TRAVEL, MEALS & ENTERTAINMENT POLICY

Transcription

1 - 1 - TRAVEL, MEALS & ENTERTAINMENT POLICY I. PURPOSE OF THE POLICY All employees ( Employees ) of Pembina U.S. Corporation (the Company ) and all U.S. affiliated entities (collectively, Pembina US ) are expected to be responsible fiscal stewards on Pembina US behalf, as well as on the behalf of all Pembina US stakeholders. Employees are expected to exercise prudent business judgment regarding expenses covered by this Policy. This Policy sets forth best practices for business travel and meals and entertainment expenses for Pembina US by outlining acceptable and unacceptable use of Pembina US funds. Employees may incur expenses as a result of activities that support Pembina US operations, including domestic or international business travel. Travel, meals and entertainment related expenses are those in which there is the expectation of deriving some current or future benefit for Pembina US; Employees are actively engaged in a business meeting or activity necessary to his or her job duties; or, in the case of entertainment, there is a clear business purpose. Reasonable business expenses, both general and while travelling, are intended to be reimbursed by Pembina US. All expenses must be ordinary, necessary, and have a valid business purpose. II. SCOPE AND APPLICATION This Policy applies to all Employees of Pembina US who claim business travel, meals and entertainment expenses. This Policy is designed to provide equitable and cost-effective treatment for all Employees required to travel on business and/or who incur general business expenses. Definitions In this Policy: Board or Board of Directors means the board of directors of the Company from time to time; CWT means Carlson Wagonlit Travel Company; Employee Leader means the Supervisor, Manager, Senior Manager or Vice President of the Employee s business or service unit as applicable; Executive means any of the President and/or Chief Executive Officer, the Chief Financial Officer, the Senior Vice Presidents, and the Vice Presidents as appointed by the Board from time to time; LDW means a Loss Damage Waiver; P-Card means a Pembina US Corporate Credit Card; Pembina means Pembina Pipeline Corporation; Policy means this Travel, Meals and Entertainment Policy;

2 III Spending Authority means the authority granted to certain positions in the Spending Authorization Rule; Spending Authorization Rule means the Spending Authority - Authorization Rule which delegates Spending Authority based on title/position; and WBS means work breakdown structure. PRINCIPLES A. Payment and Documentation 1. General The nature of all expenses must be carefully documented. Expenses shall be processed through a P-Card, in accordance with Pembina s Corporate Credit Card Policy. For circumstances where a travel, meals and entertainment expense was incurred and was not charged using a P-Card, an expense report, with all supporting documentation, is required. 2. Currency All currency quoted in this Policy is in U.S. dollars. If expenses are incurred in other currencies, reimbursement will be made in U.S. dollars. The exchange rate used will be at the current rate of the credit card or the exchange rate in use by the Treasury department at that time, unless Employees have documented currency exchange transactions at an alternate rate. Employees must provide the exchange rate documentation for back up when submitting their expenses. 3. Eligible Expenses Reasonable and necessary business-related expenses qualify for reimbursement unless noted otherwise; and all approved expenses incurred must be in accordance with individual departmental budgets. If there are questions relating to expense budgets, please contact your Manager for further information. 4. Corporate Credit Cards and Personal Credit Cards Employees who have been granted a P-Card must charge all possible eligible expenses through the card; and if Employees are not eligible for a P-Card, items should be expensed on a personal credit card. 5. Expense Reimbursement Guidelines In order for Pembina US to process expense reimbursement: itemized receipts for all expenses incurred must be submitted (credit card receipts alone will not be accepted); the expenses must be correctly coded (e.g. company code, cost element, and applicable cost centre, project and/or WBS, tax, tip, etc.); if the individual incurring the costs does not have appropriate Spending Authority, then approval must be received by an Employee Leader who holds the necessary Spending Authority, prior to committing Pembina US funds; and

3 - 3 - entertainment costs should be reasonable compared to the purpose of the business. Business meals and entertainment expenses are only partially deductible by Pembina US for tax purposes and are subject to close scrutiny by the applicable tax authority. As a result, expenses must be supported with: itemized receipts that adequately describe the good or service purchased and amounts tendered. In the event that a receipt has been lost and cannot be replaced, the Lost Receipt Declaration Form shall be completed for costs in excess of $25 or more; detailed explanation of the purpose of any expenditure being claimed; and a complete list of all participants (both Pembina US and external parties). 6. Duration of Eligibility for Reimbursement Expenses incurred on an Employee s P-Card are subject to the deadlines incorporated in Pembina s Corporate Credit Card Policy. Employees have 60 days from the date an expense was incurred or the return date of their business travel in which to be eligible for reimbursement outlined in this Policy for expenses incurred personally (not charged to the Employee s P-Card). Notwithstanding the foregoing, Employees should submit expenses within the same calendar year in which they were incurred. Should special circumstances prevent this, approval for an extension is required from Corporate Accounting. Expenses submitted after 60 days are considered a Policy violation and the cardholder s immediate supervisor will be notified. Pembina US reserves the right to deny reimbursement of personally paid expenses not submitted within 60 days of incurring the expense or the travel date. Employees must reconcile their P-Card statements on a monthly basis per Pembina s Corporate Credit Card Policy. 7. Audit of Expenses all incurred expenses are subject to audit by the Internal Audit, Supply Chain, and Corporate Accounting teams, relevant tax authorities and customers (for example, shippers, producers and joint venture partners); the primary responsibility for monitoring and controlling incurred expenses rests with the Employee s supervisory staff; in the event of anomalies, the Employee involved may be asked to provide further information to clarify any ambiguities or issues; and improper or unauthorized expenses may require the Employee to reimburse Pembina US for such expenditures, disciplinary action being brought against the Employee, and/or termination of employment from Pembina US. See Compliance. B. Approvals and Special Requests It is the responsibility of the Employee to have business expenses and travel pre-authorized by the Employee Leader prior to incurring expenses to prevent misalignment of expectations and potential nonreimbursement of costs or personal liability for P-Card charges. It is the Employee Leader s responsibility to monitor and control incurred business travel and entertainment expenses. The most senior Employee at an event/function/meal (etc.) is responsible for payment of the expense to ensure the expense is ultimately approved by a non-attendee. If it is not logistically possible for the most

