Travel & Expense Policy

Travel & Expense Policy As a condition of being part of the Benefit Counselor Team, you should refer to the Travel & Expense Policy prior to incurring expenses to ensure compliance with set policies. Being cost effective is critical to our success in terms of competing in the marketplace. To that end, we have developed comprehensive expense policies and practices with an eye toward effectively reducing costs. Periodic revisions will be made to this policy and you should refer to it prior to making any travel related arrangements or expenditures, or planning or incurring expenditures for food, entertainment or meetings. We will also notify you anytime we make revisions. Contact Information Any questions, concerns or suggestions regarding this Policy may be directed via email to Kathleen Pauley (kathleen.pauley@thehartford.com). Table of Contents 1.0 Scope and Purpose...2 2.0 Responsibilities, Exceptions and Enforcement...2 3.0 Pre-Approval Authorizations...2 4.0 Travel Arrangements...3 5.0 Air Travel...3 6.0 Lodging...4 7.0 Rental Cars...4 8.0 Personal Car use, Chauffeured Car Service, Other Transportation...5 9.0 Telephone Usage...6 10.0 Personal Travel in relation to Business Travel...6 11.0 Meals...6 12.0 Gratuities... 6 13.0 Travel & Entertainment Reimbursement...7 14.0 Other T&E Related Reimbursement Expenses...7 15.0 Other T&E Related Non-Reimbursable Expenses...8 1

1.0 Scope and Purpose 1.1 Scope The Travel and Expense ( T&E ) reimbursement Policy ( Policy ) applies to benefit counselors representing The Hartford Financial Services Group, Inc. and its subsidiaries ( The Hartford or Hartford ). 1.2 Purpose This document states policy for benefit counselors expecting reimbursement for incurring travel and expense related expenses on The Hartford s behalf. 1.3 The objectives of this Policy are to: Ensure benefit counselors have a clear and consistent understanding of policies and procedures for business travel, and expense reimbursement. Reduce costs by enforcing compliance to maximize The Hartford s ability to negotiate discounted rates with preferred suppliers. 2.0 Responsibilities, Exceptions and Enforcement 2.1 Responsibilities Business managers and approvers are responsible for enforcing this Policy. Counselors are responsible for complying with the Policy. Pinnacle is responsible for reimbursing counselors for all reasonable and necessary expenses while conducting authorized Hartford business. Pinnacle assumes no obligation to reimburse counselors for expenses that are not in compliance with this Policy. Counselors incurring business expenses (including travel) on The Hartford s behalf must meet the terms specified in this Policy. 2.2 Enforcement and Exceptions Counselors who are not in compliance with this Policy, including the Pre-approval Authorization, are subject to possible non reimbursement of expenses. Thus, it is imperative that all Hartford counselors fully understand The Hartford s Travel & Expense Policies and Procedures before partaking in business activities that may require payment. 2.3 Spouse/Companion Expenses in Relation to a Hartford Enrollment Event Travel and/or entertainment expenses incurred by a spouse or other individual accompanying a benefit counselor on business are not reimbursable. The Hartford will not reimburse childcare costs regardless of spousal attendance. 3.0 Pre-Approval Authorizations Pre-Approval Authorization Any overnight hotel stay that is over $200 per night must be approved before being booked. Approval must be given by your Voluntary Enrollment Specialist. Any airline flights that are over $700 must be approved before booking. Approval must be given by your Voluntary Enrollment Specialist. 4.0 Travel Arrangements You are responsible for making all travel arrangements. Policy Questions Any questions, concerns or suggestions regarding this Policy may be directed to Kathleen Pauley. 2

