That's correct.
When we're talking about the COVID payments, we need to talk about two payments that were made. The findings of the RCGT report didn't just say that the conflict of interest rules were broken. The report also found that all of the $40 million that was given out was not even effectively tracked, because anything that was funded by SDTC had to be tracked for eligible funding. None of that happened for either payment, as found by the RCGT report.