2019-11-15T11:36:12-06:00 2018-12-31 203746583 TAYLOR ROTH AND COMPANY 800 GRANT ST STE 205 DENVER CO 802032944 990 2018-01-01 464625504 TOWARDS JUSTICE OF COLORADO TOWA 9704035694 1410 HIGH STREET SUITE 300 DENVER CO 80218 BARRY BAER TREASURER 9704035694 2019-11-14 true KEN ROTH P01389203 3038308109 2019-11-15 173.14.30.85 2019-11-15 11:36:12 CS P F510452ABB4A09DEF72ED4AF0FBBE4EEFED67493 F510452ABB4A09DEF72ED4AF0FBBE4EEFED67493 2018 2020-03-31 21:24:44Z TOWARDS JUSTICE DAVID SELIGMAN ESQ 1410 HIGH STREET SUITE 300 DENVER CO 80218 578851 false X WWW.TOWARDSJUSTICE.ORG X 2014 CO TOWARDS JUSTICE IS A NONPROFIT LAW FIRM THAT SEEKS TO ADVANCE ECONOMIC JUSTICE THROUGH IMPACT LITIGATION, STRATEGIC POLICY ADVOCACY, AND COLLABORATION WITH ORGANIZERS AND PUBLIC AGENCIES. WE WERE FOUNDED IN RESPONSE TO THE HIGH VOLUME OF WAGE THEFT COMPLAINTS THAT WERE NOT BEING ADDRESSED IN COLORADO, BUT QUICKLY BROADENED OUR SCOPE TO TAKE ON CASES THAT DISMANTLE THE POWER IMBALANCES THAT UNDERMINE THE VALUE OF WORK AND DIMINISH WORKER RIGHTS. 6 5 9 10 0 307313 563197 175228 5720 64 263 9904 3907 492509 573087 0 0 389251 464651 0 5513 128243 211738 517494 676389 -24985 -103302 288003 183053 15304 13656 272699 169397 X TOWARDS JUSTICE IS A NONPROFIT LAW FIRM THAT SEEKS TO ADVANCE ECONOMIC JUSTICE THROUGH IMPACT LITIGATION, STRATEGIC POLICY ADVOCACY, AND COLLABORATION WITH ORGANIZERS AND PUBLIC AGENCIES. WE WERE FOUNDED IN RESPONSE TO THE HIGH VOLUME OF WAGE THEFT COMPLAINTS THAT WERE NOT BEING ADDRESSED IN COLORADO, BUT QUICKLY BROADENED OUR SCOPE TO TAKE ON CASES THAT DISMANTLE THE POWER IMBALANCES THAT UNDERMINE THE VALUE OF WORK AND DIMINISH WORKER RIGHTS. false false 610834 5720 TOWARDS JUSTICE IS A NON-PROFIT LAW FIRM THAT ATTACKS ECONOMIC INEQUALITY WITH A FOCUS ON WORKPLACE INJUSTICE. WE USE IMPACT LITIGATION SUPPLEMENTED WITH TARGETED AND STRATEGIC POLICY ADVOCACY AND CAPACITY BUILDING TO ATTACK SYSTEMIC INJUSTICES THAT UNDERMINE THE POWER OF WORKERS-IN PARTICULAR, IMMIGRANT WORKERS AND WORKERS OF COLOR-TO OBTAIN FAIR WAGES AND DECENT WORKING CONDITIONS. IN 2018, THE ORGANIZATION UNCOVERED AND CHALLENGED NEW WAYS THAT EMPLOYERS ARE TAKING ADVANTAGE OF WORKERS, WHILE ALSO ADDRESSING THE AGE-OLD POWER IMBALANCES THAT CALCIFY INEQUALITY AND DEPRIVE WORKERS OF FINANCIAL STABILITY. FOR EXAMPLE, WE LAUNCHED A CASE AGAINST AN ALLEGED MISCLASSIFICATION SCHEME THROUGH WHICH IMMIGRANTS WERE PEDDLED THE AMERICAN DREAM OF SMALL BUSINESS OWNERSHIP AND ASKED TO PAY THOUSANDS OF DOLLARS