Effective Date – July 2nd 2020

  1. Purpose

    This policy establishes a policy for the incurrence and reimbursement of expenses by employees during the conduct of company business.

  2. Responsibility

    Employees incurring expenses

    The Company expects its employees to use appropriate and reasonable judgment when incurring expenditures necessary to conduct the Company’s business. The employee has every right to expect fairness from the Company in its decisions regarding reimbursement. Employees are expected to obtain approval from Budget Managers prior to the incurrence of expenditures in a manner consistent with their responsibilities to conduct Company business. The employee is responsible for making sure that authorization for the expenditure has been approved prior to incurrence.

    Employees should familiarize themselves with the items listed as reimbursable and non-reimbursable in section eight below. This list is provided as guidance and is not all encompassing. The determination as to the legitimacy of the expense will sit with the employee’s direct manager and Accounts Payable. Any expense that does not have a legitimate business need or is not conducive to furthering Company business will be rejected and will not be reimbursed without the Accounting Director’s approval.

    The company guidelines in this document are enforced by Collibra’s Accounts Payable team during final review of the expense report. Accounts Payable will use discretion as to the legitimate business need of the expense and may reject questionable expenses. At the employee’s discretion, rejected expenses that they feel are appropriate can be raised for review to the Accounting Director. If rejected by the Accounting Director and the employee still feels that the expenses are legitimate to the furthering of Collibra business, the employee may raise them for review by the CFO.

    Employees will be reimbursed for legitimate business expenses for which the employee has submitted via a valid expense report. It is the employee’s responsibility to create a complete and accurate expense report prior to submission for approval and payment. Incomplete reports will be returned to the employee causing delay in reimbursement.

    Each employee is responsible for submitting expense reports on a timely basis. The timeline for expense report submission is no later than 30 days of incurring the expense.

    Expenses submitted 30 days after the expense date may be routed to the direct manager, manager’s manager, Accounts Payable, and may be routed to the Accounting Director and/or the CFO for approval prior to payment.

    Personnel approving expense reports

    Managers or their delegates are responsible for the review and approval of expense reports submitted by each employee. The approver is to make certain that the submitted expenses were normal and necessary for the conduct of the Company’s business and that the employee is exercising reasonable judgment in incurring such expenses. The approver is also to make certain that the expenses submitted for reimbursement are commensurate with the employee’s responsibilities and within the bounds of the employee’s authority.

    Personnel responsible for approving expense reports will also:

    • Ensure that the reports are complete, accurate, and within the limits of company guidelines as indicated in the this policy.
    • Return, in a timely manner, incomplete or insufficiently documented expense reports to the employee.
  3. Policy

    1. Travel Need

      Managers and employees must use judgment as to the legitimate business need for travel by their direct reports. Managers should weigh whether the business requirements could be met by non-travel options, i.e. teleconference, in lieu of incurring travel related expenses.

    2. Trip Length

      Trip length should be as short as reasonably possible to complete the business required for the trip. Generally trips should be kept to a maximum of six calendar days, i.e. Sunday to Friday.

      Flying in early before the workweek or extending the trip after the workweek is not payable nor reimbursable by the Company without legitimate business need. Costs associated with trips that include a weekend stay without a legitimate business need are payable by the employee e.g. lodging, meal, ground transport costs associated with a weekend stay before or after the workweek.

    3. Reservations: use of company-designated travel agency and systems

      All reservations for commercial transportation, hotel accommodations, and auto rentals must be placed through the Company’s designated corporate travel agency.

      For all Collibra employee travelers, the Company’s travel agency is TripActions. Use of an agency other than TripActions for business travel bookings is not allowed without Head of Business Operations approval.

    4. Form of payment

      All air travel will be purchased by the employee through a central billing method via the Company’s travel agency. See section 3.6 for lodging information.

      Any expenses incurred during the course of business travel, employee or customer entertainment are payable by the employee with an itemized receipt, a legitimate business need, and following the limits outlined in this policy.

