2013-08-15T14:03:56-05:00 2012-12-31 BKD LLP 201 N Illinois Street Indianapolis IN 46204 990 2012-01-01 351978359 THE FRIEDMAN FOUNDATION FOR EDUCATIONAL CHOICE INC % CAREY E FOLCO FRIE 3176810745 ONE AMERICAN SQUARE Suite 2420 INDIANAPOLIS IN 46282 ROBERT C ENLOW 3176810745 2013-08-15 true NICOLE B FISHBACK 3173834000 2012 2016-02-25 16:41:14Z ROBERT C ENLOW ONE AMERICAN SQUARE STE 2420 INDIANAPOLIS IN 46282 5414327 false X WWW.EDCHOICE.ORG X 1996 IN PROMOTING SCHOOL CHOICE IN ORDER TO IMPROVE, THROUGH COMPETITION, K-12 EDUCATION FOR ALL. 13 12 18 0 0 4498513 5278378 0 0 310624 86589 0 -129241 4809137 5235726 839500 1111800 0 0 1262017 1495754 0 0 747316 2007701 2281263 4109218 4888817 699919 346909 6461598 7362855 142260 241769 6319338 7121086 THE FOUNDATION WAS ESTABLISHED BY MILTON AND ROSE D. FRIEDMAN IN 1996 TO EDUCATE THE PUBLIC ON THE NEED FOR AND BENEFITS OF PARENTAL SCHOOL CHOICE. OUR EDUCATIONAL WORK INCLUDES RESEARCH, COMMUNICATIONS AND MARKETING, PUBLIC OUTREACH, AND GRANT-MAKING. false false 1111800 1111800 GRANTMAKING: THE FOUNDATION AWARDED 86 GRANTS TO CHARITABLE ORGANIZATIONS FOR EDUCATIONAL PURPOSES. 2066124 EDUCATION ACTIVITIES - THE FOUNDATION WORKED AROUND THE COUNTRY TO EDUCATE THE PUBLIC ON THE PRACTICE AND BENEFITS OF SCHOOL CHOICE, IN EACH INSTANCE PROVIDING EDUCATIONAL SERVICES TO STATE-BASED ORGANIZATIONS, INDIVIDUALS AND POLICY MAKERS. THESE SERVICES INCLUDE: SPONSORING FACT-FINDING TRIPS TO CITIES/STATES WITH SCHOOL CHOICE PROGRAMS; HOSTING INFORMATIONAL SYMPOSIUMS; SPONSORING VISITS BY EXPERT SPEAKERS; TESTIFYING IN FRONT OF VARIOUS LEGISLATIVE BODIES AT THEIR REQUEST; PARENT EDUCATION EFFORTS AND TRAINING; MEDIA SUPPORT AND MEDIA TRAINING; PROVIDING TECHNICAL ADVICE ON THE DRAFTING OF LEGISLATION; AND SPONSORING MEETINGS WITH FOUNDATION STAFF AND VARIOUS SCHOOL CHOICE EXPERTS. 676535 RESEARCH AND COMMUNICATION - THE FOUNDATION PRODUCED PUBLICATIONS AND RESEARCH REPORTS INCLUDING, BUT NOT LIMITED TO, ITS BIMONTHLY NEWSLETTER (THE SCHOOL CHOICE ADVOCATE); STATE AND NATIONAL RESEARCH REPORTS; PUBLIC POLICY SURVEYS; AND OUR ANNUAL BROCHURE ENTITLED THE ABC'S OF SCHOOL CHOICE. THE FOUNDATION PRODUCED EDUCATIONAL MARKETING FLIERS AND PROMOTIONAL BROCHURES FOR STATE SCHOOL CHOICE PARTNERS. THE FOUNDATION UNDERTOOK POLLS IN EFFORTS TO GAUGE PUBLIC OPINION. 3854459 true true false true false false false false false false true false false false false false true false false false true false false false true false false true false true false false false false false false false false false false false false false false false false false true 39 0 true 18 true false false false false false true true false false false false X 13 12 true false false false false false false true true false false