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Ethics Board Docket No. 2022-026 <br /> Page 5 of 14 <br /> development services delivered substantial and measurable value to the institution and were <br /> consistent with the duties Mr. Schroth had been performing and receiving supplemental <br /> compensation for since 2016. <br /> (d) Dr. Hollier reasonably and in good faith relied upon the advice and guidance of Louis <br /> Colletta, who served as Chief of Staff to the LSU System and held a senior administrative <br /> position with system-wide responsibilities. Mr. Colletta specifically advised him, Mr. Schroth, <br /> and Human Resources personnel that no new presidential approval was required for the <br /> continuation of Mr. Schroth's supplemental compensation following the promotion to Vice <br /> Chancellor. <br /> (e) Mr. Colletta's interpretation of LSU Permanent Memorandum 3 (PM-3) was that the <br /> policy operated prospectively rather than retrospectively, meaning that previously approved <br /> compensation arrangements could continue without new presidential approval. This <br /> interpretation was subsequently documented in the 2021 LSU Internal Audit of LSUHSC-NO, <br /> which quoted Mr. Colletta's advice: "Colletta instructed the Chancellor's Administrative Officer <br /> to move forward with the request and provided an opinion to Higginson that the policy was <br /> prospective, not retrospective; therefore, President approval was unnecessary." <br /> (� Given that Mr. Colletta occupied a senior administrative role within the LSU System <br /> with authority to interpret system-wide policies, and given that he communicated this policy <br /> interpretation to multiple stakeholders including himself, Mr. Schroth, and Human Resources <br /> personnel, his reliance on this guidance was reasonable, made in good faith, and consistent with <br /> his understanding of proper institutional procedures and the chain of authority within the LSU <br /> System. <br />