5.0 Air Travel Airfare should be booked no earlier than 2-4 weeks in advance, if possible; obvious exceptions would be assignments taken less than 2 weeks prior to an event. Non-refundable airline tickets should be purchased; if an event is cancelled, The Hartford will reimburse the flight however the credit should be used for a future Hartford enrollment event that requires airline travel. Lowest priced logical airfare shall be booked. Lowest priced logical airfare is determined using the following criteria: Lowest priced logical airfare is the lowest priced flight with no more than one connection, each way, provided that the layover for the connection does not exceed 2 hours. However, a flight without a connection whose price is no more than $100 greater than the flight with one connection may be chosen. All air travel must be in coach class. Use of private or chartered aircraft is not allowed under any circumstances. Airline Frequent Flyer Program benefits are allowed to be retained by the benefit counselor but will not be an acceptable explanation for choosing an airfare with a price greater than the lowest priced logical airfare. 5.1 Additional Airline Fees (ancillary fees, internet, upgrades, airline club programs) Carry-on and checked baggage fees vary by airline carrier, The Hartford will reimburse for the normal/applicable baggage fees. We will reimburse baggage fees for one bag unless preapproval is given by Kathleen Pauley. Ancillary fees such as pre-boarding/early check-in fees, seat assignment and seat upgrade fees (i.e. exit row, extra leg room) and ticket/class upgrades are non-reimbursable expenses. Excess baggage fees will only be reimbursed if: - Traveling with heavy or bulky materials or equipment necessary for business. - The excess baggage consists of the authorized transportation of Hartford records or property. - Traveling for more than fourteen consecutive days. In-flight internet or phone connectivity fees and airport WIFI connectivity fees are not reimbursable. Airline club memberships are non-reimbursable expenses 5.2 Lost and/or Stolen Baggage & Tickets Measures that can be taken to minimize baggage losses include: Always carry valuables (e.g., jewelry, laptop computers, cameras, etc.) on board the aircraft. Always carry important and/or confidential documents on board the aircraft. Clearly tag luggage with name, address and phone number. Retain baggage claim receipts for checked luggage. Lost Baggage Compensation The ultimate responsibility for retrieving and compensating for lost baggage lies with the airlines. Lost Baggage Procedures Follow these procedures if your bags are lost en route: Obtain a lost luggage report form from an airline representative in the baggage claim area. Itemize the contents of your bag, including receipts wherever possible. Include a copy of your airline ticket and baggage claim stubs. Keep a copy of the report, airline ticket and claim stubs. Lost or Stolen Airline Tickets Immediately upon discovery of a lost/stolen ticket, the counselor should fill out a lost ticket application at the airline ticket counter. The counselor is responsible for the value of lost tickets and any service charge for 3

replacing the lost ticket. The Hartford will NOT absorb the cost of a lost ticket, including fees charged by the airlines for processing the lost ticket application. 5.3 Travel Insurance Coverage Travel insurance coverage is not reimbursable. 5.4 Overnight Delays Traveler must first attempt to secure complimentary lodging from the airline. If unsuccessful, any additional and reasonable costs will be reimbursed. 5.5 Parking Reimbursement for short-term parking at airports is not permitted due to excessive cost. 6.0 Lodging Standard-sized, single room rate must be booked; Extended Stay Hotels are allowed if the price comparable to a standard room. Travelers may retain awards from Hotel Point Programs for personal use. Participation in these programs shall not influence hotel selection. Any membership fees associated with joining these programs are not reimbursable. Benefit Counselors can stay as guests at the home of relatives, friends or acquaintances. In the event this is done, benefit counselors will not be reimbursed for any type of compensation (payment, gifts, meals and/or other forms of entertainment). 6.1 Additional Hotel Fees (internet, fitness, check-out) If WIFI is not already included in the room rate it will be reimbursable. In general, hotels will provide health and fitness facilities at no additional charge. Fitness center charges outside of hotels, or for preferred hotels that require an additional charge, will not be reimbursed. Early check-out fee will be reimbursed if the traveler is required to check out earlier than stated on the reservation due to business requirements. The traveler should consult with the hotel reservations desk to determine if a check-out fee is applicable. 6.2 Hotel Cancellations No-show charges will not be reimbursed. Benefit Counselors should be aware of the booked hotel s cancellation policy. We will not reimburse hotel rooms with non-refundable rates when cancelled. 6.3 Parking Valet parking expenses are only reimbursable if there is no available option to self-park at the hotel. 7.0 Rental Cars Liability & Loss Damage Waiver insurance is required with every business rental. Avis business rentals booked under Corporate I.D. Number G561400, National Car business rentals booked under Corporate I.D. Number NA 48100 and Enterprise business rentals booked under Corporate I.D. number NA48100 provides this coverage. Loss Damage Waiver or equivalent coverage must cover any loss or damage to the rental vehicle, whether due to theft, collision, vandalism or any other cause. Liability Insurance covers Bodily Injury or Property Damage to a third party. When picking up a rental car, counselors should check with the rental car agent for any promotional rates, last-minute specials or free upgrades. If a promotional rate is obtained, confirm The Hartford ID that appears on the rental agreement to ensure contracted insurance provisions will be 4

