INTERNATIONAL TRAVEL AND ENTERTAINMENT POLICY
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1 INTERNATIONAL TRAVEL AND ENTERTAINMENT POLICY 1
2 Interactive Data International Travel & Entertainment Policy Summary The purpose of the Travel & Entertainment policy is to establish guidelines for employees incurring traveling or entertainment business expenses on behalf of the company. 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 Credit Cards will be issued to frequent travelers where currently offered. - Employees are billed directly and are responsible for direct payment of their credit card. II. Types of Expenses Air Travel - Should be economy. Section 5.1 describes the Premium Class Travel guidelines. Corporate rates are available through American Express Travel. All air travel should be booked through American Express Travel Cab Fare - Receipts must be obtained for all cab rides. Personal Car - Mileage reimbursement at current year per mile amount, plus parking and tolls when traveling on company business. (Changes yearly-if in doubt as to new rate please call the T&E Coordinator.) 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. Lodging - Should be reasonable and convenient to the place where business will be conducted. Lodging reservations should be made through American Express Travel US hotel room rates within a city should not exceed $350 (pretax) and $225(pretax) in suburban areas. International hotel rates should not exceed $375 (pretax). If a hotel is not available at these rates or lower, prior manager approval is required. All monetary values should be adjusted for local currencies, as applicable. 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. (See section 8.1 Business Meetings to determine when it is acceptable to entertain other company employees). At least one employee must be traveling. Country specific tax regulations might apply which do not allow the reimbursement of meals and are communicated by the local HR department also in regards to daily allowances. Entertainment - Includes at least one non-employee - Meals, snacks, cocktails, etc. are reimbursable. - Reasonable costs of business entertainment of Interactive Data employees are allowed. All travel claims must be submitted upon completion of a business trip in Oracle iexpense, where currently available. The company reserves the right not to reimburse employees for expenses submitted after 90 days. Original Receipts for all expenses over 20 are required to be scanned and attached for manager approval. Hard copies of all receipts must be submitted to Accounts Payable. 2
3 Interactive Data Corporation Travel and Entertainment Policy Table of Contents 1.0 Statement of Policy 2.0 Application of Policy 3.0 Credit Cards and Direct Charges o American Express Travel 4.0 Transportation o Air Travel o Personal Cars o Car Rental o Public Transportation o Other Modes of Transportation/Car Services 5.0 Lodging o Guaranteed Late Arrival o Reporting 6.0 Meal Reimbursement 7.0 Business Meetings/Entertainment 8.0 In Lieu of Expenses 9.0 All Other o Other Reimbursable Expenses o Unallowable Expenses o Other Considerations 10.0 Approvals 11.0 Processing of Expense Reports 3
4 1.0 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 traveling 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. 2.0 APPLICATION OF POLICY This policy applies to all non-us employees 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 ensure that reported expenses are in accordance with established policy and properly documented. Managers reviewing expense reports are required to review attached receipts. Reimbursement of reported expenses is however, subject to audit by the finance department to ensure compliance with this policy and Inland Revenue rules. Deviations from established policy may be warranted from time to time and must be approved by the individual manager and brought to the attention Finance Manager Europe Transactions. 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. 3.0 CREDIT CARDS AND DIRECT CHARGES Corporate Credit Cards are the only cards authorized by Interactive Data. Individual traveler credit cards will be authorized only where Corporate Credit cards are unavailable or where American Express is not accepted. 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 leaves the company, all corporate sponsored Interactive Data credit cards held by that employee must be sent to the Finance Department before a final payroll check will be released. 4
5 3.1 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 or other online travel booking tool (when available - see below) for all business travel needs. In addition to its 24/7 online booking services, American Express also provides 24-hour emergency service via telephone. However, we do expect all employees to utilize the applicable 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 coordinator (corinne.thomas@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 site, (If you need assistance, please contact the Navigational Support Desk at within the UK and outside of the UK). 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 preferences, including your credit card information, TSA information, preferred airplane seating, meal preference, etc. Applicable American Express online booking tools and availability: Available 1/31/2011 Country UK/Channel Islands Ireland Online Tool Available 3/31/2011 Country France Netherlands Switzerland Germany Italy Finland Belgium Australia Hong Kong Singapore Japan UAE Online Tool /etravel etravel etravel etravel online booking is not available Please continue to use your current travel service until notified of American Express Travel availability in your area. 4.0 TRANSPORTATION 5
6 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 obtained via American Express Travel. All air travel should be coach, unless otherwise noted in section Employees are encouraged to book a flight early enough to take advantage of advanced fares offered, which is typically 4 weeks in advance of the trip Premium Class Travel Guidelines Premium class includes Business Class and Full Fare or Premium Economy Class. The ability to purchase premium class air tickets is determined the length of travel as noted in the table below. 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 Employee Job Level Class of ticket Under 5 Hours All Employees Economy Class Between 5 & 10 hours All Employees Senior Management and their Direct reports Full fare Economy Class or Premium Economy on an approved carrier. Business Class Over 10 Hours All Employees Full fare Economy Class or Premium Economy on an approved carrier.or Business Class with the express approval of a Senior Manager. If an employee plans to fly not in accordance with the above guidelines due to emergency or unavoidable circumstances, an explanation must be provided on the expense report and, if possible, brought to the attention of the Finance Manager Europe before issuance of the ticket. 6
