2024-09-11T15:52:31-05:00 2023-12-31 111986323 MARCUM LLP 1601 MARKET ST 4TH FLOOR PHILADELPHIA PA 19103 990 2023-01-01 311627155 EASTERN STATE PENITENTIARY HISTORIC SITE INC EAST 2152365111 2027 FAIRMOUNT AVENUE PHILADELPHIA PA 19130 KERRY SAUTNER PRESIDENT AND CEO 2152365111 2024-09-05 1 0 FRANK SMITH P00639053 2152972100 2024-09-05 2023 2024-08-08 14:25:15Z KERRY SAUTNER 2027 FAIRMOUNT AVENUE PHILADELPHIA PA 19130 11383688 0 X WWW.EASTERNSTATE.ORG X 1998 PA EASTERN STATE PENITENTIARY HISTORIC SITE INTERPRETS THE LEGACY OF AMERICAN CRIMINAL JUSTICE REFORM, FROM THE NATION'S FOUNDING THROUGH TO THE PRESENT DAY, WITHIN THE LONG-ABANDONED CELLBLOCKS OF THE NATION'S MOST HISTORIC PRISON. 22 22 465 50 0 0 2684747 2534889 3020283 3225027 41963 128647 1964506 1690963 7711499 7579526 0 0 0 0 3329917 3688975 12022 72000 387644 3068202 3621525 6410141 7382500 1301358 197026 22560132 23034445 443329 705756 22116803 22328689 X EASTERN STATE PENITENTIARY HISTORIC SITE, INC. WORKS TO PRESERVE AND RESTORE THE ARCHITECTURE OF EASTERN STATE PENITENTIARY; TO MAKE THE PENITENTIARY ACCESSIBLE TO THE PUBLIC; TO EXPLAIN AND INTERPRET ITS COMPLEX HISTORY; TO PLACE CURRENT ISSUES OF CORRECTIONS AND JUSTICE IN AN HISTORICAL FRAMEWORK; AND TO PROVIDE A PUBLIC FORUM WHERE THESE ISSUES ARE DISCUSSED. THE PROGRAM IS BUILT ON THE BELIEF THAT THE PROBLEMS FACING EASTERN STATE PENITENTIARY'S ARCHITECTS HAVE NOT YET BEEN SOLVED, AND THAT THE ISSUES THESE EARLY PRISON REFORMERS ADDRESSED REMAIN OF CENTRAL IMPORTANCE TO OUR NATION. 0 0 3243722 3221000 DAYTIME TOUR PROGRAM:ESPHS OFFERS A VARIETY OF DAYTIME HISTORIC TOURS AND EXHIBITS TO THE PUBLIC INCLUDING, BUT NOT LIMITED TO: AUDIO TOURS, GUIDED TOURS, HISTORY AND HISTORICAL EXHIBITS AND ARTIST INSTALLATIONS. THE ORGANIZATION WAS DRAMATICALLY IMPACTED BY COVID-19, WHICH CAUSED THE SITE TO BE CLOSED FOR MUCH OF 2020 WITH A GRADUATED RE-OPENING IN 2021. COVID-19 CONTINUES TO IMPACT VISITATION DUE TO A LACK OF RETURN TO PRE-PANDEMIC VISITATION AT MOST OF THE CULTURAL INSTITUTIONS IN PHILADELPHIA. ATTENDANCE FOR ALL THE VARIOUS DAYTIME TOURS IN 2023 WAS 186,911 COMPARED TO 190,153 IN 2022. 