true true true true true true true false false AL AK AZ AR CA CT FL GA HI IL IN KS KY MD MA MI MN MS MO NH NJ NM NY NC OH OK OR PA RI SC TN UT VA WA WV WI X CAREY E FOLCO 3176810745 ONE AMERICAN SQUARE STE 2420 INDIANAPOLIS IN 46282 ROBERT C ENLOW 45.0 X X 200800 0 22932 PATRICK M BYRNE 2.0 X X 0 0 0 JANET FRIEDMAN MARTEL 2.0 X X 0 LAWRENCE A O'CONNOR JR 1.0 X X 0 DAVID D FRIEDMAN 1.0 X 0 CHARLES H BRUNIE 1.0 X 0 WILLIAM J HUME 1.0 X 0 FRED REAMS 1.0 X 0 MICHAEL WALKER 1.0 X 0 FRED S KLIPSCH 1.0 X 0 VIRGINIA WALDEN-FORD 1.0 X 0 GREG GIANFORTE 1.0 X 0 J SCOTT ENRIGHT 5.0 X X 0 CAREY E FOLCO 40.0 X 78800 0 14712 LESLIE HINER 45.0 X 153300 5640 CYNTHIA SPARKS 45.0 X 283317 0 716217 0 43284 3 false true false 0 372990 4905388 5278378 0 86589 86589 0 0 0 0 0 0 49360 372990 178601 -129241 -129241 0 0 0 5235726 -42652 X 1111800 1111800 0 0 0 476184 282964 92939 100281 0 863199 485185 48505 329509 22525 14576 3074 4875 55776 36094 7612 12070 78070 49334 8717 20019 0 59465 4731 54734 16668 16668 101089 101089 0 15 15 333142 316276 12185 4681 279123 279123 61228 38643 15842 6743 0 0 105000 72542 12569 19889 202656 183504 949 18203 41950 41950 372281 329626 6498 36157 0 0 13403 9384 1563 2456 18346 12834 2143 3369 MAILING AND PRINTING FEES 410330 220009 3029 187292 STATE POLLING 85590 85590 SPEAKER/MODERATOR FEES 143680 143680 SPONSORED FEES 37297 35525 1772 4888817 3854459 287042 747316 1178128 717711 2369731 2170505 0 0 0 10200 0 0 0 0 0 0 0 0 26156 35627 209854 165592 43671 44262 2843912 4384550 0 0 0 0 0 0 0 0 6461598 7362855 142260 241769 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 142260 241769 X 6319338 6666086 0 455000 0 0 6319338 7121086 6461598 7362855 346909 454839 X false true X true false X 3614015 3484296 4214115 4498513 5327738 21138677 0 0 3614015 3484296 4214115 4498513 5327738 21138677 9689850 11448827 257849 134075 96407 59604 86589 634524 0 509 0 0 0 0 509 21773710 0.52581 0.51820 X RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 41040 70644 111684 4955734 5067418 403371 100843 329588 354167 355461 403371 1442587 2163881 23627 47404 81219 111684 263934 82397 88542 88865 100843 360647 540971 12803 15463 23721 41040 93027 LOBBYING EXPENDITURES TO INFLUENCE PUBLIC OPINION SCHEDULE C, PART II-A THE FRIEDMAN FOUNDATION FOR EDUCATIONAL CHOICE IS NEVER INVOLVED IN POLITICAL CAMPAIGNS. THE SUBSTANTIAL ACTIVITY UNDERTAKEN BY THE FRIEDMAN FOUNDATION FOR EDUCATIONAL CHOICE IS EDUCATIONAL IN NATURE. CONSISTENT WITH A NONPROFIT ORGANIZATION WITH "H ELECTION," THE FOUNDATION ALSO UNDERTAKES LIMITED LOBBYING ACTIVITIES IN CERTAIN STATES TO AID IN THE PASSAGE OF LEGISLATION THAT ENABLES PARENTS TO RECEIVE A PUBLICLY FUNDED VOUCHER OR A TAX CREDIT FUNDED SCHOLARSHIP TO SEND THEIR CHILDREN TO APPROVED PRIVATE SCHOOLS. IN 2012, THESE ACTIVITIES INCLUDED ALLOCATING STAFF TIME FOR DIRECT LOBBYING TO STATE LEGISLATORS AND ENCOURAGING THE GENERAL PUBLIC TO SUPPORT SPECIFIC LEGISLATION. 