FOR WORK AS COMMERCIAL CLEANERS WITHOUT ANY OF THE CONTROL AND OPPORTUNITY FOR PROFIT THAT COME WITH TRUE INDEPENDENT BUSINESS OWNERSHIP. WE ALSO CHALLENGED THE ALL-TOO-COMMON SHORT-CHANGING OF FOREIGN GUEST WORKERS THROUGH A LAWSUIT ON BEHALF OF A PROPOSED CLASS OF JAMAICAN WORKERS WHO ALLEGE THAT THEY NEVER RECEIVED TIPS WHEN THEY WORKED AT AN EXCLUSIVE MONTANA SKI AND GOLF RESORT. AND WE FILED A CASE ON BEHALF OF NAIL TECHNICIANS ALLEGING THAT THEIR EMPLOYER'S POLICIES GOVERNING COMPENSATION WERE ILLEGAL. THE ORGANIZATION ALSO CONTINUED ADVOCATING FOR SHEPHERDS IN 2018. THE ORGANIZATION ARGUED BEFORE THE TENTH CIRCUIT COURT OF APPEALS ON BEHALF SHEPHERDS WHO ALLEGE THAT THEIR WAGES, WHICH AMOUNT TO BETWEEN 2 AND 4 PER HOUR DEPENDING ON THE STATE, WERE SUPPRESSED BY ANTI-COMPETITIVE ACTIVITY IN THE MARKETPLACE. THE ORGANIZATION ALSO WON A VICTORY FROM THE DC CIRCUIT ON BEHALF OF AMERICAN AND FOREIGN SHEPHERDS IMPACTED BY THE GOVERNMENT'S ONGOING FAILURE TO REASONABLY IMPLEMENT THE TEMPORARY VISA PROGRAM THAT BRINGS MOST SHEPHERDS TO THIS COUNTRY. THE CIRCUIT COURT RETURNED THE CASE TO THE DISTRICT COURT FOR FURTHER PROCEEDINGS. THE ORGANIZATION ALSO SAW THE EFFECTS OF OUR 2017 LITIGATION IN 2018. FOR EXAMPLE, OUR CLIENT'S LAWSUIT AGAINST CARL'S JR. AND ITS PARENT COMPANY ALLEGING THAT NO-HIRE AGREEMENTS BETWEEN FRANCHISES VIOLATE ANTITRUST LAWS SPURRED PUBLIC ENFORCERS AROUND THE COUNTRY TO CHALLENGE THESE PRACTICES IN A VARIETY OF FAST FOOD FRANCHISES. BY THE END OF 2018, THESE AGREEMENTS HAD BEEN ELIMINATED AT SEVERAL FAST FOOD FRANCHISES AROUND THE COUNTRY. IN ADDITION TO OUR LITIGATION EFFORTS, THE ORGANIZATION ENGAGED IN TARGETED POLICY ADVOCACY AND COLLABORATION WITH PUBLIC ENFORCEMENT AGENCIES AND REGULATORS. WE TEND NOT TO SPEND RESOURCES ON POLICY CAMPAIGNS INVOLVING BIG-PICTURE SUBSTANTIVE ISSUES THAT WILL HAVE THE SUPPORT OF MANY ADVOCATES. HOWEVER, ON ISSUES RELATING TO THE ENFORCEMENT AGAINST WAGE- AND-HOUR VIOLATIONS AND ANTICOMPETITIVE PRACTICES, WE DEDICATE TARGETED RESOURCES TO POLICY EFFORTS. IN 2018, THE ORGANIZATION WORKED WITH PARTNERS IN THE LAW ENFORCEMENT COMMUNITY TO EXPAND THE FIGHT AGAINST WAGE THEFT IN COLORADO AND COLLABORATED WITH NATIONAL AND LOCAL PARTNERS TO CALL UPON OUR CITY AND STATE PUBLIC ENFORCEMENT AGENCIES TO PROTECT WORKERS. IN PARTICULAR, WE WORKED WITH THE BOULDER COUNTY DISTRICT ATTORNEY'S OFFICE AND THE COLORADO DISTRICT ATTORNEY'S COUNCIL TO DISCUSS PUBLIC AND PRIVATE ENFORCEMENT OF THE WAGE AND HOUR LAWS AND