2015-05-13T13:26:55-07:00 2014-06-30 990 2013-07-01 042103638 WHEATON COLLEGE WHEA 5082868219 35 East Main Street Norton MA 02766 Dennis Hanno President 5082868208 2015-05-13 2013 2016-02-25 16:41:14Z Dennis M Hanno 35 East Main St Norton MA 02766 154410354 0 X www.wheatoncollege.edu X 1834 MA Wheaton College provides a transformative liberal arts education for intellectually curious students in a collaborative, academically vibrant residential community that values a diverse world. 36 34 1802 1350 425109 0 11836625 12345009 86910826 90928196 10628657 7349894 2757802 2635034 112133910 113258133 31800917 34354995 0 0 43384357 42782284 0 0 4691207 35005857 36498995 110191131 113636274 1942779 -378141 331044935 345894681 54537324 48906035 276507611 296988646 Wheaton College provides a transformative liberal arts education for intellectually curious students in a collaborative, academically vibrant residential community that values a diverse world. 0 0 103945927 34354995 92651965 Wheaton College (the "college") is a private, coeducational, liberal arts college located in Norton, Massachusetts and is accredited by the New England Association of Schools and Colleges. Founded as a Female Seminary in 1834 and chartered as a four-year college in 1912, the college became coeducational in 1988. The college provides academic, residential and other services to a diverse student population of approximately 1,660 drawn from schools predominately in the Northeast region of the United States, as well as from many other U.S. states and territories and approximately 40 foreign countries. The curriculum features more than 600 courses of study and 47 majors in the humanities, the social sciences, and the natural sciences. The college offers the Bachelor of Arts degree at the undergraduate level, and the Masters of Arts degree under special circumstances. 0 0 0 103945927 1 1 0 1 0 0 0 1 0 1 1 1 0 0 1 1 1 0 1 0 1 0 1 0 1 0 0 0 1 1 1 0 0 0 0 0 0 0 0 1 1 1 0 0 0 0 1 1 1 0 0 1 X 193 0 1 1802 1 1 1 0 0 0 0 1 1 0 0 0 0 X 36 34 0 0 0 0 0 0 0 1 1 0 0 0 1 1 1 1 1 1 1 0 MA X Meghan Kass 5082863440 35 East Main Street Norton MA 02766 Kenneth R Babby Trustee 2 0 X 0 0 0 Monique Lee Bahadur Trustee 2 0 X 0 0 0 Anson M Beard Jr Trustee 2 0 X 0 0 0 Roger Brown Trustee 2 0 X 0 0 0 Mary Bartlett Bryson Trustee 2 0 X 0 0 0 Wayne A Budd Trustee 2 0 X 0 0 0 Nancy Pearlstine Conger Trustee 2 0 X 0 0 0 Caroline Campbell Edwards Trustee 2 0 X 0 0 0 Debra Kent Glidden Trustee 2 0 X 0 0 0 Paul E Gray Trustee 2 0 X 0 0 0 Thomas J Hollister Trustee 2 0 X 0 0 0 Amanda Gray Idema Turstee 2 0 X 0 0 0 Wyneva Johnson Trustee 2 0 X 0 0 0 James B Karman Trustee 2 0 X 0 0 0 Janet L Kelly Trustee 2 0 X 0 0 0 Kirk D Kolenbrander Trustee 2 0 X 0 0 0 Janet Lindholm Lebovitz Trustee 2 0 X 0 0 0 S Catherine Longley Trustee 2 0 X 0 0 0 Adrienne Bevis Mars Trustee 2 0 X 0 0 0 Jane A Martin Trustee 2 0 X 0 0 0 Diane C Nordin Trustee 2 0 X 0 0 0 Christopher B Paquet Trustee 2 0 X 0 0 0 Keith J Peden Trustee 2 0 X 0 0 0 Mary Zygala Schleyer Trustee 2 0 X 0 0 0 Alison Grant Small Trustee 2 0 X 0 0 0 Brian R Smiley Trustee 2 0 X 0 0 0 Margaret Dunn Smith Trustee 2 0 X 0 0 0 Kerin E Stackpole Trustee 2 0 X 0 0 0 Matthew Strekel Trustee 2 0 X 0 0 0 John C Talanian Trustee 2 0 X 0 0 0 Cathy Ann Trower Trustee 2 0 X 0 0 0 Cheryl Vedoe Trustee 2 0 X 0 0 0 David L Wagner Trustee 2 0 X 0 0 0 Cornelia Clifford Wareham Trustee 2 0 X 0 0 0 John Hazen White Jr Trustee 2 0 X 0 0 0 Ronald A Crutcher President and ex officio Trustee 40 0 X X 368427 0 102677 Gail Berson Vice President Enrollment & Marketing 40 0 X 193686 0 32913 Mary Casey Vice President Advancement 40 0 X 233425 0 44388 Brian Douglas Vice President for Finance & Administration 40 0 X 241364 0 50900 Linda Eisenmann Provost 40 0 X 211186 0 38124 Ellen Hallett Secretary of the Board 40 0 X 93995 0 18269 Lee Williams Vice President Student Affairs & Dean of College 40 0 X 166115 0 39308 Philip Timothy Barker Professor of Astronomy 40 0 X 275512 0 10708 Grace Baron Professor of Psychology 40 0 X 200534 0 12213 Darlene Boroviak Professor of Political Science 40 0 X 306392 0 12719 George Cunard Professor of Art 40 0 X 200465 0 9877 Derek Price Professor of Psychology 40 0 X 203178 0 5442 Meghan Kass Controller & Assistant Treasurer 40 0 X 114353 0 34007 2808632 0 411545 54 1 1 0 Aramark 1101 Market Street Philadelphia PA 