The Blinded Veterans Association’s (BVA) best interest should be considered and apparent for all transactions incurred on its behalf. A problem arises when there is a conflict of interest. It is very important that BVA understands and becomes aware of any perceived, potential, or actual conflicts of interest between BVA’s interests and those of its board members, committee members, employees, and independent contractors. Conflicts of interest must be disclosed properly and promptly.

This conflict-of-interest policy is designed to help BVA’s board members, committee members, employees, and independent contractors identify situations that present potential conflicts of interest and to provide a procedure on how to recognize the majority of perceived, potential, or actual conflicts of interest. This procedure will allow such conflicts of interest to be dealt with fairly and expeditiously through appropriate disclosure and management. This procedure may allow a transaction to be treated as valid and binding even though a conflict of interest exists. Early disclosure of a perceived, potential, or actual conflict of interest is very important in resolving the matter before it becomes a public issue.

While it is impossible to anticipate or describe every circumstance that might create a conflict of interest that requires disclosure, below are some examples of actual or apparent conflicts of interest. If a board member, committee member, employee, or independent contractor:

• - Owns, manages, participates in (such as being a board member or employee) or receives compensation from an actual or potential vendor or supplier of BVA.
• - Directly conducts business with a family member.
• - Gives to or receives from a vendor, board member, employee, or governmental official anything of value in exchange for something, including a decision or recommendation. This does not preclude the acceptance of items or entertainment of nominal or insignificant value which are not related to any particular transaction or activity of BVA.

Board Members and Committee Members

Any board or committee member who may be involved in a BVA business transaction in which there is a perceived, potential, or actual conflict of interest shall promptly notify the National President. The member shall refrain from voting on any such transaction, participating in deliberations concerning it, or using personal influence in any way in the matter. This individual’s presence may not be counted in determining the quorum for any vote regarding this particular transaction. If the individual is not present, the National President or the Committee Chair (if desired by the National President) shall disclose a potential conflict of interest to the other members prior to any vote regarding this particular transaction to be recorded in the meeting’s minutes.

Employees and Independent Contractors

Any employee or independent contractor who may be involved in a BVA business transaction in which there is a perceived, potential, or actual conflict of interest shall promptly report it to the Executive Director. If the conflict involves the Executive Director, it shall be reported to the National President.

After receiving information about a perceived, potential, or actual conflict of interest, the Executive Director or National President shall take such action as is necessary to assure that the transaction is completed in the best interest of BVA without involving the individual with the potential conflict of interest.

Annual Review for Disclosure

BVA will conduct an annual review requesting its board members, committee members, employees, and applicable independent contractors (most importantly, those who come onsite and are identified on the Form 990) to disclose any perceived, potential, or actual conflicts of interest. After completing the Conflict-of-Interest Questionnaire, the signed document is to be returned to the Executive Director within two weeks of receipt to be reviewed and filed as confidential.

Board and committee members should direct any perceived, potential, or actual conflicts of interest or questions to the National President or his/her designee, and employees and independent contractors to the Executive Director. A written record of any report of such conflicts of interest and actions taken shall be maintained by the Executive Director or National President, if designated, to be filed as confidential.

“Conflict of Interest” as defined above.

“Compensation” includes direct or indirect remuneration as well as gifts or favors that are substantial.

"Family members” include spouses, children, siblings, parents, aunts and uncles, and spouses and children of the above.

“Transaction” includes any agreement or relationship involving the sale or purchase of goods, services, or rights of any kind, and the providing or receipt of a grant. The making of a gift to BVA is not included in this definition of a transaction.

“Involved in a BVA business transaction” includes initiating, making the principal recommendation for, or approving a purchase or contract; recommending or selecting a vendor or contractor; drafting or negotiating the terms of the transaction; or authorizing or making payments from BVA accounts.

This policy may pertain to other parties (such as independent contractors) as deemed necessary by the Executive Director or National President.

The Executive Director and the Board of Directors reserve the right to amend this policy. Any changes will be communicated to the committee members and employees.

The confidential and/or proprietary nature of information received by a BVA board member, committee member, or employee must be considered, and the procedures set forth must be adhered to before communicating it to others.

To provide board members, committee members, employees, and independent contractors with examples of what BVA considers confidential and/or proprietary information and a procedure regarding its disclosure.

During business operations, confidential and/or proprietary information may become available to the board members, committee members, and employees. Some examples of such information are:

• - Financial, medical, or personal information pertaining to BVA’s employees;
• - Financial and personal information, data reports, and statistics pertaining to BVA’s members, veterans, vendors, or service providers;
• - Information, ideas, or data developed or obtained by BVA;
• - Information not generally made available to the public;
• - Information that is required by law, regulation, agreement, or policy to be kept confidential;
• - Information about donors; and
• - Information or data when BVA is bound by confidentiality obligations to a third party.

Board members, committee members, employees, and independent contractors may not disclose confidential and/or proprietary information to each other (unless it is about themselves) or to persons not affiliated with BVA without BVA’s written consent. Such information may be disclosed to persons affiliated with BVA only on a need-to-know basis (such as salaries to the Executive Committee, etc.). Consent will be authorized by the Executive Director or National President. Board and committee members should address any concerns or questions regarding this matter or whether a specific disclosure is appropriate to the National President or their designee and employees to the Executive Director.

This policy may pertain to other parties (such as independent contractors) as deemed necessary by the Executive Director or National President.

The Executive Director and the Board of Directors reserve the right to amend this policy. Any changes will be communicated to the committee members and employees.