An ethics complaint filed Friday against Colorado Gov. John Hickenlooper alleges the two-term Democrat has made a habit of crisscrossing the globe on private jets owned by wealthy benefactors and then not disclosing the gifts as the law requires.

The 189-page complaint by the newly formed Public Trust Institute — a nonprofit run by former House Speaker Frank McNulty — lays out nearly 100 questionable flights Hickenlooper has taken since September 2011, when he first took office, though it primarily focuses on those from the past year, which the state’s Independent Ethics Commission is able to investigate.

Read the full complaint or scroll to the bottom of the page

Each flight would cost into the thousands of dollars, PTI’s complaint alleges, a far cry from the $59 gift limits each elected official in Colorado must abide by, the result of Amendment 41 that voters passed in 2006.

Hickenlooper’s office called the complaint “frivolous” and a “political stunt” in a response late Friday afternoon.

The complaint also questions whether the governor has accepted other benefits associated with the flights, including stays at luxury hotels for all-expense-paid events in Italy, Switzerland and several states across the country. Those events would also exceed Amendment 41’s gift limits, the complaint says.

“Governor Hickenlooper’s extravagant travel habits have been the source of public speculation for years,” McNulty said in a news release issued Friday. “After conducting extensive research, we learned that the problem is far more serious than any of us could have realized.”

If Hickenlooper personally paid for the travel and events up front, there’s no need to report them. If he accepted any freebies or even if he reimbursed his hosts after the fact, he must report them under Amendment 41 rules. Gifts that are excluded under the rules, such as from a close friend for a special occasion, need not be reported.

The complaint comes from an organization whose leader is a Republican who has traded barbs in the past with the Democrat, who is exploring whether to make a presidential run in 2020.

The group says it cross-checked the dates with Hickenlooper’s campaign finance reports and did not find any payments. The governor’s campaign committee, Hickenlooper for Colorado, terminated in October 2015 and was zeroed out by January 2016, records show.

“It looks like the organization was created in the last few days to trump up frivolous accusations,” Hickenlooper’s press secretary, Jacque Montgomery, said in the statement. “They ignored the Independent Ethics Commission process by going straight to the media. This is clearly a political stunt aimed at influencing the upcoming election.”

Commission complaints are confidential and subject to review before an investigation begins. PTI made its complaint available on its website.

Hickenlooper’s office has been the focus of at least one other ethics complaint dealing with travel expenses, in 2013, but the commission said no rules were violated.

Some events, such as the Bilderberg Meetings in Turin, Italy — a gathering of high-powered corporate executives and political leaders from around the world — are so exclusive and secret that “neither the identity nor the affiliation of the speaker(s) nor of any other participant may be revealed,” according to the group’s website.

Much of the event is paid for by its sponsors, which in 2018 included Fiat Chrysler, PTI’s complaint shows.

PTI also alleges that Hickenlooper accepted a chauffeured Maserati limousine and other amenities at the June 2018 meetings — he was caught on camera at the airport saying he had “no official statement” about why he was there, but said he paid for the trip himself — including transportation via private jet that PTI estimates to have cost as much as $10,000.

“Bilderberg is a luxurious, corporately paid event to discuss international affairs amongst global business and political leaders,” the complaint says. “This is precisely the type of event Amendment 41 is intended to restrict.”

McNulty told The Denver Post that Hickenlooper has an obligation to prove whether he’s paid for the events or not.

“He doesn’t get a free pass to simply say he’s paid for it himself,” said the former Republican state lawmaker, who represented House District 43 from 2007 to 2015. “If he did, then show us. Every elected official in the Capitol has to abide by the same rules; not a single one of them is above the law.”

Hickenlooper was one of 37 Americans who attended the four-day event, exhibits attached to the complaint show, but the only politician from the United States, opening questions about whether the trip had anything to do with a potential presidential bid.

Hickenlooper on Sept. 17 filed paperwork that formed the Giddy Up PAC, a federal political action committee that’s known as a leadership PAC, a common step by presidential aspirants that allows them to raise money on the federal level.

Hickenlooper’s term ends early next year, and he has said he won’t decide before then whether to run for the White House.

Another questioned flight — from Vail to San Francisco — was allegedly to attend Super Bowl 50 in 2016 in which the Denver Broncos defeated the Carolina Panthers. The complaint says the only planes that flew from the airports Hickenlooper used were private jets and not commercial airliners. The complaint also questions whether tickets to the sports event were also complimentary.

If so, Hickenlooper is required by law to report who provided the freebies and the approximate cost of each.

