The We Card Program Inc

“The organization maintains a management contract with otm partners llc to provide day-to-day management and other services. An employee of otm partners served as an officer throughout all of 2014. The other directors (including two directors that served as officers) are independent and are not employees of otm partners. The board of directors reviews and/or provides all management duties as well.”

“In 2014, yes, the organization had "key members and regular members." description: the key members of the corporation shall be trade associations and business entities, including corporations, partnerships, limited partnerships, limited liability companies and sole proprietorships, engaged in or representing those engaged in the manufacture, distribution and sale, at wholesale and retail, of tobacco products which are interested in advancing the purposes and programs of the corporation. Each key member shall be entitled to one vote upon such matters or issues as shall be authorized by the board of directors and upon any corporate matter or action which, under the nonstock corporation act of the commonwealth of virginia, requires a vote of members. The regular members of the corporation shall be individuals, business entities, trade associations, organizations, agencies, including law enforcement organizations, how or which are interested in advancing the purposes and programs of the corporation. Regular members shall be entitled to vote only upon such matters or issues as shall be authorized by the board of directors, provided that no regular member shall be authorized or entitled to vote upon any corporate matter or action under the nonstock corporation act of the commonwealth of virginia, the articles of incorporation, or these by-laws.”

“Voting rights of key members - each key member shall designate on individual, which designation may be changed from time to time by written notice from the key member to the corporation, to represent the interest of the key member in its relationship with the corporation. The individual designated shall be entitled to one vote upon such matters or issues as shall be authorized by the board of directors and upon any corporate matter or action which, under the nonstock corporation act of the commonwealth of virginia, requires a vote of members. Voting rights of regular members - each regular member (other than an individual person) shall designate an individual, which designation may be changed from time to time by written notice from the regular member to the corporation, to represent the interest of the regular member in its relationship with the corporation. The regular member who is an individual person shall be his or her own representative. Regular members shall be entitled to vote only upon such matters or issues as shall be authorized by the board of directors, provided that no regular member shall be authorized or entitled to vote upon any corporate matter or action under the nonstock corporation act of the commonwealth of virginia, the articles of incorporation, or the by-laws. In 2014, the organization has members who may elect one or more members of the governing body. See description and nature of their rights as answered in the previous question.”

“The 990 is reviewed by the audit committee of the board of directors in advance of its filing.”

“The audit committee reviews annually the conflict of interest policy and compliance activity with the policy. Each member of the board of directors and each officer and member of management of this corporation shall disclose to the president of this corporation the material facts as to any relationship or interest he or she may have in, and any direct or indirect financial benefit he or she might derive from, any contemplated contract or transaction with this corporation. For any such contemplated contract or transaction, all such material facts shall be disclosed to the board of directors and the director or officer or employee having the relationship or interest in (or as to) any such contemplated contract or transaction shall not be present at, or participate in, the deliberations of or the vote by the board of directors of this corporation relating to such contract or transaction. Such contract or transaction may be authorized, approved or ratified by the affirmative votes of a majority of the disinterested directors, even though the disinterested directors be less than a quorum, if such disinterested directors determine in good faith to their satisfaction that the contract or transaction would be in the best interest of this corporation and would otherwise have been authorized or entered into in the ordinary course of this corporation's business.”

“Currently, the organization's governing documents, conflict of interest policy and financial statements are not made available to the public. However, the articles and by laws were included as attachments in the organization's original form 1024 (application to become a c(4) entity).”

“The audit oversight process has remained unchanged from the previous year.”