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Travel and Entertainment Expense Policy and Procedures PUR-002 Revision 4 06/01/2018

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Page 1: Travel and Entertainment Expense Policy and …...2018/06/28  · Travel and Entertainment Expense Policy and Procedure. 2.1.1.3 Individuals who request reimbursement or incur the

Travel and Entertainment Expense Policy and Procedures

PUR-002

Revision 4

06/01/2018

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Table of Contents

1.0 Purpose ............................................................................................. 3 2.0 Responsibility ..................................................................................... 4

3.0 Policy ................................................................................................. 5

4.0 Practice and/or Procedures) ................................................................ 6

5.0 Definitions ........................................................................................ 18

6.0 Forms .............................................................................................. 20

7.0 References ....................................................................................... 20

8.0 Local Deployment Actions/Table ........................................................ 20 9.0 Revision History Table ....................................................................... 21

10.0 Appendix .......................................................................................... 22

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1.0 PURPOSE

1.1 The purpose of this Business Travel & Entertainment Policy (“Policy”) is to

provide guidelines and standardize the process and administration of the Express Energy Services (herein after referred to as “Company”) Policy, and to provide users (managers, supervisors, employees and non-employees) with specific policies and procedures regarding business and travel expenses.

1.2 This Policy applies to, and governs, all employees of the Company and all

individuals traveling on Company business and/or incurring reimbursable expenses in the conduct of their employment and/or relationship with the Company.

1.3 The primary emphasis of this Policy is on business and travel expense

reimbursements as described in IRS Publication 463. Business and travel expenses that are reimbursed following IRS accountable plan rules are not subject to income or employment taxes (e.g., federal income tax withholding, social security taxes or Medicare taxes).

1.4 Very generally, the following are the IRS requirements for tax-free reimbursement of expenses under an appropriate accountable plan:

1.4.1 There must be a business connection for the expense, and the expense must be reasonable and necessary;

1.4.2 There must be a reasonable accounting for the expense;

1.4.3 All excess reimbursements must be repaid within a reasonable

amount of time.

1.5 The IRS has issued a number of regulations which further define these requirements and this Policy is designed to meet them.

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2.0 RESPONSIBILITY

2.1 The primary responsibility for compliance with this Policy rests with the individuals who request reimbursement or incurs the business expense, and the managers who authorize and approve the business and travel expenses.

2.1.1 Individuals requesting reimbursement or incurring the business expense

2.1.1.1 The individual requesting reimbursement or incurring the business expense maintains the responsibility for preparing the Expense Reimbursement Report using the company’s expense reporting software.

2.1.1.2 Individuals who request reimbursement or incur the business expense using a company issued credit card are responsible for ensuring the requests comply with the Company’s Travel and Entertainment Expense Policy and Procedure.

2.1.1.3 Individuals who request reimbursement or incur the business expense are responsible for submitting the receipts (see requirements as identified in this document) along with the completed Reimbursement Report. Receipts must be submitted in accordance with this document. Without the proper receipt – the company will not process the employee’s reimbursement request.

2.1.2 Business Expense Approver

2.1.2.1 This individual is responsible for approving the Expense Reimbursement Report and ensuring the report complies with the Company’s Travel and Entertainment Expense Policy and Procedures.

2.2 Who Should Read This Policy?

2.2.1 Employees who incur expenses on the Company’s behalf by using a company issued credit card or incurring the expense themselves and request reimbursement;

2.2.2 Employees who travel on Company business;

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2.2.3 Employees who supervise employees incurring Company business expenses;

2.2.4 Employees who make travel and other arrangements for:

2.2.4.1 Company employees; 2.2.4.2 Prospective Company employees (including job candidates); 2.2.4.3 Interns who travel on approved Company business or

Company-sponsored conventions, conferences, or seminars;

2.2.4.4 Non-employees (this includes but is not limited to, Members of the Board of Directors, recruits, independent contractors, consultants, auditors, and courtesy appointments) who travel for Company related business or incur expenses for which the Company has agreed to pay.

