2025-11-13T10:12:37-06:00 2024-12-31 991856619 GRANT THORNTON ADVISORS LLC 53 STATE STREET SUITE 1600 BOSTON MA 02109 990 2024-01-01 050296998 DELTA DENTAL OF RHODE ISLAND DELT 4017526000 10 CHARLES STREET PROVIDENCE RI 02904 SEAN NEWTH CFO 4017526000 2025-11-13 1 1 ERIN COUTURE P01390592 6177327900 2024 2025-03-06 01:10:19Z JOSEPH R PERRONI 10 CHARLES STREET PROVIDENCE RI 02904 87463640 0 X WWW.DELTADENTALRI.COM X 1959 RI TO PROVIDE COST EFFECTIVE GROUP DENTAL INSURANCE TO THE RHODE ISLAND BUSINESS COMMUNITIES. 15 14 55 15 1249 0 0 0 64330960 67755271 2189591 1880892 97491 62489 66618042 69698652 2656723 1441865 44518446 48535742 11222888 11826479 0 0 0 7274726 7281076 65672783 69085162 945259 613490 131064002 139305705 15487102 17264441 115576900 122041264 OUR MISSION IS TO DELIVER IMPECCABLE SERVICE, QUALITY AND INNOVATION THAT EXCEEDS EXPECTATIONS. AS EXPERTS IN ORAL HEALTH CARE, WE ARE COMMITTED TO ACCESSIBLE, AFFORDABLE CARE THAT DRIVES IMPROVED HEALTH OUTCOMES. 0 0 49977607 0 65924321 DENTAL BENEFITS FOR 428,445 MEMBERS UNDER 222,772 CONTRACTS. THE COMPANY OFFERS A BROAD RANGE OF PREPAID DENTAL CARE COVERAGE OPTIONS AND ADMINISTRATIVE SERVICES TO ORGANIZATIONS PROVIDING SUCH BENEFITS TO THEIR EMPLOYEES ON A CONTRIBUTORY OR A NONCONTRIBUTORY BASIS. 8203600 1441865 0 AT DELTA DENTAL, WE HAVE A LONG-STANDING TRADITION OF HELPING OUR STATE'S MOST VULNERABLE CITIZENS. IN 2005, WE ESTABLISHED THE DELTA DENTAL OF RHODE ISLAND FUND, FORMALIZING OUR COMMITMENT TO DENTAL HEALTH INITIATIVES IN OUR COMMUNITY. AS A VESTED COMMUNITY PARTNER, WE LEVERAGE THE DELTA DENTAL OF RHODE ISLAND FUND, AS WELL AS OUR ROBUST EMPLOYEE VOLUNTEER PROGRAM, AND MATCHING GIFT PROGRAM TO SUPPORT CRITICAL ORAL HEALTH NEEDS ACROSS THE STATE. GRANTS ARE AWARDED TO QUALIFYING CHARITABLE ORGANIZATIONS FOR PROGRAMS OR CAPITAL EXPENDITURES THAT INCREASE ACCESS TO DENTAL CARE FOR AT-RISK, VULNERABLE RHODE ISLANDERS. 0 0 1830950 THE COMPANY PARTICIPATED, PURSUANT TO RISK SHARING AGREEMENTS, IN THREE SEPARATE JOINT VENTURES WITH OTHER DELTA DENTAL MEMBER COMPANIES. PROJECTED LOSSES ARE RECOGNIZED IN THE PERIOD THEY BECOME PROBABLE. CHANGES IN ACCRUED LOSS ESTIMATES ARE REFLECTED IN CURRENT PERIOD OPERATIONS. 58181207 0 0 0 0 0 0 0 0 0 1 1 0 0 1 1 0 1 0 0 0 0 0 0 0 0 0 1 0 1 0 0 0 0 0 0 0 1 0 0 0 0 0 1 1 1 0 1 149 0 1 55 1 1 1 0 0 0 0 0 0 0 X 15 14 0 0 0 0 1 1 1 1 1 0 0 1 1 1 1 1 1 1 1 0 X DUANE EASTER 4017526267 10 CHARLES STREET PROVIDENCE RI 02904 JOHN T RUGGIERI CHAIR 1.00 1.00 X X 14550 0 0 JAMES V ROSATI VICE CHAIR 1.00 1.00 X X 16200 0 0 MARC A PAULHUS DIRECTOR 1.00 1.00 X 12600 0 0 STEVEN ISSA DIRECTOR 1.00 