China Travel and Entertainment Policy

Transcription

1 EXECUTIVE SUMMARY Purpose: To familiarize Company employees with the basic elements of our travel and expense polices and procedures. To whom it applies: Bausch & Lomb China employees Key policy points: Establishes standard behavior in the execution of business travel in a manner that maximizes employee productivity and minimizes cost to the Company. FRAMEWORK FOR DECISIONS It is the Company s intent to provide processes and services that will allow employees to travel in a safe and effective manner as they conduct Company business. The purpose of this policy is to establish behavior associated with travel and entertainment expenditures that are consistent with good business practices. This behavior will allow employees to maximize their effectiveness while conducting business at the lowest cost to the Company. CONTENTS Topics See Page General Requirements 2 Making Travel Arrangements 3 Payment Methods 4 Transportation Guidelines 4 Lodging/Hotel Accommodation Guidelines 6 Laundry and Dry Cleaning 6 Meals and Entertainment Guidelines 7 Telecommunications 11 Expenses Reporting 11 Group Travel and Meetings 12 Appendix 13 Policy Owner: Charles Yang, Finance Director Page 1 of 13

2 1. GENERAL REQUIREMENTS 1.1 Policy Statement While some travel is appropriate and required, all employees are responsible for evaluating every trip to ensure the expense is justified and that appropriate alternatives to travel (such as video, web and teleconferencing) have been considered. Travelers are expected to exercise common sense and prudent business judgment in incurring expense on behalf of the Company. Travelers must also ensure that expenditures are directly connected to or pertain to the transaction of Company business, properly documented, and are supported by original receipts where required. Bausch + Lomb s T&E system is reimbursement-based. In general, employees will be reimbursed for reasonable business expenses (as defined throughout this Policy) incurred in the performance of their job duties. In order to be eligible for reimbursement, employees must: Use the Company Designated Travel Agency; Use the Corporate Card when available and applicable; Provide invoices and/or receipts where required for claimed expenses; and Submit timely and accurate expense reports with required documentation. Bausch + Lomb reserves the right to refuse reimbursement of inappropriate or excessive expenses incurred in violation of this Policy and its related procedures or to seek reimbursement from employees for inappropriate claims. 1.2 Exceptions Any exceptions, unless specified to this policy must receive advance written approval from the China Finance Director or China Managing Director. Line managers and travel approvers do not have the authority to issue pre- or post-authorization of non-reimbursable expenses. 1.3 Non-Reimbursable Expenses It is the policy of the Company not to reimburse any personal expenses. Questions about whether an expense is reimbursable should be discussed with an employee s management. Listed below are examples of business travel and entertainment expenses that are not reimbursable to employees. Expenditures for illegal activities; Ancillary hotel charges lacking business purpose (e.g. in-room movies); Valet services (except in cases where there is no reasonable alternative); Policy Owner: Charles Yang, Finance Director Page 2 of 13

3 Non technical newspapers and magazines or personal reading material; Personal expenses, side-trips, entertainment and trip/travel insurance; Airline and other club memberships; Laundry and dry cleaning for travel under four (4) consecutive nights duration; Personal legal charges and fines/penalties for violation of traffic laws; and Loss, theft, or damage to personal property (e.g., luggage, auto, clothing) and associated expenses 1.4 Consequences of violations Failure to comply with this Policy and related policies and procedures may result in delay or refusal of reimbursement, and/or disciplinary action up to and including termination of employment. This includes failing to repay the Company in a timely manner for any expenses found to be inappropriate or excessive during monitoring, auditing and investigations. Managers/Travel Approvers will be held accountable for approval or authorization of non-compliant or excessive expenses. Delinquency fees associated with delayed reimbursement due to non-compliance with this Policy and associated procedures are the responsibility of the employee and will not be reimbursed by the Company. 1.5 Monitoring and compliance controls The Company closely tracks expenses and has implemented a system of controls to monitor and audit for policy violations, including controls to identify fraudulent or inappropriate expense reports and travelers who do not comply with the various requirements of this Policy. 1.6 Policy maintenance, implementation and compliance The China Finance Director is responsible for publishing and maintaining this Policy. Business units are responsible for implementing and ensuring compliance with this Policy and associated procedures. 2. MAKING TRAVEL ARRANGEMENTS Travel requisition must be submitted at least 2 working days in advance, through e-workflow system, by the employee s direct managers, and 2 nd line managers if applicable. CLT members travel requisition must be approved by China Managing Director. Approved travel requisition must be printed out and submitted to Finance department together with expense report. Use of the company s designated travel agency is a requirement in all BU s. This includes air tickets reservation and changes/cancellations. Travelers should request and record the change confirmation Policy Owner: Charles Yang, Finance Director Page 3 of 13

