AAU Workshop: Governance of Universities Accra,
Description: AAU Workshop: Governance of Universities Accra, Ghana Dec 2015 Our programme (final programme will be distributed closer to the date) Some key concepts Institutional autonomy Academic freedom Accountability Authority Responsibility
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slide1. AAU Workshop: Governance of Universities Accra, Ghana
Dec 2015<br>
slide2. Our programme (final programme will be distributed closer to the date)<br>
slide4. Some key concepts Institutional autonomy
Academic freedom
Accountability
Authority
Responsibility
Transparency
Alignment
Governance
Access
Relevance
Quality
Success
Optimal M-E-I flow<br>
slide5. Corporate Governance – a definition The system by which corporate entities:
exercising accountability to shareowners and responsibility to stakeholders
are directed and controlled to achieve sustainable improvement in shareowner prosperity
(KPMG)<br>
slide6. Key considerations for HEIs Can HEIs be classified as ‘corporate entities?
Who are their key shareowners?
How does the goal of shareowner prosperity applies to HEIs?
Is governance in its most fundamental form different to an appropriate ‘enlightened self-interest’?
Does sound HEI governance build on the principles of Integral theory?<br>
slide7. (Epistemology) Expansiveness/inclusive shareholders/stakeholders perspective Expansiveness of HEI’s worldview Ontological levels of behavior<br>
slide8. Governance: a multi-element perspective<br>
slide9. Governance: Multi-element definition<br>
slide10. Governance: Systemic perspective The ‘why is’ question
The ‘how well is’ question
The ‘what is’ question
The ‘how is’ question (dynamic multi-directional MEI flow – M= flow of matter, E= flow of energy (normative and strategic leadership), I= flow of information)<br>
slide11. (Rothhaermel, 2013) Sound governance: a prerequisite for Sustainable Competitive Advantage<br>
slide12. University, Organization, Governance and Competitiveness (PPT 10-12: Lombardi, Craig, Capaldi & Gater, Aug 2002))PP Community engagement<br>
slide13. Embedded in a broader institutional context…. (Lombardi, Craig, Capaldi & Gater, Aug 2002)<br>
slide14. Institution embedded in macro systems context M E I<br>
slide15. At the heart of it all: ensure sustained composite quality<br>
slide16. Fundamental The dynamic tension between institutional autonomy and academic freedom
Where is the tipping point: is it benefiting to and rewarding for society to allow HEI institutions to govern themselves and to decide on the central questions:
Who to teach
What to teach
How to teach
When to teach
(based on SASCO Discussion document, 2009)<br>
slide17. Institutional autonomy High degree of self –regulation and administrative independence with respect to:
student admissions, curriculum, methods of teaching & assessment,
research, establishment of academic regulations and
the internal management of resources generated from private and public sources
(Higher Education White Paper, 1997)<br>
slide18. Institutional Autonomy implies… Freedom of government regulation iro:
Internal organization
Its governance
Internal management of financial resources
In generation of income from non-public sources
Recruitment and appointment of its staff
Conditions of study
Its teaching and research
Summarized: HEI’s should be autonomous from government and political control
Question: Autonomy from business, donors, sponsors and other sectors of society? (Higher Education White Paper, 1997)<br>
slide19. Institutional autonomy implies.. HEIs should be accountable to society at large – society: totality of such sectors and sections as communities, business, labour, government, church, social movements and other organized forms
Warning: High level of institutional autonomy not necessarily a guarantee for high level of academic freedom (Higher Education White Paper, 1997)<br>
slide20. Academic Freedom Freedom of teachers, students and academic institutions to pursue knowledge wherever it may lead, without undue or unreasonable interference. As a minimum, freedom to:
Engage in the entire range of activities iro production, of knowledge
Choosing a research focus
Determining what to teach in the class room
Presenting research findings to colleagues
Publishing research findings<br>
slide21. Prerequisites for Academic Freedom Recognizing intellectual independence means protection of students and faculty from imposition of political, religious or ideological nature
Preventing academics from ‘taking unfair advantage of students’
Promoting inquisition of the knowledge system
Forbidding indoctrination of any kind (Higher Education White Paper, 1997)<br>
