EXPENSES POLICY FOR DIRECTORS, EMPLOYEES, TUTORS AND REGIONAL REPRESENTATIVES Approved By the Board: 22 nd November 2017 Review Date: December 2018 1 P a g e
1. INTRODUCTION It is our policy to reimburse directors, employees, tutors, regional representatives and others for reasonable expenses incurred in connection with AACP Ltd. Directors, staff, tutors, regional representatives and others should be neither financially advantaged nor disadvantaged as a result of incurring genuine business expenses. The purpose of the policy is to reimburse travel and other expenses properly incurred in the course of legitimate AACP Ltd business, whilst seeking to manage cost and avoid reputational damage that could arise from excessive, inappropriate or unauthorised claims. It is important that directors, employees, tutors, regional representatives and any other claimants read and understand this policy before making travel arrangements, travelling or making any claim for expenses. It is each person s responsibility to ensure that any claims made for the reimbursement of expenses comply with the terms of this policy. Directors, employees, tutors and others may choose to incur expenditure in excess of the levels provided for in this policy, but any such excess costs will not be reimbursed and must not be claimed. Adherence to this policy will be monitored by the Board and the Audit Committee on an ongoing basis. 2. KEY PRINCIPLES This policy applies to all claimants - the Chairman, directors, employees, tutors, regional representatives and any other associates of AACP Ltd - for expenses incurred for legitimate business purposes. Expenses must be claimed in writing using the standard Expenses Claim Form. Completed expenses claim forms must be submitted for review and authorisation in the month following the incurring of the expenses. Expenses Claim Forms submitted after this date will not be authorised for payment. Expenses Claim Forms must be completed by the individual making the claim, and signed and dated by the individual. Where appropriate, Expenses Claim Forms must be accompanied by corresponding VAT receipts. This provides supporting evidence for the claim being made. Any discounts obtained in the course of incurring an expense must be included in any subsequent claim. Authorised and approved expenses will be paid by BACS directly into the individual s nominated bank account. To ensure openness and transparency, a summary of expenses paid to the Chairman and directors will be reviewed and considered at by the Board of Directors at each Board Meeting, In addition, the Audit Committee will review all claims for expenses submitted by the chairman and directors at its regular meetings. 2 P a g e
3. TRAVEL EXPENSES Claimants are responsible for making their own travel arrangements. We will pay the reasonable costs of necessary travel on behalf of the company. Travel must be by the most cost-effective mode of travel possible, taking into account both journey time and monetary cost. If a journey is made in connection with other purposes (business, professional, personal) as well as on behalf of AACP Ltd, then only the appropriate proportion of the expenses incurred should be claimed from AACP Ltd. The appropriate proportion should be discussed and agreed with those responsible for reviewing and authorising the claim. By Car Where it is most cost-effective to make a business journey by car, a mileage allowance may be claimed as follows: First 10,000 business miles in the tax year: 45p per mile; These rates are reviewed annually and will be updated in accordance with HMRC guidance and statistics. Claims may be made for any reasonable parking fees and tolls incurred while travelling on behalf of AACP Ltd. The cost of parking/traffic fines or penalty charges or car wash/valet will not be reimbursed. All claimants remain personally responsible for ensuring that their vehicle is roadworthy, has a valid MOT certificate and that their motor insurance covers business use. By Taxi Taxis should only be used where necessary where public transport is not available, and / or where personal security is a consideration for early morning or late night travel, or where a disability restricts ability to travel on public transport. If a taxi is used, a receipt must be obtained and must be submitted with the Expenses Claim Form. By Train Travel must be by standard class rail travel, and should be booked as far in advance as possible, to obtain the cheapest fares and so minimising the costs borne by AACP Ltd. First class travel may be booked and claimed where it can be demonstrated that the costs incurred and reclaimed are less than the full standard fare for the same journey. By Air In certain circumstances it may be necessary to use air travel. As with train travel, flights should be booked well in advance wherever possible, and using the most cost-effective ticket arrangements. Air travel must be by economy class and no business class flights are permitted unless they are cheaper than the standard fare being offered at the time of booking. 3 P a g e
