PURPOSE This document describes CBOE s policies and procedures relating to travel, meals, entertainment, meetings and other business expenses. It identifies acceptable expenses and the manner in which an individual should seek reimbursement for, or request payment of, acceptable expenditures. All individuals are required to use good business judgement (e.g. reasonable spending levels, etc.) while performing CBOE business activities. SCOPE This document is intended primarily for the use of employees of CBOE, directors, consultants or other individuals that may incur expenses while performing work on behalf of CBOE. When this occurs, those individuals must comply with the applicable requirements of this policy. In addition, employees who arrange interviews for prospective employees that currently live outof-town should ensure that this policy is followed with respect to candidate travel, lodging and meals. CBOE will not pay or reimburse an employee for expenditures not expressly provided for in this policy. In addition, CBOE will not reimburse employees for: 1) non-business related expenses; 2) expenses which are reimbursed by others; 3) political contributions; 4) gas, oil or repairs to a personal automobile; or 5) any payment which is illegal, improper or prohibited by CBOE s Code of Conduct policy. The Chief Accounting Officer will approve any expense reports which contain expenses that are outside CBOE s travel policy. POLICY ENFORCEMENT Disregard for CBOE s travel policy, misappropriation of funds or altering or falsification of receipts or expenses will result in disciplinary action up to and including termination, reimbursement of funds and/or prosecution. Workplace Policies Page 1 of 11 December 2015
BUSINESS TRAVEL Business travelers are encouraged to utilize CBOE s corporate travel agency, Travel Solution Inc. (TSI), at http://www.tsiusa.com/cboe. Agency information is also located on the CBOE intranet. You may contact TSI directly for 24/7 agent assistance, but we encourage you to make your travel arrangements on-line whenever possible. We have selected TSI as our corporate travel agency as they are able to use a combination of travel networks, supplier consortiums and negotiated discounts to help us control travel expenses. We believe they will provide a sound travel management program that is convenient and easy to use. Travel authorizations are required for all employees prior to beginning business travel. The employee traveling must not charge their airfare to someone else s credit card. The cardholder is liable for all charges made on their American Express corporate credit card. Thus, the cardholder is responsible for reconciling his/her own account and must submit expense reports to CBOE s Accounting Department with proper documentation for reimbursement. Class of Service: CBOE will reimburse for coach class travel for employees. An employee may elect to fly business class on international flights longer than six hours in duration; however coach class is urged in an effort to save on travel expenses. CBOE Board of Directors may travel first class The standard class of domestic travel for the CEO and President is Coach, however CBOE will reimburse for upgrades. When using frequent flyer miles to upgrade a Coach ticket to a Business class ticket, CBOE will only reimburse an employee for the value of the Coach ticket. Employees must take advantage of the lowest fare available (if practical) and should make travel arrangements at least seven days prior to departure whenever possible. Employees may not choose a more costly flight based solely on airline preference or a mileage award program. CBOE has negotiated a corporate contract with United Airlines which may result in airfare savings over other carriers. As a result, United Airlines should be utilized when it is the most cost-effective choice. Workplace Policies Page 2 of 11 December 2015
Travelers may take advantage of discounted airfare requiring Saturday night stay-over when available. In such cases, CBOE will reimburse for additional expenses incurred (additional night of lodging, applicable meals and car rental) provided these expenses do not exhaust the airfare savings. The amount of airfare savings must be requested in writing from the corporate travel agency at the time the airfare is booked. Documentation of the airfare savings compared to the additional costs is required with the related expense report. The corporate travel agency should be notified as soon as practical but no later than two weeks of any unused airline tickets, including non-refundable tickets. The CEO and President/COO should avoid flying together. TRAVEL WARNINGS ISSUED BY THE U.S. DEPARTMENT OF STATE Periodically, the U.S. government issues travel cautions, alerts, and warnings concerning travel outside of the United States. Sometimes the caution, alert, or warning refers to a particular region of the world or may even refer to a particular region of a particular country. CBOE employees who are travelling outside of the U.S. are encouraged to review the government website at http://travel.state.gov/content/passports/en/alertswarnings.html for further information before travelling abroad. Further, CBOE employees are prohibited from travelling abroad to countries or regions of countries for which the U.S. government has issued a travel warning. Safety of our employees is our highest concern. LODGING All hotel reservations must to be arranged through CBOE s corporate travel agency unless the event is a CBOE sponsored event with a master account. The current agency contact information is reservations@tsiusa.com. You can speak to an agent 24/7 by calling (214) 915-9128 or (866) 396-1078. Travel information can also be found on the CBOE intranet at http://www.tsiusa.com/cboe The hotel bill must be itemized when completing an expense report. Employees are required to stay in reasonably priced hotels in standard single rooms. Employees must take advantage of the hotel choices offered through the corporate travel agency if they are available. These hotels will be displayed on the Travel Solution Inc. website designated by a diamond and marked CBOE rate when booking a reservation. Dismissing the alternatives provided by the travel agency requires a business explanation from a Department Workplace Policies Page 3 of 11 December 2015
