2021-08-05T16:51:49-05:00 2020-09-30 381357951 PLANTE & MORAN PLLC 10 S RIVERSIDE PLAZA 9TH FLOOR CHICAGO IL 60606 990 2019-10-01 363385581 COVENANT LIVING AT WINDSOR PARK COVE 6306824377 124 WINDSOR PARK DRIVE CAROL STREAM IL 60188 JEAN E JUSTIE CFO 7738782294 2021-07-20 1 DAVID LOWENTHAL P00378651 3122071040 2021-07-20 2019 2022-09-23 18:48:47Z TERRI CUNLIFFE C/O CLCS - 5700 OLD ORCHARD RD SKOKIE IL 60077 30802056 0 2650 X WWW.COVLIVING.ORG X 1985 IL CARE FOR SENIOR ADULTS. 18 16 381 16 0 0 258018 1100105 18535025 27950647 755985 1537988 111641 202087 19660669 30790827 0 0 0 0 7755426 12236730 0 0 37765 11396028 17680733 19151454 29917463 509215 873364 79576569 80919877 111605266 111819620 -32028697 -30899743 X AS A MINISTRY OF THE EVANGELICAL COVENANT CHURCH, COVENANT LIVING COMMUNITIES AND SERVICES CELEBRATES GOD'S GIFT OF LIFE IN CHRISTIAN COMMUNITY. WE FOLLOW THE GREAT COMMANDMENT TO LOVE AND SERVE GOD AND ONE ANOTHER AS TAUGHT BY JESUS CHRIST. (SEE SCHEDULE O) 0 0 12148344 15841583 RESIDENTIAL LIVING:THE NUMBER OF PERSONS WHO BENEFITED FROM THE SERVICES WE PROVIDED FOR THE YEAR ENDED SEPTEMBER 30, 2020 WERE AS FOLLOWS:THERE WERE A TOTAL OF 389 RESIDENTS, OCCUPYING 282 APARTMENTS AT 09/30/2020. RESIDENCY FOR THE FISCAL YEAR TOTALED 143,930 RESIDENT DAYS. 2588408 2535697 ASSISTED LIVING AND ASSISTED LIVING DEMENTIA:THE NUMBER OF PERSONS WHO BENEFITED FROM THE SERVICES WE PROVIDED FOR THE YEAR ENDED SEPTEMBER 30, 2020 WERE AS FOLLOWS:THERE WERE A TOTAL OF 30 ASSISTED LIVING RESIDENTS AT 09/30/2020. ASSISTED LIVING RESIDENCY FOR THE FISCAL YEAR TOTALED 12,394 PATIENT DAYS. 8242418 9775454 SKILLED NURSING:THE NUMBER OF PERSONS WHO BENEFITED FROM THE SERVICES WE PROVIDED FOR THE YEAR ENDED SEPTEMBER 30, 2020 WERE AS FOLLOWS:THERE WERE A TOTAL OF 59 SKILLED CARE PATIENTS AT 09/30/2020. SKILLED CARE RESIDENCY FOR THE FISCAL YEAR TOTALED 21,635 PATIENT DAYS. THE ORGANIZATION WAS INVOLVED IN VARIOUS COMMUNITY BENEFITS PROJECTS THAT INCLUDE THE FOLLOWING:STAFF MEMBERS VOLUNTEERED A TOTAL OF 252 HOURS OF THEIR TIME TO VARIOUS ACTIVITIES/EVENTS IN THE COMMUNITY (EQUIVALENT TO $13,350)RESIDENTS VOLUNTEERED A TOTAL OF 6,275 HOURS OF THEIR TIME TO VARIOUS ACTIVITIES/EVENTS IN THE COMMUNITYPROVIDED SPACE USAGE FOR SMALL (UNDER 35 PEOPLE) TO LARGE GROUPS (75+ PEOPLE) (EQUIVALENT TO $67,952)HOSTED SMALL TO LARGE SCALE COMMUNITY EVENTS (EQUIVALENT TO $497,888)MONETARY DONATIONS TO VARIOUS INDIVIDUALS AND ORGANIZATIONS ($13,250 IN TOTAL)IN-KIND DONATIONS TO VARIOUS INDIVIDUALS AND ORGANIZATIONS ($2,360 IN ESTIMATED VALUE) 22979170 1 1 0 1 0 0 0 0 1 1 1 1 0 0 1 0 0 1 0 0 0 0 0 0 1 0 0 0 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0 1 54 0 1 381 1 0 0 0 0 0 1 1 0 0 0 0 0 0 X 18 16 0 1 0 0 1 0 1 1 1 1 0 1 1 1 1 1 1 0 0 0 IL X JEAN E JUSTIE 7738782294 