7 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. Airline club memberships, such as Admiral s Club, Crown Room Club, etc. will not be reimbursed. Baggage charges are reimbursable. Meals purchased on flights are reimbursable. 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. 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. Interactive Data does not reimburse for parking tickets, towing charges or repairs for a personal car. Economic consideration should be give 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. Compact class of cars or smaller should be requested when reserving a rental car. 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 are covered by Interactive Data insurance. Collision damage and personal accident insurance should be waived when renting a car. 4.4 Public Transportation 7
8 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 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: 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. 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. When car services are used, the employee should ensure that there is no wait time, due to the high fees charged for it. If an employee continually incurs wait time, then the privilege of using car services will be removed for that employee. 5.0 LODGING 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. Employees should seek the hotel/motel with the best rates within location and quality requirements when making reservations American Express Travel. The local office is a good source for recommendations of preferential hotels/motels in a local area. 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. 8
9 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 attached to the applicable expense claim 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. 6.0 MEAL REIMBURSEMENT Meals incurred on out of town travel are reimbursable. Receipts are required for all meals. 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. Country specific tax regulations might apply which do not allow the reimbursement of meals and are communicated by the local HR department also in regards to daily allowances. It is expected that employees will not request a meal reimbursement: If a customer pays for the meal. If Interactive Data sponsors and pays for the meal. If a meal is provided at a conference or meeting. 7.0 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 expenses. Entertainment extended on behalf of Interactive Data should be reasonable and proper. 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. 9
10 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 names of attendees and type of business relationship and the nature of discussion (business purpose). 7.2 Entertainment Entertainment is any meal, cocktails, snacks, etc. at which at least one-non Interactive Data business contact is being entertained. Any alcohol consumed during related corporate events should be strictly in moderation. Any meals, snacks etc. at which only Interactive Data employees are present should be listed under "meals" and described as meals not entertainment, however, the persons for whom you are submitting a reimbursement and the business purpose should be documented on the expense claim. 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 of attendees and type of business relationship, (4) amount of the expense and (5) nature of discussion (business purpose). Farewell parties (and gifts) for terminating employees are prohibited. 8.0 IN LIEU OF Business 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. 9.0 ALL OTHER 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 other and described as gratuities. Gratuities should not exceed 20%. Exorbitant gratuities will not be reimbursed. 10
11 Other - All other reimbursable expenses must be clearly and correctly documented and described. Allowable expenses 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 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 itemizing the charge (name and business affiliation of the individual contacted) with the expense report. Interviewee Expenses - Reasonable and actual interviewee expenses are reimbursable. 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 Division Executive or Human Resources Division Executive. 9.1 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: Departmental and all team related Seminars, conference registration fees/expenses, subscriptions, membership fee/dues, software/hardware or other non-travel related expenses should not be submitted on expense reports. These vendors should be paid via the Purchase Order system or through use of the company Purchase Card (please 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. 11
12 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. 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 Christmas gifts, client gifts and Secretary s Day gestures to employees. Purchase of luggage or attaché cases. Entertainment of spouses. Cost of child care when employees are required to travel for the company. Cost of pet care when employees are required to travel for the company. Cost of airline club memberships. 9.2 Other Considerations Overseas Conversion Rates - All currency exchange receipts should be saved and used for conversion of actual foreign expenses. 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 Financial Times is a good source for obtaining currency exchange rates. All conversion rates used must be clearly indicted on expense reports APPROVALS Expenses for all travel and entertainment require approval of the traveling employee s direct manager, and in accordance to Oracle iexpense approval hierarchy (where currently available). 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 reports will be reviewed by Finance to monitor compliance in line with company audit requirements, policy and to identify potential problem areas and assist in developing and implementing solutions. Exceptions will be escalated to appropriate Management PROCESSING OF EXPENSE REPORTS All expense claims / reports should be submitted through the company s standard Oracle iexpense system, where currently available. The original hard copy of the claim must be submitted to Finance in an expense envelope containing all appropriate original receipts for charged items and cash expenditures. The company reserves the right not to reimburse employees for expenses submitted after 90 days. 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 12
13 manager to review the reported expenses for reasonableness and make inquiries as deemed appropriate. Expense reports not complying with this policy or requiring additional substantiation will be returned to the responsible manager for further review and appropriate action or response. Questions relating to reimbursement of specific items or completion of expense reports should be referred to the traveler s local Finance Department. 13
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