19107 Dining Services 5526428 RAD Corporation 171 VFW Drive Rockland MA 02370 Construction 2313405 Nauset Builders LLC PO Box 492 Dighton MA 02715 Construction 534093 LVW Advisors LLC 67 Monroe Avenue Pittsford NY 14534 Investment consultant 244621 Bernkopf Goodman LLP 2 Seaport Lane 9th Floor Boston MA 02210 Legal firm 171501 12 0 0 17430 0 513722 11813857 1394663 12345009 Tuition and fees 611310 73565266 73565266 0 0 Room & Board 611310 17261799 17261799 0 0 Education department services 611310 101131 101131 0 0 0 0 0 0 90928196 2076918 0 1524 2075394 287 0 0 287 0 0 0 0 249624 0 0 0 249624 0 249624 0 0 249624 46285892 0 41013203 0 5272689 0 5272689 0 0 5272689 25558 17430 139018 -113460 0 -113460 0 0 0 0 0 0 0 0 0 0 0 0 Dining services 721000 1181329 1181329 0 0 Telecommunications 517000 214333 0 0 214333 Conference & events 451211 536020 0 423585 112435 567188 542441 0 24747 2498870 113258133 92651966 425109 7836049 0 0 32409393 32409393 1945602 1945602 0 0 1988459 883325 642485 462649 261218 196790 64428 0 31304135 27758192 1461835 2084108 2447542 2169135 115441 162966 4475094 3917089 245687 312318 2305836 1989558 144120 172158 0 0 0 0 113388 0 113388 0 191000 0 191000 0 0 0 0 0 0 0 4320675 4147848 172827 0 6786021 6374923 137301 273797 251798 242551 9247 0 1134269 929193 22416 182660 748199 740462 6361 1376 0 0 0 0 3202074 3131348 70726 0 2190271 1893256 75859 221156 0 0 0 0 126627 103471 12326 10830 1724303 1724303 0 0 0 0 0 0 7533366 6794668 369349 369349 326373 0 326373 0 Program Support 2065758 2056828 330 8600 Equipment & Maintenance 2072722 1991673 3725 77324 Events, entertainment & food 1467469 603979 571143 292347 Library acquisition & subscriptions 1122262 954249 152838 15175 1122420 988091 89935 44394 113636274 103945927 4999140 4691207 2036770 4614368 11269715 9403464 7251191 9178820 1155179 1294982 0 0 0 0 3023193 2977178 0 0 2149829 1792556 187328231 80240436 111008901 107087795 85401414 102862955 101368500 102341348 0 0 0 0 6380243 4341215 331044935 345894681 6879892 5726791 0 0 0 0 39541304 34906802 0 0 0 0 0 0 0 0 8116128 8272442 54537324 48906035 X 119105020 123295097 66047984 75255284 91354607 98438265 276507611 296988646 331044935 345894681 -378141 20859176 0 0 0 0 X 0 1 X 1 1 1 X 12672635 16807039 12875896 11836625 12345009 66537204 0 0 0 0 0 0 0 0 0 0 0 0 12672635 16807039 12875896 11836625 12345009 66537204 9837829 56699375 2097151 2571373 2631969 2600102 2326829 12227424 55853 0 0 9397 1299 66549 1375252 263903 315603 532525 550538 3037821 81868998 427844128 0.69256 0.69634 X Schedule A, Part I, Line 7 The basis of Wheaton College's public charity status has been and continues to be its qualifications as a school described in Section 170(B)(1)(A)(II). The organization has checked box 7 on Schedule A, part 1 and completed Schedule A, part II in order to demonstrate its qualification to follow the special rule for abbreviated reporting of contributions on form 990, Schedule B. Schedule A, Part II, Line 10 The amount on line 10 includes conference and events revenue and telecommunications fees. RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 0 0 0 0 0 0 0 0 1 13822 13822 0 Schedule C, Part II-B, Line 1 The amount on line 1i reflects membership dues paid to member organizations, including NACUBO and AICUM, which may engage in lobbying activities in connection with issues that impact higher education. Therefore, a portion of the dues may be attributed to lobbying activities. The college does not directly participate in these lobbying activities. 0 554920 0 0 X X 0 176062312 2906160 27054403 3030224 5127326 4320675 193544650 159484340 4228827 23687566 2738162 4807064 3793195 176062312 164947509 3720273 488306 2912836 4834599 1924313 159484340 146689850 5485620 23529926 2673633 4631545 3452709 164947509 139758659 2327920 14921188 2677781 4587325 3052811 146689850 0.238 0.44 0.322 0 0 0 2252909 2252909 0 162376188 66409453 95966735 0 0 0 0 0 10075791 7303120 2772671 0 12623343 6527863 6095480 107087795 0 154500 Hedged equity - developed & emerging 27898596 F Real property & commodities 24699268 F Private equity 16833319 F Opportunistic credit 23817029 F Domestic & international equities 4972203 F Fixed Income 3530133 F Other 436300 F 102341348 0 Annuity obligation 3352631 Government advances for student loans 2509471 Asset retirement obligations 1313005 Student deposits 