2.3 CAUTIONS:

2.3.1 The Company may have business dealings or operations in various foreign (i.e., non-United States) countries. A particular travel or business expense that is not treated as income for personal income tax purposes in the United States, may be treated as income for personal income tax purposes in the country or locality in which the foreign operations occur, and vice versa. For example, a tax-free reimbursement of moving expenses in the United States may be taxable for personal income tax purposes in a foreign location. As a result, employees and others based at one of the Company’s foreign locations or operations may have different personal income tax consequences than those addressed and specified in this Policy;

2.3.2 Business or travel expenses may also be governed by a customer or supplier contract, and may also have additional requirements or limitations than those required in this Policy. For example, alcohol and tobacco are not permissible expenses to be charged in certain locations, e.g., Qatar. The individual who is requesting reimbursement should consult with other guidelines regarding relevant contractual obligations, procedures, and restrictions;

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2.3.3 Business or travel expenses may also be governed by the Foreign Corrupt Practices Act (FCPA). For more information, please refer to the Company’s FCPA policy in its entirety.

Failure to observe policy could result in possible Personal Income

Tax consequences.

3.0 POLICY

3.1 It is the Policy of the Company to reimburse employees for reasonable and ordinary expenses incurred by the employee while transacting Company business. Therefore, it is the intent of this policy to define the types of expenses that will be reimbursed, and the conditions under which the reimbursement will be made. The reimbursement of travel and entertainment expenses will be in concurrence with the following general guidelines:

3.1.1 Expenses are to be ordinary, necessary, and directly attributable to

the conduct of company-related business;

3.1.2 Expenditures must have been incurred in conjunction with a business purpose or provide business value to the company. Items of a personal nature will not be reimbursed;

3.1.3 Expenditures must be incompliance with the current limits outlined

in the Delegation of Authority

3.1.4 Expenses incurred should represent reasonable cost to the

Company;

3.1.5 Expenses comply with the provisions of this policy;

3.1.6 Entertainment and gift expenses are to be incurred in accordance

with the Company’s Code of Conduct and Conflict of Interest Policy;

3.1.7 Employees will be reimbursed for travel expenses after they have

submitted properly completed, documented, and approved Expense Reimbursement Report(s) supported with “original” receipts as required.

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3.2 This policy serves to ensure that representatives of the Company have the

spending flexibility to appropriately transact the business of the Company, the cost of doing so is controlled and monitored, and that all employees are treated equitably.

3.3 This policy and its related procedures are applicable to all

Company personnel of all divisions, regardless of the level of the employee, and regardless as to the source of funds supporting such expenses. If such expenses are to be charged to a job or program, the terms of the Supplier and/or Vendor Contract(s) will take precedent if they are more restrictive than those of the Company Policy.

3.4 Deviations from this policy must be obtained in writing by the

Chief Executive Officer or Chief Financial Officer prior to incurring the expense.

4.0 APPLICATIONS (PRACTICE/PROCEDURES)

4.1 Traveling Together Express has established rules regarding the numbers of employees permitted to travel together:

A. Only one Vice President may travel with the CEO B. No two Service Line Vice Presidents C. No more than two direct reports to the CEO when traveling

with the CEO D. No more than three direct reports to the CEO E. No more than three direct report to any Executive

Leadership Team member F. No more than 10 Express Employees, unless attending

company leadership meetings

4.2 Air Travel. Air travel reservations should be made as far in advance as possible. An invoice from our travel agency’s online booking system or airline at the airport must be attached to the travel report to support reimbursement for all commercial flights. To obtain the lowest fares, travelers should consider the following:

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4.2.1 Class

Use of first class is strictly prohibited for all domestic and international flights. Domestic air travel should be at the lowest available coach fare. On international flights, business class fares are permitted on flights in excess of 8 hours. Exceptions will be considered on an individual basis for extenuating circumstances, such as employees with disabilities, scheduling difficulties, etc. In such an event, written pre-approval of alternate accommodations must be obtained from the Chief Financial Officer or Chief Executive Officer. The Company will not reimburse employees for the cost of upgrade ticket purchases for window or aisle seats, stickers or coupons to upgrade to first class, or mileage premiums;

4.2.2 Airline Travel “Window”

It is the employee’s responsibility to accept the lowest fare available within a 2-hour time period for requested departure and arrival times. Employees should take the least expensive routing balanced with time management;

4.2.3 Penalty and Non-Refundable Fares

It is the employee’s responsibility to take advantage of these fares to lower air travel costs. In the event your trip is cancelled after purchasing a non-refundable fare, the ticket will retain its value for one year from the date of travel on most major airlines. The Company’s preferred travel agency will provide guidance on future use.