slide22. State and Academic Freedom President Kwame Nkrumah: ‘ if reforms do not come from within, we intend to impose them from outside and no resort to the cry of academic freedom …is going to restrain us from seeing that our university is a healthy university devoted to Ghanaian interests’ (Higher Education White Paper, 1997)<br>
slide23. State and Academic Freedom President Robert Mugabe: ‘Higher education is too important a business to be left entirely to deans, professors, lecturers and university administrations’
Assumption: Governments and states legitimately acting on behalf and in interest of society as a whole (Higher Education White Paper, 1997)<br>
slide24. Two of the key actors: The University Council and the VC The VC The Chairperson of Council/Council Systems challenge: as key enabler for appropriate governance – how to optimize multi-directional MEI-flow between Council and VC MEI: M = flow of matter (resources); E= flow of normative oversight; I = flow of appropriate and constant levels of information<br>
slide25. Panel discussion: VCs How do VCs view their role in context of the University Council
What do they consider as major positive attributes of their interaction with Council
What do they consider as major challenges iro their interaction with Council<br>
slide26. From previous panel discussions… CoC is VCs immediate line manager
VC – the prime example of servant leadership
VC’s legislative empowerment – need for sound delegation without abdication
VC’s total: accountability as outlined by the relevant legislation
Principles of entrustment, total transparency and honesty, ongoing dialogue,
Need for consultative partnership<br>
slide27. Challenges: balancing act, council members with vested interests, uninformed council members, clear demarcation of roles, micro management, VC reducing Council to ‘rubber stamping’, Politics, triangulation,
VC on the anvil between Council and rest of University community?
Clarity: Roles, rights and obligations as stipulated by law
Council members serving on University Committees?
Alignment: Institutional Vision and VCs vision, envisioning of Council members
Context very important: Public vs private universities From previous panel discussions…<br>
slide28. Role and function of the VC To develop and recommend to the Council the strategy and vision for the HEI
Develop and recommend to the Council annual business plans and budgets
To achieve the HEI’s systemic goals and objectives and to ensure sound operational management of the HEI
To ensure the sustainable competitive position of the HEI
Ensure that the HEI has an effective management team
Formulate and oversee implementation of major corporate policies
The chief public persona of the HEI<br>
slide29. How HEI leader is appointed<br>
slide30. Appointment: Leaders of HEI’s<br>
slide31. The HEI’s Council as the pivotal governance structure Ultimately responsible and accountable* for:
ensuring that the HEI is sustainable
that it fulfills its accountability to society.
finally accountable for full and effective regulation of the HEI
therefore it must direct and regulate the VC and his/her management team
and ensure that it is involved in all material decisions affecting the HEI
* Also in terms of the country’s relevant laws, statutes<br>
slide32. Panel discussion: CoC’s and Councils How do CoC’s view their role relevant to that of the VC and his/her management team
What do they consider as major positive attributes of their interaction with the VC and his/her management team
What do they consider as major challenges iro their interaction with the VC and his/her management team<br>
slide33. Generic Governance issues Council relationships with Management The roles that the VC and executive level managers should play as members of university councils
How best to balance the shared responsibility for executive manager development between the Council and the VC
How to gain the insights of other senior managers at the HEI as advice and inputs for the Council
How to ensure Council’s unfettered access to management
How to expand non-executive Council members’ insight re the HEI’s operations, culture and climate<br>
slide34. Generic Governance issues Council relationships with Management Monitoring and overseeing VC and executive management:
Reliable and timely system of performance management
Establishing appropriate level of detail to be provided
To consider both short and longer-term performance
To avoid VC and executive management domination of Council discussions
How to gain direct information from managers reporting to VC and executive level managers<br>
slide35. Role and function of the Chairperson of Council Providing overall leadership to the Council
Actively participating in selection of Council members (is this possible?)
