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 | |||||
| (A)
TUFTS ASSOCIATED HEALTH MAINTENANCE ORGANIZATION INC |
042674079 | 5 | Yes | 0 | 0 | |
|
Total 1
|
0 | 0 | ||||
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 grant.") .. | ||||||
| 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) 2020 | (b) 2021 | (c) 2022 | (d) 2023 | (e) 2024 | (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) 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) |
||||
| 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 | ||||
|
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) |
||||
| 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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| FORM 990, PART IV, SCHEDULE A, LINE 3B | CONFIRMATION OF SUPPORTED ORGANIZATION QUALIFICATION TUFTS ASSOCIATED HEALTH MAINTENANCE ORGANIZATION, INC. ("TAHMO") FURNISHED A COPY OF ITS DETERMINATION LETTER AND COMPLETED A PRO FORMA SCHEDULE A, PART III CALCULATION. ---------- |
| FORM 990, PART IV, SCHEDULE A, LINE 3C | DETAIL REGARDING USE OF SUPPORT POINT32HEALTH FOUNDATION (THE "FOUNDATION") INVESTS IN COMMUNITIES THROUGH GRANTMAKING TO NONPROFIT ORGANIZATIONS ON BEHALF OF TAHMO. THE FOUNDATION WORKS WITH COMMUNITIES TO SUPPORT, ADVOCATE AND ADVANCE HEALTHIER LIVES FOR EVERYONE. THE FOUNDATION'S PROCESS IS COMPREHENSIVE AND THOROUGH. IT IS BASED ON BUILDING DEEPER RELATIONSHIPS IN COMMUNITY. THE GRANTS TEAM UTILIZES MULTIPLE APPROACHES FOR ENGAGING PROSPECTIVE AND CURRENT GRANTEES. THESE INCLUDE REGULAR PARTICIPATION IN COMMUNITY GATHERINGS, COALITIONS AND COLLABORATIVES, OPEN "OFFICE HOURS" WHERE NONPROFITS CAN SCHEDULE TIME WITH FOUNDATION STAFF, AS WELL AS PROACTIVE OUTREACH TO COMMUNITY ORGANIZATIONS. THESE MEETINGS AND CONVERSATIONS SERVE AS THE BASIS FOR DETERMINING ALIGNMENT TO THE FOUNDATION'S MISSION AND PURPOSE AND MAY LEAD TO GRANTS BASED ON THAT ALIGNMENT. AN INDEPENDENT THIRD PARTY VERIFIES 501(C)(3) STATUS. FOUNDATION STAFF EVALUATES EACH ORGANIZATION'S ABILITY TO MANAGE A FOUNDATION GRANT. ONCE A GRANT IS MADE, COMMUNITY ORGANIZATIONS SHARE PERIODIC UPDATES AND/OR REPORTS WITH THE FOUNDATION TO HELP THE FOUNDATION TEAM LEARN FROM THE GRANTEE'S EXPERIENCE AND PROGRESS OF THE FUNDED WORK. GRANTS LESS THAN $100,000 ARE APPROVED BY STAFF. FOUNDATION STAFF CAN ONLY AUTHORIZE UP TO 25% OF THE TOTAL GRANTS BUDGET. GRANTS MORE THAN $100,000 ARE VOTED ON BY THE FOUNDATION BOARD OF DIRECTORS. ---------- |