1652264 HISTORIC PRESERVATION:THE STABILIZATION AND PRESERVATION OF THE HISTORIC SITE AND ALL OF ITS STRUCTURES IS OF VITAL IMPORTANCE FOR ESPHS TO CONTINUE ITS MISSION. ESPHS'S RESTORATION ACTIVITIES PROVIDE VISITORS WITH A CLEAR UNDERSTANDING OF THE PRISON'S HISTORY, ITS DESIGN AND USE, AND HOW THE SITE CHANGED AND EVOLVED OVER TIME. IN 2023, SIGNIFICANT PROGRESS WAS MADE IN RESTORING THE ROOFING OF CELLBLOCKS 13 AND 14 AND IMPROVING DRAINAGE IN THE GREENHOUSE COURTYARD. NEW ROOFS WERE INSTALLED ON THREE SMALL STRUCTURES: PAN STORAGE ROOM, THE BOILER ROOM OF CELLBLOCK 5 AND THE DYE SHOP OF CELLBLOCK 6. ESPHS ALSO COMPLETED A STUDY OF TWO FUTURE CAPITAL PROJECTS: A NEW VISITORS CENTER WITH BATHROOMS AND AN EDUCATION CENTER. THE STUDY INCLUDED CONCEPTUAL DESIGN, RENDERINGS AND PRICING TO HELP ESPHS PLAN AND FUNDRAISE FOR THESE PROJECTS MOVING FORWARD. LEASEHOLD IMPROVEMENTS TOTALED $22,920,448 AT THE END OF 2023, COMPARED TO $22,166,358 IN 2022. CONSTRUCTION IN PROGRESS AT THE END OF 2023 TOTALED $1,396,499 COMPARED TO $631,827 IN 2022. 145263 EXHIBITS: ESPHS PRESENTS A MIX OF HISTORY AND CONTEMPORARY EXHIBITS FOCUSING ON U.S. PRISON POLICY. INSTALLATIONS INCLUDE "THE VOICES OF EASTERN STATE AUDIO TOUR," FEATURING THE VOICES OF 35 PEOPLE WHO LIVED AND WORKED IN THE PRISON. SMALLER EXHIBITS INCLUDE AL CAPONE'S CELL, WHICH PORTRAYS CAPONE'S UNUSUAL TREATMENT DURING HIS INCARCERATION HERE, AND A RESTORED CELL FROM THE 1830S. AN EXHIBIT ON JEWISH LIFE ADJOINS THE PENITENTIARY SYNAGOGUE, AND 23 INMATE PAINTED MURALS ARE INTERPRETED IN THE CATHOLIC CHAPLAIN'S OFFICE. "PRISONS TODAY: QUESTIONS IN THE AGE OF MASS INCARCERATION, AND "THE BIG GRAPH" INVITE REFLECTION ON CONTEMPORARY US PRISON POLICY, AND CONNECTIONS BETWEEN THE PAST, THE PRESENT, AND VISITORS' HOPES FOR THE FUTURE. IN 2022, A NEW AMBITIOUS ARTIST INSTALLATION, "DLP MIRROR" (MARK MENJIVAR) WAS ADDED TO THE DEATH ROW CELLBLOCK. OTHER ART INSTALLATIONS INCLUDE " "DEADLY WEAPONS" (LINDA BOND) AND TRANSIENT ROOM (ANN REICHLIN), "PHOTO REQUESTS FROM SOLITARY" (SOLITARY WATCH'S JEAN CASELLA, JEANNE OLESON AND LAURIE JO REYNOLDS) "DORIS JEAN" (RACHEL LIVEDALEN); "APOKALUPTEIN:16389067 II" (JESSE KRIMES'), "CHORUS" (JESS PERLITZ); "SPECIMEN" (GREG COWPER); "BEWARE THE LILY LAW"( MICHELLE HANDELMAN); "GTMO" (WILLIAM CROMAR); "IDENTITY CONTROL" (TYLER HELD); "A CLIMBER'S GUIDE TO EASTERN STATE PENITENTIARY" (ALEXANDER ROSENBERG); AND "#BLACKGIRLHOOD" (DEHANZA ROGERS). 69622 314621 MERCHANDISE SALES AND GENEALOGY FEES 69622 314621 5110871 1 1 0 1 0 0 0 1 0 0 1 0 0 0 1 1 1 0 0 0 0 0 0 1 1 0 0 0 0 1 0 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 0 1 65 0 1 465 1 0 0 0 0 0 0 0 0 0 0 0 0 X 22 22 0 0 0 0 0 0 0 1 1 0 0 1 1 1 1 1 1 1 1 0 PA NY X KERRY SAUTNER PRESIDENT & CEO 2152365111 2027 FAIRMOUNT AVENUE PHILADELPHIA PA 19130 JOHN MCINERNEY VICE CHAIR/CHAIR 2.00 X X 0 0 0 MATTHEW D LEE SECRETARY/VICE