Arrange appropriate induction of new Council members
Monitoring and evaluating Council’s performance
In conjunction with VC and Registrar, developing annual work plan for Council
Main information link between Council and VC/management<br>
slide36. Enough time for discussion at Council meetings
Maintaining, in conjunction with VC, sound relationships with key HEI stakeholders
Ensuring that all Council members play a constructive role in the affairs of the HEI
Ensure that the Council receive timeous and relevant info in order to be able to make informed decisions Role and function of the Chairperson of Council<br>
slide37. CoC Panel discussion Synergistic value adding partnership
Council approved decisions providing umbrella of security for VC
Intimate knowledge of University conducive to good interrelationships
Prerequisite to maintain your independence and not to be co-opted
Council members ‘opening doors’ for Fundraising
Length of term of membership
Avoid dangers of triangulation
Promote Council stability – change of government not necessarily affects composition of Council<br>
slide38. VC: ‘one leg raised, two bags packed’
Pre-work via Committees of Council
Relevant, nimble footed, treat University as a business
Regulatory/ legislative framework – know your sources and understand your duties, rights and obligations as well as accountabilities with legal implications
Beware the governance tripod
Council – mainly normative and strategic, but with situational approach
Council’s role iro Common Law (good faith and care) as well as the moral imperative (acting in interest of the country) CoC Panel discussion<br>
slide39. Two approaches to tackle the problems of higher education institutions’ governance in Africa
It consists of rationalizing, valorizing and modernizing both the university foundations and their various systems of functioning
It supposes to put on better the whole university structure : better management, transparency in the decision-making and the participation of all actors in the decision-making
The second approach of governance fundamentally questions efficiency of systems of functioning of universities, too much centered on the hierarchical authority of the State, and on that of the university and academic administration, whether it is to define the financing, programs, the qualifications and even the courses of training
The governance of higher education will succeed only if it allows creating a common space of meeting between the actors : political, socioeconomic, students, teaching and civil society. (www.ipagu.org) AUF-ACU Partnership: on Governance<br>
slide40. Some viewpoints… Moodie & Eustace, 1974 Jarrat Report, CVPC, 1985<br>
slide41. Some more viewpoints…. (Shattock, July 2002)<br>
slide42. And some more…<br>
slide43. (Shattock, July 2002) On Shared governance<br>
slide44. Questions to consider Creating a common space where the various actors in governance can work concurrently on optimal governance of the HEI
To have a ‘meeting of the minds’/perceptions of the various actors
To consistently strive for optimal value adding by all of the actors
To get the balance right: maintaining a dynamic creative tension between academics (Senate?) and the Council
Locus of improprieties – breakdown between Governing Bodies and HEI executives (it can be be very toxic and extremely detrimental to the HEI) – how do we avoid this?
How do we enhance a positive dialogue between the Governing Body and academia – are Academia fit for this purpose (structure, composition, its strategic agenda, etc). What can the VC do in this regard?
How do we utilize the best of the corporate as well as collegial approach in a shared governance model for the HEI (sustained by a shared common purpose for the HEI) Is there still room for a collegial approach that underpins appropriate governance of a 21st century HEI?<br>
slide45. Understanding the Governance Iceberg Symptomatic challenges Fundamental root causes<br>
slide46. Small Group assignment with feedback in plenary sessions What do your group consider as the fundamental root causes of governance challenges experienced between the Governing body and the University’s VC/ executive management team
What are your max 5 recommendations to, in a systemic manner effectively treat these root causes<br>
slide47. Group feedback Each group to appoint a spokesperson
Spokesperson to do a max 10 min presentation on root causes as identified by the group as well as on recommended systemic treatment of these root causes
Group presentations will be followed by open discussion in plenary session<br>
slide48. Conclusions/summaries from previous workshop Highlighted the pivotal roles of the Chairperson of Council and the VC
Notion that their leadership should be :
both output (task) and people orientated
Should be anchored and empowered both in the legislative, regulatory ‘sources’ as well by a strong moral compass focused on the systemic positioning of the HEI as ‘good, truthful, wealth creating and aesthetically pleasing’
The behavior of all the actors should be in terms of shared values, with strict application of Codes of Conduct
The principle of concurrent involvement
The strong need for effective and efficient Council Committees
Composition and skills diversity extremely important
Council included in joint strategy sessions<br>
slide49. Understanding the HEI’s unique business model as a guideline for appropriate Governance<br>
slide50. Shareholder/stakeholder pointers for systemic corporate governance Government
Students
Staff
Council
Alumni
Communities
Donors
Sponsors<br>
slide51. The World Bank, March 2008<br>
slide52. Governance models on a continuum from control to autonomy<br>
slide53. HEI’s: How much autonomy?<br>
slide54. Governance: Life-cycle related stages of Quality Control by the State with respect to Public Universities<br>
slide55. Governance: State and HEI’s – different approaches to financial control iro various elements of control<br>
slide56. Governance: Property usage/ property transfer to HE’s – public universities<br>
slide57. Institutional autonomy<br>
slide58. (OECD,2003) Autonomy of HEI’s<br>
Dec 2015<br>
slide2. Our programme (final programme will be distributed closer to the date)<br>
slide4. Some key concepts Institutional autonomy
Academic freedom
Accountability
Authority
Responsibility
Transparency
Alignment
Governance
Access
Relevance
Quality
Success
Optimal M-E-I flow<br>
slide5. Corporate Governance – a definition The system by which corporate entities:
exercising accountability to shareowners and responsibility to stakeholders
are directed and controlled to achieve sustainable improvement in shareowner prosperity
(KPMG)<br>
slide6. Key considerations for HEIs Can HEIs be classified as ‘corporate entities?