TO CO-HOST A CONVENING FOR DISTRICT ATTORNEYS TO DISCUSS THE ROLE PUBLIC ENFORCEMENT CAN PLAY IN FIGHTING WAGE THEFT AND ECONOMIC EXPLOITATION IN OUR STATE. WE ALSO WORKED WITH PARTNERS TO: ISSUE A WHITE PAPER DESCRIBING HOW THE CITY OF DENVER COULD STEP UP IN THE FIGHT AGAINST WORKER EXPLOITATION; ENCOURAGE THE COLORADO DEPARTMENT OF LABOR AND EMPLOYMENT (CDLE) TO ENGAGE IN STRATEGIC ENFORCEMENT OF THE WAGE AND HOUR LAWS; RELEASE A MAJOR REPORT CALLING ON GOVERNOR ELECT POLIS TO STRENGTHEN AND MODERNIZE THE CDLE; AND HOST A NON- PARTISAN FORUM FOR COLORADO GUBERNATORIAL CANDIDATES TO DISCUSS ISSUES IMPORTANT TO OUR STATE'S WORKING FAMILIES. WE DID THIS WHILE SUPPORTING NINA DISALVO AS SHE STEPPED BACK FROM HER LEADERSHIP ROLE AND ALLOWED DAVID SELIGMAN TO BECOME TOWARDS JUSTICE'S SECOND DIRECTOR. THIS LEADERSHIP TRANSITION HELPED US TO FOCUS ON OUR MISSION AND THINK CRITICALLY ABOUT OUR DIRECTION AS AN ORGANIZATION. WE BEGAN DESCRIBING OUR WORK, WHICH HAS ALWAYS BEEN FUNCTIONALLY INTEGRATED, AS A LONG PIPELINE OF WORKER SUPPORT RATHER THAN AS TWO SEPARATE PROGRAMS (IMPACT LITIGATION AND ACCESS TO JUSTICE). TODAY, WE CONTINUE TO PROVIDE ACCESS TO JUSTICE SERVICES, MAINTAIN OUR COLLABORATING ATTORNEYS NETWORK, AND CONNECT VICTIMS OF WORKPLACE ABUSE TO OUR NETWORK LAWYERS, NON-PROFIT PARTNERS, AND GOVERNMENT AGENCIES. BUT WE DON'T DESCRIBE THAT AS SEPARATE FROM OUR LITIGATION WORK, BUT INSTEAD AS PART OF OUR BROAD SERVICE TO THE COMMUNITY. OUR GUIDING PRINCIPLE IS THE IMPORTANCE OF LEVERAGING OUR RESOURCES TO MAXIMIZE OUR OWN EFFECTIVENESS AND THE EFFECTIVENESS OF OUR PARTNERS TO SERVE THE INTERESTS OF WORKERS. OUR 2018 LEADERSHIP TRANSITION ALSO PROMPTED THE ORGANIZATION TO STEP BACK FROM THE SUBSTANTIAL VOLUNTEER MANAGEMENT ACTIVITIES ASSOCIATED WITH SUPPORTING BILINGUAL LEGAL INTAKE VOLUNTEERS AND JUST WAGES NAVIGATORS. WE REMAIN DEDICATED TO MAKING SURE THAT WORKERS HAVE A VOICE AND MECHANISMS TO HOLD THEIR EMPLOYERS ACCOUNTABLE FOR WORKPLACE VIOLATIONS. THAT WORK WILL CONTINUE TO INVOLVE ANSWERING THE PHONE AND MAKING REFERRALS, BUT IT WILL LIKELY INVOLVE LESS EMPHASIS ON PROVIDING ACCESS TO JUSTICE IN HOUSE, WHETHER THROUGH ATTORNEYS OR JUST WAGES NAVIGATORS. INSTEAD, WE ARE COMMITTED TO EXPANDING THE CAPACITY OF THE BROADER COMMUNITY TO ADDRESS THE DAY-TO-DAY EXPLOITATION OF WORKERS ACROSS OUR MARKETPLACE. 