2019-01-17T15:27:25-06:00 2018-06-30 410746749 CLIFTONLARSONALLEN LLP 610 W GERMANTOWN PIKE STE 400 PLYMOUTH MEETING PA 19462 990 2017-07-01 043467254 FOUNDATION FOR INDIVIDUAL RIGHTS IN EDUCATION INC FOUN 2157173473 510 WALNUT STREET NO 1250 PHILADELPHIA PA 19106 GREGORY LUKIANOFF PRESIDENT AND CEO 2157173473 2019-01-17 1 CONNIE M LIRA P00481097 2156433900 67.137.57.251 2019-01-17 14:54:49 ES P 0923F946C4CB480093980E5AA9C4B839AC66D68C 2E0D7D06F106C8D332254A4512B5BBA3400C4AD7 2017 2019-02-21 02:37:17Z GREGORY LUKIANOFF 510 WALNUT STREET NO 1250 PHILADELPHIA PA 19106 12883216 0 X HTTP://THEFIRE.ORG/ X 1999 PA FIRE'S MISSION IS TO DEFEND AND SUSTAIN THE INDIVIDUAL RIGHTS OF STUDENTS AND FACULTY MEMBERS AT AMERICA'S COLLEGES AND UNIVERSITIES. THESE RIGHTS INCLUDE FREEDOM OF SPEECH, FREEDOM OF ASSOCIATION, DUE PROCESS, LEGAL EQUALITY, RELIGIOUS LIBERTY, AND SANCTITY OF CONSCIENCE--THE ESSENTIAL QUALITIES OF LIBERTY. FIRE EDUCATES STUDENTS, FACULTY, ALUMNI, TRUSTEES, AND THE PUBLIC ABOUT THE THREATS TO THESE RIGHTS ON OUR CAMPUSES, AND PROVIDES THE MEANS TO PRESERVE THEM. 10 10 72 13 0 0 10758302 11627342 0 811468 55976 103594 84986 62842 10899264 12605246 16250 10364 0 0 3893872 4616318 0 0 902290 2877171 3474983 6787293 8101665 4111971 4503581 12003475 16378703 1311191 1245598 10692284 15133105 X FIRE'S MISSION IS TO DEFEND AND SUSTAIN THE INDIVIDUAL RIGHTS OF STUDENTS AND FACULTY MEMBERS AT AMERICA'S COLLEGES AND UNIVERSITIES. THESE RIGHTS INCLUDE FREEDOM OF SPEECH, FREEDOM OF ASSOCIATION, DUE PROCESS, LEGAL EQUALITY, RELIGIOUS LIBERTY, AND SANCTITY OF CONSCIENCE - THE ESSENTIAL QUALITIES OF LIBERTY. FIRE EDUCATES STUDENTS, FACULTY, ALUMNI, TRUSTEES, AND THE PUBLIC ABOUT THE THREATS TO THESE RIGHTS ON OUR CAMPUSES, AND PROVIDES THE MEANS TO PRESERVE THEM. 0 0 1471603 0 0 FIRE'S PUBLIC AWARENESS PROJECT: FIRE'S PUBLIC AWARENESS PROJECT WORKS TO EDUCATE THE PUBLIC ABOUT THE STATE OF LIBERTY ON CAMPUS AND THEREBY ENLIST SUPPORT FOR REFORM. THROUGH TRADITIONAL MEDIA ENGAGEMENT, MULTIMEDIA PLATFORMS, ONLINE OUTREACH, AND PRINT PUBLICATIONS, FIRE SPARKS CRITICAL DISCUSSIONS OF KEY CAMPUS ISSUES AND FIRST AMENDMENT CONCERNS. THIS PROJECT ATTRACTS OVER 5,000 MENTIONS IN PRINT AND ONLINE PUBLICATIONS YEARLY AND HAS ALSO SECURED NEARLY 600 RADIO INTERVIEWS AND 125 TELEVISION APPEARANCES SINCE 2005. FIRE ALSO BOASTS OVER 60,000 TWITTER AND FACEBOOK FOLLOWERS, 5.5 MILLION YOUTUBE CHANNEL VIEWS, AND HUNDREDS OF THOUSANDS OF ANNUAL WEBSITE VISITORS. 