2024-11-13T06:32:51-06:00 2023-12-31 521073331 DEMBO JONES PC 8830 STANFORD BLVD SUITE 290 COLUMBIA MD 21045 990 2023-01-01 651162716 TRACE INTERNATIONAL INC TRAC 4109900076 151 WEST STREET 300 ANNAPOLIS MD 21401 ALEXANDRA WRAGE PRESIDENT 4109900076 2024-11-12 1 0 MICHAEL E SMALL CPA P00528850 4102900770 2024-11-12 2023 2024-10-15 13:58:12Z 151 WEST STREET 300 ANNAPOLIS MD 21401 9027669 0 X WWW.TRACEINTERNATIONAL.ORG X 2002 DC SEE SCHEDULE 0 5 4 41 0 0 0 0 0 5548093 5280584 -29948 280810 194532 32975 5712677 5594369 559085 348894 0 0 3473519 4186999 0 0 0 1546223 1527534 5578827 6063427 133850 -469058 10765048 10747205 5878315 5863141 4886733 4884064 X SEE SCHEDULE 0 0 0 PROGRAM-1: ONLINE COMPLIANCE TRAINING: IN 2023, TRACE WON THREE (3) BRANDON HALL GROUP AWARDS FOR OUR ELEARNING INCLUDING ONE GOLD TECHNOLOGY EXCELLENCE LEARNING AND DEVELOPMENT TECHNOLOGY AWARD IN THE BEST ADVANCE IN LEARNING MANAGEMENT TECHNOLOGY FOR COMPLIANCE TRAINING CATEGORY, ONE GOLD HUMAN CAPITAL MANAGEMENT (HCM) EXCELLENCE LEARNING AND DEVELOPMENT AWARD IN THE BEST ADVANCE IN COMPLIANCE TRAINING CATEGORY, AND ONE SILVER HUMAN CAPITAL MANAGEMENT (HCM) EXCELLENCE LEARNING AND DEVELOPMENT AWARD IN THE BEST LEARNING TEAM CATEGORY. TRACE ALSO RELEASED AN UPDATED CURRICULUM IN 2023 FOR ITS TRACEPRO ADVANCED COMPLIANCE TRAINING AND PROFESSIONAL DEVELOPMENT PROGRAM WHICH MORE THAN DOUBLED THE NUMBER OF MEMBER COMPANY ENROLLMENTS, FROM 21 IN 2022 TO 46 IN 2023. ADDITIONALLY, TRACE RELEASED UPDATED/NEW ELEARNING CONTENT IN THE FOLLOWING TOPIC AREAS IN 2023 FORCED LABOR & HUMAN TRAFFICKING, ANTI-CORRUPTION, SANCTIONS, CONFLICTS OF INTEREST, HOW TO SAY NO TO BRIBES, ANTITRUST, SHIPPING AND LOGISTICS, RESPECT IN THE WORKPLACE, ANTI-MONEY LAUNDERING, TRADE & EXPORT CONTROLS.TRACE HOSTED 22 VIRTUAL WEBINARS ON VARIOUS COMPLIANCE-RELATED TOPICS (E.G. ADDRESSING CORRUPTION RISK IN VARIOUS INDUSTRIES AND COUNTRIES, FCPA YEAR-IN-REVIEW, ETC.). EACH WEBINAR HAD AN AVERAGE ATTENDANCE OF 33 PARTICIPANTS PROGRAM -2: LIVE MEMBER SUPPORT:IN AN EFFORT TO IMPROVE OUR LIVE MEMBER SUPPORT SERVICES AND OVERALL MEMBER RETENTION, TRACE HIRED ADDITIONAL MULTILINGUAL MEMBER SERVICES ASSOCIATES AND APPOINTED A NEW DEDICATED SENIOR DIRECTOR OF MEMBER SERVICES. THE INVESTMENT IN THIS TEAM ENABLED TRACE TO PROVIDE GREATER CUSTOMER SERVICE WITH MORE FREQUENT MEMBER OUTREACH AND CONTACT, DEPLOY ADDITIONAL MEMBER SURVEYS, AND SUPPORT MORE STRATEGY CALLS. ADDITIONALLY, THE ENHANCED TEAM HAS BEEN ABLE TO WORK WITH GREATER AUTONOMY AND CONTRIBUTE TO ORGANIZATION-WIDE EFFORTS TO IMPROVE OUR OPERATIONAL PROCESSES AND EFFICIENCY. PROGRAM-3: GLOBAL EVENTS:FORUM EVENTS: TRACE HELD TWO ANNUAL FORUM EVENTS IN 2023 FOR CORPORATE MEMBERS: A TWO (2) DAY IN-PERSON FORUM WAS HELD IN MARCH (66 ONSITE ATTENDEES AND SPEAKERS), AND A TWO (2) DAY IN-PERSON FORUM WAS HELD IN OCTOBER IN LONDON, UK (70 ONSITE ATTENDEES AND SPEAKERS). THERE WAS NO CHARGE FOR PARTICIPATION. WE ALLOWED ONE REPRESENTATIVE PER MEMBER COMPANY AND ONE REPRESENTATIVE TO THE WAIT LIST. SPEAKERS AND ATTENDEES AT EACH EVENT INCLUDED ENFORCEMENT OFFICIALS, SENIOR LEVEL COMPLIANCE EXECUTIVES, AND OUTSIDE COUNSEL. PANEL DISCUSSIONS PROVIDED ATTENDEES WITH PRACTICAL COMPLIANCE GUIDANCE AND FACILITATED BENCHMARKING. ROUNDTABLE EVENT: TRACE HOSTED AN EXECUTIVE ROUNDTABLE IN SINGAPORE IN MAY (13 ATTENDEES AND SPEAKERS). FURTHER ROUNDTABLES WERE NOT PLANNED. THIS ROUNDTABLE FACILITATED BENCHMARKING AMONG SENIOR LEVEL COMPLIANCE EXECUTIVES FROM TRACE CORPORATE MEMBER COMPANIES. THERE WAS NO CHARGE FOR TRACE MEMBERS TO ATTEND. 0 0 0 1 0 0 0 0 0 1 0 0 1 1 1 0 0 0 1 1 1 0 0 0 0 0 1 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 17 0 41 1 0 0 0 0 0 0 1 0 X 5 4 0 0 0 0 0 0 0 1 1 0 0 1 1 1 0 1 1 1 0 0 X X ALEXANDRA WRAGE 4109900076 151 WEST STREET SUITE 300 ANNAPOLIS MD 21401 ALEXANDRA WRAGE PRESIDENT 40.00 X X 1076520 0 272619 BAPSY DASTUR BOARD MEMBER 1.00 X 0 0 0 LEE NELSON BOARD MEMBER 1.00 X 0 0 0 ANDREA LO GAGLIO BOARD MEMBER 1.00 X 0 0 0 HENTIE DIRKER BOARD MEMBER 1.00 X 0 0 0 ROBERT CLARK MANAGER, LEGAL RESEARCH 40.00 X 148768 0 20203 VIRNA DIPALMA SENIOR DIRECTOR GLOBAL STRATEGY & 40.00 X 268895 0 22032 BEVERLY GRYDER MANAGER, IT 40.00 X 150997 0 27270 PIA MIKKOLA-VINING SENIOR DIRECTOR, MEMBER SERVICES 40.00 X 120548 0 49630 SUNSIERAY MCCALL SENIOR DIRECTOR II, COMPLIANCE TRAINING 40.00 X 185920 0 44749 LISA ROTHERT SENIOR DIRECTOR, OPERATIONS 40.00 X 169518 0 45030 2121166 0 481533 7 1 1 0 0 MEMBERSHIP DUES 541900 5041275 5041275 TRAINING PROGRAM 541900 232215 232215 OTHER PROGRAM REVENUE 541900 7094 7094 5280584 287077 287077 3425438 1595 3430350 2950 -4912 -1355 -6267 -6267 SUBLEASE INCOME 531120 32975 32975 32975 5594369 5307292 0 287077 348894 1349138 2240617 184752 184021 228471 8576 20579 17797 246389 31574 20146 325576 158964 125493 59522 36330 CONSULTING SERVICES 294969 TRAVEL 87955 UTILITIES 26980 REPAIRS AND MAINTENANCE 15271 51413 6063427 55159 478753 923487 759917 1381565 974397 57412 130650 107297 74494 41469 32803 6020408 5890606 36669 40873 2248879 2439206 10765048 10747205 552958 253059 3323022 3343307 2002335 2266775 5878315 5863141 X 4886733 4884064 4886733 4884064 10765048 10747205 -469058 466389 0 X 1 X 0 1 0 0 0 0 5041275 17772 13916 3856 74632 45685 28947 14893 14893 0 32803 SECURITY DEPOSITS 9666 ASSETS HELD IN TRUST 1604895 RIGHT OF USE ASSET - OPERATING 824645 2439206 DEFERRED COMPENSATION PAYABLE 1604895 ST LEASE LIABILITY - OPERATING 108365 LT LEASE LIABILITY - OPERATING 549719 RELATED PARTY PAYABLE 3796 2266775 X PART X, LINE 2: TRACE INTERNATIONAL, INC. QUALIFIES AS A TAX-EXEMPT NON-PROFIT MEMBERSHIP ORGANIZATION UNDER SECTION 501(C)(6) OF THE INTERNAL REVENUE CODE, EXCEPT ON NET INCOME DERIVED FROM UNRELATED BUSINESS ACTIVITIES. THERE WAS NO NET UNRELATED BUSINESS TAXABLE INCOME; THEREFORE, NO PROVISION FOR INCOME TAX IS REFLECTED IN THE FINANCIAL STATEMENTS. ACCOUNTING PRINCIPLES GENERALLY ACCEPTED IN THE UNITED STATES OF AMERICA REQUIRE THE ORGANIZATION TO EVALUATE TAX POSITIONS TAKEN AND RECOGNIZE A TAX LIABILITY IF IT IS MORE LIKELY THAN NOT THAT UNCERTAIN TAX POSITIONS TAKEN WOULD NOT BE SUSTAINED UPON EXAMINATION BY TAXING AUTHORITIES. THE ORGANIZATION HAS ANALYZED TAX POSITIONS TAKEN AND HAS CONCLUDED THAT, AS OF AND FOR THE YEAR ENDED DECEMBER 31, 2023, THERE ARE NO UNCERTAIN TAX POSITIONS TAKEN OR EXPECTED TO BE TAKEN THAT WOULD REQUIRE RECOGNITION OF A LIABILITY OR DISCLOSURE IN THE FINANCIAL STATEMENTS. THE ORGANIZATION HAD NO INTEREST OR PENALTIES RELATED TO INCOME TAXES FOR THE YEAR ENDED SUBJECT TO EXAMINATION BY THE INTERNAL REVENUE SERVICE FOR THE LAST THREE YEARS OF FILING. 0 EAST ASIA AND THE PACIFIC 0 4 MAINTAINING CONSULTANTS CONFERENCES/WORKSHOPS 90673 EUROPE (ICELAND & GREENLAND) 0 1 PROGRAM SERVICES CONFERENCES/WORKSHOPS 128711 CENTRAL AMERICA AND THE CARIBBEAN 0 1 MAINTAINING CONSULTANTS PROGRAM SUPPORT CONSULTANTS 58804 NORTH AMERICA GRANT PROGRAM SUPPORT 3685 0 6 0 0 0 6 281873 0 281873 EAST ASIA AND THE PACIFIC CHARITABLE DONATION 10000 CREDIT CARD PAYMENT 0 0 0 0 0 0 0 1 TRACE FOUNDATION 151 WEST STREET ANNAPOLIS MD 21401 475363033 501(C)(3) 300000 0 GENERAL SUPPORT INTERNATIONAL CENTER FOR JOURNALISTS 750 17TH STREET NW SUITE 300 WASHINGTON DC 20036 112724905 501(C)(3) 15000 0 SPONSORSHIP - TRIBUTE TO JOURNALISTS X X 1 1 0 ALEXANDRA WRAGE PRESIDENT 637808 0 438712 0 0 0 239800 0 32819 0 1349139 0 0 0 ROBERT CLARK MANAGER, LEGAL RESEARCH 128129 0 0 0 20639 0 7935 0 12268 0 168971 0 0 0 VIRNA DIPALMA SENIOR DIRECTOR GLOBAL STRATEGY & 107409 0 146983 0 14503 0 12432 0 9600 0 290927 0 0 0 BEVERLY GRYDER MANAGER, IT 136434 0 14563 0 0 0 8757 0 18513 0 178267 0 0 0 PIA MIKKOLA-VINING SENIOR DIRECTOR, MEMBER SERVICES 108522 0 12026 0 0 0 31517 0 18113 0 170178 0 0 0 SUNSIERAY MCCALL SENIOR DIRECTOR II, COMPLIANCE TRAIN 168173 0 17747 0 0 0 35328 0 9421 0 230669 0 0 0 LISA ROTHERT SENIOR DIRECTOR, OPERATIONS 154135 0 15383 0 0 0 34248 0 10782 0 214548 0 0 0 PART I, LINES 4A-B 4A SEVERENCE PAY - ROBERT CLARK'S COMPENSATION LINE ON SCHEDULE J, PART II INCLUDES $20,639 SEVERANCE PAY. - VIRNA DIPALMA'S COMPENSATION LINE ON SCHEDULE J, PART II INCLUDES $14,503 SEVERANCE