1.00 X 13500 0 0 EDWIN J SANTOS DIRECTOR 1.00 1.00 X 12600 0 0 COLIN P KANE DIRECTOR 1.00 1.00 X 10800 0 0 JONATHAN W HALL DIRECTOR 1.00 1.00 X 12000 0 0 JUNIOR JABBIE DIRECTOR 1.00 1.00 X 10800 0 0 HEATHER A PROVINO DIRECTOR 1.00 1.00 X 11400 0 0 ELIZABETH CATUCCI DIRECTOR 1.00 1.00 X 9600 0 0 PETE HAYES DIRECTOR 1.00 1.00 X 9900 0 0 MARK SHAW DIRECTOR 1.00 1.00 X 9600 0 0 DR THOMAS ENRIGHT DIRECTOR 1.00 1.00 X 8400 0 0 CHRISTINE GADBOIS DIRECTOR 1.00 1.00 X 8400 0 0 MICHAEL F SABITONI DIRECTOR 1.00 1.00 X 7800 0 0 JOSEPH R PERRONI PRESIDENT & CEO 40.00 1.00 X 842228 0 72392 RICHARD A FRITZ SR. VP FINANCE & CFO 40.00 1.00 X 515602 0 68337 MELISSA GENNARI AVP & DIRECTOR COMPLIANCE 40.00 1.00 X 181575 0 22364 WILLIAM LANDRY SECRETARY 1.00 1.00 X 0 0 0 DUANE S EASTER AVP OF FINANCE 40.00 1.00 X 192752 0 53763 THOMAS D CHASE SR. VP & COO 40.00 0.00 X 522828 0 72876 MICHELLE LUCAS VP COMMUNICATIONS & EXTERNAL AFFAIRS 40.00 0.00 X 249257 0 58912 JAMES KINNEY VP SALES AND BUSINESS RELATIONS 40.00 0.00 X 355228 0 71028 ELLEN M HENDRIX VP UNDERWRITING & INSURANCE RISK SVCS 40.00 0.00 X 298938 0 64226 ANGELO PEZZULLO SR ADV SALES & BUSINESS RELATIONS 40.00 0.00 X 242587 0 40284 JUDITH A LOWEN AS OF 42024 AVP OF PROD. & SERV. DEV. 40.00 0.00 X 119024 78144 43991 JASON E BROWN AS OF 42024 AVP OF GOVERNMENT PROGRAMS 40.00 0.00 X 114095 76724 36894 JOSEPH NAGLE FORMER PRESIDENT & CEO (THRU 6/2019) 40.00 1.00 X 163904 0 0 3966168 154868 605067 29 1 1 0 8 WEST CONSULTING BUILDING 1 UTC CURRAHEEN ROAD CORK EI T12 AY18 IT-PRODUCT CONSULTING SERVICES 1046430 SKYGEN USA W140 N8981 LILLY ROAD MENOMONEE FALLS WI 53051 IT-PRODUCT DEVELOPMENT 1007075 CLARITY 2801 LAKESIDE DRIVE BANNOCKBURN IL 60015 PRINT AND MAIL 705425 DUFFY & SHANLEY INC 10 CHARLES STREET PROVIDENCE RI 02903 MARKETING, PUBLIC RELATIONS 439622 GRANT THORNTON 171 N CLARK ST STE 200 CHICAGO IL 60601 AUDIT TAX SERVICES 432869 11 RISK PREMIUMS 524114 65924321 65924321 OTHER STATE RISK PREMIUMS 524114 1830950 1830950 67755271 1663191 1663191 17982689 17764988 217701 217701 217701 INCOME FROM SUBSIDIARIES 900099 54827 1249 53578 OTHER INCOME 900099 7662 7662 62489 69698652 67755271 1249 1942132 1441865 1441865 48535742 48535742 3021034 914620 2106414 163904 163904 6773598 4171895 2601703 705260 254627 450633 403402 21494 381908 759281 331043 428238 245143 245143 384595 384595 93269 93269 515148 515148 1213514 -605090 1818604 526685 526685 575710 381232 194478 979691 594847 384844 98889 7926 90963 8996 8996 172500 172500 166111 166111 EQUIPMENT RENTAL & MAIN 1888173 1888173 BOARD & ASSOCIATION FEE 419129 10253 408876 LICENSES & FEES 43500 