Forest City Enterprises Travel & Entertainment Policy

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1 SECTION III: GENERAL ADMINISTRATION POLICIES PAGE 1 OF 9 SECTION TABLE OF CONTENTS PAGE I. PURPOSE... 2 II. KEY CONTACTS.. 2 III. DEFINITIONS. 3 IV. FORMS, ROLES & RESPONSIBILITIES... 3 V. ADMINISTRATION, COMPLIANCE & ENFORCEMENT... 4 VI. POLICY PROVISIONS Corporate Card Program 5 2. Corporate Travel Agency Direct Charges to the Company Traveling Companions or Personal Travel Combined with Business Trip 5 5. Associates Traveling Together Air Travel Lodging Rental Cars and Transportation Meals and Entertainment Non-Employee T&E Expenses Non-Reimbursable Expenses Company and / or Departmental Gatherings International Travel Out of Town Work Assignments. 8 EXHIBIT A GROUP MEETINGS

2 SECTION III: GENERAL ADMINISTRATION POLICIES PAGE 2 OF 9 I. PURPOSE This document outlines the Travel and Entertainment ( T&E ) policy (the Policy ) for the Associates of Forest City Enterprises and its affiliates ( Company ) who incur T&E expenses while conducting Company business. The objectives of the Policy are to: Ensure all Associates have a clear and consistent understanding of the policies for incurring business T&E expenses. Provide Associates with appropriate levels of service, safety, and comfort while minimizing enterprise-wide T&E expenses. Maximize the Company s ability to negotiate competitive pricing, rebates and service with Preferred Vendors. Ensure neither financial gain nor loss for Associates. Ensure compliance with applicable tax laws. In developing the Policy, every attempt was made to ensure the consistency to the Company s other administrative policies including the Code of Legal and Ethical Conduct ( Code of Ethics ). In all circumstances, the Code of Ethics takes precedence over the Policy in the event of inconsistencies or lack of clarity. As a general guideline, T&E expenses must be consistent with the needs and policies of the Company. Associates should neither lose nor gain financially as the result of Company T&E. Associates should use the same discretion with the Company s money as they do with their own money. II. KEY CONTACTS Administrative Contacts Samantha VanDerbosch Accounts Payable samanthavanderbosch@forestcity.net Terminal Tower Ste Jim Criswell Internal Audit jimcriswell@forestcity.net Terminal Tower Ste Jeff Dodig Procurement jeffdodig@forestcity.net Terminal Tower Ste Procurement Department Intranet Site Corporate Travel Agency => AMERICAN EXPRESS TRAVEL Kim Bell Travel Agent kimberlybell@forestcity.net Forest City Travel line [Customer Code = A-DE0] American Express Travel On-line Booking Tool: Corporate Card Program => AMERICAN EXPRESS CORPORATE CARD PROGRAMS Jan Gilbert Corporate Card Administrator jangilbert@forestcity.net Terminal Tower Ste Card Options: 1. Corporate Card American Express Corporate Card 2. Platinum Card American Express Corporate Platinum Card 3. Meeting Card American Express Corporate Meeting Card American Express Card Services (Customer Hotline) (toll free) or (collect call outside the United States) Corporate Card Intranet Site: III. DEFINITIONS

3 SECTION III: GENERAL ADMINISTRATION POLICIES PAGE 3 OF 9 Business Class A class of seat available on most international flights that allows for more comfort and amenities than economy and domestic first-class seats and less amenities than international first-class seats offered by most airlines. Business Mileage The actual miles driven in the Associate s personal car in excess of an Associate s normal commute to work when traveling on Company business. In other words, if an Associate lives 10 miles from their office, Business Mileage begins after the first 20 miles regardless of the destination. Frequent Traveler An Associate that traveled outside of their home state at least 10 times in the previous calendar year as documented by Corporate Travel Agency. Group Meetings (See Exhibit A) Business gatherings, team building activities, Associate training, trade shows, seminars, and other business events attended by five (5) or more Associates involving air, car and / or hotel reservations. Lowest Logical Fare The rate provided by the Travel Agent allowing Associates to receive the lowest fare for a requested route meeting both of the following criteria: The flight does not increase the round trip by more than two hours compared to the requested itinerary, and The flight does not extend the departure / arrival time by more than two (2) hours. The Travel Agent may suggest an alternative airport when considering the Lowest Logical Fare parameters. Preferred Vendor A vendor relationship negotiated and/or maintained by the Procurement Department to provide the best value at the lowest cost to our Associates who incur T&E expenses while conducting Company business. Associates should contact the Corporate Travel Agency for the most current details of our Preferred Vendor contracts as they are updated regularly. The Company has Preferred Vendors that include hotels, conference facilities, production groups, equipment providers, airlines, transportation companies, etc. Reimbursable Expense