CHAIR 3.00 X X 0 0 0 DAVID PONIATOWSKI TREASURER 3.00 X X 0 0 0 BARBARA SICALIDES SECRETARY 2.00 X X 0 0 0 WILLIAM ADAIR BOARD MEMBER 2.00 X 0 0 0 DAN BOSIN BOARD MEMBER/CHAIR 3.00 X X 0 0 0 INGRID BOGEL BOARD MEMBER 2.00 X 0 0 0 CARA SCHEIDER BONGIORNO BOARD MEMBER 2.00 X 0 0 0 JOHN CHRISTMAS ESQ BOARD MEMBER, EX-OFFICIO 0.50 X 0 0 0 DARRELL CLARKE BOARD MEMBER, EX-OFFICIO 0.25 X 0 0 0 BRIDGET COLLINS-GREENWALD BOARD MEMBER, EX-OFFICIO 0.50 X 0 0 0 HOLLY HARRITY BOARD MEMBER 3.00 X 0 0 0 DAVID HOLLENBERG BOARD MEMBER 2.00 X 0 0 0 IRA KAUDERWOOD BOARD MEMBER 2.00 X 0 0 0 NANCY KLAUS BOARD MEMBER 2.00 X 0 0 0 PAMELA LAUCKS BOARD MEMBER 2.00 X 0 0 0 RANDALL MASON BOARD MEMBER 2.00 X 0 0 0 AJIMA OLAGHERE BOARD MEMBER 2.00 X 0 0 0 KEITH REEVES BOARD MEMBER 2.00 X 0 0 0 NORBERTO ROSA BOARD MEMBER 2.00 X 0 0 0 STEVEN R SHAPIRO BOARD MEMBER 2.00 X 0 0 0 TONEH A SMYTH BOARD MEMBER 2.00 X 0 0 0 SEAN KELLEY TO 102023 SENIOR VP, DIR. OF INTERPRETATION 40.00 X 179798 0 6343 SARA JANE ELK TO 072023 PRESIDENT & CEO 40.00 X 109622 0 14480 KERRY SAUTNER START 072023 PRESIDENT & CEO 40.00 X 103085 0 2319 BRETT BERTOLINO TO 042023 VP, DIR. OF OPERATIONS 40.00 X 39871 0 10021 432376 0 33163 8 0 1 0 MUNN ROOFING CORP 3413 UNIONVILLE PIKE HATFIELD PA 19440 ROOFING CONTRACTOR 1020923 YOUR PART-TIME CONTROLLER 1500 WALNUT STREET SUITE 1200 PHILADELPHIA PA 19103 ACCOUNTING SERVICES 277240 ALBARELL ELECTRIC INC 901 WEST LEHIGH STREET BETHLEHEM PA 18108 ELECTRICAL SERVICES 197366 OPS SECURITY GROUP 424 EAST ELM STREET SUITE 200 CONSHOCKEN PA 19428 SECURITY SERVICES 157020 AUDACY OPERATIONS INC 2400 MARKET STREET PHILADELPHIA PA 19103 ADVERTISING 152472 12 5085 2359858 169946 2534889 TOURS 712120 3141448 3141448 MEMBERSHIPS 712120 61332 61332 SITE ACCESS 712120 18220 18220 MISCELLANEOUS 712120 4027 4027 3225027 128647 128647 4899825 5085 3519456 1380369 1380369 595300 284706 310594 310594 7579526 3535621 0 1509016 475241 96735 302729 75777 2563227 1938440 513762 111025 110823 81438 24594 4791 131062 88656 36755 5651 408622 259240 127358 22024 229479 7147 222332 219909 126873 82027 11009 36300 36300 72000 72000 571572 253675 295250 22647 303215 303107 108 498902 367593 116000 15309 43457 5103 38354 74559 45374 29185 43103 9797 32935 371 3170 2444 726 737306 719731 17575 58704 39356 16033 3315 EQUIPMENT RENTAL 240888 237956 2687 245 RETURNED GRANT 225000 225000 REPAIRS AND MAINTENANCE 97004 97004 CONSERVATION 82249 82249 156708 123953 25575 7180 7382500 5110871 1883985 387644 902269 334409 3670151 