Attach to Form 990 or Form 990-EZ.
Information about Schedule A (Form 990 or 990-EZ) and its instructions is at www.irs.gov/form990.
| (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 listed in your governing document? | (v) Amount of monetary support (see instructions) | (vi) Amount of other support (see instructions) | |
|---|---|---|---|---|---|---|
| Yes | No | |||||
| Total | ||||||
Calendar year (or fiscal year beginning in) ![]() |
(a) 2010 | (b) 2011 | (c) 2012 | (d) 2013 | (e) 2014 | (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. | ||||||
Calendar year
(or fiscal year beginning in) ![]() |
(a) 2010 | (b) 2011 | (c) 2012 | (d) 2013 | (e) 2014 | (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. Do not include gain or loss from the sale of capital assets (Explain in Part VI.).. | ||||||
| 11 | Total support Add lines 7 through 10. | ||||||
Calendar year (or fiscal year beginning in) ![]() |
(a) 2010 | (b) 2011 | (c) 2012 | (d) 2013 | (e) 2014 | (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.) | ||||||
Calendar year (or fiscal year beginning in) ![]() |
(a) 2010 | (b) 2011 | (c) 2012 | (d) 2013 | (e) 2014 | (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 VI.) .. | ||||||
| 13 | Total support. (Add lines 9, 10c, 11, and 12.).. | ||||||
| Section A - Adjusted Net Income | (A) Prior Year |
(B) Current Year (optional) |
||||
| 1 | Net short-term capital gain | 1 | ||||
| 2 | Recoveries of prior-year distributions | 2 | ||||
| 3 | Other gross income (see instructions) | 3 | ||||
| 4 | Add lines 1 through 3 | 4 | ||||
| 5 | Depreciation and depletion | 5 | ||||
| 6 | Portion of operating expenses paid or incurred for production or collection of gross income or for management, conservation, or maintenance of property held for production of income (see instructions) | 6 | ||||
| 7 | Other expenses (see instructions) | 7 | ||||
| 8 | Adjusted Net Income (subtract lines 5, 6 and 7 from line 4) | 8 | ||||
| Section B - Minimum Asset Amount | (A) Prior Year |
(B) Current Year (optional) |
||||
| 1 | Aggregate fair market value of all non-exempt-use assets (see instructions for short tax year or assets held for part of year): | 1 | ||||
| a | Average monthly value of securities | 1a | ||||
| b | Average monthly cash balances | 1b | ||||
| c | Fair market value of other non-exempt-use assets | 1c | ||||
| d | Total (add lines 1a, 1b, and 1c) | 1d | ||||
| e | Discount claimed for blockage or other factors (explain in detail in Part VI): | |||||
| 2 | Acquisition indebtedness applicable to non-exempt use assets | 2 | ||||
| 3 | Subtract line 2 from line 1d | 3 | ||||
| 4 | Cash deemed held for exempt use. Enter 1-1/2% of line 3 (for greater amount, see instructions). | 4 | ||||
| 5 | Net value of non-exempt-use assets (subtract line 4 from line 3) | 5 | ||||
| 6 | Multiply line 5 by .035 | 6 | ||||
| 7 | Recoveries of prior-year distributions | 7 | ||||
| 8 | Minimum Asset Amount (add line 7 to line 6) | 8 | ||||
| Section C - Distributable Amount | Current Year | |||||
