p3p policy generator source code

Hi,

Does anyone know of any existing publicly available java source code which implements something similar to the IBM policy generator. Or indeed if IBM is offering the src code anywhere.
The reason I'm asking is because I'm in the process of trying to build an APPEL ruleset generator.
In thinking about the design, I realised that actually it could be remarkably similar to the policy generator. It would therefore save us a lot of work if we had the policy generator as a starting point

Thanks

Giles Hogben