U.S. TRAVEL AND ENTERTAINMENT POLICY

Transcription

1 U.S. TRAVEL AND ENTERTAINMENT POLICY The IDCO Corporate Accounting Group will manage and be the administrator of this T&E Policy. If you have any questions, please contact Cathy Palen, the T&E Coordinator, at or Jane Belair, the Manager of Accounts Payable, at

2 Table of Contents 1. Statement of Policy 2. Application of Policy 3. Credit Cards and Direct Charges o American Express Corporate Credit Cards o American Express Travel o Other Direct Charges to Interactive Data 4. Transportation o Air Travel o Personal Cars o Car Rental o Public Transportation o Other Modes of Transportation/Car Services 5. Lodging o Guaranteed Late Arrival o Reporting 6. Meal Reimbursement 7. Business Meetings/Entertainment o Business Meeting o Entertainment 8. In Lieu of Expenses 9. All Other o Other Reimbursable Expenses o Unallowable Expenses o Other Considerations 10. Approvals 11. Processing of Expense Reports 2

3 Summary The purpose of the Travel & Entertainment policy is to establish guidelines for employees incurring traveling or entertainment business expenses on behalf of Interactive Data Corporation. At their discretion, specific departments or business units may at any time issue more restrictive guidelines than those contained in this policy. I. Financing Business Expenses Credit Cards - - Corporate American Express Cards will be issued to frequent travelers. - All traveling employees must use the Corporate American Express Card unless approved by a senior manager. Charges are paid directly to American Express on your behalf based on a submitted, approved and audited expense report. All charges must be placed on the Corporate American Express Card. To obtain a corporate credit card, a written request from the employee s manager is sent to the T&E Coordinator. An American Express Corporate Card application will be completed on line by the employee. The application is reviewed and approved on line by the Manager of Accounts Payable. Turn around time for issuance of a card is approximately one to three weeks once the credit card company is in receipt of the approved application. The approval is at the sole discretion of American Express and is based on the employee s credit history. II. Types of Expenses Air Travel - Should be coach,. Section 4.1 describes the Premium Class Travel Guidelines. Cab Fair - Receipts must be obtained for any one-cab ride of $25 or more. If the total cab expenses for any one-day total $25 or more, the trips must be itemized (i.e., trips taken and amount). Personal Car - Mileage reimbursement at current year per mile amount, plus parking and tolls when traveling on company business. Rental Cars - Obtained when an employee is away from his/her home office and when the cost is less expensive than another mode of transportation. The employee is responsible for payment until he/she submits an expense report for reimbursement. Corporate rates are available through American Express Travel for Hertz, Avis and National car rental agencies. Lodging - Should be reasonable and convenient to the place where business will be conducted. Domestic hotel room rates within a city should not exceed $350 and $225 pretax in suburban areas. International rates should not exceed $375 pretax. Meals - Please attach any itemized receipts obtained. Receipts should be submitted in the form of a legible charge slip. Employees sharing meals should note which employees were present and list the expense under meals not entertainment. At least one employee must be traveling. (See section 6.0 Business Meetings to determine when it is acceptable to entertain other company employees). Entertainment - Includes at least one non-employee - Meals, snacks, cocktails, etc. are reimbursable. - Reasonable costs of business entertainment of Interactive Data employees are allowed. See Section 5 3

4 III. To Process an Expense Report Interactive Data Corporation All travel reports must be submitted through Oracle iexpense upon completion of a business trip. Expenses submitted after 90 days will not be reimbursed without approval from a senior manager Employees are required to submit all original receipts. Receipts for expenses over $25 are required. American Express statements are not accepted as receipts. Once the expenses have been approved reimbursement can be made. All expense reports should be forwarded to the T&E Coordinator located in Bedford. 1. STATEMENT OF POLICY Interactive Data s policy is to reimburse employees for actual, reasonable and proper expenditures that are incurred in the conduct of authorized business. Each manager is responsible for ensuring that employees reporting to him/her who incur travel or entertainment expenses on behalf of Interactive Data are properly instructed to comply with this policy regarding expenses. Employees on approved travel or other business assignments are expected to exercise good judgment and ensure that the expenditures incurred are reasonable, necessary and in the best interest of the company. Expense reports which do not comply with this policy or require additional information will be returned to the individual for further review and appropriate action or response. Interactive Data reserves the right not to reimburse for expenses submitted out of policy. Questions relating to reimbursement of specific items or completion of expense reports should be referred to the T&E Coordinator or the Manager of Accounts Payable. 2. APPLICATION OF POLICY This policy applies to each US employee who travels on authorized business and/or who incurs related expenses on behalf of Interactive Data. Only those expenses, which are incurred, documented and approved in accordance with this policy, are eligible for reimbursement. It is the responsibility of each manager reviewing and approving expense reports to insure that reported expenses are in accordance with established policy and properly documented. Reimbursement of reported expenses is however, subject to audit by the T&E Coordinator to ensure compliance with this policy and Internal Revenue Service regulations. Deviations from established policy may be warranted from time to time and must be approved by the individual manager and brought to the attention of the T&E Coordinator. The T&E Coordinator will assist line managers in identifying potential problem areas and assist in developing and implementing solutions. Fraudulent entries on expense reports are considered cause for dismissal. Additionally, Interactive Data reserves the right not to reimburse for expenses submitted out of policy. Questions with regard to the application of or recommended changes in the T&E Policy should be referred to the Manager of Accounts Payable or the T&E Coordinator. 4

