Department of the Treasury Internal Revenue Service
Public Charity Status and Public Support
Complete if the organization is a section 501(c)(3) organization or a section
4947(a)(1) nonexempt charitable trust.
Attach to Form 990 or Form 990-EZ. See separate instructions.
OMB No. 1545-0047
2010
Open to Public Inspection
Name of the organization
GEORGETOWN UNIVERSITY
Employer identification number
53-0196603
Part I
Reason for Public Charity Status
(All organizations must complete this part.) See instructions
The organization is not a private foundation because it is: (For lines 1 through 11, check only one box.)
1
2
3
4
5
section 170(b)(1)(A)(iv). (Complete Part II.)
6
7
8
9
receipts from activities related to its exempt functions—subject to certain exceptions, and (2) no more than 331/3% of
its support from gross investment income and unrelated business taxable income (less section 511 tax) from businesses
acquired by the organization after June 30, 1975. See section 509(a)(2). (Complete Part III.)
10
11
e
By checking this box, I certify that the organization is not controlled directly or indirectly by one or more disqualified persons other than foundation managers and other than one or more publicly supported organizations described in section 509(a)(1) or section 509(a)(2).
f
If the organization received a written determination from the IRS that it is a Type I, Type II or Type III supporting organization, check this box
..................................................
g
Since August 17, 2006, has the organization accepted any gift or contribution from any of the following persons?
(i) a person who directly or indirectly controls, either alone or together with persons described in (ii)
Yes
No
and (iii) below, the governing body of the the supported organization?
................
11g(i)
(ii)
a family member of a person described in (i) above?
......................
11g(ii)
(iii)
a 35% controlled entity of a person described in (i) or (ii) above?
................
11g(iii)
h
Provide the following information about the supported organization(s).
(i) Name of supported organization
(ii) EIN
(iii) Type of organization (described on lines 1- 9 above or IRC section (see instructions))
(iv) Is the organization in col. (i) listed in your governing document?
(v) Did you notify the organization in col. (i) of your support?
(vi) Is the organization in col. (i) organized in the U.S.?
(vii) Amount of support?
Yes
No
Yes
No
Yes
No
Total
For Paperwork Reduction Act Notice, see the Instructions for Form 990.
Cat. No. 11285F
Schedule A (Form 990 or 990-EZ) 2010
Schedule A (Form 990 or 990-EZ) 2010
Page 2
Part II
Support Schedule for Organizations Described in IRC 170(b)(1)(A)(iv) and 170(b)(1)(A)(vi) (Complete only if you checked the box on line 5, 7, or 8 of Part I or if the
organization failed to qualify under Part III. If the organization fails to
qualify under the tests listed below, please complete Part III.)
Section A. Public Support
Calendar year(or fiscal year beginning in)
(a) 2006
(b) 2007
(c) 2008
(d) 2009
(e) 2010
(f) Total
1
Gifts, grants, contributions, and membership fees received. (Do not include any "unusual grants.") ....
2
Tax revenues levied for the organization's benefit and either paid to or expended on its behalf.......
3
The value of services or facilities furnished by a governmental unit to the organization without charge..
4
Total. Add lines 1 through 3..
5
The portion of total contributions by each person (other than a governmental unit or publicly supported organization) included
on line 1 that exceeds 2% of the amount shown on line 11, column (f)..
6
Public Support. Subtract line 5 from line 4.
Section B. Total Support
Calendar year(or fiscal year beginning in)
(a) 2006
(b) 2007
(c) 2008
(d) 2009
(e) 2010
(f) Total
7
Amounts from line 4..
8
Gross income from interest, dividends, payments received on securities loans, rents, royalties and income from similar sources..
9
Net income from unrelated business activities, whether or not the business is regularly carried on..
10
Other income. (Explain in Part IV.) Do not include gain or loss from the sale of capital assets..
11
Total support (Add lines 7 through 10).
12
Gross receipts from related activities, etc. (See instructions.)
..................
12
13
First Five Years
If the Form 990 is for the organization's first, second, third, fourth, or fifth tax year as a 501(c)(3) organization,
check this box and stop here..........................................
Section C. Computation of Public Support Percentage
14
Public Support Percentage for 2010 (line 6 column (f) divided by line 11 column (f))
.........
14
15
Public Support Percentage for 2009 Schedule A, Part II, line 14
...............
