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By statute, NPC officers, directors, and employees are subject to a conflict of interest policy established by the NPC.  NPCs must have a board-approved NPC conflict of interest policy and the statute requires all directors, officers and employees to undergo training within 90 days of  appointment as well as additional annual disclosure requirements.

Handbook 1200.17 Requirements Pertaining to the NPC Conflict of Interest Policy

Overarching requirement:  Each NPC must adopt a conflict of interest policy applicable to directors, officers and employees. 

Sample policy:  Click here for NAVREF's sample policy, including a disclosure form and acknowledgement statement, may be found at:

X = Requirement applies to this category of NPC personnel

Requirements Time Period Statutory VA Directors Statutory Non-Federal Directors Other Directors (if any) Key Employees* Other Employees Officers Who are Not EEs or Directors
Training requirement
(May consist of providing appointees with a copy of the NPC policy to study.)
New appointees must be trained on the NPC COI policy within 90 days of appointment X X X X X X
Subsequent annual training on the NPC COI policy X X X X   X
Disclosure requirement (Complete and submit to NPC the NPC-approved disclosure form.)+ New appointees’ initial disclosure X X X X Not required by handbook, but NAVREF recommends a one-time disclosure X
Annual disclosure X X X X   X
Acknowledgement of understanding and agreement to comply (Complete and submit to NPC the NPC form.)+ New appointees (one time requirement) X X X X X X
Certification Annually in the June 1 NPC Annual Report to VA, the executive director certifies that each NPC Director, officer and employee has:
(1)  Been trained about the conflict of interest policy;
(2)  Acknowledged understanding of and agrees to comply with the policy; and
(3)  Submitted a conflict of interest disclosure form (annual disclosure requirement applies only to directors, officers and key employees).
 


 *Note:  Key employees = employees with decision making authority as defined by NPC.
+Note:  NPC retains these forms in NPC files.
 

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