Policy: Staples Global Travel & Business Expense Policy

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Policy Highlights 1. Associates must use Staples designated travel agency for all business travel arrangements. Use of commercial internet booking sites is not permitted. 2. Associates must book the lowest airfare within stated parameters for all business travel. 3. Reservations should be made at least 14 days in advance when possible. 4. Staples will reimburse associates for actual daily cost of breakfast, lunch and dinner for overnight business travel. Associates are expected to keep meal expenses reasonable based on location and business need. In general, daily meal expenses should not exceed $75. 5. Should an associate be required (or it is more practical) to travel from home to an alternative work destination (e.g., a distribution center), they can only seek mileage reimbursement only for miles/kilometers exceeding normal daily commute. Statement of Purpose This policy applies to all associates employed by Staples, Inc. or a subsidiary of Staples, Inc. Staples will reimburse associates for reasonable and necessary business expenses, including travel at the discretion of the approving manager, as outlined in this policy, as required by state and federal law. General Guidelines Associates are expected to use sound judgment and to spend the company s funds prudently and comply with this Global Policy and specific travel procedures for their region. It is the Manager s responsibility to ensure their associates make proper judgments between efficiency, effectiveness and cost. Managers are expected to review all expenses submitted to ensure they are reasonable, supported by a valid business purpose and comply with applicable policies. Managers should audit expense receipts to ensure compliance with policies. Travel Reservations Mandatory Use of Company Authorized Travel Agency Staples has designated an authorized travel agency for each geographic area. Associates must use this agency for all business travel arrangements. Use of commercial internet booking sites is not permitted. Use of Telepresence Prior to booking travel it is both the manager s and the associate s responsibility to review alternatives for internal Staples travel. Telepresence rooms are available in certain company locations and should be utilized in lieu of air travel when feasible. Mandatory Use of Corporate Charge Card If a corporate charge card program exists for a geographic area, associates must use this card for business expenses based on eligibility guidelines. Staples issues corporate charge cards to

associates based on grade level, projected travel expenses, and approval by the appropriate level of management (as described in the local travel procedures).). In general associates who travel regularly on behalf of the company are obligated to apply for a corporate charge card with proper approval. Associates are not allowed to use corporate charge cards for non-business related personal expenses. Air Travel Advanced Purchase Reservations should be made at least 14 days in advance to take advantage of advanced purchase discounts. Class of Service Domestic/Continental Flights All domestic/continental flights must be booked in Coach/Economy class. Class of Service Intercontinental Flights Business class is authorized ONLY under the following guidelines: Associates traveling on a continuous flight where the total flight time on one leg of the trip exceeds six (6) hours AND when upon arriving in country will be proceeding to the office (or place of business) for at least four (4) working hours on the same day of arrival; may book business class on this segment of the flight only. The approval of this type of travel is at the discretion of the appropriate level of management. All other segments of this trip are to be booked in economy/coach class. This does not apply to flights over six (6) hours within the continental US, Canada or between the US and Canada. These flights will be booking in Coach/Economy class. Associates who are traveling on a continuous flight where the total flight time on one leg of the trip exceeds six (6) hours, who are NOT reporting directly to the place of business in the destination country for at least four (4) working hours must book round trip in Coach/Economy class. On any continuous flight or flight with a transfer where the flight time of the trip exceeds nine (9) hours, or total trip travel time from departure to destination exceeds 18 hours, the round trip flight may be booked in business class. The approval of this type of travel is at management discretion. Premium Economy vs. Business Class On certain airlines where a Premium Economy cabin is available, Premium Economy may be a viable alternative to business class and should be considered. Lowest Airfare Requirement Associates must book the lowest airfare for all business travel. At minimum associates should accept and alternative airfare if it will save $50 each way or $100 Round trip on domestic/continental trips OR $100 each way or $200 round trip on Intercontinental trips. For reasonableness the lowest airfare alternative should meet the following criteria: There is no more than one additional interim stop each way (no additional stop for same day travel). The departure and arrival times fall within 2 hours of the requested times. Preferred Airlines Associates are expected to book with preferred airlines when the routing is logical. Preferred airlines will be indicated by the travel agents at the time of reservation or flagged accordingly in your online booking tool. Frequent Flyer Award/Loyalty Programs

