Executive Policy 12.211 Executive Policy 12.211

Policy for Responding to Allegations of Research and Scholarly Misconduct

Executive Policy Chapter 12, Research
Executive Policy EP 12.211, Policy for Responding to Allegations of Research and Scholarly Misconduct
Effective Date:  January 1, 2026
Prior Dates Amended: November 2021; August 2014; 2005; 1998; 1992; 1989
Responsible Office: Office of the Vice President for Research and Innovation
Governing Board of Regents Policy RP 12.201, Ethical Standards of Conduct
Review Date:  3-Year Review Cycle

Note: The University of Hawai‘i’s Interim Executive Policy (EP) 12.211 is a provisional policy to meet the University’s compliance obligations while it consults with various stakeholders, including the exclusive collective bargaining representatives of the University’s faculty and staff under HRS, Chapter 89

A.  The University of Hawai‘i (University or UH) is committed to fostering and maintaining a research environment that promotes research integrity and the trustworthiness of the University’s research enterprise throughout its campuses and research facilities. 

B.  As a recipient of Public Health Service (PHS) funds, the University is required to ensure that its research results are free from Research Misconduct defined as Fabrication, Falsification, and Plagiarism.  The UH Executive Policy (EP) 12.211 and Administrative Procedures (AP) 12.211 (collectively, this Policy) establish the framework for responding to Allegations of possible Research Misconduct in accordance with the Department of Health and Human Services’ Public Health Service Policies on Research Misconduct, 42 CFR part 93.

C.  Where allegations of Research Misconduct arise under the policies and procedures of other federal agencies, the University’s response will follow this Policy unless inconsistent with those of the particular agency.

D.  Broadly, the University appoints volunteer faculty and staff members to assist with Allegation Assessments and to serve on Review Panels to conduct Inquiries and Investigations in response to Allegations of Research Misconduct.  Where the peer review results in finds of research misconduct, these findings are reported to the University’s designated Deciding Official for final determination.  The findings of research misconduct may be accompanied by peer recommendations on remedying any significant departures from the accepted practices of the relevant research community.

E.  This Policy is not intended to replace management decisions or disciplinary matters that may be applicable under the relevant collective bargaining agreements.  Similarly, this Policy does not preempt other University policies concerning student instruction or conduct, even though the student may be involved in research activities.

A.  Accepted Practices of the Relevant Community means those practices established by 42 CFR part 93 and by PHS funding components, as well as commonly accepted professional codes or norms within the overarching community of researchers and institutions that apply for and receive PHS grants.  In cases involving Research Misconduct Allegations under other federal agencies, the commonly accepted practices, codes, or norms within the overarching community of researchers and institutions under the applicable federal policy will apply.  In cases involving academic and scholarly misconduct allegations, the accepted practices of the relevant scholarly community will apply.

B.  Administrative Action means an HHS action, consistent with § 93.407, taken in response to a Research Misconduct Proceeding to protect the health and safety of the public, to promote the integrity of (1) PHS supported biomedical or behavioral research, biomedical or behavioral research training, or activities related to that research or research training; (2) research supported by other federal agencies, governmental entities, or other extramural sources, or (3) to conserve public funds.

C.  Administrative Record comprises: the institutional record; any information provided by the Respondent in a Research Misconduct Proceeding under this policy or to the US ORI, including but not limited to the verbatim transcript of any meetings under § 93.403 between the Respondent and the US ORI, whether in person, by phone, or by videoconference, and correspondence between the Respondent and US ORI; any additional information provided to the US ORI while the case is pending before the US ORI; and any analysis or additional information generated or obtained by the US ORI.  Any analysis or additional information generated or obtained by the US ORI will also be made available to the Respondent.

D.  Allegation means a disclosure of possible Research Misconduct through any means of communication and brought directly to the attention of the Research Integrity Officer (RIO), other institutional officials, including Ethics Committee (EC) members, deans, equivalent executives, or HHS official.  The disclosure shall be submitted in writing to the RIO, together with supporting evidence.

E.  Assessment means a consideration by the RIO, in consultation with an EC Representative, of whether an Allegation of research misconduct appears to fall within the definition of Research Misconduct; appears to involve PHS-supported biomedical or behavioral research, biomedical or behavioral research training, or activities related to that research or research training; and is sufficiently credible and specific so that potential Evidence of Research Misconduct may be identified.  The Assessment only involves the review of readily accessible information relevant to the Allegation.