Reasonable and customary T&E expenses incurred by an Associate while conducting the Company s business. Reimbursable Expenses will be reimbursed to the Associate pursuant to the provisions and documentation requirements described within the Policy. Original receipts (Reimbursable Expenses greater than $25) must be attached electronically to the Expense Report in Concur and include the following documentation: Names of all individuals present including company name Name and location of where the meal or event takes place Exact amount and date of expense including applicable tip or gratuity Business purpose A Reimbursable Expense must be submitted within 60 calendar days of incurrence. Exceptions will be monitored and reported on a monthly basis to the SBU executive IV. FORMS, ROLES & RESPONSIBILITIES Roles & Responsibilities (Can not be delegated at any level): Expense Delegate Someone other than the Associate who assists with the preparation of an Associate s Expense. Associate (Submission required) Defined as an employee of the Company who incurs T&E expenses while conducting Company business. Each Associate is ultimately responsible for complying with the provisions of the Policy in the spirit of the Company s core values to promote ethical / honest relationships, cost containment and efficient use of resources. The associate incurring the expense must submit their expense reports within Concur and cannot be delegated. Approver (Sign-off required) Defined as an Associate s direct supervisor, each Approver is responsible for reviewing the validity, accuracy, and completeness of the Associate s Concur Expense Reports. For the Chairman of the Board, the Chief Executive Officer ( CEO ) of the Company, the CEO of a Strategic Business Unit ( SBU ), and the Co-Chairmen Emeritus the Approver is VP Internal Audit. Accounts Payable ( A/P ) Function The A/P Function is responsible for monitoring and processing Concur Expense Reports. Accounts Payable will audit Concur Expense Reports and will publish reports on all exceptions from policy to SBU Executives and Procurement on a monthly basis.

4 SECTION III: GENERAL ADMINISTRATION POLICIES PAGE 4 OF 9 V. ADMINISTRATION, COMPLIANCE & ENFORCEMENT Administration Policy maintenance, interpretations, and monitoring will be conducted by the Accounts Payable and Procurement Department, as necessary. In this role, the Accounts Payable Department/Procurement is responsible for the following: Policy roll-out and communications Policy questions and concerns Compliance monitoring Notification of non-compliance to Approver and / or Authorized Executive Exception monitoring and reporting Regular re-evaluation of the Policy Random compliance audits will be conducted by Internal Audit. As appropriate, Internal Audit will report non-compliance with the Policy to the Company s Audit Committee. Compliance Each Associate and Approver are responsible for complying with the provisions of the Policy. Examples of non-compliance include the following: Unapproved deviations from the Policy. Submitting multiple reports for the same or similar deviations that are avoidable Inconsistent or inappropriate use of the Corporate Card Program or the Corporate Travel Agency Submitting personal expenses of any nature for reimbursement by the Company Associate fails to pay their monthly Corporate Card or Platinum Card invoice within 26 days of the statement date. Personal use of Corporate American Express card Enforcement Enforcement of the Policy begins with the Associate and the Approver. If necessary, the below matrix defines the Enforcement Actions available when a Policy deviation occurs. Depending on the nature, extent, and frequency of occurrence, the Associate and / or the Approver will be subject to one or more of the following enforcement actions as determined by the parties responsible for program enforcement listed below: Enforcement Action Approver Authorized Executive A/P Function Internal Audit Human Resources Associate s Approver and / or Authorized Executive are X X X X notified of non-compliance. Non-compliant T&E expenses are rejected prior to X X X reimbursement Associate s Concur Expense Reports subject to central X X X X review & approval in Accounts Payable until the Associate demonstrates that the problem is resolved. Corrective Action (per the Administrative Policies X X X Manual policy no ): #1 Verbal warning issued #2 Documented verbal Corrective Action #3 Final Corrective Action Associate suspension and / or termination X X