1097335 8272442 X 95925596 20859176 0 0 -33871038 -13011862 108937458 4320675 0 4320675 113258133 75444561 0 0 0 -33871038 -33871038 109315599 4320675 0 4320675 113636274 Schedule D, Part III, Line 4 The college's collection items include rare books, historical artifacts and art work that are used for scholarly research, public exhibitions and to document the history of the college. Schedule D, Part V, Line 4 The college's endowment funds provide income and support for the furtherance of the educational mission of the college in accordance with the donors' intentions. The majority of the permanent endowment is held for scholarship, teaching, and program expenses. Schedule D, Part X, Line 2 The college accounts for the effect of any uncertain tax positions based on a "more likely than not" threshold to the recognition of the tax positions being sustained based on the technical merits of the position under scrutiny by the applicable taxing authority. If a tax position or positions are deemed to result in uncertainties of those positions, the unrecognized tax benefit is estimated based on a "cumulative probability assessment" that aggregates the estimated tax liability for all uncertain tax positions. The college has identified its tax status as a tax exempt entity as its only significant tax position; however, the college has determined that such tax position does not result in an uncertainty requiring recognition. The college is not currently under examination by any taxing jurisdictions. The college's Federal and state tax returns are generally open for examination for three years following the date filed. Schedule D, Part XI, Line 2d Scholarship and grants provided to students of $34,010,056 is presented as a contra-revenue item in the audited financial statements and as an expense item in the Form 990. Fundraising event expenses of $139,018 are shown as an expense in the audited financial statements and as a contra-revenue item on the Form 990. Schedule D, Part XII, Line 2d Scholarship and grants provided to students of $34,010,056 is presented as a contra-revenue item in the audited financial statements and as an expense item in the Form 990. Fundraising event expenses of $139,018 are shown as an expense in the audited financial statements and as a contra-revenue item on the Form 990. 1 1 0 1 1 1 1 0 0 0 0 0 0 0 0 1 0 1 Schedule E, Part I, Line 2 Wheaton College is committed to the principles of Equal Opportunity as defined under federal and state law. The college's Notice of Nondiscrimination is available on its website at http://wheatoncollege.edu/policies/eqopp.html and referenced on its Admission webpages. Schedule E, Part I, Line 3 Wheaton College customarily draws a substantial percentage of its students from the Northeast region of the United States, as well as from many other U.S. states and territories and approximately 40 foreign countries. The College follows a racially nondiscriminatory policy as to its students and enrolls students of racial minority groups in meaningful numbers. Schedule E, Part I, Line 6 Students receive financial aid from state and federal agencies based on predetermined financial and scholastic guidelines consistent with the college's educational mission. 1 Central America and the Caribbean 0 1 Program Services Study abroad 24523 Central America and the Caribbean 0 0 Grantmaking 7050 East Asia and the Pacific 0 1 Program Services Study abroad 425525 East Asia and the Pacific 0 0 Grantmaking 293602 East Asia and the Pacific 0 1 Program Services Admissions 16875 East Asia and the Pacific 0 1 Program Services Telescope site 2724 East Asia and the Pacific 0 1 Program Services Faculty research 506 Europe (including Iceland and Greenland) 0 3 Program Services Study abroad 1706839 Europe (including Iceland and Greenland) 0 0 Grantmaking 1172740 Europe (including Iceland and Greenland) 0 3 Fundraising 8726 Europe (including Iceland and Greenland) 0 2 Program Services Admissions 829 Europe (including Iceland and Greenland) 0 0 Program Services Library & IT 32234 Europe (including Iceland and Greenland) 0 0 Program Services Athletics 3752 Europe (including Iceland and Greenland) 0 9 Program Services Faculty research 15924 Middle East and North Africa 0 0 Program Services Study abroad 55359 Middle East and North Africa 0 0 Grantmaking 46500 Middle East and North Africa 0 1 Program