Head and/or Division Head approval, which is required to be included in the expense report documentation. CBOE corporate travel agency will automatically guarantee hotel reservations for late arrival. Employees must notify the corporate travel agency of any cancellation or change as soon as possible. The employee must contact either the travel agency or the hotel directly to avoid no-show charges. Employees will be responsible for no-show charges if they could have been avoided. Hotel Internet charges which are business related will be reimbursed. GROUND TRANSPORTATION When traveling out-of-town, employees should use public transportation, airport bus or a taxi instead of a rental car whenever possible and practical. Costs for such transportation are reimbursable. In the event a rental car is required, all rental car reservations should be arranged through CBOE s corporate travel agency, Travel Solution Inc. (TSI), to obtain volume discounts. CBOE will reimburse for a mid-size car. CBOE carries liability coverage on employees, members and Board of Directors driving rental cars on CBOE business. When not using the corporate credit card for car rental, Collision and Comprehensive Damage Waiver option (known as Deductible Protection ) shall not be purchased and will not be reimbursed. Write Your Name(s)/CBOE as joint renters of the automobile. If more than one employee, member or Board of Director will be driving, all driver s names should be entered on the rental contract to ensure liability coverage. Personal use of a rental car is not included in CBOE insurance coverage. example, if a car rented for CBOE business is kept over the weekend for personal use, the individual may need to take out supplemental coverage at their own expense. Rental and insurance costs related to personal use are not reimbursable. The use of limousine and chauffeur-driven cars are permissible only for transportation to and from the airport and only when it is the most cost efficient form of transportation available or as deemed appropriate by a Department Head, Division Head or a member of the Board of Directors. Where appropriate, including weekend in-town work, employees will be reimbursed for the use of their personal auto at the current IRS mileage rate. Parking and tolls For Workplace Policies Page 4 of 11 December 2015
MEALS will be reimbursed at cost. This allowance represents full compensation for use of the automobile on CBOE business in lieu of the actual cost of operation. Employees will be reimbursed for cab fares related to local travel for meetings, seminars or other similar circumstances. Cab fares resulting from working late will also be reimbursed provided the employee has worked at least four hours beyond the normal work day and approval is obtained from the employee s manager. CBOE encourages obtaining and submitting all cab receipts for expense reimbursement, especially for fares over $25. For employees temporarily assigned to the Remote Data Center, business mileage will be reimbursed. CBOE will reimburse an employee traveling away from home on CBOE business for actual out-of-pocket breakfast, lunch and dinner expenditures, to the extent that they are not lavish or extravagant. All reimbursement requests of more than $25 must be substantiated with an original receipt from the business establishment including their name, address and telephone number, whenever possible. Receipts are encouraged for all reimbursement requests. If two or more CBOE employees are away from home together for CBOE business purposes and happen to dine together, the senior employee is required to pay for the meal and submit the expense report. Meals where only CBOE employees are present (other than while traveling on CBOE business) are not reimbursable even though CBOE business is discussed unless the expenditure is approved by a Department Head or Division Head. DRY CLEANING Dry cleaning and laundry costs, within reason, will be reimbursed if the traveler is away from home five consecutive business days or more, or when the traveler is required to wear business attire that requires attention as a result of being packed away for an extended period of time. The intent of this policy is not to pay for dry cleaning or laundering of clothes that were used during the assignment, but rather to provide for dry cleaning or laundry of clothes that will be re-worn or require attention during the assignment. Workplace Policies Page 5 of 11 December 2015
