Travel and Entertainment Policy. Introduction and Purpose. Purpose

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1 Introduction and Purpose Purpose It is Colliers International s (Company) policy that employees be reimbursed for all appropriate and approved travel, entertainment and other expenses incurred when conducting Company business. This Policy clarifies acceptable expenses, how expenses should be approved and the appropriate level of documentation required in support of expense claims. This Policy will support and accelerate the expense reimbursement process and allow the Company to negotiate the best discounts available for Corporate travel. Sustainable Business Practice The Company is committed to sustainable business practices. In an effort to reduce the impact travel has on our environment, all Personnel are expected to make responsible and appropriate business travel choices. Scope and Applicability This global travel and entertainment Policy applies to all managers, employees, independent contractors and consultants ( Personnel ) of CMN companies, subsidiaries and partner firms who incur reimbursable expenses. The Policy represents the Company standards for reimbursement of travel and entertainment expenses. More stringent guidelines may be implemented by managers or the Company in response to specific situations or market circumstances. Amendments The Company is negotiating a global travel agency agreement to simplify the travel booking process. This Policy will be amended to reflect changes to processes resulting from those negotiations and may be further amended from time to time by the Company. Responsibilities & Approvals Manager, Employee, Contractor and Consultant Obligations All Personnel are responsible for familiarizing themselves with and complying with this policy. Personnel should exercise care, good business judgment and common sense when incurring expenses on behalf of the

2 Company. Personnel are responsible for the complete and accurate preparation of required expense reimbursement reports. Company Obligations The Company will reimburse Personnel for all legitimate and approved expenses within 15 business days from the point of receipt, (or sooner, if practicable and based on the local office reimbursement cycle). The Company assumes no obligation to reimburse Personnel for expenses that are not approved or in compliance with this policy. Approvals A designated signing authority ( Approver ) must pre-approve all travel and approve all reimbursable T&E expenses borne on behalf of the Company. Local finance functions will maintain a list of approvers for each office, country and region. All Personnel who are required to review and approve expenses have a responsibility to familiarize themselves with this document and only approve those expenses that are incurred within the scope and intent of this Policy. Submission Expenses must be submitted for reimbursement within 30 days of the expense being incurred and paid. Any final expenses for a calendar year ending December 31 st must be submitted for reimbursement during the first week of January. Documentation Reimbursement requests must be accompanied by expense claim forms and appropriate supporting documentation. The relevant supporting documentation required in each office will depend on local tax laws, regulations and business practices. Local finance departments will advise the minimum documentation requirements for each office or region. Conflict with Individual Employment Contracts In the event this Policy conflicts with any specific provisions within individual contracts of employment or consulting arrangements, individual contracts will take precedence.

3 Audit Expense claims will be subject to review by the Company s Internal Audit function on a regular basis. Assistance Any questions or queries relating to this policy should be directed to Air Travel Appropriateness Air travel should only take place where other means of communication or forums for meetings (web conferencing, video conference and conference calls) are inappropriate or not available. Approval If air travel is required, all such travel should be pre-approved. Personnel that undertake air travel should maintain formal or written evidence of pre-approval. Approval Frequent Travelers For administrative efficiency, and in exceptional circumstances, Regional Presidents may provide a blanket pre-approval for senior members of staff who are frequent travelers. Bookings Where practical, reservations for air travel should be made 7-14 days in advance to take advantage of discounts and early booking savings. Non-refundable airfares should be used in situations where travel can be planned in advance and is not reasonably expected to change. Class of Service The Company s general policy is that all air travel should be booked at the lowest available coach/economy airfare that allows for itinerary changes. Only where a designated approver gives specific pre-approval, may business class can be flown. First class tickets are not permissible.

4 Class of Service Upgrades Any incremental costs for upgrades are not reimbursable. Frequent Flyer Miles Personnel may retain all frequent flyer mileage awards and bonuses earned as a result of business travel. However, when there is a price differential, flights should not be booked on the basis of accruing frequent flyer miles. The least expensive carrier should be selected whenever possible. Discounts or Rebates Any discounts or rebates received by an employee as a result of a business trip, with the exception of frequency awards such as frequent flyer points, should be deducted from reimbursable expenses. Saturday Night Stays Extending your stay to include a Saturday night may reduce the cost of airfare. Provided that the airfare savings derived from extending stays to include a Saturday night exceed any additional costs (hotel, meals, rental car, etc.), this may be an acceptable option with pre-approval from your manager. Combining Personal with Business Travel It is possible to combine personal travel with business travel, however the Company will only be responsible for and reimburse the business component of the travel. Spouse or Companion Travel The Company will not generally reimburse travel expenses incurred by a spouse or other individuals accompanying Personnel on business. Advance written approval for spouse or companion travel is required from your manager and evidence of such approval must be attached to your expense claim. Unused Tickets Unused airline tickets or flight coupons may have a cash value and should never be discarded or destroyed. You should promptly notify the travel agency about unused paper or e-tickets, and return paper tickets to expedite a refund or to apply the cost of the ticket toward a future trip. If a change in your

