CORPORATE CREDIT CARD POLICY



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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

ABOUT THIS DOCUMENT 1.01 It is Cmpany plicy that all business travel and entertainment expenses are charged n the Crprate Card, if pssible. 1.02 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 e-mail ntificatins. Persnnel are expected t be familiar with plicy updates and t review, understand, and apply plicy changes when using their Crprate Card. 2.02 Questins regarding these plicies r suggested updates and/r changes t this dcument are welcmed, and can be e-mailed t Creditcard@waddell.cm. 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. 3.02 Emplyees with a pay grade belw 24 that incur business expenses may receive a crprate credit card with apprpriate manager apprval. 3.03 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 email creditcard@waddell.cm. 3.04 Charges incurred n the Cmpany-spnsred Crprate Card are the respnsibility f the individual cardhlder. 3.05 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. 4.02 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.

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. 4.04 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. 4.05 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. 4.06 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 1-800- 528-2122. 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 $500 5.02 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. 6.02 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. 6.03 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. 7.02 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. 7.03 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

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. 7.04 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. 7.05 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. 7.06 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. 7.07 The emplyee and their manager may receive emails 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. 8.02 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. 8.03 The Crprate Card prgram administratr may be reached at (913) 236-2625 r Creditcard@waddell.cm. 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. 9.02 An expense reprt related t any terminated emplyees shuld be submitted prmptly. CORPORATE CARD POLICY VIOLATIONS 10.01 Plicy vilatins may result in revcatin f the Crprate Card and may invlve disciplinary actin. 10.02 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.