Travel and Business

Expense Policy

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Table of Contents
1.0 INTRODUCTION.......................................................................................................................... 4
1.1 Objectives...................................................................................................................................... 4
1.2 Responsibility................................................................................................................................. 4
2.0 DEFINITIONS.............................................................................................................................. 5
2.1 Ordinary Business Expense ............................................................................................................ 5
2.2 Necessary Business Expense ......................................................................................................... 5
2.3 Reasonable Business Expense ....................................................................................................... 5
2.4 Entertainment Expense .................................................................................................................. 5
3.0 GENERAL POLICY GUIDELINES ............................................................................................. 6
3.1 Business Purpose Disclosure .......................................................................................................... 6
3.2 Expense Reports ............................................................................................................................ 6
3.3 Corporate Credit Cards .................................................................................................................. 6
3.4 Receipts ......................................................................................................................................... 6
3.5 Travel Advances ............................................................................................................................ 7
3.6 Incorrect or Incomplete Expense Reports ...................................................................................... 7
4.0 AIR TRAVEL REIMBURSEMENT POLICY ............................................................................. 7
4.1 Class of Travel ............................................................................................................................... 7
4.2 Frequent Flier Credits .................................................................................................................... 8
4.3 Personal Travel .............................................................................................................................. 8
4.4 Cancellation / Unused / Voided / Free Airline Tickets..................................................................... 8
4.5 Baggage Fees ................................................................................................................................ 9
4.6 Lost or Damaged Baggage............................................................................................................. 9
4.7 Changes to Reservations ............................................................................................................... 9
5.0 RAIL TRAVEL REIMBURSEMENT POLICY ........................................................................... 9
6.0 LODGING ..................................................................................................................................... 9
6.1 Class of Service / Receipts ............................................................................................................. 9
6.2 Direct Billings ............................................................................................................................... 10
6.3 Personal Items............................................................................................................................. 10
6.4 In-Room Meals ............................................................................................................................ 10
6.5 Hotel Cancellation Procedures ..................................................................................................... 10
6.6 Property Insurance Claim ............................................................................................................ 10
7.0 GROUND TRANSPORTATION ................................................................................................ 11
7.1 Rental Cars .................................................................................................................................. 11
7.2 Notification of Accidents .............................................................................................................. 11
7.3 Use of Cellular Phones ................................................................................................................. 11
7.4 Miscellaneous Ground Transportation .......................................................................................... 11
7.5 Personal Vehicles ......................................................................................................................... 12
8.0 MISCELLANEOUS TRAVEL COSTS ....................................................................................... 12
8.1 Tips ............................................................................................................................................. 12
8.2 Laundry and Valet Services .......................................................................................................... 12
8.3 Gifts in Lieu of Hotel .................................................................................................................... 12
8.4 Passports, Visas, and Medical Immunizations .............................................................................. 12
8.5 Internet Purchases ...................................................................................................................... 12
8.6 Communication Costs .................................................................................................................. 13

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9.0 Spouse, Domestic Partner, Family Member or Guest Travel ....................................... 13
10.0 MEALS & INCIDENTAL EXPENSES (M&IE) REIMBURSEMENT ................................. 13
11.0 NON-TRAVEL RELATED MEALS AND ENTERTAINMENT EXPENSES........................ 14
11.1 Business Meals........................................................................................................................... 14
11.2 Employee Activities Expense ...................................................................................................... 15
11.3 Entertainment ............................................................................................................................ 15
11.4 Departmental Functions ............................................................................................................. 16
11.5 COMPENSATORY EXPENSES ...................................................................................................... 16
11.6 Gifts ........................................................................................................................................... 16
12.0 OTHER BUSINESS EXPENSES ............................................................................................ 17
12.1 Professional Fees ....................................................................................................................... 17
12.2 Conferences and Seminars ........................................................................................................ 17
13.0 NON-REIMBURSABLE EXPENSES...................................................................................... 17
14.0 RESPONSIBILITIES ............................................................................................................... 18
14.1 Responsibility of Requester ........................................................................................................ 18
14.2 Responsibility of Authorized Approver ........................................................................................ 18
15.0 AUTHORIZATION ................................................................................................................... 18
16.0 PAYMENT ................................................................................................................................ 19

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1.0 INTRODUCTION
Business travel and discretionary business expenditures are an essential element of
doing business at Waséyabek Federal Services, LLC (WFS) and also some of its largest
controllable expenses. The following policy is intended to provide the employees of
WFS a guideline for business travel and miscellaneous expense reimbursement. This
policy establishes the minimum requirements and supersedes all previous Travel and
Business Expense Reimbursement policies.

