Policy TABLE OF CONTENTS

Transcription

1 TABLE OF CONTENTS Purpose...2 Scope...2 Background...2 Guidelines Administration of Policy Corporate Credit Cards Travel Arrangements Transportation - Air Transportation Vehicle/Rail Hotel Reservations Meals, Entertainment and Gifts Safety and Security Personal Travel associated with Business Travel Foreign Currency Conversions Documentation and Receipts Expense Reports Associate and Manager Responsibilities...12 Page 1 of 13

2 Purpose The primary purposes for this policy are to control costs, to ensure associates are properly reimbursed for business expenses and to ensure these expenses are treated appropriately for tax purposes. The policy provides minimum standards. Scope This policy covers the following: 1. Guidance to each associate regarding travel and entertainment activities performed in conjunction with Momentive business. 2. Guiding principles on the types of expenditures that do and do not qualify for reimbursement. 3. Guidance on the use of Momentive Travel Services for reservations and the corporate card for business expenses. 4. Guidance on each associate s responsibility regarding preparation, submission and management s approval of business expense reports. 5. Informs each associate of his or her responsibility to control, to properly report, and to submit travel and entertainment expenditures. This policy applies globally for all associates who travel for company business. However, it does not cover every situation that may be encountered regarding travel and entertainment expenditures. Where local laws differ or are more detailed and rigorous than those outlined in this policy, local laws and guidelines shall supersede this policy, see specifically recognized differences in the appendix or in additional guidelines documented for a specific country or region. This policy does not cover those associates who are on a short term or long term assignment. Refer to International Assignment/Ex Pat Program guidelines. Background Momentive will provide each associate with reasonable comfort and convenience when traveling for business purposes. Each associate is to exercise care and sound judgment with regard to incurring travel and entertainment expenses. These expenses are a significant cost to Momentive and control is mandatory. Each associate has full responsibility to comply with every aspect of this policy and submit only expenses actually incurred for legitimate business purposes. Associates must provide all required documentation in support of expenses. Less costly and time consuming alternatives to travel should always be evaluated as the first option before considering any travel, especially for repeat/regular meetings. Some of the alternatives to travel include web meetings and conference calls. Avoidance can be achieved through optimization and consolidation of business trips which requires advance planning and will ultimately lead to a reduction in the frequency of travel and overall travel spend. Momentive will reimburse associates for necessary and reasonable expenditures of a business nature incurred while traveling on authorized Company business. Momentive expects each associate to act with integrity and honesty. Each associate must clearly understand that non-compliance with this Travel and Entertainment Policy may result in corrective action, up to and including termination of employment. Non-compliance may also lead to delay or denial of reimbursement, suspension of company-sponsored payment privileges, or taxation of reimbursements. Guidelines 1. Administration of Policy Page 2 of 13

3 1.1 This Travel policy is administered by the Human Resources Department. Any changes to the policy require approval from the EVP of Human Resources. Any exceptions to this policy require approval. For direction on any exception contact P2P. 1.2 Administration of the Corporate Credit Card and Expense Reimbursement Tool is administered by the P2P Department. 2. Corporate Credit Cards 2.1. Where Corporate T&E credit card programs are established, frequent travelers are required to utilize the corporate card for business travel. Other means of payment such as personal credit cards or cash may be utilized if the corporate card is not accepted by the merchant. As an exception, taxis may be paid with cash or personal credit cards if necessary The associate is responsible for reviewing their corporate credit card statements monthly to ensure fraudulent charges are reported to the credit card company for reversal as well as reconciling outstanding balances with the card. Associates are also responsible for immediately reporting lost or stolen cards Associates who do not have a corporate credit card due to infrequent travel should utilize their personal credit card when asked to travel. If the associate does not have a personal credit card to utilize, and they must travel, they should consult with their manager. The manager, or a traveling co-worker, may use their corporate credit card to cover travel expenses for this associate, and expense these costs in their travel reimbursement requests These credit cards are intended for business use only. If the corporate credit card in a region offers a rewards program, you may participate; however, Momentive will not pay for any membership fees. In certain situations where international travel is required and by joining a reward program a second flight can be booked for free, the company may pay for the membership program. All such programs must be approved by a member of the Senior Leadership team Cash advances are restricted for special circumstances only. An Associate s corporate credit card will not have the ability to obtain a cash advance unless a special request is made by the Associate s Manager/Human Resources Representative and approved by the P2P Department For further details regarding corporate credit card eligibility, usage and compliance, refer to P2P-0008 Corporate T&E Credit Card Policy. 3. Travel Arrangements 3.1. All air travel arrangements must be made through the approved Travel Agency or the Company On-Line Booking tool for your country/region, where available Significantly lower fares found elsewhere are allowed on an exception basis but require contacting the approved Travel Agency first to allow them to match the price or else confirm that they cannot match or get a lower fare. Proof that this is a significantly lower fare is required when submitting the expense report. Note: The Company will not have visibility to your travel itinerary and therefore will not be able to provide travel emergency updates The Corporate T&E credit card must be used for travel arrangements. 4. Transportation - Air 4.1. All air travel shall be the lowest logical coach or discounted economy fare available, without unreasonable inconvenience (lengthy layovers, multiple connections, etc.) to the traveler. If Page 3 of 13

