Travel and Entertainment Expense Manual



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Zimmer Biomet Global Travel and Entertainment Policy

Updated: 5/1/2015

1 Responsibilities 3

1.1 Team Member’s Responsibility 3

1.2 Expense Approval Responsibility 4

2 Booking Travel 5

2.1 Booking Travel 5

2.2 Corporate Credit Card 5

3 Air Transportation 6

3.1 General 6

3.2 Airfare Booking and Reservations 7

3.3 Baggage Fees 7

3.4 Upgrades & Frequent Traveler Programs 8

3.5 Lost/Stolen Luggage 8

4 Lodging 8

4.1 General 8

5 Ground Transportation 9

5.1 General 9

5.2 Rental Car Reservations 9

5.3 Rental Car Class of Service 9

5.4 Rental Car Insurance 10

5.5 Taxis, Limousines, Shuttles, Public Transportation 10

5.6 Company Car Allowance, Company Owned / Leased Vehicles 10

5.7 Rail 10

5.8 Mileage Reimbursement 10

6 Meals and Entertainment 11

6.1 Meal Guidelines 11

6.2 Meal Limits 12

6.3 Team Member Recognition/Team Building Events 14

6.4 Non-Meal Entertainment 14

6.5 Recruiting Events 14

6.6 Alcohol 14

7 Communication Expenses 15

8 Other Reimbursable Travel Expenses 15

9 Currency Conversion 16

10 Non- Reimbursable Expenses. 16

11 Required Receipts for Reimbursement 18

12 APPROVAL 18

Responsibilities

1 Team Member’s Responsibility

As a Zimmer Biomet (Company) traveler, you are solely responsible for the completeness and accuracy of your expense report. Completeness and accuracy contribute greatly to the expeditious processing of your report. Submission of an expense report certifies that the information on the report is true, complete, accurate and in compliance with valid T&E and Compliance policies.

All expense reports must contain a detailed business purpose.

• Acceptable explanations for business purpose include “demonstration of Oxford product features” and “department recognition lunch”

• Unacceptable examples include “Oxford”, “training” and “business lunch”

• If multiple business purposes apply to an expense report, then each expense must have its own business purpose

Various regulatory agencies, good business practices and Compliance Policies require that you adhere to the practices and procedures outlined in this Policy. Failure to do so could result in corrective action up to and including termination of your employment with the Company. Ultimately, travelers are responsible for exercising sound individual judgment and seeking input from their managers in deciding if an action or expenditure is appropriate. The Company expects each team member to be cost conscious and consider the following as ways to decrease spend:

• Challenge whether too many team members from one department are traveling

• Consider web casts and video conferencing in lieu of travel

• Book travel two (2) weeks in advance

• If a trip must be cancelled, do it as soon as you are aware

• Travel for longer periods of time – rather than traveling to China or an SBU four (4) times a year, travel two (2) times a year, but stay longer.

• Select Company preferred vendors when traveling

This policy applies to all US based (NAM), EMEA based (EMEA) and Asia-Pacific based (AP) team members, independent contractors, and consultants who travel and entertain on behalf of the Company. The content and requirements of regional policies must be closely aligned. Team members must also adhere to the Code of Business Conduct and the applicable Compliance Policies when conducting business with third parties including Healthcare Professionals (HCPs).

Compliance Policies are defined as Company policies and procedures issued by the Compliance Department. For purposes of this Policy, Compliance Policies focus on requirements related to anti-corruption laws and interactions with third parties, particularly with respect to high-risk vendors, health care professionals and government officials as those terms are defined in specific Compliance Policies. Compliance Policies are available on the Zimmer Biomet Intranet. In addition, for purposes of this Policy, references to Compliance Policies include any associated industry codes such as AdvaMed, EUCOMED, JFMDA, and KMDIA

All expense reimbursements should be submitted to the Finance department via the identified expense reporting tool for that country. Where online expense reporting tools are used, all expenses must be submitted using the tool the only exception being for one time travelers that are not expected to travel again within one year.

Team members must submit expense reports including all HCP activity, within 30 days after expenses are incurred. The reporting requirements under the laws of Massachusetts, Vermont, and the federal Sunshine Act, have made the timely submission of HealthCare Professional related expenses critically important. Delays in the reporting of HCP expenses may result in significant rework in this reporting process and may prevent Zimmer Biomet from meeting its responsibilities under the law. Due to the cost of the online expense reporting tool, expenses should be combined onto one report whenever possible and reports should not be submitted at a frequency of more than one per week.