5 SECTION III: GENERAL ADMINISTRATION POLICIES PAGE 5 OF 9 VI. POLICY PROVISIONS 1. Corporate Card Program All Associates who incur business T&E expenses must utilize the Corporate Card Program as the primary payment option for all business T&E expenses. The Corporate Card is to be used for Forest City business only. No personal expenditures are to be charged to the card. Although widely accepted, an alternative payment method (including cash) may be used where the Corporate Card Program is not accepted. Applications are available from the Corporate Card Administrator. Late fees are not a Reimbursable Expense; they are personal expenses that must be paid by the associate. If an application is denied, the Corporate Card Administrator should be notified and other program options will be presented and reviewed. The Corporate Card Program is comprised of the following cards: Corporate Card The Corporate Card is the primary payment card authorized for business T&E expenses. The Corporate Card provides the following benefits subject to the terms and conditions of the card member agreement: on-line account management, travel accident insurance, baggage insurance, rental car benefits, emergency assistance, and card replacement for lost / stolen cards. Platinum Card The Platinum Card annual fee is a Reimbursable Expense for Frequent Travelers at the request of the Associate. In addition to the benefits associated with the Corporate Card, the Platinum Card allows free access to over 600 airport lounges worldwide. Meeting Card (See Exhibit A) Certain Associates (primarily department heads) have been issued a Meeting Card to be used to pay for Group Meetings (Exhibit A) and other departmental business expenses. Associates are responsible for all charges to their Meeting Card as well as the timely submission into Concur. The Corporate Meeting Card will be paid once a Concur Expense Report is submitted, approved, and audited within Concur. Associate Termination: - Upon termination, an Associate s Corporate Card, Platinum Card, and Corporate Meeting Card must be cut in half by the Approver and sent to the Corporate Card Administrator. The Associate must pay the outstanding balance in full before their last day of employment. 2. Corporate Travel Agency All Associates are required to use the Corporate Travel Agency specifically designed for Associates to book all air travel, car rentals and hotel reservations. Associates can book their own travel via our online booking site or via our dedicated travel agent. The nominal fee charged for Corporate Travel Agency services is a Reimbursable Expense and will be charged directly to you through the Corporate Card Program. Except as expressly set forth in the Policy, the Company will not reimburse T&E expenses related to travel booked through alternative travel agents or travel booking websites. 3. Direct Charges to the Company Associate T&E expenses will be reimbursed only through the Company s Expense Report filing process through Concur. This includes, but is not limited to, airline tickets, hotel accommodations and car rentals (except as described above for Group Meetings). Approved American Express Charges will be paid by the company directly to American Express. 4. Traveling Companions or Personal Travel Combined with Business Trip Family members and other non-associates are permitted to travel with an Associate on a business trip. Similarly, an Associate may combine personal travel, such as a family vacation, with a business trip. At times, the addition of a travel companion or personal travel may alter the timing and specific details of an Associate s travel arrangements. In that regard, the Associate should have the Corporate Travel Agency determine the price of the business trip with and without the personal component. The cost of the business trip without the personal component is the maximum allowable Reimbursable Expense for the Associate. The Associate must clearly document the cost of the trip with and without the personal component in their Concur Expense Report. 5. Personal travel should not be booked via our dedicated travel agent. Personal travel can be booked via our AMEX personal travel webpage at 6. Associates Traveling Together As a general guideline, the number of Associates traveling together on the same aircraft or automobile should not exceed three (3) of the Company s corporate officers, Executive Committee members, executive vice presidents, and / or senior vice presidents. Additionally, it is suggested that the following combination of Associates should not travel together on the same aircraft or automobile: Co-Chairmen Emeritus, Chairman of the Board and the CEO, or more than two directors. 7. Air Travel An Associate s air travel reserved through the Corporate Travel Agency and paid using the Corporate Card Program is a Reimbursable Expense. Air travel reserved or paid through any other source will not be reimbursed. Associates must adhere to the following guidelines: Timing - The Associate should make every effort to reserve air travel as far in advance as possible to receive favorable pricing. An Associate may request an air travel advance (pre-flight) or reimbursement (post-flight) through the Concur Expense Report. Lowest Logical Fare Associates will receive the Lowest Logical Fare by booking flights through the Corporate Travel Agency. At times, the Corporate Travel Agency will suggest that the Associate use a Preferred Vendor to take advantage of a negotiated rate or a complimentary travel voucher. If an associate is aware of a lower fare, the specific information regarding that fare should be presented to a Travel Agent. The Corporate Travel Agency guarantees the lowest fare available in the market at the time of booking.

