For the past decade, the Congressional Black Caucus Political Education & Leadership Institute has sponsored an annual policy conference in Mississippi to discuss everything from health care to clean energy and infrastructure.

But the event also has corporate sponsorships, leading to a thorny ethics question that is increasingly difficult to answer: What does it mean for a third party to “sponsor— an event that includes Members of Congress?

Members of Congress are not allowed to accept travel from private entities but are allowed to take trips sponsored by nonprofit groups.

In 2008 and 2009, a dozen members of the CBC filed forms with the House ethics committee seeking approval of their travel to the institute’s annual policy conference in Tunica, Miss. Each Member checked a box on the form certifying that the institute would be paying for the trip, and “the trip sponsor has not accepted from any other source funds earmarked directly or indirectly to finance any aspect of the trip.—

But in 2008 and 2009, the institute had collected thousands of dollars from corporate sponsors of the event, and a copy of the 2008 agenda attached to one Member’s financial disclosure form lists a separate corporate sponsor for every aspect of the conference. Toyota North America is listed as the sponsor of a roundtable on advanced technology vehicles; Lockheed Martin is listed as the sponsor of an award ceremony and concert featuring R&B stalwarts Kool & the Gang; the International Longshoremen’s Association is listed as the sponsor of the Bennie G. Thompson Sporting Clays Challenge, a target shooting event.

The Mississippi Democrat is the chairman of the institute, and the event takes place at a resort and casino in his Congressional district.

William Kirk, an institute board member and organizer of the Tunica event, said the group consulted carefully with the ethics panel, formally known as the Committee on Standards of Official Conduct, about the conference and was given the green light because none of the sponsors had any control over the agenda or the events. The 2008 agenda listing individual sponsorships does not mean that sponsors paid for or organized those sessions, Kirk said.

“The rules don’t prohibit a nonprofit from receiving contributions from folks,— Kirk said. For the purposes of the ethics rules, “What they are getting at is the sponsor of the event has to be the one who sets the agenda.— While the CBC institute sold sponsorships to companies for the event, those sponsorships conferred upon the donors only the right to attend the event and participate in the recreational and social activities scheduled around the event. They were offered no control over the agenda and no opportunity to speak during the proceedings.

“The House rules have evolved,— Kirk said in an interview. “When you use that term ‘sponsor,’ it causes confusion. … In 2007 and 2008, nobody thought the term ‘sponsor’ was significant. All we were doing was trying to find ways for people who were significant contributors to the institute to be acknowledged.—

Several sponsors contacted by Roll Call said their sponsorship was a general donation to the CBC institute and attendance at the conference, but they did not specifically designate the funds for any purpose.

The agenda for the institute’s meetings in 2008 and 2009 did include one event organized by an outside group: The American Gaming Association organized a gaming industry forum both years.

AGA spokeswoman Holly Thomsen said the industry forum “is part of the Tunica institute events … It is typically a forum and workshop for people who are interested in doing business with the gaming industry.— The Tunica conference is held at a resort and casino, and there are two dozen casinos in the area, providing a wide range of opportunities for vendors seeking to do business with the industry, she said.

A flyer sent out by the AGA for the gaming industry forum said the association “is a proud sponsor of the CBC Institute’s Gaming Industry Forum— and included as highlights of the event “networking with members of the Congressional Black Caucus, gaming industry executives and fellow attendees.—

But Kirk said the forum is not actually part of the CBC event.

“The gaming forum is a separate event — they pay for all that,— Kirk said. “We list it on some of our materials [and] the gaming industry has said that anybody who has registered for the conference can go to that event.—

Kirk said the CBC institute in past years has provided the AGA with space in the conference center but in the future will charge the AGA some rental fee for using a room in the conference center that the institute has rented for the weekend.

Kirk said that while the institute pays for meals and lodging, the Members who attend the Tunica conference pay their own airfare — several Members reported using campaign funds to pay for their travel — and are also required to pay for their own participation in the golf and shooting events.

Those events are named for Members of Congress — the Thompson shooting event and the James E. Clyburn (D-S.C.) Golf Challenge — but they are not events “honoring— those Members, Kirk said.

“We debated whether to take that off … [the Tunica conference] has been going on for almost 10 years, and that is historically what we had called it.— Kirk said the conference organizers checked with the ethics committee and that there was no objection to the name of the sporting events.

Corporate sponsorship of Congressional travel is a sensitive subject, particularly among members of the Congressional Black Caucus. The House ethics committee announced in June that it has established an investigative subcommittee to look into Caribbean trips taken in 2007 and 2008 by a handful of CBC members. The events were organized by a small nonprofit called the Carib News Foundation, but a watchdog group documented that placards at the events indicated corporate sponsors had underwritten part of the trip.

Thompson acknowledged that he had been contacted by the Office of Congressional Ethics about his participation in a Carib News trip. The OCE referred the matter to the ethics committee for further investigation.

The investigative subcommittee is being led by Rep. G.K. Butterfield (D-N.C.), who traveled on a Carib News trip in 2005 — before the ban on private travel was in place — and who participated in this year’s Tunica event.

The ethics committee pre-approved the travel of all Members to the Tunica event.