CSS INDUSTRIES, INC. EMPLOYEE TRAVEL AND BUSINESS EXPENSE POLICY

Transcription

1 I. PURPOSE Issued: 05/01/2007 Revised: 01/26/2011 Effective: 01/31/2011 CSS INDUSTRIES, INC. EMPLOYEE TRAVEL AND BUSINESS EXPENSE POLICY The purpose of this Policy is to provide specific procedures for the payment or reimbursement of certain travel and business expenses by CSS Industries, Inc. ( CSS ) and each of its U.S. affiliates (each, a Business Unit ). Company, as used in this Policy, means CSS or a Business Unit, as applicable. It is the policy of the Company to reimburse employees for actual, eligible travel and/or business expenses incurred on the Company s behalf while employees are engaged in authorized Company business. Eligible travel expenses do not include expenses relating to regular travel to and from an employee s normal workplace. All eligible travel and business expenses will be reimbursed in accordance with the terms and conditions of this Policy. Travel and business expenses represent a significant operating cost for the Company. Travel and business expenses should be necessary, customary and reasonable, and should be incurred on a basis consistent with the nature of the business assignment. When incurring travel and/or business expenses on behalf of the Company, Company employees are expected to use best efforts and good judgment to minimize the cost of such expenses, and to avoid all non-essential or unnecessary expenses. Extravagant or excess expenditures are not consistent with the intent of this Policy. In providing reimbursement of travel and business expenses under this Policy, it is the intent of the Company to comply with the rules, regulations and guidelines promulgated from time to time by the United States Internal Revenue Service ( IRS ) relating to corporate travel and business expenses. Accordingly, notwithstanding any provision in this Policy to the contrary, in the event that any provision of this Policy conflicts with then current IRS rules, regulations and/or guidelines relating to corporate travel and business expenses, the pertinent IRS rules, regulations and/or guidelines will prevail. II. POLICY ADMINISTRATION This Policy shall be effective as of the effective date shown above with respect to expenses incurred on or after such date, and supersedes all prior policies, agreements or practices, whether formal or informal, written or unwritten, of CSS or the Business Units under which CSS or any Business Unit reimbursed its employees for travel and/or business expenses prior to the effective date of this Policy. Certain CSS policies currently in effect, including without limitation the CSS Code of Ethics, the CSS Group Travel Policy, the CSS Vehicle Use Policy and the CSS Employee Relocation Assistance Policy, set forth terms and conditions relating to Company travel and/or business conduct. Except for any specific provisions in such CSS policies which specifically proscribe the method of reimbursement of Company travel and/or business expenses, the terms and conditions of this Policy are not intended to supercede, modify or otherwise affect any provision of any other CSS policy, all of which remain in full force and effect. 1

2 Reimbursement for eligible travel and business expenses will be made in accordance with the terms and conditions of this Policy. The Company is not obligated to reimburse any expense which fails to meet, in the sole discretion of CSS President, CSS Vice President Finance, CSS Vice President Legal and Human Resources, or any Business Unit President, the terms and conditions of this Policy. Employees who intentionally submit false or misleading expense reports, or who intentionally violate any provisions of this Policy, shall be subject to disciplinary action, including without limitation termination of employment. In providing reimbursement of travel and business expenses under this Policy, it is the intent of the Company to comply with the rules, regulations and guidelines promulgated from time to time by the IRS relating to corporate travel and business expenses. Accordingly, notwithstanding any provision in this Policy to the contrary, in the event that any provision of this Policy conflicts with then current IRS rules, regulations and/or guidelines relating to corporate travel and business expenses, the pertinent IRS rules, regulations and/or guidelines will prevail. Items that do not meet the IRS rules, regulations and/or guidelines as legitimate company expenses will be treated as additional compensation to the employee and the tax liability will be the employee s responsibility. The Finance Department of each Business Unit is responsible for the implementation and operation of this Policy by such Business Unit. CSS Vice President Finance and CSS Vice President Legal and Human Resources are responsible for the overall implementation and operation of this Policy by CSS. If a determination or approval by the Company is required under a particular section of this Policy, but an authorized person is not otherwise specified, it shall be deemed to be the senior executive of the applicable Business Unit s Finance Department or either CSS Vice President Finance or CSS Vice President - Legal and Human Resources, as the case may be. Requests for interpretation of this Policy may be submitted to CSS Vice President Finance or CSS Vice President Legal and Human Resources for review. Any decision of CSS Vice President Finance or CSS Vice President Legal and Human Resources shall be at the sole discretion of such individual, and shall be final and conclusive. CSS reserves the right, in its sole and absolute discretion, to modify, change, suspend, cancel or terminate this Policy at any time, and from time to time, without notice. Any modification, exception or variation to this Policy must be approved in writing in advance by CSS President or CSS Vice President Legal and Human Resources. III. REIMBURSEMENT PROCEDURES Overview All requests for reimbursement should be prepared and submitted for approval, in the manner provided in this Policy, on the form of expense report as may be approved for use from time to time by the applicable Company (the Expense Report ). 2