While the policy is intended to be comprehensive, it is impossible to anticipate

every situation encountered by travelers. The intent is that these guidelines will
ensure compliance with good business practice and Federal Acquisition Regulations
(FAR) including any applicable agency supplements, Federal Travel Regulations (FTR),
Joint Travel Regulations (JTR), and Internal Revenue Service (IRS) regulations while
providing essential customer service to our clients. WFS expects employees to use
good judgment in committing WFS funds. Travelers should expect to receive service
and accommodations that are both safe and comfortable, but not lavish or
extravagant. Individuals should neither gain nor lose personal funds as a result of
official travel.

WFS will reimburse the ordinary, necessary and reasonable business expenses incurred
by employees who have been authorized to incur such expenses in the transaction
of WFS business. Subject to the provisions of this policy, reimbursements will be
made promptly after expenses have been:
• Itemized by amount on a properly prepared expense report;
• Substantiated properly by attaching original receipts for expenses requiring
receipts; and
• Approved by the appropriate company official.

1.1 Objectives
• To ensure all employees have a clear and consistent understanding of policies
and procedures for business travel, entertainment and miscellaneous business
expenditures.
• To provide business travelers with a reasonable level of service and comfort at
the lowest possible cost while complying with FAR, FTR, JTR, IRS regulations,
and contractual requirements, as applicable.

1.2 Responsibility
The traveler is responsible for complying with this travel and expense policy,
submitting timely requests for travel authorization, submitting timely travel expense
reports, and providing all required documentation and receipts as outlined in this
policy.

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The expense report approver is responsible for ensuring the travel objective was met;
submitted expenses comply with the travel and expense policy; and required receipts,
approved by travel authorizations, and/or excess cost justificati ons are submitted.

WFS will not reimburse employees for expenses that are not in compliance with this
policy. Employees who do not comply with this travel and expense policy may be
subject to withholding of reimbursement and/or disciplinary action, up to and including,
termination.

2.0 DEFINITIONS

2.1 Ordinary Business Expense

Ordinary business expenses are those expenses which are customary or usual to a
business community.

2.2 Necessary Business Expense

Necessary business expenses are those expenses which are appropriate and helpful
for the development of WFS's business.

2.3 Reasonable Business Expense

Reasonable business expenses are those expenses that allow the employee to conduct
business in comfort and without extravagance. A reasonable cost is defined in the FAR
as a cost if, in its nature and amount, does not exceed that which would be incurred
by a prudent person in the conduct of competitive business. Consequently, this policy
will be interpreted on a conservative basis.

2.4 Entertainment Expense

Entertainment is defined as expenses incurred to promote business through the
entertainment of customers and other non-WFS business employees at places such as
restaurants, theaters and sporting events, at which, or immediately before or after
the event, a business discussion takes place.
• Federal: Alcohol is not allowed nor billable to government contracts.
• WFS Employees and Board Members: Alcohol is not an allowable expense,
unless a special circumstance is approved by the CEO.
• WFS Employees and Commercial Clients and Customers: Nominal alcohol
charges may be reimbursable by the company provided the expenses are not lavish
or extravagant.

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3.0 GENERAL POLICY GUIDELINES

3.1 Business Purpose Disclosure

The business purpose of expenditures must be disclosed on the expense report form in
sufficient detail as to make clear that the expense incurred had a WFS business
purpose. In the absence of a clear business purpose disclosure, the IRS could take a
position that reimbursement is for expenses which are of a personal nature, and
therefore, tax deductible for WFS only if the W-2 earnings of the employee included the
amount reimbursed by WFS.

3.2 Expense Reports

Expense reports should be filed as soon as possible after completing a trip or incurring
a business-related expense, but not later than 3 days after the end of the calendar
month.