THEFT OR OTHER LOSSES, FINES AND PENALTIES CBOE will reimburse an employee for replacement of minimal essentials resulting from theft, accident, lost luggage or other cause. If an employee s luggage is lost by an airline, the employee should file a claim with the airline. In addition, travel insurance is provided by CBOE s corporate American Express credit card for transactions charged to the corporate credit card. Employees are expected to comply with all federal, state and local laws, ordinances and statutes regulating personal conduct and the operation of a motor vehicle. Fines for traffic violations, parking tickets or other similar matters are not reimbursable. ENTERTAINMENT AND BUSINESS MEETINGS Qualified expenditures for business meals and entertainment are reimbursable to the extent that they are not lavish or extravagant. CBOE will reimburse an employee for actual entertainment expenses incurred (including meals with customers, associates, or other industry contacts) in the furtherance of their duties at CBOE, provided there is a substantive CBOE business purpose for the expense. All reimbursement requests for entertainment or business meal expenditures must meet Internal Revenue Service (IRS) substantiation requirements including all original receipts, name and business affiliation of each individual present, the business relationship to the taxpayer and the business purpose. Pursuant to IRS regulations the nature and time of the business discussion shall be included as part of the reimbursement request. Original receipts are required for all entertainment expenditures in excess of $25. Although not required, all individuals are encouraged to submit receipts for all purchases regardless of the price. If two or more employees are entertaining CBOE business guests, the senior employee is required to pay for the entertainment or business meal and submit the reimbursement request for approval. CBOE will generally not reimburse an employee or pay for the cost of business meals, entertainment, or meetings where only CBOE personnel are present. This includes departmental meetings and farewell celebrations for departing employees. Exceptions to this policy will be made only with prior written approval of a Department Head and/or Division Head. A copy of the written approval must be included in the expense report. Workplace Policies Page 6 of 11 December 2015
TIPS The cost of a welcome lunch for a new hire will be reimbursed if deemed appropriate and approved by a Department Head. This lunch should generally be attended by no more than 2 3 co-workers. A retirement party for a long-standing employee must be approved by the Division Head and President. The cost of entertaining business guests at an employee s home is not reimbursable. Tips for meals and refreshments should be included in the meals or entertainment expense as part of the total cost of the item reported. Tips should generally be 15% - 20% of the cost of meals or refreshments. General guidelines for other tips (sky caps, bellmen, doormen or maids at the hotel) are $2 for each bag, hailing of cab, or night of stay, respectively. Tips to taxi drivers should be included as part of the total taxi fare on the expense report. In general, tips should be no more than 15% - 20% of the cab fare domestically and in line with local international customs. TELEPHONE Business telephone calls are fully reimbursable. Any staff member that has a CBOE cell phone should use that phone while travelling. If a CBOE cell phone is not used, reimbursement requests must include a copy of the related phone bill indicating the call for which reimbursement is requested. Individuals traveling on CBOE business will be reimbursed for reasonable personal calls. NON-BUSINESS TRAVEL AND ACCOMPANIMENT BY GUEST CBOE will not reimburse an employee for any expenses related to personal travel. If a CBOE business trip is extended for personal reasons, all expenses incurred as a result of the extension are the responsibility of the employee and are not reimbursable. In order to qualify for business related reimbursement, the primary purpose of a trip must be CBOE business. An employee who happens to transact CBOE business while on vacation or traveling for personal reasons will not be entitled to reimbursement for expenses incurred. If an employee, is on a scheduled vacation or traveling for personal reasons and during their travels, is required by his/her manager to attend a meeting, transact CBOE Workplace Policies Page 7 of 11 December 2015
business by telephone or entertain for business purposes, then the direct cost (i.e. cab fare to the meeting, cost of the telephone call or cost of meal/entertainment) of transacting CBOE business will be reimbursed. All other expenses which are related to their scheduled time off (such as airfare, hotel, auto rental, limousine, cab or mileage to/from airport) are non-reimbursable. Scheduling of business meetings or appointments for personal benefit is not permissible. Violators may be subject to loss of reimbursement and disciplinary action. If a guest accompanies an employee on a CBOE business trip, then all additional expenses incurred as a result of the accompanying guest are the responsibility of the employee and are not reimbursable unless it can be shown that the presence of the guest serves a bona fide business purpose. If an employee s Department Head and Division Head approves, an employee may convert his/her international airfare ticket to two lower class tickets if applicable (i.e. one business class ticket converted to two coach tickets). The excess cost of the two lower fares, if any, is the responsibility of the employee and must be reimbursed to CBOE. Additionally, the cost of the non-employee ticket or portion thereof paid by CBOE will be treated as compensation to the employee and included in wages for the purpose of collecting applicable withholding and employment taxes. B. CBOE will reimburse for hotel costs at the single standard room rate. The business traveler will be responsible for reimbursement of additional room charges as a result of double occupancy, if any. Meals will be reimbursed at actual cost for the business traveler or one half of the total