15
16a
33 1/3% support test—2010.
If the organization did not check the box on line 13, and line 14 is 33 1/3% or more, check this box
and stop here. The organization qualifies as a publicly supported organization
......................
b
33 1/3% support test—2009.
If the organization did not check the box on line 13 or 16a, and line 15 is 33 1/3% or more, check this
box and stop here. The organization qualifies as a publicly supported organization
.....................
17a
10%-facts-and-circumstances test—2010.
If the organization did not check a box on line 13, 16a, or 16b and line 14
is 10% or more, and if the organization meets the "facts and circumstances" test, check this box and stop here. Explain
in Part IV how the organization meets the "facts and circumstances" test. The organization qualifies as a publicly supported
organization
..................................................
b
10%-facts-and-circumstances test—2009.
If the organization did not check a box on line 13, 16a, 16b, or 17a and line
15 is 10% or more, and if the organization meets the "facts and circumstances" test, check this box and stop here.
Explain in Part IV how the organization meets the "facts and circumstances" test. The organization qualifies as a publicly supported organization
..............................................
18
Private Foundation
If the organization did not check a box on line 13, 16a, 16b, 17a or 17b, check this box and see
instructions
...................................................
Schedule A (Form 990 or 990-EZ) 2010
Schedule A (Form 990 or 990-EZ) 2010
Page 3
Part III
Support Schedule for Organizations Described in IRC 509(a)(2) (Complete only if you checked the box on line 9 of Part I or if the organization
failed to qualify under Part II. If the organization fails to qualify under
the tests listed below, please complete Part II.)
Section A. Public Support
Calendar year(or fiscal year beginning in)
(a) 2006
(b) 2007
(c) 2008
(d) 2009
(e) 2010
(f) Total
1
Gifts, grants, contributions, and membership fees received. (Do not include any "unusual grants.") .
2
Gross receipts from admissions, merchandise sold or services performed, or facilities furnished in any activity that is related to the organization's tax-exempt purpose......
3
Gross receipts from activities that are not an unrelated trade or business under section 513..
4
Tax revenues levied for the organization's benefit and either paid to or expended on its behalf...
5
The value of services or facilities furnished by a governmental unit to the organization without charge..
6
Total. Add lines 1 through 5.
7a
Amounts included on lines 1, 2, and 3 received from disqualified persons...
b
Amounts included on lines 2 and 3 received from other than disqualified persons that exceed the greater of $5,000 or 1% of the amount on line 13 for the year.
c
Add lines 7a and 7b..
8
Public Support (Subtract line 7c from line 6.)
Section B. Total Support
Calendar year (or fiscal year beginning in)
(a) 2006
(b) 2007
(c) 2008
(d) 2009
(e) 2010
(f) Total
9
Amounts from line 6...
10a
Gross income from interest, dividends, payments received on securities loans, rents, royalties and income from similar sources..
b
Unrelated business taxable income (less section 511 taxes) from businesses acquired after June 30, 1975.
c
Add lines 10a and 10b.
11
Net income from unrelated business activities not included in line 10b, whether or not the business is regularly carried on.
12
Other income. Do not include gain or loss from the sale of capital assets (Explain in Part IV.)
13
Total support (Add lines 9, 10c, 11 and 12.).
14
First Five Years
If the Form 990 is for the organization's first, second, third, fourth, or fifth tax year as a 501(c)(3) organization,
check this box and stop here.............................................
Section C. Computation of Public Support Percentage
15
Public Support Percentage for 2010 (line 8 column (f) divided by line 13 column (f))
.........
15
16
Public support percentage from 2009 Schedule A, Part III, line 15
...............
16
Section D. Computation of Investment Income Percentage
17
Investment income percentage for 2010 (line 10c column (f) divided by line 13 column (f))
......
17
18
Investment income percentage from 2009 Schedule A, Part III, line 17
.............
18
19a
33 1/3% support tests—2010.
If the organization did not check the box on line 14, and line 15 is more than 33 1/3% and line 17 is not more than 33 1/3%, check this box and stop here. The organization qualifies as a publicly supported organization
..........
b
33 1/3% support tests—2009.
If the organization did not check a box on line 14 or line 19a, and line 16 is more than 33 1/3% and line 18 is not more than 33 1/3%, check this box and stop here. The organization qualifies as a publicly supported organization
....