Associates may keep any loyalty program awards, such as frequent flyer awards, for personal use. However it is unacceptable to insist on a particular airline because it will enable the associate to earn more personal awards. Upgrades Domestic/Continental Flights The purchase of any type of extra leg room seat or similar upgraded seats are not reimbursable. It is also against policy to choose a more expensive fare for the sole purpose of upgrading on a domestic/continental flight. Upgrades to Business Class International Upgrades used as a less expensive alternative to purchasing business class are permitted when business class on a flight is applicable per this policy. Upgrading from economy to business on any leg that is not eligible for business class is not reimbursable. Baggage Fees Staples will reimburse the cost of up to one checked bag per flight. Please note most airlines waive these fees for certain level frequent flyers. Please always check with your airline for the most up to date information on baggage allowance. In-flight Internet Usage Staples will reimburse use of In-flight internet. Associates are expected to use this prudently and for business purposes. Advanced Boarding Fees Staples will reimburse the cost for advanced boarding ONLY for low cost airlines that do not generate a seat assignment. Security Clearance Programs Security programs such as Global Entry, Pre-Check etc. are not reimbursable. Visa and Passports Please work with your designated travel agency to determine passport and visa requirements. Staples will reimburse travelers for specified fees related to passport and/or visa requirements if business travel necessitates a need for these services. Personal/Spouse Travel Combining personal travel and/or vacation with a business trip is permitted ONLY if: the primary reason for the trip is business; personal travel does not interfere with the business objectives; personal trip will not increase Staples cost. The associate is responsible for any additional costs (including, airfare, car rental, hotels, meals, taxes, etc.) that are beyond what the costs would have been for the business trip alone. Staples will not reimburse travel, meals or entertainment expenses incurred by a spouse or other individuals accompanying the associate on business, unless there is a bona fide business reason and prior approval is given. Hotels Required Use of Staples Travel Agency Where a designated travel agency is in place, hotel reservations must be made along with air travel with the travel agency. The only exceptions to this would be for external conferences where a room block is already established. Required use of Staples Preferred Properties Staples has negotiated rates with certain properties in heavily traveled cities. When staying in a city where there is a corporate rate place, and the preferred property is in the vicinity of where a traveler will be conducting business, the Staples preferred hotel must be used. In cities/areas with no corporate preferred property, reservations will be made at a moderately priced hotel.

Preferred properties will be marked on the online tool or verbalized at the time of reservation by the agent. Hotel Internet Usage Associates will be reimbursed for the use of hotel internet usage at properties where it is not included or has not been negotiated in the rate, however are expected to use this prudently. Where possible utilize wireless at Staples offices to keep paid use down. Cancellation or Early Check out Fees When travel plans change, it is the associate s responsibility to notify the hotel or travel agency, in order to prevent hotel charging a fee. (Please make sure to check each hotel s policies on these topics to avoid surprises hotel rules may be viewed on the online tool). Hotel Rewards Associate s are permitted to keep award points related to business hotel stays, however, it is against policy to insist on a particular hotel solely for the purpose of gaining personal awards. Personal Hotel Charges Associates will not be reimbursed for personal expenses incurred at hotels such as, movies, video rentals. Laundry will only be reimbursed for trips of 5 days or greater. Car Rental Associates should rent a car when traveling on business in the following circumstances: Going to the destination: in case renting a car is more cost-effective than other forms of travel At the destination: in case renting a car is less expensive than other forms of transportation such as taxis, airport limousines, or airport shuttles Preferred Rental Car Company The company will designate a preferred car rental company for both the home and destination country locations. Associates are required use the designated car rental agency. Rental Car Categories We expect associates to select rental car categories based on the number of people and miles driven. Category Midsize/Intermediate Full-Size/Standard Number of People 1-4 people 2-4 people if driving more than 200 miles/320km Rental Car Upgrades Joining the preferred car rental frequent renter program affords associates with special promotions such as free upgrades. When picking up a rental car, check for any promotional rates, last-minute specials or free upgrades. Note: The category guidelines set above identify the car associates should end up with, not the starting point. For example, if associate secures a free upgrade, they should request a compact car (locking in at the compact car rate) and then upgrade. GPS Devices The cost of GPS device in a rental car will be reimbursed if there is a true business reason. If traveling directly from the airport to a hotel or place of business, directions can be obtained from the rental car company or before the trip by accessing a website such as MapQuest. This avoids the daily rental cost and liability of a GPS device. Rental Car Insurance

