National Multifamily Housing Council Inc

“The organization has members that are elected by the board of directors.”

“The organization's members may elect members of the governing body as authorized by the organization's governing documents.”

“The coo and the accounting director answer the questions on the form 990 using an independent accounting firm's advice and guidance, as necessary. The president reviews the completed 990. An independent accounting firm reviews the completed 990 and the nmhc operating committee reviews and accepts the final 990. The 990 is signed by the coo.”

“It is the policy of the council to prohibit its employees from engaging in any activity, practice, or act which conflicts with, or appears to conflict with, the interests of the council or the council's members. The following guidelines should be followed to avoid conflicts of interest. It is impossible to describe all of the situations that may result in a conflict of interest. Therefore, the guidelines included in this policy are not exhaustive and only include some of the more clear-cut examples. Employees have an obligation to avoid all conflicts of interest and to refer questions and concerns about potential conflicts to the coo. Employees are not to engage in, directly or indirectly, any conduct which is disloyal, disruptive, competitive or damaging to the council. Employees must disclose any financial interest they or their immediate family have in any firm which does business with the council or which competes with the council. The council may require divestiture of such interest if it deems the interest to be in conflict with its best interests. Employees must disclose any financial interest they or their immediate family (spouse, parents, children and parents in law) have in any member owned entities. The council may require divestiture of such interest if it deems the interest to be in conflict with its best interests. Employees may learn or become aware of information about members of the council which, if known to the public, might affect the decision of a reasonable investor to buy, sell or hold member-owned property or securities. Employees are prohibited from misusing such material inside information prior to public disclosure by purchasing or selling member-owned property or securities for their own account or for accounts of members of their immediate family. Further, employees are not to disclose inside information to anyone, either inside or outside the council who does not have a legitimate need to know. All employees should avoid personal activities or involvement which may result in personal benefit and thus create or appear to create a conflict with their responsibility and loyalty to the council. Should you receive any gifts, gratuities, or other items of value greater than $100 from member owned entities, vendors, or business contacts of nmhc. Employees should disclose such items in writing to their supervisor, who in turn will give the disclosure to the coo. Under no circumstances does nmhc allow the payment of bribes, kickbacks, or anything of value to any employee in exchange for any type of favor, profit, or concession. No later than january 31 of each year the vice president of administration will distribute the conflicts of interest form to all employees who will complete the form within 30 days of receipt and return it to the vice president of administration who will file the conflicts of interest form with the corporate files. The coo reviews the completed forms with the president and takes actions to mitigate any conflicts as appropriate. Nmhc also provides a toll-free number and website of a third-party reporting organization to report suspected violations of the law, violations of nmhc policies and procedures, dishonest or unethical behavior, crimes, or improper business activities. The reporting service provides monthly reports to nmhc and the treasurer of the operating committee. In each annual report nmhc provides the following information: nmhc members and employees are encouraged to report suspected violations of the law, violations of nmhc policies procedures, dishonest or unethical behavior, crimes, or improper business activities to nmhc's coo or through report line at 844/927-2221 or www.multifamily.ethicspoint.com. From time to time the board may change the process by which members or employees may communicate such reports. Employees will be notified of changes by internal communications. Members should check the nmhc web site for any changes to the reporting process. The operatin”

“For the president, the october 2022 process included a compensation benchmark study provided by a executive search firm and their compensation consultants, a review of the president's accomplishments by the elected officers, an evaluation by the elected officers, and a determination of a bonus communicated by the operating committee. For other nmhc officers or key employees, the process included a review of the 2023 compensation benchmark study provided by a professional compensation consultant and a current review of compensation data from peer real estate associations. A review of each employee's accomplishments and a determination of a bonus is made by the president.”

“Nmhc makes its financial statements available to the operating committee monthly. The audited financial statements are available upon request and approved by the nmhc operating committee. The governing documents and conflict of interest policy are also available upon request.”