Attach to Form 990 or Form 990-EZ.
Go to
www.irs.gov/Form990 for instructions and the latest information.
| (i) Name of supported organization | (ii) EIN | (iii) Type of organization (described on lines 1- 10 above (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 | |||||
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Total |
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Calendar year
(or fiscal year beginning in)
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(a) 2020 | (b) 2021 | (c) 2022 | (d) 2023 | (e) 2024 | (f) Total | |
|---|---|---|---|---|---|---|---|
| 1 | Gifts, grants, contributions, and membership fees received. (Do not include any "unusual grant.") .. | 3,430,000 | 4,940,952 | 4,896,009 | 10,696,130 | 13,896,517 | 37,859,608 |
| 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 | 3,430,000 | 4,940,952 | 4,896,009 | 10,696,130 | 13,896,517 | 37,859,608 |
| 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) .. | 30,868,160 | |||||
| 6 | Public support. Subtract line 5 from line 4. | 6,991,448 | |||||
Calendar year
(or fiscal year beginning in)
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(a) 2020 | (b) 2021 | (c) 2022 | (d) 2023 | (e) 2024 | (f) Total | |
|---|---|---|---|---|---|---|---|
| 7 | Amounts from line 4.. | 3,430,000 | 4,940,952 | 4,896,009 | 10,696,130 | 13,896,517 | 37,859,608 |
| 8 | Gross income from interest, dividends, payments received on securities loans, rents, royalties and income from similar sources... | 189 | 584 | 130 | 903 | ||
| 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 | 37,860,511 | |||||
Calendar year (or fiscal
year beginning in) ![]() |
(a) 2020 | (b) 2021 | (c) 2022 | (d) 2023 | (e) 2024 | (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) 2020 | (b) 2021 | (c) 2022 | (d) 2023 | (e) 2024 | (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 on 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) |
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| 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) |
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| 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): |
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| 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 0.015 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 0.035 | 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 | ||||
| Section D - Distributions | Current Year | |
|---|---|---|
| 1 Amounts paid to supported organizations to accomplish exempt purposes | 1 | |
|
2
Amounts paid to perform activity that directly furthers exempt purposes of supported organizations, in excess of income from activity |
2 | |
| 3 Administrative expenses paid to accomplish exempt purposes of supported organizations | 3 | |
| 4 Amounts paid to acquire exempt-use assets | 4 | |
| 5 Qualified set-aside amounts (prior IRS approval required - provide details in Part VI) | 5 | |
| 6 Other distributions (describe in Part VI). See instructions | 6 | |
| 7Total annual distributions. Add lines 1 through 6. | 7 | |
|
8
Distributions to attentive supported organizations to which the organization is responsive (provide details in Part VI). See instructions |
8 | |
| 9 Distributable amount for 2024 from Section C, line 6 | 9 | |
| 10 Line 8 amount divided by Line 9 amount | 10 | |
| Section E - Distribution Allocations (see instructions) |
(i) Excess Distributions |
(ii) Underdistributions Pre-2024 |
(iii) Distributable Amount for 2024 |
|
|---|---|---|---|---|
| 1 Distributable amount for 2024 from Section C, line 6 | ||||
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2
Underdistributions, if any, for years prior to 2024 (reasonable cause required-- explain in Part VI).