1448287 0 811468 FIRE'S LITIGATION PROJECT: FIRE COORDINATES NATIONAL LITIGATION EFFORTS AIMED AT CHALLENGING SOME OF THE BIGGEST THREATS TO CAMPUS RIGHTS. BEGINNING WITH THE LAUNCH OF OUR STAND UP FOR SPEECH LITIGATION PROJECT, FIRE HAS WORKED WITH PLAINTIFFS FROM THE AROUND THE COUNTRY TO CHALLENGE UNCONSTITUTIONAL SPEECH CODES. OUR MILLION VOICES CAMPAIGN EXPANDS THAT WORK EVEN FURTHER BY PARTNERING OUR OWN COUNSEL WITH FIRE LEGAL NETWORK ATTORNEYS IN AN EFFORT TO FILE CHALLENGES THAT ULTIMATELY FREE ONE MILLION STUDENT VOICES. SINCE 2013, THESE EFFORTS HAVE WON 11 COURT VICTORIES AFFECTING ALMOST 280,000 STUDENTS AND MOTIVATED NUMEROUS POLICY CHANGE VICTORIES OUTSIDE OF COURT AFFECTING HUNDREDS OF THOUSANDS MORE.FIRE STAFF ATTORNEYS DIRECTLY REPRESENTED CLIENTS IN 2018 AND THERE WERE THREE LAWSUITS IN ACTIVE LITIGATION DURING THE YEAR:SHAW V. BURKE, ET AL., CIVIL ACTION NO. 17-2386 (C.D. CAL): THIS IS A CIVIL RIGHTS LAWSUIT BY PLAINTIFF COLLEGE STUDENT RAISING FIRST AMENDMENT CLAIMS AGAINST ADMINISTRATORS AT HIS COMMUNITY COLLEGE AND THE BOARD OF TRUSTEES OF THE COMMUNITY COLLEGE DISTRICT. THE CLAIMS CHALLENGE DISTRICT AND COLLEGE POLICIES LIMITING STUDENT EXPRESSIVE ACTIVITY AND DISTRIBUTION OF LITERATURE ON CAMPUS TO A SMALL "FREE SPEECH AREA." THE CHALLENGED POLICIES IMPACT OVER 20,000 STUDENTS AT THE COLLEGE AND OVER 100,000 STUDENTS IN THE COMMUNITY COLLEGE DISTRICT. A SETTLEMENT AGREEMENT IN THE SUIT WAS REACHED IN DECEMBER OF THIS YEAR, AGREEING TO THE PAYMENT OF $225,000 IN ATTORNEY'S FEES FOR THE WORK OF BOTH FIRE STAFF AND OUTSIDE CO-COUNSEL. THAT AMOUNT WILL LIKELY BE RECEIVED IN JANUARY 2019. THE DISTRICT BOARD OF TRUSTEES ALSO AGREED TO ENACT POLICY CHANGES AT THE DISTRICT AND COLLEGE LEVELS THAT WILL HAVE A BROAD IMPACT ON STUDENT FIRST AMENDMENT RIGHTS THROUGHOUT THE LARGEST COMMUNITY COLLEGE DISTRICT IN THE COUNTRY AND PROMOTE FIRE'S MISSION TO DEFEND AND SUSTAIN FREEDOM OF SPEECH AT AMERICA'S COLLEGES AND UNIVERSITIES.SALAZAR V. JOLIET JUNIOR COLLEGE, ET AL., CIVIL ACTION NO. 1:18-CV-00217 (N.D. ILL.): THIS WAS A CIVIL RIGHTS LAWSUIT BY PLAINTIFF COLLEGE STUDENT RAISING FIRST AMENDMENT CLAIMS AGAINST HER COMMUNITY COLLEGE, VARIOUS COLLEGE ADMINISTRATORS, AND CAMPUS POLICE OFFICERS. THE CLAIMS CHALLENGED COLLEGE POLICIES