Who are their key shareowners?
How does the goal of shareowner prosperity applies to HEIs?
Is governance in its most fundamental form different to an appropriate ‘enlightened self-interest’?
Does sound HEI governance build on the principles of Integral theory?<br>
slide7. (Epistemology) Expansiveness/inclusive shareholders/stakeholders perspective Expansiveness of HEI’s worldview Ontological levels of behavior<br>
slide8. Governance: a multi-element perspective<br>
slide9. Governance: Multi-element definition<br>
slide10. Governance: Systemic perspective The ‘why is’ question
The ‘how well is’ question
The ‘what is’ question
The ‘how is’ question (dynamic multi-directional MEI flow – M= flow of matter, E= flow of energy (normative and strategic leadership), I= flow of information)<br>
slide11. (Rothhaermel, 2013) Sound governance: a prerequisite for Sustainable Competitive Advantage<br>
slide12. University, Organization, Governance and Competitiveness (PPT 10-12: Lombardi, Craig, Capaldi & Gater, Aug 2002))PP Community engagement<br>
slide13. Embedded in a broader institutional context…. (Lombardi, Craig, Capaldi & Gater, Aug 2002)<br>
slide14. Institution embedded in macro systems context M E I<br>
slide15. At the heart of it all: ensure sustained composite quality<br>
slide16. Fundamental The dynamic tension between institutional autonomy and academic freedom
Where is the tipping point: is it benefiting to and rewarding for society to allow HEI institutions to govern themselves and to decide on the central questions:
Who to teach
What to teach
How to teach
When to teach
(based on SASCO Discussion document, 2009)<br>
slide17. Institutional autonomy High degree of self –regulation and administrative independence with respect to:
student admissions, curriculum, methods of teaching & assessment,
research, establishment of academic regulations and
the internal management of resources generated from private and public sources
(Higher Education White Paper, 1997)<br>
slide18. Institutional Autonomy implies… Freedom of government regulation iro:
Internal organization
Its governance
Internal management of financial resources
In generation of income from non-public sources
Recruitment and appointment of its staff
Conditions of study
Its teaching and research
Summarized: HEI’s should be autonomous from government and political control
Question: Autonomy from business, donors, sponsors and other sectors of society? (Higher Education White Paper, 1997)<br>
slide19. Institutional autonomy implies.. HEIs should be accountable to society at large – society: totality of such sectors and sections as communities, business, labour, government, church, social movements and other organized forms
Warning: High level of institutional autonomy not necessarily a guarantee for high level of academic freedom (Higher Education White Paper, 1997)<br>
slide20. Academic Freedom Freedom of teachers, students and academic institutions to pursue knowledge wherever it may lead, without undue or unreasonable interference. As a minimum, freedom to:
Engage in the entire range of activities iro production, of knowledge
Choosing a research focus
Determining what to teach in the class room
Presenting research findings to colleagues
Publishing research findings<br>
slide21. Prerequisites for Academic Freedom Recognizing intellectual independence means protection of students and faculty from imposition of political, religious or ideological nature
Preventing academics from ‘taking unfair advantage of students’
Promoting inquisition of the knowledge system
Forbidding indoctrination of any kind (Higher Education White Paper, 1997)<br>
slide22. State and Academic Freedom President Kwame Nkrumah: ‘ if reforms do not come from within, we intend to impose them from outside and no resort to the cry of academic freedom …is going to restrain us from seeing that our university is a healthy university devoted to Ghanaian interests’ (Higher Education White Paper, 1997)<br>
slide23. State and Academic Freedom President Robert Mugabe: ‘Higher education is too important a business to be left entirely to deans, professors, lecturers and university administrations’
