As the U.S. Treasury worked on its guidelines for corporate policies on “luxury expenditures,” the meetings industry, under the auspices of the U.S. Travel Association, scrambled to create an actual board policy that it hoped the U.S. Treasury would adopt instead.
The industry's model policy is specific, including guidelines for spending on meetings as well as actual sample business purposes for meetings (though the numbers it uses are meant to be examples that will not necessarily work for every company).
In the end, the U.S. Treasury stuck with vagueness. As explained in the Treasury's summary document, “the board of directors of each TARP recipient [must] determine what are excessive and luxury expenditures and establish a set of requirements specific to the TARP recipient under this policy. This is similar to the method by which public companies adopted a code of ethics under … Sarbanes-Oxley. Under the federal securities regulations … of Sarbanes-Oxley, the SEC presented a general framework for a code of ethics, but the public company itself was required to adopt standards specific to the company.”
The two sets of guidelines work well in tandem: Companies can be sure they are following the government requirements while taking an assist on the details from the model policy.
For example, the U.S. Treasury requires companies to “identify the types … of expenditures which are prohibited (which may include a threshold expenditure amount per item, activity, or event or a threshold expenditure amount per employee receiving the item or participating in the activity or event).”
The meetings industry model demonstrates the types of numbers companies might plug in when creating those thresholds: “The following prohibitions shall apply to Company-sponsored events: (a) Total annual expense for company-sponsored events shall not exceed 15 percent of the company's total sales andspend; (b) Total annual expense for performance incentive events shall not exceed 2 percent of the total compensation of eligible participants or 10 percent of total award earners' compensation; (c) At least 90 percent of performance incentive event participants shall be other than senior executive officers of the company (as defined by TARP regulations); (d) Performance incentive events shall not promote excessive risk-taking or manipulation of financial results; and (e) All internal events attended only by senior executive officers and/or board members shall be devoted to specific business purposes, and participating SEOs and/or board members shall be responsible for any expenses incurred by non-business related activities.”
Also useful is the model policy's sample list of meetings with legitimate business purposes — everything from the very specific (“performance incentives with clear rule structures that are designed to motivate and reward high performers for exceeding established goals that generate incremental revenue growth for their respective organizations and that are beyond the investment in the program”) to the decidedly broad (“sales conferences and employee meetings to align vision, strategy, and tactics”).