Lack of timely submission of expenses can result in the loss of company credit card privileges. Once lost, privileges will not be restored for a minimum of three (3) months. As expenses incurred on behalf of Company are required to be paid for on the Company credit card, loss of Company credit card privileges may result in loss of ability to incur travel and purchasing expenses on behalf of the company. Moreover, at Company Human Resources discretion, serious or repeated violators of this policy may be subject to more severe discipline.

Periodic audits will be performed to ensure travelers are in compliance with all policies and procedures.

If it is determined that team members have been reimbursed for items outside of the policy or have incurred personal charges on the company credit card they must repay the company within 30 days after the expense was paid or incurred. Where permitted, overpayments will be deducted from the team member’s next payroll. Where not permitted, team members must refund the Company by check or wire transfer. Lack of timely repayment will result in escalation to upper management.

Travelers are responsible for safeguarding Company property and information while traveling.

The Company may at its discretion limit the number of team members traveling together to minimize losses associated with unforeseen events.

SCOPE: “NAM” is defined as a U.S. based team members. APAC is defined as an Asia-Pacific based team members. “EMEA” is defined as Europe, Middle East, and Africa based team members.

EMEA and APAC are included in the scope of this Global Zimmer Biomet Travel & Entertainment Policy. The content and requirements of any regional and local policies must be closely aligned to this Global Policy. Any division or site may opt to have a more restrictive policy than this Global Policy but must communicate this to the owner of this Policy as defined on the signature page. A less restrictive policy is not permitted. Deviations as a result of local laws, customs and procedures must be documented and provided to the owner of this Policy.

2 Expense Approval Responsibility

All expenses require the approval of the supervisor who is, at a minimum, the next level above the team member who is traveling. One-over approvers must comply with the policy when reviewing expense reports and deny and/or communicate back to the requester to correct non-compliance, errors or deficiencies before approving. Approvals must occur within 10 business days of being submitted.

Team members approving expense reports are responsible for ensuring that items submitted for reimbursement are properly documented and are in accordance with all company policies. Before approving an expense report, managers should thoroughly review the expense report and ensure that:

• All expenses are legitimate business expenses

• The expenses are reasonable and are in compliance with Compliance Policies, this Global Travel and Entertainment Policy and all regional and local T&E Policies

• Detailed business purpose(s) are provided

• All expenses are properly classified, attendees are listed and categorized per Company Policy, with no duplicate attendees

• Required receipts are attached and the amounts on the receipt match the amounts expensed

• For meal expenses, the number of meals/attendees listed on the receipt matches the number of attendees in the expense report

• For team members using an online expense submission tool, all warnings are reviewed and addressed.

• All expenses are within the Company limits set in this Policy

Exceptions to this Policy should be rare and must include a detailed explanation from the team member explaining why they are not compliant, so the approving manager and the Finance department can determine whether the expense is appropriate and reimbursable. Finance reserves the right not to reimburse expenses that are exceptions to this Policy.

Booking Travel

1 Booking Travel

The Company mandates that all team members, independent contractors and consultants use the Zimmer Biomet Travel Agency when traveling on behalf of the Company for the following reasons:.

• The Travel Agency executes the Company negotiated rates with hotel, airfare, and rental car suppliers.

• The Travel Agency is the Company’s resource should the Company need to locate a team member in cases of emergency. The Travel Agency also keeps the team member apprised of any changes or cancellations of travel reservations by the airline.

The team member is responsible for ensuring their travel profile information is accurate including; credit card numbers, full name as it appears on government issued ID, address, emergency contacts, phone numbers, frequent flyer or frequent car rental membership numbers, and seating preference. Airline, hotel and rental car reservations not made through the Travel Agency may cause the Company to lose discounts. To reduce costs the online booking tool must be used whenever possible and the calls directly to the Travel Agency should be made during normal business hours. Calls on nights and weekends are available, but are more expensive, and should be avoided whenever possible.

Arrangements should be made no later than 14 days before travel or as soon as possible after team member learns of need to travel to take advantage of the lowest available fares.