3236173 832128 1601637 175184 184159 28808 22634 26645257 9064311 16844467 17580946 107125 74487 22560132 23034445 345741 647166 97588 58590 443329 705756 X 21414320 21774909 702483 553780 22116803 22328689 22560132 23034445 197026 14860 0 X 0 1 X 1 0 X 696737 2319957 2467945 2684747 2534889 10704275 696737 2319957 2467945 2684747 2534889 10704275 14319 10689956 202118 21570 39624 41963 128647 433922 11138197 20878999 0.95980 0.86150 X SCHEDULE A, PART II, LINE 3: THE CITY OF PHILADELPHIA OWNS THE REAL PROPERTY AND IMPROVEMENTS TO THE REAL PROPERTY THAT ARE USED BY EASTERN STATE HISTORIC PENITENTIARY SITE, INC AT 2027 FAIRMOUNT AVE, PHILADELPHIA, PA. THE CITY CONTRIBUTES THE USE OF THE PROPERTY TO ESPHS FOR $1 YEARLY. THIS IN-KIND CONTRIBUTION HAS NOT BEEN VALUED. THEREFORE, NO AMOUNT HAS BEEN REPORTED ON LINE 3. HOWEVER, ESPHS WOULD NOT BE ABLE TO OPERATE ITS PROGRAMS WITHOUT THE USE OF THE PROPERTY. RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 0 0 0 0 0 0 0 0 1 36300 36300 0 PART II-B, LINE 1: EASTERN STATE PENITENTIARY ENGAGED THE SERVICES OF AN INDEPENDENT CONTRACTOR DURING 2023 TO HELP PROCURE FEDERAL, STATE, AND LOCAL GRANT MONIES FOR HISTORICAL PRESERVATION. THE ORGANIZATION USES A LOBBYING FIRM TO LOBBY FOR STATE FUNDING, WHICH COMES DIRECTLY FROM THE LEGISLATURE OR THE GOVERNOR'S OFFICE. THE LOBBYING FIRM DOES NOT LOBBY FOR GRANTS THAT GO THROUGH STATE AGENCIES. 24937325 X X 0 22920448 7062420 15858028 2328310 2001891 326419 1396499 1396499 17580946 LEASE LIABILITY 58590 58590 X 11398548 14860 3804162 3819022 7579526 0 7579526 11186662 3804162 3804162 7382500 0 7382500 PART III, LINE 4: ESPHS MAINTAINS THE HISTORIC EASTERN STATE PENITENTIARY IN ORDER TO MAKE IT ACCESSIBLE TO THE PUBLIC. THE PROGRAMS, EVENTS AND EXHIBITS HELD AT THE PENITENTIARY HELP TO PROVIDE THE MEANS NECESSARY TO KEEP THE BUILDING INTERPRETED AND OPEN TO THE PUBLIC, WHICH IS THE ORGANIZATION'S PRIMARY EXEMPT PURPOSE. THE ORGANIZATION ALSO ACQUIRES AND MAINTAINS HISTORIC SITE COLLECTIONS, INCLUDING DOCUMENTS, REFERENCE MATERIALS AND OBJECTS. PART X, LINE 2: MANAGEMENT OF THE ORGANIZATION CONSIDERS THE LIKELIHOOD OF CHANGES BY TAXING AUTHORITIES IN ITS FILED INCOME TAX RETURNS AND RECOGNIZES A LIABILITY OR DISCLOSES POTENTIAL SIGNIFICANT CHANGES THAT MANAGEMENT BELIEVES ARE MORE LIKELY THAN NOT TO OCCUR UPON EXAMINATION BY TAX AUTHORITIES, INCLUDING CHANGES TO THE ORGANIZATION'S STATUS AS A NOT-FOR PROFIT ENTITY. MANAGEMENT BELIEVES THAT THE ORGANIZATION MET THE REQUIREMENTS TO MAINTAIN