5 3. CREDIT CARDS AND DIRECT CHARGES American Express Corporate Credit Cards are the only cards authorized by Interactive Data. Employees are responsible for charges incurred with Interactive Data sponsored credit cards. Items of a personal nature should not be charged on these credit cards. Abusive use of credit cards for personal expenditures will result in suspension or revocation of credit card privileges. When an employee terminates, all corporate sponsored Interactive Data credit cards held by that employee must be sent to the T&E Coordinator. 3.1 American Express Corporate Credit Cards American Express Corporate Credit Cards are for business use only. They should only be used to charge authorized business expenses, including airfare. Abusive use of the credit card for personal expenses will result in suspension or revocation of the American Express Card. The IDCO Corporate Accounting Group receives monthly management reports summarizing American Express activity and is responsible for monitoring spending and payment activities. All charges will be paid directly to American Express based on an approved expense report. You must ensure that you submit your expenses immediately after they are incurred to ensure timely payment to American Express. If payment doesn t reach American Express in its next billing cut-off date, the account is considered 30 days past due. Accounts over 45 days past due will result in a late charge and possible suspension or cancellation of the card by American Express and the individual is responsible for paying late fee or charges incurred. Periodically employees and/or managers will be advised of past due balances. American Express will continue to send monthly statements to employees unless an online account is created with American Express (refer to intercom for directions). Miles program fees (such as American Express Membership Rewards) are not reimbursable. If your card is lost or stolen, employees should immediately notify American Express by telephone (day or night) so that another card can be obtained. 3.2 American Express Travel Interactive Data participates in a very favorable travel program with our travel management company, American Express. Employees must use the American Express Travel online booking service called Cliqbook for all business travel needs. In addition to its 24/7 online booking service, American Express also provides 24-hour emergency service via telephone. However, we do expect all employees to utilize the Cliqbook online booking service for their travel needs. All Interactive Data employees who travel will need to complete an employee travel profile with American Express Travel. In order to set up an employee profile, please contact our travel raphaela.keohane@interactivedata.com who will provide you with a Login ID and Temporary Password. In order to set up your online employee profile, please log into the Interactive Data CliqBook site, (if you need assistance, please contact the Navigational Support Desk at ) Once on the site, please create a new password. Once your profile is completed you can make your travel reservations at any time. This profile contains all pertinent information related to the employees travel 5

6 preferences, including your credit card information, TSA information, preferred airplane seating, meal preference, etc. 3.3 Other Direct Charges to Interactive Data Interactive Data does not accept direct charges to the company for airfare. 4. TRANSPORTATION In selecting the method of public or commercial transportation (for example, plane versus train), generally the most effective available method should be used, taking into consideration distance, costs, time involved, flexibility required and the purpose of the trip. 4.1 Air Travel All airline tickets must be paid via the American Express Corporate Charge Card. In cases where the employee doesn t have an American Express Corporate Charge Card due to infrequent travel or credit restrictions, then the employee may use the company s Business Travel Account (BTA). The employee or person making the reservation requests from the travel agent that they want to use the BTA. After making the reservation, the employee will complete a BTA Authorization form (located on Intercom) clearly noting the name of the travel agent who took their reservation on the form. The employee will then forward the BTA Authorization form to the T&E Coordinator for approval. The BTA form can be faxed or scanned and ed to the Manager of Accounts Payable,. The Accounts Payable Manager will approve the form then fax it to the travel agency. The cost of this airline ticket will be billed directly to the company. All air travel should be coach unless otherwise noted in section Travelers are encouraged to use lowest cost airfare unless departure time affects appointments / schedule. For example, accept the lowest logical fare within a 2 hour window that would save IDC greater than $150. For frequent travelers who have a Corporate American Express Card, American Express Travel will charge your Corporate American Express account contained in your employee travel profile. Employees are encouraged to book a flight early enough to take advantage of advanced fares offered, which is typically 2-3 weeks in advance of the trip. However change fees will apply if you need to change your flight, so please take that into account when booking 2-3 weeks in advance. Once the ticket is charged to the employees American Express Corporate Card, the employee may submit a T&E report for reimbursement. Upgrades to your reservation, such as purchase of additional miles, class of service upgrade and premium seat upgrades are not reimbursable Premium Class Travel Guidelines Premium class includes Business Class, Premium Economy Class and First Class. The ability to purchase premium class air tickets is determined if traveling domestic or international. 6