      1. Receipt Requirements for Reimbursement

        Itemized receipts for all personally paid expenditures are required for reimbursement based on the following requirements as set by the local tax authorities:

        • US Based Employees: Receipts required over USD75
        • Australia Based Employees: Receipts required over AUD82.50
        • Employees in the Rest of World: All receipts required regardless of amount.

        In rare cases where the receipt has been damaged or lost, a credit card statement containing a record of the charge may be used.

    5. Air Transportation

      Collibra maintains negotiated pricing with certain airlines. These rates are loaded and visible in the Company’s corporate travel tool. Employees should book tickets on these airlines when practical.

      1. Advanced Booking

        Employees are required to book airfare as far in advance as possible. The Company’s preferred advance booking window is 14+ days prior to the date of departure. Any booking within 14 days of the date of travel will be sent to the employee’s manager for oversight and cancelation at the manager’s discretion.

      2. Class of Service, Fare Guidance, Low Fare Policy, and Trip Approval
        Class of Service

        Collibra’s class of service for flights is Economy/Coach for all flight segments, regardless of duration.

        For Domestic US, Intra-Europe, or Regional flights, seats with more legroom (e.g. Economy Plus, Comfort +, or similar) if available for under $25/€25/Zl.100 per seat may be booked.

        For international flights with a single leg over 5 hours, economy seats with more legroom may be booked. Some examples of the seats with more legroom are KLM Economy Comfort, United Economy Plus, Delta Comfort +, American Airlines Main Cabin Extra, etc. Premium Economy is outside of policy.

        Non-coach class airfare may be booked for a medical issue that a flight in coach would aggravate/compound or if there is a legitimate business need. Budgetary compliance must still be observed.

        Any fees associated with an upgrade to a different class of service after the airfare is booked are not reimbursable.

        Fare Guidance

        The cost for US Domestic and Intra-Europe flights should be limited to EUR 450, USD 500, GBP 400, AUD 700 or other local equivalent when practical.

        International flights should be kept below EUR 1,300, USD 1,500, GBP 1,200, AUD 2,000 or other local equivalent when practical.

        Trip Approval

        Collibra does not require pre-trip approval for items booked through our corporate travel agency. Employee managers are copied on the bookings created by their direct reports and may reject the trip at their discretion within 24 hours after booking.

      3. Personal/Business travel combined

        Any personal travel arrangements that are planned before or after the Collibra business portion of a trip must be arranged separately, with the cost and arrangements being the responsibility of the traveler. Any expenses related to non-Collibra personnel traveling with an Collibra employee are not payable nor reimbursable by the Company unless it is covered as part of a relocation package.

        When personal travel is combined with business travel, the employee must pay the difference between the most economical fare for the business portion of the trip and the total amount of the fare. This amount is to be determined on the date ticketed. The Company’s travel agency or online system cannot be used for personal travel.

        The employee is solely responsible for all costs associated with the personal travel portion of the trip including but not limited to meals, lodging, ground transportation, and any expenses associated with the person the employee may be traveling with.

      4. Frequent Flyer Programs

        Employees may accrue miles from business travel in their personal frequent flyer accounts provided that flight selection is not based on the following:

        The fare is not selected based on the accumulation of a reward program

        Flights without a business reason are not scheduled to accumulate miles in a reward program Unnecessary or inconvenient plane changes are planned to accumulate segments in a reward program Company time and resources are not used to administer a reward program

      5. Airline Clubs and Known Traveler Programs

        The Company does not reimburse employees for memberships in airline clubs or programs to expedite security screening.

      6. Private Planes

        Employees are not authorized to hire private planes nor pilot themselves or Collibra employees on company business.

    6. Lodging

      Employees will utilize lodging located within a reasonable distance of the traveler’s work assignment and corporate rate hotels when available. The Company’s designated corporate travel tool maintains a list of properties where negotiated rates provide a discount to customary “rack” rates. Booking of these negotiated rate hotels is the Company’s preference.

      Generally, hotels should be kept to under €220, $250, £193, Zl.943, AUD350 per night.