See instructions. |
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| 3 Excess distributions carryover, if any, to 2024: | ||||
| a From 2019....... | ||||
| b From 2020....... | ||||
| c From 2021....... | ||||
| d From 2022....... | ||||
| e From 2023....... | ||||
| fTotal of lines 3a through e | ||||
| g Applied to underdistributions of prior years | ||||
| h Applied to 2024 distributable amount | ||||
|
i
Carryover from 2019 not applied (see instructions) |
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| j Remainder. Subtract lines 3g, 3h, and 3i from line 3f. | ||||
| 4Distributions for 2024 from Section D, line 7: | ||||
| $ | ||||
| a Applied to underdistributions of prior years | ||||
| b Applied to 2024 distributable amount | ||||
| c Remainder. Subtract lines 4a and 4b from line 4. | ||||
|
5
Remaining underdistributions for years prior to 2024, if any. Subtract lines 3g and 4a from line 2. If the amount is greater than zero, explain in Part VI. See instructions. |
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6
Remaining underdistributions for 2024. Subtract lines 3h and 4b from line 1. If the amount is greater than zero, explain in Part VI. See instructions. |
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7 Excess distributions carryover to 2025. Add lines 3j and 4c. |
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| 8 Breakdown of line 7: | ||||
| a Excess from 2020..... | ||||
| b Excess from 2021..... | ||||
| c Excess from 2022..... | ||||
| d Excess from 2023..... | ||||
| e Excess from 2024..... | ||||
| Facts And Circumstances Test |
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| Return Reference | Explanation |
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| SECTION C, LINE 17A - 10% FACTS-AND-CIRCUMSTANCES TEST 2024 | ARES CHARITABLE FOUNDATION RESPECTFULLY SUBMITS THE FOLLOWING NARRATIVE TO DEMONSTRATE ITS QUALIFICATION AS A PUBLIC CHARITY UNDER THE 10% FACTS-AND-CIRCUMSTANCES TEST, PURSUANT TO TREASURY REGULATION 1.170A-9(F)(3). THRESHOLD REQUIREMENTS PUBLIC SUPPORT PERCENTAGE: FOR THE CURRENT FIVE-YEAR PERIOD, ARES CHARITABLE FOUNDATION HAS RECEIVED 18.47% OF ITS TOTAL SUPPORT FROM PUBLIC SOURCES, INCLUDING INDIVIDUAL DONORS, FOUNDATIONS, AND PUBLIC CHARITIES. THIS SIGNIFICANTLY EXCEEDS THE MINIMUM 10% THRESHOLD REQUIRED UNDER THE TEST. CONTINUOUS AND BONA FIDE FUNDRAISING PROGRAM: THE ORGANIZATION MAINTAINS AN ACTIVE AND ONGOING FUNDRAISING PROGRAM. THIS INCLUDES: A) ANNUAL GIVING CAMPAIGNS TARGETING INDIVIDUAL DONORS, INCLUDING ENCOURAGING DONORS AND POTENTIAL DONORS TO PLEDGE MULTI-YEAR SUPPORT. B) THE FOUNDATION MAINTAINS AN ELECTRONIC PLEDGE PORTAL TO ENCOURAGE DONOR COMMITMENTS IN A MANNER THAT