RESTRICTING STUDENT EXPRESSIVE ACTIVITY AND THE DISTRIBUTION OF LITERATURE ON CAMPUS AS WELL AS THE CONSTITUTIONALITY OF PLAINTIFF'S DETENTION BY CAMPUS POLICE. THE CHALLENGED POLICIES IMPACT ROUGHLY 15,000 STUDENTS IN THE COMMUNITY COLLEGE DISTRICT. PLAINTIFF'S CLAIMS WERE SETTLED IN APRIL 2018. DEFENDANTS AGREED TO POLICY REFORMS THAT HAD A BROAD IMPACT ON STUDENT FIRST AMENDMENT RIGHTS THROUGHOUT THE DISTRICT AND PROMOTES FIRE'S MISSION TO DEFEND AND SUSTAIN FREEDOM OF SPEECH AT AMERICA'S COLLEGES AND UNIVERSITIES. DEFENDANTS AGREE TO PAY $30,000 IN DAMAGES AND ATTORNEY'S FEES FOR THE WORK OF BOTH FIRE STAFF AND OUTSIDE CO-COUNSEL.MCLAUGHLIN V. ESSEX COUNTY COLLEGE, ET AL., ESX-L-000067-18 (N.J. SUPER. CT.): THIS WAS LAWSUIT A BROUGHT UNDER THE NEW JERSEY OPEN PUBLIC RECORDS ACT SEEKING DISCLOSURE OF DOCUMENTS IMPROPERLY WITHHELD IN RESPONSE TO FIRE'S REQUEST FOR RECORDS RELATED TO ESSEX COUNTY COLLEGE'S TERMINATION OF PROFESSOR LISA DURDEN. IN RESPONSE TO THE LAWSUIT'S FILING, THE COLLEGE DISCLOSED THE REQUESTED DOCUMENTS AND AGREED TO SETTLE THE SUIT FOR $4,000 IN ATTORNEY'S FEES FOR THE WORK OF BOTH FIRE STAFF AND OUTSIDE CO-COUNSEL. THIS LAWSUIT FURTHERED FIRE'S MISSION AND BENEFITED THE PUBLIC INTEREST FOR SEVERAL REASONS. FIRST, THE UNDERLYING RECORDS WERE REQUESTED TO INVESTIGATE THE FACTS SURROUNDING AN APPARENT INFRINGEMENT OF A PROFESSOR'S ACADEMIC FREEDOM THROUGH HER TERMINATION, IN FURTHERANCE OF FIRE'S MISSION TO PROTECT AND ADVANCE FACULTY SPEECH AND ACADEMIC FREEDOM RIGHTS. SECOND, PUBLIC INTEREST WATCHDOG ORGANIZATIONS SUCH AS FIRE HAVE A STRONG INTEREST IN VIGOROUSLY PURSUING ACCESS TO PUBLIC RECORDS, GUARANTEED BY STATE STATUTE, AS A MEANS OF HOLDING PUBLIC AGENCIES ACCOUNTABLE FOR THEIR ACTIONS. 1343360 7750 0 THE SPEECH, OUTREACH, ADVOCACY, AND RESEARCH PROJECT (SOAR) IS AN AMBITIOUS THREE-YEAR CAMPAIGN AIMED AT INSPIRING GREATER UNDERSTANDING OF AND APPRECIATION FOR INDIVIDUAL RIGHTS. THIS PROJECT IS FOCUSED ON THREE PRIMARY INITIATIVES: PUBLIC OPINION POLLING, LEGAL AND SOCIAL SCIENCE RESEARCH, AND OUTREACH TO HIGH SCHOOL, FACULTY, ALUMNI, AND PUBLIC STAKEHOLDERS. SINCE ITS LAUNCH IN 2017, IT HAS ORGANIZED FOUR SUCCESSFUL CONFERENCES, RELEASED TWO PUBLIC OPINION POLLS, COORDINATED NUMEROUS CONFERENCE APPEARANCES, RELEASED A HIGH SCHOOL CURRICULUM PACKAGE AND OVER 20 ACTIVISM RESOURCES FOR CAMPUS LEADERS, INTERACTED WITH THOUSANDS OF HIGH SCHOOL STUDENTS, COLLEGE STUDENTS, FACULTY MEMBERS, AND ALUMNI, AND WRITTEN OVER 50 ACADEMIC ARTICLES, OP-EDS, AND BLOGS. 