Travel Expense Reimbursement Policy

Business Development & Travel Expense Reimbursement Policy

Effective: January 1, 2016

1. Purpose & Scope

This Business Development & and Travel Expense Policy has been developed with the intent of supporting the efforts of Nicolaides Fink Thorpe Michaelides Sullivan LLP (“Nicolaides”) personnel while incurring reimbursable expenses in the course of firm-related business while at the same time effectively managing related expenditures. The policy applies to all Nicolaides personnel who incur reimbursable business development and /or travel expenses in the course of conducting firm or client business. It is the responsibility of all personnel to support and comply with all aspects of this policy. The firm will reimburse personnel for all reasonable and necessary expenses while traveling on authorized business. The firm assumes no obligation to reimburse travelers for expenses that do not comply with this policy and reserves the right to disallow reimbursement of expenses submitted that fall outside of the firm’s policy.

This document is confidential and a trade secret of the Firm. As such, it is not to be copied, duplicated, distributed, and posted on any electronic bulletin board to any third party outside the Firm.

2. General Travel policy statements

1. The firm does not have corporate credit cards; therefore, all travel must be charged to your own credit card and reimbursed through the expense reimbursement process.
2. If a trip is outside the US, foreign currency transactions should be supported with receipts AND a copy of the credit card statement to prove foreign currency translations.
3. All travelers should make their best effort to get the lowest fare possible for the firm or client.
4. All non-attorney administrative travel requires pre-approval by COO.
5. Submitting fraudulent receipts or falsifying your expense report will result in disciplinary action.

3. Client Reimbursement Policies

Employees should be aware of their individual client expense reimbursement policies and employees should adhere to those policies. Expense reports submitted that do not adhere to those policies will be rejected and returned to the preparer for correction. See Reimbursement Chart at Appendix A to this policy. Additionally, if an expense is ever in question, please contact the Billing & Collections Manager or Accounting Clerk for clarification on whether it is reimbursable by the client.

4. Air Travel

a.   Class of Service for Non-Billable Air Travel:

a.  All non- client reimbursable air travel is to be in coach class and should be booked as a non-refundable ticket at the lowest logical fare to the extent possible. If a different cass is desired, pre-approval by the COO or Managing Partner should be obtained.

The use of full-coach fares for upgrade purposes when less expensive fares are available is a violation of this Policy and the traveler will be reimbursed only up to the lowest published coach fare.

1. Upgrades to “first class” or “business class” for firm business are made at the individual traveler’s personal expense except that non-refundable “business class” may be utilized by Partners when the air travel is international (where the originating and destination locations are in different countries) and it involves six (6) or more hours of flight time. Other staff and non-partner lawyers will travel “coach class” for all domestic and international flights, except by written exception by the Firm’s COO, Managing Partner or Controller.

i.  Flight time will be based on the airline’s published flight time for all legs of a single one-way trip except in the case that any stop or layover exceeds six (6) hours. If there is a layover exceeding six (6) hours in duration, each leg will be considered a separate flight when determining eligibility for upgrade. Layover time is not included in the airlines calculation of flight time.

1. Class of Service for Client Reimbursable Air Travel- Some client billing arrangements allow for travel at higher priced coach fares that allow for automatic upgrades and/or bookings in business or first class. In those cases, billable travel may be booked at the class allowed by the client. If the client does not approve of and agree to pay the cost of a higher class of travel, the traveler must travel coach on client business unless the upgrade is at the traveler’s personal expense. The firm will not reimburse the traveler for the difference. Follow up auditing will be conducted to verify that the client reimbursement of those costs took place. Any write offs or write downs of these costs will be charged back to the traveler.
2. Air Travel Arrangements- Firm personnel should make every effort to fly the least expensive direct route from one city to another. Booking your travel arrangements seven to fourteen days in advance typically provides the lowest fare options at the time of booking.
   1. Air travel should be booked as a non- refundable ticket when available. However, if the travel is client billable the client’s policy requires the purchase of refundable tickets, the traveler should follow the client’s policy. Also, in some cases where the travel plans are likely to change one or more times it may be more economical to book a refundable ticket. As a general rule if the refundable ticket is $200 more than the non-refundable ticket, the traveler should select the non-refundable ticket.
   2. It is acknowledged that changes in schedule are often unavoidable; however, personnel should undertake their best efforts to avoid changes that incur change fees.
   3. # of personnel on flight- No more than three name partners or executive committee members may be on the same flight.
   4. Denied Boarding Compensation- Airlines occasionally offer free tickets or cash allowances to compensate travelers for delays and inconveniences due to overbooking, flight cancellations, changes of equipment, etc. The firm does not recommend that travelers volunteer to alter travel arrangements at the request of an airline; however if the traveler elects to accept this compensation, it is the traveler’s to use as he/she sees fit and it is not the property of the firm.