6 SECTION III: GENERAL ADMINISTRATION POLICIES PAGE 6 OF 9 Class of Travel First-class tickets and travel upgrades are prohibited unless obtained as a no-cost benefit through a frequent flyer program. Business Class (or domestic first-class) is acceptable for international flights (including flights to Hawaii and Alaska) with an actual flight time longer than 5 hours, with the exception of travel done for the Military Housing program. Travel done for the Military Housing program will require associates to seek prior approval to purchase Business Class(or domestic first-class) for international flights(including flights to Hawaii and Alaska) with an actual flight time longer than 5 hours. Non-refundable Tickets - Associates must purchase non-refundable tickets. Change fees are a Reimbursable Expense if incurred in connection with a business need that is documented in the Associate s Concur Expense Report. Frequent Flyer Programs - Associates may retain frequent flyer program benefits offered by airlines for personal use. Participation in frequent flyer programs should not influence travel selections that would result in an incremental cost to the Company beyond the Lowest Logical Fare. Associates are not permitted to book air travel directly with an airline, on-line or off-line, to secure bonus miles or for any other reason. Airline Clubs Airline club memberships are not a Reimbursable Expense. Lost Baggage - The Company has negotiated baggage insurance through the Corporate Card Program. Where the terms of this Policy are followed, baggage is insured under the Corporate Card Program baggage coverage provision. Current terms and conditions can be found at the Corporate Card Program intranet site. The Company will not reimburse an Associate for lost baggage beyond the limits of the Corporate Card Program baggage coverage. Baggage Charges Associates will be reimbursed for baggage charges paid using the Corporate Card Program provided the baggage is required for the business trip. Denied Boarding Compensation At times, an airline may offer compensation (such as air travel or meal vouchers) to compensate for delays or inconveniences due to overbooking, flight cancellations, changes of equipment, etc. Associates are entitled to accept such offers as long the delay will not result in a business loss. Overnight Delays If an airline delay results in an overnight stay, the Associate must first attempt to secure complimentary meals and lodging from the airline. If unsuccessful, the Associate should contact the Corporate Travel Agency for assistance. Cancellations - When a trip is canceled after the ticket has been issued, the Associate should notify the Corporate Travel Agency to effect the cancellation. The Associate must first use the credit for future business travel. The Corporate Travel Agency uses an unused ticket tracking system to assist Associates in tracking credits. Change fees are a Reimbursable Expense. Unused tickets are not to be used for personal travel trips 8. Lodging An Associate s hotel reservation reserved through the Corporate Travel Agency and paid through the Corporate Card Program is a Reimbursable Expense. Hotel reservations booked or paid through any other source will not be reimbursed except when made in connection with a conference / seminar registration. Associates must adhere to the following guidelines: Timing Hotel reservations must be made at the same time as air travel and car rental reservations when possible. Hotel Selection Associates are required to reserve hotels through Corporate Travel Agency which will provide the best hotel options and rates. When available, the system is designed to provide Associates with a Preferred Vendor that might include Company-owned hotels or hotels participating in the companies Complete Suites hotel program Conferences / Seminars A hotel reservation booked in connection with a conference / seminar is a Reimbursable Expense when a prenegotiated rate is offered by the conference / seminar organizer. In such cases the hotel reservation can be booked according to the instructions provided, but the Corporate Card Program must be used for payment. Hotel Upgrades - Associates are entitled to stay in a single room with a private bath. Upgrades to suites or executive floor rooms may be accepted if the upgrade is at no additional cost to the Company. Telephone Usage Associates are required to use their Company-provided mobile phone while conducting business travel when possible. If a mobile phone is not provided by the Company, a reimbursement for actual costs of a phone is permitted. Room Guarantee - Unless otherwise instructed, all rooms will be guaranteed for late arrival when reserved paid through the Corporate Card Program. Cancellation Procedures Associates are responsible for: o Canceling hotel rooms by the cancellation deadline (according to hotel s time zone). Penalties incurred for not cancelling a hotel room according to the hotel s cancellation policy are non-reimbursable o Resolving all billing issues and maintaining all documentation including the cancellation number. Frequent Guest Programs - Associates may retain frequent guest program benefits offered by hotels for personal use. Participation in frequent guest programs should not influence travel selections that would result in an incremental cost to the Company. Membership fees Associated with joining these programs are not Reimbursable Expenses. Business Center Costs Hotel charges for use of any business center-related materials or services (including internet access) for business purposes are a Reimbursable Expense.

7 SECTION III: GENERAL ADMINISTRATION POLICIES PAGE 7 OF 9 Laundry / Dry Cleaning Associates may claim reasonable laundry and dry cleaning expenses incurred during business trips extending beyond five (5) business days. Fitness Center Fitness Center usage fees are a Reimbursable Expense when a complimentary fitness center is not provided at your hotel. In-Room Movies In-room movies are not a Reimbursable Expense. Incidentals Actual incidental costs are a Reimbursable Expense not to exceed $10 per night of travel. Incidentals include snacks, newspapers, mints, shampoo or related items. 9. Rental Cars and Transportation An Associate s car rental expenses reserved through Corporate Travel Agency and paid through the Corporate Card Program are Reimbursable Expenses. Car rental expenses reserved or paid through any other source will not be reimbursed. Associates must adhere to the following guidelines: Timing Car reservations must be made at the same time as air travel and hotel reservations when possible. Rental Cars - Associates should use the Corporate Travel Agency to book rental cars to ensure the lowest rate through a Preferred Vendor. The Corporate Travel Agency provides the Corporate ID Number to the car rental company at the time of booking. Size The size of the rental car should be determined based on the business purpose of the travel and the number of people being transported. Generally, a small, mid-size or intermediate size will be appropriate however; complimentary upgrades are available and may be accepted from a Preferred Vendor. Insurance Domestic rental cars are covered by the Company s insurance program. When renting a car outside of the United States, Associates must purchase collision damage insurance and liability insurance up to $250,000. If an Associate is involved in an accident while traveling, please contact the Director of Insurance. Fuel Associates should make every effort to refuel rental cars to avoid substantial refueling charges by the rental company. Frequent Rental Car Programs - Associates may retain frequent rental car programs benefits offered by rental car companies for personal use. Participation in frequent rental car programs should not influence travel selections that would result in an incremental cost to the Company. Membership fees associated with joining these programs are not Reimbursable Expenses. Cancellation Procedures Associates are responsible for canceling rental cars by the cancellation deadline and resolving all billing issues and maintaining all documentation including the cancellation number. Ground Transportation If more economical than a rental car, Associates should use a taxi, limo, subway, bus, or train for ground transportation while traveling. Associates should share ground transportation whenever possible. Personal Car Usage The expense of using an Associate s personal car for a business purpose is a Reimbursable Expense subject to the following guidelines: o Business Mileage is reimbursed at all-inclusive reimbursement rate that is determined by the Internal Revenue Service ( IRS ). The rate is updated regularly and is available at the IRS website: o The Associate must document the specific business purpose of the trip, date, location, and mileage on the Concur Expense Report. o o The use of a personal car is less expensive than air, rail or public transportation. Frequent use of a personal car for business is not encouraged as it is the Associate s responsibility to carry adequate insurance coverage for the contents of the car including passengers Parking and Tolls The cost of parking and tolls is a Reimbursable Expense when incurred in conjunction with Company business. Associates should contact the Corporate Travel Agency or visit the Procurement Department intranet site for details on Preferred Vendors for parking. Company Vehicle / Auto Allowance - Associates with a Company vehicle or an auto allowance should refer to the Automobile Program or policy # of the Company s Administrative Policies Manual for guidance specific to their use. Associates will not be reimbursed for car rentals made in their home market if they are a participant in the Company vehicle or auto allowance program. 