2125059 2614 0 INDIVIDUAL RIGHTS DEFENSE PROGRAM: THE INDIVIDUAL RIGHTS DEFENSE PROGRAM (IRDP) PROVIDES ASSISTANCE TO INDIVIDUAL STUDENTS, PROFESSORS, AND CAMPUS GROUPS WHOSE FUNDAMENTAL CIVIL LIBERTIES HAVE BEEN VIOLATED. WORKING THROUGH OUTREACH TO ADMINISTRATORS, THE STRATEGIC USE OF PUBLICITY TO GENERATE PUBLIC ATTENTION AND PRESSURE, AND, WHEN NECESSARY, THE COORDINATION OF LEGAL COUNSEL AND ACTION IN THE COURTS, THE IRDP HAS SECURED ALMOST 300 VICTORIES ON BEHALF OF STUDENTS AND FACULTY MEMBERS SINCE FIRE'S FOUNDING.POLICY REFORM PROJECT: THE POLICY REFORM PROJECT ENCOMPASSES FIRE'S EFFORTS TO PROACTIVELY AND SYSTEMATICALLY CHALLENGE CAMPUS POLICIES THAT VIOLATE STUDENTS AND FACULTY MEMBERS' FUNDAMENTAL RIGHTS. USING RESEARCH FROM FIRE'S SPOTLIGHT DATABASE, THIS PROJECT TARGETS SPEECH CODES THROUGH CORRESPONDENCE WITH CAMPUS ADMINISTRATORS, ON-CAMPUS COLLABORATION WITH STUDENT AND FACULTY ALLIES, AND PUBLIC AWARENESS INITIATIVES. IT ALSO WORKS TO ADVANCE FIRE'S MISSION IN THE LEGAL FIELD, CONNECTING WITH ATTORNEYS NATIONWIDE THROUGH OUR LEGAL NETWORK, PUBLISHING LEGAL SCHOLARSHIP, AND FILING 'AMICUS' BRIEFS IN KEY CASES. FINALLY, ITS LEGISLATIVE AND POLICY PROJECT WORKS TO SUPPORT THESE EFFORTS BY COMBATTING GOVERNMENT POLICIES THAT THREATEN CAMPUS RIGHTS AND BY ADVOCATING FOR GREATER LEGISLATIVE PROTECTIONS FOR INDIVIDUAL RIGHTS IN HIGHER EDUCATION. SINCE 1999, THESE COMBINED EFFORTS HAVE HELPED FIRE SECURE OVER 325 POLICY REFORM VICTORIES AFFECTING ALMOST 4.4 MILLION STUDENTS.FIRE STUDENT NETWORK: THE FIRE STUDENT NETWORK (FSN) IS A DYNAMIC COALITION OF THOUSANDS OF STUDENTS DEDICATED TO ADVANCING INDIVIDUAL LIBERTIES ON CAMPUS IN PARTNERSHIP WITH FIRE. THE FSN OFFERS NUMEROUS EDUCATIONAL AND ACTIVISM RESOURCES TO ITS MEMBERS, AND ITS ANNUAL CONFERENCE, SUMMER INTERNSHIP, ON-CAMPUS SPEECHES, AND VARIOUS OUTREACH PROGRAMS PROVIDE STUDENTS WITH THE SKILLS AND STRATEGIES NECESSARY FOR ACTION. IN A GIVEN YEAR, THE FSN HOSTS NEARLY 150 STUDENTS AT ITS EVENTS, COORDINATES APPROXIMATELY 50 ON-CAMPUS PRESENTATIONS, VISITS DOZENS OF NATIONAL CONFERENCES, PROVIDES RESOURCES TO HUNDREDS OF ACTIVISTS, AND RECRUITS NEARLY 1,000 NEW MEMBERS. 