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Policy 1200, Procedure Number 4

 Violations of the Conflicts of Interest Policy

  1. If any Trustee, Chief Executive Officer, or Executive has reasonable cause to believe that another Trustee, Chief Executive Officer, or Executive has failed to disclose actual or potential Conflicts of Interest, he/she shall inform the suspected Trustee, Chief Executive Officer, or Executive of the basis for such belief and afford the suspected Trustee, Chief Executive Officer, or Executive an opportunity to explain the alleged failure to disclose.

  2. If the suspected Trustee, Chief Executive Officer, or Executive believes that no actual or potential Conflict of Interest exists, and if no resolution is reached, the Trustee, Chief Executive Officer, or Executive shall petition for instructions pursuant to Section 554A-5(b), Hawaii Revised Statutes.

If any Trustee, Chief Executive Officer, or Executive determines that the suspected Trustee, Chief Executive Officer, or Executive has in fact knowingly failed to disclose an actual or potential Conflict of Interest, he or she shall petition for instructions pursuant to Section 554A-5(b), Hawaii Revised Statutes. If the failure to disclose is unintentional, the Trustee, Chief Executive Officer or Executive shall inform the Non-Conflicted Trustees, Non-Conflicted Chief Executive Officer, and Non-Conflicted Executives of the matter at a Board meeting, and the Non-Conflicted Trustees, Non-Conflicted Chief Executive Officer, and Non-Conflicted Executives promptly shall take appropriate action to address the Conflict of Interest, including, if warranted, by filing a petition pursuant to Section 554A-5(b), Hawaii Revised Statutes, and shall ensure that such failure to disclose does not recur.