Institutional Documents  ·  Effective May 2026

Vordan Governance

The institutional documents that govern how Vordan operates, what it assesses, and what it owes to the people who rely on it. Independence is not a claim. It is a structure.

Editorial Independence Conflict of Interest Subject Selection Corrections Effective May 2026

Documents

Document 01

Editorial Independence Declaration

No commercial relationship influences what Vordan publishes.

Effective May 2026  ·  Dominick Costa, Founder

Vordan is an independent governance and accountability publication. Its editorial output, including Gap Alerts, Accountability Reports, external posture assessments, and framework assessments, is determined solely by the editorial judgment of its founder. No advertiser, sponsor, subscriber, or assessed organization has any influence over what Vordan publishes, how it characterizes findings, or what conclusions it reaches.

This declaration is not a statement of aspiration. It is a structural commitment with specific and binding terms.

Term I
No advertising
Vordan accepts no paid advertising in any form, in any publication format, on any platform associated with the Vordan brand. No organization may pay to appear in, be featured in, or be excluded from Vordan's editorial output.
Term II
No sponsored content
Vordan does not produce sponsored content, branded content, native advertising, or any editorial output that is funded by or produced in coordination with an external organization. Content that would be commercially influenced is not published under the Vordan brand.
Term III
No commercial relationships with assessed organizations
Vordan does not accept payment, equity, services, or any other form of consideration from organizations it is currently assessing, has assessed within the prior twelve months, or has identified as a potential assessment subject. Where a commercial relationship with any organization is established, that organization is permanently excluded from Vordan's assessment pipeline for the duration of the relationship and for twelve months following its conclusion.
Term IV
Sole editorial authority
Dominick Costa, as founder, holds sole editorial authority over all Vordan output. No subscriber, investor, partner, or external party may direct, approve, or veto editorial decisions. If Vordan's governance structure changes to include additional editorial authorities, this declaration will be updated and the change will be disclosed publicly.
Term V
Subscription revenue does not confer influence
Subscription revenue from individuals and organizations funds Vordan's operations and does not confer any editorial access, advance notice of assessments, right of review, or influence over findings. A subscribing organization is subject to the same assessment standards as a non-subscribing organization.
Declaration

I declare that the editorial output of Vordan is and will remain independent of commercial relationships. Where a conflict arises that cannot be resolved consistent with these terms, the commercial relationship will be terminated, not the editorial standard.

This declaration is effective as of May 2026 and applies to all Vordan content published from the date of Vordan's founding.

Dominick Costa
Founder, Vordan  ·  dominick@vordan.co

Document 02

Conflict of Interest Policy

How Vordan identifies, discloses, and resolves conflicts.

Effective May 2026  ·  Applies to all assessments and editorial output

A conflict of interest exists when Vordan has a financial, professional, or personal relationship with an organization that could reasonably be expected to influence, or appear to influence, the objectivity of an assessment or editorial judgment. This policy defines what constitutes a conflict, how conflicts are disclosed, and what happens when one is identified.

Section I
What constitutes a conflict
A conflict exists when Vordan or its founder holds: any financial interest in an assessed organization or its parent, subsidiary, or affiliated entities; any consulting, advisory, or employment relationship with an assessed organization; any personal relationship with an individual whose professional interests would be materially affected by an assessment outcome; or any prior commercial relationship with an assessed organization within the preceding twelve months.
Section II
Disclosure
Where a potential conflict is identified and Vordan determines it does not affect the objectivity of the assessment, the conflict will be disclosed in the published output. The disclosure will name the nature of the relationship and state the basis on which Vordan determined the assessment could proceed without bias. Disclosure does not substitute for recusal where the conflict is material.
Section III
Recusal
Where a conflict is material, meaning it could reasonably affect or appear to affect the objectivity of an assessment, Vordan will not conduct the assessment. The organization will not be assessed until the conflict is resolved and the twelve-month exclusion period has elapsed. Recusal decisions are made by the founder and documented internally.
Section IV
Future governance bodies
If Vordan establishes an advisory board, certification committee, or other governance body, each member of that body will be subject to this conflict of interest policy. Conflicts held by governance body members will be disclosed publicly upon appointment and updated annually.
Section V
Reporting a potential conflict
Any party that believes a conflict exists that has not been disclosed may contact Vordan at dominick@vordan.co. All conflict reports are reviewed by the founder and responded to within ten business days. Where a report identifies a previously undisclosed conflict, Vordan will publish a disclosure or recusal notice within that same period.
Independence is not the absence of relationships. It is the presence of a policy that governs them.

Document 03

Subject Selection Criteria

Why Vordan assesses a particular organization and not another.