7 At their discretion, specific departments or business units may at any time issue more restrictive guidelines than those contained in this policy. Length of Flight (flying time only) Employee Job Level Class of ticket Domestic Flights All employees Economy Class International Flights Over 10 Hours All Employees Vice President or Higher All Employees Full fare Economy Class or Premium Economy on an approved carrier. Business Class Business Class If an employee plans to fly first class due to emergency or unavoidable circumstances, an explanation must be provided on the expense report and, if possible, brought to the attention of the T&E Coordinator before issuance of the ticket. No more than five employees should be on any one flight; in addition, no more than two Interactive Data officers should be on any one flight. Dates, points of origin and destination must be included on the expense report. All tickets need to be purchased through American Express Travel. A copy of your itinerary is required. Any refunds given to an employee for inconveniences caused by overbooking or downgrading of a business flight are the property of Interactive Data and must be reported as such. The use of private or charter planes is not allowed. Baggage charges are reimbursable and receipts must be included in your submitted expense report. Meals purchased on flights are reimbursable and should be charged to your American Expense card. Receipts must be attached to your expense report. 4.2 Personal Cars Business use of an employee s personal car is reimbursable for: Local Travel Normal service and sales calls in an employee s territory Round trips to the airport and railroad station. Transfer to another company location. The IRS restricts mileage reimbursement to a specific amount without impacting wages reported on W-2 s. In certain cases, legitimate tax deductions attributable to the use of a personal car may be greater than the amount reimbursed. The employee may therefore wish to consult income tax preparation manuals or a tax accountant to determine if he/she is 7

8 qualified for some relief through legitimate tax deductions on his/her personal income tax return. Mileage is reimbursable for the lower of: 1) miles driven, or 2) miles from the office. If an employee reports first to a site closer to home than the office, he will not be reimbursed for that mileage. However, the return trip from the site to the office would be reimbursed. Commuting expenses are the cost of travel between a person s home and his principal or regular place of work. Such commuting expenses, including weekend or holiday travel, are considered personal and therefore not reimbursable. It is the responsibility of the employee s manager approving the expense report to review the reasonableness of mileage claimed on the expense report. Reasonable overnight parking charges will be allowed when the employee is away from his/her home office. A receipt must always be included for overnight parking. When parking at the airport, long term or daily parking should be used dependent on the length of the trip. Hourly parking should be avoided due to higher cost. Interactive Data does not reimburse for parking tickets, towing charges or repairs for a personal car. Economic consideration should be given to the cost of using a personal auto in relation to the cost of other modes of transportation. The total cost of use of a personal car should not exceed the total cost which would have been incurred had normal public or commercial transportation been used. There may be an advantage in the use of an employee s personal car, such as a saving in working hours or transporting other Interactive Data employees. 4.3 Car Rental Rental cars are for business use when an employee is away from his/her home office. Rental cars normally should not be used unless the cost is less than that of other available public transportation, or if limousines or taxis are not available. When circumstances permit, advance reservations should be made through American Express Travel for a rental car in the destination city. Travelers are encouraged to use our preferred car rental agencies, Hertz, Avis and National. Compact class of cars or smaller should be requested when reserving a rental car, or minivan for larger parties in lieu of multiple car rentals. Alternative pricing packages should be taken into consideration when renting a car (for example, one way drop off, daily versus weekly rates, limited versus unlimited mileage). Risks associated with renting a car, including property and personal accident of passengers are covered by Interactive Data insurance. Collision damage or personal accident insurance when renting a car is not reimbursable. If an employee elects not to waive the insurance, it will not be reimbursable. Insurance should be taken out when overseas. Rental cars will be allowed for those employees assigned to training sessions except where appropriate alternative transportation is available. Vehicles are provided to transport employees from their place of lodging to their training location and reasonable local travel 8