4 travel plans are not likely to change, travelers must purchase non-refundable fares where they are offered in the market Lowest fares, regardless of individual associate airline preference should dictate travel arrangements Airline tickets are to be purchased, whenever possible to avoid undue expense, a minimum of days in advance of the trip Business class fares require the following conditions to be eligible for reimbursement: Consult with your Manager before booking business class fares. Senior leadership may suspend business class travel regardless of the flight duration if business circumstances warrant it. Projects or events involving travel by a large number of associates may require economy/coach class regardless of flight duration. Audit reports of business class travel may be provided to Senior Leadership for review Scheduled flight time for a single leg of the trip must be greater than ten (10) hours Total travel time one-way is greater than 16 hours in a 24 hour period. Total travel time constitutes departure airport to destination airport using the most efficient itinerary If the associate is offered an upgrade at no charge Business class or special travel arrangements may be approved by Senior Leadership or Human Resources based on special circumstances or medical necessity Airline tickets purchased in advance may be expensed prior to the trip, once they are visible on the Corporate Card statement to ensure prompt payment. Managers who approve expense reports and the traveling associate are responsible for reconciling any unused airline ticket expenditures Unused Non-refundable Tickets The associate can expense non-refundable tickets but remains responsible to ensure that expensed non-refundable tickets are exchanged for future business travel. Airlines will generally allow exchanges up to one year provided you have cancelled prior to departure date. Non-refundable tickets will be forfeited if not exchanged or revised prior to the departure date creating unnecessary expense for Momentive Unused Refundable Tickets Any airline ticket credit received must be refunded to the Company or applied against a future airline ticket purchase. Questions regarding credits on your Corporate T&E Card should be directed to the P2P department Momentive does not pay for frequent flyer programs. Associates may personally join frequent flyer programs and retain points for personal use Associates should not select a flight based solely on their frequent flyer program. When making flight arrangements, lowest logical costs must be adhered to Frequent flyer miles or personal flight credits/vouchers may not be exchanged for company travel resulting in payment to the associate Due to local regulations in Finland, associates may not utilize frequent flyer programs for personal use. They may only be utilized for business use Travel to certain countries considered to be high risk may be limited or suspended. These limitations are determined by the VP EHS and will be communicated to the Senior Leadership Page 4 of 13