| FORM 990, PART IV, SCHEDULE A, LINE 6 | DETAIL REGARDING SUPPORT PROVIDED NO MONETARY SUPPORT IS PROVIDED TO TAHMO. THE FOUNDATION INVESTS IN THE COMMUNITY THROUGH GRANTMAKING ON BEHALF OF TAHMO TO SUPPORT, ADVOCATE AND ADVANCE HEALTHIER LIVES FOR EVERYONE. THE FOUNDATION PROVIDES GRANTS TO OTHER SECTION 501(C)(3) ORGANIZATIONS IN THE COMMUNITY TO SUPPORT BOTH THE EXEMPT PURPOSE OF TAHMO AND FULFILL THE FOUNDATION'S EXEMPT PURPOSE. ADDITIONALLY, THE FOUNDATION ALSO SUPPORTS COMMUNITIES THROUGH THE COMPANY'S CORPORATE CITIZENSHIP PROGRAM. CORPORATE CITIZENSHIP INCLUDES VOLUNTEERING IN COMMUNITY THROUGH STRUCTURED ACTIVITIES; A MATCH PROGRAM THAT DOUBLES CONTRIBUTIONS MADE TO ELIGIBLE NONPROFITS BY EMPLOYEES, POINT32HEALTH AND FOUNDATION BOARD MEMBERS; AND ENTERPRISE-WIDE WORKPLACE GIVING OPPORTUNITIES. |
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| Return Reference | Explanation |
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| FORM 990, PART III, LINE 1 | DETAIL REGARDING THE ORGANIZATION'S MISSION TO PROVIDE COMMUNITY BENEFITS ABOVE AND BEYOND ITS REGULAR LINES OF BUSINESS, TUFTS ASSOCIATED HEALTH MAINTENANCE ORGANIZATION, INC. ("TAHMO") ESTABLISHED THE POINT32HEALTH FOUNDATION, INC.(THE "FOUNDATION"), A 501(C)(3) CHARITABLE AND SUPPORTING ORGANIZATION OF TAHMO. THE FOUNDATION'S MISSION AND PURPOSE IS ALIGNED WITH THAT OF TAHMO'S PARENT, POINT32HEALTH, INC. ("POINT32HEALTH"): TO SUPPORT, ADVOCATE AND ADVANCE HEALTHIER LIVES FOR EVERYONE. THE FOUNDATION ACHIEVES THIS MISSION PRIMARILY THROUGH COMMUNITY INVESTMENTS, COMMUNITY ENGAGEMENT AT KEY STAKEHOLDER "TABLESCONVENING ACTIVITIES FOCUSED ON HEALTHY LIVING WITH AN EMPHASIS ON OLDER PEOPLE AND COMMUNITY BUILDING. THE FOUNDATION LEVERAGES POINT32HEALTH'S GREATEST ASSET-ITS PEOPLE-IN A DELIBERATE WAY ON BEHALF OF COMMUNITY. COMMUNITY INFORMS OUR WORK. THE FOUNDATION COLLABORATES WITH OLDER PEOPLE, COMMUNITY LEADERS, CIVIC ORGANIZATIONS, GOVERNMENT AGENCIES AND NONPROFITS TO SUPPORT COMMUNITY SOLUTIONS. THE FOUNDATION EMPHASIZES INCLUSION AND COLLABORATION ACROSS SECTORS. THE FOUNDATION IS AN ADVOCATE TO ADVANCE POLICIES AND BEST PRACTICES SHAPED BY THOSE MOST AFFECTED BY THE ISSUES; A CATALYST ACCELERATING CHANGES THAT IMPROVE ACCESS AND SERVICES; AND A CONVENER CREATING OPPORTUNITIES AND SPACE FOR ORGANIZATIONS/LEADERS TO WORK TOGETHER. WHEN CONTEMPLATING FUNDING IN COMMUNITIES, THE FOUNDATION CONSIDERS THE FACETS THAT