| 1 | Adjusted net income for prior year (from Section A, line 8, Column A) | 1 | ||||
| 2 | Enter 85% of line 1 | 2 | ||||
| 3 | Minimum asset amount for prior year (from Section B, line 8, Column A) | 3 | ||||
| 4 | Enter greater of line 2 or line 3 | 4 | ||||
| 5 | Income tax imposed in prior year | 5 | ||||
| 6 | Distributable Amount. Subtract line 5 from line 4, unless subject to emergency temporary reduction (see instructions) | 6 | ||||
| 7 | Check here if the current year is the organization's first as a non-functionally-integrated Type III supporting organization (see instructions) | |||||
| Section D - Distributions | Current Year | |
|---|---|---|
| 1 Amounts paid to supported organizations to accomplish exempt purposes | ||
|
2
Amounts paid to perform activity that directly furthers exempt purposes of supported organizations, in excess of income from activity |
||
| 3 Administrative expenses paid to accomplish exempt purposes of supported organizations | ||
| 4 Amounts paid to acquire exempt-use assets | ||
| 5 Qualified set-aside amounts (prior IRS approval required) | ||
| 6 Other distributions (describe in Part VI). See instructions | ||
| 7Total annual distributions. Add lines 1 through 6. | ||
|
8
Distributions to attentive supported organizations to which the organization is responsive (provide details in Part VI). See instructions |
||
| 9 Distributable amount for 2014 from Section C, line 6 | ||
| 10 Line 8 amount divided by Line 9 amount | ||
| Section E - Distribution Allocations (see instructions) |
(i) Excess Distributions |
(ii) Underdistributions Pre-2014 |
(iii) Distributable Amount for 2014 |
|
|---|---|---|---|---|
|
1
Distributable amount for 2014 from Section C, line 6 |
||||
|
2
Underdistributions, if any, for years prior to 2014 (reasonable cause required--see instructions) |
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| 3 Excess distributions carryover, if any, to 2014: | ||||
| a From 2009.......X | ||||
| b From 2010.......X | ||||
| c From 2011.......X | ||||
| d From 2012.......X | ||||
| e From 2013....... | ||||
| fTotal of lines 3a through e | ||||
| g Applied to underdistributions of prior years | ||||
| h Applied to 2014 distributable amount | ||||
|
i
Carryover from 2009 not applied (see instructions) |
||||
| j Remainder. Subtract lines 3g, 3h, and 3i from 3f. | ||||
| 4Distributions for 2014 from Section D, line 7: | ||||
| $ | ||||
| a Applied to underdistributions of prior years | ||||
| b Applied to 2014 distributable amount | ||||
| c Remainder. Subtract lines 4a and 4b from 4. | ||||
|
5
Remaining underdistributions for years prior to 2014, if any. Subtract lines 3g and 4a from line 2 (if amount greater than zero, see instructions) |
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|
6
Remaining underdistributions for 2014. Subtract lines 3h and 4b from line 1 (if amount greater than zero, see instructions) |
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|
7 Excess distributions carryover to 2015. Add lines 3j and 4c. |
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| 8 Breakdown of line 7: | ||||