72480 40072 32408 137374 125520 11854 0 0 0 44262 5869166 454839 178601 633440 5235726 5235726 5067418 178601 178601 4888817 4888817 FIN 48 DISCLOSURE SCHEDULE D, PART X MANAGEMENT HAS EVALUATED THEIR INCOME TAX POSITIONS UNDER THE GUIDANCE INCLUDED IN ASC 740. BASED ON ITS REVIEW, MANAGEMENT HAS NOT IDENTIFIED ANY MATERIAL UNCERTAIN TAX POSITIONS TO BE RECORDED OR DISCLOSED IN THE FINANCIAL STATEMENTS. RECONCILIATION OF REVENUE AND EXPENSE PART XI & XII, LINE 2D FUNDRAISING EXPENDITURES: 178,601 East Asia and the Pacific 0 0 Program Services EDUCATION EVENTS 5000 Europe (Including Iceland and Greenland) 0 0 Program Services EDUCATION EVENTS 9000 Middle East and North Africa 0 0 Program Services EDUCATION EVENTS 1000 North America 0 0 Program Services EDUCATION EVENTS 2000 Russia and the Newly Independent States 0 0 Program Services EDUCATION EVENTS 2000 South America 0 0 Program Services EDUCATION EVENTS 9000 South Asia 0 0 Program Services EDUCATION EVENTS 5018 Sub-Saharan Africa 0 0 Program Services EDUCATION EVENTS 2000 0 0 0 0 35018 35018 false false false false false false POWER OF ONE 401470 362545 38925 71789 86441 LUNCHEON 20880 10445 10435 10596 6553 3222 0 422350 372990 49360 82385 6553 89663 178601 -129241 true 100 Black Men of Indianapolis Inc 3901 N Meridian St Indianapolis IN 46208 351813852 501(C)(3) 10000 SEE PART IV Advance America Inc 101 W Ohio St Indianapolis IN 46204 351510587 501(C)(3) 20000 SEE PART IV Agudath Israel of America 42 Broadway 14th Floor New York NY 10004 363529801 501(C)(3) 15000 SEE PART IV Alaska Policy Forum Inc 201 Barrow Street 8 Anchorage AK 99501 264380206 501(C)(3) 20000 SEE PART IV Americans for Prosperity Foundation 2111 Wilson Blvd Arlington VA 22201 521527294 501(C)(3) 59000 SEE PART IV Barry Goldwater Institute for Public Policy Resear 500 E Coronado Road Phoenix AZ 85004 860597661 501(C)(3) 30000 SEE PART IV Beacon Center of Tennessee 200 4th Ave North Nashville TN 37219 201808567 501(C)(3) 140000 SEE PART IV Becket Fund 3000 K Street Washington DC 20007 521858532 501(C)(3) 105000 SEE PART IV Education Writers Association 2122 P St Ste 201 Washington DC 20037 237439790 501(C)(3) 10000 SEE PART IV Federalist Society for Law & Public Policy Studies 1015 18th St Ste 425 Washington DC 20036 363235550 501(C)(3) 10000 SEE PART IV Franklin Center for Government & Public Integrity 127 S Peyton St Alexandria VA 22314 264066298 501(C)(3) 10000 SEE PART IV Hispanic American Center for Economic Research (HA 910 17th St NW Washington DC 20006 541901356 501(C)(3) 10000 SEE PART IV Hispanic