4 or cancellation number in case of billing disputes. Change fees, no-show charges and cancellation fees will not be reimbursed unless the change or cancellation was for the benefit of the Company and the fee could not reasonably have been avoided. 3. PAYMENT METHODS 3.1 Corporate Card Use of the Corporate Card, where applicable, for payment of business travel expenses is a requirement. Corporate Cards may only be used for business travel and related business expenses of the direct cardholder. This is to provide an effective system for payment of expenses and to maximize insurance and rebate benefits associated with use of the Corporate Card. Personal cards and/or cash may only be used when the Corporate Card is not available, not accepted, or has been lost or stolen. Lost or stolen cards must be immediately reported to the card issuer. Personal use of the Corporate Card is strictly prohibited. Personal incidental expenses included in final hotel billing can be paid for with the Corporate Card but are not reimbursable. These non-reimbursable expenses must be identified as such on the invoice and in the expense report. It is the employee s responsibility to forward payment to the card issuer for these expenses. Each cardholder is personally responsible for ensuring that expense reports are completed in a timely and accurate manner and for routine reconciliation of their Corporate Card account. Delinquency fees or penalties are the responsibility of the employee and will not be reimbursed. 4. TRANSPORTATION GUIDELINES 4.1 Air travel Travelers are required to accept the lowest logical airfare available in accordance with the parameters of their travel request. 4.2 Class of service Allowable class of service is based on the following: Economy class must be booked unless the trip meets the criteria for business class travel. Business class is permissible for travel with a total duration greater than six (6) hours. First class travel is prohibited. Policy Owner: Charles Yang, Finance Director Page 4 of 13

5 Employees may upgrade their class of travel as a non-reimbursable personal expense. The employee is responsible for the difference between the lowest logical airfare in the allowable class of service and the cost of the upgraded ticket. Personal upgrades may not be charged to the Corporate Card. Any exceptions must be approved by a BU h Director /China Function Head and the China Finance Director. 4.3 Train travel Allowable class of service is based on the following: CLT, MMT, and pre-approved exceptions can take business or 1 st class seats; All others take economy class seats. Employees may upgrade their class of travel as a non-reimbursable personal expense. The employee is responsible for the difference between the allowable class of service and the cost of the upgraded ticket. Personal upgrades may not be charged to the Corporate Card. Any exceptions must be approved by the employee s direct manager. 4.4 Transportation within a city Employees are encouraged to take bus and metro for travels within a city, when it s possible and convenient. Employees are not encouraged to use their personal cars for business transportation. If employees decide to use their own vehicles for transportation, employees need to itemize the trip including distance in expense report, and get reimbursed up to RMB 2 yuan per kilometer within the limit as defined, with BU director s or China Function Head approval. Employees need to provide official invoices for gas and other personal car related expenses. In cases of accidents, employees are responsible to pay the incurred expenses by themselves. 4.5 Taxi Taxi is prohibited for transportation between cities, unless it s in an urgent or special situation and is approved by a Business Unit Director and China Finance Director. Employees can get reimbursed for overtime taxi after 8:00pm. Policy Owner: Charles Yang, Finance Director Page 5 of 13

