2023-12-01_laszlo.kovacs_Travel & Expense Reimbursement Policy Aug 2023 (1).docx

Statement of Purpose and Responsibilities

This document establishes the policy governing the reimbursement of travel, entertainment and other business expenses incurred while conducting business for TheKey and its subsidiaries, (“TheKey” or “the Company”).  Employees and their leaders are responsible for complying with this policy and are expected to exercise prudent business judgment regarding expenses incurred.  Any exception to this policy must have the prior written approval of the employee’s manager and the Chief Financial Officer (CFO). Requests for an exception should document extenuating circumstances or proposed overall savings to TheKey.

It is TheKey's policy to reimburse employees for ordinary, necessary, and reasonable business-related expenses. This includes expenses in which there is the expectation of deriving some benefit for TheKey, the employee is actively engaged in a business meeting or activity necessary to the performance of the employee's job duties, or, in the case of entertainment, there is a clear business purpose.  Expenses submitted that are not in compliance with this policy should not be approved.

Credit Cards

Note that employees that frequently incur travel, entertainment and other business-related expenses may be issued a Company credit card.  Company or personal credit cards may NOT be used for vendor payments (i.e., building or equipment leases, office furniture, capitalized items, payments to contractors, marketing materials, computers, or other payments typically processed through Accounts Payable).  Vendor/service-provider payments should always be processed through Accounts Payable for compliance with U.S. IRS regulations including Forms-1099.

Company credit card transactions, like the use of a personal credit card, are reimbursed by the Company after expenses are submitted through Concur and approved by the employee’s manager.  The cardholder is responsible for paying the Company card statement.  The use of a Company credit card is limited to necessary and reasonable expenses incurred while conducting company business and is not to be used for personal expenses.  If use of the Company credit card is not in compliance with this policy, employees may be held personally liable for the respective card transactions, and other disciplinary actions may be taken including, but not limited to, termination.

Expense Submissions

Requests for reimbursement of business expenses must be submitted in the Company’s designated system, currently Concur (Concur Expense Management). For help with Concur, including access requests, the expense support team can be reached by emailing expense-support@thekey.com.

Each expense shall be separately identified, added to expense reports, and submitted by the employee to their manager for approval in Concur.  Company credit card transactions will be automatically added to Concur.   Expenses should be grouped and submitted twice monthly, by the 1st and 15th of the month.  Corporate cardholders should make sure they submit expenses with enough time to receive reimbursement and pay the Company credit card prior to incurring late fees.  Late fees are generally incurred 30 days after the statement is posted and are the responsibility of the employee.

General Documentation

The Company complies with IRS regulations, which require that all business expenses be substantiated with adequate records. All reimbursements require that a valid business purpose is provided.  Receipts are required for all transactions/line items on your expense reimbursement.  Acceptable receipts are from 3rd party vendors and must include a vendor name, transaction date and itemization of the expenses.  If the expense amount is $25 or less and you are unable to secure a receipt (cash tips, etc.), a note must be added in Concur.  Specific requirements for Meals, Lodging, etc. are noted in the appropriate section below.

Approvals

Expense reports, together with required documentation, must be submitted to the employee's manager for review and approval using the Company's designated process and system (Concur).  Reimbursement of expenses that are not in compliance with this Policy requires the written approval of TheKey's CFO.  It is the employee’s responsibility to obtain written approval and include it in Concur prior to reimbursement request submission.

Managers approving expense reports are responsible for ensuring:

The expenses submitted are reasonable, necessary, and reimbursable under this policy.

The expense report has been filled out accurately and the expenses are coded to the correct expense type and location.

The required documentation is included.

Managers should review expense reports and approve or return reports timely to enable the employee to submit payment of their credit card statement.

Guidance for Expense Types

Travel Meals, Business Meals, and Entertainment

Travel Meals are targeted at USD $75 maximum per person per day based on IRS guidance. The daily meal target is inclusive of all expenses including alcohol.  Detailed receipts must be provided on your expense report for actual expenses incurred.

Business Meals and Entertainment involve Company employee(s) and/or vendors or other business partners or clients.  Employees must be present with a client or prospect to be reimbursed for entertainment expenses.  Payment for business meals must be made by the highest-ranking employee in attendance.  Tips are not to exceed 20% of the food and beverage sub-total.  Receipts must include all external attendee name(s) and company name(s) for which they work as well as the business reason for the expense.  Receipts must be itemized and include the credit card receipt.