610834 true true false true false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false false true 4 0 true 9 true false false false false false false false false false false false false X 6 5 false false false false false false false true true false false true true true true true true true false true true X X DAVID SELIGMAN ESQ 9704035694 1410 HIGH STREET SUITE 300 DENVER CO 80218 NINA DISALVO ESQ EXEC DIR, BO 35.00 X X 48932 0 0 JEFFREY WILLIAMS BOARD PRESID 2.00 X X 0 0 0 CAMILA SOSMAN PALMER SECRETARY 2.00 X X 0 0 0 BARRY BAER TREASURER 2.00 X X 0 0 0 BRIAN GONZALES BOARD MEMBER 1.00 X 0 0 0 DAVID LOPEZ BOARD MEMBER 1.00 X 0 0 0 RACHEL GRAVES BOARD MEMBER 1.00 X 0 0 0 PAULA GREISEN BOARD MEMBER 1.00 X 0 0 0 DEBORA ORTEGA BOARD MEMBER 1.00 X 0 0 0 JASON STAVERS BOARD MEMBER 1.00 X 0 0 0 DAVID MILLER BOARD MEMBER 1.00 X 0 0 0 DAVID SELIGMAN ESQ EXECUTIVE DI 40.00 X 93206 0 0 142138 false false false 563197 563197 LEGAL FEE INCOME 541900 5720 5720 5720 263 263 8366 5764 2602 2602 ALL OTHER 900099 1305 1305 1305 573087 7025 2865 142138 127924 12793 1421 247386 222648 22264 2474 44503 40053 4005 445 30624 27561 2756 307 11933 11933 732 455 222 55 21115 19724 1299 92 11577 10838 517 222 23834 20736 2860 238 3102 2947 155 5151 4156 829 166 1854 1426 335 93 CLIENT COSTS 132366 132366 MISCELLANEOUS 74 74 676389 610834 60042 5513 186370 80727 100063 100326 1570 2000 288003 183053 15304 13656 15304 13656 X 224098 93529 48601 75868 272699 169397 288003 183053 -103302 X true X false true false X 27700 282075 256285 307313 563197 1436570 27700 282075 256285 307313 563197 1436570 149597 1286973 64 263 327 13057 9905 3907 26869 1463766 317115 0.87920 X PART II, LINE 10 NET SPECIAL EVENTS 25,563 ALL OTHER 1,306 RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 1720 1720 674669 676389 126458 31615 106327 95158 102624 126458 430567 645851 1000 5000 5000 1720 12720 26582 23790 25656 31615 107643 161465 FORM 990, PAGE 1, ITEM C TOWARDS JUSTICE FORM 990 - ORGANIZATION'S MISSION TOWARDS JUSTICE IS A NONPROFIT LAW FIRM THAT SEEKS TO ADVANCE ECONOMIC JUSTICE THROUGH IMPACT LITIGATION, STRATEGIC POLICY ADVOCACY, AND COLLABORATION WITH ORGANIZERS AND PUBLIC AGENCIES. WE WERE FOUNDED IN RESPONSE TO THE HIGH VOLUME OF WAGE THEFT COMPLAINTS THAT WERE NOT BEING ADDRESSED IN COLORADO, BUT QUICKLY BROADENED OUR SCOPE TO TAKE ON CASES THAT DISMANTLE THE POWER IMBALANCES THAT UNDERMINE THE VALUE OF WORK AND DIMINISH WORKER RIGHTS. FORM 990, PAGE 1, PART I, LINE 6 TOWARDS JUSTICE OF COLORADO RECEIVES SERVICES FROM A PRO BONO ATTORNEY WHO GENEROUSLY DONATED APPROXIMATELY 250 HOURS OF TIME TO THE ORGANIZATION IN 2018, VALUED