2016-11-15T09:23:24-06:00 2016-06-30 GRANT THORNTON LLP 757 THIRD AVE 3RD FLOOR NEW YORK NY 100172013 990 2015-07-01 133170676 City Harvest Inc - Copy % RENEE RICHARDSON CITY 6464120600 6 East 32nd Street 5th fl new york NY 10016 RENEE RICHARDSON VP,Finance and Admin 6464120600 2016-11-09 true Scott Thompsett P00741490 2125990100 2015 2017-02-10 21:41:12Z X Jilly Stephens 6 East 32nd Street 5th Fl new york NY 10016 125152657 false X www.cityharvest.org X 1983 NY to end hunger in communities throughout New York City. We do this through food rescue and distribution, education, and other practical, innovative solutions. 40 40 232 9508 0 116036117 123559901 0 0 8540 -15905 -941279 -811613 115103378 122732383 100994 0 0 0 15031444 14536981 253000 255128 6822611 101098889 108634825 116484327 123426934 -1380949 -694551 23384009 24348679 4002106 5628016 19381903 18720663 X City Harvest pioneered food rescue in 1982 and, in FY16 collected 55 million pounds of excess food to help feed the nearly 1.4 million New Yorkers struggling to put meals on their tables. Through relationships with farms, grocers, restaurants, and manufacturers, City Harvest collects nutritious food that would otherwise go to waste and delivers it free of charge to 500 soup kitches, food pantries and other community food programs across the five boroughs. In addition to helping meet the immediate need for food, city harvest developed long-term healthy neighborhoods programs which partner with low-income communities to increase access to fresh produce and help residents shop for and cook nutritious, budget-conscious meals. false false 111695885 0 0 Emergency Food Rescue: Using a fleet of 22 trucks, City Harvest rescues and delivers excess food seven days a week. In fiscal year 2016, City Harvest collected 55 million pounds of food, more than half of which was comprised of fresh fruits and vegetables. This food is delivered free of charge to 500 community food programs across New York City. Since our founding, we have collected over 545 million pounds of good, nutritious food for New Yorkers in need. At City Harvest, we recognize our responsibility to the people we serve and ensure the highest food safety standards in every facet of our food rescue operations. We take careful steps to ensure that each pound of food is rescued and delivered safely. 1. Food Rescue Facility: City Harvest's 45,400 square foot Food Rescue Facility in Long Island City, Queens, allows us to move some 150,000 pounds of food a day to hungry New Yorkers across the five boroughs. The Facility has a large cooler and freezer to safely hold perishable food on a short-term basis, and a large dry storage area to sort non-perishable goods, allowing us to rescue and deliver large amounts and a wide variety of food. Each morning, City Harvest's fleet of trucks are loaded with food here and begin their day picking up and delivering food for hundreds of community programs. The food rescue facility also accepts large donations of food directly from farms and corporations, which are repacked by volunteers into smaller family-sized portions that we deliver to soup kitchens and food pantries. In fiscal year 2016, city harvest rescued 55 million pounds of food. Seventy-five percent of the food was nutrient dense and more than 50% was produce. 2. Where City Harvest rescues the food: city harvest collects good, nutritious, excess food that would otherwise go to waste from over 2,500 donors, including farms, grocers, restaurants, and manufacturers. City harvest also relies on new yorkers across the city to help feed their hungry neighbors by organizing food drives in their schools, apartment buildings, businesses and places of worship. 