Council for Reform and Educational Option 8461 Lake Worth Rd Lake Worth FL 33467 743023330 501(C)(3) 20000 SEE PART IV Idaho Freedom Foundation Inc PO Box 2801 Boise ID 83701 263783048 501(C)(3) 30000 SEE PART IV Josiah Bartlett Center for Public Policy 7 S State Street Concord NH 03301 223235650 501(C)(3) 15000 SEE PART IV Kansas Policy Institute 250 N Water Ste 216 Wichita KS 67202 237047821 501(C)(3) 30000 SEE PART IV Mississippi Center for Public Policy 520 George Street Jackson MS 39202 640797905 501(C)(3) 56000 SEE PART IV Montana Family Foundation Inc PO Box 485 Laurel MT 59044 753008481 501(C)(3) 20000 SEE PART IV Oklahoma Council of Public Affairs Inc 1401 N Lincoln Oklahoma City OK 73104 731436375 501(C)(3) 65000 SEE PART IV Parents for Educational Freedom in North Carolina 434 Fayetteville St Raleigh NC 27601 202754466 501(C)(3) 65000 SEE PART IV Pelican Institute for Public Policy 643 Magazine St New Orleans LA 70130 261704791 501(C)(3) 51000 SEE PART IV School Choice Indiana Inc PO Box 441078 Indianapolis IN 46244 204046250 501(C)(3) 200000 SEE PART IV School Choice Wisconsin Inc 219 N Milwaukee St Milwaukee WI 53202 383695127 501(C)(3) 20000 SEE PART IV Schools That Can 1040 First Avenue 346 New York NY 10022 364268793 501(C)(3) 10000 SEE PART IV Thomas Jefferson Institute for Public Policy 9035 Golden Sunset Ln Springfield VA 22153 510280185 501(C)(3) 17800 SEE PART IV 25 MONITORING THE USE OF GRANT FUNDS SCHEDULE I, PART I, LINE 2 THE FOUNDATION ACCEPTS APPLICATIONS FOR GRANTS THAT CONFORM TO THE FOUNDATION'S TAX-EXEMPT PURPOSE AND EDUCATIONAL MISSION. APPLICATIONS MUST INCLUDE A BRIEF DESCRIPTION OF THE PROJECT, AMOUNT REQUESTED, PROJECT BUDGET, METHOD TO EVALUATE SUCCESS, BOARD OF DIRECTORS LIST, AND FINANCIAL STATEMENTS. THE FOUNDATIONS PROGRAM STAFF REVIEWS THE REQUEST AND SUBMITS SUGGESTED GRANTS TO THE EXECUTIVE MANAGEMENT. AFTER APPROVAL, THE VICE PRESIDENT OF OPERATIONS REVIEWS THE REQUEST FOR PROPER DOCUMENTATION AND WRITES THE GRANT AGREEMENT WHICH IS SIGNED BY GRANTEE AND THE PAYMENT IS MADE. PROGRAM STAFF WORKS CLOSELY WITH GRANTEE TO ENSURE ADHERENCE TO AGREEMENT AND USE OF GRANT FUNDS. GRANTEES ARE REQUIRED TO SUBMIT A FINAL REPORT ON THE PROJECT, INCLUDING HOW FUNDS WERE USED, IN A TIMELY MANNER AS NOTED IN THE GRANT AGREEMENT. PURPOSE OF GRANT OR ASSISTANCE SCHEDULE I, PART II, LINE 1, COLUMN H *100 BLACK MEN OF INDIANAPOLIS INC. - SUPPORT FOR THE EDUCATION PILOT COMMITTEE TO ATTEND THE ANNUAL BAEO SYMPOSIUM FOR EDUCATION POLICY. *ADVANCE AMERICA INC. - "GENERAL OPERATING SUPPORT INCLUDING TWO MEETINGS, 10 EMAIL OUTREACH LETTERS, A BRIEFING FOR CHRISTIAN SCHOOLS AND COVERAGE ON 15 RADIO PROGRAMS AIRED ON 28 STATIONS." *AGUDATH ISRAEL OF AMERICA - SUPPORT FOR PUBLIC EDUCATION