ITS TAX-EXEMPT STATUS AND HAS NO INCOME SUBJECT TO UNRELATED BUSINESS INCOME TAX, THEREFORE NO PROVISION FOR INCOME TAXES HAS BEEN PROVIDED IN THESE FINANCIAL STATEMENTS. PART XI, LINE 2D - OTHER ADJUSTMENTS: COST OF GOODS SOLD REPORTED ON PART VIII, LINE 10B 284,706. HALLOWEEN FUNDRAISING EVENT - DIRECT EXPENSES REPORTED ON PART VIII, LINE 8B 3,519,456. PART XII, LINE 2D - OTHER ADJUSTMENTS: COST OF GOODS SOLD REPORTED ON PART VIII, LINE 10B 284,706. HALLOWEEN FUNDRAISING EVENT - DIRECT EXPENSES REPORTED ON PART VIII, LINE 8B 3,519,456. X X X X X X 1 FAIRMOUNT VENTURES INC 30 SOUTH 15TH STREET PHILADELPHIA PA 19102 GRANT WRITING SUPPORT 0 0 72000 -72000 72000 -72000 PA HALLOWEEN FUNDRAISING EVENT 4904910 5085 4899825 255474 509293 2754689 4904910 5085 4899825 255474 509293 2754689 3519456 1380369 X X X X X 1 0 0 0 0 0 0 0 0 SEAN KELLEY TO 102023 SENIOR VP, DIR. OF INTERPRETATION 135890 0 43908 0 0 0 0 0 6343 0 186141 0 0 0 PART I, LINE 4A PER SEPARATION AGREEMENT, SEAN KELLEY (SENIOR VP, DIRECTOR OF INTERPRETATION) IS TO BE PAID A TOTAL OF $161,700, PAYABLE IN EQUAL INSTALLMENTS OVER 12 MONTHS. THE PAYMENTS START IN OCTOBER 2023 AND AMOUNT PAID IN 2023 IS $34,206. X ARCHIVAL RECORDS 91 0 0 1 0 PART I, LINE 33: ARCHIVAL RECORD: ZERO AMOUNT WAS REPORTED FOR LINE 25 (C), BECAUSE THE ITEMS DONATED WERE ADDED TO THE MUSEUM'S COLLECTIONS AND THE MUSEUM DOES NOT CAPITALIZE ITS COLLECTIONS, AS ALLOWED UNDER SFAS 116 (ASC 958-360-25). FORM 990, PART VI, SECTION A, LINE 1A UNDER THE ORGANIZATION'S BYLAWS, CERTAIN DIRECTORS AND OFFICERS SERVE AS MEMBERS OF THE EXECUTIVE COMMITTEE OF THE ORGANIZATION. THE EXECUTIVE COMMITTEE IS AUTHORIZED TO ACT FOR THE BOARD OF DIRECTORS BETWEEN ITS REGULAR MEETINGS. FORM 990, PART VI, SECTION B, LINE 11B MANAGEMENT AND OUTSIDE COUNSEL FOR ESPHS REVIEW THE DRAFT FORM 990. ESPHS' INDEPENDENT AUDITOR FORMALLY PRESENTS THE AUDITED ANNUAL FINANCIAL STATEMENTS AND THE DRAFT IRS FORM 990 TO THE ESPHS BOARD OF DIRECTORS (THE "BOARD") FINANCE COMMITTEE. THE FINANCE COMMITTEE REVIEWS THE AUDITED FINANCIALS AND THE DRAFT OF THE IRS FORM 990 IN-DEPTH. THE COMMITTEE APPROVES THE IRS FORM 990 FOR THE BOARD. THE COMMITTEE THEN PREPARES AN AUDIT PRESENTATION TO THE BOARD AT A FORMAL BOARD MEETING AND REQUESTS THE BOARD'S APPROVAL OF THE AUDITED ANNUAL FINANCIAL STATEMENTS. FORM 990, PART VI, SECTION B, LINE 12C ESPHS REGULARLY AND CONSISTENTLY MONITORS AND ENFORCES COMPLIANCE WITH ITS CONFLICTS OF INTEREST POLICY (THE "POLICY"). ALL OFFICERS, MEMBERS OF THE