6 5. LODGING/HOTEL ACCOMMODATION GUIDELINES Travelers are required to use company preferred hotels with which Bausch + Lomb has a negotiated rate unless another hotel is less expensive or a preferred hotel in a given area is not a viable option, as determined by the employee s manager. BU Director/China Function Head s special approval is required for any over-limit spend. Please always keep team and department travel budget in considerations when choosing hotels. Bausch + Lomb China s preferred hotels can be found in the company preferred hotel list. If a preferred hotel is not available or practical, travelers must request discount rates offered by the Designated Travel Agency or business partners when visiting a customer or service provider or others. Chart below lists out room rate limit (per night): Managing Director CLT and pre-approved exceptions MMT and pre-approved exceptions All Others Tier I Tier II Per actual and reasonable spend Tier III Travelers will be reimbursed for single-room accommodations. Suites and other higher-priced accommodations (such as deluxe views) are acceptable only when approved by BU Directors or China Function Head and China Finance Director in advance as essential to the direct conduct of business or when a viable alternative is not available. It is essential to plan appropriately in advance to avoid the circumstance where poor planning results in higher cost. If the hotel price includes breakfast and internet access, employees will not be reimbursed for those expenses. Please see Appendix A for the list of TI, TII, and TIII cities. 6. LAUNDRY AND DRY CLEANING Laundry and dry cleaning for travel over four (4) consecutive nights is reimbursable. Amount up to RMB 50 per day can be reimbursed starting from the 5 th day. Policy Owner: Charles Yang, Finance Director Page 6 of 13

7 7. MEALS, ENTERTAINMENT AND GIFTS 7.1 Meals HCPs and Other Customers Meals, beverages and refreshments with HCPs and Other Customers are permissible, but only if all such hospitalities are related to a legitimate business purpose and not offered or provided in exchange for obtaining or retaining business or any other type of benefit. Business meals must be attended by at least one Bausch & Lomb representative and accurately recorded in the Company s financial records. Further, the hospitality must be: Consistent with all known policies of the attendees organizations; Infrequent (maximum 20 times per year per individual for meals outside of the hospital or office for HCPs. Local managers will set reasonable limits for the frequency of meals with Other Customers); Conducted in a place that is appropriate for a business meeting and near the HCP or Other Customer s place of business or offered in connection with a (i) professional gathering, (ii) the promotion, demonstration or explanation of Bausch & Lomb products or services or (iii) the execution or performance of a contract; Reasonable in amount for the location (no greater than the cost limits specified in the table below): Although these spending limits are fixed for HCPs, on rare occasions they may be exceeded for Other Customers with prior written approval from the President, Asia-Pacific or Managing Director. Spend Limit RMB per person Tier I Tier II Tier III Beijing/Shanghai/ Guangzhou/Shenzhen Provincial capital cities & direct-admin cities All the other cities Not of the sort that would influence or appear to influence independent judgment. Care should be taken to not single out any particular person for special treatment as a consequence of their political status or decision making authority within a Healthcare Institution; Provided only to HCPs and Other Customers and not their spouses, family members, or any other person who has no business relationship with the Company; and Paid for directly to the restaurant or caterer and not to the HCP or Other Customer Government Officials Meals, beverages and refreshments with Government Officials are permissible, but only if all such hospitalities are related to a legitimate business purpose and not offered or provided in exchange for obtaining or retaining business or any other type of benefit. Such business meals must be attended by at least one Bausch & Lomb representative who has been authorized by the President, Asia-Pacific or Managing Director to provide such hospitalities to Government Officials. The individuals authorized to Policy Owner: Charles Yang, Finance Director Page 7 of 13

