CORPORATE CREDIT CARD POLICY

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1 TITLE: POLICY OWNERS: DATE INSTITUTED: May 1, 2008 CURRENT VERSION: Ver. 1.6 REVISION DATE: July 1, 2015 Crprate Credit Card Plicy Melissa Cluse, Vice President & Cntrller Cindy Klein, Accunts Payable Manager CORPORATE CREDIT CARD POLICY This dcument prvides plicy and establishes prcedures fr all emplyees f Waddell & Reed Financial, Inc. and its subsidiaries ( the Cmpany ), with the exclusin f the Legend Grup whse emplyees are issued a Cmpany-spnsred Crprate Credit Card ( Crprate Card ). This Crprate Credit Card plicy ( Crprate Card Plicy ) sets frth the Cmpany guidelines that will be applied t emplyees issued a Crprate Card. Its aim is t establish and cmmunicate Cmpany expectatins and effective prcedures fr the issuance, use, safeguarding, and payment f the Crprate Card. General Infrmatin The Cmpany maintains a crprate credit card prgram fr full-time emplyees wh incur travel and business expenses. The Cmpany-spnsred Crprate Card prgram is managed thrugh American Express. The use f a Cmpany-spnsred Crprate Card fr all travel expenses prvides the Cmpany with anther means f measuring travel spending t btain and maintain favrable airline, htel, and autmbile rental rates. Therefre, the use f the crprate American Express card is a valuable prgram which enables the Cmpany t manage its csts related t travel and entertainment expenses. Emplyee Respnsibilities The emplyee is respnsible fr cmplying with the Crprate Card Plicy, and is expected t use discretin and gd judgment in all matters where Cmpany funds are expended. Management Respnsibilities Individuals wh apprve travel and/r entertainment expenses have the primary respnsibility fr ensuring cmpliance with this plicy and fr the general versight t ensure Cmpany funds are being spent prudently. TABLE OF CONTENTS Sectin Reference ABOUT THIS DOCUMENT 1.01 POLICY CHANGES 2.01 COMPANY-SPONSORED CORPORATE CARD 3.01 AMERICAN EXPRESS PROGRAM 4.01 BENEFITS OF CARD PROGRAM 5.01 CORPORATE CARD UTILIZATION 6.01 CORPORATE CARD BILLING AND PAYMENT RESPONSIBILITY 7.01 REPORTING LOST / STOLEN CARDS 8.01 CARDHOLDER EMPLOYEE TERMINATION 9.01 POLICY VIOLATIONS 10.01

2 ABOUT THIS DOCUMENT 1.01 It is Cmpany plicy that all business travel and entertainment expenses are charged n the Crprate Card, if pssible The Crprate Card shuld nt be used fr business purchases that require a purchase requisitin. POLICY CHANGES 2.01 Changes t ur internal peratins and regulated envirnment will result in ccasinal updates t this dcument. Plicy changes will be updated via messaging n the Travel and Expense Sharepint website and/r thrugh ntificatins. Persnnel are expected t be familiar with plicy updates and t review, understand, and apply plicy changes when using their Crprate Card Questins regarding these plicies r suggested updates and/r changes t this dcument are welcmed, and can be ed t 2.03 A current cpy f this dcument is accessible n the Travel and Expense Sharepint website, accessed thrugh the Crprate Travel and Expense link listed n the Intranet under Ppular WR Sites and the cmpany s Human Resurces website as part f the Emplyee Handbk. COMPANY-SPONSORED CORPORATE CARD 3.01 All hme ffice and certain field emplyees with a pay grade f 24 r abve are eligible t receive a Crprate Card. Eligible emplyees that d nt incur business expenses are nt required t btain a cmpany issued credit card Emplyees with a pay grade belw 24 that incur business expenses may receive a crprate credit card with apprpriate manager apprval It is the respnsibility f each manager t btain Crprate Cards fr all their direct reprts incurring business expenses exceeding $300 per year. T btain a Crprate Card, emplyees shuld have their manager Charges incurred n the Cmpany-spnsred Crprate Card are the respnsibility f the individual cardhlder The Crprate Card is t be used fr cmpany reimbursable expenses fr travel and accmmdatins with a business related purpse. Persnal spending unrelated t a business expense charged n the Crprate Card is prhibited. AMERICAN EXPRESS PROGRAM 4.01 The Cmpany-spnsred Crprate Card prgram is managed thrugh American Express In the rare situatin where American Express is nt accepted, anther credit card may be used. In such instances, please nte n yur receipts the nn-acceptance f the Cmpany s Crprate Card when submitting yur expense dcumentatin, t minimize ptential questins frm the expense reviewer.