20
Private Foundation
If the organization did not check a box on line 14, 19a or 19b, check this box and see instructions
.....
Schedule A (Form 990 or 990-EZ) 2010
Schedule A (Form 990 or 990-EZ) 2010
Page 4
Part IV
Supplemental Information.
Supplemental Information. Complete this part to provide the explanation required by Part II, line 10; Part II, line 17a or 17b; or Part III, line 12. Also complete this part for any additional information. (See instructions).
Facts And Circumstances Test
Explanation
Schedule A (Form 990 or 990-EZ) 2010
Additional Data
Software ID:
Software Version:
-
TIN:
SCHEDULE E(Form 990 or 990-EZ) Department of the TreasuryInternal Revenue Service
SchoolsComplete if the organization answered "Yes" to Form 990, Part IV, line 13, or Form 990-EZ, Part VI, line 48. Attach to Form 990 or Form 990-EZ.
OMB No. 1545-0047
2010
Open to Public Inspection
Name of the organization
GEORGETOWN UNIVERSITY
Employer identification number
53-0196603
Part I
YES
NO
1
Does the organization have a racially nondiscriminatory policy toward students by statement in its charter, bylaws,
other governing instrument, or in a resolution of its governing body?
......................
1
Yes
2
Does the organization include a statement of its racially nondiscriminatory policy toward students in all its
brochures, catalogues, and other written communications with the public dealing with student admissions,
programs, and scholarships?
......................................
2
Yes
3
Has the organization publicized its racially nondiscriminatory policy through newspaper or broadcast media during
the period of solicitation for students, or during the registration period if it has no solicitation program, in a way
that makes the policy known to all parts of the general community it serves? If "Yes," please describe. If "No,"
please explain. If you need more space use Part II.
.............................
3
Yes
4
Does the organization maintain the following?
a
Records indicating the racial composition of the student body, faculty, and administrative staff?
..........
4a
Yes
b
Records documenting that scholarships and other financial assistance are awarded on a racially nondiscriminatory
Other extracurricular activities?
.....................................
5h
No
If you answered "Yes" to any of the above, please explain. If you need more space, use Part II.
6a
Does the organization receive any financial aid or assistance from a governmental agency?
............
6a
Yes
b
Has the organization's right to such aid ever been revoked or suspended?
...................
6b
No
If you answered "Yes" to either line 6a or line 6b, explain on Part II.
7
Does the organization certify that it has complied with the applicable requirements of sections 4.01 through 4.05
of Rev. Proc. 75-50, 1975-2 C.B. 587, covering racial nondiscrimination? If "No," explain on Part II.
7
Yes
Paperwork Reduction Act Notice, see the Instructions for Form 990.
Cat. No. 50085D
Schedule E (Form 990 or 990-EZ) 2010
Schedule E (Form 990 or 990EZ) 2010
Page 2
Part II
Supplemental Information
Complete this part to provide the explanations required by Part I, lines 3, 4d, 5h, 6b, and 7, as applicable. Also complete this part to provide any other additional information (see instructions).
Identifier
Return Reference
Explanation
SCHEDULE E, PART 1, LINE 3:
UNIVERSITY ADVERTISEMENTS, BROCHURES, CATALOGUES AND WRITTEN UNIVERSITY ADVERTISEMENTS, BROCHURES, CATALOGUES AND WRITTEN COMMUNICATIONS STATE THAT GEORGETOWN UNIVERSITY PROVIDES EQUAL OPPORTUNITIES IN EMPLOYMENT AND EDUCATION WITHOUT REGARD TO, AND DOES NOT DISCRIMINATE ON THE BASIS OF, AGE, COLOR, DISABILITY, FAMILY RESPONSIBILITIES, FAMILIAL STATUS, GENDER IDENTITY OR EXPRESSION, MARITAL STATUS, NATIONAL ORIGIN, PERSONAL APPEARANCE, POLITICAL AFFILIATION, RACE, RELIGION, SEX, SEXUAL ORIENTATION, SOURCE OF INCOME OR ANY OTHER FACTOR PROHIBITED BY LAW. THESE NON-DISCRIMINATION POLICIES ALSO ARE POSTED ON THE UNIVERSITY'S WEBSITE.