CONTRIBUTE TO A THRIVING COMMUNITY INCLUDING, BUT NOT LIMITED TO, ACCESS TO AFFORDABLE, NUTRITIOUS FOOD, HOUSING, TRANSPORTATION, SOCIAL PARTICIPATION, OUTDOOR SPACES AND BUILDINGS, RESPECT, CIVIC PARTICIPATION AND EMPLOYMENT, COMMUNICATIONS, AND INFORMATION. THIS APPROACH RECOGNIZES THE WIDE RANGE OF RESOURCES THAT CAN BE LEVERAGED IN COMMUNITY TO ADDRESS FOOD INSECURITY, PROMOTE MENTAL HEALTH AND ADVANCE SOLUTIONS TO ISSUES FACING OLDER PEOPLE, AS INFORMED BY OLDER PEOPLE THEMSELVES. THE FOUNDATION RESPONDS FLEXIBLY TO COMMUNITY NEEDS AND PREFERENCES, AND FOLLOWS COMMUNITY'S LEAD. HEALTHY AGING EFFORTS RESPECT OLDER PEOPLE'S DECISIONS AND LIFESTYLE CHOICES, AND PROMOTE OLDER PEOPLE'S INCLUSION IN AND CONTRIBUTION TO ALL AREAS OF COMMUNITY LIFE. THE FOUNDATION CONSIDERS WHAT IT TAKES TO BUILD CAPACITY AND SYSTEMS TO ADDRESS THE UNIQUE NEEDS IN COMMUNITIES FACING BARRIERS AND HONORS COMMUNITY WORK ALREADY IN SERVICE TO COMMUNITY. THE FOUNDATION STRATEGICALLY ENCOURAGES MORE COLLABORATION FOR BROADER IMPACT AND SUPPORTS ORGANIZATIONS SHARING BEST PRACTICES THAT LEAD TO IMPROVED COMMUNITY OUTCOMES AND SYSTEMIC CHANGE. IN 2024, THE FOUNDATION MADE 162 GRANTS TOTALING MORE THAN $8 MILLION TO NONPROFIT ORGANIZATIONS WORKING IN THESE AREAS. ---------- |
| FORM 990, PART III, LINE 4D | DESCRIPTION OF ALL OTHER GRANT PROGRAMS TRANSITION GRANTS: ACCESS TO HEALTHY FOOD: IN 2024, THE FOUNDATION WAS IN THE FINAL YEAR OF A THREE-YEAR TRANSITION FROM ITS EXISTING WORK TO FOCUS ON EQUITY IN AGING, WHICH BEGINS IN EARNEST IN 2025. THESE FINAL, ONE-YEAR TRANSITION GRANTS RECOGNIZE EXISTING GRANTEES' LEADERSHIP IN ADVANCING ACCESS TO HEALTHY FOOD. WHILE THESE GRANTEES' WORK NO LONGER ALIGNS WITH THE FOUNDATION'S NEW EQUITY IN AGING FOCUS, THE GRANTS MADE IN 2024 ACKNOWLEDGE THEIR IMPORTANT WORK AND THAT FOUNDATION RESOURCES MAY NOT BE AVAILABLE FOR FUTURE SUPPORT. THIS ALSO ALIGNS WITH THE FOUNDATION'S TRUST-BASED APPROACH. TRANSITION GRANTS: MENTAL HEALTH SUPPORT: IN 2024, THE FOUNDATION WAS IN THE FINAL YEAR OF A THREE-YEAR TRANSITION FROM ITS EXISTING WORK TO FOCUS ON EQUITY IN AGING, WHICH BEGINS IN EARNEST IN 2025. THESE FINAL, ONE-YEAR TRANSITION GRANTS RECOGNIZE EXISTING GRANTEES' LEADERSHIP IN ADVANCING MENTAL HEALTH ACROSS THE LIFESPAN. WHILE THESE GRANTEES' WORK NO LONGER ALIGNS WITH THE FOUNDATION'S EQUITY IN AGING FOCUS, THE GRANTS ACKNOWLEDGE THEIR IMPORTANT WORK AND THAT FOUNDATION RESOURCES MAY NOT BE AVAILABLE