5. Rail Travel

1. Rail travel- Where rail travel is an option for short trips, the traveler should consider this as a cost saving option versus air travel.
2. Class of Service for rail travel- Rail travel may be booked in coach, business or first class as is appropriate based on the business travel customs in each country.

6. Hotel

1. Hotel Reservations- Currently, the firm does not have any negotiated preferred rates with hotels in any cities. Until preferred rates are put in place, hotel reservations should be made at hotels offering reasonable rates.
2. Fees for Cancellation and Early Departure- Hotel cancellation policies vary from hotel to hotel. The traveler should be aware of the hotel’s policy. Failure to cancel reservations will result in no-show charges. No-show charges will not be reimbursed by the firm without a valid business reason. Some hotels add surcharges for early departure. These will only be reimbursed with a valid business reason.
3. Reimbursable Hotel Charges- The firm will reimburse the traveler for single occupancy room rates plus applicable taxes and surcharges (unless accompanied by a spouse with a clear business purpose). The original bill is required for reimbursement. Any upgrade fees resulting from booking suites or upper or club floors are not reimbursable.
4. Private Accommodation in Lieu of Lodging- If the traveler chooses to stay with friends, relatives or at a secondary home instead of a preferred hotel, no reimbursement for lodging, including host/hostess gifts, will be provided.
5. Mini-bar Charges- The firm will not reimburse the traveler for mini-bar charges or in-room bottled water. The traveler should attempt to purchase any snacks of sort at a reasonable price.
6. Hotel Parking- The firm will reimburse the traveler for parking charges within the hotel.

7. Ground Transportation

1. Cost Considerations- Business travel shall be done by the most economical means of transport, with due consideration given to time efficiency. Whenever more cost effective to do so, public transportation, local taxi, or complimentary hotel shuttle service should be used. Use of these means can provide substantial savings over rental vehicles.
2. Rental Vehicles- Currently, the Firm does not have any negotiated preferred rates with rental car vendors. Until preferred rates are put in place, the lowest available price for the necessary type of car should be booked.

a.   Please use discretion in the selection of the make and model of car rented. It should be of the most economical size for the number of people in your party and the distance involved in the car travel. Travelers should make all effort to share rental vehicles, when possible.

b.  Cars should be returned with a full tank of gas. Gas charges will be reimbursed by the firm.

c.  Rental car insurance- The firm’s insurance policies currently do not cover automobile insurance for employees. Employees must have their own automobile insurance when renting a vehicle and if the employee does not have personal automobile insurance, they are required to purchase the vendors insurance and the firm will reimburse for the cost. If an employee has their own automobile insurance and also purchases insurance through the rental car company, the firm will not reimburse for the cost of the insurance.

1. Taxis- Street cabs should be utilized in lieu of rental cars whenever possible. In some areas there may be security concerns that prohibit street cabs and/or require certain vetted cab or car services. Taxis will be reimbursed where their use is reasonably necessary, such as inclement weather, an urgent need to return to the office, etc. and relate to firm business or non-reimbursable client business. Receipts are required along with reason for taxi use.

d. Private Car Services - Currently, the firm does not have any negotiated preferred private car service rates. If a private car is used, the rates should be reasonable. There will be no reimbursement for car service for regular commuting from your personal residence to your home office.

e. Personal Automobile- Personnel who use their personal automobile for business- related travel may be reimbursed for the actual cost of mileage, parking and tolls. Mileage and tolls to/from the individuals’ respective office and their home will not be reimbursed unless required for a client related matter/meeting (ie. Client meeting in suburbs but need to come to office prior to meeting). Mileage will be reimbursed at the current rate published by the IRS.