3. Where the food goes: City Harvest regularly delivers food to more than 500 soup kitchens, food pantries and other community food programs across New York City, helping feed the nearly 1.4 million residents struggling to put meals on their tables regularly. These soup kitchens, food pantries, homeless shelters, senior centers, children's daycare centers, and other community food programs together help feed hundreds of thousands of new yorkers each week. 4. Kosher Initiative: City Harvest's Kosher Initiative addresses the dietary needs of the 100,000 observant jewish households facing hunger in new york city. to date, we delivered 30 million pounds of kosher food. we deliver food to 28 kosher feedings programs across the city. annually. kosher agencies, helping to feed more than one million visitors annually. 3858504 0 0 Healthy Neighborhoods: Nearly 1.4 million New Yorkers are facing hunger and for many people that City Harvest serves, healthy food is unavailable and unaffordable. In turn, diseases related to poor nutrition - including diabetes and heart disease - tend to be concentrated where demand for emergency food is greatest. As a natural extension of the anti-hunger work we began more than 30 years ago, City Harvest developed long-term Healthy Neighborhoods programs which partner with low-income communities to increase access to fresh produce and help residents shop for and cook nutritious, budget-conscious meals. Healthy Neighborhoods programs target five low-income neighborhoods of New York City, one in each borough: - Bedford Stuyvesant in Brooklyn - South Bronx - Washington Heights/Inwood in Manhattan - Northwest Queens - North Shore of Staten Island Healthy Neighborhoods programs are working to put good nutritious food on the table for New Yorkers in need, and help inspire long-term change in the fight against hunger by: 1. Relieving Food Insecurity: City Harvest works to provide hungry New Yorkers with nutritious, free food to feed themselves and their families. a. Providing food: City Harvest delivered 55 million pounds of food citywide and over 13.2 million pounds of food to emergency food programs located in healthy neighborhoods. More than 50% of this food was produce, and soup kitchens and food pantries are then able to offer participants a variety of healthy food. b. Mobile Markets: Through free, farmers market-style distributions of produce in low-income communities across the five boroughs, City Harvest distributes over 3 million pounds of fruits and vegetables each year. On-site cooking demonstrations offer recommendations on how to cook with produce, and health and wellness programming helps participants improve their health. c. ACE: Through the Agency Capacity Expansion (ACE) program, City Harvest offers grants to selected community food programs for one-time projects to upgrade infrastructure and strengthen their ability to serve the community. In addition, City Harvest University courses on subjects such as fundraising and planning help improve partner organizations' core skill sets so they can serve as a stable resource for their clients. 2. Providing Nutrition Education and Inspiring Healthy Choices: City Harvest offers free nutrition courses and activities focused on buying, preparing and eating healthy foods. a. Nutrition Education Courses: City Harvest provides free nutrition education classes for adults, families, teenagers, and senior citizens at participating community organizations, which teach residents how to prepare healthy meals on a budget. We reach over 55,000 residents a year through nutrition education programming. b. Cooking Demonstrations: The staff and volunteers of City Harvest demonstrate healthy, budget-conscious recipes and techniques for residents at senior centers, supermarkets, corner stores, health clinics, and other community gathering places. c. Shopping Workshops: Through Cooking Matters at the Store workshops, City Harvest teaches store customers practical tools on how to stretch food dollars and shop for healthy food on a budget in their neighborhood market. d. City Harvest Fruit Bowl: City Harvest delivers a regular supply of fresh fruit and low-fat dairy to 7,000 children in pre-school, head start, and after school programs and combine a unique nutrition education program designed to teach life-long health eating habits to children and caregivers. 