4.2.4 Reservations

It is the employee’s responsibility to make reservations as far in advance as possible. This not only increases the possibility of lower fares, but also of obtaining your seating preference. The required method for booking travel is to use our travel agency’s online booking system. There may be instances where the online booking system may not meet the needs of more complex travel arrangements. In this instance, the traveler will utilize the agency’s full-service resources.

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4.2.5 Frequent Flier Programs The accumulation of frequent flier benefits may be accrued by employees for their personal use; however, the selection of one airline over another for each trip should be made strictly for business reasons, (i.e. cost, scheduling, etc.). Although travelers may identify airline preference, they may not use a specific airline for the sole purpose of the accumulation of frequent flier benefits. Note that cash refunds, resulting from special promotions, downgrading of tickets, denied boarding, etc. must be returned to the Company. Additionally, the cost of programs associated with major credit cards that provide mileage credits for spending activity (e.g. American Express Membership Miles) are not reimbursable;

4.2.6 Airline Club Memberships The cost of airline club memberships is considered a personal expense of the employee. These types of expenses will not be reimbursed;

4.2.7 Unused Tickets It is the responsibility of the traveler to track and apply any unused tickets toward future business travel whenever possible; any unused ticket expiring within 2 months will be used to support travel for other Express employees.

4.2.8 Flight/Life Insurance In the event the traveler purchases additional flight, life or baggage insurance, the employee does so at their own expense and will not be reimbursed by the Company;

4.2.9 Air Charters Air charter service may be used only in those instances for which the aggregate cost of a group of employees traveling together is less by air charter than the cost incurred to purchase individual commercial airline tickets. Use of an air charter service requires prior written approval of the Company’s Chief Executive Officer or Chief Financial Officer and the selection of vendors will be coordinated through the Chief Executive Officer’s office.

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4.2 LODGING

4.2.1 The cost of lodging accommodations is reimbursable in the event

of travel that includes an overnight stay, away from their normal place of business. Employees are expected to live comfortably but prudently while traveling on Company business. In the event overnight accommodations are required, a good commercial hotel with a reasonable rate for that community should be used. Employees are required to book all lodging accommodations via the online travel agency booking tool. Premium hotels may only be used when attending a professional conference where an event group room rate has been negotiated. At no other time are premium properties acceptable and any claim for reimbursement will be denied. Premium hotels are classified as accommodations with 5 or more stars.

4.2.2 The Company has negotiated preferred rates at certain hotels, and employees are expected to take advantage of these rates whenever possible, unless suitable less expensive accommodations that do not offer a corporate discount are available. An original detailed invoice from the hotel is required for reimbursement. This invoice should reflect the charges for the room, taxes and any other purchases charged against the room. If you are aware of a local negotiated rate that is not available via the Company’s preferred travel agency, please advise the Procurement Department.

4.2.3 Hotel Services

4.2.3.1 The Company will reimburse employees for normal and

reasonable hotel service expenses such as in-room meals, hotel parking, business services, etc.

4.2.3.2 Business-related telephone calls will be reimbursed, as well as reasonable calls home; however, employees are encouraged to use cell phones.