The complaint lists several other trips Hickenlooper took on private jets it says were paid for by corporate entities, none of them reported as gifts. They include:

March 2018 to Connecticut for the dedication of the attack submarine USS Colorado on a plane owned by M.D.C. Holdings, whose CEO is Larry Mizel. Hickenlooper went on to New York City by train.

January 2018 from New Jersey on an unidentified private jet to Colorado.

August 2018 to Jackson Hole, Wyo., for the American Enterprise Institute’s Jackson Hole Symposium on an unidentified private jet from Dallas.

August 2018 from Aspen to an unknown destination.

September 2018 from Montreal to an unknown destination.

“Governor Hickenlooper has executed a scheme to prevent review and scrutiny of his extensive travel on private jets,” the complaint says, noting Hickenlooper’s office frequently redacted any travel on privately owned planes from open records requests for his schedule. Commercial flights, however, were left unredacted.

“The withholding and redaction of information about … Hickenlooper’s private air travel is carried out to conceal the fact that (he) routinely accepts private air travel that grossly violates the express restrictions set forth in Amendment 41,” the complaint says.

Hickenlooper is unusual among the state’s high-ranking politicians in filing just one gift-disclosure report — in 2017 for a $500 painting given by the first lady of Zambia — since 2013. In that year, he said he had received only T-shirts and hats to the Million Dollar Quartet Musical worth just $90.

The painting remains the property of state government; otherwise Hickenlooper would violate Amendment 41’s gift limit by personally keeping it.

Denver Mayor Michael Hancock, on the other hand, in 2017 alone listed dozens of gifts he accepted from a variety of sources — a $3,684 Denver Athletic Club membership and a $9,000 flight on Norwegian Air from Denver International Airport among them.

“This is a situation apparently where Hickenlooper thought he was above the law and continues to jet-set around the globe, and that’s an obvious red flag,” McNulty said.

PTI lays out a number of other flights Hickenlooper took before 2018, which it says is proof of his long-standing use of unreported privately paid travel, many of them on jets owned by Douglas County-based Liberty Media Corp., run by billionaire John Malone.

Hickenlooper’s wife, Robin, is senior vice president of corporate development at Liberty Media.

“If his wife accepted the trip or the governor, it must be reported,” McNulty said, “especially because the governor was on the plane.”

Hickenlooper’s office has a history of seeking guidance from the Ethics Commission about accepting gifts or other freebies.

In April 2016, the commission determined it would be a violation of Amendment 41 for the governor and a staffer to accept reimbursement for travel and lodging expenses from General Electric to attend a conference in Florence, Italy. Hickenlooper was the only American politician invited to speak.

In July 2014, the commission said the governor’s legislative director could accept travel expenses for a fellowship paid for by the American Council of Young Political Leaders.

An ethics complaint filed in 2014 said he and his staff wrongly allowed the Democratic Governors Association to cover their expenses at a conference a year earlier. The commission ruled no rules were breached.

McNulty’s new group is designed to “ensure that public officials are generally holding themselves to an ethical level,” he said, noting the group will pursue complaints objectively and without political persuasion.

“In this day and age, since politics slams to the left and right so quickly, we need someone to call balls and strikes from the outside,” McNulty said, refusing to identify the group’s revenue stream or its membership. “The main focus is me and having that outward-facing figure. That’s where we’re comfortable right now.”

McNulty was speaker of the House of Representatives from 2010 to 2012, overlapping Hickenlooper’s election as governor. The two tangled widely on the issue of civil unions, with McNulty refusing to allow it to come up for debate on the House floor and the governor calling for a special session in May 2012.

PTI appears to fill the gap left by Ethics Watch, which closed at the end of 2017 for lack of funding. The closing left no entity specifically dedicated to policing the state’s public and elected officials for ethics violations.

“There’s no entity to keep them honest,” according to its former executive director, Luis Toro, now an assistant city attorney in Boulder. “It’s up to individuals. There’s no one who’s dedicated to this anymore.”

The Ethics Commission first determines if a formal complaint is frivolous or not, meaning it decides if the matter is too menial to be worth its time. Then it can investigate and issue a report, which could include a fine or other sanction.

McNulty said the complaint against Hickenlooper is appropriate no matter that he’s nearing the end of his term as governor.

“Just because his political time in Colorado has come to an end doesn’t mean he’s allowed to skate,” McNulty said. “Folks have not taken a critical look at the Hickenlooper administration and what he’s done. In a case like this, with all the red flags popping up, it takes a bit to put the dots in place, but once there, it doesn’t take too long to connect them.”

UPDATE: This story was updated to reflect that exclusions allowed under Amendment 41 are not required to be reported.