UNIVERSITY OF VIRGINIA
FULL BOARD OF VISITORS
MEETING ON BUSINESS MATTERS
AUGUST 2, 2013
FULL BOARD MEETING ON BUSINESS MATTERS
Friday, August 2, 2013
1:30 – 2:30 p.m.
Abbott Center Dining
Conference Room, Darden School
AGENDA
PAGE
I.
II.
ACTION ITEMS (Mr. Martin)
A.
Proposed Legislation (Mr. Martin to introduce
Mr. Patrick D. Hogan; Mr. Hogan to report)
1.
Amending the Code of Virginia to Include
Certain Administrative Investigations
Conducted by Institutions of Higher
Education Within Existing Exemptions Under
the Freedom of Information Act
2.
Amending the Code of Virginia Pertaining
to Vesting Schedules for Optional
Retirement Plans
B.
Board Manual Changes
C.
Revisions to the Policy on Presidential Evaluation
Attachment
A.
Revisions to the Board Manual
1
5
8
11
UNIVERSITY OF VIRGINIA
BOARD OF VISITORS AGENDA ITEM SUMMARY
BOARD MEETING:
August 2, 2013
COMMITTEE:
Full Board
AGENDA ITEM:
I.A.1. Amending the Code of Virginia to
Include Certain Administrative Investigations
Conducted by Institutions of Higher Education
Within Existing Exemptions Under the Freedom
of Information Act
BACKGROUND: The Freedom of Information Act provides that public
records be made available to citizens of the Commonwealth, while
also exempting various records from disclosure specifically
those that include sensitive information. Section 2.2-3705.3 of
the Code of Virginia includes exemptions for records relating to
investigations of employment discrimination complaints and audit
investigations. These exemptions provide broad protections for
active investigations and limited protection for the identity of
participants of completed investigations for various public
bodies, but these provisions do not apply to institutions of
higher education even though auditors and offices of equal
opportunity programs are performing the same types of
investigations as other public bodies already covered by the
Act. The discrepancy in the current law places institutions of
higher education at risk of greater exposure in sensitive areas
of these specific types of administrative investigations.
DISCUSSION: The University proposes to amend § 2.2-3705.3 of
the Code of Virginia to exempt investigations of employment
discrimination complaints and audit investigations conducted by
institutions of higher education from disclosure to the same
extent such investigations are exempt for other public bodies
under the Freedom of Information Act. Amendments appear in
underlined italics in the body of the resolution.
Proposed legislation for the 2014 Session must be
submitted to the Governor’s Office before the next regular
Board of Visitors meeting in September, and is therefore being
brought before the Board for consideration at this time.
ACTION REQUIRED:
Approval by the Board of Visitors
1
APPROVAL OF LEGISLATIVE PROPOSAL TO AMEND CODE OF VIRGINIA
SECTION 2.2-3705.3
RESOLVED, the Board of Visitors approves and endorses
amending the Code of Virginia as it pertains to the Freedom of
Information Act.
The proposed amendments to § 2.2-3705.3 of the Code of
Virginia are as follows:
§ 2.2-3705.3. Exclusions to application of chapter; records
relating to administrative investigations.
The following records are excluded from the provisions of this
chapter but may be disclosed by the custodian in his discretion,
except where such disclosure is prohibited by law:
1. Confidential records of all investigations of applications
for licenses and permits, and of all licensees and permittees,
made by or submitted to the Alcoholic Beverage Control Board,
the State Lottery Department, the Virginia Racing Commission,
the Department of Agriculture and Consumer Services relating to
investigations and applications pursuant to Article 1.1:1 (§
18.2-340.15 et seq.) of Chapter 8 of Title 18.2, or the Private
Security Services Unit of the Department of Criminal Justice
Services.
2. Records of active investigations being conducted by the
Department of Health Professions or by any health regulatory
board in the Commonwealth.
3. Investigator notes, and other correspondence and information,
furnished in confidence with respect to an active investigation
of individual employment discrimination complaints made to the
Department of Human Resource Management, to any public
institution of higher education, or to such personnel of any
local public body, including local school boards as are
responsible for conducting such investigations in confidence.
However, nothing in this section shall prohibit the disclosure
of information taken from inactive reports in a form that does
not reveal the identity of charging parties, persons supplying
the information or other individuals involved in the
investigation.