      Collibra maintains a corporate apartment in New York. Employees are encouraged to utilize this lodging arrangement when practical and should contact the Workplace Experience team in the destination office for availability.

    7. Laundry

      Reasonable laundry or dry cleaning will be reimbursed for business trips over six calendar days.

    8. Ground Transportation

      1. The method of ground transportation is up the employee’s discretion. Collibra prefers alternative forms of ground transportation for environmental and cost reasons. Lyft, Uber, taxi, train, subway, bus, etc. should be considered and are fully reimbursable when tied to a legitimate business, non- commute trip.
      2. Rental Cars

        When required, Collibra’s class of rental car is economy/compact only. No mileage reimbursement is allowed on rental cars. The employee can claim reimbursement for the cost of the rental and refueling the rental car. Employees should refuel automobiles to the proper level before returning the car to avoid higher fuel costs.

        1. Rental Car Insurance

          You are required to purchase the supplemental auto insurance offered by rental car agencies at time of car pick up. This fees are reimbursable if paid personally.

        If you have an accident in a rental car, obtain a police report, contact the rental car agency, and Collibra’s Accounting department.

      3. Personal Cars

        Payment for the use of a personal car for business will be reimbursed at the standard rate allowed by the local tax authorities except for those receiving a car allowance. Other reimbursable fees for all trips include tolls and parking fees.

        As for Airport Parking, if other options to and from the airport are not feasible or cost effective (e.g. taxi or airport shuttle), reasonable long-term airport parking fees will be reimbursed.

        Any violation of local traffic laws, including parking fines, resulting in a penalty or fee are the responsibility of the employee and are prohibited from reimbursement.

        For personal vehicle use reimbursement rates, please refer to this document.

        Note – this amount is only applicable to the distance traveled above and beyond an employee’s standard commute to the office. (e.g. standard commute to your local office is 20 miles/km and you are driving to the airport for business which is 30 miles/km away from your home. You would be eligible for 10 miles/km each way for reimbursement. Employees working from home would be eligible for 100% of the commute to the airport).

      4. Train Travel

        The company’s class of service for train travel is second class or lower. First class train tickets may be booked if the cost of a First Class ticket is within €50 of a second class ticket.

    9. Meals While Traveling, Per Diem, and Employee Entertainment

      Meals While Traveling:

      Meals should be reasonable for the region and time of day. The chart below shows the limits per meal. If the currency of the expense is not listed, please use the local currency equivalent.

      Location Breakfast Lunch Dinner Drinks/Coffee
      Americas $15 $30 $60 $15
      Australia AUD22 AUD43 AUD85 AUD22
      Belgium €15 €30 €50 €10
      Czech Republic Czk.380 Czk.770 Czk.1300 Czk.3250
      Poland Zl. 40 Zl. 50 Zl. 75 Zl. 30
      UK £15 £30 £50 £10

      If multiple employees are present, the most senior employee is required to pay for and expense the meal. The daily limits listed above remain in effect.

      Per Diem:

      Employees of Collibra Polska will receive a per diem. The amount is different for each destination county and covers 24 hours. During this time all the expenses for food and drinks are on the account of the employee. Per diem includes breakfast (15%), lunch (30), dinner (30%), and others (25%). If Collibra provides/pays for any of the meal during the day, the employee is not entitled to this portion of the per diem. the number of days is based on the departure and arrival date and time. Up to 8 hours the employee received 1/3 of per diem, from 8 hours to 12 hours – 50% per diem, over 12 hours – the full amount.

      Employee Entertainment:

      Entertainment of employees by other employees must be kept to a minimum. Meals while not on business travel generally cannot be expensed unless there is a legitimate business need.

      Team building exercises, off-sites, etc., must have an approved Purchase Order (PO) and Legal review of the agreement prior to engaging in the event and prior to payment/reimbursement.

      The most senior employee in attendance is required to pay for and expense the item. All charges for employee entertainment are to be fully explained on the employee’s expense report as to business purpose, amount, names of the employees in attendance, and accompanied by a fully itemized receipt.