C/O CLCS 5700 OLD ORCHARD RD SKOKIE IL 60077 TERRI S CUNLIFFE DIRECTOR/CLCS PRESIDENT/CEO 1.00 58.00 X X 0 686410 104585 JODY HOLT - END 33120 CFO/TREASURER/ASST SECRETARY 1.00 58.00 X 0 449556 72415 ROGER OXENDALE - END 83120 DIRECTOR/CMB PRESIDENT 0.10 41.80 X 0 402512 32472 JOSHUA ANDERSON-END 4519 REGIONAL DIRECTOR OF OPERATIONS 1.00 43.00 X 0 377151 30351 DAVID G ERICKSON SR VP & GEN COUNSEL/ASST SECRETARY 1.00 58.00 X 0 318337 76085 WILLIAM RABE SR VP ENTERPRISE OPS/ASST SECRETARY 1.00 58.00 X 0 314888 45081 BARBARA BEAKE - END 81420 REGIONAL DIRECTOR OF OPERATIONS 1.00 47.00 X 0 191731 49356 SCOTT MOORE - END 51019 EXEC VP/CAMPUS OPERATIONS 1.00 50.00 X 0 211610 15290 JOHN WENRICH DIRECTOR/EX-OFFICIO 0.10 41.90 X 0 127242 96137 CORY STERN INTERIM FINANCE LEAD/TREASURER 1.00 58.00 X 0 193894 27786 JANET CANNON DIRECTOR OF SALES 40.00 0.00 X 128026 0 22278 BINDU ZACHARIAS DIRECTOR OF NURSING 40.00 0.00 X 115363 0 34616 LYNN BLACKBURN HEALTHCARE ADMINISTRATOR 40.00 0.00 X 120215 0 26900 KIM HAMBURG SALES REPRESENTATIVE 40.00 0.00 X 109041 0 15902 REBEKAH ERICKSON ASSISTANT SECRETARY 1.00 58.00 X 0 97105 10052 MATTHEW MANLOVE DIRECTOR/CHAIR 0.10 1.90 X X 0 0 0 SARAH BENTLEY DIRECTOR/SECRETARY 0.10 1.90 X X 0 0 0 JANET CREANEY DIRECTOR/VICE CHAIR 0.10 1.90 X X 0 0 0 MARK C EASTBURG CHAIR - PART YEAR/DIRECTOR 0.10 1.90 X X 0 0 0 KARA E DAVIS MD DIRECTOR 0.10 1.90 X 0 0 0 MARY PALMER DIRECTOR 0.10 1.90 X 0 0 0 PAMELA CHRISTENSEN-END 63020 DIRECTOR 0.10 1.90 X 0 0 0 KURT KINCANON DIRECTOR 0.10 1.90 X 0 0 0 ROBERT MARTIN DIRECTOR 0.10 1.90 X 0 0 0 ANDREW VANOVER DIRECTOR 0.10 1.90 X 0 0 0 DALE GLEN RINARD-END 63020 DIRECTOR 0.10 1.90 X 0 0 0 RICHARD P NELSON DIRECTOR/EX-OFFICIO 0.10 1.90 X 0 0 0 KATHY BUETTNER DIRECTOR 0.10 1.90 X 0 0 0 LORENE FLEWELLEN DIRECTOR 0.10 1.90 X 0 0 0 JOHN FREDRICKSON DIRECTOR 0.10 1.90 X 0 0 0 DAVID KIM DIRECTOR 0.10 1.90 X 0 0 0 LOANN PETERSON DIRECTOR 0.10 1.90 X 0 0 0 DIXIE REPPE DIRECTOR 0.10 1.90 X 0 0 0 JEAN E JUSTIE-START 92120 CFO 1.00 58.00 X 0 0 0 472645 3370436 659306 4 0 1 0 SNOWY NIGHT SIERRA OWENS 26W152 GRAND AVE WHEATON IL 60187 GROUND MAINTENANCE 1345768 HEALTHPRO REHABILITATION PO BOX 69268 BALTIMORE MD 21264 THERAPY 1071168 SODEXO INC & AFFILIATES PO BOX 360170 PITTSBURG PA 15251 DINING SERVICES 565592 QUALITY PLUS FLOORING INC 140 N WESTERN AVE CARPENTERSVILLE IL 60110 FLOORING 429339 MOOSEHEAD INDUSTRIES INC 6382 TWIN OAKS LN LISLE IL 60532 CONSTRUCTION 234440 7 135280 423157 541668 1100105 ROUTINE SERVICES 623000 16943609 16943609 ENTRANCE FEE 623000 5301118 5301118 ANCILLARY SERVICES 623000 3035154 3035154 MEDICARE/MEDICAID 623000 2457239 2457239 MEALS 623000 213527 213527 27950647 1212382 1212382 326474 0 868 326474 -868 325606 325606 10361 135280 10361 0 APARTMENT UPGRADES 623000 114631 