5 Teams as well as broadcasted on the company intranet. Any exceptions must be approved by the VP EHS Use of or piloting a personal aircraft for business purposes is not allowed. 5. Transportation Vehicle/Rail 5.1. Car Rentals: Intermediate (mid-size Class C) or smaller cars (no motorcycles) must be used unless there will be three or more persons in the car; then a full-size car may be rented If more than one associate will be driving, each driver should register at the rental counter The gas tank should be filled prior to returning the car in order for the associate to avoid costly refueling fees Associate should document any upgrades and purpose including free upgrades Insurance is to be declined on North America business rentals regardless of your home country. For all rentals other than those in the United States territories and Canada, the associate must purchase liability and property damage insurance coverage In all cases, associate must carry insurance that meets the minimum state/country legislative requirements Car Rentals International: Many countries have different customs pertaining to the use of automobiles; therefore, certain legal rights considered common in an associate s home country may not be recognized. If driving is a necessity, an international driver's license may be required. Check with the travel agency Taxis, Trains, Car Services and Other Local Transportation: Taxis, trains, and limos to and from places of business, hotels, and airports in connection with business activities are reimbursable The use of taxis is authorized only when more economical services (hotel vans, shuttles, etc.) are not available First or Business Class Rail tickets may be purchased with your manager s approval Every effort should be made to use the least expensive form of transportation and provide documentation Associates will not be reimbursed for any parking tickets or other illegal ticketing violations Personal Vehicles: Any associate who uses his or her personal automobile for Momentive business will be reimbursed at the prevailing government rate per mile/kilometer, plus necessary tolls and parking. In certain countries, the prevailing government rate is not adequate to reimburse the associate and special procedures are in place in these countries to reimburse at a higher rate. The reimbursement rate takes into consideration fair wear and tear, fuel used for the trip and coverage by associate s personal auto insurance When using a personal vehicle for business travel, this must be the lowest reasonable cost to the company vs. renting a vehicle Reimbursable business mileage is computed as miles in excess of the normal daily round trip commute between the associate s residence and their primary work location. This mileage may or may not agree with what local tax law would allow as a business deduction related to business travel. If an associate feels they are due additional miles Page 5 of 13

6 in excess of what the company has reimbursed, they may wish to consult a tax professional and determine if this can be deducted on a personal income tax return. Any expenses incurred in the associate s personal income tax return preparation are considered personal in nature and are not reimbursable by the company This policy does not cover associates who have company vehicles or are reimbursed through the company vehicle program. Refer to HR Policy Company Vehicle Program To comply with local legal requirements, personal vehicle expenses in some countries must be submitted through Human Resources and reimbursed through payroll. Please contact your Human Resources Representative or P2P department if you have any questions. 6. Hotel Reservations 6.1. Standard single-room accommodations at hotels and motels are approved. The additional cost to stay on a concierge, executive or business floor is not reimbursable unless it is the only available option. Associate should book hotel with lowest reasonable cost. See Intranet for further guidelines Associates should always keep safety in mind when traveling abroad or in high risk/high cost areas Check with the approved Travel Agency or online booking tool for preferred hotels and use where available. For selected cities, only a specific low cost hotel has been approved. Exceptions to the policy must be explained Associates are responsible for advance room cancellations to avoid a no-show penalty fee whenever possible To avoid excessive phone surcharges, the associate should make calls from the company phone at the site being visited. The associate must use his/her cell phone and/or Company phone credit card. Long-distance hotel phone service should be used in an emergency situation only. Hotel internet hook up charges are approved for business purposes, however associates should check with their manager for the appropriateness of this spend Personal charges (i.e. movie) must be charged to personal credit card. If charged to room these charges must be designated as such on the expense report and are the responsibility of the associate In the event lodging is provided free by another Company associate, business acquaintance, relative or friend, an appropriate host/hostess token gift of appreciation can be given. Reasonable expense is reimbursable. Receipts from the gift vendor (e.g. florist, restaurant, grocery, etc.) must be attached to the associate's expense report, and the name and address of the recipient must be indicated. The amount of the gift should be reasonable and less than the cost of the hotel Frequent stay program awards may be retained by the associate provided lowest logical costs are adhered to when making arrangements and the corporate travel card and preferred hotels are used where possible. 7. Meals, Entertainment and Gifts (The following does not apply to those countries with per diem regulations on meals). Page 6 of 13