SCHEDULE E, PART 1, LINE 6A:
GEORGETOWN UNIVERSITY RECEIVES FINANCIAL ASSISTANCE FOR THE FOLLOWING FEDERAL PROGRAMS: FEDERAL PERKINS LOAN, FEDERAL SUPPLEMENTAL OPPORTUNITY GRANT, FEDERAL WORK STUDY, PELL GRANTS, STAFFORD LOANS, PARENTS PLUS LOANS, GRADUATE STUDENTS, GRADPLUS LOANS, NURSING LOANS and PRIMARY CARE LOANS.
Schedule E (Form 990 or 990-EZ) 2010
Additional Data
Software ID:
Software Version:
-
TIN:
SCHEDULE O (Form 990 or 990-EZ)
Department of the Treasury Internal Revenue Service
Supplemental Information to Form 990 or 990-EZ
Complete to provide information for responses to specific questions on
Form 990 or to provide any additional information.
Attach to Form 990 or 990-EZ.
OMB No. 1545-0047
2010
Open to Public Inspection
Name of the organization
GEORGETOWN UNIVERSITY
Employer identification number
53-0196603
Identifier
Return Reference
Explanation
FORM 990, PART III, LINE 4D:
PUBLIC SERVICE: PRIMARILY THROUGH THE RECEIPT OF GOVERNMENT AND PRIVATE GRANTS AND CONTRACTS, GEORGETOWN UNIVERSITY IS ABLE TO PROVIDE COMMUNITY SERVICE PROGRAMS AND NON INSTRUCTIONAL SERVICES BENEFICIAL TO INDIVIDUALS AND GROUPS EXTERNAL TO THE UNIVERSITY.
FORM 990, PART V, LINE 4B:
DURING THE 2010 CALENDAR YEAR, GEORGETOWN UNIVERSITY REPORTED FOREIGN BANK ACCOUNTS ON FORM TD F 90-22.1 IN THE FOLLOWING COUNTRIES: -DOMINICAN REPUBLIC -EGYPT -EL SALVADOR -FRANCE -GERMANY -GUATEMALA -HAITI -HONDURAS -ITALY -MEXICO -NICARAGUA -QATAR -SPAIN -TURKEY -UNITED KINGDOM
FORM 990, PART VI, SECTION A, LINE 1:
THE BYLAWS OF GEORGETOWN UNIVERSITY PROVIDE FOR AN EXECUTIVE COMMITTEE OF THE BOARD OF DIRECTORS, WHICH IS AUTHORIZED "TO TAKE ALL ACTION WHICH THE DIRECTORS ARE AUTHORIZED TO TAKE," EXCEPT THAT THAT THE COMMITTEE MAY NOT (1) REMOVE OR ELECT THE PRESIDENT; AND (2) THE CONCURRENCE OF THE BOARD ITSELF SHALL BE NECESSARY WITH REGARD TO MATTERS PLACED UNDER THE DIRECT SUPERVISION OF THE BOARD UNDER THE BYLAWS. THE MEMBERS OF THE EXECUTIVE COMMITTEE ARE NOMINATED BY THE CHAIRMAN OF THE BOARD, AND ARE ELECTED BY THE BOARD FOR ONE-YEAR TERMS. ONLY DIRECTORS MAY SERVE ON THE EXECUTIVE COMMITTEE. THE MEMBERS OF THE EXECUTIVE COMMITTEE AS OF JUNE 30, 2011 WERE: - PAUL TAGLIABUE, CHAIR - BRADLEY M. SCHAEFFER, S.J., VICE CHAIR - WILLIAM R. BERKLEY - JOHN J. DEGIOIA - JOHN K. DELANEY - WILLIAM J. DOYLE - PHILIP A. MARINEAU - BRIAN O. MCDERMOTT, S.J. - TIMOTHY J. O'NEILL - JEANNE W. RUESCH
FORM 990, PART VI, SECTION A, LINE 5:
IN LATE 2010 THE UNIVERSITY BECAME AWARE OF A POSSIBLE DIVERSION OF ITS ASSETS IN CONNECTION WITH A CONFERENCE MANAGED BY THE UNIVERSITY AND SPONSORED BY THE UNIVERSITY AND OTHERS. THE UNIVERSITY'S INTERNAL AUDITORS PROMPTLY PERFORMED AN INTERNAL INVESTIGATION, COMPLETED IN JANUARY 2011, WHICH FOUND THAT, IN ADMINISTERING THIS CONFERENCE, AN ADMINISTRATOR INVOLVED IN THE OPERATION OF THE CONFERENCE HAD COMPENSATED HIM- OR HERSELF APPROXIMATELY $390,000 FOR WORK RELATING TO THE CONFERENCE FROM 2007 TO 2010. AS A RESULT OF THE INTERNAL INVESTIGATION, THE UNIVERSITY ALSO BECAME AWARE OF A PREVIOUSLY UNKNOWN BANK ACCOUNT OVER WHICH THE ADMINISTRATOR HAD SIGNATURE AUTHORITY THAT WAS SUBSEQUENTLY DETERMINED TO BE IN VIOLATION OF UNIVERSITY POLICY AND THAT WAS USED TO PAY EXPENSES RELATING TO THE CONFERENCE. THE ADMINISTRATOR DEPOSITED CONFERENCE DONATIONS INTO THE ACCOUNT AND PAID CONFERENCE EXPENSES, WHICH INCLUDED, WITHOUT THE KNOWLEDGE OF THE UNIVERSITY, THE UNAPPROVED COMPENSATION SET FORTH ABOVE. IN THE COURSE OF THE INTERNAL INVESTIGATION, THE UNIVERSITY'S INTERNAL AUDITORS ALSO LEARNED THAT AN AGGREGATE OF $14,500 IN SPOUSAL TRAVEL EXPENSES RELATING TO THE CONFERENCE WERE PAID IN ERROR ON BEHALF OF A UNIVERSITY EMPLOYEE FROM 2008 TO 2010. IMMEDIATELY UPON DISCOVERING THE EXISTENCE OF THE BANK ACCOUNT, THE UNIVERSITY CLOSED THE ACCOUNT AND TRANSFERRED THE REMAINING BALANCE TO A BANK ACCOUNT CONTROLLED AND AUDITED BY THE UNIVERSITY WHERE ANY DEPOSIT OF REVENUES AND ANY SPENDING WOULD TAKE PLACE UNDER UNIVERSITY POLICY AND SUBJECT TO UNIVERSITY INTERNAL CONTROLS. THE UNIVERSITY ENTERED INTO A RESTITUTION AGREEMENT WITH THE ADMINISTRATOR TO REPAY THE UNAPPROVED COMPENSATION RECEIVED IN 2010 (PLUS INTEREST), AND HAS RECEIVED FULL REIMBURSEMENT OF THE SPOUSAL TRAVEL COSTS PAID IN ERROR. THE UNIVERSITY HAS ALSO FOLLOWED INTERNAL PROCEDURES FOR DISCIPLINING THE PARTIES INVOLVED. FINALLY, THE UNIVERSITY HAS ENDED ITS SPONSORSHIP OF THE CONFERENCE AND WILL HAVE NO FINANCIAL INVOLVEMENT IN THE CONFERENCE GOING FORWARD. THE UNAPPROVED COMPENSATION AND SPOUSAL TRAVEL EXPENSES REPRESENT, IN THE AGGREGATE, LESS THAN 0.04% OF THE ORGANIZATION'S TOTAL OPERATING REVENUE FOR THE TAX YEAR AND LESS THAN 0.02% OF THE ORGANIZATION'S TOTAL ASSETS AS OF THE END OF THE TAX YEAR, AND, ACCORDINGLY, ARE NOT MATERIAL FOR FINANCIAL REPORTING PURPOSES. BECAUSE THE AGGREGATE AMOUNT EXCEEDS $250,000, IT IS CONSIDERED SIGNIFICANT FOR PURPOSES OF THE FORM 990.
FORM 990, PART VI, SECTION A, LINE 6:
THE UNIVERSITY IS ORGANIZED AS A NONSTOCK CORPORATION (THE "CORPORATION"). THE CORPORATION CONSISTS OF FIVE MEMBERS, WHO MEET ANNUALLY. JOHN J. DEGIOIA, PRESIDENT OF THE UNIVERSITY, IS AN EX-OFFICIO MEMBER OF THE CORPORATION. THE OTHER MEMBERS OF THE CORPORATION ARE ELECTED FOR THREE-YEAR TERMS; THEIR TERMS ARE STAGGERED, SO THAT EACH YEAR ONE OR MORE MEMBERS IS ELECTED. AT ANY TIME THAT A VACANCY EXISTS, THE REMAINING MEMBERS, BY A MAJORITY VOTE AT A REGULAR OR SPECIAL MEETING, MAY ELECT A SUCCESSOR TO FILL THE VACANCY.