4. Records of active investigations being conducted by the
Department of Medical Assistance Services pursuant to Chapter 10
(§ 32.1-323 et seq.) of Title 32.1.
2
5. Investigative notes and other correspondence and information
furnished in confidence with respect to an investigation or
conciliation process involving an alleged unlawful
discriminatory practice under the Virginia Human Rights Act (§
2.2-3900 et seq.) or under any local ordinance adopted in
accordance with the authority specified in § 2.2-524, or adopted
pursuant to § 15.2-965, or adopted prior to July 1, 1987, in
accordance with applicable law, relating to local human rights
or human relations commissions. However, nothing in this
section shall prohibit the distribution of information taken
from inactive reports in a form that does not reveal the
identity of the parties involved or other persons supplying
information.
6. Records of studies and investigations by the State Lottery
Department of (i) lottery agents, (ii) lottery vendors, (iii)
lottery crimes under §§ 58.1-4014 through 58.1-4018, (iv)
defects in the law or regulations that cause abuses in the
administration and operation of the lottery and any evasions of
such provisions, or (v) the use of the lottery as a subterfuge
for organized crime and illegal gambling where such official
records have not been publicly released, published or
copyrighted. All studies and investigations referred to under
clauses (iii), (iv), and (v) shall be open to inspection and
copying upon completion of the study or investigation.
7. Investigative notes, correspondence and information furnished
in confidence, and records otherwise exempted by this chapter or
any Virginia statute, provided to or produced by or for (i) the
Auditor of Public Accounts; (ii) the Joint Legislative Audit and
Review Commission; (iii) an appropriate authority as defined in
§ 2.2-3010 with respect to an allegation of wrongdoing or abuse
under the Fraud and Abuse Whistle Blower Protection Act (§ 2.23009 et seq.); (iv) the Office of the State Inspector General
with respect to an investigation initiated through the State
Employee Fraud, Waste and Abuse Hotline or an investigation
initiated pursuant to Chapter 3.2 (§ 2.2-307 et seq.); (v) the
committee or the auditor with respect to an investigation or
audit conducted pursuant to § 15.2-825; or (vi) the auditors,
appointed by any public institution of higher education or the
local governing body of any county, city or town or a school
board, who by charter, ordinance, or statute have responsibility
for conducting an investigation of any officer, department or
program of such body. Records of completed investigations shall
be disclosed in a form that does not reveal the identity of the
complainants or persons supplying information to investigators.
3
Unless disclosure is prohibited by this section, the records
disclosed shall include, but not be limited to, the agency
involved, the identity of the person who is the subject of the
complaint, the nature of the complaint, and the actions taken to
resolve the complaint. If an investigation does not lead to
corrective action, the identity of the person who is the subject
of the complaint may be released only with the consent of the
subject person. Local governing bodies shall adopt guidelines
to govern the disclosure required by this subdivision.
4
UNIVERSITY OF VIRGINIA
BOARD OF VISITORS AGENDA ITEM SUMMARY
BOARD MEETING:
August 2, 2013
COMMITTEE:
Full Board
AGENDA ITEM:
I.A.2. Amending the Code of Virginia
Pertaining to Vesting Schedules for Optional
Retirement Plans
BACKGROUND: Section 51.1-126 of the Code of Virginia authorizes
the University to establish and maintain an optional retirement
plan (ORP) for University faculty and certain other employees.
When hired, these employees must enroll in either the
University’s ORP or the retirement plan administered by the
Virginia Retirement System (VRS). The plans managed by the VRS
include a vesting provision requiring that employees must have
at least five years of continuous service in order to collect
the employer contributions to their retirement account upon
termination of their employment. Current law does not authorize
institutions that manage ORPs to implement vesting requirements,
so participating employees receive all funds contributed to
their retirement account by both the employer and the employee
upon leaving the University regardless of their length of
service.
DISCUSSION: The University seeks to amend § 51.1-126 of the
Code of Virginia to allow institutions of higher education
managing ORPs (in addition to UVa, George Mason University,
Virginia Tech, and Virginia Commonwealth University) to
implement a vesting program for employees hired on or after July
1, 2014. Note the proposed language is permissive and does not
require that an institution implement a vesting schedule. The
University contributes 10.4% of an employee’s salary to the ORP
for employees hired prior to July 1, 2010, and 8.9% for
employees hired on or after July 1, 2010. Implementing a
vesting requirement for ORPs would result in estimated savings
to the University of up to $1 million per year. All savings
realized as a result of the implementation of a vesting schedule
would revert to a forfeiture account to be used to offset future
retirement plan contributions.