Services Admissions 4956 Middle East and North Africa 0 0 Program Services Faculty research 1903 Russia and the newly independent States 0 0 Program Services Study abroad 43460 Russia and the newly independent States 0 0 Grantmaking 8750 South America 0 0 Program Services Study abroad 102588 South America 0 0 Grantmaking 73530 South America 0 1 Program Services Admissions 2906 South Asia 0 1 Program Services Study abroad 401815 South Asia 0 0 Grantmaking 246990 South Asia 0 1 Fundraising 1896 South Asia 0 2 Program Services Admissions 3091 South Asia 0 2 Program Services Faculty research 4468 Sub-Saharan Africa 0 1 Program Services Study abroad 105946 Sub-Saharan Africa 0 0 Grantmaking 96440 Sub-Saharan Africa 0 2 Program Services Faculty research 20088 Central America and the Caribbean 0 0 Investments 45835109 0 33 50767644 Scholarship to students Central America and the Caribbean 1 0 7050 Tuition offset Scholarship to students East Asia and the Pacific 22 0 293602 Tuition offset Scholarship to students Europe (including Iceland and Greenland) 103 0 1172740 Tuition offset Scholarship to students Middle East and North Africa 4 0 46500 Tuition offset Scholarship to students Russia and the newly independent States 2 0 8750 Tuition offset Scholarship to students South America 5 0 73530 Tuition offset Scholarship to students South Asia 23 0 246990 Tuition offset Scholarship to students Sub-Saharan Africa 6 0 96440 Tuition offset 1 0 1 1 1 0 Schedule F, Part I, Line 2 The college is committed to making study abroad programs available to as wide a range of students as possible. As a result the number of Wheaton students who study abroad is consistently high. Students pay the college its comprehensive fee with offsetting scholarships provided in accordance with standard college financial aid policies and procedures. The college pays foreign schools to provide teaching and accommodations. Schedule F, Part I, Line 3 The study abroad programs are separately tracked in the college's general ledger system by activity and the amounts represent tuition payments, lodging, travel costs and incidentals for students and faculty liaisons. The admissions recruiting, fundraising and faculty research amounts are tracked primarily using the college's credit card system and represent travel, meals and lodging costs for college employees conducting business in these regions. All expenses are under the accrual method of accounting. Golf Tournament 28120 13395 14725 0 0 10952 0 0 6062 City Seminar Series 14868 4035 10833 0 0 122004 0 0 0 0 42988 17430 25558 0 0 132956 0 0 6062 139018 -113460 1 Scholarship to students 1404 0 32064454 Reduction of student balance for tuition owed to the college Fellowship stipend 129 344939 0 Fellowship stipend Schedule I, Part I, Line 2 The college's Office of Financial aid is responsible for awarding and monitoring all college, federal and state grant assistance. More than 60% of Wheaton students receive some form of financial aid and most students who demonstrate need receive aid. Financial assistance at Wheaton is awarded on the basis of demonstrated need and academic performance. "Need" is determined by the financial information that a student and his/her family provides on the Free Application for Federal Student Aid (FAFSA) and PROFILE forms which capture the data required to determine eligibility based on federal and/or state regulations. A need-based package may include a merit scholarship, grants, loans or work award. When funds are awarded, student eligibility is monitored through the college's operational system financial aid module to ensure there are no changes in status that might affect their ongoing eligibility. Total grant funds awarded are tracked to ensure compliance with budgeted amounts. X X X 1 1 X X X X 1 0 0 0 0 0 0 1 0 Philip Timothy Barker Professor of Astronomy 68117 0 10000 0 197395 0 6263 0 4445 0 286220 0 0 0 Grace Baron Professor of Psychology 42358 0 0 0 158176 0 4143 0 8070 0 212747 0 0 0 Gail Berson Vice President Enrollment & Marketing 193326 0 0 0 360 0 17663 0 15250 0 226599 0 0 0 Darlene Boroviak Professor of Political Science 78939 0 10000 0 217453 0 7223 0 5496 0 319111 0 0 0 Mary Casey Vice President Advancement 213425 0 20000 0 0 0 20036 0 24352 0 277813 0 0 0 Ronald A Crutcher President and ex officio Trustee 356783 0 0 0 11644 0 47170 0 55507 0 471104 