Chair, I'll mention a couple of things.
One is that yes, it's clear in the letter of offer that conflicts should be disclosed, and you have 60 days to do so. I think there are various times—once a year—when employees are reminded of their obligations and asked to redisclose.
I think one of the things that could or should happen is being more aggressive in reminding employees of their obligations. We talked earlier today about possibly helping employees with their thought process in identifying potential conflicts. There are some questions they should consider when assessing their own conflicts.
I would rather be in a place where employees disclose anything that might be an issue and give an independent person a chance to decide whether it's a conflict or not. Obviously, managers should be reminded that if they learn anything about their employees while they're managing them on a day-to-day basis, they should ask them if they've disclosed it. When they have not, I would expect the manager to initiate a discussion around disclosure.
It's raising awareness of employees and reminding managers that if they become aware of the business activities of their employees, they should be proactively asking if they have disclosed them, and maybe flagging the annual requirements through performance assessments and performance agreements. Make it shine in flashing lights a bit more to remind employees of their obligations. All of that would be helpful.