3. Increasing Access to Affordable, Healthy Food: City Harvest works with residents, community organizations, afterschool programs, and local businesses to raise awareness of healthy food, and to ensure that residents can find affordable, nutritious food in their neighborhoods. a. Healthy retail: City Harvest works with supermarkets and corner stores to reach residents where they shop for food. In addition to offering assistance to these food retailers to increase the quantity, quality and variety of available produce, City Harvest hosts healthy cooking demonstrations and budget shopping workshops to encourage nutritious and affordable choices right on site. b. Community Action Networks: To build public support for healthy food availability and consumption, and sustain change over time, City Harvest convenes Community Action Networks (CANS) in each of the Healthy Neighborhoods. These networks engage passionate and dedicated residents and businesses who are committed to improving access to healthy food choices. 4. Increase Community Engagement: City Harvest trains community residents to engage in hunger relief efforts in their own neighborhoods. Through Community partner mobile markets, City Harvest helps provide residents and local businesses with the tools needed to help fight against hunger and diet-related diseases in the communities we help. Community residents also volunteer to lead nutrition education courses, help run City Harvest Mobile Markets, work with corner store owners, and other opportunities to increase healthy food access in their communities. 115554389 true true false false false false false false false true true false false false true true true false false false false false false true true false false false false true false false false false false false false false true false false false false false false false false true 136 0 true 232 true false false false false false true true false false false false X 40 40 false false false false false false false true true false false true true true true true true true true false AL AK AR CA CO CT FL IL KS KY ME MD MA MI MN MS MO NH NJ NM NY NC ND OH OK OR PA RI SD UT VA WA WV X X RENEE RICHARDSON 6464120600 6 EAST 32ND STREET 5TH FL new york NY 10016 James Kallman Chairman 1.0 0.0 X X 0 0 0 Eric Ripert Vice Chair 1.0 0.0 X X 0 0 0 Marc Granetz Secretary 1.0 0.0 X X 0 0 0 Jeffrey L Weiss Treasurer 1.0 0.0 X X 0 0 0 Marjorie Sybul Adams Director 1.0 0.0 X 0 0 0 Carol Atkinson Director 1.0 0.0 X 0 0 0 Alex Berenson Director 1.0 0.0 X 0 0 0 Richard Berry Director 1.0 0.0 X 0 0 0 Ashish Bhutani Director 1.0 0.0 X 0 0 0 Benjamin Bram Director 1.0 0.0 X 0 0 0 Randy Brown Director 1.0 0.0 X 0 0 0 Jason Carroll Director 1.0 0.0 X 0 0 0 Dana Cowin Director 1.0 0.0 X 0 0 0 Misook Doolittle Director 1.0 0.0 X 0 0 0 Celine Dufetel Director 1.0 0.0 X 0 0 0 J Michael Evans Director 1.0 0.0 X 0 0 0 Tom Guba Director (thru 12/1/2015) 1.0 0.0 X 0 0 0 Mitchell Harris Director 1.0 0.0 X 0 0 0 Christine Hikawa Director 1.0 0.0 X 0 0 0 Joy Ingham Director 1.0 0.0 X 0 0 0 Sharon H Jacquet Director 1.0 0.0 X 0 0 0 Pamela Kaufmann Director 1.0 0.0 X 0 0 0 David Kirchhoff Director 1.0 0.0 X 0 0 0 Bill Koenigsberg Director 1.0 0.0 X 0 0 0 Grace Koo Director 1.0 0.0 X 0 0 0 Kerrie Macpherson Director 1.0 0.0 X 0 0 0 William J Mills Director 1.0 0.0 X 0 0 0 Nadine Mirchandani Director 1.0 0.0 X 0 0 0 Heather Mnuchin Director 1.0 0.0 X 0 0 0 Elizabeth WY Moore Director (thru 11/1/2015) 1.0 0.0 X 0 0 0 Amanda Morcos Director 1.0 0.0 X 0 0 0 Marc Murphy Director 1.0 0.0 X 0 0 0 Victor Ozeri Director 1.0 0.0 X 0 0 0 Rachael Ray Director 1.0 0.0 X 0 0 0 Mary Rubin Director 1.0 0.0 X 0 0 0 Marcus Samuelsson Director 1.0 0.0 X 0 0 0 Rick Smilow Director 1.0 0.0 X 0 0 0 Robert M Stein Director 1.0 0.0 X 0 0 0 AJ Vaccarino Director 1.0 0.0 X 0 0 0 Tim Walsh Director 1.0 0.0 X 0 0 0 Katie Raskin Workman Director 1.0 0.0 X 0 0 0 Michael A Young Director 1.0 0.0 X 0 0 0 Jilly Stephens Executive Director 40.0 0.0 X 403924 0 27929 Jennifer Mclean COO 40.0 0.0 X 232370 0 36593 Renee Richardson VP, Finance and Administration 40.0 0.0 X 16922 0 1902 Kevin Duffy VP, Development 40.0 0.0 X 185845 0 34303 Heather