2 Corporate Credit Card

Where available, it is expected that all frequent travelers will be issued a Corporate Credit Card. The Corporate Credit Card must be the primary form of payment used for travel and entertainment expenses. Each card is the responsibility of the team member.

• For individual liability cards the cardholder is responsible for prompt payments to the credit card company and late fees will not be reimbursed.

The Corporate Credit Card is not to be used for personal purchases. Personal use will be monitored and reported to OpCom. Repeated violations will result in disciplinary action that can include the loss of company credit card privileges. As expenses incurred on behalf of the Company are required to be paid for on the Company credit card, loss of Company credit card privileges may result in loss of ability to incur travel and purchasing expenses on behalf of the company. Moreover, at Human Resources discretion, serious or repeated violators of this Policy may be subject to more severe discipline, up to and including termination of employment.

Cash Advances and Gift Card Purchases using a Corporate Credit Card are prohibited

Other than for team member travel and entertainment expenses, the corporate credit card is not to be utilized for payments made directly to high risk parties (HRPs), Required Meeting Facilitators (RMFs), Health Care Professionals (HCPs), or Customs Brokers.  Separate processes, required forms, approvals and/or checklists have been established for payments to these types of entities.

Air Transportation

1 General

Travelers should make every effort to schedule trips in advance to minimize ticket prices and to avoid unnecessary charges. Changes or cancellations should be made directly through the Zimmer Biomet Travel Agency. In the event of cancelation, these tickets often can be reused for similar travel or applied as a credit against future tickets.

Air transportation is restricted to regularly scheduled and certified airlines. The following are not acceptable when traveling on Company business and will not be reimbursed:

• Unscheduled and non-certified airlines

• Chartered aircraft

• Private aircraft

A team member may elect to extend their stay for personal reasons if the extended stay results in the same or a reduction of airfare costs. However, the cost of hotel, meals, rental car, change ticket fees, etc. due to an extended stay for personal reasons are the responsibility of the team member and are not reimbursable. Supporting documentation is required to be submitted with the expense report to substantiate the same or lower airfare. If extension of the stay results in a higher airfare, the team member must have pre-approval and must reimburse the company within 15 days of date of charge to the Company.

Company owned aircraft - Refer to form F02041F

Airfare is not authorized for business trips that could have been driven in four hours or less (one-way). If the round-trip flight is less than the cost of traveling round-trip by car/rail, the team member may choose air as the means of travel. Calculation of the mileage vs the cost of airfare must be included in the expense report as verification of the cost savings.

2 Airfare Booking and Reservations

• Team members traveling on a flight that is 14 hours or greater (if multiple legs, one flight must equal 14 hours or greater) are approved to book business class fares. Flight time is measured by scheduled time in the air. Ground connection time is excluded. Any exception to this policy requires approval from the Corporate Controller.

• Team Members traveling on a flight that is greater than 7 hours are allowed to book preferred coach seating (i.e. Economy Comfort/Economy Plus) if the additional cost is less than $400.  Flight time is measured by scheduled time in the air.  Ground connection time is excluded.

• Exception to class of travel is not permitted for team members even if traveling with an HCP.

• Required company approvals when booking flights:

o APAC – approval required by traveler’s local country leader for all national/regional and international flights and by an OpCom member or their direct line Vice President delegate for all intercontinental flights.

o EMEA – approval required by traveler’s direct line manager for all national/regional and international flights and by an OpCom member or their direct line Vice President delegate for all intercontinental flights.

o NAM – approval required by a member of OpCom or their direct line Vice President delegate for all international flights. International travel cannot be booked online.

▪ All International travel must be booked through an agent at the Zimmer Biomet Travel Agency. Agents do not have the authority to issue the ticket until all Company approvals have been provided. (Fares and reservations are not guaranteed until time of ticketing therefore it is imperative that approvals are provided immediately).

• There may be instances where business class fares are less expensive than economy, in those instances the Travel Agency will ensure the lowest logical fare is booked.

• Reimbursement of first class service is prohibited.

Team members should contact the Travel Agency in advance to understand the passport/visa requirements when traveling internationally. Some countries require confirmed airline arrangements prior to issuing a visa. The Travel Agency is available to assist team members in obtaining documentation.