FACILITATES A DONOR'S ABILITY TO TRACE ANTICIPATED AND ACTUAL GIVING TOTALS. C) QUARTERLY NEWSLETTERS WITH DONATION APPEALS THAT PROVIDE UPDATES ON ACTIVITIES, AND STRATEGIC STORYTELLING CAMPAIGNS TO SHOWCASE THE REACH AND THE IMPACT OF THE FOUNDATION'S CHARITABLE INITIATIVES. D) PARTICIPATION IN COMMUNITY FUNDRAISING EVENTS. E) ONGOING AND DEDICATED FUNDRAISING ACTIVITIES TO RETAIN EXISTING DONORS AND SOLICIT NEW CONTRIBUTORS. THESE INCLUDE QUARTERLY NEWSLETTERS, TARGETED ANNOUNCEMENTS, SPECIAL EVENTS, AND PERSONALIZED ONE-ON-ONE COMMUNICATIONS. THESES EFFORTS ARE COMMENSURATE WITH THE SCALE OF OUR OPERATIONS AND REFLECT A GENUINE COMMITMENT TO PUBLIC SUPPORT. F) THIRD PARTIES ARE PROJECTED TO CONTRIBUTE APPROXIMATELY $30 MILLION OVER THE NEXT FIVE YEARS, REPRESENTING A PORTION OF PERFORMANCE FEES FROM INVESTMENT FUNDS THAT THEY ARE ENTITLED TO AND THAT ARE EXPECTED TO BE REALIZED OVER THAT TIME PERIOD. SUPPORTING FACTORS 1. PERCENTAGE OF FINANCIAL SUPPORT: WHILE OUR PUBLIC SUPPORT PERCENTAGE IS MODEST, IT IS STEADILY INCREASING YEAR-OVER-YEAR. WE CONTINUE TO DIVERSIFY OUR FUNDING BASE AND REDUCE RELIANCE ON ANY SINGLE DONOR OR PRIVATE FOUNDATION. IN ITS EARLY YEARS OF EXISTENCE, THE FOUNDATION LIMITED THE SCOPE OF ITS SOLICITATIONS TO PERSONS DEEMED MOST LIKELY TO PROVIDE SEED MONEY IN AN AMOUNT SUFFICIENT TO ENABLE IT TO COMMENCE ITS CHARITABLE ACTIVITIES AND EXPAND ITS SOLICITATION PROGRAMS. WITHOUT THE SUPPORT OF ITS LARGEST DONOR, THE ORGANIZATION'S PUBLIC SUPPORT WOULD BE APPROXIMATELY TWICE THE 33 1/3% REQUIREMENT. HOWEVER, WITHOUT THIS SUPPORT, THE ORGANIZATION COULD NOT HAVE FULFILLED ITS MISSION TO HELP ACCELERATE ECONOMIC EQUITY AND EQUALITY BY SUPPORTING INITIATIVES THAT PROVIDE CAREER PREPARATION AND RESKILLING, ENCOURAGE ENTREPRENEURSHIP, AND DEEPEN INDIVIDUALS' UNDERSTANDING OF PERSONAL FINANCE. 2. BOARD COMPOSITION: OUR BOARD OF DIRECTORS IS CURRENTLY COMPOSED OF EIGHT INDIVIDUALS WHO HAVE VARIOUS AREAS OF EXPERTISE. FOR EXAMPLE, OUR BOARD INCLUDES SUBJECT MATTER EXPERTS IN HUMAN RESOURCES, NONPROFIT ADMINISTRATION, FINANCE, DEVELOPMENT, FUNDRAISING, AND LAW. 3. BOARD MEETING MATERIALS: BOARD MEETING MATERIALS, BUDGETS, FINANCIAL REPORTS, AND OTHER DOCUMENTS THAT VERIFY PUBLIC FUNDRAISING ACTIVITIES, DIVERSE BOARD RECRUITMENT EFFORTS, AND CHARITABLE INITIATIVES THAT BENEFIT THE PUBLIC ARE DIGITALLY ARCHIVED AND CAN BE FURNISHED UPON REQUEST. 