Assumption: Governments and states legitimately acting on behalf and in interest of society as a whole (Higher Education White Paper, 1997)<br>
slide24. Two of the key actors: The University Council and the VC The VC The Chairperson of Council/Council Systems challenge: as key enabler for appropriate governance – how to optimize multi-directional MEI-flow between Council and VC MEI: M = flow of matter (resources); E= flow of normative oversight; I = flow of appropriate and constant levels of information<br>
slide25. Panel discussion: VCs How do VCs view their role in context of the University Council
What do they consider as major positive attributes of their interaction with Council
What do they consider as major challenges iro their interaction with Council<br>
slide26. From previous panel discussions… CoC is VCs immediate line manager
VC – the prime example of servant leadership
VC’s legislative empowerment – need for sound delegation without abdication
VC’s total: accountability as outlined by the relevant legislation
Principles of entrustment, total transparency and honesty, ongoing dialogue,
Need for consultative partnership<br>
slide27. Challenges: balancing act, council members with vested interests, uninformed council members, clear demarcation of roles, micro management, VC reducing Council to ‘rubber stamping’, Politics, triangulation,
VC on the anvil between Council and rest of University community?
Clarity: Roles, rights and obligations as stipulated by law
Council members serving on University Committees?
Alignment: Institutional Vision and VCs vision, envisioning of Council members
Context very important: Public vs private universities From previous panel discussions…<br>
slide28. Role and function of the VC To develop and recommend to the Council the strategy and vision for the HEI
Develop and recommend to the Council annual business plans and budgets
To achieve the HEI’s systemic goals and objectives and to ensure sound operational management of the HEI
To ensure the sustainable competitive position of the HEI
Ensure that the HEI has an effective management team
Formulate and oversee implementation of major corporate policies
The chief public persona of the HEI<br>
slide29. How HEI leader is appointed<br>
slide30. Appointment: Leaders of HEI’s<br>
slide31. The HEI’s Council as the pivotal governance structure Ultimately responsible and accountable* for:
ensuring that the HEI is sustainable
that it fulfills its accountability to society.
finally accountable for full and effective regulation of the HEI
therefore it must direct and regulate the VC and his/her management team
and ensure that it is involved in all material decisions affecting the HEI
* Also in terms of the country’s relevant laws, statutes<br>
slide32. Panel discussion: CoC’s and Councils How do CoC’s view their role relevant to that of the VC and his/her management team
What do they consider as major positive attributes of their interaction with the VC and his/her management team
What do they consider as major challenges iro their interaction with the VC and his/her management team<br>
slide33. Generic Governance issues Council relationships with Management The roles that the VC and executive level managers should play as members of university councils
How best to balance the shared responsibility for executive manager development between the Council and the VC
How to gain the insights of other senior managers at the HEI as advice and inputs for the Council
How to ensure Council’s unfettered access to management
How to expand non-executive Council members’ insight re the HEI’s operations, culture and climate<br>
slide34. Generic Governance issues Council relationships with Management Monitoring and overseeing VC and executive management:
Reliable and timely system of performance management
Establishing appropriate level of detail to be provided
To consider both short and longer-term performance
To avoid VC and executive management domination of Council discussions
How to gain direct information from managers reporting to VC and executive level managers<br>
slide35. Role and function of the Chairperson of Council Providing overall leadership to the Council
Actively participating in selection of Council members (is this possible?)