Effective May 2026  ·  Applies to Gap Alerts, VEPAs, and VAF assessments

Subject selection is an editorial decision. It determines who Vordan covers, who it assesses, and who it holds to account. Without a published selection policy, every assessment is vulnerable to the perception that it was motivated by something other than the accountability gap it claims to map. This document states the criteria Vordan applies and what it does not consider.

Criterion I
The intelligence warrants it
A Gap Alert or external assessment is initiated when the founder identifies a material accountability gap through ongoing monitoring of security disclosures, regulatory filings, incident reports, and practitioner-sourced signals. The gap must be real, documented, and traceable to a specific failure in one or more VAF components. The existence of a gap is the threshold, not the organization's size, sector, or public profile.
Criterion II
The public interest is material
The accountability gap must affect or potentially affect a population of people who have no direct means of assessing it themselves. Organizations that handle sensitive personal data, deploy AI systems that make consequential decisions, or provide critical infrastructure to other organizations meet this threshold by default. Organizations that do not meet this threshold are not Vordan assessment subjects regardless of the severity of internal governance failures.
Criterion III
The evidence is available
Vordan does not publish assessments based on inference, rumor, or unverifiable claims. For a Gap Alert or VEPA, sufficient primary source evidence must exist in the public record to support the findings. For a VAF Assessment, the organization must engage Vordan and provide the access required by the instrument. Assessments that cannot meet this evidentiary standard are not published.
Criterion IV
No commercial motivation
Vordan does not select subjects because they are competitors of organizations with which Vordan has a commercial relationship, because they have declined to engage with Vordan commercially, or because any third party has requested or incentivized their selection. Selection is not for sale and is not influenced by external pressure in either direction.
Criterion V
Organizations may request assessment
An organization may request a VAF Assessment by contacting Vordan directly. Requested assessments are subject to the same evidentiary standards and editorial independence requirements as self-initiated assessments. A request does not guarantee a positive finding. Vordan reserves the right to decline assessment requests that present unresolvable conflicts of interest or that do not meet the public interest threshold.

Document 04

Correction and Retraction Policy

What Vordan does when it gets something wrong.

Effective May 2026  ·  Applies to all published output

Vordan holds other organizations to the standard that accountability requires a defined, tested process for handling failures, and that the process must exist before it is needed. This policy is that process for Vordan itself.

Section I
Types of error
Vordan distinguishes between three categories of error. A factual error is a statement of fact that is demonstrably incorrect based on the evidence available at the time of publication or subsequently. An evidentiary error is a finding that was supported by evidence at the time of publication but is materially contradicted by subsequently available evidence. A contextual error is a characterization that, while factually accurate, omitted material context that would have changed the finding or its weight.
Section II
How to submit a correction request
Any party may submit a correction request to dominick@vordan.co. The request must identify the specific claim, the basis on which it is believed to be incorrect, and any supporting evidence. Anonymous correction requests are reviewed but do not receive a direct response. Correction requests from assessed organizations are subject to the same evidentiary standard as any other request. Disagreement with a finding is not a basis for correction.
Section III
Review and response timeline
Vordan will acknowledge receipt of a correction request within five business days and complete its review within fifteen business days of receipt. Where additional evidence or research is required, the review period may be extended; Vordan will notify the requester of the extension and the expected completion date. All correction requests are reviewed by the founder.
Section IV
Corrections
Where a factual or evidentiary error is confirmed, Vordan will publish a correction in the original piece and, where the error is material, as a standalone notice. Corrections identify the original statement, the correct information, and the date of correction. Corrections are not deletions. The original erroneous statement remains visible with the correction appended.
Section V
Retractions
A retraction is issued only where an error is so fundamental that no correction can adequately remedy it, where the central finding of a piece cannot stand. Retractions are published as standalone notices, linked from the original piece, and the original piece is labeled as retracted. Retractions do not delete the original content; they contextualize it. Vordan does not issue retractions in response to legal pressure where the underlying finding is accurate.
Section VI
Right of response
An organization that is the subject of a Gap Alert or assessment may submit a response for publication. Responses must be factual, must be submitted within thirty days of publication, and are published in full without editorial modification, adjacent to the original piece. Vordan reserves the right to append a brief editorial note where the response contains factual claims that are contradicted by the evidentiary record.
A correction policy that only exists after the first error is not a correction policy. It is a reaction.

Version history

These governance documents are versioned. Changes to any document will be disclosed in this section with the date of change, the nature of the change, and the reason for it. The current versions of all documents are effective as of May 2026.

Version 1.0, May 2026. Initial publication of all four governance documents concurrent with the publication of the VAF Public Specification v1.0.