4.2.3.3 In-room movies, video rentals, etc. are not reimbursable 4.2.3.4 Frequent Stay Clubs. The cost of frequent stay clubs

offered by many hotel chains is to be at the expense of the employee

4.2.3.5 Laundry costs will only be reimbursed for trips in excess of 7 days unless there are extenuating circumstances

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4.2.3.6 Guaranteed Reservations

4.2.3.6.1 If guaranteed reservations are made for an employee at a particular lodging, and the employee fails to arrive at the designated facility, the employee will be responsible for the “no show” charges unless failure to arrive is through no fault of the employee (e.g. canceled flight)

4.2.3.6.2 If, however, an employee’s trip is canceled or modified, it is the employee’s responsibility to ensure that the guaranteed reservations are canceled in sufficient time to avoid the “no show” charges, and to secure either a cancellation confirmation number and/or the name of the person with whom the cancellation was made, together with the date and time

4.3 GROUND TRANSPORTATION. Employees are expected and encouraged to use the most economical form of ground transportation available except in the event the most economical form of ground transportation would result in an unreasonable and undue inconvenience or costly loss of time. 4.3.1 Car Rental

4.3.1.1 Employees are expected to rent from Full Size Category or lower. It is the responsibility of the traveler to choose the most economical rental car rate. Upgrades should be made only in the event 4 or more employees are traveling together, entertaining customers, etc. The employee will bear the cost of voluntary upgrades if not justified.

4.3.1.2 It is the responsibility of the driver to decline supplemental insurance coverage.

4.3.1.3 Use of Electronic Equipment. It is the responsibility of the driver to obtain or initiate driving directions before operating the rental car. Additionally, it is the responsibility of the driver to refrain from texting,

Note: Please see section “Non-Reimbursable Expenses” in this Section for additional clarification

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sending emails, using a cell phone (unless it is hands free and while not in a school zone) while operating a rental car. It is strictly a violation of Company policy to read, compose or send text messages or email messages while driving a Company Vehicle (see EES Company Vehicle Policy and HSE-010 Safe Driving and Journey Management Procedure).

4.3.1.4 Employees are expected to refuel rental cars before returning the car to prevent gasoline fees charged by the rental car companies. Additionally, the purchase of the “pre-paid fuel service” option currently offered by many of the major car rental companies, should be not be used.

4.3.1.5 An automobile should be rented only if it is necessary to conduct the business of the Company efficiently and productively, and should not be rented merely to provide the employee with the opportunity to sight-see, visit relatives, etc.

4.3.1.6 The cost of Car Rental Company preferred membership programs (e.g. Hertz #1 Club Gold) are not reimbursable. However, membership in these clubs is generally complimentary for frequent travelers and available upon request of the rental car company.

4.3.1.7 It is the responsibility of the traveler to attach the original contract from the car rental agency to the Expense Reimbursement Request Form for all car rentals.

4.3.2 Personal Automobile

4.3.2.1 Employees may use their personal automobile on business trips, or to conduct the business of the Company in the event less expensive transportation is not available, or in the event it is in the best interest of the Company.

4.3.2.2 Employees will be reimbursed for the use of their personal automobile, based on the current IRS Standard Mileage Rate for the number of actual miles driven for business purposes plus the actual parking and toll charges. [Note: this does not apply to employees who have a company car or participate in the mileage tracking and reimbursement program. (see Vehicle Allowance Policy).

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• The basic rule that the IRS follows is that commuting is a personal expense that is never deductible. Commuting occurs when you go from home to a permanent work location—either your: a) office or other principal place of business, b) to a location near your normal place of work (as a guide, within 30 miles of your base), or c) two or more permanent workplaces: the employee has a desk and support services at the second location which he/she regularly uses

4.3.2.2.1 To qualify for this reimbursement,

employees are required to determine the total mileage for the trip, less the normal commute to and from work.

4.3.2.2.2 In addition, to qualify for this reimbursement, employees must maintain the minimum liability insurance required by their respective state. This reimbursement is to be calculated on the distance actually driven. For example, if an employee drives directly from home to the airport or other business destination, the mileage would be calculated from home rather than from the plant or office. [For more information, please see also the Company’s Vehicle Policy and Procedures; and the Company’s Vehicle Allowance Policy and Procedures.]

4.3.3 Airport Parking 4.3.3.1 Airport parking will be reimbursed. The employee should

take advantage of long-term and extended stay parking rates if stay is longer than 7 days. A parking receipt is required for reimbursement. Expenses incurred by using Valet parking will not be reimbursed by the company.

4.3.4 Limousine and Taxi 4.3.4.1 Limousine and taxi service may be used for business

purposes only. The most economical mode should be utilized. These services may be used in travelling to and from airports, to and from hotels, or to and from meeting destinations unless the travel originates from the employee’s home.