3 Expense Reports Preparation: Each employee is responsible for the preparation and submission of his or her requests for reimbursement of all eligible travel and business expenses. Appropriately completed Expense Reports should be submitted within fourteen (14) calendar days after the later of the (a) incurrence of the applicable travel and/or business expense or (b) the conclusion of the business-related event for which the expense was incurred. No otherwise eligible travel and/or business expenses will be eligible for reimbursement if an appropriately completed Expense Report is not submitted within ninety (90) calendar days after the later of (a) incurrence of the applicable travel and/or business expense or (b) the conclusion of the business-related event for which the expense was incurred. An Expense Report must be used to request reimbursement for all eligible travel and business expenses. Expense Reports must be legible and in ink or typed. All Expense Reports having more than one (1) page should have the total appearing on the front page in U.S. Dollars. Documentation: Receipts for all expenses should be obtained as a matter of business practice. So that the Company may comply with IRS rules, regulations and guidelines on travel expense substantiation, and to attempt to ensure that appropriate eligible expense reimbursements are not reported to the IRS as personal income to the employee, each employee submitting a request for reimbursement of eligible travel and business expenses must provide appropriate documentation and receipts as may be specified by this Policy or as may be requested from time to time by the Company, in its sole discretion. Except as otherwise specifically described in this Policy, all eligible reimbursable expenses exceeding Ten Dollars (US$10.00) must be supported by an original, itemized receipt, invoice, bill or credit card statement and must contain information detailing the date, purpose, names, and titles of people involved. A credit card summary billing for a month is not an acceptable form of receipt. Photocopies and faxes of supporting documentation will not be accepted. If a receipt is lost or unavailable, a note should be attached to the Expense Report detailing expenditure type, amount of expenditure, date and the reason that the original receipt, invoice, bill or credit card statement cannot be attached. In addition, for the reimbursement of business meal and entertainment expenses, the following documentation is required by the IRS, and must be recorded on the Expense Report: Names, occupations or other designations of individuals present, and company name, Name and location of where the meal or event took place, Exact amount and date of the expense, Specific business purpose and nature of business discussed, and In the case of entertainment events, the specific time the business discussion took place (i.e. before, during, or after the event). 3

4 If the submitted expenses relate to more than one meeting or activity, it is important that the expenses for each meeting and activity be clearly defined. All employees are required to certify and sign their completed Expense Reports, verifying that they have incurred the expense(s) set forth on the Expense Report on behalf of the Company. Prior to signing the Expense Report, the employee is responsible for ensuring that the Expense Report is accurate and has been prepared in accordance with the terms and conditions of this Policy. After signing the Expense Report, the employee should submit the Expense Report for approval, in the manner specified in this Policy, and should retain a copy of the Expense Report for the employee s records. Vehicle Rental: All vehicle rental expenses must be documented with a valid receipt. Rental vehicle receipts should be electronic, rather than handwritten, whenever available, and show the final charge. Rental contracts are not acceptable as support for reimbursement of the rental vehicle expense. Employees who receive a Company car allowance are ineligible to rent vehicles for local travel. Transportation Taxi, Train, Limousine and Bus Usage: Receipts must be provided for any and all taxi, train, limousine and bus usage expenses (excluding, where appropriate, reasonable tips and gratuities). Receipts should be electronic, rather than handwritten, whenever available. Lodging: All lodging receipts, regardless of amount, must be documented with a valid receipt. Lodging receipts must have the employee s name listed and must include information relating to the room rate, all incidentals being submitted for reimbursement, and taxes. Lodging charges must be properly classified and itemized by day when reporting expenses. Summary pages from credit card bills are not acceptable for this category of expense. Meals and Entertainment: Meal and beverage receipts are required for each submitted expense, regardless of the amount of such expense (by way of example, a receipt should be submitted with a request for reimbursement of a nominally priced snack). If the receipt is for more than one person, the names of all people involved must be written on the receipt or expense report form. Summary pages from credit card bills are not acceptable forms of receipt for this category of expense. Expenditures in a Foreign Currency: For purposes of conversion of expenses incurred in a foreign currency, the employee submitting the expense should: Obtain the foreign exchange rate for the first day of the applicable stay from either the Company s designated corporate credit card service or from an appropriate Internet currency exchange rate listing; Write the rate used on the primary lodging bill, and use this to convert all funds to US dollars; When the credit card statement arrives, forward a copy to the Company s Accounts Payable Department for comparison; and If the Company s Accounts Payable Department provides the employee with a note listing differences, the employee should submit such differences on a supplemental Expense Report. 4