8 provide hospitalities to Government Officials must receive training regarding local and international anti-bribery laws and Company policies and procedures relating to such activities. Further, the hospitality must be: Conducted in a place that is appropriate for a business meeting and offered in connection with a (i) Government Official s visit to a Bausch & Lomb facility, (ii) discussions relating to a regulatory matter, (iii) the government s purchase of Bausch & Lomb products or (iv) other legitimate communications regarding issues related to Bausch & Lomb s business; and In accordance with all other requirements and spending limits for meals with HCPs or Other Customers. Particular care must be taken in circumstances when the Company has a pending regulatory matter before a government agency. In such circumstances, business meals with Government Officials involved in acting upon a pending regulatory matter require prior written approval from the President, Asia-Pacific or Managing Director When Inviting More Than 10 Guests If more than 10 guests (excluding Bausch & Lomb personnel) are anticipated at any one event outside of the office or hospital, prior written approval from the President, Asia-Pacific or Managing Director is required. In case where prior written approval is not practicable, written notification must be made after the event Personal meal expenses Personal meal expenses are incurred by a traveler when lunching or dining alone on an out-of-town business trip. CLT and pre-approved exceptions will be reimbursed for personal meal expenses according to actual and reasonable cost. MMT and pre-approved exceptions will be reimbursed for actual personal meals up to the limit of RMB 200 per day. All others will be paid for an allowance of RMB 120 per day (60 for lunch and 60 for dinner). If the meal is covered by other activity, related allowance must be deducted accordingly and cannot be claimed. 7.2 Entertainment Government Officials and HCPs Entertainment such as golf outings, sporting events, theater, sight-seeing trips, other leisure arrangements, and arrangements where live music is the main attraction for Government Officials and HCPs is prohibited. Policy Owner: Charles Yang, Finance Director Page 8 of 13

9 7.2.2 Other Customers Entertainment such as golf outings, sporting events, theater and the like may be provided to Other Customers, but only if all such activities: Are permitted by law; Are not lavish and serve a valid business purpose such as providing an opportunity to discuss business or strengthen customer relationships and trust; Are consistent with all known policies of the attendees organizations; Are infrequent (no more than 8 times per year per person); Are reasonable in amount for the location (no greater than the cost limits specified in the table below): Spend Limit RMB per person Tier I Tier II Tier III Beijing/Shanghai/ Guangzhou/Shenzhen Provincial capital cities & direct-admin cities All the other cities Will not influence or appear to influence the independent judgment of the attendees; Provided only to Other Customers and not their spouses, family members, or any other person who has no business relationship with the Company; Are not given in exchange for, or as a reward for, the purchase, recommendation or use of Company products or services; Are attended by at least one Bausch & Lomb employee; and Are accurately recorded in the Company s financial records. 7.3 Gifts Government Officials Offering or providing gifts to Government Officials is prohibited unless the gift is approved in advance by the Corporate Headquarters Law Department Other Customers Providing gifts is generally discouraged. However, gifts may be provided to Other Customers if all of the following requirements are fully satisfied. Policy Owner: Charles Yang, Finance Director Page 9 of 13

10 Gifts must: Serve a valid business purpose; Be given infrequently; Be reasonable, customary and of small value to a limit of RMB 200 for promotional gifts; Cultural courtesy gifts in celebration of New Year, Spring Festival, Labor Day, National Day or the Mid Autumn Festival are permitted, subject to a limit of RMB 200 per person per holiday. - Items allowed to be provided as cultural courtesy gifts include food, tea, flowers, plants, crafts or locally produced products that relate specifically to one of the listed holidays. Gifts of tobacco, alcohol or tickets to social or sporting events are explicitly prohibited. Be consistent with all known policies of the recipient s organization; Comply with all applicable advertising law requirements if the Bausch & Lomb logo is used; and Be accurately recorded in the Company s financial records. It is never permissible to give a gift: That would influence or appear to influence the independent judgment of the person receiving the gift; In exchange for, or as a reward for, the purchase, recommendation or use of Company products or services or for providing any other type of benefit in favor of Bausch & Lomb; Consisting of cash or cash equivalents; or To or for the benefit of spouses, family members, or any other person who has no business relationship with the Company except as indicated above for approved gifts at Other Customer weddings or funerals. Note: Payments or rewards for Other Customers as part of a sales incentive program are not considered gifts but are generally prohibited unless offered in accordance with the Promotional Allowances section of Code of Conduct HCPs and Healthcare Institutions Gifts may be provided to HCPs and Healthcare Institutions if they meet all of the above requirements for Other Customers and they are: Of the type that may be used in a healthcare practice for patient benefit, serve an educational purpose or are branded promotional items of small value (less than RMB 100 per item) such as books, informational posters, pens, mouse pads, and mugs. Medical textbooks, journals, magazines, e-journal subscriptions, anatomical models and diagrams may have a value of up to RMB 500 per item. Pre-paid coupons or purchase cards for these types of gifts are prohibited. Not for the personal benefit of an HCP or employee of a Healthcare Institution (except for appropriate cultural courtesy gifts). Policy Owner: Charles Yang, Finance Director Page 10 of 13