5 itinerary requires reissuance of your ticket, always request that your unused portion be credited against your new ticket's cost. Bumping Airlines will often overbook flights. In many cases, passengers are offered free vouchers and/or financial incentives for bumping to later travel. Personnel may take advantage of voluntary bumping insofar as a later flight will not impact regular business and would not incur any additional expense to the Company. Use of Frequent Flyer Mileage Personnel may utilize their earned frequent flyer miles to book business travel in order to create savings for the Company. As an incentive, the Company will reimburse personnel up to 75 percent of the total cost of the lowest economy fare providing appropriate documentation is submitted and manager approval is given. Sundry Expenses The costs of reasonable food and beverage consumed before boarding or during the flight will be reimbursed. In line with current practice by North American airlines, the costs of checking in 2 items of baggage will be reimbursed to the extent that such costs are not for excess weight or excess baggage. The costs of books or magazines purchased for reading during flights and the costs of in flight movies or telephone calls will not be reimbursed. Restrictions The following restrictions apply to airline travel: No more than four (4) executives should fly on the same aircraft. Executives are defined as country heads or the heads of global functional departments. Personnel may not fly in an aircraft owned or operated by him/her or by any member of his/her household, nor pilot, operate or act as a crewmember of any aircraft while traveling on Company business. Ground Transportation Taxis, trains, or public transportation should be considered over limousines, unless the use of a limousine is more economical or equal in cost.

6 Rental Cars Automobiles should be rented only when alternatives are unavailable or less cost efficient. Economy or Mid-size cars should be rented unless prior approval is obtained from your manager for a larger or nonstandard vehicle. Charges for accessories such as car telephones will not be reimbursed. Car Rental Insurance Personnel should assess the extent to which insurance coverage is provided by the credit card used to pay for the rental or by other travel insurances provided by the Company or carried individually. Currently, the Company s insurance (as it may be modified from time to time) does include some coverage for Personnel when renting a car for business purposes for a period of 30 days or less. However, Personnel should inquire about a particular jurisdiction and coverage with their Manager before they travel, as some jurisdictions require the purchase of automobile coverage locally. In the absence of appropriate insurance cover, LDW (Lost Damage Waiver) and CDW (Collision Damage Waiver) insurances (or the equivalent in markets outside of North America) should be purchased from the car rental company. Sharing Ground Transportation Arrangements should be coordinated with other employees travelling on the same trip to minimize the costs of ground transportation. Parking Parking at your usual place of work or your normal Company office is not reimbursable unless your manager has pre-approved this expenditure. Airport parking garages should typically only be used for periods of 3 days or less. Offsite airport parking facilities with shuttle to/from the airports should be used for trips longer than 3 days. Tolls Tolls for roads and bridges are reimbursable. Fines and Violations Personnel will not be reimbursed for any parking or traffic violations or associated court or legal costs.

7 Mobile Phones Personnel should not operate any mode of transportation when using a mobile phone, except, where acceptable under local laws, if using a hands free device. Personnel must obey all applicable laws. Hotels and Lodging Preferred Hotels Personnel should take advantage of any preferred deals or discounts negotiated by CMN offices within local cities. To retain these preferred deals, CMN is typically required to provide the hotel with a minimum number of bookings per year. When planning to travel, Personnel should contact the local CMN office to determine if a preferred hotel is available at the CMN negotiated rate. Where such a hotel is available, this should be the first choice of accommodation for all Personnel. Alternative Hotels In the absence of a room being available at a hotel with a CMN negotiated discount, Personnel should stay at appropriately priced 3 or 4 star hotels. Hotel rooms should be booked based on the best available hotel rate for the intended destination. As a general rule, if alternative choices are available, staying at 5-star hotels is not permitted. Location For efficiency, hotel rooms should be booked in proximity to meeting sites or local offices. If choosing to stay away from the immediate proximity of the meeting location, consideration should be given to the additional cost of taxis or rental cars. Frequent Guest Programs Personnel may retain awards derived from hotel frequent guest programs, however participation in these programs should not influence hotel selection if it would result in an incremental cost above an alternative hotel of the same class. Trade Shows and Conferences Hotel bookings for trade shows and other business meetings should be made as far in advance as possible. This will offer the greatest choice and rates among hotels.