F.  Complainant means an individual, funding agency, or other entity who in Good Faith makes an Allegation of Research Misconduct.

G.  Conflict of Interest means a potential, perceived, or actual personal, professional, or financial relationship with the Complainant, Respondent, or witnesses that may reasonably call into question the fairness or objectivity of any institutional official responsible for managing or conducting the Research Misconduct Proceeding.

H.  Contract means an acquisition instrument awarded under the Federal Acquisition Regulation (FAR), 48 CFR chapter 1.

I.  Day means calendar day unless otherwise specified.  If a deadline falls on a Saturday, Sunday, Federal or State holiday, the deadline will be extended to the next day that is not a Saturday, Sunday, Federal or State holiday.

J.  Departmental Appeals Board or DAB means the organization, within the HHS Office of the Secretary, established to conduct hearings and provide impartial review of disputed decisions made by HHS operating components.

K.  Ethics Committee or EC means the standing committee of peer faculty and staff appointed by the DO and established to assist the University in Allegation Assessments and by serving on Review Panels to conduct Inquiries and Investigations, as needed.

L.  Ethics Committee Representative means an EC Co-Chair or senior EC member who assists the RIO.

M.  Evidence may include anything offered or obtained during a Research Misconduct Proceeding that tends to prove or disprove the existence of an alleged fact.  Evidence may include, but is not limited to, documents, whether in hard copy or electronic form, information, tangible items, testimony, equipment, and information in any form of media.

N.  Funding Component means any organizational unit of the PHS authorized to award grants, contracts, or cooperative agreements for any activity covered by this part involving research or research training; Funding Components may be agencies, bureaus, centers, institutes, divisions, offices, or other awarding units within the PHS.

O.  General Counsel means the Vice President for Legal Affairs and University General Counsel and their Associate General Counsel (OGC).  OGC represents the University and advises institutional officials responsible for managing or conducting the University’s evaluations of Research Misconduct Allegations as part of their official duties.  OGC does not represent the Respondent, Complainant, witnesses, or any other person participating during the Allegation Assessment, Inquiry, Investigation, or any follow-up action.

P.  Good Faith
    1.  Good Faith as applied to a Complainant or witness, means having a reasonable belief in the truth of one’s Allegation or testimony based on the information known to the Reporting Party or witness at the time.  An Allegation or cooperation with a Research Misconduct Proceeding is not in Good Faith if made with knowledge of or reckless disregard for information that would negate the Allegation or testimony.
    2.  Good Faith as applied to a Respondent or witness identified by the Respondent means having a belief in the truth of one’s testimony, evidence, or cooperation with the Research Misconduct Proceeding.  A Respondent or witness’ testimony, evidence, or cooperation is not in Good Faith if made with knowledge of or reckless disregard for information that would negate the testimony, evidence, or cooperation.
    3.  Good faith as applied to an institutional, EC , or Review Panel member means cooperating with the Research Misconduct Proceeding by impartially carrying out the duties assigned for the purpose of helping the University meet its responsibilities under this policy and 42 CFR part 93.  An institutional, EC, or Review Panel member does not act in Good Faith if their acts or omissions during the Research Misconduct Proceedings are dishonest or influenced by personal, professional, or financial conflicts of interest with those involved in the Research Misconduct Proceeding.

Q.  HHS means the United States Department of Health and Human Services.

R.  Informant means a person who wishes to remain anonymous and who informs the University (e.g., through the Ethics Committee, the RIO, or institutional official) of the possibility of research misconduct.

S.  Inquiry means preliminary information-gathering and preliminary fact-finding that meets the criteria and follows the procedures of this policy and where required by §§ 93.307 through 93.309.
Institution means any Person that applies for or receives PHS support for any activity or program that involves the conduct of biomedical or behavioral research, biomedical or behavioral research training, or activities related to that research or training.  This includes, but is not limited to, colleges and universities, PHS intramural biomedical or behavioral research laboratories, research and development centers, national user facilities, industrial laboratories or other research institutes, small research institutions, and independent researchers.

T.  Institution may also be defined by other Federal agencies, as applicable.

U.  Institutional Deciding Official or DO means the senior academic or research institutional official appointed by the University president who makes final determinations on Allegations of Research Misconduct and any institutional actions.  The same individual cannot serve as the Institutional Deciding Official and the Research Integrity Officer.