969 42531 INCOME TAX 50 50 -50027 138342 -188369 69085162 58181207 10903955 0 250 250 1378445 2909240 6816009 5716308 4183319 3801935 24526904 13949474 5719474 10577430 86145151 89456851 26370534 26406818 450820 436873 131064002 139305705 11495636 13526847 3991466 3737594 15487102 17264441 X 0 0 0 0 115576900 122041264 115576900 122041264 131064002 139305705 613490 5850874 0 X 0 1 X 1 0 3193642 3134216 59426 7738847 7451456 287391 13594415 3363802 10230613 10577430 SUBSIDIARIES 19465026 C INVESTMENT - OTHER 6941792 F 26406818 ACCRUED FOR DENTAL CLAIMS EXPENSE 1573220 UNEARNED SUBSCRIPTIONS 1546321 ADVANCED DEPOSITS 468546 ACCRUED FOR CLAIMS HANDLING EXP 99157 ACCRUED FOR VISION CLAIMS EXPENSE 50350 3737594 X PART X, LINE 2: ASC 740 DELTA DENTAL OF RHODE ISLAND IS A NOT-FOR-PROFIT CORPORATION PURSUANT TO SECTION 501(C)(4) OF THE INTERNAL REVENUE CODE (IRC) AND IS GENERALLY EXEMPT FROM FEDERAL INCOME TAXES ON RELATED INCOME UNDER SECTION 501(A) OF THE IRC. ACCORDINGLY, NO PROVISION FOR INCOME TAXES RELATIVE TO DELTA DENTAL OF RHODE ISLAND HAS BEEN MADE IN THE ACCOMPANYING CONSOLIDATED FINANCIAL STATEMENTS. THE COMPANY EVALUATES ITS UNCERTAIN TAX POSITIONS WITH A TWO-STEP PROCESS IN ACCORDANCE WITH GAAP. FIRST, THE COMPANY DETERMINES WHETHER IT IS MORE LIKELY THAN NOT THAT AN UNCERTAIN TAX POSITION WILL BE SUSTAINED UPON EXAMINATION BASED ON THE TECHNICAL MERITS OF THE POSITION. SECOND, AN UNCERTAIN TAX POSITION THAT MEETS THE MORE LIKELY THAN NOT THRESHOLD IS MEASURED TO DETERMINE THE AMOUNT OF BENEFIT TO RECOGNIZE IN THE FINANCIAL STATEMENTS. THE POSITION IS MEASURED AT THE LARGEST AMOUNT OF BENEFIT THAT IS GREATER THAN 50% LIKELY OF BEING REALIZED UPON ULTIMATE SETTLEMENT. UNCERTAIN TAX POSITIONS THAT PREVIOUSLY FAILED TO MEET THE MORE LIKELY THAN NOT RECOGNITION THRESHOLD ARE RECOGNIZED IN THE FIRST SUBSEQUENT REPORTING PERIOD IN WHICH THE THRESHOLD IS MET. PREVIOUSLY RECOGNIZED UNCERTAIN TAX POSITIONS THAT NO LONGER MEET THE MORE LIKELY THAN NOT RECOGNITION THRESHOLD ARE DERECOGNIZED IN THE FIRST SUBSEQUENT REPORTING PERIOD IN WHICH THE THRESHOLD IS NO LONGER MET. SHOULD INTEREST OR PENALTIES BE ASSESSED, SUCH EXPENSES WOULD BE REFLECTED IN SELLING, GENERAL AND ADMINISTRATIVE EXPENSES. AS OF DECEMBER 31, 2024 AND 2023, THE COMPANY HAD NO UNCERTAIN TAX POSITIONS. 