There are two thingsāor probably three things.
When I started at SDTC in 2015, I was surprised to find that the conflict of interest policies for the employees and the board were actually the same. That is to say that employees actually were allowed at that point to have direct conflicts of interest. One of my first acts as CEO was to separate those two policies and ensure that there were no direct conflicts for employees. That continues to this day.
With respect to boards of directors, all a CEO can do is advise. The ethics policy for the board of directors had always had the ability for a board member to have conflicts. By the time I was appointed, most of the GIC appointees did not, but it had been a long-standing practice that the non-governmental appointees had managed conflict, as we have been talking about earlier.
The process in place is as follows: Before we go into an investment committee round, there are standing conflicts when people are appointed that are managed and are always looked at by the investment vice-president and director when we're going into a round.
The next thing that happens is there is a circulation well in advance of the meeting for boards of directors to declare if they have a conflict or a perceived conflict with a potential recipient of funds and consortia partners related to them. That has to be received back before the board members will receive any of the materials. If they declare a conflict, they do not receive the materials related to that declared conflict in the board package.
In the board package, all of the declarations are summarized and the chair would then call for any additions or any changes at the board meeting. Anybody who perhaps became aware of something between those dates could raise it at that time.
That's the process.
The idea is that these things would be minuted and followed up on as the case may be.
That's the process. It was followed in most cases. This was the managed conflict that we had in place.