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4.3.4.2 Taking a limousine and/or taxi may be used from home only if it is more economical to use this service. It is the responsibility of the traveler to attach a statement of justification to the Employee Expense Account Form for reimbursement if using a limousine and/or taxi to and from traveler’s home.

4.3.4.3 Limousine services required to transport multiple customers or vendor representatives for justifiable business purposes, are reimbursable only in the event they have been pre-approved in writing (email acceptable), and the usage and purposes must be in accordance with the Company’s policy on Code of Conduct and Conflicts of Interest.

4.4 MEALS. Meal expenses incurred during business travel are reimbursable and should not exceed $60 per person per day in major metropolitan areas (see Appendix) and $40 per person per day in non-metropolitan areas. Employees should use discretion when tipping; the tip should not exceed 20% of the total cost of the meal. Reimbursable meals are to only include those incurred while away from home for more than 10 hours and 50 or more miles away (meals that may be taken at home, at the beginning or end of a trip are not reimbursable). Suggested daily meal amounts excluding tax and gratuity are as follows:

MEAL MAXIMUM Breakfast $15.00 Lunch $15.00 Dinner $30.00

4.4.1 Employees are expected to use discretion regarding food and

beverage expense. Excessive beverage or meal expense will not be considered an appropriate business expense, and will not be reimbursed.

4.4.2 Alcoholic drinks will only be reimbursed when consumed with a meal during approved business entertainment. Alcoholic beverages separate from a meal are not reimbursable except if entertaining customers. The consumption of alcoholic beverages while entertaining for official company business is strongly

Note: Amounts allotted for meal expenses are in no way intended to act as a per diem.

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discouraged. In the event either the traveler or the guest will be driving an automobile and alcohol has been consumed, the Company could be considered legally responsible in case of an accident.

4.4.3 In the event two or more employees dine together while traveling,

either the costs may be divided among those dining together, or the senior ranking employee may elect to incur and report the expense. A receipt must support each individual’s meal.

4.4.4 Reasonable and customary gratuities should not exceed 20% of

the total of cost of the expense. Tipping/ Gratuities for services such as those listed below will be reimbursed, based on the destination and quality of service rendered:

• Airport Skycap Porter • Bell Service/ Porter

• Valet Parking • Housekeeping • Chauffeurs, Lyft, Taxi, Uber Drivers • Wait Staff

4.5 WI-FI. The Company will reimburse employees for business-related WI-FI charges incurred at a hotel (in the event the hotel does not provide complimentary WI-FI). WI-FI charges incurred elsewhere (airport, airplane, etc.) and personal MI-FI devices or charges will not be reimbursed.

4.6 TELEPHONE. The Company will reimburse employees for business-related telephone calls while traveling, as well as reasonable calls home. It is suggested that cell phones should be used to avoid the expense of long distance fees and surcharges charged by hotels.

4.6.1 Employees are not authorized to use airline in-flight telephones

except in the case of an extreme emergency.

4.7.2 It is strictly a violation of Company policy to read, compose or send text messages or email messages while driving a Company Vehicle. The use of cell phones and other hand-held devices, such as pagers, mobile phones, smart phones, laptops, vehicle entertainment devices (i.e., DVD Players, etc.), or any other

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electronic communication devices while operating a company vehicle is strictly prohibited. Employees may use approved hands-free devices for voice calls only. (Refer to HSE-010 for additional information).

4.7 TRAVEL TIME. Actual travel time for non-exempt employees outside the

normal work schedule will be considered hours worked, and will be compensated in the normal manner. Non-travel time, such as time spent eating or sleeping, is not considered time worked and will not be compensated. Exempt employees will not be compensated for travel time.

4.8 FOREIGN CURRENCY EXCHANGE EXPENSES. In submitting a

reimbursement request for expenses incurred in a foreign currency, it is the responsibility of the traveler to attach a receipt showing the exchange rate received. If expenses were charged to a credit card, the credit card statement, if available should be used as support. Costs associated with the exchange of one currency for another are reimbursable.

