Company-wide Credit Card Policy

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1 Company-wide Credit Card Policy Department: Corporate Finance Policy Number: CW-FIN Subject: Corporate Credit Cards Effective Date: 11/05/2008 Document Owner: Drew Hurt Title: Corporate Credit Card Plan Administrator Approved by: Corp. Policy Committee Review anniversary: November 2009 Purpose: To set forth guidelines regarding the application, use, and termination of credits cards issued to MED3OOO employees. Overview: It is the policy of MED3OOO to permit use of corporate credit cards by employees designated by appropriate authorities for charging legitimate company expenses. Eligible employees are those who are or will be regularly incurring legitimate business expenses. After reading this policy, all employees who currently have obtained a corporate credit card must sign the addendum to this document and return it to the Corporate Credit Card Plan Administrator (Plan Administrator) listed above. All employees who wish to obtain a corporate credit card must sign the addendum to this document and obtain their manager s signature prior to receiving a credit card application. Effective immediately, the recipients of this document are mandated to abide by the following corporate credit card policy and procedures. Requests for exceptions to this Policy are to be directed to the Plan Administrator with copies to your designated expense processor. Eligible employees, as designated by their direct supervisors, who desire to use corporate credit cards, should contact the Plan Administrator who will handle all arrangements for obtaining and cancelling corporate credit cards. The following review and documentation procedures are to be followed: CREDIT CARD CARDHOLDER AGREEMENT Policy Credit cards are issued by American Express at the discretion of Management to current employees who have been determined to incur legitimate business expenses. The employee (i.e. cardholder) agrees to comply with all applicable MED3OOO policies and procedures and this Credit Card Cardholder Agreement (see attached acknowledgement form). When signed and accepted, this form acts to assign the

2 formal delegation of purchase authority to a current MED3OOO cardholder to execute credit card purchases. It is MED3OOO s policy that all receipts must accompany the employee s expense report. Failure to provide supporting documentation will result in forfeiture of right of reimbursement. Expenses must be submitted within 60 days from the time expense was incurred. Expense reports submitted outside of this time frame will not be reimbursed. Monthly billings for corporate credit cards will be mailed to the address designated by the cardholder. It is the cardholder s responsibility to review statements for accuracy and to pay the balance in full by the designated due date as shown on the monthly statement from American Express. Compliance with Policy, Violations and Consequences Cardholder violations to this agreement, or to any MED3OOO policy regarding the purchase of goods or services, will be investigated by Internal Audit, Chief Compliance & Ethics Officer, Legal, and any other group or individual as designated by the Board of Directors and/or Compliance Committee, and to recommend actions that may be taken: written warning, revocation of credit card privileges, cancellation of delegation of purchasing authority, criminal prosecution, and disciplinary action up to and including termination. MED3OOO will consider the facts and circumstances of each incident, and will take action as deemed appropriate, and as permitted by applicable law and/or MED3OOO policy. Credit Card violations may include but are not limited to: Purchase of items for personal use. Purchase of items in violation of the MED3OOO travel policy. Allowing unauthorized users to use the corporate credit card. Use of the credit card for cash advances. Exceeding card credit line limit. Failure to promptly return the credit card when a cardholder is reassigned, terminated or at the discretion of Management. Note: Any violations to the Corporate Credit Card Policy will result in notification to the cardholder s direct supervisor/manager. Ownership and Cancellation of the Credit Card The credit card remains property of American Express. It may not be transferred to, assigned to, or used by anyone other than the designated cardholder. The cardholder is accountable for the activity on the card. American Express or MED3OOO may suspend or cancel cardholder privileges at any time for any reason. The cardholder will surrender the credit card upon request to MED3OOO or any authorized agent of American Express. Spending Limits Each credit card has a pre-set limit that may not be exceeded unless there is prior written authorization from Management.