Reynolds VP, Marketing 40.0 0.0 X 184597 0 26364 James Schembari Senior Director, Finance 40.0 0.0 X 183903 0 17514 Leslie Gordon Sr. Director, Prgm Operations 40.0 0.0 X 163633 0 21869 Kate Mackenzie Dir, Policy & Community 40.0 0.0 X 140000 0 29603 Miguel Bido Sr. Dir, Transport & Warehouse 40.0 0.0 X 153013 0 15902 Debra L Lucarello SR. DIR, HUMAN RESOURCES 40.0 0.0 X 148508 0 7888 1812715 0 219867 17 false true false the production Management group 7160 columbia gateway drive suite 3 COLUMBIA MD 21046 production 671047 Lake Group Media Inc 1 Byram Brook Pl ARMONK NY 10504 Digital Marketing 227624 Craver Matthews Smith Co 1900 Campus Commons Dr 450 RESTON VA 20191 Fundraising Consult. 166200 Unimac Graphics 350 Michele Pl CARLSTADT NJ 07072 Printing 164036 Swiss Post Solutions Inc 10 East 40th Street 9th Fl NEW YORK NY 10016 office services 150721 14 4054631 1503996 118001274 96124303 123559901 0 27506 27506 0 0 0 0 0 1216436 1259847 -43411 -43411 -43411 336835 4054631 1160427 -823592 -823592 0 0 MISCELLANEOUS 900099 11979 11979 11979 122732383 -827518 0 0 0 0 835890 602177 28359 205354 0 10211666 7356502 346452 2508712 0 1873446 1531116 32136 310194 1615979 1163748 64036 388195 0 5922 2005 328 3589 126916 42973 7023 76920 0 255128 255128 0 1227888 502139 82067 643682 739338 29422 4122 705794 1329126 228766 19145 1081215 574122 387239 85829 101054 0 1811926 1289451 232005 290470 0 0 0 19770 14824 1793 3153 0 882026 791202 40546 50278 0 FOOD DISTRIBUTED 95383805 95383805 FOOD TRANSPORT & DISTRIBUT. 5182686 5182686 FOOD PACKAGING SUPPLIES 181203 168949 12254 MISCELLANEOUS 1170097 877385 106093 186619 123426934 115554389 1049934 6822611 3467348 6231979 8469327 3521129 6144521 5387879 0 0 0 0 0 0 0 0 869585 996653 301523 394473 5883117 3308435 3183080 2574682 343133 4633257 0 0 0 0 0 0 605492 608627 23384009 24348679 2079868 1869361 0 0 0 1879440 0 0 0 0 0 0 526751 386576 0 0 1395487 1492639 4002106 5628016 X 13418073 13114219 5659073 5293181 304757 313263 19381903 18720663 23384009 24348679 -694551 33311 X false true X true false X 90671162 112460481 102698372 116036117 123641608 545507740 0 0 90671162 112460481 102698372 116036117 123641608 545507740 65985221 479522519 157132 73101 46024 42216 27506 345979 0 1164597 1107800 1136585 339271 267107 4015360 549869079 0.87207 0.90201 X RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 304757 8506 313263 344541 -39784 304757 328484 16057 344541 327028 1456 328484 331347 -4319 327028 1.00000 false false 1080458 433527 646931 4223954 2427217 1796737 578705 447691 131014 2574682 0 DEFERRED RENT 1492639 1492639 X 124715219 33311 1949525 1982836 122732383 122732383 125376459 1949525 1949525 123426934 123426934 Endowment Funds Part V, Line 4 City Harvest's endowment supports the general charitable mission of the organization. The organization anticipates using the endowment's interest and dividends to support its charitable programs, while leaving the principal and gains to grow to continue to fund the organization as it grows. FIN 48 Part X, Line 2 City Harvest follows the provisions of FASB Interpretation No. 48 ("FIN 48") Accounting for Uncertainties in Income Taxes - an interpretation of FASB Statement No. 109, now incorporated in accounting standards codification ("ASC") 740. ASC 740-10 clarifies the accounting for uncertainty in tax positions taken or expected to be taken in a tax return, including issues relating to financial statement recognition and measurement. This section provides that the tax effects from an uncertain tax position can be recognized in the financial statements only if the position is "more-likely-than-not" to be sustained if the position were to be challenged by a taxing authority. The assessment of the tax position is based solely on the technical merits of the position, without regard to the likelihood that the tax position may be challenged. City Harvest is exempt from federal income taxation by virtue of being an organization described in Section 501(c)(3) of the Internal Revenue Code. Nevertheless, City Harvest may be subject to tax on income unrelated to