Please refer to the geographic region specific travel and expense procedures in the appendix for more detailed information on proper handling of insurance when renting a car. Toll Passes The daily rental cost of toll passes will be reimbursed in areas where they are required. Rental Car General Travelers should refill the gas/petrol tank of rental cars whenever possible to avoid premium charges charged by the rental car companies to refuel. Travelers should when possible avoid dropping off rental cars at a location other than the original pick up location, to avoid costly one-way drop off charges. Other Transportation Train/Rail Travel Train travel should be used when it is more economical than other means of transportation. Train travel in general should be booked in coach class. Ground Transportation To and From Airports and Other Terminals Associates must choose the most economical transportation when traveling to and from airports and public transportation terminals. Use of private car services are discouraged due to the high cost. For information on express buses, public transportation, airport shuttle services, and off airport parking options please contact your designated travel agency. Privately Owned Car Use Associates may use privately owned car for business travel if it is more cost-effective or perceived as the normal means of transport. We do not encourage the frequent use of associates own vehicle if a less expensive alternative is available. It is the associate s responsibility to ensure that they are in possession of a current driver s license and appropriate insurance that permits the use of a private car on company business. Refer to the geographic region specific travel and expense procedures in the appendix for more detailed information. Only miles/kilometers exceeding normal daily round-trip commute will be reimbursed. Should an associate be required (or it is more practical) to travel from home to an alternative work destination (e.g., a distribution center), they can seek reimbursement only for miles/kilometers exceeding normal daily commute. In countries where standard Government reimbursement rates for business travel exist this is the rate that will be used for reimbursement. Please note these rates already account for fuel costs, so there will be no extra reimbursement for fuel. In countries where no standard Government rate exist use of associates own car and any reimbursement will be subject to country specific car arrangements and will be detailed in the geographic region specific travel and expense procedures included in the appendix. Meal Expenses Overnight Meal Reimbursements Staples will reimburse associates for actual daily cost of breakfast, lunch and dinner for overnight business travel. Meals should be consistent with the nature of the trip and at normal living standard. Receipts are required for all meal expenses. Individual meals when traveling should be expensed as such. In general, daily meal expenses should not exceed $75

Snacks Snacks, such as bottled water, coffee, energy bars etc. are not considered reimbursable expenses, unless the snack is submitted in lieu of a daily meal. Business Meals Taken with Others (Including Associates) A business meal is only reimbursable, if it is directly related or associated with the active conduct of Company business. In the case of more than one Staples associates dining together, the most senior associate in attendance must pay for the meal. Documentation Requirement The following information must be supplied for each business meal when there is a guest; date of entertainment, name of restaurant, city, guest name(s), title, company, business purpose and amount. Same Day Travel In regards to same day business travel, if the associate is on the road for 10 hours or more including travel time, meals (Breakfast and/or Dinner) will be reimbursed within reason. Hotels Offering Breakfast Many hotel chains offer complimentary breakfast or it has been negotiated into the rate for many Staples preferred properties. Use these properties when available to reduce meal expenses. Tips and Gratuities Tips are allowable when appropriate and customary. This would normally include wait-staff, taxicab drivers, etc. Tips for skycaps, bellhops and valet services are allowable only when necessary. Tipping for Meals Tips included on meal receipts will be reimbursed. Any tips considered excessive will not be reimbursed. As a general rule, associates will not tip more than they would on a personal trip. Employee Recognition Team Recognition Team recognition in the form of team celebrations; outings, team meals will be reimbursed within reason and pending supervisor s approval. Individual Recognition Individual recognitions such as birthday, holiday, birth of a child, etc. are not reimbursable. Flowers or similar sent by the department for bereavement related to an associates immediate family member will be reimbursed. Individual recognition in the form of awards, gift cards, etc. should follow the preferred HR policies and procedures. Please refer to your local HR contact for information Telephone Guidelines Telephone Use (while traveling on business) Staples will reimburse associates for all reasonable business calls made while traveling on company business. It is the associate s responsibility to utilize the most economical way to place telephone calls. The use of hotel phones and airline phones for business use is prohibited due to their high cost. Personal Calls

Staples will reimburse associates for a reasonable number of personal telephone calls while traveling on company business, at a reasonable cost. As a general rule, up to 2 phone calls per day is considered reasonable. Corporate Card Use of Corporate Charge Card Use of the corporate card, where one exists, is mandatory. Credit cards are issued at the discretion of the business and may be revoked at any time without the need for explanation. They must be used in accordance with this Policy and used exclusively for expenditure incurred for business purposes. Failure to use the cards provided in accordance with the policy will result in the card being revoked and may result in disciplinary action. Refer to the refer to the geographic region specific travel and expense procedures in the appendix for more detailed information. Expense Reporting and Documentation Associates are required to provide appropriate documentation to support business expenses. Business Expenses Only Associates may seek reimbursement for legitimate business expenses. Reimbursement for personal expenses is not permitted. Refer to the refer to the geographic region specific travel and expense procedures in the appendix for more detailed information. Contractors Contracted employees regardless of length of service, must process expenses through their employment agency or vendor. Staples will not directly reimburse a contracted employee s expenses. Travel Safety and Insurance Staples has partnered with International SOS (ISOS) to provide you with important safety, medical and travel information prior to departing on international business trips. Refer to the Travel and Safety Insurance policy for details. Exceptions Any exceptions to this policy require the prior approval of an Executive Committee member. Related Policies Appendix 1 - Staples US Travel and Expense Procedures Appendix 2 - Staples Canada Inc. & Staples Advantage Canada Travel Procedures Appendix 3 - Staples European Travel and Expense Procedures SA Expense Policy Supplement (Sales Policy) Travel Safety and Insurance Policy Administration Applies to: All Staples Associates Policy Number: TE001 Effective Date of this Version: 9/17/2014 Revision Date 10/22/2014 Revision Date 10/06/2015 Revision Date 07/22/2016 Revision Date 09/08/2016