| a From 2010.......X | ||||
| b From 2011.......X | ||||
| c From 2012.......X | ||||
| d From 2013....... | ||||
| e From 2014....... | ||||
| Facts And Circumstances Test |
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| Return Reference | Explanation |
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Attach to Form 990 or 990-EZ.
Information about Schedule O (Form 990 or 990-EZ) and its instructions is at| Return Reference | Explanation |
|---|---|
| FORM 990, PART III, LINE 3 | THE ORGANIZATION MERGED WITH HAZELDEN BETTY FORD FOUNDATION AND BECAME AN OPERATING DIVISION OF THE FOUNDATION. FOR ADDITIONAL INFORMATION, PLEASE SEE SCHEDULE N. |
| FORM 990, PART VI, SECTION A, LINE 2 | THE BETTY FORD CENTER BUYS OPERATING SUPPORT SERVICES FROM EISENHOWER MEDICAL CENTER (EMC). AUBRY SERFLING IS A MEMBER OF THE BETTY FORD CENTER'S BOARD OF DIRECTORS, THE CHIEF EXECUTIVE OFFICER OF EMC AND A MEMBER OF THE EMC BOARD OF TRUSTEES. MADELINE REDSTONE IS A MEMBER OF THE BETTY FORD CENTER'S BOARD OF DIRECTORS AND HER SPOUSE IS A MEMBER OF THE EMC BOARD OF TRUSTEES. ONE BETTY FORD CENTER BOARD MEMBER IS THE PERSONAL PHYSICIAN TO ANOTHER BOARD MEMBER. A BETTY FORD CENTER BOARD MEMBER SERVES ON THE BOARD OF AN ORGANIZATION THAT HAS A PRICING AGREEMENT WITH THE BETTY FORD CENTER. A BETTY FORD CENTER BOARD MEMBER SERVES AS PERSONAL LEGAL COUNSEL TO THREE OF THE CENTER'S EXECUTIVES AND HAS PREVIOUSLY REPRESENTED OVER 150 STAFF MEMBERS IN VARIOUS LEGAL MATTERS. |
| FORM 990, PART VI, SECTION A, LINE 4 | AN AGREEMENT OF MERGER WAS FILED BETWEEN HAZELDEN BETTY FORD FOUNDATION AND THE BETTY FORD CENTER, IN WHICH, THE BETTY FORD CENTER LEGALLY DISSOLVED AND BECAME A SEPARATE OPERATING DIVISION OF THE HAZELDEN BETTY FORD FOUNDATION. SEE ATTACHED ARTICLES OF MERGER |
| FORM 990, PART VI, SECTION A, LINE 6 | EFFECTIVE FEBRUARY 7, 2014, THE HAZELDEN FOUNDATION ("HAZELDEN") WAS SUBSTITUTED AS THE SOLE CORPORATE MEMBER OF THE BETTY FORD CENTER AT EISENHOWER TO FACILITATE THE PLANNED STATUTORY MERGER OF THE TWO ORGANIZATIONS AT JANUARY 1, 2015. HAZELDEN, A 501(C)(3) TAX-EXEMPT ORGANIZATION, IS CONSIDERED TO BE A LEADER IN CHEMICAL DEPENDENCY TREATMENT HEADQUARTERED IN MINNESOTA. HAZELDEN AND ITS SUBSIDIARIES OWN AND OPERATE SUBSTANCE ABUSE TREATMENT FACILITIES AND OTHER PROGRAMS AND SERVICES IN VARIOUS SITES ACROSS THE COUNTRY. BOTH PARTIES DETERMINED THAT A COMPLETE INTEGRATION AND MERGER OF THEIR PROGRAMS AND SERVICES WOULD FURTHER THE MISSION OF BOTH ORGANIZATIONS DUE TO IDENTICAL MISSIONS, CLINICAL MODEL ROOTED IN THE TWELVE STEPS OF ALCOHOLICS ANONYMOUS, AND COMMITMENT TO PROVIDING THE HIGHEST QUALITY OF CARE. THE BENEFITS OF THE MERGER INCLUDED OPERATING EFFICIENCIES, EXPANDING GEOGRAPHIC REACH TO HELP MORE PEOPLE, COMBINING RESOURCES TO RESPOND TO THE NEEDS OF HEALTH REFORM AND STRENGTHENING AND ENHANCING THE CONTINUUM OF PROGRAM OFFERINGS IN THE COMMUNITIES SERVED BY EACH ORGANIZATION. |
