POLICIES AND PROCEDURES SECTION: Corporate Policy - Administration NUMBER: OP # 1004 ISSUED: February 25, 2013 SUBJECT: Reimbursable Travel, Entertainment, and Other Business Expense APPROVALS: Executive Vice President, Chief Financial Officer and Treasurer SUPERSEDES: January 1, 2012 I. Purpose: Snyder s-lance, Inc. (the Company ) associates incur travel and other business related expenses while performing their job duties. This policy provides the guidelines for what expenses are reimbursable business expenses. II. Scope and Definitions: 1. The requirements of this policy apply to all of the Company functional areas and all of the Company s wholly owned and majority owned subsidiary companies. 2. The Company reimburses associates for all reasonable and necessary business related expenses. Refer to policy OP#1005 Business Expense Report, Documentation, and Approval for the Company s policy on reporting business expenses. 3. Excluded from this policy are reimbursement for associate relocation, travel expenses for employment applicants, and tuition reimbursement. Human Resources policies and procedures address these items. III. Responsibilities: 1. The Company's associates who incur expenses because of performing their duties as an associate are responsible for being aware of and complying with this policy. 2. All Company associates in a leadership position are responsible for ensuring their department s associates are aware of and comply with this policy. 3. It is the responsibility of each associate to incur business expenses only as required and in a cost effective and reasonable manner. 4. Authority for this policy rests with the Executive Vice President, Chief Financial Officer and Treasurer.
IV. Policy - General: The Company will reimburse associates for reasonable travel and entertainment expenses incurred in the course of doing business. It is expected that all associates will control costs whenever possible. This policy sets forth the following: 1. To ensure available rebates, discounts and/or corporate contracts are utilized, associate travel arrangements should be made through the Company travel agency or a Company-designated travel coordinator for the following: a. Purchase of airline tickets b. Car rental reservations c. Hotel reservations 2. Associates should check with the Company travel agency or coordinator for all other travel related services before using any other source. 3. Associates may use the Company travel agency for personal travel arrangements, at the associate s expense. 4. Associates may enroll in any frequent flyer or other travel award program at their own expense. The credits earned for such programs are for the associate s personal use. 5. Routine travel expenses, including meals, hotels, rental cars, etc. (except for the purchase of airline tickets) are the responsibility of the associate. The Company will reimburse allowable business expenses through the I-Expense system. Special payment arrangements may be set up for associates that are unable to pay for their travel, including temporary travel advances, subject to approval by the functional Vice President. 6. Associates should present questions about acceptable reimbursable expenses to their manager or one level up. V. Policy Allowable Business Expenses: All necessary and reasonable business expenses are reimbursable to the associate, including but not limited to the following: 1. Associate meal expenses including reasonable and customary gratuity while traveling for business, and meal expenses for associate meetings or functions (Section VII), 2. Lodging or hotel room and tax charges (Section VIII), 3. Airline baggage charge, seat upgrades, airfare charges due to flight changes during travel, etc. (Section IX), 4. Automobile expenses such as rentals, fuel for rentals, mileage for personal car use, company car expenses, etc. (Section X), 5. Business gifts: a. Associate Business Gifts (Section XI), b. Business Gifts for Vendors and Service Providers (Section XII), c. Customer-Related Business Gifts (Section XIII), 6. Communication expense, including internet service, incurred while traveling for business (Section XIV), Policy OP # 1004 (Rev. 2/25/13) Page 2 of 9 Reimbursable T&E and Other Expense
7. Reasonable communication charges (internet, telephone, and fax costs) for associate s home when incurred for business use (Section XIV), 8. Train fares, 9. Dues for airline clubs for those flying a minimum of 20 round trips per year, when approved by the functional Vice President, 10. Taxis, ground transportation to and from airports, etc., 11. Reasonable and customary non-meal gratuities for services rendered, 12. Parking fees, including airport and hotel self-park, 13. Toll charges, including E-Z Pass (monthly fees not reimbursable) 14. Dry cleaning services, only if business travel is for more than three consecutive days, 15. Facility room charges for meetings, 16. Subscriptions for business related materials, 17. Dues and memberships for professional associations less than $1,000, 18. Professional license fees, 19. Professional seminar and training fees, 20. Visa and Passport costs for associates required to travel out of the country, 21. Postage and express mail for business mailings. VI. Policy Expenses that are Not Reimbursable: Expenses that are not reimbursable to the associate include, but are not limited to the following: 1. Avoidable hotel no show charges, 2. Travel insurance, 3. Travel club memberships, including AAA and air travel clubs, except airline clubs (Section V.9). 4. Automobile rental insurance coverage (Section X), 5. Normal commuting mileage, 6. Personal vehicle expenses, including gas, maintenance, etc., other than business mileage reimbursement (Section X). 7. Car washes (except Company-owned cars per Section X), 8. Airline charges for fare class upgrades, 9. Credit card finance charges or annual fees, 10. Gifts for associate celebrations, for example gift cards, shower gifts, birthday gifts, clothing purchases, cigars, etc. (Section XI), 11. Large non-cash, and all cash or cash-equivalent business gifts (Sections XI, and XII), 12. Trade spending, (including gift cards) for customers (Section XIII), 13. Cell phone charges (Section XIV), 14. Reimbursement for use of frequent flyer reward miles or other flight coupons for business travel, 15. Parking tickets or traffic violations caused by the associate, Policy OP # 1004 (Rev. 2/25/13) Page 3 of 9 Reimbursable T&E and Other Expense