114631 SUPPORT SERVICES 623000 27703 27703 SERVICES TO RESIDENTS 623000 23383 23383 36370 36370 202087 30790827 28152734 0 1537988 9796666 8071254 1720921 4491 270420 220213 49091 1116 1437270 1173725 260497 3048 732374 565936 160339 6099 146055 146055 50751 50751 1478 1478 1054 1054 2220778 2067390 153388 147619 7744 139779 96 1527833 1260002 266815 1016 661103 1334 659769 1671967 1262267 409700 45798 8758 37040 47733 7274 40459 2401740 1844742 553966 3032 5166960 3968667 1191771 6522 327132 327132 RELATED PARTY ACTIVITY 1760043 58137 1701906 DINING SERVICES 1128519 1128519 MAINT. FOR RESIDENTS 738210 738210 BAD DEBT 108481 108481 -472521 121811 -606677 12345 29917463 22979170 6900528 37765 129829 34604 20366 11746 75248 51229 1072985 1389720 154353 117012 98168217 64442327 32725679 33725890 37636606 34940611 5876143 8779144 1885360 1869921 79576569 80919877 485261 563822 30593528 30898523 48722797 47714709 221618 135059 1671000 31582062 30836507 111605266 111819620 X -34015410 -32902630 1986713 2002887 -32028697 -30899743 79576569 80919877 X 873364 250307 5283 X 0 1 X 1 0 X 352775 538344 1205045 258018 1100105 3454287 23973115 25606043 27125144 18646666 28152734 123503702 24325890 26144387 28330189 18904684 29252839 126957989 0 0 0 126957989 1904668 1667017 896391 685146 1212382 6365604 1904668 1667017 896391 685146 1212382 6365604 11443 10361 21804 26230558 27811404 29226580 19601273 30475582 133345397 0.95210 0.95750 0.04770 0.04240 X SCHEDULE A, PART III, LINE 12, EXPLANATION OF OTHER INCOME: FUNDRAISING INCOME PART III: BECAUSE OF THE SHORT YEAR-END FILING, THE COLUMNS IN SCHEDULE A PART III CORRESPOND TO THE FOLLOWING TAX YEARS: 2015 = FYE 1/31/17 2016 = FYE 1/31/18 2017 = FYE 1/31/19 2018 = SHORT YEAR-END 9/30/19 2019 = FYE 9/30/20 RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 0 0 0 0 0 0 0 0 1 1054 1054 0 PART II-B, LINE 1: A PORTION OF MEMBERSHIP DUES PAID TO LEADING AGE ARE USED FOR LOBBYING PURPOSES 0 1 X 1885360 -15439 1869921 1797063 88297 1885360 1985449 -188386 1797063 1785597 199852 1985449 1624062 161535 1785597 0.00000 1.00000 0.00000 0 1 1 1281659 1281659 66072596 48951420 17121176 24138350 14161024 9977326 6675612 1329883 5345729 33725890 MORTGAGES 136237 F DOMESTIC EQUITY 2823720 F INTERNATIONAL EQUITY 3602007 F HEDGE FUNDS & DERIVATIVES 1435965 F PRIVATE EQUITY 675715 F FIXED INCOME 105500 F 8779144 REFUNDABLE CONTRACT LIABILITIES 12837760 ACCRUED TAXES & EMPLOYEE BENEFITS 364565 INTER-COMPANY ADVANCE ACCOUNTS 16254924 OTHER LIABILITIES 1379258 30836507 PART IV, LINE 2B: RESIDENT ENTRANCE FEE ACCOUNT: PROSPECTIVE RESIDENTS PAY AN APPLICATION FEE DEPOSIT WHICH IS CARRIED IN AN ESCROW ACCOUNT. AT MOVE IN, THE DEPOSIT IS APPLIED AGAINST THE TOTAL ENTRANCE FEE AMOUNT AND THE REMAINDER OF THE MONEY IS COLLECTED AND