BOARD, KEY-EMPLOYEES AND MEMBERS OF COMMITTEES WITH BOARD-DELEGATED POWERS ARE REQUIRED TO COMPLY WITH THE POLICY. EACH SUCH INDIVIDUAL IS PROVIDED WITH A COPY OF THE POLICY AND IS THEN REQUIRED TO REVIEW IT AND SIGN AN ACKNOWLEDGMENT OF HIS OR HER UNDERSTANDING AND COMMITMENT TO COMPLY WITH THE POLICY; NON-COMPLIANCE WITH THE POLICY IS SUBJECT TO DISCIPLINARY ACTION INCLUDING, BUT NOT LIMITED TO, DISMISSAL FROM ESPHS. PRIOR TO ENTERING INTO ANY TRANSACTION OR ARRANGEMENT THAT MIGHT BENEFIT OR INURE TO THE BENEFIT OF AN "INTERESTED PERSON" (AS THAT TERM IS DEFINED IN THE POLICY), SUCH TRANSACTION OR ARRANGEMENT IS DISCUSSED IN GREAT DETAIL BY THE BOARD (EXCLUDING ANY BOARD MEMBER(S) THAT MAY BE AN INTERESTED PERSON). EACH AND EVERY MEMBER IS REQUIRED TO FULLY DISCLOSE ANY AND ALL BENEFIT HE OR SHE MAY DIRECTLY OR INDIRECTLY DERIVE FROM, OR BECAUSE OF, ANY TRANSACTION OR ARRANGEMENT. TO THE EXTENT A TRANSACTION OR ARRANGEMENT HAS ALREADY BEEN ENTERED INTO, IN THE EVENT SUCH TRANSACTION OR ARRANGEMENT IS QUESTIONABLE PURSUANT TO THE POLICY, OR SOMEONE HAS A QUESTION ABOUT, OR ISSUE WITH, HOW SUCH ARRANGEMENT OR TRANSACTION IS BENEFITING AN INTERESTED PERSON, IT IS REPORTED, OR BROUGHT, TO THE ATTENTION OF THE CHAIRPERSON OF THE EXECUTIVE COMMITTEE (THE "CHAIR") WHO CONDUCTS AN INVESTIGATION TO DETERMINE IF A VIOLATION OF THE POLICY HAS OCCURRED. IF THE CHAIR DETERMINES A VIOLATION HAS OCCURRED, THE MATTER IS REFERRED TO THE BOARD FOR APPROPRIATE DISCIPLINARY AND CORRECTIVE ACTION. IF THE CHAIR IS UNABLE TO MAKE SUCH A DETERMINATION, THE CHAIR PRESENTS HIS OR HER INVESTIGATION TO THE ENTIRE BOARD TO MAKE THE DETERMINATION. ALL EXISTING TRANSACTIONS AND ARRANGEMENTS THAT ARE IN EFFECT FOR LONGER THAN A YEAR ARE REVIEWED EACH YEAR BY THE BOARD TO DETERMINE WHETHER A CONFLICT OF INTEREST, IN ACCORDANCE WITH THE POLICY, EXISTS. THE EXECUTIVE, GOVERNANCE AND NOMINATIONS COMMITTEES CONSTANTLY REVIEW TRANSACTIONS, NOMINATIONS AND OTHER ARRANGEMENTS IN ACCORDANCE WITH THE POLICY. IN THE EVENT ANY OF THE AFOREMENTIONED COMMITTEES FINDS AN ISSUE WITH AN EXISTING TRANSACTION OR ARRANGEMENT OR ARE UNABLE TO MAKE A DETERMINATION, THE ISSUE IS PRESENTED TO THE ENTIRE BOARD TO DETERMINE WHETHER THE TRANSACTION OR ARRANGEMENT VIOLATES THE POLICY. FORM 990, PART VI, SECTION B, LINE 15 COMPENSATION FOR OFFICERS AND ALL KEY-EMPLOYEES IS DETERMINED ANNUALLY BY THE BOARD'S COMPENSATION COMMITTEE, AND REPORTED TO THE FINANCE COMMITTEE WHEN IT SETS THE ANNUAL BUDGET. THE COMPENSATION COMMITTEE AND EXECUTIVE