TRAVEL & ENTERTAINMENT

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GROUP POLICY Document No: GP016 Revision No: 01 Issue Date: January 2011 Author: Xolani Mbambo Approval: Exco/Board TABLE OF CONTENTS 1. Overview 2. General Provisions 3. Mode of Travel 4. Accommodation and meals 5. Entertainment 6. Foreign Exchange Regulations 7. Expenses 8. Travel Approval 1. Overview Grindrod acknowledges the need for employees to travel both nationally and internationally in order to fulfil their responsibilities. In this regard Grindrod will pay for all business-related travel and allowable expenses incurred by the employee as defined within this policy. The aim of this policy is to provide employees with guidelines on how to book cars, flights and accommodation when fulfilling their out of town business obligations and to inform employees of the maximum allowable reimbursement of expenses incurred on business related trips. 2. General Provisions 2.1 Grindrod Travel is the preferred provider of travel services, including flights, hotel accommodation and car rental. In instances where it is not possible to employ Grindrod Travel s services, only Grindrod-approved travel agents are to be utilised. 2.2 Employees are expected to consider reducing the quantum of travel where practical by: Video and / or tele-conferencing (important) Arranging as many meetings as possible in one trip Staying overnight if this will save another trip to the same destination. page 1 of 5

2.3 Travel and accommodation costs paid on behalf of suppliers and / or clients must be reported in line with Grindrod s Gift Policy (available on the intranet). 2.4 All employees travelling internationally on the business of Grindrod have automatic travel cover via the MRG group risk cover. This insurance is secondary to any medical aid or personal insurance available. 3. Mode of Travel 3.1 Air Grindrod Travel will present a list of carriers and fares, from which the employee should select the lowest convenient fare. 3.1.1 The following class of air tickets may be utilised: Group Chief Executive Officer (CEO) and direct reports to the Group CEO - business class for domestic and international flights All other employees economy class 3.1.2 All employees who are travelling are required to be circumspect in their travel choices. Every effort should be made to make bookings well in advance so as to take advantage of reduced fares. The minimum should be at least two weeks in advance. 3.1.3 Departure time changes may only be requested if the employee s planned meetings have been cancelled or changed for reasons out of their control. Changes made to the value of R1 000 and over, require line manager authorisation. This also applies if the traveller has made more than one change to his / her booking. 3.1.4 Recommended limitation on number of same flight travellers: 3.1.5 In order to ensure adequate risk protection, a maximum of three members of management may fly on any non-major airline or chartered flight, of which no more than two may be Executive (i.e. Directors or Chief Executive Officers) members of management. 3.1.6 No restrictions are required for major airlines such as SA, Virgin, British Airways, Lufthansa, etc. 3.1.7 A maximum of three members of management may travel in a single vehicle, of which no more than two may be Executive (i.e. Directors or Chief Executive Officers) members of management. 3.2 Car Hire 3.2.1 All vehicles booked for businesses purposes must be booked through Grindrod Travel and if outside South Africa, through a company approved supplier. 3.2.2 Note the following guidelines when hiring cars: Where possible, cars must be booked at least a week in advance to ensure availability. The most economical vehicle available is to be hired and should be fitted with airbags. The standard vehicle to be booked is Group B. A larger vehicle may only be hired in the event that four passengers are travelling together and the distance to be travelled is significant. Fines received will be for the employee s account. Where a Grindrod employee is required to be outside of their home country over a weekend, a car may be hired for reasonable private use. page 2 of 5

3.3 Before taking delivery of any hired vehicle, it must be carefully inspected and any existing damage or missing equipment must be drawn to the attention of the car rental company. 3.4 Insurance for Hired Cars 3.4.1 Businesses insured under Grindrod s motor policy are automatically covered under the motor fleet policy and therefore additional car accident insurance on rental in South Africa is not necessary. 3.4.2 In instances where a vehicle is hired for use outside of the employees home country or if the car is to be driven across the South African border, relevant cover offered by the rental company must be taken. 3.4.3 Employees may be liable for any damage, accidents and related claims and costs where he/she is found to have been negligent. 3.4.4 If a hired vehicle is damaged anywhere by acts of rioters or during any civil disturbance, the matter is to be reported to the nearest Police Station immediately. An affidavit must be obtained and reports on the circumstances submitted to the company. 4. Parking and Transfers 4.1 Employees are required to park in the ACSA long term parking. 4.2 If an individual is travelling for longer than 24 hours, it is recommended that they make use of the Grindrod preferred transport shuttle company to and from the airport. 5. Accommodation and Meals 5.1 An employee is expected to stay in a hotel or other accommodation of an acceptable standard. All business related accommodation must be booked through Grindrod Travel or via the preferred supplier list. The Grindrod Group has a list of preferred hotels where preferential rates have been arranged and these are first choice. All accommodation must be authorized by the line manager. 5.2 If the employee is unable to keep a hotel reservation, Grindrod Travel must be informed well in advance to avoid cancellation charges being levied. 5.3 Should the employee stay with a friend/relative he/she will be entitled to a subsistence allowance as determined by SARS. These rates can be obtained from the Human Resources Department. Subsistence allowances that exceed the limits defined by SARS will be subject to assessment by SARS. 5.4 The following limits apply to meals eaten while an employee is away from home on a business related trip for longer than one day: Breakfast is to be added to the room bill. Due reasonability is to be used for meal and beverage / alcohol choices. 6. Entertainment 6.1 Entertainment is in accordance with the spirit outlined in Grindrod s Code of Ethics. 6.2 Only meals, drinks, golf and other forms of entertainment with non-company personnel relating to Grindrod s business are considered entertainment. 6.3 Meals and other expenses with colleagues from within Grindrod are not considered entertainment for claim purposes. 6.4 Gifts to non-grindrod employees are considered entertainment and are required to be declared on the Gift Register in terms of the Gift Policy. page 3 of 5