0 0 0 George Cunard Professor of Art 49035 0 0 0 151430 0 4531 0 5346 0 210342 0 0 0 Brian Douglas Vice President for Finance & Administration 221334 0 15000 0 5030 0 20925 0 29975 0 292264 0 0 0 Linda Eisenmann Provost 206961 0 0 0 4225 0 18673 0 19451 0 249310 0 0 0 Meghan Kass Controller & Assistant Treasurer 110853 0 3500 0 0 0 11126 0 22881 0 148360 0 0 0 Derek Price Professor of Psychology 50499 0 0 0 152679 0 4569 0 873 0 208620 0 0 0 Lee Williams Vice President Student Affairs & Dean of College 162819 0 0 0 3296 0 14891 0 24417 0 205423 0 0 0 Schedule J, Part I, Line 1a The President, Provost and Dean of Students are provided with housing, including maintenance of such space, for the convenience of the employer on the college's premises. The value of the personal space within the housing is included as a nontaxable benefit on Schedule J. The value of the maintenance of the personal space is taxed accordingly. The President is provided with a college vehicle for business use and any personal miles are taxed accordingly. In addition, the President is a member of a local country club and local social clubs for which the college is responsible for the payment of dues. Any personal use of such clubs is reimbursed to the college. Schedule J, Part I, Line 3 The Wheaton College Executive Committee, an independent board, establishes compensation to ensure that the Internal Revenue Code provision of "rebuttable presumption of reasonableness" is met and "intermediate sanctions" are not incurred. The Executive Committee obtains and relies upon appropriate data regarding comparability of the compensation package prior to making its determination. Appropriate data includes compensation levels paid by similarly situated organizations, independent compensation surveys by nationally recognized independent firms, and written offers from similar institutions competing for the services of the individual. The Executive Committee documents the basis for its determinations including: the terms of the approved transaction and date approved; the members of the committee who were present during the discussion; and the data obtained and relied upon. Schedule J, Part I, Line 4 Darlene Boroviak, Grace Baron, Derek Price, Timothy Barker and George Cunard received $216,729, $157,848, $152,283, $196,770 and $151,041, respectively, as a result of their separation from the college on June 30, 2013 as part of a faculty retirement program. Gail Berson, Vice President for Enrollment and Marketing, received a payment of $198,196 as a result of her separation from the college on June 30, 2014. Schedule J, Part I, Line 7 Timothy Barker and Darlene Boroviak received a $10,000 bonus in lieu of taking a regular sabbatical leave during the 2012-13 academic year under the faculty retirement incentive plan. The Vice President for Advancement, the Vice President for Finance and Administration, the Secretary of the Board, and the Controller and Assistant Treasurer received a performance related bonus of $20,000, $15,000, $1,000 and $3,500, respectively. A Massachusetts Health and Educational Facilities Authority 042456011 57586CCH6 2004-04-28 18369960 Refunding of Series C, campus renovations 1 0 0 B Massachusetts Health and Educational Facilities Authority 042456011 57586EUF6 2010-05-04 32361170 Construction of academic facilities 0 0 0 C Massachusetts Development Finance Agency 043431814 000000000 2014-04-11 13203807 Refunding of 2004 Series E Bonds and renovation of dining facilities 0 0 0 A 0 0 18369960 0 0 14861557 336096 0 0 3172307 0 0 2005 1 0 1 1 B 0 0 32361170 0 1412008 0 448729 0 0 30500433 0 0 2011 0 0 1 1 C 0 0 13203807 0 0 7064922 138885 0 0 0 0 6000000 1 0 0 1 A 0 1 0 0 0 0.02 0.02 0 0 1 B 0 0 0 0 0.001 0.0148 0.0158 0 0 1 C 0 1 0 0 0 0 0 0 0 1 A 0 0 0 1 0 0 0 0 1 B 0 0 0 1 0 0 0 0 1 C 0 0 0 1 0 0 0 0 1 A 1 B 1 C 1 Schedule K, Part IV, Line 2c-04/28/2004 18,369,960 Massachusetts Health and Educational Facilities A The computations were performed for the June 30, 2014 computation date. Schedule K, Part IV, Line 2c-05/04/2010 32,361,170 Massachusetts Health and Educational Facilities A The computations were performed for the June 30, 2014 computation date. Schedule K, Part IV, Line 2c-04/11/2014 13,203,807 Massachusetts Development Finance Agency The computations were performed for the June 30, 2014 computation date. Global