| FORM 990, PART VI, SECTION A, LINE 4 |
SIGNIFICANT CHANGES TO THE GOVERNING DOCUMENTS: ICI MADE IT A REQUIREMENT THAT THE CONFLICT OF INTEREST POLICY BE ACKNOWLEDGED AND ACCEPTED BY EACH DIRECTOR ANNUALLY. ICI REMOVED THE REQUIREMENT THAT OFFICERS ALSO HAVE TO BE DIRECTORS. THE FULL BOARD DOES NOT NEED TO VOTE ON AN EXTENSION OF TERM OF AN OFFICER OR THE FILING OF AN OFFICER VACANCY. |
| FORM 990, PART VI, SECTION B, LINE 11B |
PROCESS TO REVIEW THE FORM 990: ICI'S BOARD OF DIRECTORS HAS FORMALLY DELEGATED AUTHORITY FOR THE REVIEW OF ITS FORM 990 TO THE ICI AUDIT COMMITTEE AFTER THE SAME IS PRELIMINARILY REVIEWED BY THE ORGANIZATION'S EXECUTIVE LEADERSHIP. A FULL COPY OF THE FORM 990 IS PROVIDED TO THE BOARD BEFORE IT IS FILED. IN ADDITION, ICI'S OUTSIDE ACCOUNTING FIRM PREPARED AND REVIEWED THE FORM 990 BEFORE FILING. |
| FORM 990, PART VI, SECTION B, LINE 12C |
PROCESS FOR MONITORING COMPLIANCE WITH CONFLICT OF INTEREST POLICY: THE ORGANIZATION 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 ORGANIZATION. IN ADDITION, DIRECTORS, OFFICERS, AND KEY EMPLOYEES ARE REQUIRED TO IMMEDIATELY DISCLOSE ANY POSSIBLE CONFLICTS OF INTEREST THAT ARISE 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 OR COMMITTEE MEMBERS DETERMINE THAT THE PROPOSED TRANSACTION IS IN THE BEST INTEREST OF THE ORGANIZATION, AND THE TRANSACTION MUST BE APPROVED BY A VOTE OF THE INDEPENDENT DIRECTORS OR COMMITTEE MEMBERS WITHOUT THE PARTICIPATION OF ANY INTERESTED INDIVIDUAL. |
| FORM 990, PART VI, SECTION B, LINE 15A AND 15B |
REVIEW OF CEO OR TOP MGMT OFFICIAL COMPENSATION: THE EXECUTIVE COMMITTEE DETERMINES THE COMPENSATION OF THE CEO. THIS COMMITTEE IS COMPOSED OF DISINTERESTED BOARD MEMBERS, AND THEY RELY UPON COMPARABILITY DATA REGARDING SIMILARLY SITUATED INDIVIDUALS AT PEER ORGANIZATIONS WHEN SETTING THE PROPOSED COMPENSATION TERMS. THIS PROCESS ENSURES THAT ALL COMPENSATION ARRANGEMENTS WITH RELATED PARTIES ARE EVALUATED AND ENTERED INTO AT ARMS' LENGTH AND THAT ANY COMPENSATION THAT IS PAID TO A RELATED PARTY IS REASONABLE AND REFLECTS FAIR MARKET VALUE. THE CEO EVALUATES THE OTHER EMPLOYEES AND DETERMINES THEIR COMPENSATION AND ENSURE THAT IT IS REASONABLE AND REFLECTS FAIR MARKET VALUE. THE COMPENSATION OF THE OTHER EMPLOYEES ARE RATIFIED AND APPROVED BY THE EXECUTIVE COMMITTEE BASED ON THE CEO'S RECOMMENDATION. THE LAST COMPENSATION REVIEWS WERE CONDUCTED IN 2021. |
| FORM 990 PART VI, SECTION C, LINE 19 |
AVAILABILITY OF GOVERNING DOCS., FIN.STATEMENTS, AND COI POLICY: THE ORGANIZATION MAKES ITS GOVERNING DOCUMENTS AND FINANCIAL STATEMENTS AVAILABLE TO ALL DONORS AND AVAILABLE UPON REQUEST TO ALL OTHER RELATED ORGANIZATIONS. |
| FORM 990, PART VII, SECTION A |
COMPENSATION FROM RELATED ORGANIZATIONS: ICI IS REPORTING IN COLUMNS (E) AND (F) REPORTABLE COMPENSATION RECEIVED BY ITS DIRECTORS AND OFFICERS FROM THEIR OWN COLLEGES AND UNIVERSITIES, WHICH ARE RELATED ORGANIZATIONS. THE DIRECTORS AND OFFICERS DID NOT RECEIVE COMPENSATION FROM ICI FOR THEIR SERVICE AS OFFICERS OR DIRECTORS OF ICI. THE DIRECTORS AND OFFICERS WORK 40 OR MORE HOURS FOR THEIR RESPECTIVE COLLEGES AND UNIVERSITIES. |
Attach to Form 990 or 990-EZ.