2125059 2614 0 6388309 1 1 0 1 0 0 0 0 0 1 1 1 0 0 1 1 1 0 0 0 0 0 0 0 0 0 0 0 1 1 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 0 0 1 33 0 72 1 0 0 0 0 0 0 0 0 0 0 X 10 10 0 0 0 0 0 0 0 1 1 0 0 1 1 1 1 1 1 1 0 0 PA NY X X X THE ORGANIZATION 2157173473 510 WALNUT STREET SUITE 1250 PHILADELPHIA PA 19106 HARVEY SILVERGLATE FOUNDER 8.00 X X 0 0 0 DANIEL SHUCHMAN CHAIRMAN 1.00 X X 0 0 0 BARBARA BISHOP SECRETARY 1.00 X X 0 0 0 ANTHONY DICK TREASURER 1.00 X X 0 0 0 MARLENE MIESKE VICE CHAIRMAN 1.00 X X 0 0 0 RICHARD LOSICK DIRECTOR 1.00 X 0 0 0 JOSEPH MALINE DIRECTOR 1.00 X 0 0 0 DAPHNE PATAI DIRECTOR 1.00 X 0 0 0 VIRGINIA POSTREL DIRECTOR 1.00 X 0 0 0 NICK ROSENKRANZ DIRECTOR 1.00 X 0 0 0 GREGORY LUKIANOFF PRESIDENT AND CEO 60.00 X 358696 0 22780 ROBERT SHIBLEY EXECUTIVE DIRECTOR 50.00 X 206836 0 25786 WILLIAM CREELEY SENIOR VP OF LEGAL & PUBLIC 40.00 X 145000 0 23089 ALISHA GLENNON SENIOR VP OF FINANCE & DEVELOPMENT 40.00 X 141333 0 27244 JOSEPH COHN DIRECTOR 40.00 X 112900 0 8988 SAMANTHA HARRIS SENIOR VP FOR PROCEDURAL ADVOCACY 40.00 X 105173 0 2976 1069938 0 110863 6 0 1 0 DAVIS WRIGHT TREMAINE 1919 PENNSYLVANIA AVENUE SUITE 800 WASHINGTON DC 20006 LEGAL SERVICES 991913 1 11627342 277970 11627342 LITIGATION SETTLEMENT PROCEEDS 900099 811468 811468 811468 103566 103566 1337 1337 277998 277970 28 28 28 OTHER INCOME 900099 61505 61505 61505 12605246 811468 0 166436 10364 10364 608387 403654 58228 146505 3267274 2468028 417863 381383 55479 41459 6917 7103 413311 342597 28884 41830 271867 193955 34527 43385 1098428 1097891 238 299 73405 58467 6614 8324 400815 395353 1621 3841 86058 76543 1209 8306 68767 36009 10482 22276 112030 90756 7079 14195 512621 419376 33538 59707 322546 290896 6062 25588 60281 59684 43 554 185647 185647 32671 26022 2944 3705 EVENT EXPENSE 212167 170949 41218 PRINTING AND REPRODUCTI 101418 40178 640 60600 RESEARCH 53718 48507 386 4825 COMMUNICATIONS 45784 36337 4104 5343 108627 81284 4040 23303 8101665 6388309 811066 902290 3109618 5845326 6939330 7854939 325000 238333 3092 2653 226973 325464 1640205 503037 1308153 1137168 841806 91309 133014 12003475 16378703 185633 206868 307848 309341 817710 729389 1311191 1245598 X 8021881 13797040 2647039 1312337 23364 23728 10692284 15133105 12003475 16378703 4503581 -62760 0 X 0 1 X 1 0 X 3092602 7235443 6160810 10758302 11627342 38874499 3092602 7235443 6160810 10758302 11627342 38874499 7428586 31445913 16398 18845 28910 57496 104903 226552 20844 255245 169511 84986 61505 592091 39693142 811468 0.79220 0.64560 X SCHEDULE A, PART II, LINE 10, EXPLANATION OF OTHER INCOME: OTHER INCOME - 2013 AMOUNT: $ 20,844. 