A board member, staff at the foundation and consultants at the foundation are all given the conflict of interest policies that exist in the foundation, and they must proactively declare when they have a link to an organization that may be applying for funding with the organization.
That declaration is then included in the minutes of the board of directors or the project review committee that looks at all of the projects. I would have expected that the foundation would be a little more proactive, then, to say, well, there is certain documentation you shouldn't get and certain conversations you shouldn't be part of, but because they didn't have a way to manage this, that proactiveness didn't happen.
It rested, then, with the individuals to recuse themselves. What we found is that the records did not show that this took place in 90 cases. They did show that it took place in 96 other cases. It's clear that at times it was well managed, but there are 90 cases that really were not properly managed.