V.  Institutional Member means an individual (or individuals) who is employed by, is an agent of, or is affiliated by contract or agreement with the University, including employees of the Research Corporation of the University of Hawai‘i (RCUH).  Institutional Members may include, but are not limited to, executives and managerial personnel, officials, tenured and untenured faculty, teaching and support staff, researchers, research coordinators, technicians, postdoctoral and other fellows, students, volunteers, subject matter experts, consultants, or attorneys, or employees or agents of contractors, subcontractors, or sub-awardees.

W.  Institutional Record means the institutional record comprising of:
    1.  The records that the Review Panel compiled during the Research Misconduct Proceeding, except records the Review Panel did not consider or utilize.  The Institutional Record includes, but are not limited to:
        a.  Documentation of the Assessment;
        b.  If an Inquiry is conducted, the Inquiry report and all records (other than drafts of the report) considered or utilized during the Inquiry, including, but not limited to, Research Records and the transcripts of any interviews conducted during the Inquiry, information the Respondent provided to the Review Panel, and the documentation of any decision not to investigate;
        c.  If an Investigation is conducted, the Investigation Report and all records (other than drafts of the report) in support of that report, including, but not limited to, Research Records, the transcripts of each interview conducted and information the Respondent provided to the Review Panel;
        d.  Decision(s) by the DO, such as the written decision from the DO; and
        e.  The complete record of any proceeding involving institutional administrative actions.
    2.  A single index listing all the Research Records and Evidence that the Review Panel compiled during the Research Misconduct Proceedings except records the Review Panel did not consider or utilize.
    3.  A general description of the records that were sequestered but not considered or utilized.
    4.  The institutional record of the Research Misconduct Proceeding is retained for seven (7) years after the conclusion of the last phase of the Research Misconduct Proceeding, as applicable, including records of any proceeding involving institutional administrative actions.

X.  Intentionally, To act intentionally means to act with the aim of carrying out the act.

Y.  Investigation means the formal development of a factual record and the examination of that record by a Review Panel that meets the criteria and follows the procedures of this policy and where required §§ 93.310 through 93.317.

Z.  Knowingly. To act knowingly means to act with the awareness of the act.

AA.  Notice means a written or electronic communication served in person or sent by mail or its equivalent to the last known street address, facsimile number, or email address of the addressee.

BB.  Office of Research Integrity or US ORI means the office established by Public Health Service Act section 493 (42 U.S.C. 289b) and to which the HHS Secretary has delegated responsibility for addressing research integrity and misconduct issues related to PHS-supported activities.

CC.  Person means any individual, corporation, partnership, institution, association, unit of government, or other legal entity, however organized.

DD.  Policy means Executive Policy 12.211 and Administrative Procedures 12.211, as amended.

EE.  Public Health Service or PHS consists of the following components within the HHS: the Office of the Assistant Secretary for Health, the Office of Global Affairs, the Administration for Strategic Preparedness and Response, the Advanced Research Projects Agency for Health, the Agency for Healthcare Research and Quality, the Agency for Toxic Substances and Disease Registry, the Centers for Disease Control and Prevention, the Food and Drug Administration, the Health Resources and Services Administration, the Indian Health Service, the National Institutes of Health, the Substance Abuse and Mental Health Services Administration, and any other components of HHS designated or established as components of HHS designated or established as components of the Public Health Service.

FF.  PHS Support means PHS funding, or applications or proposals for PHS funding for biomedical or behavioral research, biomedical or behavioral research training, or activities related to that research or training that may be provided through: funding for PHS intramural research; PHS grants, cooperative agreements, or contracts, subawards, contracts, or subcontracts under those PHS funding instruments; or salary or other payments under PHS grants, cooperative agreements, or contracts.

GG.  Recklessly. To act recklessly means to propose, perform, or review research, or report research results, with indifference to a known risk of Fabrication, Falsification, or Plagiarism.

HH.  Research means a systematic experiment, study, evaluation, demonstration, or survey designed to develop or contribute to general knowledge (basic research) or specific knowledge (applied research) by establishing, discovering, developing, elucidating, or confirming information or underlying mechanisms related to biological causes, functions, or effects, diseases, treatment, or related matters to be studied.  This definition includes academic and scholarly works.