4. ACCOMMODATION AND SUBSISTENCE EXPENSES Accommodation The Chief Executive Officer and Team are able to make arrangements for directors who require overnight accommodation in Peterborough prior to Board meetings. In a similar way, the Chief Executive Officer and Team will make arrangements for other Board committee members who require overnight accommodation in Peterborough prior to their Board committee meetings. Where possible, and when sufficient notice is given, the Chief Executive Officer and Team will make arrangements for tutors where overnight accommodation is needed in connection with the provision of a course or other training event. These arrangements will be on a dinner, bed and breakfast basis, and will be settled by AACP Ltd directly with the hotel. Occasionally, other AACP Ltd business needs may require the booking of accommodation. This should be approved in advance, and in writing, by the Chairman (or, in the case of the Chairman, by the Audit Committee Chairman or Company Secretary). If a booking is made directly, a copy of the hotel s invoice must be attached to the claim. As far as possible, accommodation should be selected for convenience and booked in advance to secure the best possible rates. The rate per night for bed-and-breakfast should not exceed 85 (including VAT) (or 130, including VAT, for accommodation in London. In this instance, the London area is defined as comprising zones 1-6 inclusive, as set out by Transport for London). Subsistence: Away Overnight When a journey on behalf of the company makes it necessary to stay away overnight, reasonable out-of-pocket expenses will be reimbursed, including: Hotel accommodation bills; Breakfast (if the hotel rate does not include breakfast), up to 10 per day (incl. VAT); Lunch, and accompanying beverages, up to 15 per day (incl. VAT); Dinner, and accompanying beverages, up to 25 per day (incl. VAT); Other personal expenses, such as private telephone calls, tea and coffee, to a maximum of 5 per day (incl. VAT). Claims must be supported by receipts and itemised on the expenses claim form. These figures are not flat-rate allowances, but limits on the actual amount of expenditure that will be reimbursed against receipts. Items such as newspapers and magazines, laundry, access to films/videos, alcoholic drinks, bar bills and other extras cannot be claimed for. No meals or other items may be claimed for where no overnight stay is required. Subsistence: not involving a night away When a journey on behalf of the company doesn t involve staying away overnight, claimants may use a daily allowance of up to 10 for incidental expenses such as refreshments which will be reimbursed against receipts. 4 P a g e
Foreign Travel Overseas travel is only permitted where there is a clear business need and with the prior approval of the Board. The company s Expenses Policy applies to overseas travel as well as to travel within the UK. Claims for expenditure incurred in foreign currency should reflect the sterling value charged, or, if paid in local currency, reimbursement will be calculated using the prevailing tourist exchange rate at the time of processing the claim form for reimbursement. Spouse/Partner/Family Travel Directors, employees and all other claimants who wish to have their spouse, partner and/or other family member/friend travel with them and/or stay with them while travelling on business must pay any additional costs incurred as a result. This includes any additional costs borne by AACP Ltd, where a hotel booking is made directly by the company. The exception to this will be where the director and their spouse/partner have been specifically invited to an official function for which approval has been granted in advance by the Chairman (or, in the case of the Chairman, by the Company Secretary or Chairman of the Audit Committee). 5. HOSPITALITY AND ENTERTAINMENT EXPENSES The approach outlined here aims to minimise the risk of bribery, as defined in the Bribery Act 2010, or the use of improper influence and the potential impact on the company, or perceived bribery and impropriety and the associated reputational damage that this might cause. The Chairman and directors should not ordinarily be personally responsible for entertaining, but if this is necessary, then the prior approval of the Board must be obtained. If the required prior approval is obtained, then an expenses claim is made for the entertainment, detailing the names, positions and organizations of the people present. Where the Chairman, director or employee is invited to attend an event hosted by an external third party (another organization) then prior approval from the Board must be obtained. 6. PAYMENTS FOR ATTENDING MEETINGS / SPEAKER S FEES AND DIRECTORS ADDITIONAL HONORARIUM Claims for such fees should be included on the Expenses Claim Form, and must accord with the claimant s letter of engagement or contract and / or the company s remuneration rates as set out in each committee s terms of reference as approved by the Board of Directors, or as otherwise approved by Board resolution. 5 P a g e
7. CLAIM PROCEDURE Reimbursement of expenses Expenses will be reimbursed if they are: Submitted in accordance with this policy; Supported by valid receipts; Submitted on the company s Expenses Claim Form and Authorised in accordance with the procedure below: Position Authorised By Authorisation Limit Company Secretary AND Chairman Chief Executive Officer All Expenses CEO Chairman AND Company Secretary All Expenses Director CEO AND Chairman or Company All Expenses Secretary Employee / Tutor / Regional CEO < 1,000 Representative / Other CEO AND Chairman or > 1,000 Company Secretary Expenses Claim Forms, including the signed and dated Claimant s Declaration, and accompanying receipts, may be submitted by post or as scanned attachments to emails. If Expenses Claim Forms are submitted as an email attachment, both sides must be scanned and submitted (so that those authorising the claim can see both the details of the claim, and the signed and dated Claimant s Declaration), and the claimant must retain their original Expenses Claim Forms for at least a year, in case of any need for the original documents to be audited. Authorised expenses submitted in accordance with this policy will be paid directly into the claimant s nominated bank account. Where completed Expenses Claim Forms are submitted by the 7 th of the month, expenses will be paid by the end of the same month. Where completed Expenses Claim Forms are submitted later than the 7 th of the month, expenses will be paid by the end of the following month. 6 P a g e