applicable. Important: If unable to rent with a preferred supplier, counselors must purchase LDW and Liability insurance. The minimum Liability limits that should be purchased are $100,000 per person, $300,000 per accident for Bodily Injury and $50,000 for Property Damage. This will be reimbursed. 7.1 Rental Car Re-Fueling and Accessories The rental vehicle must be returned with a full tank of gas to avoid refueling fees by the car rental company. Fuel charges for use during rental and fill-up prior to returning the rental car are reimbursable Pre-fueling options must not be purchased Costs associated with car accessories such as a GPS system, etc. are not reimbursable. Rental cars should be returned: intact (i.e., no bumps, scratches or mechanical failures) on time, to avoid additional hourly charges with a full tank of gas 7.2 Rental Car Accident Procedures If a rental car accident occurs, counselors should contact Pinnacle, The Hartford, the rental car company and the local authorities, and your insurance company as required. As a general policy, Pinnacle does not provide reimbursement to counselors under those circumstances. Included in this category of non-reimbursable expenditures includes insurance deductibles. Any such expenditure is the sole responsibility of the individual counselor and should be resolved amongst the counselor and the counselor s insurance company. 8.0 Personal Car use, Chauffeured Car Service, Other Transportation 8.1 Personal Car Use Benefit counselors should always endeavor to choose the least costly form of transportation. When evaluating whether to use a personal vehicle, the following should be considered: Is it more efficient (timelier) than taking public transportation Is it less expensive than renting a car, taking a taxi or alternate transportation Am I transporting Hartford goods for delivery 8.2 Personal Car Use Reimbursement If the use of a personal vehicle is chosen: Parking and/or traffic tickets/fines are not reimbursable. Benefit counselors will be reimbursed for up to a maximum of 250 miles per day at a fixed rate set by the Internal Revenue Service of.54 cents per mile (effective January 1, 2016). Counselors will be reimbursed for business usage of personal cars at a fixed rate set by the Internal Revenue Service. Please check with your manager on the updated amount per mile. This rate is designed to approximate expenses for gasoline, oil, personal insurance and normal wear and tear. To be reimbursed for use of their personal car for events, counselors must provide the purpose and destination of the trip (to - from), date and the number of roundtrip miles in the expense report. Expenses for items such as parking fees and tolls are reported separately on the expense report. Receipts are required for all parking fees and tolls over $15.00. 8.3 Chauffeured Car Service Chauffeured car service should not be used as a Counselor. If you feel the need to use this option, it must be pre-approved by Kathleen Pauley. 8.4 Other Transportation Benefit counselors are expected to choose the most cost effective means of transportation at all 5

times. Taxi, Rail (Amtrak) or Mass Transit (Commuter train -i.e. Metro North, Subway, Bus) travel may be used if it is available and cost effective. The use of taxis is encouraged for local travel, where no other more economical means of transportation is available (i.e. airport shuttle/private car). 9.0 Telephone Usage Benefit counselors shall not be reimbursed for cell phones calls while traveling on business. Benefit counselors should take advantage of free WIFI areas to use other communication methods The cost of phone calls from hotel phones will not be reimbursed. Benefit counselors will not be reimbursed for telephone calls, either business or personal, made from air phones or rail phones. 10.0 Personal Travel in relation to Business Travel Combining Personal with Business Travel is allowed in certain circumstances. Personal/vacation travel may be combined with business travel: Provided there is no additional cost to The Hartford. The Hartford will NOT pay or reimburse for vacation expenses such as sightseeing, bus tours, souvenirs and personal expenses, such as movies, health club fees and meals. 11.0 Meals 11.1 Meals While Traveling Meal refers to food, refreshments and/or beverages. Use of alcoholic beverages will be monitored. The Hartford will only reimburse counselors for meal costs provided at a business establishment. Meal expenses while on business related travel are reimbursable. When a counselors business related travel includes an overnight, counselors will be reimbursed for meal expenses up to a daily maximum limit (including taxes and gratuities) of $60.00 for meals. When the business related travel does not require an overnight stay, the meal expense daily maximum limit (including taxes and gratuities) is $20.00. While traveling, counselors should maintain itemized receipts for expenses above $15.00; without these receipts those expenses will not be reimbursed. 12.0 Gratuities Gratuities for services such as those listed below will be reimbursed, based on the destination and quality of service rendered. Any tips or gratuities considered excessive will not be reimbursed. Suggested gratuities are: Airport Skycap Porter $1 per bag Bell Service/Porter $1 per bag Valet Parking $1-$2 (if baggage, $1 per bag) Lobby Attendant (None for opening doors or calling a taxi from the stand; $1 for help with luggage or obtaining a taxi from the street) Housekeeping $1/$2 per day Taxi drivers 15% of the total fare Wait Staff 15% of the total bill (excluding taxes) 6