4 - 4 - senior Employee attending to be responsible for payment, the most senior attending Employee s Supervisor must still ultimately approve payment of the expense. C. Meals and Entertainment Expenses Meals and entertainment expenses may be incurred for travel and for other business-related purposes. Business entertainment expenses may be eligible for reimbursement in the following situations: Primarily to: hosting external business contacts to advance commerce on behalf of Pembina US. Occasionally to: host fellow employees from other Pembina US or Pembina offices; acknowledge job performance, employee retirement or mentor employees; conduct relevant and necessary department team-building and planning meetings; and/or celebrate and host social events for the purpose of fostering business relationships (holiday parties, local events). These expenses include tickets to shows or sporting events, lodging, transportation, food and/or facility costs related to the event. Costs should be consistent with local conditions. Meal expenses will be reimbursed based on the actual cost. However, limits may be imposed where amounts are deemed to be excessive. Any meal costs reflected in a hotel receipt must be separated out and booked under the meals category on the expense report, as only 50% of meal costs are deductible for corporate tax purposes. Reasonable and customary tips will be reimbursed but should not exceed 20%. Recommended rate in North America is 15%. D. Alcohol Related Business Expenses Employees are reminded that Pembina US Alcohol and Drug Policies (DOT and non-dot) prohibit individuals from being under the influence of intoxicating substances, including alcohol, while at their place of work; expenses for the consumption of alcohol during normal business hours are not allowed unless preapproved by a manager or above or at a Pembina US social club event. Outside of normal business hours and where local custom and occasion support the consumption of alcohol, reasonable and appropriate expenses may be approved; and expenses for the consumption of alcohol shall not be charged through projects or cost centres that are ultimately reimbursed by customers (including shippers, producers and/or joint venture partners) and instead should be charged to general and administrative expenses through the Employee s cost centre. Please contact the Corporate Accounting department for clarification on which cost centre and projects would be reimbursable. E. Combined Business, Personal, Spousal and Family Member Travel Pembina US allows spouses and other family members to accompany Employees on business trips where appropriate. However, the costs associated with spousal and family travel are at the Employee s own expense unless the family member is an invited guest to a Pembina US or related function. As a rule, Pembina US paid business class airfare for Employees may not be exchanged for multiple economy class airfares.

5 - 5 - Pembina US allows Employees to combine business and personal travel, where appropriate. However, the personal travel must be incidental to the business travel and advance approval, as appropriate, is obtained. Employees will only be reimbursed for expenses that would have been incurred had no personal travel been taken. If a spouse, a family member, or a guest accompanies Employees on a business trip, such individual is responsible for all of the associated expenses unless prior written approval has been received by the Employee Leader authorizing the expenses. Additional approval is required by a project manager for spousal/family member travel when the expense may be reimbursed by a third party (e.g. shipper, producer, etc.). Please note that: if the spouse, a family member, or a guest is not required at the event, the expenses will be treated as a taxable benefit to Employee and will be reflected on the Employee s current year s tax form slip; and if the spouse, a family member, or a guest has been invited to a company function (e.g. Long Service Award Celebration) then Pembina US will reimburse Employees for normal expenses and this will not be treated as a taxable benefit. F. Modes of Travel 1. Airline Travel Pembina US has entered into an agreement with CWT to provide travel services to all Employees. CWT is to be used whenever possible when booking air travel, rental vehicles or accommodation. For all domestic and US travel, Employee shall travel at economy or discounted fares, where available. It is advised that Employee s plan and book their flights as early as practicable. For international air travel, Employees can travel at business class fares with approval from their Employee Leader prior to making travel arrangements. While Executives are encouraged to travel at economy fares, Executives can choose to travel at business class fares where the flight is in excess of four (4) hours in duration; if the flight is late in the evening or overnight travel is required; or, where work is required to be completed during the flight. A copy of the invoice for the airline travel is required to be submitted as support for the expense; copies of boarding passes or itineraries are not sufficient. 2. Rental Cars (i) Car Size Rental sport utility vehicles or trucks that are safe for travel to field locations and unpredictable road conditions should be used for Pembina US business. Otherwise, compact vehicles are permitted. (ii) Additional Third-Party Liability Insurance If renting a vehicle for Pembina US business, additional insurance providing at least $1,000,000 third party liability must be purchased unless the vehicle is rented from Enterprise Rent-A-Car or National Car Rental under Pembina US account which has the loss damage waiver included in the price of the rental. Wherever possible, rent a vehicle from one of our preferred suppliers. (iii) Loss Damage Waiver Employee should purchase the LDW since Pembina US corporate insurance policy does not cover physical damage to rental vehicles. Purchasing LDW relieves Pembina US of financial responsibility if the vehicle is