1 RHODE ISLAND FOUNDATION ONE UNION STATION PROVIDENCE RI 02914 222604963 501(C)(3) 906132 0 PROGRAM SUPPORT UNITED WAY OF RI 50 VALLEY STREET PROVIDENCE RI 02909 050276059 501(C)(3) 110608 0 PROGRAM SUPPORT BROWN UNIVERSITY HEALTH DEVELOPMENT OFFICE PO BOX H PROVIDENCE RI 02901 050258809 501(C)(3) 32000 0 PROGRAM SUPPORT MAKE A WISH FOUNDATION OF MA & RI 133 FEDERAL STREET 2ND FLOOR BOSTON MD 02110 222867371 501(C)(3) 26650 0 PROGRAM SUPPORT PROVIDENCE COLLEGE 1 CUNNINGHAM SQ PROVIDENCE RI 02918 050258932 501(C)(3) 20860 0 PROGRAM SUPPORT MIRIAM HOSPITAL FOUNDATION DEVELOPMENT OFFICE PO BOX H PROVIDENCE RI 02901 050377502 501(C)(3) 15300 0 PROGRAM SUPPORT AMERICAN HEART ASSOCATION PO BOX 5026 BOONE IA 50950 135613797 501(C)(3) 15000 0 PROGRAM SUPPORT RI HOSPITAL FOUNDATION 167 POINT STREET PROVIDENCE RI 02903 050468736 501(C)(3) 13500 0 PROGRAM SUPPORT ST PATRICK ACADEMY 244 SMITH STREET PROVIDENCE RI 02908 050348697 501(C)(3) 12750 0 PROGRAM SUPPORT ST PETER ROMAN CATHOLIC 350 FAIR STREET PROVIDENCE RI 02888 050259051 501(C)(3) 11640 0 PROGRAM SUPPORT MCAULEY MINISTRIES 622 ELMWOOD AVE PROVIDENCE RI 02907 050440470 501(C)(3) 11500 0 PROGRAM SUPPORT BRYANT UNIVERSITY 1150 DOUGLAS PIKEL BOX 40 SMITHFIELD RI 02917 050258810 501(C)(3) 10000 0 PROGRAM SUPPORT FIRSTWORKS 235 PROMENADE STREET SUITE 130 PROVIDENCE RI 02908 222597014 501(C)(3) 10000 0 PROGRAM SUPPORT DELTA DENTAL PLANS ASSOCIATION 222 W MERCHANDISE MART PLAZA STE 631 CHICAGO IL 60654 362551984 501(C)(3) 9814 0 PROGRAM SUPPORT JUNIOR ACHIEVEMENT 57 GREENE STREET WARWICK RI 02886 050263443 501(C)(3) 9500 0 PROGRAM SUPPORT NATIONAL OVARIAN CANCER COALITION 12221 MERIT DRIVE STE 1950 DALLAS TX 75251 650628064 501(C)(3) 8524 0 PROGRAM SUPPORT BRADLEY HOSPITAL FOUNDATION DEVELOPMENT OFFICE PO BOX H PROVIDENCE RI 02901 050500688 501(C)(3) 8000 0 PROGRAM SUPPORT RHODE ISLAND BUSINESS GROUP HEALTH 951 NORTH MAIN STREET PROVIDENCE RI 02904 204545288 501(C)(3) 7500 0 PROGRAM SUPPORT HOPE HEALTH HOSPICE PALLIATIVE CARE 1085 N MAIN STREET PROVIDENCE RI 02904 942576059 501(C)(3) 7500 0 PROGRAM SUPPORT PLEASANT STREET CHRISTIAN REFORMED 25 CROSS STREET WHITINSVILLE MA 01588 042134810 501(C)(3) 6250 0 PROGRAM SUPPORT AMOS HOUSE 415 FRIENDSHIP STREET PROVIDENCE RI 02907 050387218 501(C)(3) 6000 0 PROGRAM SUPPORT OCEAN STATE JOB LOT CHARITABLE 375 COMMERCE PARK RD N KINGSTOWN RI 02852 200959438 501(C)(3) 6000 0 PROGRAM SUPPORT RHODE ISLAND FREE CLINIC 655 BROAD STREET PROVIDENCE RI 02907 050550127 501(C)(3) 5200 0 PROGRAM SUPPORT 23 0 PART I, LINE 2: THE COMPANY DOES NOT ISSUE SPECIFIC GRANTS, HOWEVER, AS PART OF THE CORPORATE RESPONSIBILITY PROGRAM, DELTA DENTAL OF RHODE ISLAND SUPPORTS LOCAL CHARITABLE ORGANIZATIONS. X X 1 1 X X X X X 0 1 0 0 0 0 0 0 0 JOSEPH R PERRONI PRESIDENT & CEO 619661 0 218697 0 3870 0 44283 0 28109 0 914620 0 0 0 THOMAS D CHASE SR. VP & COO 430438 0 86450 0 5940 0 45575 0 27301 0 595704 0 0 0 RICHARD A FRITZ SR. VP FINANCE & CFO 420571 0 83600 0 11431 0 46428 0 21909 0 583939 0 0 0 JAMES KINNEY VP SALES AND BUSINESS RELATIONS 272967 0 75217 0 7044 0 46743 0 24285 0 426256 0 0 0 ELLEN M HENDRIX VP UNDERWRITING & INSURANCE RISK SVC 246051 0 49224 0 3663 0 42541 0 21685 0 363164 0 0 0 MICHELLE LUCAS VP COMMUNICATIONS & EXTERNAL AFFAIRS 219430 0 29077 0 750 0 32003 0 26909 0 308169 0 0 0 ANGELO PEZZULLO SR ADV SALES & BUSINESS RELATIONS 186833 0 44655 0 11099 0 27154 0 13130 0 282871 0 0 0 DUANE S EASTER AVP OF FINANCE 172380 0 18721 0 1651 0 25440 0 28323 0 246515 0 0 0 JUDITH A LOWEN AS OF 42024 AVP OF PROD. & SERV. DEV. 117910 61014 0 16554 1114 576 13841 7733 14359 8058 147224 93935 0 0 JASON E BROWN AS OF 42024 AVP OF GOVERNMENT PROGRAMS 113848 59532 0 17062 247 130 7186 7290 14360 8058 135641 92072 0 0 MELISSA GENNARI AVP & DIRECTOR COMPLIANCE 162989 0 17163 0 1423 0 21475 0 889 0 203939 0 0 0 JOSEPH NAGLE FORMER PRESIDENT & CEO (THRU 6/2019) 0 0 0 0 163904 0 0 0 0 0 163904 0 0 0 PART I, LINE 1A GROSS-UP PAYMENTS THE PRESIDENT'S EMPLOYMENT AGREEMENT CONTAINS PROVISIONS FOR HIM TO RECEIVE PAYMENTS SO THAT HE CAN PERSONALLY PROCURE CERTAIN FRINGE BENEFITS SUCH AS LIFE INSURANCE AND LONG TERM DISABILITY POLICIES THAT ARE OTHERWISE AVAILABLE TO ALL OTHER EMPLOYEES. THIS ADDITIONAL INCOME IS GROSSED UP TO ACCOUNT FOR THE TAX IMPACT OF THESE PAYMENTS AND THE GROSS-UP IS INCLUDED IN REPORTABLE COMPENSATION ON SCHEDULE J PART II COLUMN (B)(III). HEALTH OR SOCIAL CLUB DUES THE PRESIDENT IS A MEMBER OF A LOCAL BUSINESS CLUB. REIMBURSEMENT FOR USE OF THIS IS EXCLUSIVELY FOR OFFSITE EMPLOYEE MEETINGS AS WELL AS BUSINESS RELATED MEETINGS WITH INDIVIDUALS OUTSIDE THE COMPANY. THE COMPANY MAINTAINS STRICT POLICIES REGARDING SUBSTANTIATION AND DOCUMENTATION FOR ALL BUSINESS RELATED EXPENSES INCURRED. THIS BENEFIT IS NOT REPORTED AS TAXABLE COMPENSATION. PART I, LINE 4B DURING THE 2024 CALENDAR YEAR, DELTA DENTAL OF RHODE ISLAND MAINTAINED A SUPPLEMENTAL NON-QUALIFIED DEFERRED COMPENSATION PLAN FOR JOSEPH R. PERRONI, THOMAS D. CHASE, RICHARD A. FRITZ, AND JOSEPH NAGLE. DURING 2024 JOSEPH NAGLE RECEIVED A $163,904 DISTRIBUTION FROM THE PLAN. BLISH & CAVANAGH LANDRY - SECRETARY 139738 LEGAL SERV 0 EAST BAY DENTAL ASSO INC ENRIGHT - BOARD MEMBER 563937 DENTAL SERV 0 SCHEDULE L PART IV BUSINESS TRANSACTIONS INVOLVING INTERESTED PERSONSTHE ORGANIZATION ENGAGES IN TRANSACTIONS WITH DENTAL PRACTICES WITH WHOM THE BOARD MEMBER IDENTIFIED ON SCHEDULE L, PART IV, LINE (2) HAS A CONTROLLING INTEREST. THE TRANSACTION IS ENTERED INTO IN THE ORDINARY COURSE OF BUSINESS AND AT FAIR MARKET VALUE. THE TRANSACTION WITH THIS ENTITY