13.0 Travel & Expense Reimbursement 13.1 Benefit counselor Travel and Expense Reimbursement Benefit counselors must file their travel and expense reports within 30 days of the date the expense was incurred. Benefit counselors failing to file for expense reimbursement within the 30 day period will be denied reimbursement. Expenses on the expense reimbursement report must be categorized appropriately or the expense report will be denied. It is the responsibility of the approving supervisor to deny any incorrect or incomplete expense reports. Receipts must be reviewed prior to an expense report being approved. Denied expense reports are automatically returned to the counselor for corrective action and re-submission. After the counselor s expense report has been submitted and approved, reimbursable amounts will be paid out according to the payroll company s procedures. 13.2 Receipt Requirements Counselors must submit itemized receipts for: All meal, transportation, and misc receipts A detailed invoice for Hotel/Lodging is required regardless of the dollar amount Documentation requested at the discretion of The Hartford should also be provided The Hartford will only reimburse expenses up to $15.00 without an itemized receipt Approvers must be able to view the receipts uploaded into the Beeline system before they can approve the expense report. 13.3 Acceptable Receipts Original receipt completed by the vendor (e.g. hotel folio, taxi receipts) Card billing statement, when other supporting documentation is not available, accompanied by a full explanation For air travel include: Proof of who traveled How the airfare was paid i.e., itinerary, eticket, etc. 13.4 Unacceptable Receipts The following receipts are NOT acceptable: Restaurant tear tabs Receipts which have been modified or are handwritten 14.0 Other T&E Related Reimbursement Expenses Benefit counselors may be reimbursed for the following other expenses when incurred while conducting business on behalf of The Harford: Materials printing and shipping If asked to print and/or ship materials, please notify Kathleen Pauley. Luggage check-in fees Parking fees necessary for conducting business Tolls 7

15.0 Other T&E Related Non-Reimbursable Expenses In addition to those already described in the Policy, benefit counselors will not be reimbursed for the following other expenses while traveling on business or otherwise: Airline ticket upgrades Amusements Baby-sitting, child-care costs Business office expenses (fax, copy services, etc.) Car washes for non-hartford vehicles Court costs Credit card and reward membership fees Faxes Frequent flier membership charges GPS (Global Positioning System) or any other rental car upgrade Gum or candy (unless purchased for a Benefit Fair you attended) Hotel cancellation (no show) charges In-flight alcoholic drinks Laundry/valet services, Lavish or unreasonable gratuities Medical bills incurred during domestic travel Movies (including in-flight and hotel in-house movies) Newspapers/magazines Office supplies and equipment Optional travel or baggage insurance Pet care Phone usage - Air, Rail and other transportation-provided phones Rental car upgrades Routine maintenance/tune-ups Safe-deposit box rentals (for high-valued items not to be confused with hotel in-room safes) Service charge for using ATM Snacks or nonstandard meals for individual consumption (excludes pre-approved events) Software Spouse/companion travel Unsupported, unexplained expenses Medical bills incurred during domestic travel Movies (including in-flight and hotel in-house movies) Newspapers/magazines Non-profit board membership fees unless membership is required by The Hartford. Optional travel or baggage insurance Parking or traffic tickets and fines Personal expenses of any type, including but not limited to personal care products and services, personal purchases, personal entertainment and personal accident, medical, travel, automobile, property or liability insurance, personal items not required for business lost on the trip (i.e. camera) 8