3.3 Corporate Credit Cards

Employees who are authorized to utilize a Corporate Credit Card are reminded that use
of a Corporate Credit Card is a privilege not a right, and as such, abuse in the use of
the Corporate Credit Card will result in revocation of the card, and may result in
disciplinary action, including possible termination of employment. Employees using
corporate credit cards are required to submit a properly completed expense report,
supported by original receipts that meet the requirements of this policy. Attaching
receipts to the monthly credit card statements is not adequate. Cash advances on the
Corporate Credit Card are not permitted.

3.4 Receipts
All expenditures must be supported by an original receipt noting proof of payment and
that the goods and/or services have been received. Specific documentation
requirements are detailed in the various sections of this policy.

• Advance Purchase - Payment for goods/services that will be received at a future

date (such as air travel, registration for a training seminar, etc.) will be recorded as
an expense advance to the employee. This includes payments made by a corporate
credit card, personal credit card or reservations made through the company travel
agency. It is the traveler's responsibility to make note when the goods/services have
been received (see notations on the expense reimbursement and other
documentation required under other sections of this policy), so that accounting can
record the expense appropriately. It is also the employee’s responsibility to
cancel/transfer/reschedule such arrangements if the goods/services purchased will
not be used as intended.

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• Lost Receipt- If a receipt is lost; attach a statement documenting the actual
expense. This statement must be signed by your Supervisor. This practice is
acceptable only on an exception basis.

3.5 Travel Advances

WFS does not routinely issue travel advances. However, if an employee needs a travel
advance due to mitigating circumstances, the request must be made to the accounting
department by the employee's manager. Travel advances, when approved, will be
processed through Accounts Payable. Travel advance checks will be processed in
conjunction with weekly Accounts Payable check runs and require a minimum of one-
week advance notice for processing.

Travel advances will be limited to 75 percent of the total estimated cost of travel. The
travel advance amount must be deducted from the applicable expense report when
filed. Failure to properly account for travel advances on expense reimbursements will
result in disciplinary action including recovery of unauthorized expenses through payroll
deduction and possible termination.

3.6 Incorrect or Incomplete Expense Reports

Incorrect or incomplete expense reports will be returned to the employee for corrective
action and may result in delay or non-reimbursement of specific items.

4.0 AIR TRAVEL REIMBURSEMENT POLICY

Air transportation costs represent a significant portion of a traveler's expense. It is

important that the traveler take reasonable care to reduce these expenditures. When
feasible, non-refundable tickets are to be utilized. Refundable tickets should only be
used when travel is uncertain and must be approved in advance by a supervisor.

4.1 Class of Travel

Travel accommodations for all employees on domestic or international travel are limited
to Coach/Economy class. Coach class is defined as the basic or lowest class of
accommodations available to the company during normal business hours. Tickets will be
purchased in advance as far as possible to take advantage of the lowest fares. Tickets
may be purchased with the corporate credit card or a personal credit card. On-line
booking frequently offers the lowest possible fares and should be used whenever
possible. The following exceptions to class of travel must be approved in advance by
your Supervisor.
• Medical necessity as substantiated by Doctor's certificate; or
• Continuous one leg flight duration that exceeds 8 hours in duration or when travel
time (defined as aircraft boarding at home station; to luggage collection at
temporary duty station) exceeds 14 hours and then only at business, business

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 economy or economy plus rates; or
• Business necessity such as overnight flight followed by early morning meeting
• No-cost mileage upgrades may be used. However, a notation must be submitted
with the expense reimbursement request to indicate that the upgrade is at no cost
to the company.

4.2 Frequent Flier Credits

WFS recognizes the time and effort travelers make on behalf of the organization. The
accumulation of "points" by participating in airline programs is for the employee's
personal benefit. As such, travelers may retain credits through frequent flier programs
when traveling on company business. However, if an employee arranges a more
expensive flight, or an altered travel itinerary to accumulate points or qualify for
immediate upgrade to business or first-class travel, the employee must reimburse WFS
the difference between the booked fare and the lowest available discounted fare if the
ticket was paid with a corporate credit card or booked through the company's travel
agency. If the employee paid for the ticket with their own credit card, then they can
only claim reimbursement for the lowest available discounted fare.

Tickets purchased with frequent flier miles have no intrinsic "cost" and as such an
imputed ticket value is not reimbursable.