1. Receipts are not required for mileage however individuals must record the date, destination, business purposes and the number of miles driven for each trip. A print out of the map directions showing the mileage is necessary for roundtrips in excess of 50 miles and is helpful in all cases.
2. The firm assumes no responsibility for personal automobiles used for firm business. Individuals must have a minimum bodily injury and property damage insurance protection as required by law in order to use their personal vehicles on firm business. The firm will not reimburse personal or third party damage/injury claims, including deductible amounts. The firm will not reimburse travelers for parking fines, moving violations, towing, automobile repairs or everyday commuting to the office where the travelers works.

8. Other Travel Related Expenses

a.   Meals- The firm will reimburse personnel for all meals while they are traveling out of town, whether client reimbursable or non-client reimbursable. The reimbursement limitations per person for non-client reimbursable travel meals are up to $20 for breakfast, $25 for lunch and $50 for dinner. Client reimbursable meal costs should be within the client’s reimbursement policy. Alcoholic drinks may only be claimed if consumed with a meal. On travel days, only the meals within the travel time will be covered (i.e. if the trip began at 5AM, breakfast would be covered.

If it started at 9AM, breakfast would not be covered. If the trip ended at 3PM, dinner would not be covered. If the trip ended at 9PM, dinner would be covered.). Please use discretion. The firm has the right and obligation to refuse reimbursement for any meal or beverage expense deemed to be excessive or not in the price range appropriate to the city visited.

1. Telephone Calls and Other Communication Charges- Business calls, faxes and other similar communication charges while traveling on business are reimbursable. The original telephone bill must be attached to the expense report. Hotels often charge a premium for calls made from hotel telephones; therefore, whenever possible, travelers should use their cell phone or a calling card for telephone charges. Calls using airlines’ onboard telephone service are not reimbursable. When traveling internationally, travelers should consult with their cellular phone carrier regarding short-term international rates or plan to utilize calling cards while in a foreign country.
2. Internet Charges- If possible, the traveler should obtain a Mi-Fi from the Office Administrator prior to their trip to avoid any additional internet charges while traveling. Internet charges at airports, restaurants, hotels, in-flight, etc. will not be reimbursed if the individual did not attempt to obtain a Mi-Fi. If there were no Mi-Fi’s available to the traveler prior to their trip, the firm will reimburse for necessary internet charges up to $10 per day. It should be noted on the traveler’s expense report why internet charges are included.
3. Dry Cleaning/Laundry- Laundry and dry cleaning expense are only reimbursable for international travel and/or trips exceeding four nights, or in the event of an unexpected travel disruption. This disruption must be documented on the expense report.
4. Tips and Gratuities- Tips and gratuities should not exceed 20% for taxis and meals. Tips should only be calculated based on the subtotal of food and drinks. Tips to skycaps, hotel porters, bellhops, maids, etc. are reimbursable expenses up to a maximum of $10 per day and should be itemized on the expense report.
5. Airport Parking- Airport parking will be reimbursed at cost. However, if the traveler is parking for multiple dates, remote, extended or long-term parking must be used. If it is not, only the cost of remote, extended or long-term parking will be reimbursed.
6. Spouse/Guest Travel- Reimbursement for spouse/guest travel must be in response to a clear and appropriate business requirement and must be pre-approved by the COO, Managing Partner or Controller. In the absence of a significant, specific client entertainment event, spouse/guest travel will not be reimbursed. Spouse/guest participation in the following situations shall be accepted with preapproval: travel to respond to client invitations that specifically include spouse/guest attendance or travel in connection with entertainment of clients where the inclusion of the traveler’s guest is essential to the success of the event and facilitates development of business relationships.

9. Cellular Phone Charges

Exempt (salaried) employees and partners will be reimbursed a maximum of $40.00 per month

for data charges. Itemized cellular phone bills are required with expense report and will be closely audited. Cellular phone bills do not have to be originals.

Reimbursement up to $20 per day will be provided for taxis home for staff that work 10 hours or more in a day and leave the office after dark (~7PM) or work 4 hours or more on a Saturday or Sunday. Reimbursement for overtime meals must be approved by the COO or Controller. Receipts are required.

11. Private Club Memberships

Clubs and memberships are not a reimbursable item.

12. Personal Losses

Personal losses while on Company business are not reimbursable.

13. Gifts and Flowers

Gifts and flowers are a budgeted item and are subject to budget limitations. Any gifts/flowers/cards/etc. to be paid for by the firm should be approved by the Office Administrator and will be consistent within Firm wide budgets for these items. This approval should be attached to the expense report submitted.