9 during the assignment (not more than 50 miles per day). It is not the intent of Interactive Data to pay for extended trips out of the area, either to sightsee or to visit family or friends. Personal use of a rental car should be prorated. The American Express Corporate Credit Card or a personal charge card is required to charge a car. Interactive Data does not accept direct billing to the company for car rentals. The original detailed car rental receipt must be attached to the expense report. If an employee must leave off a rental car at a fast-drop location due to unforeseen circumstances, please note this on the expense report that a rental car expense will follow at a later date. 4.4 Public Transportation Airport limousines, buses, subways, etc., should be used for local transportation where most convenient. Taxis should be used only when other local transportation is untimely or unavailable, or when heavy luggage is being transported. Reimbursement will be for actual expense, including tip. Taxi fares over $25 in any one day should be detailed by the individual trip. If any individual trip is $25 or more, then a receipt is required in addition to the itemization. Taxi fares shared with other employees should be noted on the expense report or on an attached sheet. 4.5 Other Modes of Transportation/Car Services Travel other than local via bus or train or other modes of transportation is reimbursable and should be substantiated by receipts attached to the expense reports. Car Services 5. LODGING BEDFORD: When visiting the Bedford offices, local hotels should be used. Use should be made of local taxis or free shuttles. The use of a car service to provide daily transfers from downtown hotels to the Bedford or Boston offices will no longer be allowed. When car services are used, the employee should ensure that there is no wait time, due to the high fees charged for wait time. If an employee continually incurs wait time, then the privilege of using car services will be removed for that employee. NY / NJ: When car services are used they will be approved to and from the airport and after 8pm from offices to your home. INTERNATIONAL: Car service is allowable to and from the airport as long as the price does not exceed the cost of a taxi. Employees are expected to stay in good business hotels/motels that are reasonable, close and convenient to the place where business will be transacted, but should avoid staying in luxury type hotels or motels. Reimbursement will be made for actual costs incurred for reasonable accommodations within guidelines to employees who are away from their primary office. 9

10 Employees should seek the hotel/motel with the best rates within location and quality requirements when making reservations through American Express. The local office is a good source for recommendations of preferential hotels/motels in a local area. See Business Meetings/Entertainment, Section 7 for the policy regarding the use of hotel/motel rooms for business meetings. 5.1 Guaranteed Late Arrival Reservations through credit cards or travel agencies will guarantee a room for late arrival where requested. Hotel/motel reservations not guaranteed for late arrival will generally not be held after 6:00 p.m. However, if the employee is nearby and it is close to the 6:00 p.m. release time, he/she should call the hotel/motel and they will usually hold the room until arrival. If hotel/motel, transportation, or other reservations are not to be used, cancel them in advance. If an employee cancels a guaranteed hotel room, obtain the cancellation number from the hotel clerk. Employees are responsible for charges resulting from negligent failure to cancel, unless business circumstances dictate otherwise. 5.2 Reporting Hotel/motel detailed receipts (folio bill) must be scanned to the applicable expense report submitted for reimbursement. The reimbursable expenses incurred at a hotel or motel must be separately stated on the expense report by expense category (entertainment, lodging, valet, etc.). Reimbursement will be made at the single occupancy rate. See In Lieu of section for reimbursement policy relating to instances of double occupancy for personal reasons. 6. MEAL REIMBURSEMENT Meals incurred on out of town travel are reimbursable. Receipts are requested for all expenditures. Scanned receipts should be submitted in the form of legible charge slips in addition to restaurant receipts that contain meal details It is expected that employees will exercise good business judgment when dining out. Reimbursement will be limited to the actual expenditure. Explanations and specific manager approval is required on the expense report where the expense appears to be excessive. It is expected that employees will not request a meal reimbursement: If a customer pays for the meal. If Interactive Data sponsors and pay for the meal. If a meal is provided at a conference or meeting. 7. BUSINESS MEETINGS/ENTERTAINMENT 7.1 Business Meetings The purpose of business meetings is to establish or enhance constructive business relationships. Particular care and good judgment is to be exercised in incurring related 10