7. Foreign Exchange Regulations 7.1 Exchange control regulations regarding foreign currency are to be strictly observed. An employee who intends undertaking an overseas business trip must liaise with their Finance Department to ensure that any special arrangement in regard to Foreign Exchange is made in good time. 7.2 It is Grindrod s preference to pay as much as possible to foreign suppliers through the finance process. Foreign currency issued should be kept to a minimum. 7.3 Foreign currency will be issued to employees going on international business travel to cover expenses that have not been pre-paid by the company. 7.4 All unused foreign currency must be returned to the company immediately after returning from overseas travel. 7.5 No travellers cheques are permitted. 7.6 Each employee issued with foreign currency is required to submit an expense claim with supporting documents to finance. 7.7 Foreign exchange differences may be claimed via the expense claim process. Supporting documents are required in order to claim the difference. 8. Expenses 8.1 Incidental expenses 8.1.1 Other business related expenses (such as petrol, entertainment, etc.) is required be approved by the relevant manager before payment will be made. 8.1.2 This is to be claimed back via the employee expense sheet. 8.1.3 All invoice slips are to be attached to the claim form. 8.2 Travel Reimbursement (private vehicles) 8.2.1 Travel reimbursements will be considered only in cases where the travel was for valid business purposes and only where travel was necessary. 8.2.2 Travel reimbursements may not be claimed where an employee receives a travel allowance as part of their remuneration. 8.2.3 Prior arrangement and approval by the employee s manager must be obtained. 8.2.4 Employees using their private vehicle for company business can claim a reimbursive travel allowance. 8.2.5 The reimbursed rate per kilometre will always be at the gazetted rate. These rates can be obtained from the Human Resources Department. 8.2.6 Employees using their own private vehicle for company business should ensure that their vehicles are comprehensively insured or covered for the balance of third-party, as Grindrod will not be held liable should an accident or theft occur whilst the employee is using his/her private vehicle on company business. 8.2.7 Travel costs will be reimbursed via payroll. The claim forms must be submitted prior to payroll deadline in order to qualify for reimbursement in that month (please liaise with HR for deadline dates). A travel claim form must be completed and authorised by the line manager before payment will be made. 8.2.8 The company reserves the right to amend or cancel the Travel Reimbursement Claim policy if there are suspicions that it is being abused. page 4 of 5

8.3 Allowable Expenses 8.3.1 The basic principle is that reasonable expenses actually incurred while travelling or entertaining, will be reimbursed by Grindrod, provided that claims are submitted within 10 working days of return from travel. 8.3.2 The following expenses may be claimed: Airport parking. For stays exceeding 24 hours, long-term parking must be utilised. Accommodation(including breakfast) and meals Business incidentals such as faxes, telephone calls, postage and the use of Internet. Owing to the high premium levied by hotels on telephone calls, employees are encouraged to use their cellular phone. Due to the high costs of data usage, employees travelling internationally are advised to switch off data usage on cellphones and 3G usage on laptops when WIFI networks are available. Laundry costs will be reimbursed via the expense claim process should a business stay exceed one week Special fees for foreign travel, including costs related to obtaining passports, visas, and required photographs; costs of certificates of birth, health, identity, and related affidavits; charges for required inoculations; and medical evacuation insurance Use of local buses, trains and taxis, including tip 8.3.3 The following expenses may not be claimed: Any costs which may accrue for an employee s spouse if the spouse/partner is not an authorized delegate on the trip. Items of a personal nature such as pay channel TV and mini-bar will not be reimbursed by Grindrod 8.3.4 In the event of an account being subject to a subsequent VAT refund, such refund will accrue to Grindrod and not the employee. 8.3.5 Expenses incurred during the course of travel must be detailed on an expense claim form with itemised supporting vouchers attached, and must be authorised by management. See Annexure A. [template to be drafted]. 8.3.6 An employee planning international travel may request an advance from the Company to cover expenses. As an alternative the employee may utilise his/her own personal credit card and claim the full reimbursement on return. 8.3.7 No employee may approve his/her own expense claim, and the necessary approval must be obtained from the next level of authority. 9. Travel approval 9.1 Any air travel bookings that do not comply with 3.1.1., require prior approval from the Group Chief Executive Officer. 9.2 All international travel is to be approved by the relevant direct report to the Group CEO. 9.3 Regional and international business travel is reported to and reviewed by the Grindrod Limited Executive on a quarterly basis. 9.4 All travel requests are to be created using a travel purchase order duly approved in terms of the limits of authority. No travel and related invoices are to be processed by the finance department without an approved purchase order number. 9.5 For entities that do not use a purchase order system, all travel and related invoices are to be duly signed as approved in terms of the limits of authority. page 5 of 5