Proposed legislation for the 2014 Session must be
submitted to the Governor’s Office before the next regular
Board of Visitors meeting in September, and is therefore being
brought before the Board for consideration at this time. The
specific language to be added appears as paragraph F.2. of §
5
51.1-126 of the Code of Virginia in the resolution below.
ACTION REQUIRED:
Approval by the Board of Visitors
APPROVAL OF LEGISLATIVE PROPOSAL TO AMEND CODE OF VIRGINIA
SECTION 51.1-126
RESOLVED, the Board of Visitors approves and endorses
amending the Code of Virginia as it pertains to optional
retirement plans managed by institutions of higher education.
The proposed amendment to § 51.1-126 of the Code of
Virginia is as follows:
§ 51.1-126. Employees of institutions of higher education.
For purposes of this section, "optional retirement plan" means a
retirement plan covering the employee for retirement purposes
other than the Virginia Retirement System defined benefit
retirement plan established under this chapter or the hybrid
retirement program described in § 51.1-169.
F.1. The contribution by the Commonwealth on behalf of an
employee participating in an optional retirement plan maintained
by the Board or on behalf of an employee participating in an
optional retirement plan established by his institution of
higher education under this section to such employee's
retirement plan shall be (i) at least 8.5% but not in excess of
8.9% of creditable compensation for any person who becomes a
member on or after July 1, 2010, and (ii) 10.4% of creditable
compensation for all other employees. Any institution of higher
education that elects a contribution in excess of 8.5% of
creditable compensation for any employee described in clause (i)
shall provide for the same percentage of creditable compensation
as contributions for each of its employees described in clause
(i) who participates in such optional retirement plan. The
portion of the contribution in excess of 8.5% of creditable
compensation pursuant to clause (i) shall not be funded from the
general fund of the state treasury, but shall be paid by the
institution of higher education from other funds. In addition,
any person who becomes a member on or after July 1, 2010, shall,
pursuant to procedures established by the Board, pay member
contributions on a salary reduction basis in accordance with §
414(h) of the Internal Revenue Code, in an amount equal to 5% of
his creditable compensation, to the optional retirement plan
maintained by the Board on his behalf or the optional retirement
plan established by his institution of higher education on his
6
behalf, as applicable. Each employee making such member
contribution shall be deemed to consent and agree to any salary
reduction for purposes of the member contribution. Such member
contributions shall be in addition to all contributions pursuant
to clause (i). An institution of higher education may make an
additional contribution for participants who, before January 1,
1991, exercised the election to participate in the plan provided
by the institution employing them. Such additional
contributions shall be made using funds other than general
funds, tuition or fees, up to an additional 2.17% of creditable
compensation.
2. The Board of any institution of higher education that
establishes its own optional retirement plan under this section
may impose a vesting schedule on employer contributions made
pursuant to subdivision 1 for any person who becomes a member on
or after July 1, 2014. Contributions made by the employer on
behalf of the member under subdivision 1 that are not vested,
shall be forfeited upon the member’s termination of employment.
The employer may establish a forfeiture account and may specify
the uses of the forfeiture account.
3. These contribution rates shall be examined by the Board at
least once every six years. The examination shall consider the
salary peer group mean contribution as determined by the State
Council of Higher Education and the Virginia Retirement System
actuary, and, if deemed advisable, recommend a revision to the
rate of contribution by the Commonwealth.
7
UNIVERSITY OF VIRGINIA
BOARD OF VISITORS AGENDA ITEM SUMMARY
BOARD MEETING:
August 2, 2013
COMMITTEE:
Full Board
AGENDA ITEM:
I.B.
Board Manual Changes
BACKGROUND: Legislation was enacted by the General Assembly,
effective July 1, 2013, that, inter alia, requires the Board to
revise its bylaws. The Manual of the Board of Visitors of the
University of Virginia contains the bylaws.