4.9 TRAVEL EXPENSES REIMBURSED BY OTHERS. It is not permissible, and it is in violation of the Company’s Code of Conduct and Conflict of Interest Policy, for any travel expense to be paid by a vendor or prospective vendor without the approval of the Chief Financial Officer (CFO) or higher position. Travel expenses incurred by company employees may be paid by a professional association or other group if the employee is performing a service for the group (e.g. teaching, speaking, etc.)

4.10 TRAVEL ADVANCES. Travel advances will not be made to employees

except under extraordinary conditions, and must be approved in accordance with the Travel Approval Form. Travel advances will not be made to employees who have company credit cards, except in unusual circumstances such as foreign travel, etc.

4.11 COMBINATION OF BUSINESS AND PERSONAL TRAVEL. If an employee combines personal activities with a business trip, or includes a spouse or other family member or friend, then all additional expenses incurred attributable to the personal activities (hotel room days, airport parking days, meals, additional airfare, etc.) must be excluded from the employee’s request for reimbursement. In cases where it is expected that spouses attend, prior written approval from the Company’s Chief Executive Officer or Chief Financial Officer is required. In those situations, the expenses of the spouse are reimbursable. These expenses, however,

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are to be shown separately to permit the proper accounting of spousal travel expenses, which are not deductible for federal income tax purposes.

4.12 NON-TRAVEL BUSINESS MEALS AND ENTERTAINMENT. The

company will reimburse employees for the cost of non-travel business meals and entertainment expenses if a valid business purpose exists for the expenditure and appropriate authorizations are obtained. Meals costing more than $25 must be supported by a receipt. The following entertainment expenses qualify for reimbursement: 4.12.1 Business meals with representatives of outside corporations or

entities during which necessary Company business is transacted. 4.12.2 Entertainment expenses that are expected to be in excess of $250

per occurrence must be pre-approved in writing by the CEO or CFO.

Note: Reference should be made to the Company’s Code of Conduct and Conflict of Interest Policy regarding these types of expenditures.

4.12.3Meals and entertainment for Express Energy Services staff

members incurred specifically for an existing business purpose must be pre-approved in writing by the Service Line VP. An agenda must be presented with receipt for full reimbursement.

4.13 FEES AND MEMBERSHIPS. Professional association fees, memberships, and licenses incurred to maintain standing or in the furtherance of employee’s company-related duties are reimbursable, if approved by the CEO or CFO per the DOA policy. 4.13.1 Country Club memberships will not be reimbursed. Only those

expense related to entertaining customers are eligible for reimbursement. All personal expenses incurred as a result of the membership shall be the employee’s responsibility.

4.14 NON-REIMBURSABLE EXPENSES. In addition to any non-

reimbursable expenses specifically mentioned above, the following expenses are never reimbursable:

4.14.1 Repair, maintenance or insurance of personal automobiles

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4.14.2 Theft, loss or damage of personal luggage or effects unless extenuating circumstances outside the employees control exist which will be reviewed on a case by case basis

4.14.3 Theft or loss or personal funds and other personal property

4.14.4 Personal reading materials or entertainment

4.14.5 Fines for parking or traffic violations

4.14.6 Personal credit card service or late fees

4.14.7 Personal hygiene, health care items, or services purchased while

traveling, including haircuts, shoe shines, etc.

4.14.8 Child-care expenses and/or housesitting costs

4.14.9 Pet care, including fees for boarding pets and other animal care

4.14.10 Amenities such as in-room movies, in-room bars, saunas and

massages, etc.

4.14.11 Liquor by the bottle and tobacco products

4.14.12 Gambling expenses/losses

4.14.13 Gift cards are considered cash. Many customers’ codes of ethics

and behavior forbid cash gifts (including gift cards) to their employees. Therefore, no gift cards are to be given to customers, and no reimbursement will be given for gift cards purchased by a Company employee

4.14.14 Expenses associated with sexually-oriented businesses, escort

services, services and entertainment such as but not limited to “gentlemen’s clubs,” adult entertainment and cabarets

4.14.15 Greeting or holiday cards for fellow employees

4.14.16 Unexplained expenses

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4.14.17 Personal recreation, entertainment such as greens fees, sight-seeing fares, tours, movies, theater tickets, entry fees, lift tickets, etc.