16. Snacks and beverages consumed between meals, 17. Hotel movie rentals, 18. In-room honor bar expenses, 19. Personal care items or spas, 20. Losses due to theft or fire, 21. Furnishings for home offices. VII. Policy Meals: 1. Meals While Traveling: Reasonable costs of meals are reimbursable. Depending on the circumstances of a particular trip, the costs of one, two or three meals per day may be appropriate: a. Meals en route and at the destination location are reimbursable for overnight travel. Local meals, prior to departure or after return, will not be reimbursed. b. Associates should always take advantage of meals included in the price of a business seminar, conference, etc. c. For day trips (no overnight stay), one meal may be reimbursed when the trip extends beyond the normal workday. 2. Meals with Other Associates: Reasonable costs of meals attended by Company associates are reimbursable only when specifically for business purposes. Examples would include a department lunch meeting, dinner with associates traveling together, etc. Business meals with other associates should be paid for and reported by the highest level, most senior associate in attendance. 3. Meals with Customers: Meals with customers or potential customers for business purposes are reimbursable as entertainment expense (Section XIII). VIII. Policy Hotel and Lodging: Reasonable, single rate hotel and lodging charges are reimbursable: 1. When practical, associates should use the Company travel agency or coordinator for hotel and lodging reservations. 2. Associates should stay in safe, secure accommodations. 3. Hotels should be reasonably priced, such as Fairfield Inn by Marriott, Courtyard by Marriott, Hilton Garden Inn, Hampton Inn, Holiday Inn Express, Spring Hill Suites by Marriott, etc. Associates should consider convenience, the cost of staying in the location in which the hotel is located, and proximity to other venues on the associate s itinerary in determining reasonableness. 4. Associates should use available corporate and discount rates for hotels. In locations where the Company has contracted with a specific hotel, the associate should stay in the contracted hotel. 5. Associates expecting to be at a specific destination for an extended period should arrange lodging at weekly or monthly rates. Policy OP # 1004 (Rev. 2/25/13) Page 4 of 9 Reimbursable T&E and Other Expense
IX. Policy Air Travel: Associates should use the Company travel agency or coordinator for purchasing airline tickets to ensure the Company receives all applicable discounts and rebates. This agency or coordinator is responsible for securing the lowest airfare possible. All airfare expenses are charged to a Company purchasing card. 1. Air travel should be well planned and scheduled as far in advance as possible to obtain the lowest airfare. 2. Associates should travel coach class accommodations for most air travel. Business class is allowable if air travel is longer than seven consecutive hours of one-way flight time or if coach class is not available and the timing of travel is essential. 3. Seat upgrade and early boarding charges are reimbursable up to $40.00 per round trip, if necessary to expedite deplaning due to business schedules or connecting flight times. 4. Associates may accept and retain frequent flyer miles and compensation for denied boarding for their personal use. However, associates may not deliberately patronize specific airlines to accumulate frequent flyer miles if less expensive comparable tickets are available on another airline. 5. If required for business reasons, associates will be reimbursed for flight change fees paid in locations at the airport. 6. The Company travel agency or coordinator should receive all unused portions of airline tickets when credit is expected. 7. The use of private or charter aircraft is prohibited, unless approved in advance by the Executive Vice President, Chief Financial Officer and Treasurer. X. Policy Auto Expenses: Reasonable auto business expenses are reimbursable: 1. Car Rentals: Associates may rent a car when other more cost-effective transportation, such as shuttle services, public transportation, or taxis, is not practical: a. Associates should use the Company travel agency or coordinator for car rental reservations to ensure the Company receives all applicable discounts and rebates. The agency or coordinator is responsible for securing the best car rental rates available. b. Associates should rent a standard size car or smaller, unless carrying more than one passenger or materials requiring additional space. c. If more than one person is traveling to the same destination on similar schedules, associates should share the rental car. d. Associates should refill the gas tank before returning the rental automobile to avoid excessive refueling charges whenever practical. e. A GPS navigation unit may be rented with the vehicle, considering the following: 1) Trips should be pre-planned to avoid the need for GPS where practical, 2) Associates familiar with their routes of travel should not rent a GPS, 3) Frequent travelers should consider the purchase of a GPS unit. This may be more cost effective than frequent GPS rental fees. Policy OP # 1004 (Rev. 2/25/13) Page 5 of 9 Reimbursable T&E and Other Expense