Partners LP Trustee is COO & CFO 760702 Fixed rate energy contract 0 Jay Goodman Spouse of officer 196790 Employment 0 Betty Neal Crutcher Spouse of officer 64428 Employment 0 Schedule L, Part I, Line 1 All employees, including employees who may meet the definition of an interested person, are hired through procedures administered by the college's Human Resources Department under applicable college policies. All such employees are provided the same benefits, and are subject to the same policies and procedures, as other college employees. All business transactions, including those with individuals or companies that may meet the definition of an interested party, are made within the normal course of business and are conducted at arm's length. Purchasing decisions are not made by these individuals. X 105 1075913 fair market value X 1 318750 fair market value 0 0 1 0 Schedule M, Part I, Line 9 The college is disclosing the number of contributions of publicly traded securities. These contributions may be comprised of one or more securities. Schedule M, Part I, Line 15 The college is disclosing the contribution of a house located in Florida. Form 990, Part V, Line 2a The total number of employees includes faculty and staff of 667 and student employees of 1,135. Form 990, Part VI, Section B, Line 11b The college's Form 990 is prepared by the Finance Office of the college and reviewed by the Vice President for Finance and Administration. In addition, the Form 990 is reviewed and signed by an independent accounting firm. The first draft is reviewed by the Audit Committee of the Board of Trustees and any changes are incorporated into the final draft. The final draft is distributed to the full Board of Trustees via their secure website for final review prior to submission to the IRS. The draft provided to the Audit Committee of the Board of Trustees and to the full Board agrees to what was filed with the IRS with the exception of Schedule B, which was omitted. Form 990, Part VI, Section B, Line 12c All trustees and officers of the college are covered in the Wheaton College Conflict of Interest Policy for Trustees and Officers. The policy and conflict of interest disclosure statement is sent to all officers and trustees on an annual basis. The completed forms are reviewed by the Chair of the Board of Trustees, the Vice President for Finance and Administration and the President, who determine if an actual or potential conflict exists. Officers and trustees recuse themselves from discussion and voting on any matters where a conflict exists. Form 990, Part VI, Section B, Line 15 The Wheaton College Executive Committee, an independent board, establishes compensation to ensure that the Internal Revenue Code provision of "rebuttable presumption of reasonableness" is met and "intermediate sanctions" are not incurred. The Executive Committee obtains and relies upon appropriate data regarding comparability of the compensation package prior to making its determination. Appropriate data includes compensation levels paid by similarly situated organizations, independent compensation surveys by nationally recognized independent firms, and written offers from similar institutions competing for the services of the individual. The Executive Committee documents the basis for its determinations including: the terms of the approved transaction and date approved; the members of the committee who were present during the discussions; and the data obtained and relied upon. Form 990, Part VI, Section C, Line 19 The employee conflict of interest policy is contained in the Staff Handbook, which is posted to the college's Human Resources website and available to the public. The college's audited financial statements are posted to the college's Finance website, which is available to the public. In addition, the Form 990 and the audited financials are available via the Massachusetts Attorney General's website. The governing documents and trustee conflicts of interest policy are available to the public upon request. Pooled Income Fund 35 East Main Street Norton MA 02766 Pooled Income Fund MA N/A T 1 Perpetual Trust 35 East Main St Norton MA 02766 Perpetual Trust MA N/A T 1 Charitable Remainder Unitrust 35 East Main St Norton MA 02766 Charitable Remainder Trust MA N/A T 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Perpetual Trust a-i 0