4. PUBLIC BENEFIT ACTIVITIES: WE ENVISION A WORLD IN WHICH EQUITABLE ACCESS TO KNOWLEDGE, RESOURCES, AND OPPORTUNITIES ENABLES PEOPLE TO ACHIEVE THEIR FULL POTENTIAL. THE ARES CHARITABLE FOUNDATION STRIVES TO ACCELERATE EQUALITY OF ECONOMIC OPPORTUNITY THROUGH GRANTS THAT PROVIDE CAREER PREPARATION AND RESKILLING, ENCOURAGE ENTREPRENEURSHIP, AND SUPPORT CLIMATE-RESILIENT JOBS. OUR STRATEGIC GRANTMAKING HELPS ADDRESS CRITICAL SOCIETAL ISSUES TO MAKE A MEASURABLE, MEANINGFUL, AND SUSTAINED DIFFERENCE. OUR PARTNERSHIPS WITH SOME OF THE WORLD'S LEADING NONPROFITS STRIVE TO HELP CLOSE THE WIDENING WEALTH GAP A DISPARITY THAT OFTEN THREATENS BASIC HUMAN DIGNITY AND SURVIVAL. OUR 2024 GRANT-MAKING PROGRAMS INCLUDED THE FOLLOWING GRANTS AND INITIATIVES: -ALT FINANCE CORPORATION. INVESTING IN BLACK FUTURES. THIS INITIATIVE IS DESIGNED TO DIVERSIFY THE ALTERNATIVE INVESTMENT INDUSTRY BY ATTRACTING, TRAINING, AND PROVIDING CAREER OPPORTUNITIES FOR COLLEGE STUDENTS ATTENDING HISTORICALLY BLACK COLLEGES AND UNIVERSITIES. THE INITIATIVE HAS THREE PRIMARY COMPONENTS: (1) A MENTORED FOLLOWSHIP PROGRAM; (2) A TAILORED VIRTUAL INSTITUTE, AND (3) A SCHOLARSHIP PROGRAM. DURING 2024, A TOTAL OF 133 COLLEGE STUDENTS PARTICIPATED IN THIS U.S. BASED PROGRAM. -JOBS FOR THE FUTURE (JFF). THIS INITIATIVE IS DESIGNED TO HELP INDIVIDUALS PREPARE FOR CLIMATE-RESILIENT JOBS IN THE UNITED STATES AS WELL AS IDENTIFY LEADING TRAINING PROVIDERS, ORGANIZATIONS, AND BEST PRACTICES TO DESIGN PATHWAYS TO THOSE CAREER OPPORTUNITIES. THIS INITIATIVE IS ON TRACK TO FACILITATE EDUCATION AND TRAINING FOR 25,000 INDIVIDUALS. -WORLD RESOURCES INSTITUTE (WRI): THIS INITIATIVE IS DESIGNED TO HELP BUILD THE RESILIENCE OF INDIA'S MICRO, SMALL, AND MEDIUM ENTERPRISES IN TWO STATES TO FUTURE-PROOF THEIR BUSINESS MODELS WITHIN A CHANGING CLIMATE. THIS IS A FIVE-YEAR INITIATIVE ON TRACK TO PROVIDE EDUCATION AND TRAINING TO 1,000 INDIVIDUALS IN INDIA. 5. PUBLIC PARTICIPATION: THE ORGANIZATION ACTIVELY INVOLVES THE PUBLIC THROUGH VOLUNTEER OPPORTUNITIES, COMMUNITY ADVISORY PANELS, AND OPEN TOWN HALL MEETINGS. FEEDBACK FROM THESE ENGAGEMENTS DIRECTLY INFORMS PROGRAM DEVELOPMENT. 6. TRANSPARENCY AND ACCOUNTABILITY: WE PUBLISH ANNUAL REPORTS, MAINTAIN AN UPDATED WEBSITE WITH FINANCIAL DISCLOSURES, AND FILE FORM 990 CONSISTENTLY. OUR COMMITMENT TO TRANSPARENCY REINFORCES OUR PUBLIC ORIENTATION. CONCLUSION: BASED ON THE ABOVE FACTS AND CIRCUMSTANCES, ARES CHARITABLE FOUNDATION OPERATES IN THE NATURE OF AN ORGANIZATION THAT IS PUBLICLY SUPPORTED. WE RESPECTFULLY REQUEST RECOGNITION OF OUR PUBLIC CHARITY STATUS UNDER IRC SECTIONS 509(A)(1) AND 170(B)(1)(A)(VI) VIA THE 10% FACTS-AND-CIRCUMSTANCES TEST. |
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| Return Reference | Explanation |
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| FORM 990, PART VI, SECTION A, LINE 8B | THE ORGANIZATION DOES NOT HAVE A COMMITTEE WITH AUTHORITY TO ACT ON BEHALF OF THE GOVERNING BODY. |