Team members are required to accept the itinerary representing the lowest available airfare with the Company’s preferred airlines. Connections should be selected unless they add more than two hours to the duration of the trip. Acceptable maximum exception to the lowest available airfare is $200 domestically or $300 internationally. Zimmer Biomet is notified when a flight is booked that exceeds the allowable exception rate and reserves the right to require the flight to be changed or to only reimburse the lower rate.

3 Baggage Fees

Normal baggage fees are reimbursable. Excess baggage fees will only be reimbursed with prior management approval.

4 Upgrades & Frequent Traveler Programs

Team members may retain frequent flyer program benefits. However, a team member must not modify flights or other arrangements for the purpose of accumulating additional points if such action would result in a higher cost to the Company.

It is recommended that frequent flyer miles that are earned on Company business be used to reduce the flight cost to Zimmer Biomet. If frequent traveler program points are used to purchase tickets for business-related travel, the Company will reimburse the associated ticketing fee. However, all fees associated with upgrading to a higher class of service will not be reimbursed; if personal funds or miles are used to upgrade the class of service, documentation should be provided with the expense report to differentiate the Company’s responsibility from the team member responsibility.

Airlines occasionally offer free tickets or cash value to compensate travelers for delays and inconvenience. Travelers may volunteer to give up their seats if the delay does not result in an interruption to company business or addition cost to Zimmer Biomet.

5 Lost/Stolen Luggage

Team members will not be reimbursed for lost luggage. In the event of lost luggage, travelers should file a claim with the airline/insurance company. Any replacement items purchased are considered to be part of the claim with the airline and are not reimbursable by the Company.

Lodging

4.1 General

All hotel travel must be booked through the Zimmer Biomet Travel Agency or their online booking tool where available. Where not available, team members should ensure they are choosing the most economical lodging utilizing company negotiated rates when available. All team members are expected to select the preferred hotels identified on the Zimmer Biomet Travel Agency site or corporate hotels negotiated by the region and identified in the local policy. Upgraded suites or nonstandard executive/concierge level rooms are not reimbursable unless pre-authorized by a vice president or higher level management team member. Travelers should verify that room rates and duration of stay match the travel itinerary upon checking in to the hotel.

Traveler may retain hotel reward program benefits for business travel. Participation in these programs must not influence hotel selection or result in incremental cost to the Company.

When traveling to the Corporate Headquarters in Warsaw, rooms shall be booked by calling the Travel Agency. Only commercial hotel lodging expenses are reimbursable. The Company will not provide compensation for staying with a friend or relative, or for staying in your own residence

Internet and work out facilities (on hotel premises) will be reimbursed. Spa use and treatments are not reimbursable.

If the sponsor of a seminar or conference requires attendees to utilize their reserved hotel rooms in order to attend the event, the team member can book through the seminar or conference service.

If it is necessary to cancel reservations, the travel must adhere to hotel deadlines. To avoid no-show charges, cancel via the online booking tool and record the cancelation number provided. If the traveler is unable to access the reservation online, they may call the Travel Agency or hotel directly to cancel. Expenses incurred due to a “no show” will not be reimbursed. Early check-in fees or late check-out fees are allowed when necessary to accommodate flight schedules.

Ground Transportation

1 General

Team members must use the most cost effective and customary form of ground transportation. When deciding whether to use a personal automobile or a rental car a rental car should be used if the mileage will be greater than 300 miles (or 500 kilometers) round trip. Rental car reservations must be made through the Travel Agency when available.

Team members approved for a toll pass (EZpass, toll sticker, etc.) will be reimbursed for the actual toll charges on their statement.

Team members should not place toll pass replenishment amounts on their company card.

2 Rental Car Reservations

Rental cars are authorized when airport shuttles, hotel transportation or other modes of public transportation are unavailable or when they are the more cost effective mode of travel.

Rental car reservations are to be made through the Zimmer Biomet Travel Agency or on-line booking system to ensure that negotiated rates and full insurance coverage are applied. The traveler is responsible to ensure that rental car reservations are cancelled through the travel agency to avoid penalties. Fees resulting from not booking though the travel agency or for failing to properly cancel reservations may not be reimbursed.

Justification must be provided in the expense report if a non-preferred supplier is used. If the preferred supplier is not available, the traveler should ask for a corporate rate and accept LDW (loss damage waiver) insurance coverage.