The provisions of Chapter 577 of the 2013 Acts of Assembly
(House Bill 1952) pertinent to the Board of Visitors are as
follows:
Be it enacted by the General Assembly of Virginia:
1. That § 23-9.14:1 of the Code of Virginia is amended and reenacted and that the Code of
Virginia is amended by adding sections numbered 23-2.01 through 23-2.05 as follows:
§ 23-2.01. Boards of visitors; public access to information.
Notwithstanding § 2.2-4342 and the Virginia Freedom of Information Act (§ 2.2-3700 et seq.),
the board of visitors of each public institution of higher education and the State Board for
Community Colleges may conduct closed meetings pursuant to §§ 2.2-3711 and 2.2-3712 and
may conduct business as a "state public body" for purposes of subsection B of § 2.2-3708.
§ 23-2.02. Boards of visitors; bylaws.
The board of visitors of each public institution of higher education and the State Board for
Community Colleges shall adopt bylaws for its own governance. This document shall be posted
conspicuously on the board's website and shall include provisions that:
1. Establish the requirement of transparency, to the extent required by law, in all board actions;
2. Describe the board's obligations under the Virginia Freedom of Information Act (§ 2.2-3700
et seq.), as set forth in § 23-2:1, including the requirements that:
a. The board shall record minutes of each open meeting and post the minutes on the board's
website, in accordance with subsection I of § 2.2-3707 and § 2.2-3707.1;
b. Discussions and actions on any topic not specifically exempted by § 2.2-3711 shall be held in
an open meeting;
8
c. The board shall give public notice of all meetings, in accordance with subsection C of § 2.23707; and
d. Any official action taken in a closed meeting shall be approved in an open meeting before it
can have any force or effect, in accordance with subsection B of § 2.2-3711; and
3. Require that the board notify and invite the Attorney General's appointee or representative to
all meetings of the board, executive committee, and board committees.
§ 23-2.03. Boards of visitors; annual meeting with the president of the institution.
A. In addition to all meetings prescribed in Chapters 5 (§ 23-39 et seq.) through 16 (§ 23-214 et
seq.), the board of visitors of each public institution of higher education and the State Board for
Community Colleges shall meet with the president of that institution at least once annually, in a
closed meeting pursuant to subdivision A 1 of § 2.2-3711, and deliver an evaluation of the
president's performance.
B. Any change to the president's employment contract during any such meeting or any other
meeting of the board shall be made only by a vote of the majority of the board's members.
§ 23-2.04. Boards of visitors; executive committee.
The executive committee of the board of visitors of each public institution of higher education
and the State Board for Community Colleges shall (i) organize the working processes of the
board and (ii) recommend best practices for board governance.
The committee shall:
1. Develop and recommend to the board a statement of governance setting out the board's role;
2. Periodically review the board's bylaws and recommend amendments;
3. Provide advice to the board on committee structure, appointments, and meetings;
4. Develop an orientation and continuing education process for visitors that includes training on
the Virginia Freedom of Information Act (§ 2.2-3700 et seq.);
5. Create, monitor, oversee, and review compliance with a code of ethics for visitors; and
6. Develop a set of qualifications and competencies for membership on the board for approval by
the board and recommendation to the Governor.
§ 23-2.05. Boards of Visitors; annual executive summaries.
The board of visitors of each public institution of higher education and the State Board for
Community Colleges shall submit to the General Assembly and the Governor an annual
executive summary of its interim activity and work no later than the first day of each regular
9
session of the General Assembly. The executive summary shall be submitted as provided in the
procedures of the Division of Legislative Automated Systems for the processing of legislative
documents and reports and shall be posted on the General Assembly's website.
DISCUSSION: The proposed resolution addresses all of the new
legislative requirements that were not already included in the
Manual except two: an annual closed meeting of the Board with
the president to deliver an evaluation of the president’s
performance, and the annual reporting requirement. A separate
resolution amending the presidential evaluation policy will
cover the first requirement, and the Board Office will handle
the reporting as it does with other legislatively mandated
reporting requirements concerning Board activities.
ACTION REQUIRED:
Approval by the Board of Visitors
REVISIONS TO THE MANUAL OF THE BOARD OF VISITORS OF THE
UNIVERSITY OF VIRGINIA
RESOLVED, the Board of Visitors authorizes the attached
revisions (Attachment A) to the Manual of the Board of Visitors
of the University of Virginia, 2004 edition as amended through
November 9, 2012 (the Manual), to conform the provisions of the
Manual to the Code of Virginia, specifically § 23-2.01 through §
23-2.05, effective July 1, 2013.
