Travel_Entertainment_Policy_Final.txt

THEKEY POLICY AND PROCEDURE
	Company: The Key
	Title: Travel & Expense Policy
	Policy Owner: Finance>Disbursements
	Version: 2
	Effective Date: June 30, 2023
Updated: 12/2/2024
	Approved By: Paul Kahn, CFO and Gerri Nath, CAO
	Classification: Confidential – Controlled Distribution
	  

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.
Brex Corporate Credit Card
We are now requiring employees to use Brex corporate cards for all company expenses. This change is designed to streamline expense management, enhance financial transparency, and ensure compliance with company policies. Personal cards should only be used if a corporate card is unavailable.
Note that employees that frequently incur travel, entertainment and other business-related expenses will be issued a Company credit card. Company or personal credit cards should NOT be used for vendor payments (i.e., office supplies, capitalized items, payments to contractors, marketing materials, computer supplies, 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 Coupa and approved by the employee’s manager. 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 Coupa (Coupa Expense Management). For help with Coupa, including access requests, the expense support team can be reached by emailing coupasupport@thekey.com.
Each expense shall be separately identified, added to expense reports, and submitted by the employee to their manager for approval in Coupa. Company credit card transactions will be automatically added to Coupa. 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. 


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 within the Coupa Expense Management tool. 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 Coupa. 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 (Coupa). Reimbursement of expenses that are not in compliance with this Policy requires the written approval of TheKey's CFO and/or COO. It is the employee’s responsibility to obtain written approval and include it in Coupa 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 expenses submitted are within the appropriate budgeted amount for the associated spend category. 
* 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 up to $85, or less, per person per day based on IRS guidance. The daily meal target is inclusive of all expenses including alcohol. Itemized receipts must be provided as support for travel meal expenses and must be 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.


*All people in attendance for company sponsored meals must be listed within the expense including employees and guests. 


   * 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.


   * The associated costs of DoorDash, UberEats and any other such food delivery service should be counted against the targeted daily spend limit for employee travel meals. For business 


meals and employee relations events these services should be used sparingly and only 
when appropriate.   
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. No upgrades to premium economy or equivalent are permitted without advanced permission in writing from manager. This approval must be attached as support for the expense submitted in Coupa. Business class is only permitted for international flights exceeding eight hours in duration and must receive pre-approval from an Executive Team member. Written approval must be attached as support for the expense submitted in Coupa.
   * 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. Please note in the instance of a cancelled/changed flight, an employee should request a credit to be used at a future time. Should an employee with credits leave employment at TheKey, the employee will request a refund from the carrier and reimburse TheKey for said amount.
      * 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.
   * Use of AirBnB, VRBO and other such lodging vendors is prohibited unless previously approved 


by leadership.
   * Meals and beverages consumed at the hotel still fall under the requirements Travel Meals, Business Meals, and Entertainment guidance provided above.
   * Itemization on hotel folios is required (detailed breakdowns of charges) and is essential for transparency, accurate billing, and compliance with business and tax requirements. Please note that all purchases of food and beverages count toward the daily food allowance.  
   * 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.
      * Upgrades to premium rooms/accommodations including premium Wi-Fi and hotel lounge access.
      * 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 costs for hotel clubs/status.
Car Rental
   * It is expected that reservations will be made depending on the type of travel. The 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. Prepaid fuel fill up should be avoided.


   * A limousine/car service requires prior Executive Team approval in writing and submitted as support within the expense report.
   * Rideshare services like Uber and Lyft are reimbursable when they are less expensive than car rentals and airport parking fees. 


   * If a vehicle is rented, all use of rideshare services such as Uber and Lyft should be avoided.


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. 
   * Origination and destination points must be detailed within Coupa for all requested milage reimbursements. 
   * 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.
   * All spend on employee gifts and teambuilding should be in line with budgeted spend and the employee and their manager will be responsible for appropriate tracking. 
Other
* All licenses for technical tools (i.e., Zoom, Adobe, etc.) should be procured through TheKey’s IT department (ITSupport@thekey.com). In the event that the IT department cannot provide a license or access to a needed tool, written permission from a manager is required and should be included as support for all recurring instances of said spend. 
* Subscriptions to such recurring services as those provided by LinkedIn, Apple, Canva, etc. require the express permission of a manager in writing which should be included as support for all recurring instances of said spend. 
* Any and all donations to charitable organizations and causes are strictly prohibited. Approval from the Executive team is expressly required in writing for any such expenditure. 
* Any employees utilizing Amazon.com or 1800Flowers for purchases should send a request to be set up on the corporate account so purchases being made can utilize any corporate discounting. Please forward requests to coupasupport@thekey.com. 
* Forwarding/advancement of petty cash to clients by caregivers or other agents of TheKey is strictly prohibited.
* It is expected that all attempts are made to obtain and provide an itemized, written receipt for all spend. In the event that an itemized receipt cannot be sourced, the employee must attest that the expense was reasonable, necessary and compliant with this policy.