FOR FUTURE SUPPORT. THIS ALSO ALIGNS WITH THE FOUNDATION'S TRUST-BASED APPROACH. COLLEAGUE RESOURCE GROUPS GRANTS: POINT32HEALTH COLLEAGUE RESOURCE GROUPS ("CRGS") ARE OPEN TO ALL COLLEAGUES. CRG MEMBERS HELP SHAPE AN INCLUSIVE WORK ENVIRONMENT, CREATE SPACE FOR DIALOGUE AND LEARNING ACROSS DIFFERENCES, SHARE BUSINESS INSIGHTS, AND PROVIDE DEVELOPMENT, NETWORKING AND MENTORING OPPORTUNITIES. Thirty-two PERCENT OF POINT32HEALTH COLLEAGUES ARE MEMBERS OF CRGS. EACH CRG (A TOTAL OF 9) IS ELIGIBLE TO SELECT AN ORGANIZATION THAT IS ALIGNED WITH ITS AFFINITY TO RECEIVE A $5,000 GRANT. A TOTAL OF $45,000 WAS ALLOCATED TO THESE GRANTS FOR 2024. ---------- |
| FORM 990, PART VI, LINE 2 | DETAIL OF FAMILY OR BUSINESS RELATIONSHIPS THE FOLLOWING INDIVIDUALS SERVED ON THE BOARDS OR WERE AN OFFICER OR KEY EMPLOYEE OF ONE OR MORE FOR-PROFIT-ORGANIZATIONS AFFILIATED WITH THE POINT32HEALTH FOUNDATION FROM 1/1/2024 TO 12/31/2024: CAIN HAYES, DIRECTOR; PRESIDENT & CEO (END 9/12/2024) TOM MALONEY, CLERK/SECRETARY (START 1/24) ---------- |
| FORM 990, PART VI, LINE 3 | DESCRIPTION OF MANAGEMENT ARRANGEMENT THE FOUNDATION IS A SUPPORTING ORGANIZATION OF TAHMO. TAHMO AND ITS SUBSIDIARY, POINT32HEALTH SERVICES, INC. ("P32HS"), PROVIDE ADMINISTRATIVE AND MANAGEMENT SERVICES TO THE FOUNDATION. ---------- |
| FORM 990, PART VI, LINE 4 | CURRENT YEAR CHANGES TO GOVERNING DOCUMENT THE BYLAWS WERE AMENDED WITH RESPECT TO: a. ALLOWING THE EX OFFICIO TAHMO CEO WHO SERVES AS MANAGEMENT DIRECTOR TO FILL THE REQUIREMENT THAT AT LEAST ONE DIRECTOR SERVE ON THE BOARD IF NEEDED. b. REPLACING THE POSITION OF CO-CHAIR WITH VICE CHAIR. c. REMOVING THE BOARD CHAIR TERM LIMIT. ---------- |
| FORM 990, PART VI, LINE 6A & 7A | MEMBERS TAHMO AS THE SOLE CORPORATE MEMBER OF THE FOUNDATION, ELECTS THE MEMBERS OF THE FOUNDATION'S GOVERNING BODY. ---------- |
| FORM 990, PART VI, LINE 7B | DESCRIPTION OF CLASSES OF PERSONS, DECISIONS REQUIRING APPROVAL & TYPE OF VOTING RIGHTS TAHMO AS THE SOLE CORPORATE MEMBER OF THE FOUNDATION, HAS THE RIGHT TO MAKE CERTAIN DECISIONS REGARDING THE FOUNDATION, AND IS REQUIRED TO APPROVE ANY CHANGES TO THE FOUNDATION'S BYLAWS. ---------- |
| FORM 990, PART VI, LINE 8B | CONTEMPORANEOUS BOARD MEETING DOCUMENTATION THE FILING ORGANIZATION CURRENTLY DOES NOT HAVE ANY STANDING COMMITTEES. IF IN THE FUTURE THE ORGANIZATION WERE TO HOLD COMMITTEE MEETINGS, THEN THE ORGANIZATION WOULD ALSO CONTEMPORANEOUSLY DOCUMENT COMMITTEE MEETINGS HELD AND WRITTEN ACTIONS UNDERTAKEN BY ITS COMMITTEES. ---------- |