COMMITTEE MEMBERS INVOLVED IN PAY DECISIONS ARE FREE FROM CONFLICTS OF INTEREST WITH RESPECT TO THEIR EFFORTS IN DETERMINING COMPENSATION LEVELS. THE CEO'S COMPENSATION IS RECOMMENDED BY THE COMPENSATION COMMITTEE FOR APPROVAL BY THE BOARD'S EXECUTIVE COMMITTEE. THE BOARD'S COMPENSATION COMMITTEE INCORPORATES RELEVANT MARKETPLACE DATA FOR EACH JOB (EXAMINING MUSEUMS AND OTHER ARTS AND CULTURE NON-PROFITS OF ROUGHLY THE SAME SIZE AS WELL AS SOME GENERAL INDUSTRY DATA FOR ADMINISTRATIVE ROLES), INCORPORATING REPUTABLE STUDIES PERFORMED BY ORGANIZATIONS SUCH AS THE AMERICAN ASSOCIATION OF MUSEUMS INTO ITS ANALYSIS, ITS DECISION MAKING PROCESS AND THE SALARY BUDGET WORKSHEET. EXTERNAL DATA IS CAREFULLY "AGED" TO A COMMON DATE IN TIME AND REGIONALLY ADJUSTED WHERE APPROPRIATE DECISION MAKERS ON THE BOARD, BASE COMPENSATION RECOMMENDATIONS AND DECISIONS ON THEIR OWN RESEARCH OR ON INPUT FROM INDEPENDENT EXTERNAL CONSULTANTS USING OUTSIDE INFORMATION FOR SIMILARLY QUALIFIED PERSONS IN FUNCTIONALLY COMPARABLE POSITIONS AT SIMILARLY SITUATED ORGANIZATIONS. INDEPENDENT COMPENSATION CONSULTANTS HAVE NO PAST, PRESENT OR POTENTIAL FUTURE CONFLICTS OF INTEREST THAT WOULD COMPROMISE SUCH FIRMS' INDEPENDENCE IN CONDUCTING ANALYSES. FEES RECEIVED BY ANY INDEPENDENT COMPENSATION CONSULTANT ARE NOT CONTINGENT UPON THE ADOPTION OF ANY PARTICULAR ACTION OR EVENT RESULTING FROM EITHER THEIR WORK PROCESS OR THE USE OF THEIR RECOMMENDATIONS AND ANALYSES. THE FINANCE COMMITTEE PRESENTS THE DRAFT BUDGET AND SALARY/COMPENSATION RECOMMENDATIONS TO THE FULL BOARD WITH ALL OF THE RELEVANT SALARY AND COMPENSATION STUDIES FOR BOARD APPROVAL. THE DECISION MAKERS ON THE COMPENSATION COMMITTEE AND THE EXECUTIVE COMMITTEE RECEIVE DETAILED ANALYSES, AND HAVE AMPLE OPPORTUNITY TO ASK QUESTIONS OF THE ANALYST WHO PREPARED THEM. MEMBERS OF MANAGEMENT NEITHER EXERT UNDUE INFLUENCE NOR DRIVE THE CONCLUSIONS OF THE COMPENSATION ANALYSES, AND THEY ARE RECUSED DURING DELIBERATIONS ABOUT THEIR PAY. THE COMMITTEE AND THE BOARD FINALIZE AND CONTEMPORANEOUSLY DOCUMENT ALL RECOMMENDED COMPENSATION ACTIONS WITHIN 60 DAYS OF THE MEETING, PRIOR TO ANY SUCH PERSON'S RECEIPT OF MONEY OR OTHER ECONOMIC BENEFITS. ESPHS HAS ESTABLISHED A REBUTTABLE PRESUMPTION OF REASONABLENESS UNDER TREASURY REGULATIONS SECTION 53.4958-6(A). FORM 990, PART VI, SECTION C, LINE 19 ESPHS PROVIDES ITS GOVERNING DOCUMENTS, THE POLICY, AND ITS FINANCIAL STATEMENTS TO THE PUBLIC UPON REQUEST AND ALL BOARD MEMBERS RECEIVE A COPY OF SUCH DOCUMENTS EVERY YEAR.