7 7.1. Meals: To qualify as a meal expense, only one associate should be on the bill. More than one person sharing a meal qualifies as an entertainment expense and should be expensed as such Associate meals when traveling will be reimbursed at reasonable meal costs incurred plus a reasonable tip and should be reflected on the receipt. Many countries do not require tips or different standards may apply. Please check with your destination site for appropriate cultural rules It is the associate's responsibility to use discretion in keeping meal costs in line with acceptable business practices Entertainment/Meals - Internal Associates: This category is used for activities or events where two or more Momentive associates are present Entertainment expenses for associates at the same location are only reimbursable when incurred in conjunction with a business purpose. Business purpose means that the business discussions could not be conducted during normal business hours If multiple individuals are combined on a single restaurant bill, the most senior-level associate hosting the meal/event is responsible for the bill. If there are concerns, associates should consider separate bills. The associate should not pay for their management s meal except in extenuating circumstances which should be documented appropriately on the expense report. In these cases, approval from the Manager of the highest level attendee should be attached to the report Reasonable and customary expenses are reimbursable for meals and entertainment while the associate is conducting company business and for associates visiting from out-of-town Entertainment/Meals (External vendors or customers). This category is used for activities or events where one or more attendees are not Momentive associates Entertainment expenses for external vendors or customers are reimbursable only if they are directly related to Company business. This means that (1) business must actually be conducted either during the entertainment or immediately before or after and (2) business is conducted within the requirements of the ethics policy In order to qualify for reimbursement, employees must be able to prove the business purpose and provide documentation for the amount of each expense, the date and place of the entertainment, and the business relationship of the persons entertained In general, entertainment of customers and business associates at an employees home/residence is considered a personal expense and not reimbursable by the Company. For insurance and liability purposes, advance written approval from Management is required for reimbursement of expenses associated with entertainment in an employee s home. Reimbursement will be limited to reasonable out-of-pocket expenses appropriate for the necessary scale of entertainment. A list of attendees and a summary of the business purpose must be submitted for reimbursement Adult entertainment is not a reimbursable expense. Regardless of whether this might be an accepted business practice in some countries, Momentive will not tolerate the use of Company funds at adult entertainment establishments or for adult entertainment provided at some other location. Page 7 of 13

8 7.6. Gifts: Gifts should be charged on a department or site Procurement Card if available. Where Procurement Cards are not available the Corporate Travel card may be used and submitted in an expense report. Associates must specify recipient s name and the purpose of the gift to qualify for reimbursement For additional guidance on internal, external and gifts to officials and employees of governments please refer to the Legal Business Courtesies and Gifts Policy. 8. Safety and Security 8.1. Each associate is required to wear a seat belt (both driver and passenger) while traveling on Company business, whether using a personal vehicle or a company-owned, leased, or rented vehicle Associates are not to operate vehicles while texting, using cellular telephones or other electronic devices when hands free devices cannot be used Any associate who is involved in an incident or accident while traveling should notify their supervisor. US associates may be subject to drug and alcohol testing per the US Substance Abuse Policy. See HR US Substance Abuse Policy on the Momentive intranet Because of the inherent risk of frequent travel, travel by associates on the same airplane, automobile, train or other common carrier is restricted. No more than two Senior Management Team members may travel with the Chief Executive Officer or Chief Financial Officer. If a large percentage of associates from a division or function are traveling to the same destination, consideration should be given to limiting the number of associates on the same flight in the event of a catastrophic occurrence Travel Insurance Associates traveling internationally on behalf of the company are provided with International SOS services which are designed to assist with medical, travel, security and legal problems when associates are away from home. This worldwide health care and emergency assistance service is available 24 hours a day Accidental death and dismemberment insurance is provided by a global policy through CIGNA Please refer to Momentive@Work for additional information on SOS and CIGNA Business Travelers Insurance Airlines will reimburse for lost/damaged luggage per their policies Travel Insurance, if purchased will not be reimbursed by Momentive If the associate experiences an undue loss, they may work with their manager, P2P, and or Human Resources on a case by case basis Associates are to take precaution regarding traveling with valuable personal items and or carrying excessive amounts of cash as lost or stolen items are not covered under this policy. 9. Personal Travel associated with Business Travel 9.1. Prior written approval from a Vice President (the associate s business or functional leader) is required for combining personal travel associated with business travel. Reimbursable expenses will be limited to expenses that would have been incurred if only the associate had made the trip and limited to business activity. Definitive proof must be provided to differentiate personal Page 8 of 13

