This sample policy outlines guidelines and procedures for the use of corporate aircraft, ensuring that all operations align with the company's governance standards and ethical considerations. It addresses the administrative, accounting and tax aspects of corporate aircraft usage to enhance the productivity, efficiency and security of board members and executive management. The policy specifies the conditions under which corporate aircraft can be used for business and personal travel, detailing the processes for imputing income for non-business flights and calculating tax deduction disallowances. It also describes the disclosure of aircraft use in corporate financial reporting and the reimbursement protocols for personal use of corporate aircraft.

Additionally, this document provides a framework for the reimbursement of travel expenses for directors attending meetings and other company-related events. It sets forth eligibility criteria for such reimbursements, the approval process involving the chairman or designated company officers, and the documentation required to support reimbursement claims. This policy also emphasizes the need for pre-clearance for any travel not explicitly covered under the policy and outlines the tax treatment and reporting requirements for all travel reimbursements. This ensures that the use of corporate aircraft adheres to legal and regulatory standards, maintaining transparency and accountability within corporate practices.

Sample procedures include:

• Imputing income for non-business flights by eligible people, their family members and guests in accordance with IRS safe harbor rules utilizing standard industry fare level (SIFL) rates
• Calculating any disallowance of tax deduction to the extent required by existing tax law
• Disclosing and calculating corporate aircraft use as executives' benefit or "perquisites" in the annual proxy statement
• Calculating and reimbursing certain costs to the company for flights of a personal nature that must not be included as imputed income to eligible people