its exempt purpose, unless that income is otherwise excluded by the Code. The tax years ending June 30, 2013, 2014, 2015 and 2016 are still open to audit for both federal and state purposes. Management determined that there are no uncertain tax positions within its financial statements. X X X X X true Craver Mathews Smith Co consultant direct mail false 5626763 84000 5542763 London Misher Public Relations Inc consultant -Gala false 2037351 40000 1997351 Karlitz and company LLC Consultant -BID false 1745142 131128 1614014 9409256 255128 9154128 AL AK AR CA CO CT FL IL KS KY ME MD MA MI MN MS MO NH NJ NM NY NC ND OH OK OR PA RI SC TN VT VA WA WV WI Bid against 1529067 1406942 122125 56450 2715 1600 448513 practical magic 2200641 2037966 162675 40000 158890 6600 298989 13 661758 609723 52035 40125 34456 6000 66089 4391466 4054631 336835 136575 196061 14200 813591 1160427 -823592 Schedule G, Part II City Harvest holds a variety of special events throughout the year, most notably, its Annual Gala. City Harvest raised a total of $4,391,466 in connection with its special event activities in 2015. Of that total, $336,835 is considered event revenue, the fair value of goods and services provided to donors at the events, and $4,054,631 consists of contributions received in connection with the events. The costs associated with the events totaled $1,160,427 and the net loss derived from event activities (without contributions factored in) totaled $823,592. Most of the revenue is reported as pure contribution revenue on Part VIII, Line 1(c). X X X X X true false false false false false false true false Jilly Stephens Executive Director 343924 0 60000 0 0 0 13972 0 13957 0 431853 0 0 0 Jennifer Mclean COO 215120 0 17250 0 0 0 12587 0 24006 0 268963 0 0 0 Kevin Duffy VP, Development 172318 0 13527 0 0 0 10298 0 24005 0 220148 0 0 0 Heather Reynolds VP, Marketing 129999 0 13048 0 41550 0 9916 0 16448 0 210961 0 0 0 James Schembari Senior Director, Finance 167657 0 16246 0 0 0 9661 0 7853 0 201417 0 0 0 Leslie Gordon Sr. Director, Prgm Operations 151633 0 12000 0 0 0 5421 0 16448 0 185502 0 0 0 Kate Mackenzie Dir, Policy & Community 136942 0 3058 0 0 0 5572 0 24031 0 169603 0 0 0 Miguel Bido Sr. Dir, Transport & Warehouse 142232 0 10781 0 0 0 8049 0 7853 0 168915 0 0 0 Debra L Lucarello SR. DIR, HUMAN RESOURCES 136867 0 11641 0 0 0 7888 0 0 0 156396 0 0 0 Schedule J, Part I, Line 4a Heather Reynolds, VP of Marketing, received a severance payment of $41,550 in 2015; this payment is reported in Schedule J, part II, column (b)(iii). Schedule J, Part I, Line 7 Employees may receive a bonus for meeting certain performance metrics; the bonus is awareded by the board of directors without any input by the employee in the decision-making to offer the bonus. the board's decision-making process is memorialized in the board minutes. X 72 960528 fair market value X 95163775 3RD PARTY VALUATION false true false In Kind contributions Part II Food products are donated to City Harvest by restaurants, corporations and individuals, and are subsequently distributed to a network of 500 soup kitchens, food pantries, and other community food programs. City Harvest also arranges for food from its donors to be distributed directly to other food banks or directly to community food programs. In addition to donations of food, City Harvest accepts donations of prepared food and meals. All food has been valued based on the wholesale value of donated product at the national level, as determined by an independent study, which has been calculated by City Harvest at $1.70 per pound for fiscal year 2016 and $1.72 per pound for fiscal year 2015. Process used to review form 990 FORM 990, PART VI, Section B, LINE 11 City harvest's board of directors has assigned the audit committee the responsibility of reviewing and approving the form 990. accordingly, after management and the audit committee have fully reviewed the form 990, it is approved by the audit committee and made available electronically to the board of directors. Any comments are reviewed by management and the Audit