14. Marketing Sponsorships

Marketing sponsorships are budgeted. If a sponsorship is desired, approval from the Managing Partner, COO and/or Controller should be obtained. The nature and business reason of the sponsorship should be noted and the approval should be attached to the expense report submitted. If an individual wishes for the firm to pay for sponsorship directly, a check request should be completed.

15. Recruiting Efforts

Reimbursement for recruiting efforts such as meals, job posting costs, etc. will be reimbursed. These costs are budgeted, therefore should not be excessive. All efforts should be made to keep costs to a minimum. If the individual would prefer that the firm pay the cost directly, a check request should be completed. Reimbursement to candidates for flight, lodging, etc. should be pre-approved by the COO. All approvals and receipts should be attached to the expense report submitted.

16. Contributions to Charities

Contributions to charities are budgeted. If a contribution is desired, approval from the Managing Partner, COO and/or Controller should be obtained. The nature and business reason for the contribution should be noted. If individual wishes the firm to pay for the contribution directly, a check request should be completed. All support documents obtained for the contribution should be provided to the Controller for tax return purposes. All approvals and receipts should be attached to the expense report submitted.

17. Bar and Other Professional Associations

The Firm will pay an attorney’s state license related dues and the dues for one (1) local or national bar association of his/her choice, provided the associate indicates a desire to join the

local bar association and a willingness to participate in its affairs. Requests to pay additional association dues must be approved by the COO and this approval should be attached to the expense report submitted. Invoices for such associations should be submitted directly to the Accounting Clerk for payment. If the attorney pays for the dues themselves, an expense report should be completed and submitted.

1. 18. Seminars/Conferences

Registration fees and travel costs for pre-approved seminars/conferences will be reimbursed. Attendance to such seminar/conference should be pre-approved by the Managing Partner or COO. Attorneys should submit a pre-approved request setting forth the business reason for the conference and an estimated budget. It is also preferred that the conference includes a speaking engagement or firm advertisement opportunity. Attorneys should not attend more than one (1) seminar/conference per annual period unless approved by the Managing Partner or COO. Business purpose must be proven for any seminar/conference attended. Approvals and receipts should be attached to the expense report submitted.

1. 19. Partner Accountant Reimbursement

The firm will reimburse each partner up to $1,000 for the preparation of their personal annual tax returns and quarterly estimates. Under this policy, however, a partner will only be reimbursed up to the established amount of $1,000. For example, if the accountant selected by a partner charges $1,200, the partner will only be reimbursed $1,000.

1. 20. Reimbursements on Behalf of Other Personnel

Firm Personnel should pay for individual expenses incurred wherever possible. If the expense is excessive, it is permitted for a name partner to incur a firm or client related expense on behalf of another attorney.

1. 21. Non-Reimbursable Expenses

The following are not reimbursable. The exception to these items being reimbursable is if it pertains to client entertainment which should be noted on the expense report.

• airline club fees
• alcohol
• credit card interest and late payment service charges, unless foreign exchange costs for international travel related to a client
• day-care for children or pets
• extra and overweight baggage fees after first bag
• fees for upgrades of air, hotel, or auto
• golfing/green fees/cart rental
• grooming, nail or spa/hair salon expenses
• headphones on airlines
• health club fees
• massage
• medicines
• movies (either in-room, in-flight, or at the theater)
• personal bar bills
• personal books, magazines or other entertainment
• personal travel portion during business trip
• pet hotel stays or pet transportation
• political or charitable contributions, unless otherwise approved by Managing Partner or COO
• professional attire
• sporting events
• toiletries
• theater, cinema or opera tickets
• tobacco and tobacco related items
• travel and flight insurance