| FORM 990, PART VI, SECTION A, LINE 7A | IT IS THE INTENT OF BOTH THE BOARD OF TRUSTEES OF HAZELDEN BETTY FORD FOUNDATION AND THE BOARD OF DIRECTORS OF THE BETTY FORD CENTER THAT THEIR BOARDS FULLY MELD TOGETHER TO CREATE ONE UNIFIED BOARD OVER THE COMBINED ORGANIZATIONS AND AFFILIATED SUBSIDIARIES. UPON THE EFFECTIVE DATE OF JANUARY 1, 2015, IN ACCORDANCE WITH THE REVISED HAZELDEN FOUNDATION BYLAWS, THE INITIAL BOARD OF TRUSTEES OF HAZELDEN BETTY FORD FOUNDATION AND THE INITIAL BOARD OF DIRECTORS OF BETTY FORD CENTER SHALL BE COMPRISED OF ALL HAZELDEN FOUNDATION AND BETTY FORD CENTER DIRECTORS INTERESTED AND ELIGIBLE TO SERVE AS BOARD MEMBERS OF HAZELDEN BETTY FORD FOUNDATION AND BETTY FORD CENTER, AS DETERMINED PURSUANT TO SECTION 2.2.9 OF THE BYLAWS. THEREAFTER, THE HAZELDEN BETTY FORD FOUNDATION BOARD MEMBERSHIP SHALL BE SELF PERPETUATING, AND THE BETTY FORD CENTER BOARD MEMBERSHIP SHALL BE IDENTICAL TO THE HAZELDEN BETTY FORD FOUNDATION BOARD MEMBERSHIP. THE PRESIDENT AND CHIEF EXECUTIVE OFFICER OF HAZELDEN BETTY FORD FOUNDATION SHALL SERVE ON THE BOARD OF TRUSTEES OF HAZELDEN BETTY FORD FOUNDATION AND THE BOARD OF DIRECTORS OF BETTY FORD CENTER AS AN EX-OFFICIO MEMBER WITH A VOTE. |
| FORM 990, PART VI, SECTION B, LINE 11 | EACH BOARD MEMBER IS SENT A COPY OF FORM 990 FOR REVIEW BEFORE THE FORM IS FILED. |
| FORM 990, PART VI, SECTION B, LINE 12C | OFFICERS, DIRECTORS, FOUNDATION TRUSTEES AND MEMBERS OF SENIOR MANAGEMENT ARE REQUIRED TO COMPLETE ANNUAL CONFLICT OF INTEREST STATEMENTS WHICH ARE REVIEWED BY THE BETTY FORD CENTER'S LEGAL COUNSEL. CONFLICT OF INTEREST POLICY: BETTY FORD CENTER EMPLOYEES AND TRUSTEES MUST AVOID CONFLICTS OF INTEREST BY APPROPRIATELY ARRANGING OUTSIDE OBLIGATIONS, FINANCIAL INTERESTS, CONSULTATION AND OTHER ACTIVITIES THAT RELATE TO OR CONFLICT WITH THEIR EMPLOYMENT OR RELATIONSHIP WITH THE BETTY FORD CENTER. ACCORDINGLY, EMPLOYEES MAY NOT UNDERTAKE ANY ACTIVITY, WITH OR WITHOUT COMPENSATION, WHICH MIGHT: A. INTERFERE WITH THE PROPER PERFORMANCE OF HIS/HER DUTIES; B. CAUSE LOSS OR CAUSE UNFAVORABLE PUBLICITY OR EMBARRASSMENT TO THE BETTY FORD CENTER IF DISCLOSED OR POSTED ON ANY SOCIAL MEDIA SITE/BLOG; C. BE UNETHICAL OR UNLAWFUL IN THEIR RELATIONSHIPS WITH PATIENTS AND THEIR FAMILIES, HEALTH CARE PRACTITIONERS, SUPPLIERS, SUBCONTRACTORS AND COMPETITORS. TO ENSURE COMPLIANCE WITH THIS POLICY, ALL EMPLOYEES/TRUSTEES MUST DISCLOSE ANY KNOWN OR POTENTIAL CONFLICT OF INTEREST AS DEFINED IN THIS POLICY AND RECEIVE APPROVAL PRIOR TO UNDERTAKING THE "QUESTIONABLE" ACTIVITY. IN ADDITION, ALL MANAGEMENT EMPLOYEES SHALL COMPLETE A CONFLICT OF INTEREST CERTIFICATION WHEN AN EXTERNAL ACTIVITY MAY BE CONSTRUED AS A CONFLICT OF INTEREST. THE CHIEF EXECUTIVE OFFICER (CEO) MUST APPROVE ALL POTENTIAL CONFLICT TRANSACTIONS OR ACTIVITIES INVOLVING EMPLOYEES OF BETTY FORD CENTER. THE CEO AND THE CHAIRMAN, BOARD OF DIRECTORS MUST APPROVE ALL POTENTIAL CONFLICT TRANSACTIONS OR ACTIVITIES INVOLVING TRUSTEES. IT IS THE RESPONSIBILITY OF MANAGEMENT TO ENSURE THAT ALL EMPLOYEES ARE INFORMED OF THIS POLICY STATEMENT AND PROCEDURE. A. DEFINITIONS 1. CONFLICT OF INTEREST: A CONFLICT OF INTEREST IS DEFINED AS A SITUATION IN WHICH AN EMPLOYEE, EITHER DIRECTLY OR INDIRECTLY THROUGH A SPOUSE, PARENTS, CHILDREN OR OTHER FAMILY MEMBERS, HAS THE OPPORTUNITY, OR APPEARS TO HAVE THE OPPORTUNITY TO INFLUENCE BETTY FORD CENTER DECISIONS OR TO USE ANY RESOURCES OR INFORMATION WHICH IS CONFIDENTIAL WITH RESPECT TO THE CENTER IN WAYS THAT COULD LEAD TO PROFESSIONAL, PERSONAL OR ECONOMIC GAIN OR GIVE IMPROPER ADVANTAGE TO SELF OR ASSOCIATES OUTSIDE OF THE CENTER. 