The team member:

• Is responsible for the costs of operating the vehicle and will be reimbursed for daily rental charges, gasoline charges, toll charges and parking charges.

• Must not accept the “fuel tank purchase” option when entering into a rental agreement. The “fuel tank purchase” option will not be reimbursable.

• Is responsible for refilling the gas tank prior to returning the vehicle. Refueling charges from the car rental companies will not be reimbursed.

• Should allow enough time to ensure that they can return the vehicle to the originating city.

If required, one-way requirements should be clearly specified when booking through the agency.

3 Rental Car Class of Service

Travelers should reserve mid-size cars or smaller. If a mid-size car will not accommodate the size of the group traveling, a full-size car class is acceptable. If two or more team members are traveling together, they should share a rental car. Sport Utility Vehicles (SUVs) should only be rented if 4 or more team members are traveling in one vehicle or you are transporting heavy or large equipment.

4 Rental Car Insurance

Insurance for rented vehicles in the US is automatically included when choosing the preferred corporate supplier. Travelers should always decline additional insurance coverage with rental in the US. When traveling internationally, NAM, EMEA, APAC travelers should work with the travel agency to ensure proper coverage for the local laws.

In the event of an accident while traveling in a rented vehicle, the traveler should contact the rental car agency directly as soon as safely possible while at the accident site. Contact information should be on the rental agreement or inside the glove compartment of the vehicle.

5 Taxis, Limousines, Shuttles, Public Transportation

Taxis, shuttle service, and public transportation are the preferred mode of transportation.

Use of limo or car services are discouraged and should only be used when they are the most economical mode of transportation available.

As a reminder, team members should pay transportation expenses with their company credit card whenever possible.

6 Company Car Allowance, Company Owned / Leased Vehicles

NAM team members with a Company car allowance, and are not covered under another plan like Runzheimer, will be reimbursed for Company mileage at half the government rate. Fuel costs, vehicle maintenance, and vehicle repairs are not reimbursable. Team members authorized to drive Company-owned and maintained vehicles will be reimbursed for fuel costs, tolls, and parking only.

EMEA team members are entitled to reimbursement as defined in the EMEA Car Policy agreement for the use of company cars.

7 Rail

Rail transportation is acceptable if it is the most effective and economical mode of transportation.

Standard class travel is required for all levels below manager. Metro club for U.S. and 1st class for international team members at manager level or above are acceptable. Team members below the manager level can travel in the same class when traveling with managers and above.

Sleeping accommodations, when necessary, are limited to a roomette or equivalent.

If the team member regularly travels by train, EMEA allows the purchase of an annual discount card to reduce the train fare.

8 Mileage Reimbursement

The Company reimburses team members and independent contractors and consultants traveling on Company business for mileage incurred when using a personal vehicle. Team members may use their personal automobile for business travel when it is less expensive than other modes of transportation and can save the traveler time.

The Company is not responsible for traveler’s personal vehicle operating costs and any losses resulting from collision, fire, or theft during Company related travel. Travelers must ensure the vehicle has proper insurance in accordance with local laws in the area of travel. Non-insured or under-insured vehicles must never be used for Company travel.

The traveler will be reimbursed for the business use of their vehicle based on the current governmental rate or local applicable/approved reimbursement rates. This mileage rate covers normal wear and tear of the vehicle and gasoline. Travelers must document the origin city, destination city, and business purpose.

Miles driven as part of a team member’s normal commute are not reimbursable. Reimbursement for personal vehicle use is limited to the difference between actual miles driven and the team member’s normal daily commute.

Mileage between Company buildings within the same city is not reimbursable – unless local law or regulations require reimbursement.

Meals and Entertainment

1 Meal Guidelines

The Company will reimburse team members for actual meal expenses that are reasonable and customary while on Company business, including the following:

• Team member is on overnight travel status

• Team member is engaged in a business related meal with a third party

• Team member is at an off-site training event

• Team member is on a single-day business trip away from their normal place of business lunch is allowed; dinner is allowed only when returned home after 7 pm.

Note: it should be rare that team member only meals are expensed unless you meet 1 of the 4 criteria above. Whenever possible, team member meetings over lunch should be avoided. Company provided team member lunches should be limited to instances of all day meetings and should not be provided as a standard course of business. A valid business reason must be provided.

When attending events where food expense is already included in the cost to attend, additional meals taken outside the venues will not be reimbursed.