f. Associates involved in rental car accidents should report the incident to their manager and Safety/Risk Management immediately. g. The Company is self-insured. As a result, associates should not purchase additional auto insurance coverage. 2. Company Cars: Reimbursable automobile expenses for associates with Company owned cars are as follows (also see Company Policy OP#1010, Company Car Policy): a. The Company normally assigns fuel cards to associates for the purchase of all fuel for their Company car (fuel cards cannot be used for personal vehicles). Fuel purchases for Company cars are reimbursable only for associates that have not been issued a fuel card for their vehicle. b. Car washes for Company owned cars, not to exceed $25.00 per month, are reimbursable. This is to assist in maintaining the value of the Company vehicles. c. Aftermarket accessories added to company cars are reimbursable with the approval of the associate s manager. d. Associates with Company owned cars are not eligible for mileage reimbursement for driving the company car or their own personal vehicle. e. Associates should report all car repair and maintenance issues to the Snyder s Lance Fleet Services department. In most cases, the Company will pay the service provider directly for these expenses. However, the associate may pay necessary expenses for emergency and/or safety reasons. Upon notification of Fleet Services, those expenses are reimbursable. 3. Personal Vehicles: Associates using a personal vehicle for business travel may be eligible for mileage reimbursement for miles driven that exceed the normal daily commute to their normal work location: a. Associates participating in the Company Fixed and Variable Rate (FAVR) business mileage program are not eligible for mileage reimbursement through the Company expense reimbursement process (I-Expense). Associates in the FAVR program report mileage and are reimbursed in accordance with the FAVR program through a separate system. b. Associates not participating in the FAVR program or do not have a company car are eligible for mileage reimbursement at the approved rate for mileage reimbursement. XI. Policy Associate Business Gift Expenses: The Human Resources Department is the primary contact for associate gifts, such as rewards and recognition. These purchases (including gift cards) should be coordinated and approved through your Human Resources Department. Gifts to associates may qualify as reportable compensation, and require tracking and recordkeeping to ensure regulatory compliance. 1. Meals with associates are reimbursable as a normal business meal (Section VII). 2. Nominal and reasonable non-cash business-related gifts, such as Company items given to participants in business meetings, are reimbursable. The names of all associates receiving the gifts must be provided for reimbursement. 3. Cash or cash-equivalent business gifts (such as gift cards, pre-paid debit cards, etc.) are not a reimbursable expense. Policy OP # 1004 (Rev. 2/25/13) Page 6 of 9 Reimbursable T&E and Other Expense
XII. Policy Business Gifts to Vendors, Service Providers, etc.: The Company prohibits associates from giving gifts in any circumstance where the gift is intended to (or could be perceived as intended to) influence action by the recipient in business matters between the Company and another entity. Company associates should not give business-related gifts to vendors, service providers, etc. unless the gift is offered as a normal business courtesy (such as lunch or dinner) and is of nominal value. 1. Meals with vendors, etc. are reimbursable as a normal business meal (Section VII). 2. Nominal and reasonable gifts, such as Company logo items given to participants in business meetings, are reimbursable. 3. Cash or cash-equivalent business gifts (such as gift cards, pre-paid debit cards, etc.) are not a reimbursable expense. 4. All business gifts require pre-approval by department management, and should be in conformity with the Company Code of Ethics. XIII. Policy Customer-Related Business Expense: 1. Business Gifts to Customers: The Company prohibits associates from giving gifts in any circumstance where the gift is intended to (or could be perceived as intended to) influence action by the recipient in business matters between the Company and another entity. The intent of business gifts to customers should be to improve or enhance Company business relationships, financial position, or marketability of products. a. All business gifts require pre-approval by department management, and should be in conformity with the Company Code of Ethics : b. Non-cash business gifts should be reasonable and appropriate for the customer. Associates should purchase these gifts through the normal Company procurement process. However, appropriate nominal gifts may be reimbursed through the I-Expense process. c. Cash or cash-equivalent business gifts (such as gift cards, pre-paid debit cards, etc.) require additional restrictions and controls. Cash-equivalent business gifts should not be purchased and reimbursed through the business expense process described in this policy. These gifts should be coordinated/purchased through the Company Procurement Department, and detailed records must be provided that specify the purpose and the recipients of the gifts. d. Associates with questions regarding business gifts should present them to their manager, one level up, or the Company s Legal Department. Policy OP # 1004 (Rev. 2/25/13) Page 7 of 9 Reimbursable T&E and Other Expense