| FORM 990, PART VI, SECTION B, LINE 11B | THE FORM IS REVIEWED AND APPROVED BY THE ORGANIZATION'S EXECUTIVE DIRECTOR. SUBSEQUENTLY, FORM 990, COMPLETE WITH ALL SCHEDULES, IS THEN PROVIDED TO THE FULL BOARD BEFORE FILING WITH THE IRS. |
| FORM 990, PART VI, SECTION B, LINE 12C | THIS CONFLICT OF INTEREST POLICY APPLIES TO OFFICERS, KEY EMPLOYEES AND MEMBERS OF THE BOARD OF DIRECTORS (EACH A "DIRECTOR AND COLLECTIVELY, THE "BOARD") OF ARES CHARITABLE FOUNDATION, A DELAWARE NONSTOCK, NONPROFIT CORPORATION (THE "CORPORATION'). ALL PERSONS COVERED UNDER THIS CONFLICT OF INTEREST POLICY (DIRECTORS, OFFICERS AND KEY EMPLOYEES OF THE CORPORATION) ARE HEREINAFTER COLLECTIVELY REFERRED TO AS "COVERED PERSONS." DISCLOSURE OF ACTUAL OR POTENTIAL CONFLICTS OF INTEREST: COVERED PERSONS ARE UNDER A CONTINUING OBLIGATION TO DISCLOSE ANY ACTUAL OR POTENTIAL CONFLICT OF INTEREST AS SOON AS IT IS KNOWN OR REASONABLY SHOULD BE KNOWN. PRIOR TO ELECTION, APPOINTMENT, OR HIRING, AS APPROPRIATE, AND ANNUALLY THEREAFTER, EACH COVERED PERSON COMPLETES A CONFLICT OF INTEREST DISCLOSURE STATEMENT ("DISCLOSURE STATEMENT"), TO FULLY AND COMPLETELY DISCLOSE THE MATERIAL FACTS ABOUT ANY ACTUAL OR POTENTIAL CONFLICTS OF INTEREST HE OR SHE MIGHT HAVE. IF AT ANY TIME DURING A COVERED PERSON'S TERM OF SERVICE CIRCUMSTANCES ARISE THAT COULD GIVE RISE TO A RELATED PARTY TRANSACTION, OR ANY OTHER REAL OR POTENTIAL CONFLICT OF INTEREST, HE OR SHE WILL PROMPTLY SUBMIT A DISCLOSURE STATEMENT TO THE BOARD DISCLOSING IN GOOD FAITH ALL RELEVANT MATERIAL FACTS. FOR ALL COVERED PERSONS, DISCLOSURE STATEMENTS ARE PROVIDED TO THE SECRETARY OF THE CORPORATION (ON BEHALF OF THE BOARD). THE SECRETARY OF THE CORPORATION PROVIDES COPIES OF ALL DISCLOSURE STATEMENTS TO BE FILED WITH THE OFFICIAL RECORDS OF THE CORPORATION SO THAT EACH STATEMENT IS AVAILABLE TO ANY DIRECTOR ON REQUEST. PROCEDURES FOR REVIEW OF ACTUAL OR POTENTIAL CONFLICTS: WHENEVER THERE IS REASON TO BELIEVE THAT AN ACTUAL OR POTENTIAL CONFLICT OF INTEREST EXISTS BETWEEN THE CORPORATION AND A COVERED PERSON, THE DISINTERESTED DIRECTORS SHALL BE RESPONSIBLE FOR REVIEWING THE MATTER AND DETERMINING AN APPROPRIATE ORGANIZATIONAL RESPONSE TO PROTECT THE INTERESTS OF THE CORPORATION. THIS RESPONSE MAY INCLUDE, BUT IS NOT NECESSARILY LIMITED TO, FURTHER BOARD REVIEW OR INVOKING THE PROCEDURES DESCRIBED BELOW WITH RESPECT TO A SPECIFIC PROPOSED ACTION OR TRANSACTION. PROCEDURES FOR ADDRESSING CONFLICTS OF INTEREST FOR SPECIFIC TRANSACTIONS: IF IT IS DETERMINED THAT AN ACTUAL OR POTENTIAL CONFLICT OF INTEREST EXISTS BETWEEN THE INTERESTS OF THE CORPORATION AND A COVERED PERSON WITH RESPECT TO A SPECIFIC PROPOSED ACTION OR TRANSACTION, THE CORPORATION REFRAINS FROM THE PROPOSED ACTION OR TRANSACTION UNTIL SUCH TIME AS THE