IS SUBJECT TO THE SAME PROCEDURES AND REVIEW AS ALL DENTAL PRACTICES.THE ORGANIZATION RECEIVED LEGAL SERVICES FROM THE LAW FIRM, BLISH & CAVANAGH, WITH WHOM THE SECRETARY, IDENTIFIED ON SCHEDULE L, PART IV, LINE (1), HAS A CONTROLLING INTEREST. THIS TRANSACTION IS ENTERED INTO IN THE ORDINARY COURSE OF BUSINESS AND AT FAIR MARKET VALUE. FORM 990, PART VI, SECTION A, LINE 6 MEMBERS OF THE ORGANIZATION THE ORGANIZATION HAS 81 CORPORATE MEMBERS. FORM 990, PART VI, SECTION A, LINE 7A MEMBERS THAT MAY ELECT THE GOVERNING BODY THE CORPORATE MEMBERS MEET ANNUALLY TO APPROVE ANY BY-LAW CHANGES AND TO ELECT INDIVIDUALS TO THE 15 MEMBER BOARD OF DIRECTORS WHICH IS THE ORGANIZATION'S GOVERNING BODY. ALL 15 MEMBERS OF THE BOARD OF DIRECTORS ALSO SERVE AS REPRESENTATIVES OF THE CORPORATE MEMBERS. FORM 990, PART VI, SECTION A, LINE 7B DECISIONS OF THE GOVERNING BODY SUBJECT TO APPROVAL BY MEMBERS THE MEMBERS OF THE CORPORATION, AT THE ANNUAL MEETING, SHALL ELECT DIRECTORS OF THE CORPORATION THAT HAVE BEEN PROPOSED BY THE BOARD OF DIRECTORS AND SHALL APPROVE AMENDMENTS OR ALTERATIONS OF THE BY-LAWS PROPOSED BY THE BOARD OF DIRECTORS. FORM 990, PART VI, SECTION B, LINE 11B FORM 990 REVIEW PROCESS THE ANNUAL FORM 990 IS PREPARED BY GRANT THORNTON ADVISORS LLC, THE COMPANY'S TAX ADVISOR USING INFORMATION PROVIDED BY DELTA DENTAL OF RHODE ISLAND. AFTER PREPARATION AND REVIEW OF THE RETURN BY GRANT THORNTON ADVISORS, THE DRAFT IS REVIEWED BY DELTA DENTAL'S FINANCE DEPARTMENT AND MANAGEMENT, INCLUDING THE CONTROLLER, THE DIRECTOR OF FINANCE, SR VP-CFO, AND CEO AS NECESSARY. THE COMPLETE FORM 990 IS THEN PROVIDED TO EACH MEMBER OF THE BOARD OF DIRECTORS PRIOR TO FILING WITH THE INTERNAL REVENUE SERVICE. FORM 990, PART VI, SECTION B, LINE 12C CONFLICT OF INTEREST POLICY ALL W-2 EMPLOYEES, INTERNS, TEMPS, DENTAL CONSULTANTS, AND BOARD MEMBERS COMPLETE AN ANNUAL CONFLICT OF INTEREST QUESTIONNAIRE. THE REVIEW PROCESS FOR COMPLETE QUESTIONNAIRES CONTAINING DISCLOSURES IS AS FOLLOWS: FOR W-2 EMPLOYEES, INTERNS, AND TEMPS, DISCLOSURES ARE REVIEWED BY THE AVP & DIRECTOR OF COMPLIANCE AND SR VP-CFO. DISCLOSED POTENTIAL CONFLICTS ARE DISCUSSED AND MAY BE ELEVATED IN THE REVIEW PROCESS TO THE CEO AND EXTERNAL LEGAL COUNSEL FOR ADVICE. ANY REQUIRED ACTIONS ARE IMMEDIATELY IMPLEMENTED IN ACCORDANCE WITH THE COMPANY'S DOCUMENTED CONFLICT OF INTEREST POLICIES. FOR THE CEO AND SR VP-CFO, DISCLOSURES ARE REVIEWED BY EXTERNAL LEGAL COUNSEL. LEGAL COUNSEL ADVISES OF ANY REQUIRED ACTIONS WHICH ARE IMMEDIATELY IMPLEMENTED IN ACCORDANCE WITH THE COMPANY'S DOCUMENTED STANDARDS OF CONDUCT AND BUSINESS ETHICS AND CONFLICT OF