duties. Willful interference is the only source of potential conflict of interest that the act categorizes as unlawful activity.

The committee reviewed conflicts of interest in the context of three conceptual variations: conflicts of loyalty, conflicts of commitment, and conflicts of control. These address issues of judgment and objectivity, time and attention, and independence, respectively.

Concern over conflicts of interest are justifiable given the multiple forces and incentives that influence the behavior and decision making of the many individuals and entities with whom the ombudsman interacts. To address the conflicts of interest problems that the committee judged to exist, it suggested four recommendations.



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