| FORM 990, PART VI, LINE 11B | PROCESS USED TO REVIEW THE FORM 990 THIS FORM 990 WAS PREPARED BY THE ORGANIZATION'S EXTERNAL ACCOUNTANT, REVIEWED BY P32H'S FINANCE DEPARTMENT AND CERTAIN SECTIONS ARE REVIEWED FOR INPUT BY SUBJECT MATTER PERSONNEL IN OTHER DEPARTMENTS THROUGHOUT THE ORGANIZATION. THE FORM 990 IS PROVIDED TO THE BOARD OF DIRECTORS BEFORE FILING. ---------- |
| FORM 990, PART VI, LINE 12C | MONITORING & ENFORCEMENT OF COMPLIANCE WITH CONFLICT OF INTEREST POLICY: THE P32H'S CONFLICT OF INTEREST ("COI") POLICY AND PROCEDURES ("P&P") APPLIES TO THE FILING COMPANY AS A SUBSIDIARY ORGANIZATION. P32H'S COI P&P IS REVIEWED ANNUALLY, REVISED AS NEEDED AND APPROVED UPON MATERIAL REVISIONS. THE POLICY REQUIRES ALL EMPLOYEES, INCLUDING THE PRESIDENT AND CEO AND GOVERNING BODY MEMBERS TO COMPLY WITH THE COI POLICY AND PROCESSES. ALL EMPLOYEES RECEIVE ANNUAL COMPLIANCE TRAINING WHICH INCLUDE EXPECTATIONS RELATED TO FOLLOWING THE COI P&P. THE COI P&P REQUIRES THE OFFICERS, KEY EMPLOYEES AND BOARD OF DIRECTORS OF THE TAX-EXEMPT ENTITIES TO COMPLETE AND SUBMIT AN ANNUAL DISCLOSURE SURVEY AND STATEMENT TO THE CHIEF LEGAL OFFICER ("CLO") OR DESIGNEE IN THE LEGAL DEPARTMENT, LISTING ANY OUTSIDE RELATIONSHIPS, INCLUDING FINANCIAL AND/OR BOARD RELATIONSHIPS THAT THEY OR A FAMILY MEMBER HAVE WITH P32H'S (OR ITS SUBSIDIARIES) SUPPLIERS, PURCHASERS, PROVIDERS AND/OR COMPETITORS. ADDITIONALLY, P32H REQUIRES EXECUTIVE MANAGEMENT AND SENIOR MANAGEMENT (AS DEFINED IN THE COI POLICY) TO COMPLETE AND SUBMIT AN ANNUAL DISCLOSURE SURVEY AND STATEMENT TO THE CHIEF COMPLIANCE OFFICER OR DIRECTOR, CORPORATE COMPLIANCE. BY COMPLETING THE ANNUAL DISCLOSURE STATEMENT, THESE INDIVIDUALS ACKNOWLEDGE THE P32H COI P&P. ALL EMPLOYEES ARE REQUIRED TO REPORT THE OFFER BY AN OUTSIDE ENTITY OF GIFTS OVER $250, HONORARIA OR COVERAGE OF BUSINESS EXPENSES, OR OTHER EVENTS OR RELATIONSHIPS THAT MAY BE PERCEIVED AS CONFLICTS TO THE CHIEF COMPLIANCE OFFICER, DIRECTOR, CORPORATE COMPLIANCE OR DESIGNEE AND THE EMPLOYEE'S MANAGEMENT. BOTH MUST APPROVE BEFORE ACCEPTANCE IS ALLOWED. THERE ARE PROTOCOLS AND PROCESSES TO REVIEW ANY DISCLOSURE THAT MIGHT BE A POTENTIAL CONFLICT OF INTEREST. BOARD MEMBERS, OFFICERS, AND KEY EMPLOYEES' RESPONSES TO THE DISCLOSURE SURVEY AND STATEMENT ARE REVIEWED BY THE CLO, WHO WILL REVIEW THE SELF-DISCLOSURE WITH THE CHAIR OF THE GOVERNANCE