II.  Research Integrity Officer or RIO refers to the institutional official responsible for administering the University’s written policies and procedures for addressing allegations of Research Misconduct.  The RIO may also serve as the Institutional certifying official.

JJ.  Research Misconduct means Fabrication, Falsification, or Plagiarism (FFP) in proposing, performing, or reviewing research, or in reporting research results.  Research Misconduct does not include honest error or differences of opinion.
    1.  Fabrication means making up data or results and recording or reporting them.
    2.  Falsification means manipulating research materials, equipment, or processes, or changing or omitting data or results such that the research is not accurately represented in the Research Record.
    3.  Plagiarism means the appropriation of another person’s ideas, processes, results, or words without giving appropriate credit.
        a.  Plagiarism includes the unattributed verbatim or nearly verbatim copying of sentences and paragraphs from another’s work, which materially mislead the reader regarding the contributions of the author.  It does not include the limited use of identical or nearly-identical phrases which describe what is considered to be general knowledge or commonly-used methodology.
        b.  Plagiarism does not include self-plagiarism, authorship, or credit disputes including disputes among former collaborators who participated jointly in the development or conduct of a research project.  Self-plagiarism and authorship disputes do not meet the definition of Research Misconduct and are subject to procedures outlined in the Non-FFP Allegations section below.
    4.  Research Misconduct Allegations involving undergraduate or graduate students may be referred to the UH Office of Judicial Affairs, Graduate Division, department chairs, deans, directors, or equivalent executives, overseeing the academic unit where the Allegations arose to investigate and resolve unless the Allegations involve PHS support, support from non-PHS federal agencies, other government support, or support from extramural sources.

KK.  Research Misconduct Proceeding means any action related to alleged Research Misconduct taken under this policy, including Allegation Assessments, Inquiries, Investigations, US ORI oversight reviews.

LL.  Research Record means the record of data or results that embody the facts resulting from academic research, or scientific Inquiry that may reasonably be expected to provide Evidence or information that constitutes the subject of an Allegation of Research Misconduct.  Data or results may be physical or electronic form.  Examples of items, materials, or information that may be considered part of the Research Record include, but are not limited to, research proposals or applications (whether funded or unfunded), raw data, processed data, clinical Research Records, laboratory records, study records, laboratory notebooks, progress reports, manuscripts, abstracts, theses, records of oral presentations, notes, equipment use logs, laboratory procurement records, animal facility records, human and animal subject protocols, consent forms, medical charts, patient research files, correspondence, videos, photographs, X-ray film, slides, biological materials, online content, lab meetings reports, internal reports, journal articles, computer files and printouts, computer disks and diskettes, or any other written or non-written account or object.  The Research Record includes any communications, documents, or materials provided to the RIO, an EC member, Review Panel, or an institutional official during the course of a Research Misconduct Proceeding.

MM.  Respondent means the individual against whom an Allegation of Research Misconduct is directed and who is the subject of a Research Misconduct Proceeding.

NN.  Retaliation means an adverse action taken against a Complainant, witness, institutional official, Ethics Committee member; or Review Panel member by a University or one of its members in response to:
    1.  A Good Faith Allegation of Research Misconduct; or
    2.  Good Faith cooperation with a Research Misconduct Proceeding. 
Adverse action or hostile treatment includes, but are not limited to, the examples in EP 9.10 Workplace Non-Violence.

OO.  Review Panel means the panel of University faculty and staff, including subject matter experts from outside the Ethics Committee or the University where special qualifications, expertise, or experience is required, or where a conflict of interest exists, appointed by the RIO, in consultation with an EC Representative, whose members are qualified by practice and/or experience to conduct, support, or participate in the Research Misconduct Proceeding.  The same Review Panel members may be used for the Inquiry and Investigation.

PP.  University or UH means the University of Hawai‘i.