5 Approval: Appropriately completed Expense Reports should be submitted for approval in accordance with the applicable Company s approved authorization process, as such process may be in effect from time to time. Once completed and signed by the employee, the Expense Report must be reviewed and approved in writing by the submitting employee s supervisor, or in the unavailability of the submitting employee s supervisor, the Company s President or a Company Vice President. Expense Reports for Business Unit Presidents must be reviewed and approved in writing by CSS President, or in the unavailability of such individual, CSS Vice President Finance. The individual reviewing and approving the Expense Report is responsible for ensuring that the submitted Expense Report is in compliance with the terms and conditions of this Policy. Written approval can be in the form of an original signature or an electronic message transmitted directly by the applicable approving employee using such employee s Company authorized account. An expense report will be honored for payment when it has been reviewed and approved in writing in accordance with this Policy. If approved in writing in accordance with this Policy, the approved Expense Report should be forwarded to the Company s Accounts Payable Department for processing and payment. Payment: Once all approvals are obtained, an approved Expense Report should be forwarded to the Company s Accounts Payable Department for processing and payment. Expense reimbursement checks typically should be processed in the Company s next scheduled Accounts Payable Department/Payroll check run, allowing for processing time. Use of Company Credit Cards The Company may provide, in its sole discretion, a corporate credit card to certain employees whose positions require regular travel. If provided, the Company expects that the applicable employee will use the Company corporate credit card solely for Company travel and business expenses, and that the employee will not use personal credit cards for Company travel and business expenses unless circumstances prevent use of the Company corporate credit card. If provided, all travel expenses, including automobile rental and hotel charges, but excluding airline and train tickets, must be charged to the Company corporate credit card. All airline and train tickets will be charged to a Company travel account. IV. ELIGIBLE REIMBURSABLE TRAVEL AND BUSINESS EXPENSES The following expenses are eligible for payment or reimbursement under this Policy, subject to compliance with the terms and conditions of this Policy: Transportation Air Travel Unless otherwise determined by the Company, all airline ticket reservations and purchases must be made through Travel Leaders and/or the CSS Cliqbook online booking tool. Appropriate usage of the Cliqbook online booking tool is limited to basic, US and Canada, roundtrip bookings to one destination. All flights to more than one destination, and all international flights with the exception of Canada, must be made through Travel Leaders. 5