9 and business expenditures and these expense reports are subject to higher scrutiny during audits The prior written approval must be attached to the expense report and must include a clear statement of the business purpose of the trip. 10. Foreign Currency Conversions Expenses incurred in a foreign currency must be converted and reported in the country of employment If the Corporate T&E Credit Card is utilized, the exchange rate utilized on the associate s statement must be used If a personal credit card was utilized due to unavailability of a corporate card, the exchange rate from that card should be utilized All fees, including bank fees, to purchase or exchange local currency are reimbursable. The associate should attach receipts which document the exchange rate and fees. This exchange rate should be utilized on all cash transactions on the associate s expense report All other foreign transactions should utilize the prevailing foreign exchange rate for the date of the transaction. 11. Documentation and Receipts The following guidelines are applicable regardless of the expense report system and process you are using Receipts for all expenditures are required. Original receipts that detail the expense must be attached. The following is a defined exception: If you utilized the Corporate T&E Credit Card and the amount is $25 USD or less, you do not need to retain or submit the receipt. However, if your receipt contains GST or VAT taxes (such as those found in Europe, Canada, Australia and New Zealand) or your country requires receipts to be kept for all expenditures (please refer to local HR, you must submit your receipt regardless of the amount. These taxes are usually reclaimable, and often cannot be reclaimed without the receipt. Other than the exception above, copies from your Corporate Credit card bill or statement is not considered a receipt. Receipts must be easily identifiable in relation to the expense reimbursement request line items. For instance, where the Concur Expense reimbursement tool has been implemented, associates using the legacy MSC Concur system are required to reference a sequential number in the expanse report which is also written on the receipts; associates using the legacy MPM Concur system are required to put the receipts is a logical order so they are easily auditable back to the expense report Airfare charges (domestic and international) require the complete itinerary showing cost of ticket and destination (i.e. copy from your travel agency). Associates do not need to provide boarding passes if the above is provided Hotel expenses require the original bill plus credit card receipt and/or hotel folio with indication of credit card payment are required. If hotel charges contain other items Page 9 of 13

10 besides room charges, they must be itemized on your expense report. Receipts for cash tips are not required. Each night s stay should be itemized by day in order to evaluate average nightly hotel costs Car Rental reimbursement requires the credit card receipt or method of payment indicated on the car rental agreement is required Transportation: Receipts are required for transportation expenses such as parking, tolls and other auto expenses, including cabs/taxis, and car services. These require original or hand written receipts with name and address of the company. If a receipt is not available, a handwritten receipt from the vehicle driver with the transportation company's name, phone number, city, date, and amount of fare is required. Toll receipts must be submitted where available. Transponder logs are acceptable as receipts Entertainment, meal and miscellaneous travel expenses require receipts with details of what was purchased. Generic cash receipt or ticket stub is not an acceptable receipt. If this is not available, a comment should be provided as to why. Entertainment receipts should have the name and address of the establishment imprinted on the receipt. In conjunction with business entertainment, i.e., gifts, sponsorships, awards, and gift cards, you must have an itemized receipt and cost. Names of attendees should be written on the receipts unless you are utilizing an electronic reimbursement system such as Concur where the attendees are clearly defined on the expense item. For example: vendor name, item purchased, item cost should be included Cell phone bills, Internet access fees and home cable require detailed receipts. Home office expenses will be reimbursed for approved home office users only. Associates who have local access to a Momentive site are not eligible for home office expenses. Home office allowances are not reimbursed via the Travel expense process but via payroll to ensure local tax regulations are applied for these expenses. Refer to HR Home Office Policy Missing or Absent Receipts: Detailed written explanation must be given as to why receipts are not provided. Associates must understand that reimbursement for expenses for which an appropriate receipt is not provided, may be rejected and/or disallowed. Please see the only defined exception in Page 10 of 13