11 expenses. Entertainment extended on behalf of Interactive Data should be reasonable and proper at all times. Surroundings should be conducive to business discussions. Business meetings must intend to contribute to the cultivation of the relationship with an existing or prospective customer or vendor and/or contribute to the development of an operation of Interactive Data s business. Employees will be reimbursed for business related meals with other employees in the following circumstances: When, for confidentiality reasons, business must be conducted outside of the office When dining with other employees while traveling When authorized by a senior manager for reward, recognition or other appropriate business purpose. When reporting the above expenditures, they should be categorized as meals not entertainment on the T&E report. All business meetings and similar expenditures are to be accounted for on an approved expense report. It should be approved by the manager of the senior employee in attendance. The expense report must include: (1) date of meeting, (2) name of establishment where the meeting was held, (3) names of attendees and type of business relationship, (4) amount of the expense and (5) nature of discussion (business purpose). While we understand there are certain instances when confidentiality is important, we still need a more detailed business purpose. client visit is not sufficient. The IRS requires this documentation and expense reports that are submitted without this documentation will be returned to the employee for completion. 7.2 Entertainment Entertainment is any meal, cocktails, snacks, etc. at which at least one-non Interactive Data business contact is being entertained. The consumption of alcohol at any corporate related event is not encouraged. Any meals, snacks etc. at which only Interactive Data employees are present should be listed under "meals" not entertainment, however, the persons for whom you are submitting a reimbursement and the business purpose should be documented in iexpense including a justification as well as the number of attendees and the name of the attendees. Entertainment expenses are reimbursable only if the entertainment contributes or might contribute to Interactive Data s business. All entertainment expenses are to be accounted for on an approved expense report. It should be approved by the manager of the senior employee in attendance. The expense report must include: (1) date of meeting, (2) name of establishment where the meeting was held, (3) names and number of attendees and type of business relationship, (4) amount of the expense and (5) nature of discussion (business purpose). While we understand there are certain instances when confidentiality is important, we still need a more detailed business purpose. client visit is not sufficient. The IRS requires this documentation and expense reports that are submitted without this documentation will be returned to the employee for completion. 8. IN LIEU OF EXPENSES 11

12 Employees may be reimbursed for expenses incurred in lieu of normal traveling and living expenses provided the expenses are reasonable in amount. The intent is to provide flexibility in recognition of personal convenience and save Interactive Data money. Generally, these types of expenses should be considerably less than the expense the employee would have incurred. As always, good judgment and reasonableness should be exercised when using this privilege. A gift to a host or hostess is allowed for meals or lodging, which would normally be incurred by the employee on business travel. Providing a gift is a gesture of appreciation. Cash payments are not to be given as gifts. A receipt must be submitted for all in lieu of gifts regardless of amount. In lieu of expenditures should be entered on expense reports in the space provided for the substituted item and must be footnoted with a brief explanation shown on or attached to the expense report. The explanation should include an appropriate cost comparison between in lieu of costs and expenses which otherwise would have been incurred. 9. ALL OTHER 9.1 Other Reimbursable Expenses Seminars, Conferences or Membership Fees should be included on your expense report with appropriate backup including receipts. Software/Hardware are unallowable expenses except for individual computer supplies that must be purchased while traveling. Examples include cables, disks/cd s laptop batteries. Laundry and Valet - Reasonable and actual expenses for trips of five days or more duration away from the individual s headquarters will be reimbursed. Fitness Center Fee - Fees for the use of hotel fitness centers will be reimbursed up to $20 per day. Gratuities - Gratuities to waiters and taxi drivers should be included in the cost of meals and taxis, respectively. Other gratuities should be shown separately in Gratuities (other than Meals). Gratuities should not exceed 20%. Other - All other reimbursable expenses must be clearly and correctly documented and described. Allowable expense in this category include such items as baggage checking charges reasonable gratuities to porters, local taxi, bus and subway fares, bridge, ferry, tunnel and road tolls, and other necessary expenses incurred in connection with the conduct of business. Unusual - Unusual Expenses should be explained on the expense report or on an attached note. Some general rules that can be used in deciding what items should be considered unusual are: 1) an amount spent for a routine item (hotel, meals, transportation) that exceeds the normal guidelines for what these normally run. 2) Any expenditure that is not normally considered a business expense. 3) Items covering expense of family other than relocation expenses. Telephone - Non-Credit Cards (See section 3.1 for Credit card use). 12