PUT IN THIS ACCOUNT. AT THE END OF THE MONTH THE RESIDENT HAS MOVED IN, ALL MONEY IS TRANSFERRED OUT OF THE ESCROW ACCOUNT. BENEFIT GALA 145641 135280 10361 6742 800 2819 145641 135280 10361 6742 800 2819 10361 0 1 1 0 0 0 0 0 1 0 TERRI S CUNLIFFE DIRECTOR/CLCS PRESIDENT/CEO 0 471251 0 149048 0 66111 0 83455 0 23721 0 793586 0 0 JODY HOLT - END 33120 CFO/TREASURER/ASST SECRETARY 0 299125 0 107712 0 42719 0 46829 0 26065 0 522450 0 0 ROGER OXENDALE - END 83120 DIRECTOR/CMB PRESIDENT 0 299074 0 0 0 103438 0 8400 0 33765 0 444677 0 0 JOSHUA ANDERSON-END 4519 REGIONAL DIRECTOR OF OPERATIONS 0 45549 0 34827 0 296775 0 6739 0 24537 0 408427 0 97535 DAVID G ERICKSON SR VP & GEN COUNSEL/ASST SECRETARY 0 265881 0 0 0 52456 0 46166 0 34399 0 398902 0 18563 WILLIAM RABE SR VP ENTERPRISE OPS/ASST SECRETARY 0 214285 0 50694 0 49909 0 34363 0 15271 0 364522 0 0 BARBARA BEAKE - END 81420 REGIONAL DIRECTOR OF OPERATIONS 0 170606 0 5536 0 15589 0 20847 0 28827 0 241405 0 0 SCOTT MOORE - END 51019 EXEC VP/CAMPUS OPERATIONS 0 118604 0 55000 0 38006 0 6181 0 9311 0 227102 0 0 JOHN WENRICH DIRECTOR/EX-OFFICIO 0 127242 0 0 0 0 0 25438 0 70700 0 223380 0 0 CORY STERN INTERIM FINANCE LEAD/TREASURER 0 125102 0 15669 0 53123 0 19468 0 8587 0 221949 0 10523 JANET CANNON DIRECTOR OF SALES 75217 0 41375 0 11434 0 4035 0 18417 0 150478 0 0 0 BINDU ZACHARIAS DIRECTOR OF NURSING 103609 0 7925 0 3829 0 9457 0 25370 0 150190 0 0 0 PART I, LINE 3 SEE SCHEDULE O EXPLANATION FOR FORM 990 PART VI SECTION B LINE 15 FOR THE METHODS USED TO DETERMINE CEO COMPENSATION. THE REVIEW AND APPROVAL PROCESS IS DESIGNED TO SATISFY AND QUALIFY FOR THE REBUTTABLE PRESUMPTION OF REASONABLENESS UNDER THE INTERNAL REVENUE CODE SECTION 4958. PART I, LINES 4A-B LINE 4A: JOSHUA ANDERSON RECEIVED SEVERANCE PAYMENTS TOTALING $150,137 DURING THE TAX YEAR. PAYMENTS ARE MADE IN BIWEEKLY INSTALLMENTS OVER A 12 MONTH PERIOD PER THE AGREEMENT SIGNED BY THE PARTIES ON 12/16/2018. LINE 4B: EXECUTIVE BENEFIT PLAN COVENANT MINISTRIES OF BENEVOLENCE (CMB), A RELATED ORGANIZATION, PROVIDES CERTAIN SUPPLEMENTAL RETIREMENT BENEFITS TO ITS OFFICERS AND KEY EMPLOYEES. THESE BENEFITS ARE PROVIDED THROUGH A NONQUALIFIED DEFERRED COMPENSATION PLAN, UNDER WHICH A PORTION OF THE BENEFITS BEING EARNED ARE SUBJECT TO A "SUBSTANTIAL RISK OF FORFEITURE." THE SUPPLEMENTAL RETIREMENT BENEFITS ARE STRUCTURED TO PROVIDE A RETENTION INCENTIVE THAT HAS BEEN DETERMINED BY THE EXECUTIVE COMPENSATION COMMITTEE OF CMB'S BOARD ("COMMITTEE") TO BE OF SUBSTANTIAL VALUE TO THE ORGANIZATION. THE COMMITTEE APPROVES ALL RETIREMENT BENEFITS, TOGETHER WITH ALL OTHER FORMS OF COMPENSATION AND BENEFITS FOR THESE AND OTHER EXECUTIVES, IN A MANNER INTENDED TO QUALIFY FOR THE REBUTTABLE PRESUMPTION OF REASONABLENESS UNDER THE INTERMEDIATE SANCTIONS