6 Any travel reservations made through Travel Leaders and/or the CSS Cliqbook online booking tool which are outside of the Standard Operating Procedure established with Travel Leaders will be automatically directed to such Company employees as the Company shall designate from time to time in order to approve travel arrangements in accordance with this Policy. All travel arrangements which are within Company policy shall be directed to the applicable Company employee s supervisor for notification purposes only. Employees are required to fly in Coach Class, unless a free upgrade to Business Class or First Class is available or unless otherwise generally authorized by CSS President. Employees with certain physical conditions/disabilities may use Business Class with the written approval of the applicable Company President. For all international flights, with the exception of Canada, the applicable Company President or CSS President must be notified in advance of, and must pre-approve, all international travel. No Business Class seating may be approved by the applicable Company President for international flights unless one or more of the following conditions is satisfied: (a) the applicable employee has certain physical conditions/disabilities that require the use of Business Class seating, and such physical conditions/disabilities are reviewed with CSS Vice President Legal and Human Resources; (b) the applicable employee is a Company President or a Company Vice President who directly reports to the applicable Company President; or (c) the use of Business Class seating for the applicable employee has been approved in advance by CSS President. International travelers also should refer to Section VI of this Policy for international travel guidelines. All Company employees, and the Company approved travel agency or travel website, should seek the lowest fare between origination and destination based upon the authorized seating class. Additional hotel and ground transportation costs should be considered when evaluating the use of alternate airports. Employees are encouraged to book reservations for airline travel at least twenty-one (21) days in advance to take advantage of advance purchase discounts. A time window of at least three (3) hours should be used to determine whether a lower-priced alternative flight should be booked (i.e. if a 4:00pm flight time is desired, but a lower priced alternative is available at 5:30pm, then the later flight time should be used). Travelers should choose only non-refundable tickets. Because making changes to airline tickets can be costly, it is expected that every effort be made to make firm and sensible travel plans which will not require changes after ticketing. Because of the complex and dynamic nature of airline ticketing rules, Cliqbook may not be used for making changes to booked flights. When travel plans must be changed, travelers or CSS designated travel arrangers must directly contact a Travel Leaders agent via telephone or to make the change. It is expected that an appropriate effort will be made by employees to exchange unused airline tickets before purchasing a new ticket on a different airline. 6

7 Employees may use frequent flyer credits for personal use, but earning frequent flyer credits should not interfere with strict adherence to booking flights in accordance with this Policy. Employees may not insist on the use of a particular airline in order to accumulate mileage with such airline if an alternate carrier offers a lower fare for the same itinerary. Transportation Personal Automobile Usage If an employee is not entitled to receive a Company-paid car allowance or leased vehicle, and Company owned or leased automobiles or vans for general employee use are located at the employee s worksite, then the employee must reserve and use such vehicles before using his or her personal vehicle or renting a vehicle. For car trips exceeding 300 miles, employees are encouraged to consider using rental vehicles rather than personal vehicles if the cost of using a rental vehicle is less than the cost of mileage reimbursement for using a personal vehicle. Employees will be reimbursed on a mileage basis for use of their personal car for Company business purposes. The reimbursable rates will be set from time to time by CSS Vice President-Finance, in his or her sole discretion, based upon factors such as the reimbursable rates established from time to time by the IRS. In no event will the reimbursable rate exceed the then applicable reimbursable rate established by the IRS. The actual cost of highway and bridge tolls will be reimbursed. If an employee's personal auto is used for Company business purposes, the employee is required to maintain insurance coverage as required by the CSS Vehicle Use Policy. If the employee s personal vehicle is involved in a traffic accident while the employee is on Company business, the individual should pursue arrangements with their individual insurance company and the Company may, at its sole discretion, reimburse the employee s insurance deductible after receiving and reviewing all appropriate documentation (such as an accident report, insurance policy, and proof of deductible paid as a result of the accident). If there is more than one employee traveling in the same area, such employees should share the same vehicle (to the extent permitted under the CSS Group Travel Policy). Transportation Rental Vehicle Usage Employees who receive a Company car allowance are ineligible to rent vehicles for local travel. If an employee is not entitled to receive a Company-paid car allowance or leased vehicle, and Company owned or leased automobiles or vans for general employee use are located at the employee s worksite, then the employee must reserve and use such vehicles before using his or her personal vehicle or renting a vehicle. 7