2. Entertainment Expenses: Entertainment expenses, such as sporting events and meals with clients are for business purposes only. All entertainment activity should be in conformity with the Company Code of Ethics. Significant entertainment expenses should be pre-approval by the associate s manager. Associates should present questions about acceptable entertainment activity to their manager, one level up, or the Company s Finance Department. a. Meals with customers and potential customers are reimbursable as an entertainment expense (not meals ). b. Entertainment expense for the client s spouse or prospective client s spouse is allowable when associated with conducting Company business. c. Inappropriate entertainment expenses are not reimbursable, including gambling and any other activity that could be considered offensive or obscene. d. Functions attended only by Company associates (no current or potential clients or customers) are not considered entertainment expense. Reimbursement of these expenses will be according to other sections of this policy. 3. Trade Spending and Sales Development: a. Business expenses authorized through the Company trade spending program are not reimbursable expenses through I-Expense. These expenses should be managed through the applicable processes such as Purchasing and Accounts Payable. b. Trade spending and sales development expenses that should not be reimbursable through I- Expense include but are not limited to: 1) Event sponsorships 2) Promotion expenses 3) Cash 4) Gift cards 5) Membership fees 6) Donations XIV. Policy Communications Expense: 1. Cell phone costs are not reimbursable through the expense reimbursement process described in this policy. Associates routinely using cell phones for business use are reimbursed according to Company policy OP#1008, Cell Phone Reimbursement. 2. An associate receiving a Company cell phone allowance should use their cell phone for business use whenever possible to avoid unnecessary phone charges. Other telephone charges, other than cell phone charges, incurred during the normal course of business travel are reimbursable to the associate. These charges include: a. Long distance charges, b. Fax charges, c. Hotel local access fees Policy OP # 1004 (Rev. 2/25/13) Page 8 of 9 Reimbursable T&E and Other Expense
3. When traveling for business, use the Company 800-phone numbers for calling Company locations. This is the least costly method for the Company. These 800-phone numbers are 1-800-438-1880 for the Charlotte Support Center and 1-888-722-1163 for the Company Cisco Unity answering system. The Cisco Unity answering system provides access to the Company operator, the Company directory, and a listing of 800 numbers for other Company locations, if the contact s direct extension is unknown. 4. Internet connection fees used for business purposes at airports, in-flight, and at hotels are reimbursable. If more cost effective, frequent travelers will be reimbursed for subscriptions to commercial internet access programs. 5. Reasonable communication charges (internet, land-line telephone, and fax costs) for an associate s home are reimbursable, but should only include actual costs incurred by the associate directly due to business use. Home communication expenses will be reimbursed only under the following conditions: a. The associate is using his or her home as their primary office location, and communication access is specifically required for the associate to fulfill work responsibilities (and the Company is not providing them with a Company office of business location for their routine use), b. The requested amount for reimbursement represents the actual portion of the associate s home communication expenses that are attributable to business use. The associate should include copies of bills/invoices with the reimbursement request, and maintain records that support the reimbursed portion of the expenses. c. If the associate is receiving an allowance for internet access ( Tethering/Laptop Internet Card ) per Policy OP#1008, Cell Phone Reimbursement, the associate is not eligible for home internet reimbursement, and d. The expense is authorized by the functional Vice President. XV. Combined Business and Personal Trips: 1. If an associate traveling for business purposes decides to take a vacation either before or after the business trip or brings along family members, the cost of the trip should be split appropriately between business and personal expenses. Only business expenses will be reimbursed: a. Hotel Accommodations: If the associate has family members travel with them, only the single accommodations rate will be reimbursed for the business portion of the trip. If the associate extends the trip beyond the number of days required to complete the business purpose of the trip, those additional nights are considered personal and costs will not be reimbursed. b. Meal Expenses: Only associate meal costs, including tax and reasonable gratuity, will be reimbursed. c. Other Travel-Related Expenses: Usual costs for associate business travel, as defined in this policy, are reimbursable. All costs generated as a result of non-associates on the trip are considered personal expenses, and will not be reimbursed. 2. Costs for travel to Company sponsored events that invite associate spouse or guest are reimbursable: a. Events involving reimbursable spouse or guest travel must be approved in advance by the functional Vice President. b. Spouse or guest reimbursable expenses will follow the same guidelines as provided in this policy for Company associates. Policy OP # 1004 (Rev. 2/25/13) Page 9 of 9 Reimbursable T&E and Other Expense