10. Meals and Entertainment The cost of up to three meals per day incurred by an Associate and entertainment paid through the Corporate Card Program are Reimbursable Expenses. Meals (including drinks) are expected to be reasonable in cost and quantity. Meals and entertainment paid through any other source will not be reimbursed; however meals and incidentals paid using cash are acceptable. Tips and gratuities are Reimbursable Expenses based on discretion generally exercised by Associates during personal T&E and should not exceed 20% on meals (including beverages). Associates must adhere to the following guidelines: Personal Meals: o Meal expenses incurred while dining alone on an out-of-town business trip are Reimbursable Expenses at the actual cost of the meal including tip. The Concur Expense Report will automatically calculate the amount to the appropriate general ledger account. These meals are 50% deductible for tax purposes. Business Meals & Entertainment:

8 SECTION III: GENERAL ADMINISTRATION POLICIES PAGE 8 OF 9 o Meal & entertainment expenses incurred with current or prospective clients, vendors, partners, or Associates are Reimbursable Expenses to the extent of the actual cost only when a specific business discussion takes place before, during, or after the meal and properly documented on the Concur Expense Report. The actual cost of two or more Associates dining at a moderately priced restaurant together is a Reimbursable Expense for the most senior level Associate (i.e., an Associate should not pay for the Approver s meal) when: Two or more Associates dine together while on an out-of-town business trip, or While in their hometown and a specific business discussion takes place before, during, or after the meal o The Concur Expense Report will automatically calculate the amount to the appropriate general ledger account. These meals are 50% deductible for tax purposes. o Company Sponsored Meals: Meals provided by the Company during recreational or social activities benefiting Associates, such as a holiday party or the summer picnic, as well as meals provided to a department requiring Associates to work more than eleven (11) hours in one day. An Associate working in excess of eleven hours in one day is entitled to be reimbursed for the actual cost of one meal based on the business meal guidelines established above. Entertainment-only Meals & Entertainment: o Entertainment-only meals incurred while dining with current or prospective clients, vendors, partners, or Associates should follow the same guidelines as a business meal, except that no specific business discussion takes place before, during, or after the meal. Entertainment-only meals are expected to be infrequent in occurrence and should be verbally pre-approved by the Approver. 11. Non-Employee T&E Expenses Company directors, vendors, partners, contractors, consultants, and other non-employees who incur T&E expenses while working on Company business are not bound by the provisions of the policy, but are expected to comply with the documentation requirements set forth in the Policy when requesting reimbursement. The Associate responsible for oversight of the non-employee is the Approver for their T&E reimbursement requests. Non-employees are not required to use the Company s Concur Expense Report form. 12. Non-Reimbursable Expenses Child care costs Travel upgrades resulting in an incremental cost to the Company (Wi-Fi service, DIRECTV, etc) Clothing Late fees Personal services - Saunas, massages, haircuts, etc. Helicopter services In-flight and in-room movies Hotel mini bar charges Medical bills Parking or traffic tickets Computer equipment Music related costs, headphones and other items of a personal nature. Hotel cancellation fees Premium Seating Upgrading an assigned seat to a premium seat (exit row, extra leg room seats, premium seating area) 13. Company and / or Departmental Gatherings Costs associated with Associate functions not sponsored or organized by the Company such as picnics, holiday parties, lunches, department functions, sport outings, etc., are only Reimbursable Expenses when paid through the Meeting Card and with the written pre-approval of the appropriate Authorized Executive on an Exception Report. 