76327627 14056426 17717286 2382994 570290 106123779 114576799 4484989 5955326 31198670 34488495 13069853 12488640 46279314 48491639 95032826 101424100 X 11090953 13152699 11090953 13152699 106123779 114576799 2402015 -340269 0 X 0 1 X 1 0 X 9147804 7809514 4335108 5524173 3146539 29963138 101381160 85090478 47637427 46109616 48168158 328386839 757251 603525 290360 284284 280096 2215516 111286215 93503517 52262895 51918073 51594793 360565493 9147804 7809514 4335108 5524173 3146539 29963138 0 9147804 7809514 4335108 5524173 3146539 29963138 330602355 2444044 1644848 371562 348984 613981 5423419 2444044 1644848 371562 348984 613981 5423419 195448 125000 320448 113925707 95273365 52634457 52267057 52208774 366309360 0.90250 0.89840 0.01480 0.01600 X RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 333953 333953 168506961 99843993 68662968 22335887 15378635 6957252 373454 373454 76327627 SAFEKEEPING ACCOUNTS 820295 REFUNDABLE ENTRANCE FEES 44538047 REFUNDABLE DEPOSITS 804971 DUE TO AFFILIATE 2063898 OTHER LONG-TERM LIABILITY 264428 48491639 X 1 1 0 1 0 0 0 0 0 1 0 TODD F SWORTZEL CEO 0 475073 0 101606 0 408077 0 169513 0 25003 0 1179272 0 0 NADIM M ABI-ANTOUN COO 0 329139 0 60480 0 37960 0 71312 0 13995 0 512886 0 0 MARK HAVRILKA CFO 0 286573 0 59696 0 25365 0 64485 0 27090 0 463209 0 0 NANCY TOLAN VP, FACILITY MANAGEMENT 0 169642 0 29307 0 23113 0 30245 0 19459 0 271766 0 0 ANDREW T WISSEL VP, HUMAN RESOURCES 0 154131 0 5562 0 11603 0 27318 0 26569 0 225183 0 0 ANDREW REESE-CLAUSON EXEC. DIR. WESTMINSTER PLACE 201263 0 5000 0 637 0 20547 0 588 0 228035 0 0 0 ROBERT A WERDAN VP, MARKETING&PUBLIC RELATIONS 0 187176 0 20577 0 20314 0 33664 0 32477 0 294208 0 0 PETER L JAGGARD MEDICAL DIRECTOR 204230 0 802 0 9750 0 12254 0 0 0 227036 0 0 0 MARY ANN ANICHINI VP, CQI UNTIL 7/20/2018 0 95215 0 0 0 98863 0 5724 0 801 0 200603 0 0 DANIEL M WEINBERGER VP, INFORMATION TECHNOLOGY 0 149344 0 15918 0 323 0 26660 0 22859 0 215104 0 0 ROSARIO L ALBA NURSING SUPERVISOR 149727 0 2559 0 0 0 9162 0 8090 0 169538 0 0 0 KEITH STOHLGREN FORMER VP /EXEC. DIR. 0 0 0 0 190358 0 0 0 0 0 190358 0 190358 0 PART I, LINE 1A TODD F. SWORTZEL, CEO, RECEIVES A $24,000 TAXABLE HOUSING ALLOWANCE FROM PRESBYTERIAN HOMES (THE SOLE CORPORATE MEMBER OF WESTMINSTER PLACE WHICH IS INCLUDED IN W-2 WAGES.) PART I, LINE 3 THE GOVERNANCE COMMITTEE OF PRESBYTERIAN HOMES (SOLE MEMBER OF WESTMINSTER PLACE) IS RESPONSIBLE FOR ALL COMPENSATION AND BENEFIT MATTERS FOR SENIOR MANAGEMENT AND KEY EMPLOYEES. PRESBYTERIAN HOMES ANNUALLY PARTICIPATES IN AN INDUSTRY SPECIFIC EXECUTIVE COMPENSATION SURVEY. THE RESULTS OF THIS SURVEY IS REVIEWED BY MANAGEMENT AND SHARED WITH THE COMMITTEE AS NECESSARY. IN ADDITION THE COMMITTEE REGULARLY ENGAGES AN EXTERNAL COMPENSATION CONSULTING FIRM TO ASSIST IN ITS REVIEW OF THE LEVEL OF COMPENSATION, INCENTIVES AND BENEFITS FOR SENIOR EXECUTIVES AND