1. General policy statement: The CEO shall be responsible for implementing adequate controls to assure that meetings, events, and incentive/recognition travel organized by the company serve legitimate business purposes and are cost justified.

2. All proposed meetings, events, and incentive/recognition travel organized by the company must serve one or more specified legitimate business purposes. Each proposed meeting, event or incentive/recognition travel with a cost exceeding $75,000 must be supported by a written business case identifying a specific business purpose.

3. Total annual expenses for meetings, events and incentive/recognition travel shall not exceed 15 percent of the company's total sales and marketing spend.

4. The amount spent for an employee performance incentive/recognition event shall not exceed 2 percent of the total compensation of eligible participants or 10 percent of total award-earners' compensation.

5. The process for approving meetings, events, and incentive/recognition travel, and the procedures for assuring adherence to this policy, will be subject to independent audit to confirm policy adherence.

6. At least 90 percent of incentive program attendees shall be other than senior executives (as defined by applicable Treasury Department guidelines) from the host organization.

7. Performance incentives shall not promote excessive or unnecessary risk-taking or manipulation of financial results.

8. All internal meetings or events attended only by senior executives (as defined by applicable Treasury Department guidelines) and/or board members shall be devoted to specific business purposes, and participating senior executives shall be responsible for any expenses incurred for non-business related activities.

9. The CEO of the company shall certify to the board at least annually that the foregoing policies are being followed, and are sufficient to provide reasonable assurance that the company's expenditures for such purposes are not excessive.

10. These policies shall be subject to modification only with board approval stating the specific business rationale for the change in policy.

Calendar:

March 29-31

Pharmaceutical Meeting Management Forum
Baltimore, Md.
www.meetingsnet.com

April 5-7

ACTE Global Education Conference
Washington, D.C.
www.acte.org

May 26-28

IMEX
Frankfurt, Germany
www.imex-frankfurt.com

June 21-23

FICP 2009 Education Forum
Colorado Springs, Colo.
www.ficpnet.com

July 11-14

MPI World Education Conference
Salt Lake City, Utah
www.mpiweb.org

August 23-26

NBTA International Convention & Exposition
San Diego
www.nbta.org

Sept. 29-Oct. 1

The Motivation Show
Chicago, Ill.
www.motivationshow.com

Oct. 30-Nov. 2

Site (formerly Society of Incentive & Travel Executives) International Conference, Aruba
www.site-intl.org

Nov. 15-19

Financial & Insurance Conference Planners Annual Conference
Toronto, Ont., Canada
www.ficpnet.com

Dec. 1-3

EIBTM Global Meetings & Incentives Exhibition
Barcelona, Spain
www.eibtm.com

Dec. 8-10

Expo! Expo! International Association of Exhibitions & Events
Atlanta
www.iaee.com