4.14.18 Candy, energy drinks, gum, snacks, water, etc.

4.15 REPORTING TRAVEL AND EXPENSE ITEMS 4.15.1 Actual expenses must be reported using the “Employee Expense

Reporting Software”, filed promptly (within 14 days) after incurring expenses. Requests for reimbursement of expenses after 60 days from the transaction date will not be reimbursed. Company credit card expenses not submitted in an expense report via the employee expense reporting software within 60 days of the transaction date will result in the employee’s company credit card being suspended. The unsubmitted expenses will be then be subject to automatic payroll deductions.

4.15.2 An employee charges airline tickets to a personal credit card, the original passenger coupon showing the credit card number must be submitted for reimbursement.

4.15.3 Receipts documenting all travel-related expenditures over $25 not

discussed elsewhere in this policy should be submitted with the Employee Expense Account form.

4.15.4 Only amounts related to hotel costs (including applicable taxes)

should be reported under “Hotel Charges”. Other costs on the itemized hotel bill (e.g. meals, etc.) should be broken out and reported in their respective categories.

4.15.5 The specific business purpose, the names of persons entertained

and the names of the organizations represented by those persons are to be clearly indicated on the Expense Reimbursement Report. Employees will use Business Meals Attendees or Entertainment Clients to list the names and companies of the attendees.

4.15.6 Approved travel advances and company direct-billed expenses, i.e.,

airline tickets, are to be entered in the space marked “Other Expenses Paid by Company.” These will not be included in the amount to be reimbursed.

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4.15.7 Expense reports must be submitted by the employee using the

Expense Reporting Software. Expense reports must then be approved in the expense report system by the employee’s VP.

4.15.8 Once the Expense Reimbursement Report is properly approved, the

expense reporting software will then route the report to the accounting department.

4.15.9 The accounting department may request specific authorization for

reimbursement of expenditures that are not addressed in these procedures.

5. Definitions

5.1 Business Travel – Travel that involves one or more of the following:

5.1.1 Using commercial transportation for business purposes

5.1.2 Overnight stay away from home or place of residence for business purposes

5.1.3 Travelling more than 50 miles AND 10 hours away from home office or home location during one trip

5.2 Delegation of Authority – Required expenditure approval levels as authorized by the Chief Executive Officer, Chief Financial Officer and Board of Directors

5.3 Foreign Corrupt Practices Act (“FCPA”) – The Foreign Corrupt Practices Act of 1977, as amended, 15 U.S.C. §§ 78dd-1, et seq., was enacted for the purpose of making it unlawful for certain classes of persons and entities to make payments to foreign government entities to assist in obtaining or retaining business. Specifically, the anti-bribery provisions of the FCPA prohibit the willful use of the mails or any means of instrumentality of interstate commerce in furtherance of any offer, payment, promise to pay, or authorization of the payment of money or anything of value to any person, while knowing that all or a portion of such money or thing of value will be offered, given or promised, directly or indirectly, to a foreign official to influence the foreign official in his or her official capacity, induce the foreign official to do or omit to do an act in violation of his or her lawful duty, or to secure any improper advantage

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in order to assist in obtaining or retaining business for or with, or directing business to, any person.

5.4 Foreign Government Entity or Official – Any person, party or entity acting in his/her capacity as an officer or employee of or otherwise on behalf of: a foreign government, any agency, department or instrumentality of such a government, a business partly or wholly owned by such a government (such as a national oil company); an official or candidate of a political party; or a public international organization, such as the International Red Cross or the World Bank. Under this definition, for example, any employee of a national oil company, of a customs office, or of a visa office would be considered to be a Foreign Government Official. Similarly, members of a royal family and some honorary officials would be considered to be Foreign Government Officials.

5.5 Metropolitan Areas – A region consisting of a densely populated urban core and its less-populated surrounding territories, sharing industry, infrastructure, and housing. Sometimes referred to as a metropolitan region, metro area or just metro, it usually comprises multiple jurisdictions and municipalities: neighborhoods, townships, cities, and counties. Typically, metropolitan areas include one or more urban areas, as well as satellite cities, towns and intervening rural areas that are socio-economically tied to the urban core, typically measured by commuting patterns. Generally, the population of a metropolitan area is greater than one million. See Appendix “A” for listing of example Metropolitan Areas.