8 Unless otherwise determined by the Company, all vehicle rentals must be made through Travel Leaders and/or the CSS Cliqbook online booking tool. Employees should use a Company-designated vehicle rental provider unless an employee can document that the day rate charged by a non-company-designated vehicle rental provider is at least US$5.00 less expensive than the lowest day rate available from a Company-designated vehicle rental provider for a comparable vehicle. The CSS Cliqbook online booking tool will display the Company-designated vehicle rental provider, if any. An intermediate/mid-sized automobile is permitted for use; however, if less than three (3) employees are traveling together, then the use of an economy/compact size automobile is encouraged. Rentals of larger vehicles must be evaluated on an individual basis (by way of example, additional employees, customers, or vendors sharing the vehicle, inclement weather that may require the rental of a larger vehicle). If there is more than one employee traveling in the same area, such employees should share the same vehicle (to the extent permitted under the CSS Group Travel Policy). Insurance should be declined or waived for the navigation system, and for collision, liability and personal accident insurance, as coverage is provided under CSS insurance policies. The actual cost of highway and bridge tolls, and the actual cost of gasoline used in the rental vehicle, will be reimbursed. Employees must pay for such costs with a Company corporate credit card whenever possible. Rental vehicles should be filled with regular gasoline prior to their return to the rental car company. Optional Navigational System (GPS) should be declined. Directions can be obtained at no charge through Google Maps, Map Quest, GPS Navigational Software Nav4All, the Cliqbook website or at a car rental counter. Transportation Taxi, Train, Limousine and Bus Usage The actual cost of taxi, train, limousine and bus usage for Company business purposes will be reimbursed. Employees should pay for such usage with a Company corporate credit card whenever possible; provided, however, that all airline and train tickets will be charged to a Company travel credit card account. Employees are encouraged to balance the cost of public transportation to and from the airport with the cost of long-term airport parking. Employees should drive to the airport if the intended business trip is scheduled for less than five (5) calendar days and the cost of parking is less than the cost of a round trip taxi or limousine ride. Long-term airport parking should be used in lieu of short-term airport parking whenever time permits. 8

9 Limousine or car services should not be used unless business reasons preclude the use of more economical modes of transportation. Applicable circumstances include, without limitation, the following: Overseas flights with departures from airports which are one (1) hour or more from the employee s home Transportation of multiple employees into congested cities (to the extent permitted under the CSS Group Travel Policy) Customer visits, with the prior written approval of the Company s President Recruiting, with the prior written approval of the Company s senior Human Resources executive. Limousine or car service reservations should be made through Travel Leaders. Lodging Unless otherwise determined by the Company, all hotel reservations must be made through Travel Leaders and/or the CSS Cliqbook online booking tool. If it is not possible to make a hotel reservation through Travel Leaders and/or the CSS Cliqbook online booking tool, the traveling employee has the responsibility of securing reasonable lodging cost. The CSS Cliqbook online booking tool will display Company-preferred hotels with negotiated corporate rates. Travelers should use, as much as possible, hotels with whom the Company or Travel Leaders have negotiated corporate rates. Employees will be reimbursed for the actual and reasonable cost of lodging; provided, however, that the maximum daily aggregate amount to be reimbursed does not exceed, without the prior written approval of such Company s President or Vice President Finance, the greater of (a) Two Hundred Fifty Dollars (US$250.00) or (b) the maximum per night rate established by the applicable Company. No portion of the foregoing per day allowance may be carried to any other day. A standard room in a moderately priced business class hotel (such as Hampton Inn, Holiday Inn Express, Best Western, Fairfield Inn or Marriott Courtyard) is the Company standard. Deluxe, suite or luxury accommodations, and the use of first class hotels, will not be reimbursed unless other rooms are not available at hotels in the immediate area or without the prior written approval of the applicable Company s President or Vice President Finance. 9

10 Meals and Beverages Personal Meals: Personal meals are meals in which an employee dines alone during a Company out-oftown business trip. Employees will be reimbursed for the actual and reasonable cost of personal meals (breakfast, lunch and dinner expenses); provided, however, that the maximum daily aggregate amount to be reimbursed does not exceed Sixty Dollars (US$60.00); and if an employee chooses not to attend a hosted meal arranged as part of the business trip, then such employee will not be eligible to receive reimbursement for any alternate meal expense. No portion of the per day allowance above may be carried over to any other day. Business Meals: Business meals are meals in which an employee dines with Company customers, vendors, or employees, during which a specific Company business discussion takes place. Employees will be reimbursed for the actual and reasonable cost of business meals (to the extent permitted under CSS Code of Ethics); provided, however, that employees will be reimbursed for business meals with other Company employees only when: at least one Company employee is from out of town; for confidentiality reasons, business must be conducted off Company premises; or the business meal is authorized by a Company senior executive for testimonial, reward, recognition or other appropriate business purposes. When more than one Company employee is present at a business meal, the most senior level Company employee must pay and expense the bill, ensuring that someone other than those in attendance approves the Expense Report. Entertainment Employees will be reimbursed for the actual and reasonable cost of entertaining customers (to the extent permitted under CSS Code of Ethics). Entertainment events eligible for reimbursement must satisfy all of the following requirements: The individual entertained has a potential or actual business relationship with the Company, and a business discussion takes place during, immediately before, or immediately after the event. 10