8 Long Term Stays For extended stays away from home, accommodation on a weekly or monthly basis at reduced rates should be negotiated. No Shows No-show fees are generally not reimbursable except in extraordinary circumstances and when approved by your manager. Alternative Stays Personnel who stay with friends or relatives in lieu of a hotel may provide a gift to their host/hostess. The maximum amount of any gift is the equivalent of US$50 per day, up to a maximum of US$200 for the entire stay. Cash gifts are not permitted and an original receipt for the gift must be included with the expense claim. Sundry Expenses Itemized receipts are required for all lodging expenses. In room movies will not be reimbursed. Reasonable telephone calls are acceptable for reimbursement. The consumption of contents from in room bars or refrigerators should be kept to a minimum and only used where it is not practical for Personnel to use alternative hotel or external facilities. In the case of telephone calls, where possible, individuals should seek to use calling cards. Laundry expenses are reimbursable for extended stays (typically over 7 days). Meals Meals When Traveling The cost of meals when traveling will depend on a number of factors such as location and lodging arrangements. As such, the Company does not have a global per diem allowance for meals. General guidelines may exist in your region and all Personnel should check with their local Finance departments for such guidelines. All meal expenses incurred while traveling should be reasonable relative to the cost of food and beverage in the country or city being visited.

9 Staff Meals Meals between Company Personnel are reimbursable only when directly related to Company business. In the circumstances where business critical activities do take place during a meal, the costs will be reimbursable on the basis that i) the business purpose is documented on the expense claim form ii) the names of all CMN Personnel in attendance are listed on the expense claim form iii) the most senior individual present should pay the bill and iv) the expense is approved by someone who did not attend the meal or event. Client Gifts, Awards, and Entertainment General Conditions The Company is mindful that, in many cultures and countries, gifts, awards and entertainment play an important role in building and maintaining business relationships. When deciding to provide a gift, award or entertainment, all Personnel should give consideration to the business practices of the recipient client, any perceived or real reciprocity that the gift, award or entertainment creates and the implications of local, state, or federal rules and taxes on the Company. Conflict of Interest Certain gifts or entertainment are not permitted if it is believed that they would create a real or perceived conflict of interest. A gift or business courtesy should not be accepted if it does not fall within the guidelines described within this document or if the donor expects something in return, may be attempting to gain an unfair advantage, may be attempting to influence judgment, or if acceptance creates the appearance of any of the foregoing. Any gift with a value in excess of US$250, requires the written pre-approval of your manager. Any gift with a value in excess of US$500 requires the approval of your country Finance Director. If you have any doubt about the appropriateness of a certain gift or entertainment, please seek written approval. Gifts Gifts and/or business courtesies that may be accepted are subject to the conditions outlined in section 7.02 and include those considered to be promotional in nature and nominal in value, such as: Retail merchandise (e.g., coffee mugs, pens, clothing or items of similar value displaying a company logo) or event considered reasonable within your region or approved by your manager;

10 Refreshments or meals considered reasonable within your region or approved by your manager; Hospitality or recreational activities (e.g., concerts, sports event) considered reasonable within your region or approved by your manager; Contributions to charitable and/or other non-profit organizations considered reasonable within your region or approved by your manager; Use of the donor s facilities materials or equipment considered reasonable within your region or approved by your manager. Entertainment Entertainment shall at all times be reasonable and proper and have the purpose of establishing, enhancing or pursuing appropriate business relations. Business meals deemed excessively lavish or extravagant will not be reimbursed. Alcohol When ordering alcohol, common sense should be applied in terms of the quantity and cost of such purchase. The cost of expensive wines and alcoholic beverages will not be reimbursed. Personnel should not operate any mode of transportation or other equipment under the influence of alcohol. Personnel must obey all applicable laws. Cash and Negotiable Instruments Under no circumstances does cash, negotiable instruments or anything else that is easily and/or readily converted into cash represent an appropriate gift from and/or to a business partner or client. The acceptance or giving of cash or negotiable instruments to any person or entity is strictly prohibited. Specific Exclusions In addition to the above guidelines, the following expenses are specifically non-reimbursable: Airline, hotel or other loyalty program membership costs Airline lounge access Excess baggage charges Babysitters or pet care Barbers and hair dressers Car washes, repairs or damage to employee s vehicle while traveling on Company business Charitable donations

11 Personal items (including clothing, luggage and toiletries) Country and other club dues and memberships Credit card annual charges, late payment fees or interest Fitness/Health club monthly charges Flowers and gifts unless approved in advance by your manager Golf green fees unless covered by section 7.04 above Guaranteed no show /cancellations fees at hotels Loss of personal property Personal entertainment including movies in hotel rooms Newspapers, books, magazines and souvenirs Personal medical expenses Spouse/companion travel Tips in excess of what is customary for the country and service provided Tobacco products Transportation to and from home to regular place of work

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