3 Receipts It is the cardholder's responsibility to obtain transaction receipts from the merchant each time the credit card is used. Individual transaction receipts are to be attached to the expense report and submitted to designated expense processor. The designated expense processor will be responsible for review and approval of expense reports, along with the cardholder s authorizing manager. Designated expense processor must keep expense reports, including receipts, and proof of review on file for a period consistent with the record retention requirements of the law, which is 7 years for Accounting Documentation. Failure to turn in receipts or other supporting documentation to the designated expense processor within 30 days of a request from an expense processor will result in forfeiture of reimbursement. Disputed Items It is the cardholder's responsibility to follow-up on any erroneous charges, returns or adjustments to ensure proper credit is given on subsequent statements. Protecting the Credit Card The credit card is valuable property which requires proper treatment by the cardholder to protect it from misuse by unauthorized parties. Validation and Safekeeping Sign the credit card immediately upon receipt. The credit card should always be treated with the same care as personal credit cards, bankcards, cash and checks. Keep your card in an accessible, but secure location. When using the credit card for internet purchases, cardholders should make sure that the site utilizes industry recognized encryption transmission tools (e.g. such as VeriSign). When the expiration date is passed and/or after you have received a new credit card, cut the old credit card in half and dispose of it. Make sure the credit card is returned to you after each charge and verify that the returned credit card has your name on it. Lost or Stolen Credit Cards If the credit card is lost, stolen, or in the case of identity theft, contact American Express 24-hour tollfree number immediately then notify your immediate supervisor and the Plan Administrator. RESPONSIBILITIES CARDHOLDERS Cardholders must use the card responsibly and in accordance with this policy. Cardholder responsibilities include: Purchasing items for MED3OOO business use only. Paying the total balance by the payment due date every month. Never lending or sharing the credit card or account number. Purchasing only goods and services that are approved by MED3OOO or are in accordance with MED3OOO policies.

4 Attaching purchasing documents, such as sales receipts, with expense reports. Submitting expense reports within 60 days of date expenses were incurred. Responding to inquiries within 30 days of a request for additional information. All charges on the credit card statement shall be examined by the cardholder to ensure that they represent actual and authorized expenditures. Canceling the credit card upon notification of resignation from MED3OOO or the position which entitled use of the card, or upon request of designated expense processor or management. Returning the credit card to designated expense processor upon leaving MED3OOO or the position which entitled use of the card, or upon request of designated expense processor. Reading this policy and signing the addendum as verification of understanding to comply with MED3OOO policies. Note: All corporate credit cards are issued in the cardholder s name and social security number. Failure to pay balances timely will result in a negative impact to the card holder s credit score and the balance going to a collection agency. On a monthly basis, Plan Administrator obtains reports from American Express detailing outstanding balances and past-due cardholders. This report will be used for monitoring purposes. DESIGNATED EXPENSE PROCESSOR Designated expense processor is responsible for: Timely reconciliation. Appropriate record keeping. Sharing new program information with cardholders. Answering cardholder questions about use of cards. Monitoring card usage to ensure that internal policies and procedures are being followed. Notifying Internal Audit, Compliance, Legal and Human Resources of any possible violation of company policies. Providing this policy to new cardholders prior to providing them a credit card application, and obtaining the signed policy. Notify the Plan Administrator of violations to the Corporate Credit Card Policy. Designated expense processor will reimburse cardholders for authorized business expenses within business days of submission of expense report. The timing of payment will be dependent on the following: Timing of payroll processing. Submission of receipts and supporting documentation. Manager approval on expense report. Inquiry needed by expense processor.

5 PLAN ADMINISTRATOR Plan Administrator responsibilities include: Implementing and updating internal procedures that govern use of the credit cards. Communicating and updating the procedures for obtaining, using, and canceling corporate credit cards for designated cardholders. Ensuring that these procedures are in place for all cards before cardholders are given card privileges. Assigning credit card privileges to cardholders. Providing new cardholders with program information Obtaining signed acknowledgement from cardholders who currently have corporate credit cards, documenting their understanding of company policy. Ensuring accounts have been terminated for cardholders who have left MED3OOO or the position which entitled the cardholders to a corporate credit card. Reviewing monthly reports from American Express to look for past-due cardholders. Notifying supervisors/managers, Human Resources, Legal and Compliance Officer of any violations to the Corporate Credit Card Policy. RESPONSIBILITIES OF OTHER PERSONNEL Supervisors/Managers are responsible for examining all charges on the cardholder expense report to ensure the expenditures represent proper and legitimate business expenditures. Human Resources are responsible for notifying the Plan Administrator of cardholder resignations from MED3OOO or termination of the positions which entitled the cardholders to a corporate credit card. Internal Audit is responsible for reviewing the use of corporate credit cards, supporting documentation and tax treatment of expenditures as requested by management or as deemed necessary. Any questions on procedures for corporate credit cards may be directed to the Plan Administrator. Approval Signature: Policy Review Committee Approval Date: 11/05/08 Policy Number: CW-FIN

6 CORPORATE CREDIT POLICY ACKNOWLEDGEMENT I have read and understood the attached Company-wide Credit Card Policy (the Policy) and agree to abide by the responsibilities as set forth in this document. I understand that any violations to this policy will result in remediation actions as listed in the Policy, up to and including termination of employment. EMPLOYEE/CARDHOLDER NAME: DATE:

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