RULES OF FEDERAL INCOME TAX LAW. THE COMMITTEE HAS DETERMINED THAT TOTAL COMPENSATION FOR EACH SUCH EXECUTIVE IS REASONABLE. THE FOLLOWING ARE PARTICIPANTS IN THE PLAN: TERRI CUNLIFFE DAVID ERICKSON REBEKAH ERICKSON JODY HOLT ROGER OXENDALE WILLIAM RABE CORY STERN BINDU ZACHARIAS LYNN BLACKBURN BARBARA BEAKE JOSHUA ANDERSON IN 2019, THESE INDIVIDUALS VESTED IN THE PLAN IN THE FOLLOWING AMOUNTS: ROGER OXENDALE - $39,746 JOSHUA ANDERSON - $5,541 DAVID ERICKSON - $18,563 CORY STERN - $10,523 IN 2019, THIS INDIVIDUAL RECEIVED DISTRIBUTIONS FROM THE PLAN IN THE FOLLOWING AMOUNT: JOSHUA ANDERSON - $97,535 PART I, LINE 7 THE FOLLOWING APPLIES TO CERTAIN INDIVIDUALS LISTED ON PART VII WHOSE COMPENSATION IS PAID FROM RELATED ORGANIZATIONS: THE EXECUTIVE COMPENSATION COMMITTEE (OF CMB'S BOARD) FOLLOWS A PRESCRIBED METHOD FOR CALCULATING INCENTIVE COMPENSATION AWARDS. THE CALCULATION IS BASED ON MEASURABLE TARGETS DETERMINED AT THE BEGINNING OF THE YEAR. THE COMMITTEE HAS THE ABILITY TO ADJUST THE DOLLAR VALUE OF THE CALCULATED AWARDS BY UP TO 10%. THE ADJUSTMENT CAN BE AN UPWARD OR DOWNWARD ADJUSTMENT BASED ON VARIOUS PERFORMANCE FACTORS OR ON FACTORS THAT WILL ASSURE THAT FINAL INCENTIVE COMPENSATION AWARDS ARE IN THE BEST INTEREST OF THE ORGANIZATION AND APPROPRIATELY REFLECT THE PERFORMRANCE OF THE ORGANIZATION. REFER TO ADDITIONAL INFORMATION ON THE COMMITTEE INCLUDED IN SCHEDULE O. PART II, COLUMN B (II): BONUS AND INCENTIVE COMPENSATION - CERTAIN KEY PERSONS EMPLOYED BY COVENANT LIVING AND CMB ARE ELIGIBLE FOR INCENTIVE COMPENSATION AS DETERMINED BY THE EXECUTIVE COMPENSATION COMMITTEE OF EITHER THE COVENANT LIVING OR CMB'S BOARD BASED ON WHERE THESE INDIVIDUALS ARE EMPLOYED. INCENTIVES PAID IN 2019 RELATE TO THE ACHIEVEMENT OF TARGETS FOR THE FISCAL YEAR ENDED 1/31/2019. PART II, COLUMN D: NONTAXABLE BENEFITS INCLUDE HEALTH INSURANCE PREMIUMS PAID BY THE EMPLOYER AND EMPLOYEE. FORM 990, PART III, LINE 1: AS A MINISTRY OF THE EVANGELICAL COVENANT CHURCH, COVENANT LIVING COMMUNITIES AND SERVICES CELEBRATES GOD'S GIFT OF LIFE IN CHRISTIAN COMMUNITY. WE FOLLOW THE GREAT COMMANDMENT TO LOVE AND SERVE GOD AND ONE ANOTHER AS TAUGHT BY JESUS CHRIST. THAT COMPELS US TO AFFIRM THE DIGNITY OF EACH PERSON AND TO PURSUE EXCELLENCE AND FINANCIAL INTEGRITY IN ALL THAT WE DO. AS WE PROVIDE A BROAD RANGE OF RESOURCES, SERVICES AND PROGRAMS TO ENHANCE INDIVIDUAL AND COMMUNITY WELLNESS, WE COLLABORATE WITH RESIDENTS AND FAMILIES TO ACHIEVE THE BEST POSSIBLE RESULTS. WHILE SEEKING TO FOSTER INDEPENDENCE, WE RESPOND TO EACH INDIVIDUAL'S EVOLVING NEEDS IN ORDER TO PROVIDE THE SECURITY THAT ASSURES PEACE OF MIND. IN LIVING OUT THE MISSION, THE COMMUNITY PROVIDES A COMPLETE CONTINUUM OF CARE FROM RESIDENTIAL LIVING THROUGH SKILLED NURSING. SUCH SERVICES ARE GUIDED BY