11 Gifts of music CDs, DVDs, sporting or entertainment tickets, paintings, food baskets, electronic items and cash or cash equivalents are prohibited. Cultural courtesy gifts in celebration of New Year, Spring Festival, Labor Day, National Day or the Mid Autumn Festival. - Cultural courtesy gifts are subject to a limit of RMB 200 per person per holiday. Items allowed to be provided as cultural courtesy gifts include food, tea, flowers, plants, crafts or locally produced products that relate specifically to one of the listed holidays. Gifts of tobacco, alcohol or tickets to social or sporting events are explicitly prohibited. 7.4 Payment When more than one employee is present, the most senior level employee must pay and expense the bill, listing all participants. 8. TELECOMMUNICATIONS 8.1 Telephone and long-distance calls Do not use hotel services to place calls. Hotel telephone charges for long-distance calls will not be reimbursed unless such charges were unavoidable. When on business travel, calls home are to be kept to a minimum. Employees who have 3G cards are expected to use 3G cards 8.2 Internet access charges When traveling, Bausch + Lomb will reimburse nominal internet access fees for employees who need to access the internet outside of a B + L facility. Such access must be reasonable and necessary for business, and pre-approved at travel application. If the hotel price includes internet access, employees will not be reimbursed for internet access. 9. EXPENSES REPORTING 9.1 Expense reports Travelers must submit expense reports promptly after incurring charges and no later than 2 months after the completion of travel. This allows for timely reimbursement to the traveler and to the traveler s Corporate Card account, as well as accurate recordkeeping. The Company will not reimburse delinquency charges due to late expense filing. Policy Owner: Charles Yang, Finance Director Page 11 of 13

12 9.2 Documentation The following information is required prior to expenses reimbursement: The name and location of the restaurant or event location; A complete listing of attendees (including name, title and company); The nature and purpose of the event; Any other substantiation required by local tax authorities or other regulations (e.g. state laws); Official receipts with full B+L company name and vendors chop; Credit card receipts if a corporate card is used; For individual receipt over RMB 800, and hotel receipts of any amount, employees are required to provide printed detail expenses list; or written detail expenses list with vendor chop, if the vendors cannot provide computer printed list 10. GROUP TRAVEL AND MEETINGS 10.1 General guidelines Group meetings are an important part of the on-going management and development of our business. The requirements herein apply whenever travel and/or meeting arrangements of any kind (air travel, lodging, meeting space, group meals or ground transportation) are made for 10 or more people (internal B&L employees). Examples include: Sales meetings and recognition/incentive trips (national, divisional, regional, district); Training and management meetings; New product introductions; Professional/technical meetings; and Trade shows/conventions Request for Concurrence (RFC) Process Group meetings that meet the requirement above require an RFC to be completed and Approved by the President Asia Pacific prior to making any spending commitment Lodging/Hotel Accommodation Guidelines Company encourages hotel room sharing between employees of same gender: Tier I Tier II Tier III CLT, MMT, and pre-approved exceptions Per actual and reasonable spend All Others Policy Owner: Charles Yang, Finance Director Page 12 of 13

13 APPENDIX A City Categorization Tier I as defined in this document include: Shanghai, Beijing, Guangzhou, Shenzhen Tier II as defined in this document include the provincial capital cities and zhi-xia cities (cities directly under central government): Tianjin, Chongqing, Ha er bin, Shenyang, Changchun, Shijiazhuang, Taiyuan, Xining, Jinan, Zhengzhou, Nanjing, Hefei, Hangzhou, Fuzhou, Nanchang, Changsha, Wuhan, Haikou, Lanzhou, Xian, Chengdu, Guizhou, Kunming, Huhehaote, Wulumuqi, Lasa, Yinchuan, Nanning. Tier III include all the rest cities. Policy Owner: Charles Yang, Finance Director Page 13 of 13