P.O. Box 1209 
P.O. Box 1209 
Seattle, WA 98111-1209 
Seattle, WA 98111-1209 
Tel: 787-3000 
Tel: 206-787-3000 
www.portseattle.org 
www.portseattle.org 

August 28, 2012 

The Honorable Zack Hudgins 
Washington State House of Representatives 
Post Office Box 40600 
Olympia, WA 98504-0600 

Dear Representative Hudgins: 
The Port Commission appreciates the interest you have expressed in the Port of Seattle and it
shares your commitment to ensuring the port remains an institution worthy of the public's trust. 
As you are aware, over the last five years the commission has implemented broad and deep
reforms, one of which is a strengthened employee code of conduct and ethics policy. Be assured,
all commissioners are committed to ensuring these policies are followed. 
It is because of that commitment that we thank you for sharing the concern you expressed in
your letter dated August 24. As chair of the commission's Audit Committee, I am responding to
your letter on behalf of the Commission to clarify several points and correct a few others. 
First, allow me to clarify that as part of his employment contract approved publicly by the
commission on March 1, 2011 and posted on the port's website shortly thereafter, Mr. Yoshitani
may "on his own time (e.g., after close of business or while on Paid Time-Off), participate as a
member of a Board of Directors for a private entity; provided, that prior to accepting such
appointment, the Port's General Counsel determines that CEO's participation would not create or
appear to create a conflict of interest, or is contrary to any other provision of the Port's Code of
Ethics for Employees." Mr. Yoshitani's appointment to the board of directors of Expeditors
International was reviewed by the port's general counsel to ensure compliance with the port's
Code of Conduct for employees and for any potential conflict of interest before he joined the
board. The general counsel of Expeditors International has informed us that the appointment
was reviewed in accordance with its internal policies and the rules promulgated by the Nasdaq
Stock Market and the Securities and Exchange Commission regarding independence and related
party transactions.
The commission president stated in public session on August 14, 2012 that the CEO was in full
compliance with the terms of his employment contract. As with any contract, continued 
compliance will be monitored through audits, including our commission audit committee. 
Second, permit me to correct some of the statements and inferences in the letter you and your
colleagues signed. It is important that the facts are accurate when concerns are raised about
public employees. Mr. Yoshitani does not have dual employment with both Expeditors'
International and the Port of Seattle. As a member of their board of directors, he is not an
employee of that company. Also, Mr. Yoshitani serves as one of nine board members and is

The Honorable Zack Hudgins 
August 28, 2012 
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neither the Chairman of the Board, the Lead Independent Director, nor the president of the board
at Expeditors (a position that does not exist).
Third, state law provides clear statutory language defining conflicts of interest and other matters
pertaining to public employees today who sit on corporate boards of directors. If you have
specific information regarding a conflict of interest, please have your legal counsel send us an
assessment of that conflict and how the port's ethics policy or employee code of conduct has
been violated. Should the commission determine that further review is warranted, we have
several options available. 
Once again, thank you for sharing our commitment to ensuring King County's Port of Seattle
remains a public institution that serves the public, and conducts itself in a manner in which the
people of King County may be proud. 
Sincerely, 


Tom Albro 
Chair, Audit Committee 
Seattle Port Commission 
Cc:   Senator David Frockt 
Senator Karen Keiser 
Senator Adam Kline 
Senator Sharon Nelson 
Representative Joe Fitzgibbon 
Representative Bob Hasegawa 
Representative Luis Moscoso 
Representative Tina Orwall 
Representative Gerry Pollet 
Representative Derek Stanford 
Representative Pat Sullivan 
Representative Dave Upthegrove 
Members of the Seattle Port Commission