Committee, and changes made if deemed necessary. these changes are reviewed with the audit committee after which, the vice president of finance notifies the audit firm to finalize the form 990 and file it with the internal revenue service. Form 990, Part VI, Section B, line 12 conflict of interest policy monitoring & enforcement City harvest issues its conflict of interest policy along with its handbook upon employment. additionally, each board member is required to submit a potential conflict of interest disclosure statement immediately upon election or appointment to the board, and on an annual basis thereafter. each employee is required to place the interest of city harvest foremost in any dealing with city harvest and has a continuing responsibility to comply with the requirements of the conflict of interest policy. any potential conflict of interest shall be reviewed by the executive committee of the board, which shall attempt to resolve any actual or potential conflict. employees are required to notify their supervisors of any potential conflicts and the matter is resolved by the human resource department in consultation with the executive director. form 990, part VI, Section B, line 15 PROCESS FOR DETERMINING COMPENSATION THE EXECUTIVE DIRECTOR'S COMPENSATION IS ADMINISTERED IN ACCORDANCE WITH AN EMPLOYMENT CONTRACT THAT WAS REVIEWED BY AN INDEPENDENT COMPENSATION FIRM THAT PROVIDED BOTH BENCHMARKING AGAINST THE COMPETITIVE MARKET AND AN INTERMEDIATE SANCTIONS REVIEW. THE CONTRACT WAS REVIEWED BY THE EXECUTIVE COMMITTEE OF THE BOARD AND APPROVED BY THE FULL BOARD. ANNUALLY, THE BOARD CHAIR CONVENES A COMMITTEE OF DIRECTORS WHO HAVE WORKED CLOSELY WITH THE EXECUTIVE DIRECTOR. THIS COMMITTEE DISCUSSES, INDEPENDENT OF THE EXECUTIVE DIRECTOR, THE EXECUTIVE DIRECTOR'S PERFORMANCE RELATIVE TO THE JOB DESCRIPTION. DURING THESE DELIBERATIONS, THE COMMITTEE MAY ALSO CONSIDER INPUT OBTAINED FROM OTHER BOARD MEMBERS, STAFF AND PROFESSIONAL ADVISORS. ONCE A CONSENSUS IS REACHED REGARDING PERFORMANCE, A SIMILAR DISCUSSION IS HELD CONCERNING COMPENSATION AND ANNUAL BONUS RELATIVE TO ANNUAL BENCHMARK AND ESTABLISHED OBJECTIVES. ONCE THE COMMITTEE DECIDES ON AN APPROPRIATE COMPENSATION LEVEL AND BONUS THE COMMITTEE AND/OR BOARD CHAIR MEETS WITH THE EXECUTIVE DIRECTOR TO DISCUSS AND DOCUMENT STRENGTHS, WEAKNESSES AND GOALS FOR THE UPCOMING YEAR. COMPENSATION FOR THE UPCOMING YEAR IS ALSO DISCUSSED AND DOCUMENTED AND MAINTAINED ON FILE WITH THE HUMAN RESOURCES DEPARTMENT. COMPENSATION FOR OTHER OFFICERS AND KEY EMPLOYEES ARE ADMINISTERED BY THE EXECUTIVE DIRECTOR OR APPLICABLE DIRECT REPORT TO THE EXECUTIVE DIRECTOR ALONG WITH THE HUMAN RESOURCES DEPARTMENT SIMILAR TO THE PROCESS FOR EXECUTIVE COMPENSATION. CITY HARVEST PERFORMS AN ANNUAL REVIEW OF ITS NON-UNIONIZED EMPLOYEES. THE EXECUTIVE DIRECTOR WILL CONDUCT A WRITTEN PERFORMANCE APPRAISAL OF OTHER OFFICERS AND KEY EMPLOYEES WHICH WILL BE USED TO DETERMINE ELIGIBILITY FOR STAFF INCREASES. IN ADDITION, HUMAN RESOURCES PROVIDE SALARY SURVEYS AND OTHER INDEPENDENT BENCHMARK DATA TO ASCERTAIN IF STAFF COMPENSATION LEVELS ARE DEEMED APPROPRIATE. THE EXECUTIVE DIRECTOR MEETS WITH OTHER OFFICERS AND KEY EMPLOYEES TO DISCUSS PERFORMANCE AND COMPENSATION. COMPENSATION FOR THE UPCOMING YEAR IS ALSO DISCUSSED AND DOCUMENTED AND MAINTAINED ON FILE WITH THE HUMAN RESOURCE DEPARTMENT. form 990, part VI, section b, line 19 availability of documents to the public The organization makes its Form 990 available to the public by retaining a copy at its place of business. The Form 990 is likewise published on various third party websites such as the internet at www.guidestar.org, www.charitynavigator.org, www.ag.ny.gov and on the organization's webpage at www.cityharvest.org. The Form 1023 is not available on the organization's website, but will be made available upon request at the organization's head offices. The organization's financial statements, governing documents and conflict of interest policy are not ordinarily made available to the public, but, if requested, will be provided at management's discretion.