2021-889 - Laserfiche WebLink

Ethics Board Docket No. 2021-889 Page 8 of13 records, fully subject to taxation, disclosed in required financial reports, and available for review by internal and external auditors. (r) Any technical violation of PM-3 resulted from a procedural oversight during an organizational transition, made in reliance upon guidance from senior administrative officials, rather than f'rom any intentional misconduct, willful disregard for policy, concealment, or attempt to obtain unauthorized benefits. (s) He acknowledges that the formal requirements of PM-3 technically required renewed presidential approval for executive-level employees receiving additional compensation, even when that compensation represented continuation of previously approved payments for previously approved duties. He further acknowledges that his reliance on institutional guidance and Human Resources processes, while reasonable and made in good faith, did not technically satisfy PM-3's express procedural requirements. (t) The circumstances of this matter reflect what was, at most, an administrative oversight shared by multiple University offices and personnel, including Human Resources, the Chancellor's office, and the Chief of Staff, occurring during a period of organizational transition and made in the context of institutional complexity regarding the application of PM-3 to previously approved compensation arrangements. (u) He has fully cooperated with the Board's investigation, has been forthcoming with information and documentation, acknowledges the technical nature of the procedural violation, and has never contested that the continuation of supplemental compensation without renewed presidential approval did not satisfy the literal requirements of PM-3, even though all parties operated in good faith belief that existing approvals sufficed.