KEY EMPLOYEES EVERY THREE YEARS. THE COMPENSATION CONSULTANTS ACCUMULATE AND PRESENT TO THE GOVERNANCE COMMITTEE MARKET INFORMATION FOR EACH SENIOR EXECUTIVE POSITION, SUMMARIZE INDIVIDUAL EXECUTIVE COMPENSATION, INCENTIVE AND BENEFITS PACKAGES AND BENCHMARK THAT INFORMATION TO THE INDUSTRY DATA THEY HAVE ACCUMULATED. ANNUALLY, THE ORGANIZATION'S STAFF AND/OR THE BOARD OF DIRECTORS PREPARES PERFORMANCE REVIEWS FOR ALL SENIOR MANAGERS AND KEY EMPLOYEES AND MAKES A RECOMMENDATION TO THE GOVERNANCE COMMITTEE REGARDING COMPENSATION, INCENTIVES AND BENEFITS ADJUSTMENTS. THE GOVERNANCE COMMITTEE CONSIDERS THE PERFORMANCE RECOMMENDATION, COMPARISONS OF TOTAL COMPENSATION BY EXECUTIVE TO MARKET COMPENSATION PERCENTILE FOR INDUSTRY EXECUTIVES WITH SIMILAR JOB TITLES AND/OR SKILL SETS, AND ORGANIZATIONAL NEEDS IN TERMS OF MEETING THE CHALLENGES OF THE UNIQUE BUSINESS OF PROVIDING SENIOR CARE SERVICES. THE GOVERNANCE COMMITTEE MAKES A RECOMMENDATION REGARDING COMPENSATION AND BENEFITS CHANGES FOR SENIOR MANAGEMENT WHICH IS APPROVED ANNUALLY BY THE FULL BOARD OF DIRECTORS WITHIN THE BUDGET PROCESS. THE GOVERNANCE COMMITTEE PROCEEDINGS ARE CONTEMPORANEOUSLY DOCUMENTED AND MINUTES ARE MAINTAINED AND ON FILE AT THE CORPORATE OFFICE. PART I, LINE 4B DURING THE YEAR THE FOLLOWING INDIVIDUALS PARTICIPATED IN A NON-QUALIFIED SECTION 457(F) DEFERRED COMPENSATION PLAN: TODD SWORTZEL, MARK HAVRILKA, NADIM ABI-ANTOUN, NANCY TOLAN, ROBERT WERDAN, ANDREW WISSEL, MARY ANN ANICHINI, ANDREW REESE-CLAUSON AND DANNY WEINBERGER. DURING THE YEAR TODD SWORTZEL RECEIVED PAYMENTS TOTALING $380,513 FROM A NON-QUALIFIED SECTION 457(F) DEFERRED COMPENSATION PLAN. DURING THE YEAR NADIM ABI-ANTOUN RECEIVED PAYMENTS TOTALING $16,956 FROM A NON-QUALIFIED SECTION 457(F) DEFERRED COMPENSATION PLAN. DURING THE YEAR MARK HAVRILKA RECEIVED PAYMENTS TOTALING $8,013 FROM A NON-QUALIFIED SECTION 457(F) DEFERRED COMPENSATION PLAN. DURING THE YEAR NANCY TOLAN RECEIVED PAYMENTS TOTALING $15,471 FROM A NON-QUALIFIED SECTION 457(F) DEFERRED COMPENSATION PLAN. DURING THE YEAR ANDREW WISSEL RECEIVED PAYMENTS TOTALING $4,912 FROM A NON-QUALIFIED SECTION 457(F) DEFERRED COMPENSATION PLAN. DURING THE YEAR ROBERT WERDAN RECEIVED PAYMENTS TOTALING $18,449 FROM A NON-QUALIFIED SECTION 457(F) DEFERRED COMPENSATION PLAN. DURING THE YEAR MARY ANN ANICHINI RECEIVED PAYMENTS TOTALING $67,180 FROM A NON-QUALIFIED SECTION 457(F) DEFERRED COMPENSATION PLAN. INCLUDED IN PART II, COLUMN (B)(III) ARE AMOUNTS THAT WERE PAID TO THE EXECUTIVE UNDER THE SECTION 457(F) DEFERRED COMPENSATION PLAN. THESE AMOUNTS WERE CREDITED TO AN ACCOUNT FOR THE EXECUTIVE IN PRIOR YEARS, BUT THE EXECUTIVE WAS REQUIRED TO REMAIN EMPLOYED UNTIL THE YEAR FOR WHICH THIS FORM IS BEING FILED IN ORDER TO BECOME VESTED IN HIS OR HER ACCOUNT. AS A RESULT, THE AMOUNTS THAT WERE PREVIOUSLY CREDITED TO THE EXECUTIVE'S ACCOUNT SHOULD HAVE