FORM 990, PART VI, SECTION B, LINE 11B:
THE GEORGETOWN UNIVERSITY FORM 990 IS REVIEWED INTERNALLY BY SENIOR MANAGEMENT AND EXTERNALLY BY AN INDEPENDENT TAX SERVICE FIRM, PRICEWATERHOUSECOOPERS LLP, AFTER WHICH IT IS SUBMITTED BY THE CHIEF FINANCIAL OFFICER AND GENERAL COUNSEL TO THE AUDIT COMMITTEE OF THE UNIVERSITY'S BOARD OF DIRECTORS FOR REVIEW. THE FINAL FORM 990 IS SENT TO EACH BOARD MEMBER BEFORE FILING WITH THE INTERNAL REVENUE SERVICE.
FORM 990, PART VI, SECTION B, LINE 12C:
GEORGETOWN UNIVERSITY HAS WRITTEN CONFLICTS OF INTEREST POLICIES THAT APPLY TO ALL DIRECTORS, OFFICERS AND SENIOR ADMINISTRATORS, AND EMPLOYEES IN ROLES WHERE CONFLICTS COULD REASONABLY ARISE. THESE POLICIES REQUIRE DISCLOSURES OF INTERESTS THAT MIGHT GIVE RISE TO CONFLICTS WITH THE GOAL OF AVOIDING EITHER THE APPEARANCE OF CONFLICTS OR ACTUAL CONFLICTS. THE UNIVERSITY'S FINANCIAL CONFLICTS OF INTEREST POLICY REQUIRES ALL EMPLOYEES IN ROLES WHERE CONFLICTS COULD REASONABLY ARISE TO MAKE INITIAL, AS WELL AS ANNUAL AND UPDATED, DISCLOSURES OF "SIGNIFICANT FINANCIAL INTERESTS" AND OTHER RELATIONSHIPS THAT MAY GIVE RISE TO CONFLICTS OF INTEREST. EMPLOYEES RESPOND TO A SERIES OF QUESTIONS TO ELICIT INFORMATION ABOUT POTENTIAL CONFLICTS, ACKNOWLEDGE THAT THEY HAVE READ THE POLICY AND ARE PROVIDING ACCURATE INFORMATION, AND AGREE TO UPDATE THE DISCLOSURE IF CIRCUMSTANCES CHANGE. CONFLICT OF INTEREST OFFICERS ON EACH CAMPUS REVIEW THE DISCLOSURES, OBTAIN ADDITIONAL INFORMATION AS NECESSARY, AND MAKE DETERMINATIONS ABOUT THE APPROPRIATE MANAGEMENT OF ACTUAL OR POTENTIAL CONFLICTS WHEN THEY ARISE. A UNIVERSITY-WIDE FINANCIAL CONFLICTS OF INTEREST COMMITTEE REVIEWS CAMPUS OFFICER DETERMINATIONS AND OVERSEES THE IMPLEMENTATION OF THE POLICY. THE UNIVERSITY HAS SEPARATE POLICIES AND PROCESSES FOR THE ANNUAL DISCLOSURE AND EVALUATION OF POTENTIAL CONFLICTS FOR UNIVERSITY OFFICERS AND SENIOR ADMINISTRATORS AND FOR MEMBERS OF THE BOARD OF DIRECTORS. THESE POLICIES REQUIRE ANNUAL CERTIFICATIONS AND DISCLOSURES OF ANY CIRCUMSTANCES THAT MIGHT GIVE RISE TO AN ACTUAL OR APPARENT CONFLICT OF INTEREST AND PROHIBIT INVOLVEMENT IN DECISION MAKING BY ANY OFFICER, SENIOR ADMINISTRATOR OR DIRECTOR WHO HAS A CONFLICT. IN ADDITION TO THESE POLICIES AND PROCEDURES, THE UNIVERSITY MONITORS POTENTIAL CONFLICTS RELATING TO RESEARCH PROJECTS THROUGH A REQUIRED STUDY-SPECIFIC DISCLOSURE AND REVIEW PROCESS. POTENTIAL NON-COMPLIANCE WITH THE CONFLICT OF INTEREST POLICIES CAN BE REPORTED ON AN ANONYMOUS BASIS THROUGH THE UNIVERSITY'S COMPLIANCE HELPLINE, AND MAY ALSO BE REVEALED THROUGH REVIEWS CONDUCTED BY THE OFFICE OF INTERNAL AUDIT. VIOLATIONS OF THE UNIVERSITY'S CONFLICTS POLICIES MAY RESULT IN SANCTIONS UP TO AND INCLUDING TERMINATION OF EMPLOYMENT.