A SERIES OF VALUES AND GOALS ADDRESSING RESIDENT NEEDS, PRIVACY, SAFETY AND DIGNITY, INCLUDING APPROPRIATE ACCESS TO SERVICES. IN CARRYING OUT THE MISSION STATEMENT OF COVENANT LIVING, WINDSOR PARK MANOR PROVIDED $455,890 FREE OR DISCOUNTED SERVICES TO THOSE RESIDENTS UNABLE TO PAY ALL OR A PORTION OF THEIR CHARGES, AND WHO MEET CERTAIN ELIGIBILITY REQUIREMENTS. FORM 990, PART IV, LINE 24A: TAX-EXEMPT BONDS THE ORGANIZATION HAS TAX-EXEMPT BONDS ISSUED AFTER DECEMBER 31, 2002 WITH AN OUTSTANDING PRINCIPAL OF MORE THAN $100,000. THE BONDS ARE REPORTED ON SCHEDULE K OF THE PARENT ORGANIZATION. FORM 990, PART VI, SECTION A, LINE 3 WINDSOR PARK MANOR DELEGATED CONTROL OVER MANAGEMENT DUTIES TO COVENANT LIVING COMMUNITIES AND SERVICES, INC., ITS PARENT ORGANIZATION. FORM 990, PART VI, SECTION A, LINE 6 THE SOLE MEMBER IS COVENANT LIVING COMMUNITIES AND SERVICES, INC. FORM 990, PART VI, SECTION A, LINE 7B S 2.4 OF BYLAWS INCLUDE RESERVED POWERS TO THE [INDIVIDUAL] MEMBERS SUCH AS APPOINTMENT OF PRESIDENT OF COVENANT LIVING, CHANGES TO MISSION AND STRATEGIC PLAN, APPROVAL OF CERTAIN ACQUISITIONS, DISPOSITIONS AND FINANCINGS, CHANGES TO ARTICLES AND BYLAWS. FORM 990, PART VI, SECTION B, LINE 11B MANAGEMENT REVIEW: THE DRAFT FORM 990 WAS REVIEWED BY MULTIPLE LEVELS OF MANAGEMENT INCLUDING THE CHIEF FINANCIAL OFFICER AND THE SENIOR VICE PRESIDENT AND GENERAL COUNSEL. BOARD REVIEW: PRIOR TO FILING, THE 990 PROCESS WAS REVIEWED WITH THE BOARD OF DIRECTORS AT THE BOARD MEETING AND THE FINAL FORM 990 WAS PROVIDED TO EACH BOARD MEMBER. FORM 990, PART VI, SECTION B, LINE 12C COVENANT LIVING COMMUNITIES AND SERVICES, INC. HAS AN ADMINISTRATIVE POLICY ON CONFLICT OF INTEREST, IDENTIFYING THE PARAMETERS OF A CONFLICT OF INTEREST AND THE REQUIREMENT TO DISCLOSE ANY SUCH CONFLICT OF INTEREST. THE COVENANT LIVING POLICY IS DISTRIBUTED ANNUALLY TO COVENANT LIVING BOARD MEMBERS AND OFFICERS. THEY ARE ASKED TO SIGN ACKNOWLEDGING RECEIPT OF THE POLICY AND TO DISCLOSE IF THEY HAVE ANY CONFLICT OF INTERESTS. IF SOMEONE IS ABSENT FROM THE MEETING OR FAILS TO RETURN THE ACKNOWLEDGMENT, THERE IS A FOLLOW-UP WITH THE INDIVIDUAL UNTIL THE SIGNED ACKNOWLEDGMENT IS PROVIDED. IN ADDITION TO THE ABOVE, A SEPARATE AND MORE COMPREHENSIVE QUESTIONNAIRE IS SENT TO THE BOARD MEMBERS, OFFICERS, KEY EMPLOYEES AND OTHER INTERESTED PERSONS. THE COMPLETED QUESTIONNAIRES ARE REVIEWED BY COVENANT LIVING'S LEGAL COUNSEL TO DETERMINE IF ANY ACTUAL OR POTENTIAL CONFLICTS EXIST. IF A PERSON BECOMES AN INTERESTED PERSON, HE OR SHE MAY BE CONSIDERED IN DETERMINING WHETHER A QUORUM IS PRESENT. THE INTERESTED PERSON MAY MAKE A SHORT STATEMENT RELATING TO THE TRANSACTION OR ARRANGEMENT IN QUESTION, BUT SHALL NOT BE PRESENT DURING THE DISCUSSION AND SHALL NOT VOTE ON THE MOTION ADDRESSING THE ACTUAL