11 11.2. In order to facilitate VAT (Value Added Tax) retrieval in Europe, all associates globally should do the following when traveling in Europe: Hotel Bills: Request the Hotel to provide you with a tax invoice. The first line of your receipt should contain the legal entity for which you are employed. For example, if you are employed in the Pernis plant in the Netherlands, you would ask that the first line of the bill state "Momentive Specialty Chemicals B.V." or MSC B.V.. Your name may appear on the bill as well, but the first line must be your home legal entity in order for Momentive to reclaim the tax. If you are not sure of the proper legal entity name, please contact your Human Resources partner or Tax Department. Associates should always check their receipts to be sure the format is correct Car Rentals: Perform the same request as above at the time you are booking the car. Please make sure you check the receipts. 12. Expense Reports Each associate completing an expense report is responsible to fully comply with the Travel and Entertainment Policy. Associates submitting expense reports thereby are agreeing that all expenditures are reasonable, properly documented expenses are reimbursable under this policy and any exceptions to policy have prior written approval Associates must complete their expense reports within one to two (1-2) weeks of completion of travel and reasonable time for credit card transactions to be billed in order to ensure appropriate time for approval and reimbursement of expenditures. Please follow specific rules for your location regarding submission of hard copy reports. For instance, in Europe hard copies of the expense reports must be forwarded to a central location for VAT retrieval European based associates on the legacy MSC Concur system must submit expense reports within 1 week of travel or Corporate card transactions showing in Concur to accommodate the payment terms for the Corporate card When using an electronic expense reimbursement system such as Concur, associates must use the corporate credit card transaction list, for all charges associated with the corporate card. This means the associate must wait until the card transaction shows up in the list before submitting that expense. Associates should not delete corporate credit card transactions from their lists. These should always be included in an expense report. Reimbursements should be due to the corporate credit card in all transactions except when an associate had to use cash and or a personal credit card (when the corporate T&E card was not accepted or unavailable), i.e. parking, tips, tolls, etc Manager s Approval of Expense Reports - Each Manager must approve completed expense reports in a timely manner for his or her direct reports. The time frame for approval should not exceed 1-2 weeks from receipt of appropriate documentation necessary to approve the report. An alternate signing authority must be appointed to cover for the manager during absences; the manager delegating this authority takes full responsibility for the delegate signing authority s approvals. The approving Manager s signature is authorization and validation of the business purpose of the trip, validity of the attached receipts and supporting documents and signifies he/she has reviewed all documents and is in full agreement with expenses incurred Approval of expenses for European based associates in the legacy MSC Concur system must be completed within 1 week of submission to accommodate the payment terms for the travel card. Page 11 of 13

12 Delegation of approval authority may only be given upward to a higher level manager within the associate s reporting structure. VP and above may delegate to another VP or Director in their reporting structure. Director level positions and above may delegate approval authority to an administrative assistant. The manager delegating approval authority takes full responsibility for their delegate s approvals. Contact P2P with questions or requests for delegation exceptions Audit of Expense Reports - The P2P organization and Internal Audit will conduct audits regularly and have the authority to question and reject any submitted expense. Upon completion of any audit procedures (either internal or external) any associate expense report determined not to be in full compliance or properly documented will be discussed with the associate and/or manager for appropriate handling. All associates are subject to this audit procedure. Audits surfacing non-compliance with the Corporate T&E Credit Card policy and/or the Travel and Entertainment policy may result in warning of card removal, escalation to management, Internal Audit and/or Human Resources, suspension of the card or card cancellation as well as corrective action up to and including termination and subject to local laws 13. Associate and Manager Responsibilities Associate Responsibilities: Each associate is responsible for the following: Determining if there is a way to meet business objectives without traveling. Teleconferencing or videoconferencing may meet business needs and result cost and less time away from home and work; Reasonably managing how Momentive s funds are spent and providing details as to the business reason for those expenses through the expense report process; Ensuring that all expenses incurred are in compliance with the standards of business conduct set out in Momentive s core values and Ethics Policy; Taking proper precautions while traveling to ensure personal safety and to prevent theft or loss of Momentive property (e.g. tickets, computers, documentation) by keeping valuable property close at hand or locked in a secure location; Complying with the Momentive Travel Policy requirements; Reviewing their expense report before it is submitted; and Ensuring that they are aware of and are in compliance with the International Personnel Security Procedures. If travel to a restricted country is necessary, written approval must be given by an EVP prior to departure and the associate must make themselves familiar with the risks of the country Manager Responsibilities: Managers are responsible for the following: Ensuring associates understand the Momentive Travel Policy; Reviewing and validating associate s expense reports to ensure that they are reasonable and consistent with business travel requirements; and Taking necessary steps to investigate any suspected violations of the Momentive Travel Policy and taking appropriate action (including corrective action, where warranted) when violations have been confirmed. References: International Assignment/Ex Pat Program guidelines P2P-0008 Corporate T&E Credit Card Policy Page 12 of 13

13 HR Policy Company Vehicle Program Legal Business Courtesies and Gifts Policy HR US Substance Abuse Policy HR Home Office Policy Momentive s core values and Ethics Policy HR-8002 Approved Expense List Travel & Entertainment Site on Momentive@Work International Personnel Security Procedures Page 13 of 13