22. Expense Reports and Approval Requirements

1. Preparation- Firm personnel requesting reimbursement are responsible for the preparation and submission of reports covering expenses. The firm expense report template should be utilized at all times for firm related expenses and the client expense report template should be utilized at all times for client related expenses (DM #583862). Expense items should be itemized separately wherever possible. For example, travel meals charged to the traveler’s hotel bill must be broken out separately on the expense report. All expenses must be supported by actual original receipts or supporting documentation as required by the IRS. This applies to all expenditures whether paid in cash or credit card. A credit card statement alone does not provide sufficient documentation in support of the expense. Itemized receipts are required where applicable (typically meals and hotel). Failure to provide such will result in denial of reimbursement. Meals of less than $5.00 value do not require a receipt. The firm does not offer a per diem rate. The individual may choose to have their legal assistant prepare the expense report for them; however, they must still approve the expense report indicated by their signature on the form. Loose receipts should be taped to a full piece of plain paper and any necessary documentation should be noted next to the receipt (attendees, etc.). For all meals, the individuals attending the meal should be noted on the expense report and/or receipt. For any business development travel or entertainment, the company and individual visited and entertained should be noted on the expense report and/or receipt.
2. Submission of Expenses- Expense reports should be submitted to the Accounting Department by 5PM on Thursday for payment no later than the following Wednesday. If expense reports are received after this time or require further documentation or clarification by the submitter, they will not be processed until the next check run. Expense reports are required to be submitted within six (6) weeks of incurring the expense. The firm will strictly enforce a no reimbursement policy for any expense items submitted more than six (6) weeks after the expense was incurred. Attorneys submitting expense reports or legal assistants on behalf of attorneys will ensure the completed expense report with documentation is scanned appropriately into the DM system at the time of submission and indicate the document number on the report.
3. Approval of Expense reports- The Accounting Department will review and approve all expense reports. All non-billable expense reports (firm expenses) will be reviewed by the Accounting Clerk and approved by the Controller prior to check signing. All client related expense reports will be reviewed and approved by the Accounting Clerk and approved by the Controller via check signature (under $10K). Checks over $10K are signed by a name partner. Individuals will be notified via email if any expenses will not be reimbursed. If errors are noted within the expense report, it will be returned to the preparer for correction. The preparer is responsible for necessary edits and timely resubmission.

REIMBURSEMENT CHART

EXPENSE CLIENT	INVOICES	MILEAGE/	TRAVEL AIR/	MEALS (W/TRAVEL ONLY)	COPIES	LEGAL RESEARCH
		PARKING	HOTEL
AIG	Over $500 submit to client	No mileage ever >100 round trip parking, tolls ok	Economy/Coach-Complimentary upgrades or if only seat available must be indicated on receipt No mini-bar charges; (Time billed at 100%)	When travel >50. Receipts absolutely must be itemized. No meals/refreshments during meetings. depositions etc.	.8/pp	>5 hours per ATLP timeframe authorization required
Allied World	Over $2500 submit to client	IRS rate; No travel between home& office Must include # of miles	Economy/Coach; Reasonable accommodations (Time billed at 50%)	Reasonably priced	Not reimb.	>2 hours authorization required
American Modern Insurance		>25 miles IRS rate (Local travel time at 50%)	Economy/Coach Reasonably priced No minibar charges Preapproval for all travel >2 hours	Reasonably priced At least 1 hour from office No bar tabs	.10/pp	>2 hours
Arch Insurance Group	Over $500 submit to client	>50 miles roundtrip Note destination, Googlemaps is helpful Parking>50 miles	Economy/Coach No mini bar charges Approver name and date of authorization for all long distance travel must be included in entry (Time billed at 100% for long-distance driving; Time billed at 50% for flying, train etc. If work performed during local or long distance travel, bill at 100%) Note mode of transport and destination in entry. Need copies of actual ticket	Must be itemized $25/Breakfast; $35/lunch; $50 dinner (per person) No alcohol	.08/pp b&w; .25/pp color	>3 hours authorization required
Endurance	Over $1000 submit to client All expenses over $5000 require approval	IRS rate No mention of a minimum, parking or tolls	Coach/Economy, except when; Moderate accommodations No mini-bar charges; (Time billed at 100%) Preapproval of all travel expenses must be documented with bill	Only in connection with overnight travel; $100/day maximum	.10/pp	>3 hours authorization required Associates only Name of person who approved must be included in each entry.
Global Indemnity	No specific guidelines	Only >90 miles	Yes “reasonable accommodations” (no mini-bar charges)	Yes	.15/pp	Auth req’d >2 hours; no Lexis/Westlaw w/o authorization
Mitsui	Firm pays all third party vendors	No specific guidelines provided	No specific guidelines provided	No specific guidelines provided	No specific guidelines provided	No specific guidelines provided
Markel	Over $500 submit to client	>25 miles Parking, tolls ok >25	Economy/Coach Reasonable accommodations No mini-bar charges (Time billed at 50%)	No alcohol; $75 maximum	.10/pp .25/color	>10 hours authorization required