5.6 Travel-Related Expenses – Expenses incurred for Business Travel, which may include but are not limited to, transportation, lodging/accommodation, meals and mileage.

5.7 U.S. Government Entity or Official – Any person, party or entity acting as, or selected to be an officer, employee, or individual acting on behalf of the United States, any state or local government, or any department, agency or branch of government in any official function, including any person in the private sector with responsibility to carry out a government policy or program. Under this definition, for example, any Congressman, city councilman or judge or employee of Homeland Security, the Bureau of Land management, Environmental Protection Agency (EPA) or the Transportation Security Administration (TSA) would be considered a U.S. Government Official.

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6. Forms

6.1 Lost receipts

A. If an employee loses a receipt, the employee will need to contact the

airline, car rental agency, hotel, restaurant, etc. to request a replacement.

B. Photos are acceptable as receipts in the expense reporting software

system. For example, a photo can be used as a replacement for a fuel

receipt if the receipt failed to print at the pump. The employee will need to

take a picture of the gas pump detailing the total cost of the fuel and total

number of gallons of fuel purchased. The picture will then be used instead

of a receipt for this purchase.

C. If the employee still does not receive a copy of a lost receipt after

requesting a copy from the vendor, the employee may submit a Lost

Receipt form. Before the employee can submit the Lost Receipt form in

lieu of the receipt, the employee must receive approval of the Lost Receipt

form from either the CEO or CFO.

7. References

7.1 Express Energy Services Code of Conduct Policy

A. Conflict of Interest Policy

B. Entertainment and Gifts

7.2 Express Energy Services FCPA Policy

7.3 HSE-010 Safe Driving and Journey Management Procedure

7.4 Express Energy Services Company Vehicle Policy

7.5 Express Energy Services Vehicle Allowance Policy

7.6 HR-001 Express Energy Employee Handbook

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8 Local Deployment Actions/Table

9. Revision History Table

Rev Date Description Prepared by: Reviewed by: Approved by:

1 10/07/10 New, initial

release

2 8/12/2016 Revision Englisha Wells Kyle Lorentzen,

Derrick Doud

3 06/01/2018 Revision Cheryl Weishiemer Derrick Doud,

Cherie Kelsey Stuart Bodden

Signatures:

Appendix

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10.1 Examples of Metropolitan Areas

Atlanta-Athens-Clarke County-Sandy Springs, GA

Boston-Worcester-Providence, MA-RI-NH-CT

Charlotte-Concord, NC-SC

Chicago-Naperville, IL-IN-WI

Cincinnati-Wilmington-Maysville, OH-KY-IN

Cleveland-Akron-Canton, OH

Columbus-Marion-Zanesville, OH

Dallas-Fort Worth, TX-OK

Denver-Aurora, CO

Detroit-Warren-Ann Arbor, MI

Houston-The Woodlands, TX

Indianapolis-Carmel-Muncie, IN

Kansas City-Overland Park-Kansas City, MO-KS

Las Vegas-Henderson, NV-AZ

Los Angeles-Long Beach, CA

Miami-Fort Lauderdale-Port St. Lucie, FL

Milwaukee-Racine-Waukesha, WI

Minneapolis-St. Paul, MN-WI

New York-Newark, NY-NJ-CT-PA

Orlando-Deltona-Daytona Beach, FL

Philadelphia-Reading-Camden, PA-NJ-DE-MD

Pittsburgh-New Castle-Weirton, PA-OH-WV

Portland-Vancouver-Salem, OR-WA

Raleigh-Durham-Chapel Hill, NC

Sacramento-Roseville, CA

Salt Lake City-Provo-Orem, UT

San Jose-San Francisco-Oakland, CA

Seattle-Tacoma, WA

St. Louis-St. Charles-Farmington, MO-IL

Washington-Baltimore-Arlington, DC-MD-VA-WV-PA