10
UNIVERSITY OF VIRGINIA
BOARD OF VISITORS AGENDA ITEM SUMMARY
BOARD MEETING:
August 2, 2013
COMMITTEE:
Full Board
AGENDA ITEM:
I.C. Revisions to the Policy on Presidential
Evaluation
BACKGROUND: Legislation enacted by the General Assembly and
effective July 1, 2013, (Code of Virginia §23-2.03) requires the
board of visitors of all institutions of higher education to
meet with the president of the institution “at least once
annually in a closed meeting pursuant to subdivision A 1 of
§ 2.2-3711, and deliver an evaluation of the president's
performance.”
The presidential evaluation policy adopted by
the Board in 2011 does not contain this specific requirement.
In addition, the presidential evaluation policy should
explain the process for evaluating the president with sufficient
specificity to be consistent from year-to-year, and the
assessment committee should be representative of the Board
membership as a whole.
DISCUSSION: The proposed resolution addresses the new
legislative requirement and provides a timeline and process for
the evaluation. It also expands the assessment committee to six
members, the Board’s executive committee, rather than the threemember assessment committee included in the current policy.
ACTION REQUIRED:
Approval by the Board of Visitors
AMENDED POLICY ON ANNUAL PRESIDENTIAL EVALUATION
WHEREAS, the Board of Visitors in November 2011 adopted
guidelines for annually evaluating the President; and
WHEREAS, the annual performance assessment is an important
tool for monitoring the institution’s progress in meeting its
strategic goals and for integrating leadership activities with
such goals and with emerging external issues, and is intended to
clarify and communicate the Board’s expectations and level of
satisfaction regarding the President’s performance; and
WHEREAS, in order to assure that the annual evaluation is
consistently conducted in an effective fashion, the Board
11
desires to institute and adopt a systematic and formal method of
conducting the evaluation of the President; and
WHEREAS, Section 23-2.03 of the Code of Virginia requires
an annual meeting with the president in closed session for the
purpose of delivering an evaluation of the president’s
performance;
RESOLVED, the Board of Visitors adopts the following
process to guide its annual evaluation and potential renewal of
the President's contract:
1. Annually in the fall, but no later than October 15, the
Rector shall solicit the self-evaluation of the President for
the fiscal year ending the previous June 30, and the President’s
goals for the current fiscal year. The self-evaluation shall be
in the form of a narrative reviewing progress on the mutually
agreed-upon goals for the previous year.
2. Concurrent with the transmittal of the self-evaluation, the
President shall provide to the Rector a full accounting of all
earned outside income for the previous calendar year, and all
anticipated earned outside income for the current calendar year,
from service on boards of directors and any other source, as
required by the Commonwealth's annual budget act, and shall
additionally provide any other accounting required by the Board
Manual, the President's contract, or other applicable source.
3. The Executive Committee of the Board of Visitors shall serve
as the Assessment Committee to evaluate the President.
4. The Rector shall distribute the President’s self-evaluation
and goals to every member of the Board for their review. Each
Board member shall have an opportunity to provide his or her
observations and counsel regarding the self-evaluation and goals
of the President, in writing, to the Rector, or if preferred,
another member of the Assessment Committee by completing an
evaluation in a form similar to the one attached to this policy.
The Assessment Committee shall then review the Board input,
develop a written evaluation, and send the draft evaluation and
goals to the President and Board members. The draft evaluation
and goals shall be considered part of the President's
confidential personnel record.
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5.
At the late fall regular meeting of the Board, the Board
shall meet, in closed session, to review the evaluation and
goals with the President, and to gain the President’s input. The
Assessment Committee shall also formulate a recommendation to
the full Board regarding any compensation adjustments.
6.
Following the meeting with the President, the Assessment
Committee shall finalize the evaluation, and a set of goals for
the current fiscal year and the future that are mutually agreed
on by the President and the Board, and send the final evaluation
and goals to the President and Board members. The final
evaluation and goals shall be considered part of the President’s
confidential personnel record.
7.
If the Board is considering contract renewal, it may seek
and consider input from key University constituencies (including
faculty), in which case such input shall be considered part of
the President’s confidential personnel record.
Meetings of the Board and the Assessment Committee shall be
coordinated through the Secretary to the Board.