FORM 990, PART VI, SECTION B, LINE 14:
THE UNIVERSITY HAS A WRITTEN DOCUMENT RETENTION AND DESTRUCTION POLICY, HOWEVER, IT HAS NOT BEEN APPROVED BY THE BOARD OF DIRECTORS.
FORM 990, PART VI, SECTION B, LINE 15:
THE SUBCOMMITTEE ON COMPENSATION OF THE EXECUTIVE COMMITTEE OF THE BOARD OF DIRECTORS IS CHARGED WITH REVIEWING THE PHILOSOPHY BEHIND, AND STRATEGIES TO IMPLEMENT, THE UNIVERSITY'S COMPENSATION STRUCTURE. IN ADDITION, THE COMPENSATION SUBCOMMITTEE IS RESPONSIBLE FOR: EVALUATING THE PRESIDENT AND DETERMINING HIS COMPENSATION LEVEL; REVIEWING THE RECOMMENDATIONS OF AND ADVISING THE PRESIDENT REGARDING SALARY LEVELS AND EMPLOYMENT AGREEMENTS FOR SENIOR OFFICERS; AND PERFORMING ANY OTHER FUNCTION ASSIGNED BY THE EXECUTIVE COMMITTEE. DATA AS TO COMPARABLE COMPENSATION FOR SIMILARLY QUALIFIED PERSONS IN FUNCTIONALLY COMPARABLE POSITIONS AT SIMILARLY SITUATED ORGANIZATIONS IS OBTAINED FROM A VARIETY OF SOURCES, INCLUDING INDEPENDENT OUTSIDE CONSULTANTS, AND IS TAKEN INTO CONSIDERATION AS PART OF THE COMPENSATION ASSESSMENT PROCESS. NO MEMBER OF THE SUBCOMMITTEE ON COMPENSATION RECEIVES ANY COMPENSATION FROM THE UNIVERSITY OR OTHERWISE HAS A CONFLICT OF INTEREST. THE LAST REVIEW OF THE PERSONS DESCRIBED ABOVE WAS ON JUNE 28, 2011.
FORM 990, PART VI, SECTION B, LINE 16B:
THE UNIVERSITY HAS A WRITTEN JOINT VENTURE POLICY, HOWEVER, IT HAS NOT BEEN APPROVED BY THE BOARD OF DIRECTORS.
FORM 990, PART VI, SECTION C, LINE 19:
GEORGETOWN UNIVERSITY MAKES ITS GOVERNING DOCUMENTS, CONFLICT OF INTEREST POLICIES, AND FINANCIAL STATEMENTS AVAILABLE TO THE PUBLIC ON ITS WEBSITE AT WWW.GEORGETOWN.EDU.
FORM 990, PART XI, LINE 5:
OTHER CHANGES IN NET ASSETS OR FUND BALANCES: CHANGE IN VALUE OF SPLIT INTEREST AGREEMENTS $ 4,936,319; NET UNREALIZED GAINS $ 104,101,223; UNREALIZED GAINS ON SWAPS $ 11,126,510; MINIMUM PENSION LIABILITY ADJUSTMENT $ 28,220,000; OTHER NON OPERATING ADJUSTMENTS $ 1,375,592; TOTAL PART XI, LINE 5: $ 149,759,644
FORM 990, PART VI, SECTION A, LINE 2:
JOSEPH DELLA ROSA AND VICTOR WRIGHT, BOTH MEMBERS OF THE BOARD OF DIRECTORS, HAVE A COMMON BUSINESS RELATIONSHIP, WHICH THEY ENTERED INTO BEFORE THE TAX YEAR BEGINNING JULY 1, 2010.
For Paperwork Reduction Act Notice, see the Instructions for Form 990 or 990-EZ.