BEEN INCLUDED IN PART II, COLUMN (C) IN THE YEAR THAT THE AMOUNT WAS CREDITED. NEVERTHELESS, THE ORGANIZATION INADVERTENTLY EXCLUDED THOSE AMOUNTS FROM COLUMN (C) ON PREVIOUSLY FILED FORM 990S. WHEN THE PREVIOUSLY CREDITED AMOUNTS BECOME VESTED, THE AMOUNTS ARE INCLUDED IN PART II, COLUMN (B)(III). THESE AMOUNTS SHOULD BE VIEWED AS HAVING BEEN EARNED OVER THE EXECUTIVE'S ENTIRE PERIOD OF EMPLOYMENT AS AN EXECUTIVE OF THE ORGANIZATION. THE ORGANIZATION HAS CORRECTED THE REPORTING OF THE AMOUNTS CREDITED TO THE 457(F) DEFERRED COMPENSATION PLANS ON A PROSPECTIVE BASIS. NEVERTHELESS, THE FOLLOWING AMOUNTS REPRESENT THE CUMULATIVE AMOUNTS THAT WERE CREDITED TO THE 457(F) DEFERRED COMPENSATION PLAN IN PRIOR YEARS BUT NOT YET PAID, AND SHOULD HAVE BEEN REPORTED IN PART II, COLUMN (C) OF PREVIOUSLY FILED FORM 990S: TODD SWORTZEL $209,271 NADIM ABI-ANTOUN $138,279 DANNY WEINBERGER $ 28,868 MARK HAVRILKA $168,375 NANCY TOLAN $ 81,396 ROBERT WERDAN $ 96,238 ANDREW WISSEL $ 79,832 ANDREW CLAUSON $ 1,667 PART I, LINE 7 AS INDICATED IN SCHEDULE J, PART II, THE OFFICERS AND KEY EMPLOYEES OF THE ORGANIZATION RECEIVED A BONUS BASED ON PERFORMANCE, QUALITY AND CENSUS METRICS AND THE FINANCIAL RESULTS OF THE ORGANIZATION. THIS BONUS WAS APPROVED BY BOARD OF DIRECTORS UPON THE RECOMMENDATION OF THE GOVERNANCE COMMITTEE. A ILLINOIS FINANCE AUTHORITY 861091967 45204EBD9 2016-04-27 114484316 TO REFUND THE SERIES 1996A, 2001, 2006 AND 2007 BONDS 0 0 0 A 1115593 14230400 14000000 230400 2016 1 0 1 1 A 0 0 0 0 0.00000 0.00000 0.00000 0 0 1 A 0 1 0 0 1 0 0 0 1 A 1 FORM 990, PART VI, SECTION A, LINE 1 THE EXECUTIVE COMMITTEE SHALL CONSIST OF THE CHAIR, THE VICE CHAIR, THE SECRETARY, THE TREASURER, AND SUCH ADDITIONAL MEMBERS OF THE BOARD AS FROM TIME TO TIME MAY BE DETERMINED BY THE BOARD OF DIRECTORS. THE PRESIDENT/CEO SHALL BE A NON-VOTING ATTENDEE AT ALL MEETINGS OF THE COMMITTEE. THE EXECUTIVE COMMITTEE SHALL HAVE AND EXERCISE THE AUTHORITY OF THE BOARD OF DIRECTORS IN EMERGENCIES WHEN CONVENING THE FULL BOARD IS NOT PRACTICABLE AND SHALL REPORT ITS ACTIONS TO THE BOARD AT THE EARLIEST OPPORTUNITY. FORM 990, PART VI, SECTION A, LINE 3 THE ORGANIZATION HAS AN AGREEMENT WITH PRESBYTERIAN HOMES MANAGER, LLC WHO EMPLOYS THE MANAGEMENT TEAM AND MANAGES THE FACILITIES AND PROVIDES A NUMBER OF SERVICES ON A CENTRALIZED BASIS UNDER THE TERMS OF A SEPARATE MANAGEMENT SERVICES AGREEMENT. PURSUANT TO THE MANAGEMENT SERVICES AGREEMENT, THE FEE IS DETERMINED ON AN ANNUAL BASIS BY AGREEMENT BETWEEN PH MANAGER, LLC AND THE ORGANIZATION. TOTAL MANAGEMENT FEES PAID FOR THE YEAR ENDED MARCH 31, 2019 WERE $3,289,200, 6.5% OF THE ORGANIZATION'S BUDGETED REVENUES. FORM 990, PART VI, SECTION A, LINE 6 THE SOLE CORPORATE MEMBER OF WESTMINSTER PLACE IS PRESBYTERIAN HOMES (EIN 47-1545753). FORM 990, PART VI, SECTION A, LINE 7A ARTICLE I, SECTION 4 OF THE BYLAWS INDICATES THAT