Employee Relations Meals and Entertainment involve Company employee meals provided for the convenience of TheKey or to support employee relations and team building.  Payment must be made by the highest-ranking employee in attendance. Tips are not to exceed 20% of the food and beverage sub-total.  Receipts must include all attendee name(s) and the business reason for the expense.  Receipts must be itemized and include the credit card receipt.

Travel - Airfare

Travel arrangements must be booked at least 14 days in advance of your desired travel date.

All employees are expected to reserve coach or economy class and are encouraged to search for the lowest available restricted but changeable fare, rather than the fully refundable fare.  Business class is only permitted for international flights exceeding eight hours in duration and must receive pre-approval from an Executive Team member.

Reimbursable expenses:

Expenses for in-flight wi-fi for business purposes

Baggage fees, unless traveling with personal items, such as golf clubs, except where required for business.

Non-Reimbursable expenses:

business use of personal frequent flyer credits

personal flights, even if such flights are incorporated into a flight schedule that serves business purposes.

Charges for overweight baggage

Air travel insurance

Additional charges for flight upgrades (e.g., Economy Comfort)

Flight change fees for non-business reasons

Airline club memberships

Other personal charges related to air travel.

Travel - Hotel

Prudent judgment should be used when selecting a hotel to identify a reasonable price for acceptable accommodation.

Folios provided by a hotel are to be used as itemized receipts.

Reimbursable expenses:

Laundry and dry-cleaning expenses are reimbursable for employees traveling 5 or more nights.

Non-Reimbursable expenses:

travel costs associated with his/her spouse or partner.

Hotel penalties and cancellation fees unless the trip cancellation is at the Company’s request.

Personal toiletries, personal entertainment, lost property, companion expenses, childcare, and pet care.

Room damage charges including room cleaning due to excessive usage or smoking.

Membership in hotel clubs

Car Rental

It is expected that reservations will be made depending on the type of travel.  Standard policy for vehicle rental is a midsize for one or two employees, full size for three to four employees, and minivan for five to six employees.

Employees are responsible for inspecting rental cars for damage prior to rental commencement.

All vehicles should be filled with gasoline to the appropriate level before returning to the rental location.

A limousine service requires prior Executive Team approval.

Car services like Uber and Lyft are reimbursable when they are less expensive than car rentals and airport parking fees.

Other Transportation

Employees who utilize personal vehicles for business purposes are required to have a valid driver's license and at least the minimum insurance coverage required by law.

Employees will be reimbursed at the current IRS or CRA rate for mileage over their "base" mileage while traveling or otherwise conducting company business. Base mileage is defined as the round-trip mileage between the local office (i.e., work) and home. Employees must note, as appropriate, that base mileage has been subtracted from total mileage on expense reports.  Gasoline is not reimbursable due to the use of the reimbursable mileage rate which covers gasoline.

Primary insurance for employees who use their personal vehicles for business purposes shall be through their own personal automobile insurance policy and will be responsible for any damage to the vehicle, as well as for liability.

Regular use of a car service like Uber or Lyft to TheKey local office is not reimbursable.  Car services may only be used with the approval of your manager and for the exclusive benefit of TheKey.

Shuttles, taxis, etc. will be reimbursed while traveling or otherwise conducting company business, if usage is reasonable and for the benefit of TheKey.

Parking, bridge, tunnel and road tolls will be reimbursed while traveling or otherwise conducting company business. With respect to airport parking fees, employees should avoid utilization of short-term parking lots for trips 36 hours or longer.

Employee Gifts

Gifts to employees are reimbursable up to the U.S. IRS de minimis benefit limit of $100 per employee.  Appropriate gifts include items such as flowers, food, special occasion gift items, etc.  These types of gifts are not taxable to the employee and do not need to be reported to TheKey Payroll department.

All gift cards, regardless of amount, are considered taxable to the employee and must be reported to TheKey Payroll department.

Mobile Phone

A Company provided mobile phone may be purchased for employees with significant client interaction or executives at the Vice President level and above.

Business use of personal cell phones is not reimbursed by TheKey.