2. SIGNIFICANT FINANCIAL INTEREST: A SIGNIFICANT FINANCIAL INTEREST SHALL BE ANY INTEREST, FEE, SALARY, DIVIDEND, RENT OR ANY OTHER FORM OF COMPENSATION IN EXCESS OF $7,500 PER ANNUM, OR A 1% OR GREATER EQUITY OR OTHER FINANCIAL POSITION (INCLUDING STOCK, STOCK OPTIONS, WARRANTS, DEBT, OR OTHER SECURITIES OR OWNERSHIP INTEREST) IN ANY COMPANY OR OTHER INVESTMENT ENTITY WHICH CONDUCTS BUSINESS WITH BFC, BUT EXCLUDING ANY INTEREST ARISING SOLELY BY REASON OF AN INVESTMENT IN WHICH THE EMPLOYEE OWNS LESS THAN A 1% INTEREST. 3. PROFESSIONAL ACTIVITY: AN OUTSIDE PROFESSIONAL ACTIVITY SHALL MEAN ANY CONSULTATION, EMPLOYMENT, SCIENTIFIC ADVISORY ROLE, AND PARTICIPATION IN ANY CORPORATION, PARTNERSHIP AGREEMENT, BUSINESS, HEALTH CARE ENTERPRISE OR ANY OTHER LEGAL ENTITY. B. EXAMPLES OF PROHIBITED ACTIVITIES THE FOLLOWING ACTIVITIES ARE CONSIDERED "PROHIBITED" UNLESS WRITTEN PERMISSION IS GRANTED BY THE CEO OR THE CHAIRMAN, BOARD OF DIRECTORS. 1. ANY PARTICIPATION IN OR ACCEPTANCE OF ANY PLAN, TRANSACTION, OR ARRANGEMENT, WHICH THE EMPLOYEE KNOWS OR SUSPECTS, IS UNETHICAL OR UNLAWFUL. 2. ANY DIRECT OR INDIRECT SIGNIFICANT FINANCIAL INTEREST IN ANY BUSINESS OR HEALTH CARE ENTERPRISE THAT PRODUCES SERVICES OR PRODUCTS WHICH COMPETE OR COULD POTENTIALLY COMPETE WITH THOSE OF THE BETTY FORD CENTER. 3. DISCLOSURE OF CONFIDENTIAL PATIENT INFORMATION, FINANCIAL, OPERATING, MEDICAL OR OTHER INFORMATION RELATED TO BFC INTENDED TO BE PRIVILEGED OR CONFIDENTIAL TO ANY PERSON OR ORGANIZATION. 4. ACCEPTANCE FOR HIS OR HER PROFESSIONAL ACTIVITY HONORARIA, CONSULTING FEES OR OTHER REMUNERATION IN ANY AMOUNT FROM AN INDIVIDUAL OR COMPANY WHICH CONDUCTS BUSINESS WITH BFC AND FOR WHICH THE EMPLOYEE IS IN A POSITION TO MAKE OR INFLUENCE DECISIONS. 5. SERVICE AS AN OFFICER, DIRECTOR, EMPLOYEE, COMMITTEE MEMBER, ADVISOR, AGENT, REPRESENTATIVE OR CONSULTANT OR IN ANY OTHER PROFESSIONAL ACTIVITY CAPACITY FOR ANY COMPANY, FIRM OR BUSINESS OTHER THAN THE BETTY FORD CENTER WHEN, IN THE JUDGMENT OF THE EMPLOYEE'S CEO, SUCH SERVICE CONFLICTS WITH THE CENTER'S INTERESTS OR DETRACTS FROM OR INFRINGES IN A SIGNIFICANT WAY ON THE EMPLOYEE'S RESPONSIBILITIES TO THE BETTY FORD CENTER. 6. DIRECTLY OR INDIRECTLY OWN, TRADE, OR DEAL IN REAL ESTATE, MATERIALS, SUPPLIES, EQUIPMENT OR OTHER PROPERTY WITH THE INTENT OF SELLING, RENTING OR CONTRACTING TO BETTY FORD CENTER, OR ITS EMPLOYEES. 