PAY. 4B RETIREMENT AND OTHER DEFERRED COMPENSATION - ALEXANDRA WRAGE'S RETIREMENT AND OTHER DEFERRED COMPENSATION LINE ON SCHEDULE J, PART II INCLUDES $220,000 CONTRIBUTION MADE BY THE ORGANIZATION TO A NON-QUALIFIED DEFERRED COMPENSATION PLAN. - PIA MIKKOLA-VINING'S RETIREMENT AND OTHER DEFERRED COMPENSATION LINE ON SCHEDULE J, PART II INCLUDES $25,000 CONTRIBUTION MADE BY THE ORGANIZATION TO A NON-QUALIFIED DEFERRED COMPENSATION PLAN. - SUNSIERAY MCCALL'S RETIREMENT AND OTHER DEFERRED COMPENSATION LINE ON SCHEDULE J, PART II INCLUDES $30,000 CONTRIBUTION MADE BY THE ORGANIZATION TO A NON-QUALIFIED DEFERRED COMPENSATION PLAN. - LISA ROTHERT'S RETIREMENT AND OTHER DEFERRED COMPENSATION LINE ON SCHEDULE J, PART II INCLUDES $25,000 CONTRIBUTION MADE BY THE ORGANIZATION TO A NON-QUALIFIED DEFERRED COMPENSATION PLAN. PART II - BONUS AND INCENTIVE COMPENSATION -ALEXANDRA WRAGE'S BONUS AND INCENTIVE COMPENSATION LINE ON SCHEDULE J, PART II INCLUDES $213,712 DISTRIBUTION RECIEVED FROM THE NON-QUALIFIED DEFERRED COMPENSATION PLAN. -VIRNA DIPALMA'S BONUS AND INCENTIVE COMPENSATION LINE ON SCHEDULE J, PART II INCLUDES $146,983 DISTRIBUTION RECIEVED FROM THE NON-QUALIFIED DEFERRED COMPENSATION PLAN. FORM 990, PART I, LINE 1 TRACE IS A NON-PROFIT BUSINESS ASSOCIATION, HEADQUARTERED IN THE UNITED STATES AND REGISTERED IN CANADA, DEDICATED TO ANTI-BRIBERY, COMPLIANCE, AND GOOD GOVERNANCE. MEMBERS OF THE TRACE COMPLIANCE COMMUNITY INCLUDE HUNDREDS OF MULTINATIONAL CORPORATE AND SME COMPANIES LOCATED WORLDWIDE AND REPRESENTING ALMOST EVERY INDUSTRY. TRACE'S SHARED SERVICES MEMBERSHIP MODEL PROVIDES OUR MEMBER COMPANIES WITH PRACTICAL AND AFFORDABLE COMPLIANCE SOLUTIONS AND THE OPPORTUNITY TO SHARE COMPLIANCE BEST PRACTICES. TRACE OFFERS SEVERAL MEMBERSHIP PLAN OPTIONS OFFERING ACCESS TO RESOURCES RELATED TO THE FOLLOWING PROGRAM AREAS: *ONLINE COMPLIANCE TRAINING* TRACE OFFERS MULTILINGUAL COMPUTER-BASED COMPLIANCE COURSES ON TOPICS SUCH AS ANTI-BRIBERY, CONFLICTS OF INTEREST, SEXUAL HARASSMENT, CONFLICT MINERALS, ETC. COURSES ARE AVAILABLE IN UP TO 29 LANGUAGES AND MANY ARE CUSTOMIZABLE. DEPENDING ON THE MEMBER'S ELECTED MEMBERSHIP PLAN, THEY CAN ASSIGN TRAINING COURSES BOTH TO THEIR EMPLOYEES AND THIRD PARTIES (E.G. SUPPLIERS, VENDORS, INTERMEDIARIES, CONSULTANTS, AGENTS, AFFILIATES, BUSINESS PARTNERS, ETC.). COURSES CAN BE DEPLOYED VIA TRACE'S CUSTOMIZABLE LEARNING MANAGEMENT SYSTEM (LMS) AND / OR APPROVED COMPANY AND SUBSIDIARY INTERNAL LMS PLATFORM(S). OPTIONAL TRAINING PACKAGES ARE AVAILABLE TO ALL CORPORATE MEMBERS SEEKING ENHANCED TRAINING OR LMS CONTENT CUSTOMIZATIONS OR SUPPORT. ADDITIONALLY, MEMBERS ARE INVITED TO ATTEND TRACE WEBINARS ON VARIOUS COMPLIANCE-RELATED TOPICS, TO