PROPOSED ACTION OR TRANSACTION HAS BEEN APPROVED BY THE DISINTERESTED DIRECTORS. THE FOLLOWING PROCEDURES APPLY: - A COVERED PERSON WHO HAS AN ACTUAL OR POTENTIAL CONFLICT OF INTEREST WITH RESPECT TO A PROPOSED ACTION OR TRANSACTION OF THE CORPORATION WILL NOT PARTICIPATE IN ANY WAY OR BE PRESENT DURING THE DELIBERATIONS AND DECISION MAKING OF THE CORPORATION WITH RESPECT TO SUCH ACTION OR TRANSACTION. THE COVERED PERSON MAY, UPON REQUEST, BE AVAILABLE TO ANSWER QUESTIONS OR PROVIDE MATERIAL FACTUAL INFORMATION ABOUT THE PROPOSED ACTION OR TRANSACTION PRIOR TO ANY DELIBERATION ON THE PROPOSED ACTION OR TRANSACTION; HOWEVER, A COVERED PERSON IS PROHIBITED FROM IMPROPERLY INFLUENCING THE DELIBERATION OR VOTING ON THE PROPOSED ACTION OR TRANSACTION GIVING RISE TO THE ACTUAL OR POTENTIAL CONFLICT. -THE DISINTERESTED DIRECTORS MAY APPROVE THE PROPOSED ACTION OR TRANSACTION UPON FINDING THAT IT IS IN THE BEST INTERESTS OF THE CORPORATION. THE DISINTERESTED DIRECTORS CONSIDER WHETHER THE TERMS OF THE PROPOSED ACTION OR TRANSACTION ARE FAIR, REASONABLE AND IN THE CORPORATION'S BEST INTEREST. WITH RESPECT TO ANY RELATED PARTY TRANSACTION IN WHICH A RELATED PARTY HAS A SUBSTANTIAL FINANCIAL INTEREST, THE DISINTERESTED DIRECTORS, PRIOR TO ENTERING INTO THE TRANSACTION, CONSIDER ALTERNATIVE TRANSACTIONS TO THE EXTENT AVAILABLE. - APPROVAL BY THE DISINTERESTED DIRECTORS ARE BY VOTE OF A MAJORITY OF THE DISINTERESTED DIRECTORS IN ATTENDANCE AT A MEETING AT WHICH A QUORUM OF THE BOARD IS PRESENT. VIOLATIONS OF CONFLICT OF INTEREST POLICY: IF THE BOARD HAS REASON TO BELIEVE THAT A COVERED PERSON HAS FAILED TO DISCLOSE AN ACTUAL OR POTENTIAL CONFLICT OF INTEREST, IT INFORMS THE PERSON OF THE BASIS FOR SUCH BELIEF AND AFFORD THE PERSON AN OPPORTUNITY TO EXPLAIN THE ALLEGED FAILURE TO DISCLOSE. IF, AFTER HEARING THE RESPONSE OF THE COVERED PERSON AND MAKING SUCH FURTHER INVESTIGATION AS MAY BE WARRANTED IN THE CIRCUMSTANCES, THE BOARD DETERMINES THAT THE COVERED PERSON HAS IN FACT FAILED TO DISCLOSE AN ACTUAL OR POSSIBLE CONFLICT OF INTEREST, IT TAKES APPROPRIATE DISCIPLINARY AND CORRECTIVE ACTION. ANY RELATED PARTY TRANSACTION FOUND TO BE IN VIOLATION OF THE CONFLICT OF INTEREST POLICY IS VOIDABLE AT THE DISCRETION OF THE BOARD. |
| FORM 990, PART VI, SECTION C, LINE 19 | GOVERNING DOCUMENTS, CONFLICT OF INTEREST POLICIES, AND FINANCIAL STATEMENTS CAN BE OBTAINED UPON REQUEST. HOWEVER CURRENT TAX LAW DOES NOT REQUIRE THESE DOCUMENTS BE PROVIDED TO THE PUBLIC. |
| FORM 990, PART IX, LINE 11G | CONSULTING SERVICES: PROGRAM SERVICE EXPENSES 1,155,540. MANAGEMENT AND GENERAL EXPENSES 0. FUNDRAISING EXPENSES 0. TOTAL EXPENSES 1,155,540. |
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