AT 12,500 ON THE REVIEWED FINANCIAL STATEMENTS. FORM 990, PAGE 2, PART III, LINE 4A TOWARDS JUSTICE IS A NON-PROFIT LAW FIRM THAT ATTACKS ECONOMIC INEQUALITY WITH A FOCUS ON WORKPLACE INJUSTICE. WE USE IMPACT LITIGATION SUPPLEMENTED WITH TARGETED AND STRATEGIC POLICY ADVOCACY AND CAPACITY BUILDING TO ATTACK SYSTEMIC INJUSTICES THAT UNDERMINE THE POWER OF WORKERS-IN PARTICULAR, IMMIGRANT WORKERS AND WORKERS OF COLOR-TO OBTAIN FAIR WAGES AND DECENT WORKING CONDITIONS. IN 2018, THE ORGANIZATION UNCOVERED AND CHALLENGED NEW WAYS THAT EMPLOYERS ARE TAKING ADVANTAGE OF WORKERS, WHILE ALSO ADDRESSING THE AGE-OLD POWER IMBALANCES THAT CALCIFY INEQUALITY AND DEPRIVE WORKERS OF FINANCIAL STABILITY. FOR EXAMPLE, WE LAUNCHED A CASE AGAINST AN ALLEGED MISCLASSIFICATION SCHEME THROUGH WHICH IMMIGRANTS WERE PEDDLED THE AMERICAN DREAM OF SMALL BUSINESS OWNERSHIP AND ASKED TO PAY THOUSANDS OF DOLLARS FOR WORK AS COMMERCIAL CLEANERS WITHOUT ANY OF THE CONTROL AND OPPORTUNITY FOR PROFIT THAT COME WITH TRUE INDEPENDENT BUSINESS OWNERSHIP. WE ALSO CHALLENGED THE ALL-TOO-COMMON SHORT-CHANGING OF FOREIGN GUEST WORKERS THROUGH A LAWSUIT ON BEHALF OF A PROPOSED CLASS OF JAMAICAN WORKERS WHO ALLEGE THAT THEY NEVER RECEIVED TIPS WHEN THEY WORKED AT AN EXCLUSIVE MONTANA SKI AND GOLF RESORT. AND WE FILED A CASE ON BEHALF OF NAIL TECHNICIANS ALLEGING THAT THEIR EMPLOYER'S POLICIES GOVERNING COMPENSATION WERE ILLEGAL. THE ORGANIZATION ALSO CONTINUED ADVOCATING FOR SHEPHERDS IN 2018. THE ORGANIZATION ARGUED BEFORE THE TENTH CIRCUIT COURT OF APPEALS ON BEHALF SHEPHERDS WHO ALLEGE THAT THEIR WAGES, WHICH AMOUNT TO BETWEEN 2 AND 4 PER HOUR DEPENDING ON THE STATE, WERE SUPPRESSED BY ANTI-COMPETITIVE ACTIVITY IN THE MARKETPLACE. THE ORGANIZATION ALSO WON A VICTORY FROM THE DC CIRCUIT ON BEHALF OF AMERICAN AND FOREIGN SHEPHERDS IMPACTED BY THE GOVERNMENT'S ONGOING FAILURE TO REASONABLY IMPLEMENT THE TEMPORARY VISA PROGRAM THAT BRINGS MOST SHEPHERDS TO THIS COUNTRY. THE CIRCUIT COURT RETURNED THE CASE TO THE DISTRICT COURT FOR FURTHER PROCEEDINGS. THE ORGANIZATION ALSO SAW THE EFFECTS OF OUR 2017 LITIGATION IN 2018. FOR EXAMPLE, OUR CLIENT'S LAWSUIT AGAINST CARL'S JR. AND ITS PARENT COMPANY ALLEGING THAT NO-HIRE AGREEMENTS BETWEEN FRANCHISES VIOLATE ANTITRUST LAWS SPURRED PUBLIC ENFORCERS AROUND THE COUNTRY TO CHALLENGE THESE PRACTICES IN A VARIETY OF FAST FOOD FRANCHISES. BY THE END OF 2018, THESE AGREEMENTS HAD BEEN ELIMINATED AT SEVERAL FAST FOOD FRANCHISES AROUND THE COUNTRY. IN ADDITION