11 The following entertainment expenses are eligible for reimbursement (to the extent permitted under CSS Code of Ethics): Concert and theater tickets, Sporting event tickets, Tennis court fees, Golfing green fees, Transportation to and from the event, and Meals and beverages consumed at the event. If listed separately from meals, the expense receipt must show the people involved and the reason for the expense. No entertainment expenses without appropriate receipts will be reimbursed. The Company reserves the right to deny any entertainment expense which fails to meet IRS requirements regarding entertainment expense substantiation. Other Laundry: Reasonable laundry and valet services in a hotel or by a service near a hotel will only be reimbursed when the employee is required by the Company to be away from home on Company business for five (5) consecutive calendar days or more. Such expenses may not exceed One Hundred Dollars (US$100.00) for every five (5) consecutive calendar days of travel. Parking: Reasonable airport, hotel, or parking lot expenses will be reimbursed for Company business purposes. Employees are encouraged to balance the cost of public transportation to and from the airport with the cost of long-term airport parking. Employees should drive to the airport if the intended business trip is scheduled for less than five (5) calendar days and the cost of parking is less than the cost of a round trip taxi or limousine ride. Long-term airport parking should be used in lieu of short-term airport parking whenever time permits. Telephone, Facsimile and Telegraph: All reasonable business related telephone, facsimile and telegraph charges, including without limitation reasonable hotel Internet access charges, are reimbursable while on Company business. An original receipt, calling card statement, or another bill with a detailed listing must support each expense. Personal calls of a reasonable nature are allowed while traveling on Company business. Whenever possible, the least expensive means of making a call should be used (such as the use of calling cards or cellular telephones instead of dialing direct from a hotel line). Travel coordinators should provide a traveling employee with a pre-paid phone card if the employee does not have a cellular telephone to use for personal calls. An original receipt, calling card statement, or another bill with a detailed listing must support each expense. 11

12 Reimbursement of hotel telephone charges, other than reasonable hotel Internet access charges, are prohibited if the employee has a cellular telephone with available minutes or a Company issued phone card. Fitness Center: Employees are encouraged to exercise while traveling on Company business. If a hotel does not provide a free fitness center, an employee may be reimbursed for the reasonable cost of off-site or fee-based exercise services actually used by such employee while traveling on Company business. Such expenses may not exceed Fifty Dollars (US$50.00) for every ten (10) successive calendar days of travel, and do not include spa-related services. Tips and Gratuities: Reasonable tips and gratuities for services provided to employees on Company business will be reimbursed. Examples of reasonable tips and gratuities include Two Dollars (US$2.00) per day for maid service and One Dollar (US$1.00) per bag for bellmen/porter/skycap. Tips for meal service should be included on the meal receipt, and should be in accordance with local practice (but no more than 20% of the bill). Tips for cab drivers should be included in the cab receipt. Any tips considered excessive by the Company will not be reimbursed. As a general rule, employees should not tip more than they would on a personal trip. Special Costs Relating to International Business Travel: When a passport or visa, or medical immunization, is required for international business travel, reasonable direct costs incurred by an employee with obtaining and renewing a passport or visa, or with obtaining the medical immunization, will be reimbursed by the Company. Professional Fees and Expenses: Reasonable travel and business expenses relating directly to the employee s position with the Company, such as professional licensing fees, membership fees and dues to professional organizations and associations, and professional reading materials, will be reimbursed. Miscellaneous Expenses: An employee may be reimbursed for reasonable travel and business expenses not specifically identified in this Policy if (i) such expenses are incurred on the Company s behalf while the employee is engaged in authorized Company business and (ii) either (a) such expenses are approved in writing by the applicable Company President if the aggregate expenses are less than Five Thousand Dollars (US$5,000.00) or (b) such expenses are approved in writing by CSS Vice President - Finance if the aggregate expenses equal or exceed Five Thousand Dollars (US$5,000.00). 12