2014 AMOUNT: $ 255,245. 2015 AMOUNT: $ 169,511. 2016 AMOUNT: $ 84,986. 2017 AMOUNT: $ 61,505. 210788 210788 8074417 8285205 564260 141065 0 0 364971 432907 494307 564260 1856445 2784668 119592 168294 129150 210788 627824 91243 108227 123577 141065 464112 696168 3051 3051 23364 364 23728 23332 32 23364 23301 31 23332 23299 2 23301 23296 3 23299 0.00000 1.00000 0.00000 0 0 1142020 261643 880377 330260 112746 217514 167925 128648 39277 1137168 U.S. TREASURY BILL 841806 C 841806 DEFERRED LEASE OBLIGATION 729389 729389 X 12542486 -62760 -62760 12605246 0 12605246 8101665 0 8101665 0 8101665 PART V, LINE 4: THE FOUNDATION'S ENDOWMENT CONSISTS OF ONE INDIVIDUAL FUND ESTABLISHED PRIMARILY TO FUND OPERATIONS. PART X, LINE 2: THE FOUNDATION IS A NON-PROFIT ORGANIZATION AS DESCRIBED IN SECTION 501(C)(3) OF THE INTERNAL REVENUE CODE AND IS EXEMPT FROM FEDERAL AND STATE INCOME TAXES. ACCORDINGLY, THERE IS NO PROVISION FOR INCOME TAXES. THE FOUNDATION IS NOT AWARE OF ANY ACTIVITIES THAT WOULD JEOPARDIZE ITS TAX-EXEMPT STATUS, NOR IS IT AWARE OF ANY OF ITS ACTIVITIES THAT ARE SUBJECT TO TAX ON UNRELATED BUSINESS INCOME TAXES. THE FOUNDATION FOLLOWS THE GUIDANCE IN THE INCOME TAX STANDARD REGARDING THE RECOGNITION AND MEASUREMENT OF UNCERTAIN TAX POSITIONS. THE GUIDANCE CLARIFIES THE ACCOUNTING FOR UNCERTAINTY IN INCOME TAXES RECOGNIZED IN AN ENTITY'S FINANCIAL STATEMENTS. THE GUIDANCE FURTHER PRESCRIBES RECOGNITION AND MEASUREMENT OF TAX PROVISIONS TAKEN OR EXPECTED TO BE TAKEN ON A TAX RETURN THAT ARE NOT CERTAIN TO BE REALIZED. THE APPLICATION OF THIS STANDARD HAD NO IMPACT ON THE FOUNDATION'S FINANCIAL STATEMENTS. THE FOUNDATION'S INCOME TAX RETURNS ARE SUBJECT TO REVIEW AND EXAMINATION BY FEDERAL, STATE, AND LOCAL AUTHORITIES. 1 ESSAY WRITING SCHOLARSHIP 8 10364 PART I, LINE 2: SCHOLARSHIPS ARE AWARDED BASED UPON THE SELECTIONS OF AN ASSESSMENT COMMITTEE THAT READ AND EVALUATE ESSAY CONTEST SUBMISSIONS. WINNERS' ELIGIBILITY IS VERIFIED BY CONTACTING THEIR UNIVERSITY AND VERIFYING ENROLLMENT. SCHOLARSHIPS ARE PAID DIRECTLY TO THE UNIVERSITY AND CREDITED TO THE STUDENT'S TUITION ACCOUNT. RECEIPT OF SCHOLARSHIP FUNDS IS VERIFIED BY RETURN OF A CANCELLED CHECK THAT WAS CASHED BY THAT