TO OUR LITIGATION EFFORTS, THE ORGANIZATION ENGAGED IN TARGETED POLICY ADVOCACY AND COLLABORATION WITH PUBLIC ENFORCEMENT AGENCIES AND REGULATORS. WE TEND NOT TO SPEND RESOURCES ON POLICY CAMPAIGNS INVOLVING BIG-PICTURE SUBSTANTIVE ISSUES THAT WILL HAVE THE SUPPORT OF MANY ADVOCATES. HOWEVER, ON ISSUES RELATING TO THE ENFORCEMENT AGAINST WAGE- AND-HOUR VIOLATIONS AND ANTICOMPETITIVE PRACTICES, WE DEDICATE TARGETED RESOURCES TO POLICY EFFORTS. IN 2018, THE ORGANIZATION WORKED WITH PARTNERS IN THE LAW ENFORCEMENT COMMUNITY TO EXPAND THE FIGHT AGAINST WAGE THEFT IN COLORADO AND COLLABORATED WITH NATIONAL AND LOCAL PARTNERS TO CALL UPON OUR CITY AND STATE PUBLIC ENFORCEMENT AGENCIES TO PROTECT WORKERS. IN PARTICULAR, WE WORKED WITH THE BOULDER COUNTY DISTRICT ATTORNEY'S OFFICE AND THE COLORADO DISTRICT ATTORNEY'S COUNCIL TO DISCUSS PUBLIC AND PRIVATE ENFORCEMENT OF THE WAGE AND HOUR LAWS AND TO CO-HOST A CONVENING FOR DISTRICT ATTORNEYS TO DISCUSS THE ROLE PUBLIC ENFORCEMENT CAN PLAY IN FIGHTING WAGE THEFT AND ECONOMIC EXPLOITATION IN OUR STATE. WE ALSO WORKED WITH PARTNERS TO: ISSUE A WHITE PAPER DESCRIBING HOW THE CITY OF DENVER COULD STEP UP IN THE FIGHT AGAINST WORKER EXPLOITATION; ENCOURAGE THE COLORADO DEPARTMENT OF LABOR AND EMPLOYMENT (CDLE) TO ENGAGE IN STRATEGIC ENFORCEMENT OF THE WAGE AND HOUR LAWS; RELEASE A MAJOR REPORT CALLING ON GOVERNOR ELECT POLIS TO STRENGTHEN AND MODERNIZE THE CDLE; AND HOST A NON- PARTISAN FORUM FOR COLORADO GUBERNATORIAL CANDIDATES TO DISCUSS ISSUES IMPORTANT TO OUR STATE'S WORKING FAMILIES. WE DID THIS WHILE SUPPORTING NINA DISALVO AS SHE STEPPED BACK FROM HER LEADERSHIP ROLE AND ALLOWED DAVID SELIGMAN TO BECOME TOWARDS JUSTICE'S SECOND DIRECTOR. THIS LEADERSHIP TRANSITION HELPED US TO FOCUS ON OUR MISSION AND THINK CRITICALLY ABOUT OUR DIRECTION AS AN ORGANIZATION. WE BEGAN DESCRIBING OUR WORK, WHICH HAS ALWAYS BEEN FUNCTIONALLY INTEGRATED, AS A LONG PIPELINE OF WORKER SUPPORT RATHER THAN AS TWO SEPARATE PROGRAMS (IMPACT LITIGATION AND ACCESS TO JUSTICE). TODAY, WE CONTINUE TO PROVIDE ACCESS TO JUSTICE SERVICES, MAINTAIN OUR COLLABORATING ATTORNEYS NETWORK, AND CONNECT VICTIMS OF WORKPLACE ABUSE TO OUR NETWORK LAWYERS, NON-PROFIT PARTNERS, AND GOVERNMENT AGENCIES. BUT WE DON'T DESCRIBE THAT AS SEPARATE FROM OUR LITIGATION WORK, BUT INSTEAD AS PART OF OUR BROAD SERVICE TO THE COMMUNITY. OUR GUIDING PRINCIPLE IS THE IMPORTANCE OF LEVERAGING OUR RESOURCES TO MAXIMIZE OUR OWN EFFECTIVENESS AND THE EFFECTIVENESS OF OUR