13 V. INELIGIBLE REIMBURSABLE TRAVEL AND BUSINESS EXPENSES The following expenses are not eligible for payment or reimbursement under this Policy, unless specifically approved in writing by the Company: personal care, such as toiletries, hair care, massages, spa visits; rental of safe deposit boxes for personal valuables; travel expenses of any family members or companion accompanying any employee on a business trip are not reimbursable unless the specific travel expenses are authorized in advance in writing by the applicable Company President, in his or her sole discretion; travel expenses relating to regular travel to and from an employee s normal workplace; expenses involved in any pre or post-tour for any meeting or convention; tips for tour guides/drivers, unless part of official program; medical expenses, such as medicines; personal credit card fees; points capturing fee for credit cards; costs relating to the purchase of, and to the loss or theft of, luggage or briefcases; fees and fines for violation of laws (traffic or parking); personal entertainment or recreational expenses, such as golf, tennis, or movies or video games (regardless of whether in an airline or hotel); babysitting fees; country club memberships and dues; pet care and kennel costs; reading materials, including newspapers, which are not directly related to the employee s position with the Company; tobacco products; the cost of travel insurance; any land-line telephone charges (hotels, payphones, etc.) if the Company pays for, or reimburses the applicable employee for, such employee s use of a cellphone (unless the use of a cellphone is not available or practicable at the time of the use of the land-line telephone call); airline club fees not approved by the Company s President; additional fees for airline seat upgrades within coach/economy; and additional fees for Navigational System (GPS) with rental vehicles. Exceptional circumstances in a specific case may be considered. 13

14 VI. INTERNATIONAL TRAVEL GUIDELINES All international travel should be arranged in accordance with this Policy. Travel Advisory Review Prior to booking international flights, the employee is required to review government websites for travel alerts and warnings. As guidance changes constantly, traveling employees must also review the government websites 48 hours prior to departure to ensure there have been no changes in travel warnings. Sites to be reviewed are: (1) The U.S. Department of State at (2) The Center for Disease Control (CDC) at If the U.S. Department of State or the CDC has issued a warning advising against travel to a specific destination, approval must first be obtained from the CSS Vice President of Human Resources. It is also advised that employees review the latest airport security measures for international flights prior to travel. Information can be found on the Transportation Security Administration (TSA) website at Vaccinations and Other Health Precautions Prior to travel, employees should review the CDC website for guidance on recommended vaccinations and other health precautions. The Company strongly recommends that employees follow the CDC recommendations. Employees can be reimbursed (through an expense report) for the cost of recommended vaccinations that are not covered by the employee s medical insurance. Proper Documentation Prior to booking international flights, the employee or designated travel coordinator is required to review the entry and exit requirements of all foreign countries on the travel itinerary and secure the required documents prior to departure. Information on entry and exit requirements can be obtained from: (1) The U.S. Department of State at (2) Embassy websites (3) Passport and visa service companies such as or No international flights should be booked if the employee will not be able meet the entry or exit requirements. Medical Issues While Traveling Abroad Prior to embarking on an international trip, employees are advised to obtain a MEDEX International Travelers Assistance card from their Company travel coordinator. MEDEX can assist you in locating medical care, monitor your medical progress during the course of your treatment and recovery and arrange for emergency evacuation if medically necessary. 14

15 The voluntary medical plan currently offered by the Company, if an employee elected to participate in such plan, does cover emergency medical care in foreign countries (subject to applicable co-pays and deductibles). Employees who do not participate in the Company s medical plan should review their own policies prior to travel. If the medical issue is work related, the claim will be handled through the Company s workers compensation provider. In the case of a work related medical issue, the employee should notify the Company s Health, Safety and Environmental Manager as soon as possible. Emergency Assistance While Traveling Abroad If an employee encounters an emergency situation (e.g., civil unrest, natural disaster, legal problems, hospitalization) while traveling abroad, the employee should immediately notify his or her Manager and contact the U.S. Department of States Bureau of Consular Affairs or the U.S. Embassy for guidance. The Bureau of Consular Affairs can be reached at or, from overseas, Contact information for Embassies, along with guidance on how to handle emergency situations, can be found on the U.S. Department of State s website at Once a Manager becomes aware that an employee is in need of emergency assistance, the CSS Vice President of Human Resources should be immediately notified. 15