Typically, what would happen is that a complainant—and it would either be an individual or that individual's counsel—would write to the board, raising a concern in writing. The matter would be referred to the member's immediate manager in the region. The manager would look into the complaint, conduct an investigation, make a determination, and if the person who complained didn't like that outcome, they would request a review by the deputy chairperson. If they didn't like the deputy chairperson's decision, they would request a review by the chairperson.
It was a very layered process. It was diffuse in the sense that there was inconsistency between regions in the way that the complaints were managed. I think, with the benefit of hindsight, that was when the person doing the investigating was a little too close to the person being investigated.