PARTNERS TO SERVE THE INTERESTS OF WORKERS. OUR 2018 LEADERSHIP TRANSITION ALSO PROMPTED THE ORGANIZATION TO STEP BACK FROM THE SUBSTANTIAL VOLUNTEER MANAGEMENT ACTIVITIES ASSOCIATED WITH SUPPORTING BILINGUAL LEGAL INTAKE VOLUNTEERS AND JUST WAGES NAVIGATORS. WE REMAIN DEDICATED TO MAKING SURE THAT WORKERS HAVE A VOICE AND MECHANISMS TO HOLD THEIR EMPLOYERS ACCOUNTABLE FOR WORKPLACE VIOLATIONS. THAT WORK WILL CONTINUE TO INVOLVE ANSWERING THE PHONE AND MAKING REFERRALS, BUT IT WILL LIKELY INVOLVE LESS EMPHASIS ON PROVIDING ACCESS TO JUSTICE IN HOUSE, WHETHER THROUGH ATTORNEYS OR JUST WAGES NAVIGATORS. INSTEAD, WE ARE COMMITTED TO EXPANDING THE CAPACITY OF THE BROADER COMMUNITY TO ADDRESS THE DAY-TO-DAY EXPLOITATION OF WORKERS ACROSS OUR MARKETPLACE. FORM 990, PAGE 6, PART VI, LINE 11B THE EXECUTIVE DIRECTOR AND A BOARD MEMBER, AS AVAILABLE, HAVE A MEETING WITH THE EXTERNAL CONSULTANT TO REVIEW THE FORM 990 AND ITS REQUIRED ATTACHMENTS AND SCHEDULES. DURING THIS MEETING, A REVIEW OF ALL FINANCIAL AND NARRATIVE INFORMATION IS UNDERTAKEN TO MAKE SURE ALL REPORTS AND SCHEDULES REFLECT THE ACTUAL OPERATING RESULTS OF THE AGENCY FOR THE MOST RECENTLY COMPLETED FISCAL YEAR. AFTER THIS PROCESS, THE EXECUTIVE DIRECTOR PRESENTS THE 990 TO THE FULL BOARD FOR REVIEW. FORM 990, PAGE 6, PART VI, LINE 12C THE BOARD ADOPED A CONFLICTS OF INTEREST POLICY IN OCTOBER OF 2014 AND THE BOARD EXECUTIVE COMMITTEE AND EXECUTIVE DIRECTOR WORK TOGETHER TO ENSURE COMPLIANCE WITH THAT POLICY THROUGHOUT THE YEAR. THE AGENCY MAINTAINS BOARD POLICIES AND PROCEDURES IN A CLOUD-BASED FORMAT ACCESSIBLE TO ALL BOARD MEMBERS. EACH BOARD MEMBER HAS ACCESS TO THE FOLDER AND THE ORIENTATION TO FULLY EXPLAIN THE ROLES AND RESPONSIBILITIES OF EACH MEMBER. FORM 990, PAGE 6, PART VI, LINE 15A THE BOARD OF DIRECTORS CONDUCTS AN ANNUAL PERFORMANCE AND COMPENSATION EVALUATION OF THE EXECUTIVE DIRECTOR, WHICH INVOLVES SURVEYING BOARD AND STAFF MEMBERS AND ANALYZING ORGANIZATIONAL PERFORMANCE RELATIVE BOTH TO MONETARY AND PROGRAMMATIC GOALS. THE BOARD THEN ANALYSES NONPROFIT SECTOR SALARY SURVEY DATA FOR EXECUTIVE PERSONNEL, INCLUDING COLORADO-SPECIFIC SURVEY INFORMATION COMPILED BY THE COLORADO NONPROFIT ASSOCIATION. SALARY IS SET BASED ON EXISTING SALARY STRUCTURE OF THE ORGANIZATION, EXECUTIVE DIRECTOR PERFORMANCE, AND RELEVANT NONPROFIT SECTOR TRENDS. FORM 990, PAGE 6, PART VI, LINE 19 GOVERNING AND PUBLIC FINANCIAL DOCUMENTS ARE AVAILABLE UPON WRITTEN REQUEST. THE ORGANIZATION WAS INCORPORATED IN 2014.