Documentation for reimbursable business meals must include the following information:

• Names of all attendees (number of attendees must match the number of meals purchased)

• Company and title of non-team member guests (Distributor personnel, contract team members, and temporary team members are NOT Zimmer Biomet team members)

• Date of meal

• Restaurant name

• Amount

• Business purpose

Itemized receipts must accompany all meals. In countries where receipts are typically not provided the team member must make an effort to obtain the itemized receipt. If required receipts are lost or an itemized receipt is not obtained, an explanation must be documented on the expense report. The Company reserves the right to request the submitter to contact the vendor to obtain a copy of the itemized receipt prior to reimbursement.

2 Meal Limits

The table below represents the meal expense limit that should be followed when traveling. The limit includes taxes and gratuity.

• The limit shown for the country represents the amount that should not be exceeded when a meal is incurred within that country. For countries not listed in the table below, the US meal limit applies.

• These limits cover any meal where an HCP is not present (external business partners who are not HCP’s).

• Meals limits for HCP meal attendees are published in the Company Compliance Policies. If HealthCare Professionals (HCPs) are present, team members must also comply with the respective Compliance Policy for meals, entertainment, and gifts with/for HealthCare Professionals. (SOP 73.000 and ZP 72.000)

• It is a violation of this policy, to split the meal bill between attendees and submit separately for reimbursement. This includes splitting alcohol expenses and meal expenses for separate submission in an attempt to circumvent the meal limits or for any other reason. Failure to comply may result in disciplinary action and the traveler may not be reimbursed.

• Any amounts spent above the limits indicated will be considered personal and will not be reimbursed.

For countries that do not have meal allowances, the company will reimburse team members for actual meal expenses that are reasonable and customary while on Company business.

In cases where more than one Company team member attends a meal or entertainment activity, the most senior team member must pay the bill and submit the expense for reimbursement. In the event that the most senior team member did not pay, additional approval for the expense must be obtained by a level above the most senior team member in attendance.

If hosting another locations team member(s) the most senior-level team member of the hosting location should pay the bill. For large off site meetings it is acceptable for the coordinator of the meeting to pay the bill in lieu of the most senior-level team member.

Reasonable between meal snacks are allowed i.e. coffee, water, candy bar, muffin etc. Use of mini bar for snacks should be avoided whenever possible. Alcohol is not considered a snack.

| |LOCAL CURRENCY |

|Country |Currency |Breakfast |Lunch |Dinner |

|Australia |AUD (Dollars) |45 |50 |110 |

|Canada |USD (Dollars) | 35 | 40 | 75 |

|China |CNY (RMB Yuan) |220 |250 |470 |

|Costa Rica |CRC (Colon) |10,000 |24,000 |36,000 |

|El Salvador |USD (Dollars) | 35 | 40 | 75 |

| Czech Republic |CZK (Koruna) | 650 | 900 | 1,500 |

| Greece |EUR (Euro) | 25 | 30 | 56 |

|Norway |NKK (Krone) | 200 | 245 | 460 |

| Russia |RUN (Ruble) | 875 | 1,000 | 2,000 |

|South Africa |SA Rand |360 |465 |865 |

|Switzerland |CHF (Franc) | 32 | 36 | 68 |

| United Arab Emirates |AED (Dirham) |120 |147 |275 |

|Hong Kong |HKD (Dollar) |270 |310 |600 |

|Indonesia |IDR (Rupiah) |175,000 |350,000 |850,000 |

|Korea |KRW (Won) |38,000 |45,000 |98,000 |

|Mexico |MXN (Pesos) |300 |650 |900 |

|Paraguay |PYG (Guarani) |89,180 |178,360 |267,540 |

|Philippines |PHP (Peso) |550 |950 |2700 |

|Singapore |SGD (Dollars) |45 |55 |120 |

|Thailand |THB (Baht) |1100 |1,300 |2,500 |

|Venezuela |VEB (Bolivar) |130 |260 |400 |

4 Team Member Recognition/Team Building Events

Team Member Recognition

Management may incur expenses associated with a business related team member recognition event such as milestone anniversaries, job promotion or retirement (examples of non-allowable events include birthday’s, wedding/baby showers, etc.) In all instances, activities must be appropriate to the event and prudent judgment must be used.

