TAG GECC PPIF Master Fund, L.P.
LUXURY EXPENSE POLICY
- INTRODUCTION
- POLICY
- Entertainment
- Conferences
- Holiday Parties and Other Events
- Aviation Services and Other Transportation Services
- Office and Facility Renovations
- Waste, Fraud and Abuse Hot Line
- Administration
- Amendments
INTRODUCTION
AG GECC PPIF GP, LLC (the “Fund Manager”) Luxury Expense Policy is designed to guide the PPIF Manager’s activities in connection with determining reasonable and appropriate expenditures in connection with its activities as a PPIF Manager and as a service provider to the United States Treasury (“Treasury”). This policy covers the expenses charged to the PPIF Manager and not the expenses charged to the PPIF. Expenses charged to the PPIF will be governed by the terms of its Limited Partnership Agreement.
In general, the PPIF Manager prohibits excessive or luxury expenditures on entertainment and events, office and facility renovations, lodging, aviation and other transportation services or other activities or events that would not be viewed as reasonable expenditures in the context of the normal course of its business operations. Expenses should not be incurred that would give the appearance of being extraordinary or excessive from a prudent outsider’s perspective.
This policy applies to all personnel who have been identified as PPIF Manager Employees as set forth in the PPIF Manager’s Code of Ethics. The policy supplements the requirements contained in the PPIF Manager’s Code of Ethics, in particular related to Gifts and Entertainment.
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POLICY
Entertainment
Entertainment refers to activities such as business meals, concerts, sporting or theatrical events where a PPIF Employee uses the PPIF Manager’s funds for business development purposes to enhance existing or prospective business relationships or otherwise related to the normal conduct of the business of the PPIF Manager. All entertainment must be limited to reasonable expenses and avoid the appearance of being extravagant or excessive. The PPIF Investment Committee will determine what is considered reasonable in the context of the circumstances. PPIF Manager Employees who have questions concerning the reasonableness of entertainment expenses should consult with the Investment Committee.
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Conferences
The PPIF Manager encourages its staff to attend conferences that provide appropriate educational and professional development opportunities. These conferences should have a direct correlation to the Employee’s function. When possible, it is preferred that such conferences be in the Employee’s local geographical area. At times it may be acceptable that a spouse travels to these conferences with the PPIF Manager’s employee or officer. In the event a spouse travels to the event, the spouse’s travel expenses will not be paid by the PPIF Manager.
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Holiday Parties and Other Events
The PPIF Manager believes that an annual holiday party for PPIF Manager’s Employees and other similar events are important in terms of employee appreciation and employee morale. Accordingly, this policy does not prohibit expenditures in conjunction with such events. However, such employee events must be local as neither overnight nor long distance travel expenses will be paid by the PPIF Manager, absent approval of the PPIF Investment Committee. Other events, such as the occasional department party or outing are subject to the same standards. When planning such events, please consult the PPIF Manager Investment Committee to ensure compliance with this Luxury Expense Policy.
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Aviation Services and Other Transportation Services
All transportation for PPIF Manager Employees for conferences, business development meetings, and research, should be on commercial transportation in the most cost appropriate way for the PPIF Manager taking into account the time and distance of the travel and other relevant factors, unless otherwise approved by the PPIF Manager Investment Committee.
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Office and Facility Renovations
Material renovations of PPIF Manager facilities and office space should be appropriate relative to the project, the business objective and approved in advance by the PPIP Manager’s Investment Committee. If the PPIF Manager must deal with an emergency situation where renovations or expenditures are necessary in order to achieve business continuity, the approval of the PPIF Manager Investment Committee is not required. No renovation should be performed that would give the appearance of being extraordinary or excessive from an outsider’s perspective.
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Waste, Fraud and Abuse Hot Line
Any PPIF Manager Employee who is aware of fraud, waste, abuse, mismanagement or misrepresentations affiliated with the management of the PPIP should contact the Special Inspector General for Troubled Asset Relief Program at the Toll Free Hotline – (877) SIG-2009.
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Administration
On no less than an annual basis, all PPIF Manager Employees as designated in the Code of Ethics shall certify as to their understanding of and compliance with this Policy. Any violations of this Policy should be reported to the PPIF Manager Investment Committee promptly.
The PPIF Manager Investment Committee is responsible for oversight of the PPIF Manager’s overall adherence to this Policy and may determine sanctions or discipline, if any, associated with any violations thereof.
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Amendments
This Policy and any amendments shall be provided to Treasury within 90 days of adoption.
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October 2009 |