Electrical Workers' Veba Trust

“The Trust is administered by an eight-member Board of Trustees. IBEW Locals 77, 125, 483, and 659 appoint four trustees on behalf of the represented employees. The Northwest Line Constructor's Chapter of the National Electrical Contractors Association appoints four trustees on behalf of the participating employers.”

“The Trust auditor annually completes a draft of the Form 990 and sends a copy of that draft via e-mail to the Trust's legal counsel and plan consultant for review. The Trust's auditor presents the audited financials and draft Form 990 (which includes any revisions from the Trust's legal counsel and plan consultant) during a regularly scheduled Trustee Meeting before filing the Form 990 with the IRS. During the Board's review with the Trust auditor, the Board may discuss any recommended or required changes, which will be reflected in the meeting minutes. Upon confirmation that the Board has accepted the Form 990, the Trust auditor files the Form 990 in accordance with IRS instructions. The plan consultant maintains the final copies of the Trust's Form 990 and supporting audited financials in accordance with the Trust's Document Retention and Destruction Policy.”

“A party in interest is under continuing obligation to disclose any potential conflict of interest to the Board of Trustees as soon as it is known, or reasonably should be known. The interested party is given the opportunity to disclose all material facts to the Trustees when considering the proposed transaction or arrangement. To ensure that the Trust operates in a manner consistent with its purposes and does not engage in activities that could jeopardize its tax-exempt status, periodic (at least annual) reviews are conducted. These periodic reviews include: Whether compensation arrangements and benefits are reasonable, based on competent survey information, and the result of arm's length negotiation; Whether partnerships, joint ventures, and arrangements with other organizations conform to written policies, are properly recorded, reflect reasonable investment or payments for goods and services, further the Trust's purposes, and do not result in inurement, impermissible private benefit or in an excess benefit transaction; and Whether any transaction conducted by the Trust during the review period involves or could possibly give rise to a conflict of interest. In connection with such review, each interested party will complete an annual questionnaire which will include (1) acknowledgement by such person or entity that they have read and understand the Trust's Conflict of Interest Policy and (2) disclosure of such person's or entity's knowledge regarding any of the above subjects and any other potential or perceived conflict of interest.”

“The Trust's governing documents, conflict of interest policy and Form 990 are available to the general public upon written request sent to the Trust at: Gallagher Benefit Services, Inc., 906 W 2nd Avenue, Suite 400, Spokane, WA 99201.”

“None of the members of the Board of Trustees are compensated by the organization. The Board of Trustees is composed of eight individuals, four of whom are representatives of participating employers and four of whom are representatives of participating local unions. The Trustees serve on a volunteer basis, and receive no known specifically stated compensation from their employers or any other party for their services on the Board. The Trust does not readily have access to information related to compensation paid by other entities to the Trustees.”