A.  Mandatory Review of Allegations involving FFP and PHS Support, Discretionary Non-FFP Allegations, and Concurrent Jurisdiction
    1.  Mandatory Review of FFP Allegations.
        a.  The University must investigate each Allegation of Research Misconduct that meets the PHS definition of Research Misconduct (FFP) and involves PHS support in a manner consistent with this policy and 42 CFR part 93.
        b.  If the Allegation involves both FFP and PHS support, the Allegation will have priority over any intertwined Allegation of misconduct defined in the non-FFP Allegations section, below.
        c.  If the Allegation of Research Misconduct involves research supported by another federal agency, the University must conduct the Research Misconduct Proceeding in accordance with this policy and the regulations of the sponsoring agency (e.g., National Science Foundation, Research Misconduct, 45 CFR part 689; National Aeronautics and Space Administration, Research Misconduct, 14 CFR part 1275).
        d.  If there is a conflict between this policy and applicable federal regulations, the federal regulations will apply and supersede any inconsistent provision of this policy.
        e.  A Research Misconduct Proceeding brought under this section may involve non-FFP Allegations or Allegations brough under other UH policies and procedures.  Where such circumstances occur, the Research Misconduct Proceeding under this policy will have priority and will not be precluded, delayed, or terminated by any collateral institutional proceedings that may arise.  These other collateral institutional proceedings will follow their respective institutional policies and procedures.

    2.  Discretionary Non-FFP Allegations.
        a.  The RIO will refer to the non-FFP Allegations, defined below, to the appropriate dean or equivalent executive overseeing the academic or research unit where the non-FFP Allegations arose to investigate and resolve.  The outcome of the investigation will be reported to the RIO in writing and provide a detailed rationale for the decision and any corrective action imposed, as appropriate, after the matter concludes.
        b.  The non-FFP Allegations may include, but are not limited to:
          (1)  Improprieties of Authorship, involves authorship disputes, including but not limited to, improper assignment of credit, such as excluding others who may qualify for authorship, misrepresentation of the same material as original in more than one publication, or the order of authorship.  Improprieties of authorship also include allowing oneself to be listed as an author when significant contributions have not been made commonly referred to as ghost authorship, gift authorship, guest authorship, honorary authorship, and rolling authorship.  Improprieties of authorship may include submission of multi-authored publications without the concurrence of all authors.
In the absence of department, journal, or discipline-specific-authorship guidelines, the International Committee of Medical Journal Editors (ICMJE) recommended criteria for “Who is an Author?” may be applied.
A finding of Improprieties of Authorship may be reported to the journal, editors, or sponsors, as appropriate.
          (2)  Violation of generally accepted research practices, including but not limited to, serious deviation from accepted practices in proposing or carrying out research; improper manipulation of experiments to obtain biased results; deceptive statistical or analytical manipulations; improper reporting of results; or failure to properly mentor those working under a PI (including post-doctoral researchers, graduate students, undergraduates, or other junior colleges).
Serious deviations from accepted practices are those that are committed negligently (rather than Intentionally, Knowingly, or Recklessly) but do not rise to the level of Research Misconduct.  In order to constitute serious research error, there must be a finding, by a Preponderance of the Evidence, that the conduct represents a significant deviation from accepted practices AND that it was committed negligently.
          (3)  Deliberate material misrepresentation of qualifications, experience, or research accomplishments to advance a research program, to obtain external funding, or to attain professional advancement.
          (4)  Conduct that violates research and scholarly-related ethical standards as expressed in relevant codes of conduct promulgated by professional associations and learned societies within the various disciplines.
        c.  The RIO, in consultation with an EC Representative, reserves the right to exercise jurisdiction over non-FFP Allegations if PHS support, support from non-PHS federal agencies, other governmental support, or support from other extramural sources, are involved.  If the RIO commences a proceeding involving non-FFP Allegations, the RIO may adapt and apply the procedural requirements under this policy.
        d.  A finding of misconduct involving FFP-only and non-FFP Allegations is final and binding within the University.

    3.  Referral to Other University Offices with Concurrent Jurisdiction.
        a.  The RIO may refer additional non-FFP Allegations not defined in this policy to other University offices that may have specific jurisdiction for investigation and resolution, as appropriate, without prejudice to the RIO assuming jurisdiction as may be warranted by the facts and circumstances of the specific matter.
        b.  The RIO may coordinate Investigations of non-FFP Allegations with other UH offices with concurrent jurisdiction.  The RIO may initiate a Research Misconduct Proceeding in accordance with this policy regardless of the conduct or outcome of any collateral institutional proceeding initiated by other University offices.