4.3 Personal Travel

Transportation which combines business and personal travel must be approved in
advance by your Supervisor. The incremental (leisure) cost of transportation expenses
are personal expenses and are not reimbursable. The employee is expected to pro-rate
business costs / personal costs and submit for company reimbursement, only those
costs associated with WFS business.

4.4 Cancellation / Unused / Voided / Free Airline Tickets

Unused airline tickets or flight coupons must never be discarded or destroyed as these
documents may be used for future trips or returned to the air carrier for a refund. It is
the employee's responsibility to expedite refunds and utilize unused or partially used
airline tickets as soon as possible. Travelers must submit documentation supporting the
unused or partially used airline ticket to receive reimbursement.

When the unused or partially used airline tickets are used for another trip, the traveler
must make notation of such on the expense reimbursement form.

Any charges accumulated due to an employee choosing to delay their flight in order to
receive a free ticket or credit on a future flight from the airline company will not be
reimbursed (e.g., hotel charges, ground transportation, meals, etc.)

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4.5 Baggage Fees
Employees will be reimbursed for baggage costs, as implemented by the airline, for up
to two (2) bags.

4.6 Lost or Damaged Baggage

The ultimate responsibility for retrieving and compensating lost baggage lies with the
airlines. Lost or damaged baggage must be reported to the airlines and a claim filed.
Damages and losses that are not covered by the airline are not reimbursable.

4.7 Changes to Reservations

Fees and/or penalties charged for changing or canceling a reservation are reimbursable
as long as there was a business purpose for the change. The circumstances describing
the business purpose of the change must be documented on the expense report form.

5.0 RAIL TRAVEL REIMBURSEMENT POLICY

Domestic and International rail travel is permitted, provided that it is booked in coach
class. First class (club class) is permitted, if approved in advance by the Supervisor, when
it is:
• Less expensive than the lowest logical fare for the same itinerary
• At the traveler's expense
• Due to medical necessity as substantiated by Doctor's certificate

Confirmed seat reservations, if the ticket is not used, must be canceled in advance to
avoid penalties.

6.0 LODGING

6.1 Class of Service / Receipts

To aid in managing travel costs, travelers are encouraged to stay in locations near their
business/event site to minimize transportation costs (e.g. avoiding the need for rental
car). The accommodations should be made in a business class hotel such as Hilton,
Marriott Courtyard or equivalent. If a rental car is authorized, the traveler should
determine if suitable accommodations are within a reasonable driving distance to the
business/event site, so as to avoid excessive costs of staying at downtown properties
(i.e. overnight parking often is more expensive that the daily cost of the rental car).
Luxury class hotels are not permitted without approval.

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Lodging expenses will be reimbursed when an original hotel folio is attached to the
expense report. Employees should use accommodations that are reasonably
priced considering the location and the purpose of the business trip. Lodging receipts
should include the following:
• Name and location of the facility
• Dates of stay
• Itemized listing of charges
• Proof of payment

6.2 Direct Billings

Direct billings for lodging and meeting rooms are acceptable for group meetings,
seminars, etc.; however, the organizer of the function should make it clear with the
hotel, conference center, etc., that incidental items are not to be charged to any
participant's room. Items such as, but not limited to, movies and sundry items
purchased at the gift shop, etc., would be considered incidental.

6.3 Personal Items

Items of a personal nature that are billed to the room, such as in-room movies, snacks,
alcohol, etc. are not reimbursable.

6.4 In-Room Meals

In room meals are reimbursable and must be reported separately; not included in the
lodging charges.

6.5 Hotel Cancellation Procedures

Travelers are responsible for cancelling lodging reservations if your travel plans change.
Failure to cancel a guaranteed lodging reservation could result in a no-show billing for
the reserved room, which is considered a non-reimbursable travel expense unless there
are extenuating circumstances beyond the control of the traveler (for example, a
canceled flight). These circumstances must be documented on the expense report form.

6.6 Property Insurance Claim

An employee's homeowners/renter’s insurance will be the primary carrier in the case of
a personal property insurance claim (e.g. property stolen from a hotel room) when
traveling on business for WFS. Local authorities should be contacted immediately upon
noticing the damaged or stolen property. Also notify your supervisor.

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7.0 GROUND TRANSPORTATION

7.1 Rental Cars

Rental cars should be used at the destination only when absolutely necessary (e.g.
when less expensive than taxi or shuttle service). Travelers are to use the most
economical vehicle-class appropriate for the number of people, geographic area, and
safety. WFS will reimburse the cost of rental cars up to a full-size vehicle. Under no
circumstances is a luxury vehicle authorized.

