22.4.6 The COO

The COO must establish and staff a “Conflict of Interest Review Panel” comprised of the General Counsel, the COO, and two faculty members. The COO is responsible for making determination of appropriate actions regarding conflict of interests or commitments, hearing report and recommendation by the panel. In addition, the COO, for University Officers and Senior Level Executives, must establish procedures to assure compliance with annual disclosure and other Conflict of Interest reporting requirements, provide review of disclosed situation, and report to the President and Board of Governors when it deems necessary.

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