3 4.03 The issuance f a Crprate Card des nt create an inquiry n an emplyee s credit reprt; hwever, American Express will run the emplyee thrugh a database t check any previus American Express accunt standing The Crprate Card may nt be transferred t, assigned t, r used by anyne ther than the cardhlder. American Express r the Cmpany may, at any time, suspend r cancel the cardhlder privileges fr any reasn, and the cardhlder will surrender the crprate credit card t his r her supervisr upn request American Express ffers a rewards prgram. Emplyees may sign up fr the rewards prgram and persnally retain any rewards generated frm this prgram; hwever, the membership cst is the respnsibility f the emplyee and is nt a reimbursable expense Infrmatin abut American Express may be accessed thrugh the American Express website link included n the Travel and Expense Sharepint website. American Express may be reached directly at BENEFITS OF CARD PROGRAM 5.01 American Express prvides, at n additinal cst, a cmprehensive package f travel insurance with cverage amng the highest levels in the industry, including: Business Travel Accident Insurance Autmatic cverage f up t $350,000 Carry-n Baggage Benefit Replacement cst f up t $1,250 Check Baggage Benefit Replacement cst f up t $ The use f a Cmpany-spnsred prgram fr all travel expenses prvides the Cmpany with anther means f measuring travel spending t btain and maintain favrable airline, htel, and autmbile rental rates. CORPORATE CARD UTILIZATION 6.01 Business-related airline, autmbile rental, and htel reservatins are expected t be charged t the emplyee s Crprate Card fr subsequent reimbursement thrugh the Cncur expense reprting system Managers shuld ensure the Crprate Card is being used fr all business-related travel expenses where American Express is accepted. An emplyees repeated use f a persnal credit card fr business-related expenses shuld be questined as apprpriate Managers must apprve all emplyee expenses incurred n the Crprate Card. CORPORATE CARD BILLING AND PAYMENT RESPONSIBILITY 7.01 Transactins charged t the Crprate Card will link directly and autmatically int the Cncur expense reprting system. Apprved business related Crprate Card charges will be paid directly by the Cmpany t American Express Any persnal expenses charged t the Crprate Card are the respnsibility f the emplyee and shuld be paid by the emplyee directly t American Express. Persnal expenses wuld include emplyee csts incurred n a business trip that are nt cvered in the travel plicy, r csts fr guests accmpanying the emplyee n a business trip that were charged n the Crprate Card In accrdance with the American Express Cardmember Accunt Agreement (distributed by American Express t emplyees with the crprate cards), American Express will charge a mnthly delinquency fee in

4 additin t a late fee fr any prtin f the amunt shwn as due n a billing statement that is nt paid within 45 days. Please see the American Express Cardmember Accunt Agreement fr specific details n hw the delinquency fees are assessed Any delinquency fees incurred are the respnsibility f the emplyee and will nt be reimbursed unless the Cmpany s payment prcess is determined t have caused the emplyee s accunt t becme delinquent. Having a past due balance may result in the suspensin r cancellatin f an emplyee s accunt privileges The Crprate Card will nt affect the emplyee s credit rating unless the card becmes past due 90 days, which can be avided by timely submissin f expense reprts fr business related expenses and timely payment f any persnal charges n the Crprate Card If the Crprate Card ges 60 days past due, American Express r the Cmpany may suspend yur card. American Express may charge a reinstatement fee; that fee is the respnsibility f the emplyee t pay The emplyee and their manager may receive s frm Accunting if their card ges 60 days past due. If yur card ges 90 days past due Human Resurces will be ntified and will wrk with Accunting t reslve the issue. REPORTING LOST / STOLEN CARDS 8.01 The cardhlder is respnsible fr the Crprate Card s safekeeping A lst r stlen card must be reprted immediately t American Express, the Crprate Card prgram administratr, and t yur manager t ensure the card is cancelled in the mst timely manner pssible and that risk related t the lst r stlen card is prperly managed The Crprate Card prgram administratr may be reached at (913) r CARDHOLDER EMPLOYEE TERMINATION 9.01 If the cardhlder s emplyment is terminated fr any reasn, the cardhlder is required t return the card t his r her supervisr. The supervisr shuld immediately frward the terminated emplyee s card t the Crprate Card prgram administratr r t Human Resurces An expense reprt related t any terminated emplyees shuld be submitted prmptly. CORPORATE CARD POLICY VIOLATIONS Plicy vilatins may result in revcatin f the Crprate Card and may invlve disciplinary actin Plicy vilatins include, but are nt limited t, the fllwing: Use f a persnal credit card t pay fr business expenses that shuld have been charged n the Crprate Card, except in extenuating circumstances; Using the Crprate Card fr persnal expenses with n business related purpse; Failure t submit prper transactin dcumentatin substantiating charges incurred n the Crprate Card in a timely manner; Failure t reprt a lst r stlen Crprate Card t the apprpriate persn immediately after discvery; Transferring assignment f the Crprate Card t anther individual.

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