COMMITTEE OF THE BOARD OF DIRECTORS Of P32H AND DETERMINE EXPECTATIONS AND RECOMMENDED ACTIONS IF NEEDED. A SUMMARY REPORT OF ALL DISCLOSED ACTUAL OR POTENTIAL CONFLICTS ALONG WITH ANY RECOMMENDED ACTIONS TO ADDRESS A DISCLOSED ACTUAL OR POTENTIAL CONFLICT IS REVIEWED AND APPROVED BY THE GOVERNANCE COMMITTEE AND THE COMMITTEE'S REVIEW/FINDINGS ARE REPORTED TO THE FULL BOARD. THE CLO COMMUNICATES THE RECOMMENDED ACTIONS TO INDIVIDUAL SURVEY RECIPIENTS. THE CHIEF COMPLIANCE OFFICER IS CONSULTED AND INFORMED OF THE DECISIONS MADE BY THE CLO OR LEGAL DESIGNEE. EXECUTIVE MANAGEMENT AND SENIOR MANAGEMENT'S RESPONSES TO THE DISCLOSURE SURVEY AND STATEMENT ARE REVIEWED BY THE DIRECTOR, CORPORATE COMPLIANCE, LEGAL, AND CHIEF COMPLIANCE OFFICER, WHO WILL REPORT TO THE CLO ANY POTENTIAL CONFLICTS ALONG WITH ANY RECOMMENDED ACTIONS TO ADDRESS THE POTENTIAL CONFLICT, IF NECESSARY. RECOMMENDED ACTIONS/EXPECTATIONS ARE COMMUNICATED BY THE DIRECTOR, CORPORATE COMPLIANCE, LEGAL, AND CHIEF COMPLIANCE OFFICER TO IMPACTED INDIVIDUALS. FOR CONFLICT DISCLOSURES INVOLVING THE CHIEF COMPLIANCE OFFICER, THE CLO WILL MAKE THE FINAL DETERMINATION. ANY ACTUAL OR POTENTIAL CONFLICT OF INTEREST THAT ARISES AFTER COMPLETION OF THE DISCLOSURE SURVEY WILL FOLLOW THE SAME REVIEW PROCESS. ---------- |
| FORM 990, PART VI, LINE 13 | WRITTEN WHISTLEBLOWER/NON-RETALIATION POLICY THE FILING ORGANIZATION IS SUBJECT TO THE WRITTEN WHISTLEBLOWER/NON-RETALIATION POLICY WITHIN THE CODE OF CONDUCT THAT WAS APPROVED BY THE BOARD OF DIRECTORS OF P32H. ---------- |
| FORM 990, PART VI, LINE 14 | WRITTEN DOCUMENT RETENTION POLICY THE FILING ORGANIZATION IS SUBJECT TO THE WRITTEN DOCUMENT RETENTION POLICY AND RECORD RETENTION SCHEDULE OF P32H. ---------- |
| FORM 990, PART VI, LINE 15A & 15B | COMPENSATION REVIEW AND APPROVAL THE FOUNDATION DOES NOT HAVE ANY EMPLOYEES. THE EMPLOYEES OF RELATED ORGANIZATIONS PROVIDE SERVICES TO THE FOUNDATION. THE PRESIDENT, CLERK/SECRETARY, AND TREASURER ARE COMPENSATED SOLELY FOR THEIR CAPACITY AS EMPLOYEES OF P32HS. A PORTION OF THEIR COMPENSATION IS REMUNERATION FOR DUTIES RELATED TO THE FOUNDATION. ---------- |
| FORM 990, PART VII, LINE 19 | PROCESS FOR MAKING DOCUMENTS AVAILABLE TO THE PUBLIC THE ORGANIZATION'S GOVERNING DOCUMENTS, COI POLICY, AND ANNUAL FINANCIAL REPORT AND QUARTERLY FINANCIAL UPDATES ARE MADE AVAILABLE TO THE PUBLIC UPON REQUEST. ---------- |
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