B.  Scope of Review
    1.  This policy applies to all University executives and managerial personnel, faculty, researchers, and staff members including, without limitation, graduate and undergraduate students; postdoctoral fellows and postdoctoral research associates; visiting faculty or staff; faculty or staff on sabbatical leave; adjunct faculty when performing University work; faculty or staff on leave without pay; and research personnel employed by the RCUH.
        a.  This policy also applies if Research Misconduct is suspected to have been committed by a former University employee while employed by the University or former student while attending the University.
        b.  Allegations of Research Misconduct that occurred before or after the Respondent’s employment at the University or RCUH will be referred to the Respondent’s employer at the time the alleged Research Misconduct occurred.

    2.  Time limitations.
        a.  Six-year limitation.  This policy applies only to Allegations of Research Misconduct occurring within six (6) years of the date the University of HHS received the Allegations.
        b.  Exceptions to the six-year limitation.  Paragraph (a) of this section does not apply in the following instances.
          (1)  Subsequent use exception.  The Respondent continues or renews any incident of alleged Research Misconduct that occurred before the six-year limitation though the use of, republication of, or citation to the portion(s) of the Research Record (e.g. processed data, journal articles, funding proposals, data repositories) alleged to have been fabricated, falsified, or plagiarized, for the potential benefit of the Respondent.
              (i)  When the Respondent uses, republishes, or cites to the portion(s) of the Research Record that is alleged to have been fabricated, falsified, or plagiarized, in submitted or published manuscripts, submitted PHS grant applications, progress reports submitted to PHS funding components, posters, presentations, or other Research Records within six (6) years of when the Allegations were received by HHS or the University, this exception applies.
              (ii)  For Research Misconduct that appears subject to the subsequent use exception, the University must document their determination that the subsequent use exception does not apply.  Such documentation must be retained in accordance with this policy and § 93.318.
          (2)  Exception for the health or safety of the public.  If the University or the US ORI, following consultation with US ORI, determines that the alleged Research Misconduct, if it occurred, would possibly have a substantial adverse effect on the health or safety of the public, this exception applies.

C.  General Principles and Policies to Promote Research Integrity and Resolve Allegations of Research Misconduct.
    1.  Responsibility to Report Misconduct.
        a.  All Institutional Members should immediately report observed, suspected, or apparent Research Misconduct to the RIO, or other institutional official such as an EC member, department chair, dean or equivalent executive.  Any institutional official or EC member who receives an Allegation of Research Misconduct must report it immediately to the RIO.
        b.  If the person reporting the Allegation of Research Misconduct is unsure whether a suspected incident falls within the definition of Research Misconduct, the person may informally discuss the suspected Research Misconduct with the RIO, which may include discussing the suspected Research Misconduct anonymously and/or hypothetically.  If the circumstances described by the person do not meet the definition of Research Misconduct, the RIO will refer the person or the Allegation to the other University offices or officials with responsibility for resolving the problem, as appropriate.  The RIO may also refer the person or the Allegation to external offices, including for example, the Hawai‘i State Ethics Commission.

    2.  Cooperation with Research Misconduct Proceedings.
        a.  Institutional Members have a responsibility to cooperate with the RIO and other institutional officials in the review of an Allegation and the conduct of the Assessment, Inquiry, and Investigation.
        b.  Institutional Members, including the Respondent, have an obligation to provide Evidence relevant to the Assessment, Inquiry, and Investigation of an Allegation to the RIO, EC representative, Review Panel, or to other institutional officials.

The University of Hawai‘i’s Vice President for Research and Innovation is delegated authority to serve as the Deciding Official.

Office of the Vice President for Research and Innovation
Phone: (808) 956-5006
Email: uhrio@hawaii.edu

Public Health Service Policies on Research Misconduct, 42 CFR part 93
National Science Foundation Research Misconduct Policy, 45 CFR part 689
Regents Policy RP 12.201, Ethical Standards of Conduct.
Regents Policy RP 2.205, Policy on Whistleblowing and Retaliation
Administrative Procedures AP 12.211, Administrative Procedures for Responding to Allegations of Research and Scholarly Misconduct.
Executive Policy EP 1.206, Whistleblower and Retaliation Policy
Executive Policy EP 9.210, Workplace Non-Violence
Link to superseded UH Executive Policies in old format https://www.hawaii.edu/policy/archives/ep/
Link to UH Administrative Procedures in old format https://www.hawaii.edu/policy/archives/apm/sysap.php

No Exhibits and Appendices found

    President