bill, if reasonable and the exact employee cost cannot be determined. Additional charges for limousines, taxis, tips, etc. related to the accompanying guest are not reimbursable. The attendance of an employee s guest at certain functions is generally not necessary to conduct CBOE business. Certain occasions, as determined by the President, may arise where the employee s guest is required to attend a function for CBOE business purposes. Under these circumstances, CBOE will pay or reimburse the employee for all guest costs. PERSONAL CHARGES CBOE will generally not reimburse an individual for any costs related to birthdays, Secretaries Day celebrations, gifts, flowers for illness or any other similar event. If a department or group wishes to undertake any of these, a collection should be made from participating employees to Workplace Policies Page 8 of 11 December 2015
cover the related cost. Any exception to this policy must be approval in writing by a Department Head and/or Division Head. In the event of a death in an employee s immediate family, CBOE will reimburse for the purchase of flowers upon Department Head approval. Although not an all-inclusive list, the following expenses are not considered reimbursable: Airline clubs (i.e. Red Carpet, Admirals Club, requires prior approval by Division Head) Doctor bills, prescriptions, or other medical services Excessive personal telephone calls Extra personal baggage charges at airports or assessed by airlines Golf (except when part of customer entertainment) Gum, candy, cigarettes Interest charges related to use of personal credit card Late charges related to use of personal credit card Luggage Magazines, books or newspapers Movies, either in-room or outside Nightclubs (except when part of customer entertainment) Parking tickets or traffic tickets Personal toiletries Pet care or boarding Sightseeing tours Shoe shines Spectator events (except when part of customer entertainment) Tennis and health club facilities (except when part of customer entertainment) Theatre (except when part of customer entertainment) Holiday parties for department, division and/or individual staff members. EXPENSE REPORTS Employees are required to complete the expense report located on CBOE intranet. The expense report should include all necessary supporting documentation (receipts, etc.) and submit to the proper person for approval. The following information for all travel and other business related expenses should be included on the expense report: Workplace Policies Page 9 of 11 December 2015
Cost of transportation, meals, lodging and incidentals Date Dates of departure and return Place or places of travel Business purpose Place of expenditure Name and firm of person(s) entertained Once the expense report has been approved, the approver is to forward the expense report to the Accounting Department. Failure to include proper receipts will delay reimbursement of the expenses. Upon completion of a trip, expense reports are to be completed within ten (10) days for domestic travel and thirty (30) days for international travel. APPROVAL & REVIEW OF EXPENSE REPORTS The person approving expense reports has the responsibility to ensure that the report is properly supported by receipts, the accounts charged are correct, the expense has a valid business purpose, and that the expenses are reasonable and appropriate. Any expenses outside of CBOE s travel policy must be forwarded to the Chief Accounting Officer for review of those expenses. All expense reports require immediate supervisor s approval. Approval required for expense reports are as follows: Report Submitted By Chairman of the Board (COB) Chief Executive Officer (CEO) President Board Member Business Conduct Committee Chair Division Head Department Head Staff Members Approval Required By CFO COB CEO Chief Financial Officer Chief Regulatory Officer President or CEO Division Head Department Head During periods of extended absence, such as vacation, the next senior authorized individual can be designated to approve expense reports containing all necessary supporting documentation. Workplace Policies Page 10 of 11 December 2015
Employees may not approve their own expense reimbursements, and no employee may approve a subordinate s request for reimbursement of costs of meals or entertainment expense in which they participated. (Such costs should be paid for by the highest ranking employee in attendance, and his/her expense report should be approved by the next level above.) An expense report that does not comply with CBOE policy will be subject to the corrective action outlined in the Section 3 of this policy, Policy Enforcement. CBOE CORPORATE CREDIT CARD Employees who travel frequently are encouraged to use a corporate American Express card for all airfares, lodging, car rental, meals along with any goods and services for or incidental to business travel. The use of the corporate credit card will enable CBOE to better manage travel expenses. The corporate American Express card may be obtained by contacting the Accounting Department and requires a Department Head approval. The cardholder is liable for all charges made on the corporate card. The cardholder must submit periodic expense reports to CBOE s Accounting Department with proper documentation for reimbursement. The annual fee for each corporate card will be charged to the Exchange. This is the only credit card membership fee the Exchange will reimburse. PROFESSIONAL ASSOCIATIONS Professional association dues and entrance fees which are necessary for conducting business for the Exchange will be reimbursed upon approval by the Department Head. Workplace Policies Page 11 of 11 December 2015