      Employee entertainment over €50, USD60, £50, Zl75, AUD 70 or other local equivalent per person may be rejected.

      1. Tips

        Tipping of personnel in certain venues (bar, restaurants, hotel cleaning staff, etc.) is allowed and will reimbursed by Collibra but should be in line with local/national customs and standards and based on the perceived quality of service by the venue/staff. Tips should be no more than 20% of the bill less tax and cash tips are discouraged. Properly itemized receipts are required for reimbursement.

  4. Customer/Prospect Entertainment

    Entertainment of customers or prospects must be limited to locations conducive to furthering company business and reasonable in scope and cost. It is the employee’s responsibility to inform their manager about any customer/prospect entertainment or gifts prior to providing them.

    The name of the person(s) and company entertained, Company employee’s present, cost, business purpose, and venue, as well as a fully itemized receipt must be included on the expense report.

    The most senior employee in attendance is required to pay for and expense the item.

    The Company’s general guidance for customer/prospect entertainment is per person EUR 100, USD 125, GBP 100, Zl 380, AUD 150 or other local equivalent. Situations resulting in expenses exceeding these amounts will be reviewed on a case by case basis.

  5. Donations and Gifts

    Gifts or incentive awards to employees are not allowed without written pre-approval from the Chief People Officer and Payroll. Any gift with a value of over EUR 250, USD 250, GBP 250, Zl 1,000, AUD 250 or local equivalent must be pre-approved by the CFO in writing. Evidence of this pre- approval must be attached to the expense report or it will be rejected. All approved gifts or incentive awards will be taxed as income to the employee receiving them.

    Political contributions and donations are expressly prohibited as well as any payments which would be a violation of the Foreign Corrupt Practices Act (FCPA), the UK Bribery Act and OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions.

  6. Mobile Phone & Internet

    Mobile Phone

    At the discretion of the employee’s direct manager reasonable charges for legitimate business use of a personal mobile phone during the course of international travel may be reimbursed if over the monthly stipend.

    Internet while Traveling

    Paid internet use while traveling may be approved for reimbursement at the discretion of the employee’s direct manager.

  7. Exceptions

    Should a deviation from this policy be made, the supporting documents attached to the expense report must include a full explanation of the expenditure with approval of the Accounting Director.

    A violation of any portion of this Policy may result in disciplinary action, up to and including termination of employment and/or legal action.

  8. Reimbursable and Non-Reimbursable Items

    While not all inclusive, this list contains guidance for items that are reimbursable or not reimbursable. Legitimate business need will be the driving factor in determining validity for reimbursement.

    Reimbursable Non-Reimbursable
    Airfare, hotel, ground transportation, assuming pre-trip approval TSA or expedited security screening fees
    Parking when on company business In-flight sky entertainment or phones
    Mileage for use of a personal vehicle for business purposes less any mileage incurred during a daily commute to the office Loss of personal items while traveling for business
    Reasonable laundry or dry cleaning for business trips over six days Airport/Airline club memberships or passes
    Reasonable gratuities Loss of cash, traveler’s checks, or credit cards
    Hotel and in-air wifi Traffic or parking fines
    Visas or vaccinations required for traveling Personal entertainment e.g. in-flight movies, in room movies, sightseeing tours, etc.
    Reasonable expenses for flowers for bereavement, a serious medical condition, or new baby gifts Passport charges/fees, including renewals or application
    Reasonable airline luggage fees Any personal trip expenses, including meals, ground transport, airfare, entertainment, etc. and/or expenses for non-Collibra employees traveling with a Collibra employee
    Meals for employees if not part of employee travel or part of accompany sponsored event e.g. a group of employees go out to lunch
    Baby-sitting, child-sitting, pet-sitting, or nanny services as part of or due to a business trip
    Personal items: Supplements (vitamins, sleeping pills, etc.) toiletries, luggage, clothing, etc.
  9. Approval & Revision History

    Date Approval Purpose
    17 Jul 2019 Matt Moore Updating corporate agency to TripActions and updated approval process