Team Building Events

If previously budgeted, management may incur expenses associated with a team building event.

Meals included in a team building event must comply with the meal expense limits. The meal expense limit must be consistent with the time of day of the meal (e.g. if the meal is at 12:30 pm the lunch meal limits would be used).

Expenses for anything other than food/beverages are considered expenses associated with the team building event (non-meal entertainment).

Non-meal expenses for the team building event cannot exceed $100 per person (inclusive of all expenses associated with the team building event except meal expenses).

A minimum Z10 level must be present at the team building event. The most senior-level team member present at the event must pay and provide documentation for the entire bill, unless a location is hosting another locations team member(s) and in this case the most senior-level team member of the hosting location can pay the bill.

This section does not apply to recognition of team members under programs approved by Human Resources.

5 Non-Meal Entertainment

Non-meal entertainment with Company business partners (HCP, suppliers, customers etc.) is not authorized. Team members considering non-meal entertainment activities with HCP’s must seek guidance from Corporate Compliance prior to the planning and execution of any events.

Team members must comply with the respective HCP Compliance Policies for meals, entertainment, and gifts with/for HealthCare Professionals. (SOP 73.000 and SP 72.000)

6 Recruiting Events

Recruiting events that include buffet style meals such as pizza, subs, etc., must include a guest list (if known) or approximate headcount. If the HR recruiting event is an invitation-only event, the attendees must be listed.

7 Alcohol

Team members must exercise good judgment in situations where alcoholic beverages are purchased. It is expected that there are times when it is appropriate to have a business discussion over drinks (e.g., a legitimate business discussion while waiting at an airport for a flight, pre-dinner drinks while waiting for a table, a late evening discussion in the hotel at an educational conference). The venue must be conducive to conducting a business discussion.

Expense report submissions requesting reimbursement for what the Company deems to be excessive alcohol purchases will be forwarded to the requestor’s direct supervisor and possibly higher for additional review prior to reimbursement. The Company reserves the right to limit reimbursement for alcoholic beverage expenses before meals, included with meals and after meals, even if the expense has been approved by the one-over manager.

Alcohol purchases through Hotel Mini-Bars will not be reimbursed.

Expense classifications for drinks before or after a meal are considered part of that meal’s expense and are included in the meal limit. Documentation requirements are consistent with Section 6.2. The names, titles, and companies for all attendees must be included.

Communication Expenses

Cell phone purchases are not to be expensed. Cell phone equipment (i.e. chargers, carriers etc.) is to be issued by the assigned department responsible at each Company division.

Home internet service may be reimbursable, in very limited cases, if pre-approved (in writing) with one-over-one approval (minimum of director level as the second approver). Original invoices must be submitted.

Hotel telephone usage will be reimbursed for business and reasonable personal telephone calls. Travelers should make every effort to minimize these costs by using a cell phone to avoid high surcharges levied by hotels.

Wi-Fi expenses on Airplanes or in Airports in order to conduct business are reimbursable.

Other Reimbursable Travel Expenses

Passport or Visa expenses required for business travel are reimbursable. Team members requiring passports or visas may use a passport/visa service to obtain the needed documents.

Currency conversion fees related to business expenses are reimbursable and must be properly supported with receipts.

Immunizations, vaccinations or other credentialing fees are reimbursable if required for business related travel or for access approval to operating rooms. Required immunizations must be administered by a licensed health care facility.

Business supplies and services including fax or copy fees, postage etc. that are essential during business travel are reimbursable. All other ordinary business supplies should be purchased through the purchasing card (P-Card) program or other purchase methods (e.g. purchase orders, invoice).

Tips and gratuities should be consistent with general market conditions for the location where the expenditure has been incurred. As a general guideline, tips should not exceed 15% - 20% in the US and 10% in Europe and other parts of the world. Excessive tipping will not be reimbursed; it is the traveler’s responsibility to verify tips that are automatically added to the bill. Tips and gratuities are included in the meal limits above.

Travel and entertainment expenses for a team member’s spouse/companion/other family member are not reimbursable and should not be charged to the company credit card unless pre-approved in writing by an OpCom member. If approved, the reimbursement of travel expenses will be reported as taxable income to the team member. If the team member is an OpCom member, the pre-approval must be in writing by another OpCom member. Meal and entertainment expenses for spouses attending events with team member candidates are reimbursable and will not be reported as taxable income to the team member.