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ANNUAL APPRAISAL OF THE PRESIDENT’S
PERFORMANCE AND EFFECTIVENESS
UNIVERSITY OF VIRGINIA
INSTRUCTIONS: Please rate the President on the following aspects of performance.
BOARD OF VISITORS RELATIONS
•
•
Disseminates adequate and accurate information to the BOV in a timely manner.
☐ Poor
☐ Fair
☐ Good
☐ Excellent
☐ Not Observed
Enjoys a positive overall relationship with the BOV.
☐ Poor
☐ Fair
☐ Good
☐ Excellent
☐ Not Observed
INSTITUTIONAL LEADERSHIP/MANAGEMENT
•
•
•
•
•
•
Has assembled a strong leadership team.
☐ Poor
☐ Fair
☐ Good
☐ Excellent
☐ Not Observed
Advances the mission of the University.
☐ Poor
☐ Fair
☐ Good
☐ Excellent
☐ Not Observed
Assures quality academic and support programs.
☐ Poor
☐ Fair
☐ Good
☐ Excellent
☐ Not Observed
Operates the University with a commitment to strategic planning, goal setting and
evaluation.
☐ Poor
☐ Fair
☐ Good
☐ Excellent
☐ Not Observed
Manages resources proficiently.
☐ Poor
☐ Fair
☐ Good
☐ Excellent
☐ Not Observed
Has established a pattern of success in achieving goals.
☐ Poor
☐ Fair
☐ Good
☐ Excellent
☐ Not Observed
EXTERNAL RELATIONS
•
•
•
•
•
Effectively and enthusiastically advocates for the University.
☐ Poor
☐ Fair
☐ Good
☐ Excellent
☐ Not Observed
Effectively presents the University’s resource needs to government officials and private
contributors.
☐ Poor
☐ Fair
☐ Good
☐ Excellent
☐ Not Observed
Appreciates the need for institutional accountability.
☐ Poor
☐ Fair
☐ Good
☐ Excellent
☐ Not Observed
Relates well with alumni, parents, and donors.
☐ Poor
☐ Fair
☐ Good
☐ Excellent
☐ Not Observed
Represents the University in national higher education organizations.
☐ Poor
☐ Fair
☐ Good
☐ Excellent
☐ Not Observed
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RELATIONSHIPS
•
•
•
•
Enjoys a positive relationship with local community leaders.
☐ Poor
☐ Fair
☐ Good
☐ Excellent
☐ Not Observed
Maintains a positive relationship with the faculty and staff.
☐ Poor
☐ Fair
☐ Good
☐ Excellent
☐ Not Observed
Maintains a positive relationship with students.
☐ Poor
☐ Fair
☐ Good
☐ Excellent
☐ Not Observed
Maintains an effective relationship with legislators and their staff and with executive
branch senior management.
☐ Poor
☐ Fair
☐ Good
☐ Excellent
☐ Not Observed
PERSONALITY TRAITS
•
•
•
•
•
•
•
•
Poised under pressure.
☐ Poor
☐ Fair
Communicates effectively.
☐ Poor
☐ Fair
Integrity.
☐ Poor
☐ Fair
Energy.
☐ Poor
☐ Fair
Forward-looking.
☐ Poor
☐ Fair
Skillful in relating to others.
☐ Poor
☐ Fair
Respected.
☐ Poor
☐ Fair
Deliberate decision-maker.
☐ Poor
☐ Fair
☐ Good
☐ Excellent
☐ Not Observed
☐ Good
☐ Excellent
☐ Not Observed
☐ Good
☐ Excellent
☐ Not Observed
☐ Good
☐ Excellent
☐ Not Observed
☐ Good
☐ Excellent
☐ Not Observed
☐ Good
☐ Excellent
☐ Not Observed
☐ Good
☐ Excellent
☐ Not Observed
☐ Good
☐ Excellent
☐ Not Observed
PLEASE COMMENT ON ANY ASPECT OF THE PRESIDENT’S PERFORMANCE
AND EFFECTIVENESS:
15
Attachment A
REVISIONS TO THE BOARD MANUAL
Attachment A
2
Attachment A
3
Attachment A
4
Attachment A
5
Attachment A
6
Attachment A
7
Attachment A
8
Attachment A
9
Attachment A
10