Please take a few minutes to review the draft sample conflict of interest policy for NPCs and to provide NAVREF with the benefit of your insights on this important policy.  NAVREF welcomes your comments and edits by close of business on Monday, August 16.

 Background:  The NPC authorizing statute enacted in May 2010 states, “Each director, officer and employee of a corporation established under this subchapter shall be subject to a conflict of interest policy adopted by that corporation.” [38 USC § 7366(c)]  This statement replaced the clause in the former NPC statute that invoked the federal conflict of interest laws and regulations for NPC personnel. 

 To help NAVREF members comply with the new requirement, the NAVREF board and staff developed the attached draft sample policy.  After incorporating member comments, the final draft will be shared with the VA Office of General Counsel for review and assurance that it meets the statutory requirement. 

 Thank you in advance for your comments.

Click here for draft sample conflict of interest policy for NPCs