THE MEMBER (PRESBYTERIAN HOMES) SHALL BE ENTITLED TO ONE VOTE ON EACH MATTER SUBMITTED TO A VOTE OF THE MEMBER. ARTICLE III, SECTION 1 OF THE BYLAWS INDICATES THAT THE NUMBER OF DIRECTORS MAY BE DECREASED TO NOT FEWER THAN THREE (3) OR INCREASED TO ANY NUMBER FROM TIME TO TIME BY THE MEMBER (PRESBYTERIAN HOMES), IN A WRITING SIGNED BY THE MEMBER (PRESBYTERIAN HOMES). FORM 990, PART VI, SECTION B, LINE 11B THE FORM 990 IS PREPARED BY AN INDEPENDENT ACCOUNTING FIRM, AND IS THEN PRESENTED TO THE AUDIT COMMITTEE, WHICH ACTS AS A REPRESENTATIVE OF THE BOARD OF DIRECTORS FOR REVIEW AND APPROVAL. THIS IS ACCOMPLISHED PRIOR TO THE FILING OF THE FORM 990. THE AUDIT COMMITTEE FORWARDS ITS RECOMMENDATION FOR ACCEPTANCE OF THE FORM 990 TO THE BOARD OF DIRECTORS. COPIES OF THE FORM 990 ARE ALSO FORWARDED TO THE ENTIRE BOARD FOR THEIR REVIEW AND COMMENT PERIOD. THE BOARD THEN ACTS ON THE RECOMMENDATION OF THE AUDIT COMMITTEE PRIOR TO THE 990 BEING FILED WITH THE IRS. FORM 990, PART VI, SECTION B, LINE 12C WESTMINSTER PLACE EMPLOY MULTIPLE PRACTICES TO ENSURE SENIOR STAFF AND MEMBERS OF THE BOARD OF DIRECTORS FOLLOW BEST GOVERNANCE PRACTICES. AN EXTENSIVE CONFLICTS OF INTEREST POLICY WAS ADOPTED IN APRIL 2001, REVISED IN APRIL 2004 AND FURTHER REVISED IN 2011. ALL DIRECTORS AND SENIOR STAFF ARE REQUIRED TO FILE AN ANNUAL STATEMENT RELATED TO CONFLICTS OF INTEREST. IN ACCORDANCE WITH WESTMINSTER PLACE'S ACCREDITATION BY THE COMMISSION ON ACCREDITATION OF REHABILITATION FACILITIES-CONTINUING CARE ACCREDITATION COMMISSION (CARF-CCAC), A CODE OF ETHICS WAS ADOPTED IN APRIL 2007 AND ALL DIRECTORS ARE REQUIRED TO FILE AN ANNUAL STATEMENT CONFIRMING THEIR ACCEPTANCE OF THE CODE. FINALLY, WESTMINSTER PLACE ADMINISTERS THE IRS RELATIONSHIP SURVEY TO ALL DIRECTORS AND KEY EMPLOYEES ANNUALLY. FORM 990, PART VI, SECTION B, LINE 15 SEE SCHEDULE J, PART III FORM 990, PART VI, SECTION C, LINE 19 THE GOVERNING DOCUMENTS AND FINANCIAL STATEMENTS ARE AVAILABLE UPON REQUEST TO THE PUBLIC. CONTACT FOR THE INFORMATION IS THE CHIEF FINANCIAL OFFICER, MARK HAVRILKA AT PRESBYTERIAN HOMES, 8707 SKOKIE BOULEVARD, SUITE 400, SKOKIE, IL 60077. THE FINANCIAL STATEMENTS ARE AVAILABLE THROUGH THE ILLINOIS ATTORNEY GENERAL'S OFFICE. FORM 990, PART VII: MR. TODD F. SWORTZEL, CHIEF EXECUTIVE OFFICER ASSIGNS 60 PERCENT OF HIS TIME TO WESTMINSTER PLACE AND PRESBYTERIAN HOMES, AND 40 PERCENT OF HIS TIME TO THE GENEVA FOUNDATION. THE CFO ASSIGNS 6.2 PERCENT OF HIS TIME TO THE GENEVA FOUNDATION OF PRESBYTERIAN HOMES. GENEVA FOUNDATION OF PRESBYTERIAN HOMES 8707 SKOKIE BOULEVARD SUITE 400 SKOKIE IL 60077 710945228 SUPPORTING ORGANIZATION IL 501(C)(3) LINE 12A, I PRESBYTERIAN HOMES 0 PRESBYTERIAN HOMES 8707 SKOKIE BOULEVARD SUITE 400 SKOKIE IL 60077 471545753 LIFE PLAN COMMUNITY (F/K/A CONTINUING CARE RETIREMENT COMMUNITY) IL 501(C)(3) LINE 10 N/A 0 0 0 1 0 1 0 0 0 0 0 0 0 0 1 1 0 0 0 0