Arrange appropriate induction of new Council members
Monitoring and evaluating Council’s performance
In conjunction with VC and Registrar, developing annual work plan for Council
Main information link between Council and VC/management<br>
slide36. Enough time for discussion at Council meetings
Maintaining, in conjunction with VC, sound relationships with key HEI stakeholders
Ensuring that all Council members play a constructive role in the affairs of the HEI
Ensure that the Council receive timeous and relevant info in order to be able to make informed decisions Role and function of the Chairperson of Council<br>
slide37. CoC Panel discussion Synergistic value adding partnership
Council approved decisions providing umbrella of security for VC
Intimate knowledge of University conducive to good interrelationships
Prerequisite to maintain your independence and not to be co-opted
Council members ‘opening doors’ for Fundraising
Length of term of membership
Avoid dangers of triangulation
Promote Council stability – change of government not necessarily affects composition of Council<br>
slide38. VC: ‘one leg raised, two bags packed’
Pre-work via Committees of Council
Relevant, nimble footed, treat University as a business
Regulatory/ legislative framework – know your sources and understand your duties, rights and obligations as well as accountabilities with legal implications
Beware the governance tripod
Council – mainly normative and strategic, but with situational approach
Council’s role iro Common Law (good faith and care) as well as the moral imperative (acting in interest of the country) CoC Panel discussion<br>
slide39. Two approaches to tackle the problems of higher education institutions’ governance in Africa
It consists of rationalizing, valorizing and modernizing both the university foundations and their various systems of functioning
It supposes to put on better the whole university structure : better management, transparency in the decision-making and the participation of all actors in the decision-making
The second approach of governance fundamentally questions efficiency of systems of functioning of universities, too much centered on the hierarchical authority of the State, and on that of the university and academic administration, whether it is to define the financing, programs, the qualifications and even the courses of training
The governance of higher education will succeed only if it allows creating a common space of meeting between the actors : political, socioeconomic, students, teaching and civil society. (www.ipagu.org) AUF-ACU Partnership: on Governance<br>
slide40. Some viewpoints… Moodie & Eustace, 1974 Jarrat Report, CVPC, 1985<br>
slide41. Some more viewpoints…. (Shattock, July 2002)<br>
slide42. And some more…<br>
slide43. (Shattock, July 2002) On Shared governance<br>
slide44. Questions to consider Creating a common space where the various actors in governance can work concurrently on optimal governance of the HEI
To have a ‘meeting of the minds’/perceptions of the various actors
To consistently strive for optimal value adding by all of the actors
To get the balance right: maintaining a dynamic creative tension between academics (Senate?) and the Council
Locus of improprieties – breakdown between Governing Bodies and HEI executives (it can be be very toxic and extremely detrimental to the HEI) – how do we avoid this?
How do we enhance a positive dialogue between the Governing Body and academia – are Academia fit for this purpose (structure, composition, its strategic agenda, etc). What can the VC do in this regard?
How do we utilize the best of the corporate as well as collegial approach in a shared governance model for the HEI (sustained by a shared common purpose for the HEI) Is there still room for a collegial approach that underpins appropriate governance of a 21st century HEI?<br>
slide45. Understanding the Governance Iceberg Symptomatic challenges Fundamental root causes<br>
slide46. Small Group assignment with feedback in plenary sessions What do your group consider as the fundamental root causes of governance challenges experienced between the Governing body and the University’s VC/ executive management team
What are your max 5 recommendations to, in a systemic manner effectively treat these root causes<br>
slide47. Group feedback Each group to appoint a spokesperson
Spokesperson to do a max 10 min presentation on root causes as identified by the group as well as on recommended systemic treatment of these root causes
Group presentations will be followed by open discussion in plenary session<br>
slide48. Conclusions/summaries from previous workshop Highlighted the pivotal roles of the Chairperson of Council and the VC
Notion that their leadership should be :
both output (task) and people orientated
Should be anchored and empowered both in the legislative, regulatory ‘sources’ as well by a strong moral compass focused on the systemic positioning of the HEI as ‘good, truthful, wealth creating and aesthetically pleasing’
The behavior of all the actors should be in terms of shared values, with strict application of Codes of Conduct
The principle of concurrent involvement
The strong need for effective and efficient Council Committees
Composition and skills diversity extremely important
Council included in joint strategy sessions<br>
slide49. Understanding the HEI’s unique business model as a guideline for appropriate Governance<br>
slide50. Shareholder/stakeholder pointers for systemic corporate governance Government
Students
Staff
Council
Alumni
Communities
Donors
Sponsors<br>
slide51. The World Bank, March 2008<br>
slide52. Governance models on a continuum from control to autonomy<br>
slide53. HEI’s: How much autonomy?<br>
slide54. Governance: Life-cycle related stages of Quality Control by the State with respect to Public Universities<br>
slide55. Governance: State and HEI’s – different approaches to financial control iro various elements of control<br>
slide56. Governance: Property usage/ property transfer to HE’s – public universities<br>
slide57. Institutional autonomy<br>
slide58. (OECD,2003) Autonomy of HEI’s<br>