UNIVERSITY. X X X 0 0 0 0 0 0 0 0 0 GREGORY LUKIANOFF PRESIDENT AND CEO 281250 0 65000 0 12446 0 2500 0 20280 0 381476 0 0 0 ROBERT SHIBLEY EXECUTIVE DIRECTOR 185167 0 20000 0 1669 0 2500 0 23286 0 232622 0 0 0 WILLIAM CREELEY SENIOR VP OF LEGAL & PUBLIC 135500 0 6000 0 3500 0 2500 0 20589 0 168089 0 0 0 ALISHA GLENNON SENIOR VP OF FINANCE & DEVELOPMENT 131333 0 10000 0 0 0 2500 0 24744 0 168577 0 0 0 X 15 277970 FAIR MARKET VALUE 0 0 0 0 PART I, COLUMN (B): THE NUMBER LISTED IS THE NUMBER OF CONTRIBUTORS. FORM 990, PART VI, SECTION A, LINE 1 THE EXECUTIVE COMMITTEE SHALL BE COMPOSED OF THE OFFICERS OF THE CORPORATION. THE EXECUTIVE COMMITTEE SHALL BE AUTHORIZED TO ACT FOR THE BOARD BETWEEN ITS REGULAR MEETINGS. EXCEPT AS OTHERWISE PROVIDED BY THE CHAPTER, SECTION 7.1. OF THESE BYLAWS, OR BY RESOLUTION OF THE BOARD, THE EXECUTIVE COMMITTEE SHALL HAVE AND MAY EXERCISE ALL OF THE POWERS AND AUTHORITY OF THE BOARD IN THE MANAGEMENT OF THE CORPORATION. FORM 990, PART VI, SECTION B, LINE 11B THE FORM 990 IS PREPARED BY AN INDEPENDENT ACCOUNTING FIRM. THEN MANAGEMENT INCLUDING THE EXECUTIVE DIRECTOR, VP OF FINANCE AND DEVELOPMENT, AND PRESIDENT AND CEO WILL ALL REVIEW THE FORM 990 PRIOR TO ITS FILING IN DETAIL. FORM 990, PART VI, SECTION B, LINE 12C THE BOARD OF DIRECTORS WILL UNDERTAKE A REVIEW OF THE MATTER BY MAKING ALL NECESSARY INQUIRIES DEEMED WARRANTED BY THE CIRCUMSTANCES. AN APPROPRIATE ORGANIZATIONAL RESPONSE SHALL BE DETERMINED BY DISINTERESTED MEMBERS OF THE BOARD OF DIRECTORS. THE ORGANIZATION REVIEWS BUSINESS RELATIONSHIPS WITH ALL VENDORS ANNUALLY. CONFLICTS INVOLVING EMPLOYEES ARE RESOLVED BY THE PRESIDENT. CONFLICTS INVOLVING THE PRESIDENT OR BOARD OF DIRECTORS ARE RESOLVED BY THE BOARD OF DIRECTORS. PROCEEDINGS ARE DOCUMENTED IN A MEMO OR MINUTES AS DEEMED APPROPRIATE BY THE CIRCUMSTANCES. FORM 990, PART VI, SECTION B, LINE 15A THE COMPENSATION COMMITTEE OF THE BOARD OF DIRECTORS CONDUCTS A COMPENSATION STUDY AND USES OTHER COMPARATIVE DATA TO DETERMINE APPROPRIATE COMPENSATION OF THE PRESIDENT/CEO. THE COMPENSATION COMMITTEE REPORTS FINDINGS TO THE BOARD OF DIRECTORS. THE BOARD OF DIRECTORS APPROVES THE COMPENSATION PACKAGE. FORM 990, PART VI, SECTION C, LINE 19 THE ORGANIZATION MAKES ITS GOVERNING DOCUMENTS AND CONFLICT OF INTEREST POLICY AVAILABLE TO THE PUBLIC UPON REQUEST. ITS FINANCIAL STATEMENTS ARE AVAILABLE ON ITS WEBSITE.