EFFORTS IN THE JEWISH COMMUNITY, PARTICULARLY FOR PUBLIC POLLING AND FOR OHIO REGIONAL DIRECTOR. *ALASKA POLICY FORUM INC. - SUPPORT TO HOST EDUCATIONAL FORUMS DURING NATIONAL SCHOOL CHOICE WEEK. ALSO GENERAL OPERATING SUPPORT TO EDUCATE ALASKANS ON UNIVERSAL SCHOOL CHOICE. *AMERICANS FOR PROSPERITY FOUNDATION - SUPPORT TO PRODUCE A 20-MINUTE DOCUMENTARY ON SCHOOL CHOICE IN OKLAHOMA AND SUPPORT TO HOST A SERIES OF TOWN-HALL STYLE EDUCATIONAL MEETINGS IN INDIANA. ALSO SUPPORT TO HOST OR COORDINATE AN EVENT ON JULY 31, 2012, TO HONOR THE LEGACY OF MILTON FRIEDMAN AND HIS IDEAS. *BARRY GOLDWATER INSTITUTE FOR PUBLIC POLICY RESEARCH (GOLDWATER INSTITUTE) - SUPPORT TO DEVELOP A MARKETING AND COMMUNICATIONS STRATEGY FOR PROMOTING EDUCATION SAVINGS ACCOUNTS. *BEACON CENTER OF TENNESSEE - SUPPORT FOR PARENT OUTREACH AND MARKETING EFFORTS AIMED AT EDUCATING TENNESSEANS ON SCHOOL CHOICE. ALSO SUPPORT FOR THE CHOOSE ME TENNESSEE CAMPAIGN AS WELL AS OTHER MARKETING EFFORTS FOR THE PURPOSE OF EDUCATING THE PUBLIC ABOUT THE BENEFITS OF SCHOOL CHOICE. *BECKET FUND - SUPPORT FOR THE BECKET FUND'S REPRESENTATION OF PARENTS AND THEIR CHILDREN IN LITIGATION PROCEEDING IN OKLAHOMA'S STATE COURTS, WHERE PUBLIC SCHOOL DISTRICTS HAVE SUED THEIR OWN RESIDENT PARENTS FOR ACCESSING EDUCATIONAL VOUCHERS FOR THEIR CHILDREN WITH SPECIAL NEEDS TO ATTEND SCHOOLS OF THEIR CHOICE UNDER THE LINDSEY NICOLE HENRY SCHOLARSHIP FOR CHILDREN WITH DISABILITIES PROGRAMS. *EDUCATION WRITERS ASSOCIATION - SUPPORT TO SPONSOR THE NATIONAL SEMINAR IN MAY 2012. *FEDERALIST SOCIETY FOR LAW & PUBLIC POLICY STUDIES - SUPPORT TO EDUCATE FEDERALIST SOCIETY LAW SCHOOL CHAPTER LEADERS AND STUDENTS ABOUT THE MERITS OF SCHOOL CHOICE. *FRANKLIN CENTER FOR GOVERNMENT & PUBLIC INTEGRITY - SUPPORT FOR THE PROJECT CAPITOL BEAT OK TO PROMOTE FAMILIES' SCHOOL CHOICE STORIES. *HISPANIC COUNCIL FOR REFORM AND EDUCATIONAL OPTIONS - GENERAL OPERATING SUPPORT FOR EDUCATIONAL ACTIVITIES IN ARIZONA AND NEW MEXICO. *IDAHO FREEDOM FOUNDATION INC. - GENERAL OPERATING SUPPORT FOR RESEARCH, EDUCATION AND OUTREACH EFFORTS TO EDUCATE PARENTS, MEDIA AND COMMUNITY LEADERS ON THE BENEFITS OF SCHOOL CHOICE. *JOSIAH BARTLETT CENTER FOR PUBLIC POLICY - SUPPORT FOR CONDUCTING SCHOOL CHOICE RESEARCH AND PROMOTION OF THE RESEARCH. *KANSAS POLICY INSTITUTE - SUPPORT FOR EDUCATION RESEARCH AND THE PROMOTION OF EDUCATION REFORM IN KANSAS. ALSO SUPPORT FOR CONDUCTING EDUCATIONAL RESEARCH AND PROMOTING THAT RESEARCH. *MISSISSIPPI CENTER FOR PUBLIC POLICY - GENERAL OPERATING SUPPORT FOR EDUCATING COMMUNITY LEADERS, POLICY-MAKERS AND PARENTS ABOUT THE BENEFITS OF SCHOOL CHOICE. *MONTANA FAMILY FOUNDATION INC. - GENERAL OPERATING SUPPORT, INCLUDING AN EDUCATIONAL CONFERENCE FOR NORTHWEST STATE