14. International Travel The cost of passports, visas, and currency conversion are Reimbursable Expenses when an Associate is required to travel internationally. Business Class (or domestic first-class) is acceptable for international flights (including flights to Hawaii and Alaska) with an actual flight time longer than 5 hours. When renting a car outside of the United States, Associates must purchase collision damage insurance and liability insurance up to $250,000 through the rental car company. International usage of the Corporate Card may be more limited when traveling internationally. In that regard, Associates should be prepared to utilize alternative payments when the Corporate Card is not accepted. 15. Out of Town Work Assignments When an associate is assigned an out of town work assignment that extends four weeks or more, reimbursement based on a per diem amount is allowed. A business purpose must be noted on the Concur Expense Report. Receipts will not be required when reimbursement is made on a per diem basis; however, the rate should not exceed the IRS guidelines. The food per diem should be noted separately on the Concur Expense Report from the non-food per diem. Per Diem rates are available at

9 SECTION III: GENERAL ADMINISTRATION POLICIES PAGE 9 OF EXHIBIT A GROUP MEETINGS Group Meetings Business gatherings, team building activities, Associate training, trade shows, seminars, and other business events attended by five (5) or more Associates involving air, car and / or hotel reservations. Group Meeting Organizer The Associate responsible for organizing a Group Meeting. Group Meeting Organizers should notify the Corporate Travel Agency as soon as details of a Group Meeting are available. Group Meeting Arrangements The Group Meeting Organizer must utilize the Corporate Travel Agency to coordinate arrangements for out-of-town Group Meetings and the related travel. The Corporate Travel Agency will ensure that the Group Meeting receives the most favorable rates by leveraging the Company s existing Preferred Vendors or negotiating new contracts when necessary. Contracts All Group Meeting contracts should be reviewed by the Corporate Travel Agency and the Corporate Legal department. Specific clauses should be included in all contracts such as cancellation policies, reuse of credits, payment methods, and indemnification. Payment Procedures - Group Meeting contracts should state that the Meeting Card will be accepted for meeting deposits (pre-payment), at the meeting s execution (on-site payment), and for the final meeting bill reconciliation (post-meeting payment). There should be no additional fee charged by a supplier for using the Meeting Card to pay for Group Meeting expenses. The recommended contract language is as follows: The Meeting Card will be accepted for meeting deposits (pre-payment), at the meeting s execution (on-site payment), and for the final meeting bill reconciliation (post-meeting payment). There will be no additional fee charged for using the Meeting Card for meeting payments. Upon receipt and reconciliation of the final master bill, the Company will fax or a payment authorization letter to the hotel. Charges will then be applied to the Meeting Card. No charges are authorized to be submitted on a Meeting Card until such an authorization is received by the hotel. Unauthorized charges will be considered fraudulent and will be disputed. The Group Meeting Organizer must obtain all approved account folios from the hotel and reconcile any disputes with the hotel prior to processing the charge on the Meeting Card. Expense Reporting & Documentation Prior to the Group Meeting, the Group Meeting Organizer must clearly communicate the payment process to Associates attending the Group Meeting outlining specific details on which expenses will be paid by the Company via a Meeting Card and / or the Associate through his/her Corporate Card or Platinum Card. The Corporate Travel Agency can assist the Group Meeting Organizer in determining the best payment process based on the specific details of the Group Meeting. Example of Group Meeting expenses to be paid with the Meeting Card: Meeting room costs, A/V equipment rentals, and related services Catering and group meals (recognition dinners, board meetings, etc) Meeting supplies, copies, favors or promotional items Air transportation / ground transportation / lodging for a group of Associates (if group discount is available) Infrequent traveler expenses (air/hotel for travelers without a Corporate Card or Platinum Card) Loge charges (including food) at sporting and other entertainment venues (such as Quicken Loans Arena, Izod Center, etc) Meeting Card Reconciliation and Payment The Meeting Card is a Company-liable card and is required to be paid using the Concur Expense Report. Group Meeting Organizers should review and reconcile the monthly account statement. The Meeting Card remittance advice, supporting documentation, and account coding must be submitted within Concur. The Meeting Card will be paid directly once the Concur Expense Report is approved.

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