OR POTENTIAL CONFLICT. FORM 990, PART VI, SECTION B, LINE 15 COVENANT LIVING COMMUNITIES AND SERVICES' BOARD OF DIRECTORS HAS DULY APPOINTED AN EXECUTIVE COMPENSATION COMMITTEE (THE "COMMITTEE"), WHICH IS RESPONSIBLE FOR THE REVIEW AND APPROVAL OF ALL COMPENSATION AND BENEFITS PROVIDED TO COVENANT LIVING'S EXECUTIVE MANAGEMENT. THE COMMITTEE HAS ADOPTED A WRITTEN EXECUTIVE COMPENSATION PHILOSOPHY STATEMENT AND AN EXECUTIVE COMPENSATION COMMITTEE CHARTER GOVERNING THE WORK AND REVIEW PROCESS OF THE COMMITTEE. THE COMMITTEE FOLLOWS THE PROCEDURES DESCRIBED IN THE PHILOSOPHY STATEMENT AND THE CHARTER WHEN IT REVIEWS AND APPROVES THE COMPENSATION AND EMPLOYEE BENEFITS PROVIDED TO THE COVENANT LIVING'S SENIOR MANAGEMENT. THE COMMITTEE'S REVIEW ANALYZES EVERY ELEMENT OF COMPENSATION, INCLUDING CURRENT AND DEFERRED COMPENSATION, AND BENEFITS, INCLUDING QUALIFIED AND NON-QUALIFIED BENEFITS. THE COMMITTEE CONDUCTS ITS REVIEW AND APPROVAL PROCESS AT LEAST ANNUALLY, AND APPROVES COMPENSATION AND BENEFITS ONLY TO THE EXTENT THAT THE COMMITTEE HAS CONCLUDED THAT THE COMPENSATION AND BENEFITS CONSTITUTE NO MORE THAN REASONABLE COMPENSATION FOR EACH EXECUTIVE. THE COMMITTEE CONSISTS ENTIRELY OF DISINTERESTED MEMBERS OF THE BOARD, AND THE COMMITTEE WORKS WITH AN INDEPENDENT COMPENSATION CONSULTANT TO PREPARE AND REVIEW IN ADVANCE COMPREHENSIVE DATA SHOWING THE COMPENSATION PROVIDED BY SIMILARLY SITUATED ORGANIZATIONS FOR FUNCTIONALLY SIMILAR POSITIONS. THE COMMITTEE ALSO PREPARES A TIMELY AND THOROUGH WRITTEN RECORD OF ITS DELIBERATIONS AND CONCLUSIONS. AS A RESULT, THE COMMITTEE'S REVIEW PROCESS IS DESIGNED TO SATISFY THE PROCEDURAL CRITERIA NECESSARY TO QUALIFY FOR THE REBUTTABLE PRESUMPTION OF REASONABLENESS UNDER THE FEDERAL INCOME TAX LAW INTERMEDIATE SANCTIONS RULES. THE RESOURCES UTILIZED BY THE COMPENSATION COMMITTEE INCLUDE: 1) INDEPENDENT COMPENSATION CONSULTANT; 2) COMPENSATION SURVEY OR STUDY; 3) APPROVAL BY THE BOARD OR COMPENSATION COMMITTEE. FORM 990, PART VI, SECTION C, LINE 19 THE GOVERNING DOCUMENTS, CONFLICT OF INTEREST POLICY AND FINANCIAL STATEMENTS ARE AVAILABLE UPON REQUEST BY CONTACTING THE COVENANT LIVING COMMUNITIES AND SERVICES, INC. FINANCE DEPARTMENT AT 773-878-2294. FORM 990, PART VI, LINE 9: CONTACT INFO FOR DIRECTORS & OFFICERS ALL OF THE ORGANIZATION'S DIRECTORS AND OFFICERS CAN BE CONTACTED AT THIS ADDRESS: COVENANT LIVING COMMUNITIES AND SERVICES, INC. - 5700 OLD ORCHARD ROAD, SKOKIE, IL 60077. FORM 990, PART XI, LINE 9: CHANGE IN PRESENT VALUE OF IRREVOCABLE TRUSTS 5,283. EVANGELICAL COVENANT CHURCH 8303 WEST HIGGINS ROAD CHICAGO IL 60631 362167730 CHURCH IL 501(C)(3) LINE 1 N/A 0 SWEDISH COVENANT FACULTY GROUP (SCFG) 5145 NORTH CALIFORNIA AVENUE CHICAGO IL 60625 363686216 PATIENT TREATMENT/EDUCATION IL 501(C)(3) LINE 