Child-care, house sitting or pet-care costs may be reimbursed in rare circumstances, such as emergency trips, special project assignments, or long-term travel. These expenses must be pre-approved in writing by the immediate supervisor and a vice president (or president in the case of a vice president traveler).

Laundry/dry cleaning services may be reimbursed if traveling on business for five or more consecutive nights or under extreme circumstances. The costs must be reasonable and necessary. Laundry or dry cleaning costs are not reimbursable at the end of a business trip or upon return from a business trip.

Currency Conversion

To minimize currency conversion charges, team members should use a credit card whenever possible.

Expenses incurred in foreign currency when using the company credit card will appear on the credit card statement already converted to your local currency. No other conversion method is required.

Expenses paid for in cash (foreign currency) will automatically be converted by Concur (where available). If the Concur conversion rate differs from the amount on your initial conversion receipt, you may use the rate on your receipt, however, the receipt must be provided as support. If a system is not available the team member should convert the amounts to local currency using that day’s rate which can be obtained at .

Cash exchange fees assessed for converting cash to foreign currency or back from foreign currency are reimbursable. The receipt from the exchange agent must be submitted with the expense report

If the Team Members does not exchange their foreign currency, the Company will not reimburse the non-exchanged foreign currency.

Non- Reimbursable Expenses THESE EXPENSES ARE NOT ELIGIBLE FOR EXCEPTION TO POLICY

• Replacement costs for personal items not required for business purposes (e.g. cameras and jewelry) that are lost or stolen during business travel

• Purchase of clothing (excluding clothing allowances provided by HR policies), luggage, briefcases, toiletries or other travel gear (even in cases of lost luggage)

• Club dues and non-professional membership fees (including country clubs, health clubs, golf clubs, vacation clubs and fitness centers)

• Travel clubs (airline, hotel)

• Non-business related books, magazines, newspapers, or other periodicals purchased while traveling

• Charge card fees such as late fees or interest costs due to team members late submission or other issue that was responsibility of the team members that resulted in a late fee or interest cost

• Award/reward program fees

• In-room movies

• Personal travel insurance, domestic medical travel insurance or non-required rental car insurance

• Fines or violations (e.g. parking fines, speeding tickets, smoking in a non-smoking room or vehicle)

• Travel upgrades for airfare, car rental, or hotel accommodations that are outside of policy

• Compensation for the use of personal frequent flyer miles for business travel or use of supplier coupons (e.g. money saved by booking a free airline ticket using frequent flyer miles or by using a coupon on a travel related purchase such as hotel or car rental)

• Tips to fitness center staff, shoeshine services, and any other non-business or non-direct activities

• Fuel tank purchase option when entering into a rental agreement.

• Hotel cleaning charges for smoking in hotel rooms

• Car washes or GPS devices for personal vehicles

• Barber, hair stylist, manicurist, masseur, or any other spa experience

• Personal contributions or donations of any kind

• Personal entertainment or recreational expenses (e.g. golf, tennis, in-room and in-flight movies, skiing, snowmobiling)

• Gift card purchases

• Cell phone usage costs (unless specifically approved by Human Resources or identified above)

• Home internet (unless specifically approved by director level or included in an HR policy)

The items listed above are examples of expenses that are not reimbursable; however, they do not constitute a complete list.

Required Receipts for Reimbursement

All required supporting receipts must be submitted with the expense report.

In countries that do not use Concur or where originals are required for tax purposes, the original receipt must be attached to the expense report and submitted to the local accounting office.

In other countries, team members are required to attach copies to the online tool and keep their original receipts for a period of one year from date of submission. Receipt requirements are as follows:

• All meals, HCP expenses and hotels require a detailed itemized receipt

• OUS team members: receipts are required for all expenses unless nominal (examples: tips, parking, vending machine)

• US team members on Concur: certain receipts are not required when using Concur and the corporate credit card. The Concur system will indicate what receipts need to be attached.

• US team members not on Concur: A receipt is required for each expense $25 or greater.

APPROVAL

Travel and Entertainment Policy Owner:

C. Walker, Associate Director, Finance Date

Approved by:

T. Collins Vice President, Corporate Controller and CAO Date

D. Florin, Senior Vice President, CFO Date

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