LEGISLATORS. *OKLAHOMA COUNCIL OF PUBLIC AFFAIRS INC. - SUPPORT FOR EDUCATIONAL ACTIVITIES TO BUILD AWARENESS AND SUPPORT FOR SCHOOL CHOICE. AND ALSO GENERAL OPERATING SUPPORT FOR EDUCATIONAL ACTIVITIES IN OKLAHOMA. *PARENTS FOR EDUCATIONAL FREEDOM IN NORTH CAROLINA INC. - GENERAL OPERATING SUPPORT FOR 501C3 ACTIVITY IN NORTH CAROLINA IN SUPPORT OF SCHOOL CHOICE. *PELICAN INSTITUTE FOR PUBLIC POLICY - GENERAL OPERATING SUPPORT TO EDUCATE THE MEDIA, GENERAL PUBLIC AND POLICY MAKERS ON THE BENEFITS OF SCHOOL CHOICE, PARTICULARLY THROUGH MEDIA RELATIONS, EDUCATIONAL EVENTS AND RESEARCH. *SCHOOL CHOICE INDIANA INC. - GENERAL OPERATING SUPPORT TO EDUCATE AND INFORM THE MEDIA AND TO CONDUCT VOUCHER IMPLEMENTATION EFFORTS IN INDIANA. *SCHOOL CHOICE WISCONSIN INC. - SUPPORT TO EXPAND PARENTAL AWARENESS OF SCHOOL CHOICE OPTIONS AVAILABLE IN WISCONSIN AND TO ASSIST WITH IMPLEMENTATION ACTIVITIES FOR NEW PROGRAMS. *SCHOOLS THAT CAN - SUPPORT TO SPONSOR THE 2012 SCHOOLS THAT CAN NATIONAL FORUM IN BOSTON, MA. *THOMAS JEFFERSON INSTITUTE FOR PUBLIC POLICY - SUPPORT FOR EDUCATIONAL ACTIVITIES TO BUILD AWARENESS AND SUPPORT FOR SCHOOL CHOICE. X X X X false false false false false false false false false ROBERT C ENLOW 200800 0 0 0 5748 0 17184 0 223732 0 0 0 LESLIE HINER 153300 0 0 3600 2040 158940 0 CYNTHIA SPARKS 283317 0 0 0 0 283317 0 COMPLIANCE WITH BACKUP WITHHOLDING RULES FORM 990, PART V, LINE 1C THE FOUNDATION WAS NOT REQUIRED TO COMPLY WITH THE BACKUP WITHHOLDING RULES BECAUSE IT DID NOT MAKE REPORTABLE PAYMENTS TO VENDORS OR PAY REPORTABLE GAMING (GAMBLING) WINNINGS TO PRIZE WINNERS. KEY OFFICER OR EMPLOYEE WITH FAMILY RELATIONSHIP WITH ANY OTHER OFFICER FORM 990, PART VI, SECTION A, LINE 2 JANET FRIEDMAN MARTEL AND DAVID D. FRIEDMAN ARE SIBLINGS. PROCESS TO REVIEW THE FORM 990 FORM 990, PART VI, SECTION B, LINE 11B THE FORM 990 IS COMPLETED BY AN OUTSIDE ACCOUNTING FIRM, IN CONJUNCTION WITH THE FOUNDATION'S VICE PRESIDENT OF OPERATIONS AND CONTROLLER. THE FORM 990 IS REVIEWED BY THE FOUNDATION'S PRESIDENT & CEO, VICE PRESIDENT OF OPERATIONS, CONTROLLER, SECRETARY, AN INDEPENDENT ACCOUNTING FIRM AND AN OUTSIDE ATTORNEY. UPON COMPLETION, THE FINAL FORM 990 IS SENT TO THE FULL BOARD OF DIRECTORS FOR REVIEW BEFORE FILING. PROCESS FOR MONITORING COMPLIANCE WITH CONFLICT OF INTEREST POLICY FORM 990, PART VI, SECTION B, LINE 12C THE FOUNDATION'S BOARD OF DIRECTORS HAS ADOPTED A CONFLICT OF INTEREST POLICY THAT REQUIRES DIRECTORS, OFFICERS AND KEY EMPLOYEES TO SUBMIT AN ANNUAL CONFLICT OF INTEREST DISCLOSURE. THE ANNUAL DISCLOSURE REQUIRES DIRECTORS, OFFICERS AND KEY EMPLOYEES TO DISCLOSE, IN WRITING, ANY KNOWN FINANCIAL INTEREST THAT THE INDIVIDUAL (TOGETHER WITH FAMILY MEMBERS) HAS IN ANY BUSINESS ENTITY THAT TRANSACTS BUSINESS