12B, II SWEDISH COVENANT HOSPITAL 0 SWEDISH COVENANT HOSPITAL 5145 NORTH CALIFORNIA AVENUE CHICAGO IL 60625 362179813 HOSPITAL IL 501(C)(3) LINE 3 COVENANT MINISTRIES OF BENEVOLENCE 0 SWEDISH COVENANT HOSPITAL FOUNDATION (SCHF) 5145 NORTH CALIFORNIA AVENUE CHICAGO IL 60625 205055155 SUPPORT OF SWEDISH COVENANT HOSPITAL IL 501(C)(3) LINE 7 SWEDISH COVENANT HOSPITAL 0 SC INSURANCE COMPANY 6970 E CHAUNCEY LANE SUITE 100 PHOENIX AZ 85054 273312053 INSURANCE AZ 501(C)(3) LINE 12B, II SWEDISH COVENANT HOSPITAL 0 COVENANT LIVING COMMUNITIES AND SERVICES 5700 OLD ORCHARD RD SKOKIE IL 60077 363478388 MANAGEMENT/SUPPORT SERVICES IL 501(C)(3) LINE 12B, II EVANGELICAL COVENANT CHURCH 0 COVENANT LIVING OF GOLDEN VALLEY INC 5800 ST CROIX AVE MINNEAPOLIS MN 55422 410841150 CONTINUING CARE RETIREMENT COMMUNITY MN 501(C)(3) LINE 10 COVENANT LIVING COMMUNITIES AND SERVICES 0 COVENANT HEALTH CARE CENTERS INC 2155 PFINGSTEN ROAD NORTHBROOK IL 60062 521115873 CONTINUING CARE RETIREMENT COMMUNITY IL 501(C)(3) LINE 10 COVENANT LIVING COMMUNITIES AND SERVICES 0 COVENANT HOME ILLINOIS 2625 TECHNY ROAD NORTHBROOK IL 60062 362643638 CONTINUING CARE RETIREMENT COMMUNITY IL 501(C)(3) LINE 10 COVENANT LIVING COMMUNITIES AND SERVICES 0 COVENANT LIVING OF CROMWELL INC 52 MISSIONARY ROAD CROMWELL CT 06416 131740015 CONTINUING CARE RETIREMENT COMMUNITY CT 501(C)(3) LINE 10 COVENANT LIVING COMMUNITIES AND SERVICES 0 COVENANT HOME OF CHICAGO 2720 W FOSTER AVE CHICAGO IL 60625 363095932 ASSISTED LIVING FACILITY IL 501(C)(3) LINE 10 COVENANT LIVING COMMUNITIES AND SERVICES 0 COVENANT HOME SERVICES 5700 OLD ORCHARD RD SKOKIE IL 60077 260744025 HOME HEALTH SERVICES IL 501(C)(3) LINE 10 COVENANT LIVING SERVICES INC 0 COVENANT HOUSING CORPORATION 5700 OLD ORCHARD RD SKOKIE IL 60077 364484624 MANAGEMENT/SUPPORT SERVICES IL 501(C)(3) LINE 12B, II COVENANT LIVING COMMUNITIES AND SERVICES 0 COVENANT MINISTRIES OF BENEVOLENCE 5145 N CALIFORNIA AVE CHICAGO IL 60625 363486813 CONTINUING CARE RETIREMENT COMMUNITY IL 501(C)(3) LINE 12A, I EVANGELICAL COVENANT CHURCH 0 COVENANT PLACE OF LENEXA INC 5700 OLD ORCHARD RD SKOKIE IL 60077 452693240 CONTINUING CARE RETIREMENT COMMUNITY IL 501(C)(3) LINE 10 COVENANT LIVING SERVICES INC 0 COVENANT LIVING OF BIXBY INC 5700 OLD ORCHARD RD SKOKIE IL 60077 320419173 CONTINUING CARE RETIREMENT COMMUNITY IL 501(C)(3) LINE 10 COVENANT LIVING SERVICES INC 0 COVENANT LIVING OF THE GREAT LAKES 2520 LAKE MICHIGAN DRIVE NW GRAND RAPIDS MI 49504 383244636 CONTINUING CARE RETIREMENT COMMUNITY MI 501(C)(3) LINE 10 COVENANT LIVING COMMUNITIES AND SERVICES 0 COVENANT LIVING WEST 2550 TREASURE DRIVE SANTA BARBARA CA 93105 953472345 CONTINUING CARE RETIREMENT COMMUNITY CA 501(C)(3) LINE 10 COVENANT LIVING COMMUNITIES AND 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