HELP THEM STAY CURRENT ON COMPLIANCE TOPICS AND DEVELOPMENTS. TRACE ALSO OFFERS A FOUNDATIONAL ANTI-BRIBERY TRAINING PROGRAM CALLED "TRACEPRO", AND A CUSTOMIZABLE CONFLICTS OF INTEREST QUESTIONNAIRE THAT COMPANIES CAN DEPLOY VIA THE LMS. *ONLINE MEMBER RESOURCES TRACE OFFERS ONLINE MEMBER ACCESS TO THE FOLLOWING RESOURCES: -COUNTRY-SPECIFIC SUMMARIES OF LOCAL LAWS, LOCAL GIFTS AND HOSPITALITY GUIDELINES, AS WELL AS OF E-GOVERNMENT RESOURCES THAT ARE AVAILABLE -TRAINING AIDS AND MEMES -MODEL POLICIES, CONTRACTS, AND COMPLIANCE CHECKLISTS -BENCHMARKING DATA -TRACE PARTNER FIRMS DIRECTORY ACCESS TO A LIST OF HUNDREDS OF REPUTABLE LAW FIRMS AND LAWYERS WITH ANTI-BRIBERY PRACTICES THROUGHOUT THE WORLD -SUMMARIES OF TRANSNATIONAL BRIBERY CASES & GLOBAL ENFORCEMENT ACTIONS, AS WELL AS RISK OF BRIBERY BY COUNTRY -ACCESS TO A CUSTOMIZABLE ONLINE SYSTEM FOR TRACKING AND APPROVING BOTH INCOMING AND OUTGOING GIFTS, MEALS, TRAVEL AND ENTERTAINMENT EXPENSES. *LIVE MEMBER SUPPORT TRACE'S MULTILINGUAL MEMBER SERVICES TEAM PROVIDES OUR MEMBERS WITH LIVE SUPPORT AND ENDEAVORS TO KEEP THEM INFORMED OF COMPLIANCE-RELATED DEVELOPMENTS AND SERVICES THAT MAY BE OF INTEREST. WHILE WE DO NOT PROVIDE LEGAL ADVICE, OUR LEADERSHIP TEAM IS AVAILABLE FOR STRATEGY CALLS AND TO ASSIST MEMBERS IN IDENTIFYING HELPFUL COMPLIANCE RESOURCES. *GLOBAL EVENTS TRACE CORPORATE MEMBERS ARE INVITED TO ATTEND TRACE'S VARIOUS IN-PERSON EVENTS. WE TYPICALLY HOST AN ANNUAL FORUM EVENT DESIGNED FOR MEMBER LEGAL AND COMPLIANCE OFFICERS, AND VARIOUS INTERNATIONAL WORKSHOPS, SOME OF WHICH ARE RESTRICTED TO MEMBER EMPLOYEES, AND OTHERS OF WHICH ARE OPEN TO MEMBER SUBSIDIARIES AND THIRD PARTIES. *SPECIAL PROJECTS THE TRACE COMPLIANCE COMMUNITY AIMS TO SPREAD GLOBAL ANTI-BRIBERY AND ANTI-CORRUPTION AWARENESS THROUGH VARIOUS INITIATIVES AND SPECIAL PROJECTS (E.G. PUBLICATIONS, FILMS, A BLOG, PODCAST AND INTERVIEWS) AND BY SUPPORTING OTHER ORGANIZATIONS. FORM 990, PART VI, SECTION B, LINE 11B THE FORM 990 IS REVIEWED BY TRACE'S INTERNAL ACCOUNTING MANAGER, SENIOR DIRECTOR OF OPERATIONS, AND THE PRESIDENT. THE FORM 990 IS THEN PRESENTED TO THE BOARD OF DIRECTORS FOR REVIEW PRIOR TO FILING. FORM 990, PART VI, SECTION B, LINE 15A THE PRESIDENT'S COMPENSATION IS DETERMINED BY THE COMPENSATION COMMITTEE WITH THE BOARD OF DIRECTORS, BASED ON PERFORMANCE. THE COMPENSATION COMMITTEE REQUESTED AN EXTERNAL REVIEW BY AN INDEPENDENT CONSULTING FIRM IN 2014 AND VIEWED THE PRESIDENT'S COMPENSATION AS CONSISTENT WITH THE CONSULTING FIRM'S REPORT RECOMMENDATIONS. FORM 990, PART VI, SECTION C, LINE 19 THIS INFORMATION IS AVAILABLE TO THE PUBLIC UPON REQUEST AT THE OFFICE OF TRACE INTERNATIONAL, INC. THE 990 IS ALSO AVAILABLE AT GUIDESTAR.ORG.