WITH THE FOUNDATION. IN ADDITION, DIRECTORS, OFFICERS AND KEY EMPLOYEES ARE REQUIRED TO IMMEDIATELY DISCLOSE ANY POSSIBLE CONFLICT OF INTEREST THAT ARISES MID-YEAR IN RELATION TO A PROPOSED TRANSACTION. THE CONFLICT OF INTEREST POLICY REQUIRES THAT ANY INDIVIDUAL WITH A CONFLICT BE RECUSED FROM THE DECISION-MAKING PROCESS, THAT INDEPENDENT DIRECTORS DETERMINE WHETHER THE PROPOSED TRANSACTION IS IN THE BEST INTERESTS OF THE FOUNDATION, AND THE TRANSACTION MUST BE APPROVED BY A VOTE OF THE INDEPENDENT DIRECTORS WITHOUT THE PARTICIPATION OF ANY INTERESTED INDIVIDUAL. THE ANNUAL CONFLICT DISCLOSURE STATEMENTS ARE SUBMITTED TO, AND REVIEWED BY, THE FOUNDATION'S VICE PRESIDENT OF OPERATIONS. IN ADDITION, THE EXECUTIVE STAFF OF THE FOUNDATION ARE RESPONSIBLE FOR MONITORING ANY POSSIBLE CONFLICT TRANSACTIONS THAT ARISE AND MANAGING THEM TO ENSURE THAT ALL TRANSACTIONS REPRESENT ARMS' LENGTH, FAIR MARKET VALUE TERMS FOR THE BENEFIT OF THE FOUNDATION. REVIEW OF CEO OR TOP MGT OFFICAL COMPENSATION FORM 990, PART VI, SECTION B, LINE 15A THE FOUNDATION'S BOARD OF DIRECTORS HAS ADOPTED AN EXECUTIVE COMPENSATION AND INTERMEDIATE SANCTIONS POLICY. THE PURPOSE OF THE POLICY IS TO ENSURE THAT THE FOUNDATION'S COMPENSATION ARRANGEMENTS WITH RELATED PARTIES ARE EVALUATED AND ENTERED AT ARMS' LENGTH AND THAT ANY COMPENSATION THAT IS PAID TO A RELATED PARTY IS REASONABLE AND REFLECTS FAIR MARKET VALUE. THE POLICY ENCOURAGES THE APPLICATION OF THE REBUTTABLE PRESUMPTION STANDARD OF CODE SECTION 4958 AND THE RELATED TREASURY REGULATIONS BY (A) EXCLUDING ANY INTERESTED PARTY FROM THE DECISION-MAKING PROCESS; (B) REQUIRING DISINTERESTED BOARD MEMBERS TO OBTAIN AND RELY UPON COMPARABILITY DATA WHEN SETTING THE PROPOSED COMPENSATION TERMS; (C) REQUIRING APPROVAL OF THE TRANSACTION IN ADVANCE BY DISINTERESTED DIRECTORS; AND (D) REQUIRING CONTEMPORANEOUS DOCUMENTATION (I.E., MINUTES) REFLECTING THE DECISION AND THE PROCESS BY WHICH IT WAS MADE. DURING JANUARY 2011, INDEPENDENT MEMBERS OF THE BOARD OF DIRECTORS, MEETING AS A SEPARATE COMMITTEE EVALUATED THE COMPENSATION OF THE PRESIDENT/CEO, EVALUATED COMPARABILITY DATA, AND USED SUCH DATA TO SET HIS COMPENSATION FOR 2011 AND 2012. AN EXECUTIVE COMPENSATION COMMITTEE WAS HELD ON JANUARY 9, 2013 TO SET COMPENSATION FOR 2013. GOVERNING DOCUMENTS AVAILABLE TO THE PUBLIC FORM 990, PART VI, QUESTION 19 THE ORGANIZATION MAKES ITS GOVERNING DOCUMENTS, CONFLICT OF INTEREST POLICY, AND FINANCIAL STATEMENTS AVAILABLE TO THE PUBLIC UPON REQUEST. PAYMENTS FOR TRAVEL FOR PUBLIC OFFICALS FORM 990, PART IX, LINE 18 PAYMENTS ARE FOR TRAVEL EXPENSES INCURRED DURING FACT-FINDING EDUCATIONAL TRIPS AND EDUCATIONAL SEMINARS HOSTED BY THE FOUNDATION. EXPENSES COVERED INCLUDED TRANSPORTATION, HOTEL AND MEALS.