American CIVIL Liberties Union Fund of the District of Columbia

“The form 990 was prepared by the outside accountants and reviewed by senior staff and the treasurer. The full board received a copy of the final 990 before it was filed.”

“To ensure that covered persons are aware of the conflict of interest policy, each aclu affiliate delivers a copy of the policy to each board member, officer, volunteer board committee member and key employee of that affiliate at the beginning of his or her service for that entity and annually thereafter. Each distributee then acknowledges having received, read and understood the policy and, if s/he has a matter s/he is required to disclose under this policy at that time, discloses that matter. Each national covered person is required to disclose in good faith to national aclu all material facts concerning any personal interest with respect to a proposed or prior national aclu transaction or action of which s/he is aware, and each affiliate covered person is required to disclose in good faith to that affiliate all material facts concerning any personal interest with respect to a proposed or prior affiliate transaction or action of which s/he is aware, prior to (if possible) the consideration of the transaction or action. In the case of board members, officers and volunteer board committee members, the usual procedure for disclosing potential conflicts of interest is that the covered person informs the applicable board or board committee (or board committee chair) considering the transaction or action or the aclu president of the personal interest. In the case of a key employee, the usual procedure is that the key employee informs his or her supervisor (or in the case of the executive director, the president) of the personal interest. In either case, the matter is referred for its consideration and decision-making to the aclu affiliate's audit committee (or, if there is no audit committee, to the board or its executive committee authorized to act on its behalf) (the "deciding body"). A covered person may participate in a meeting of the deciding body during which a transaction or action with respect to which s/he has a personal interest is discussed in order to disclose the material facts regarding the covered person's personal interest. The deciding body discusses the matter at a meeting without that person present. A covered person may not participate in making decisions with respect to any matter in which s/he has a personal interest and may not attempt to influence improperly the deciding body's deliberation or voting on the matter. In all cases, prior to an aclu affiliate entering into a transaction or taking an action after a covered person has disclosed a personal interest with respect to that transaction or action, it is determined by no less than a majority vote of the members of the deciding body present at a meeting of that aclu entity that the transaction or action is fair and reasonable to, and in the best interests of aclu national in the case of a personal interest involving a national covered person or the aclu affiliate in the case of a personal interest involving an aclu affiliate covered person, and that it does not result in an unfair or unreasonable financial or other benefit to the covered person who has the personal interest. In the case of a transaction or action in which the personal interest of the covered person is a substantial financial interest, the deciding body considers alternative transactions to the extent available.”

“The executive director's compensation process was determined and approved by independent members of the board. The process included a review of comparable data from similar organizations and was documented. The last compensation review took place in december 2025.”

“The organization makes a determination of the availability of its governing documents, conflict of interest policy and financial statements on a case by case basis.”