INTEREST POLICIES. FOR DENTAL CONSULTANTS, DISCLOSURES ARE REVIEWED BY THE AVP & DIRECTOR OF COMPLIANCE, THE SR VP-CFO, AND THE SR VP-COO. ALL CONFLICTS ARE DISCUSSED AND MAY BE ELEVATED TO EXTERNAL LEGAL COUNSEL FOR ADVICE. ANY REQUIRED ACTIONS ARE IMMEDIATELY IMPLEMENTED IN ACCORDANCE WITH THE COMPANY'S DOCUMENTED CONFLICT OF INTEREST POLICIES. FOR BOARD MEMBERS, DISCLOSURES ARE REVIEWED BY EXTERNAL LEGAL COUNSEL. LEGAL COUNSEL PREPARES A WRITTEN MEMORANDUM FOR PRESENTATION TO BOARD MEMBERS WITH THE RESULTS OF THE REVIEW. ALL CONFLICTS ARE DISCUSSED AND ANY REQUIRED ACTIONS ARE IMMEDIATELY IMPLEMENTED IN ACCORDANCE WITH THE COMPANY'S DOCUMENTED CONFLICT OF INTEREST POLICIES. IN THE CASE OF A CONFLICT, IMMEDIATE AND APPROPRIATE ACTION IS TAKEN IN ACCORDANCE WITH THE COMPANY'S POLICIES. PERSONS WITH A CONFLICT ARE RECUSED FROM DISCUSSIONS AND DO NOT VOTE ON RESOLUTIONS THAT PERTAIN DIRECTLY TO THEIR CONFLICT. FORM 990, PART VI, SECTION B, LINE 15 COMPENSATION POLICY THE BOARD OF DIRECTORS ELECTS INDEPENDENT MEMBERS TO SERVE ON ITS COMPENSATION COMMITTEE WHICH IS RESPONSIBLE FOR SETTING THE CEO'S COMPENSATION AND APPROVING PAY RANGES FOR THE VARIOUS JOB TRACKS WITHIN THE COMPANY AS WELL AS APPROVING ANY FRINGE BENEFITS. THE COMPANY AND THE COMMITTEE ANNUALLY CONTRACT WITH INDEPENDENT COMPENSATION CONSULTANTS TO HELP DETERMINE APPROPRIATE PAY RANGES AND FRINGE BENEFITS SUCH AS HEALTH AND OTHER INSURANCES AND RETIREMENT AND OTHER BENEFITS. COMPARABLE DATA IS USED TO DETERMINE WHETHER COMPENSATION IS CONSISTENT WITH SIMILAR ORGANIZATIONS. RECOMMENDATIONS FOR THE CEO'S COMPENSATION ARE MADE BY THE COMPENSATION COMMITTEE TO THE BOARD OF DIRECTORS FOR REVIEW AND APPROVAL. THE REVIEW AND APPROVAL PROCESS IS CONTEMPORANEOUSLY DOCUMENTED IN THE MINUTES OF BOTH THE COMPENSATION COMMITTEE AND THE BOARD OF DIRECTORS. FORM 990, PART VI, SECTION C, LINE 19 PUBLIC DISCLOSURE THE COMPANY'S GOVERNING DOCUMENTS, SUCH AS BYLAWS AND CORPORATE CHARTER, ARE AVAILABLE UPON REQUEST FROM THE COMPANY AND CAN ALSO BE OBTAINED FROM THE SECRETARY OF STATE'S OFFICE WITHIN THE STATE OF RHODE ISLAND. THE COMPANY'S CONFLICT OF INTEREST POLICY, AS WELL AS THE COMPANY'S AUDITED FINANCIAL STATEMENTS, ARE ALSO AVAILABLE UPON REQUEST AT THE COMPANY'S HEADQUARTERS. ADDITIONALLY, ALL STATUTORY FILINGS COMPLETED BY THE COMPANY ARE AVAILABLE THROUGH THE INSURANCE DIVISION WITHIN THE RHODE ISLAND DEPARTMENT OF BUSINESS REGULATION. THE COMPANY'S FORM 990 IS ALSO POSTED ON WWW.GUIDESTAR.ORG. ALTUS REALTY INC 10 CHARLES STREET PROVIDENCE RI 029042208 030396397 HOLDING CO. 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