13 Business - Reasonable and actual expenses for business calls. The employee must include the original telephone bill itemizing the charge (name and business affiliation of the individual contacted) with the expense report. Personal - Reimbursement of personal telephone expenses for calls home to the family will be limited to reasonable length and generally should not be more than once a day. Such calls should be made using the most economical means and should not exceed reasonable time charges. Personal Cell Phone Reasonable and actual expenses for the business use of a personal cell phone. The employee must include the telephone bill with the expense report. Employees, who submit their entire cell phone invoice for reimbursement, must work with the Communications Group to secure service from one of our Company approved carrier to maximize cost savings and ease of tracking. Interviewee Expenses - Reasonable and actual interviewee expenses are reimbursable. Relocation - Expenses are beyond the scope of this policy. Please refer to the Relocation Policy for further information. Flowers - Expenses for the birth of or death of an employee s immediate family member may be reimbursed through an expense report. Other situations require approval of the Business Unit Executive or Human Resources Executive. One-time unusual charges should be pre-approved by the Manager of Accounts Payable, Director of Centralized Accounting Operations, or Chief Accounting Officer. Charges for Baggage (Luggage) - Reasonable baggage charges are reimbursable. Excess baggage is not reimbursable unless that baggage is corporate records or property. 9.2 Unallowable Expenses Listed below is a partial list of the most common items considered to be of a personal nature and, therefore, not reimbursable under normal circumstances: Subscriptions should not be submitted on expense reports. They should be processed via the Subscription Order system (contact the Purchasing Department). Shoe shining, barber and similar items. Movies (including PAY-TV movies in hotels or motels), shows, sporting events (unless for entertainment of behalf of Interactive Data). Excess cost of making circuitous or side trips for personal convenience. Fines for traffic violations, including parking fines. Loss of personal property - clothes jewelry, etc. Loss of personal funds or tickets. Parking or garage charges at the employee s regularly assigned place of business, unless the car is there for Interactive Data s convenience. Purchase of clothing or toiletries and similar items for personal use. Travel insurance. Charges incurred as result of negligent or abusive use of Interactive Data credit cards. 13

14 Cost of members of an employee s family traveling with him/her except in those instances where their presence serves a bona fide business purpose. Maintenance and/or repair of personal property (for example, home and grounds while away from headquarters). Traveling to and from work at normally assigned location. Memberships in social or athletic organizations. Cost of Holiday gifts for employees or clients (unless part of a corporate program), client gifts and Secretary s Day gestures to employees. Purchase of luggage or attaché cases. Entertainment of spouses. Entertainment such as sporting events, marketing events, promotional items and parties. Gift Cards 9.3 Other Considerations Overseas Conversion Rates - All currency exchange receipts should be saved and used for conversion of actual foreign expenses (including Canada). On a long business trip where actual exchange rates are not known due to charged items, an average may be used and a note must be attached to the expense report explaining the method of calculation used. The Wall Street Journal is a good source for obtaining currency exchange rates. All conversion rates used must be clearly indicted on expense reports. 10. APPROVALS Travel and entertainment requires approval in accordance with the approval matrix of at least your direct manager. Approvals on expense reports indicate that the approving manager has reviewed the expenses submitted and that they are necessary, accurate and reasonable. The approval further indicates that they are all reimbursable business expenses in full accordance with this policy. Approved expense reports will be reviewed by the T&E Coordinator to monitor compliance with policy and to identify potential problem areas and assist in developing and implementing solutions. 11. PROCESSING OF EXPENSE REPORTS Expense reports should be completed in Oracle iexpense by following the appropriate guidelines (refer to Intercom for the training guidelines). Expenses submitted after 90 days will not be reimbursed without approval from a senior manager In the event of frequent traveling, living or other expenses for business purposes, an expense report must be prepared and submitted on a weekly basis. It is the responsibility of the approving manager to review the reported expenses for reasonableness and make inquiries as deemed appropriate. Employees who are on the American Express Corporate Credit Card System must use the cards for all business related expenses, including meals while out of town, and business meetings. American Express receipts 14

15 are required in addition to restaurant receipts, but not hotel/motel folios, telephone bills or airfare. American Express Travel receipts/itineraries are required for airfare documentation. Required receipts are for any expenditure $25 or greater. All approved expense reports are reviewed and audited by the T&E Coordinator for review and processing. The T&E Coordinator has been assigned responsibility for auditing expense reports to determine: 1. Adequate explanations for expenses are included 2. Required documentation is complete Expense reports which do not comply with this policy or require additional information will be returned to the individual for further review and appropriate action or response. Interactive Data reserves the right not to reimburse for expenses submitted out of policy. Questions relating to reimbursement of specific items or completion of expense reports should be referred to the T&E Coordinator or the Manager of Accounts Payable. 15