6 - 6 - stolen, vandalized or damaged. Whether the accident is the Employee s fault, or is caused by someone else, this insurance will cover costs associated with the accident. (iv) Personal Accident Insurance and the Personal Effects Coverage For Pembina US Employees (not including contractors and consultants), personal accident insurance is not required, since the employee(s) involved in an accident would be covered under Workforce Safety and Insurance or Pembina s benefits plan. Contractors and consultants on payroll are expected to carry their own personal plans and independent contractors and consultants are required to carry their own liability and automobile insurance at a minimum level required in their respective contracts, as well as Workforce Safety and Insurance. Pembina US does not insure personal effects. Employees must purchase this coverage, if desired. (v) Other Since not all rental agreements are standardized, here are a few things to look out for: off road restrictions; towing limitations; driver limitations (i.e. age); and parking limitations for propane powered vehicles (i.e., no underground). Should an Employee be involved in an accident with a rental vehicle while on Pembina US business, he or she shall immediately contact the rental company and the Employee s immediate supervisor. For a fleet vehicle, they shall also contact Pembina US Insurance department and Fleet Analyst, immediately. (vi) Taxi and Ground Transportation Pembina US preferred mode of ground transportation is taxi, uber or car service (sometimes called sedan or limousine service). For safety reasons Employees should refrain from using public transportation. Employees should keep in mind cost, safety, and security. (vii) Use of Personal Automobiles Where possible, Employees should not use personal vehicles for Pembina US travel purposes, regardless of any potential cost savings, or sense of convenience. Personal vehicles rely on that individual s insurance policy, which may not have appropriate coverage for business requirements. Pembina US insurance does not transfer to personal vehicles and could result in legal complications, should an accident occur. Instead, Employees should rent a vehicle, use a Pembina US work vehicle, taxi or other ground transportation. In the event of personal vehicle use for Pembina US business purposes, Pembina US shall not be liable for any damages incurred to a personal vehicle. Employee Leader approval is required if you are using your personal vehicle for business travel. Personal travel to and from in-town seminars and meetings is not considered business travel. (viii) Travel Safety Employee safety is Pembina US utmost concern. Pembina US requires all Employees to use their best judgement when choosing the safest and most cost-efficient form of travel and/or accommodation. Pembina US supports reasonable adjustments to travel based on varying circumstances.

7 - 7 - There are several factors to consider including: cost, time at site, activity at site, weather conditions, and/or a potential conflict with governing Pembina US policies, including the Alcohol and Drug Policy (DOT and non-dot). G. Other Reimbursable Travel Expenses The following are other reimbursable expenses: accommodation-room charges and meal charges; transportation (car rentals), including parking; business-related telephone calls, faxes, mail and internet usage costs; reasonable charges for calls home; local transportation (e.g. taxis, sedans, etc.); and laundry and/or dry cleaning, if on a business trip in excess of 5 days. Personal expenses are generally not considered reimbursable unless approved by your Employee Leader for extenuating circumstances. Some examples of personal expenses not normally reimbursable are: VI. airline club dues or fees; personal services or products (hair care, shoe shines, toiletries, etc.); recreation on personal time (theatre tickets, sporting events, in-room movies, reading material); babysitting fees; pet sitting or boarding fees; and luggage or briefcases. COMPLIANCE Employees must comply with this Policy at all times. Any breaches of this Policy may result in disciplinary action up to and including immediate termination of employment with Pembina US. All other Pembina US policies remain in effect during business travel and/or while incurring other businessrelated expenses. While travelling on company business, Employees should not participate in any activity which contravenes the intent of, or could be a violation of, Pembina US Policy Prohibiting Harassment and Discrimination or any other Pembina US policy. Violations of this Policy should be reported in accordance with Pembina US Whistleblower Policy. VII. REVIEWED AND APPROVED This Policy was last approved by the Board of Directors on October 10, 2018.

8 - 8 - VIII. RELATED POLICIES The following policies relate to the subject matter of this Policy: Pembina s Authorization for Expenditure Policy Pembina s Corporate Credit Card Policy Pembina US Alcohol and Drug Policies (DOT and non-dot), taking particular note of the alcohol-related provisions; Policy Prohibiting Harassment and Discrimination Whistleblower Policy Code of Ethics Policy