7. CASH GIFTS OF ANY AMOUNT, OR A GIFT, GRATUITY, ENTERTAINMENT OR FAVORS ARE NOT ACCEPTED. INCLUDED IN THIS PROHIBITION ARE GIFTS FROM PATIENTS, BETTY FORD CENTER EMPLOYEES, AFFILIATED PROVIDERS, AND ANY BUSINESS ENTERPRISE THAT IS A CURRENT OR PROSPECTIVE SUPPLIER, LESSOR OR LESSEE. GIFTS ARE PRESUMED TO BE OF "SUCH SIGNIFICANCE" IF THE VALUE EXCEEDS $50 PER EVENT FROM A SINGLE PERSON OR ENTITY. SUCH GIFTS ARE REPORTED TO THE SUPERVISOR, WHO MAKES A DETERMINATION: 1. THE GIFT IS ONE THAT CAN BE SHARED BY THE DEPARTMENT OR 2. THE INDIVIDUAL MAY KEEP THE GIFT. C. DISCLOSURE PROCEDURE 1. AT HIRE AND PERIODIC DISCLOSURE: ALL EMPLOYEES AT THE MANAGER LEVEL OR ABOVE ARE REQUIRED TO PROVIDE FULL DISCLOSURE OF ALL SIGNIFICANT FINANCIAL INTERESTS, POTENTIAL CONFLICT OF INTEREST SITUATIONS, AND RELATIONSHIPS WHICH MAY BE PROHIBITED ACTIVITIES. SUCH DISCLOSURES AND AGREEMENTS ARE REQUIRED AS A CONDITION OF EMPLOYMENT AT THE BETTY FORD CENTER. ALL DISCLOSURES WILL BE MADE AT THE TIME THE EMPLOYEE BEGINS EMPLOYMENT AND WHEN A NEW SITUATION DEVELOPS. 2. SITUATIONAL DISCLOSURE: IT IS THE AFFIRMATIVE RESPONSIBILITY OF ANY MANAGEMENT EMPLOYEE WHO HAS A CHANGE IN OUTSIDE PROFESSIONAL ACTIVITIES, SIGNIFICANT FINANCIAL INTERESTS, OR POTENTIAL OR ACTUAL CONFLICT OF INTEREST SITUATIONS THAT ARISE DURING THE YEAR TO DISCLOSE THE INFORMATION TO THE CEO AS SOON AS THE EMPLOYEE BECOMES AWARE OF THE POTENTIAL OR ACTUAL SITUATION. IN ADDITION, ANY NON-MANAGEMENT EMPLOYEE WHO HAS THE POTENTIAL FOR INFLUENCING BUSINESS DECISIONS AS DESCRIBED IN THIS POLICY SHALL ALSO DISCLOSE TO HIS/HER RESPECTIVE DIRECTOR AS SOON AS THE EMPLOYEE BECOMES AWARE OF THE POTENTIAL CONFLICT. 3. APPROVAL PROCESS: THE CEO IS CHARGED WITH REVIEWING, IN CONFIDENCE, ALL DISCLOSURES IN A TIMELY AND OBJECTIVE MANNER TO DETERMINE IF A PROHIBITED ACTIVITY OR CONFLICT OF INTEREST EXISTS. THE APPROVING AUTHORITY MAY GRANT WAIVERS IN SITUATIONS WHEN IT CAN BE DEMONSTRATED THAT THE INTEREST OR RELATIONSHIP AT ISSUE WOULD NOT COMPROMISE THE OBJECTIVITY OF DECISIONS AND ACTIONS TAKEN. IF A PROHIBITED ACTIVITY OR CONFLICT OF INTEREST IS IDENTIFIED, THE APPROVING AUTHORITY MAY TAKE STEPS TO ELIMINATE ANY CONFLICT, OR APPROPRIATELY MANAGE THE SITUATION, INCLUDING A RECOMMENDATION OF CORRECTIVE ACTIVE AND/OR TERMINATION OF EMPLOYMENT. |
| FORM 990, PART VI, SECTION B, LINE 15 | COMPENSATION LEVELS FOR THE CEO AND CFO/TREASURER ARE REVIEWED BY THE COMPENSATION COMMITTEE OF THE BOARD OF DIRECTORS. THE REVIEW IS ASSISTED BY THE SENIOR VICE PRESIDENT FOR HUMAN RELATIONS AND RELIES ON COMPARATIVE DATA OBTAINED FROM A NUMBER OF OUTSIDE SOURCES AS WELL AS THE PERIODIC ASSISTANCE OF AN INDEPENDENT COMPENSATION CONSULTANT. OTHER KEY EMPLOYEES' COMPENSATION IS PERIODICALLY REVIEWED BY HR THROUGH SURVEYS AND 990 INFORMATION AND MARKET ADJUSTMENTS ARE APPROVED BY THE CEO WHERE REQUIRED. |
| FORM 990, PART VI, SECTION C, LINE 19 | THE BETTY FORD CENTER DOES NOT ROUTINELY MAKE ITS GOVERNING DOCUMENTS AND CONFLICT OF INTEREST POLICY AVAILABLE TO THE PUBLIC, BUT WILL CONSIDER WRITTEN REQUESTS FOR THIS INFORMATION. AUDITED FINANCIAL STATEMENTS ARE MADE AVAILABLE UPON REQUEST. |
| FORM 990, PART XI, LINE 9: | PROVISION FOR UNCOLLECTIBLE PLEDGES -1,080,055. CHANGES IN ENDOWMENT DRAWS 229,170. |
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