Fuel tanks should be refilled prior to returning rental cars to avoid inflated refueling
charges. The pre-paid refueling option may be selected if it is anticipated that the fuel
tank would be near empty when the rental car is returned.

When renting a vehicle in the United States, rental optional insurance (CDW) should be
declined as the corporate insurance policy covers for the losses associated with car
rental.

When renting international vehicles, local compulsory rental insurance should be

purchased at the time of rental.

The original rental agreement along with proof of payment and any associated gasoline
receipts must be submitted with the expense report, along with an explanation
documenting the need for the rented vehicle.

7.2 Notification of Accidents

If you are involved in an accident while operating a rental car on business travel, follow
the procedures identified in the rental agreement. At a minimum, immediately notify the
local police, the car rental agency representative, and your Supervisor.

7.3 Use of Cellular Phones

It is the responsibility of the driver to know the rules of the state in which you are
driving in regard to the use of cellular devices. At a minimum, WFS prohibits the use of
hand-held cellular phones while driving a rental car. If necessary, use a hands-free
device or park the car until the phone call is completed.

7.4 Miscellaneous Ground Transportation

The most economical mode of transportation should be used to and from airports and
bus and rail terminals. Public transportation, airport shuttles or taxis should be used
whenever possible. Employees traveling to the same location should attempt to share
ground transportation to and from the airport whenever possible.

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Taxis, tolls, parking, etc. all require original receipts. If the original receipt is not
available for tolls due to use of electronic pass, submit electronic receipt.

7.5 Personal Vehicles

Employees who voluntarily choose to drive their own vehicle instead of flying must
show that it is more economical to WFS to do so. Employees will receive mileage
reimbursement at the current JTR/FTR published mileage rate per mile.

WFS requires that any employee that uses their personal vehicle for company business
carry their own auto insurance coverage. The employee's insurance policy serves at the
"primary" policy for third party liability and physical damage to your vehicle. WFS's
insurance policy will cover claims in excess of your policy.

The employee is responsible for any deductible amounts under their policy. WFS will not
pay for any physical damage to an employee's vehicle.

Mileage for traveling from an individual's home to principal work location or return is a
non-reimbursable commuting expense. The principal work location is defined as where
the employee spends the majority of the normal workday.

8.0 MISCELLANEOUS TRAVEL COSTS

8.1 Tips
Tips for services such as at hotels, air terminals and taxis will be reimbursed. Tips
should be reasonable but should not exceed 20%.

8.2 Laundry and Valet Services

These expenses are not reimbursable for trips less than three days, except for pressing
clothes and requirements of unusual conditions.

8.3 Gifts in Lieu of Hotel

Meals or gifts that are given to people with whom you stayed (in lieu of a hotel
expense) are limited to a maximum of $25 per night, per individual.

8.4 Passports, Visas, and Medical Immunizations

All costs associated with these items will be reimbursed if incurred for business
purposes.

8.5 Internet Purchases

All reimbursements for internet purchases must be supported by the order confirmation
provided by the internet company.

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8.6 Communication Costs
Travelers will be reimbursed for telephone, fax and computer connections costs that are
reasonable and necessary for conducting WFS business.

A reasonable number of personal telephone calls, generally one call per day that allows
a traveler to stay in contact with their families are reimbursable only if on an overnight
business trip.

9.0 Spouse, Domestic Partner, Family Member or Guest Travel

In general, the expenses of a spouse, domestic partner, family member or other guest
are not reimbursable.

In certain limited instances the expenses for these individuals may be considered a
business expense if the individual has a significant role at a function. Prior supervisory
approval is required, and the business purpose of the attendance must be stated on the
expense report.

Reimbursement of expenses to an employee for an individual who is not an employee

of WFS must be reported as taxable compensation to the employee. The
Reimbursement will be for both the reimbursed expenses and the related taxes.

10.0 MEALS & INCIDENTAL EXPENSES (M&IE)

REIMBURSEMENT

WFS employees traveling on company business will be reimbursed for actual meal
expenses.

The following information is required for all meal expenses:

• Date of the business meal
• Cost, including tip
• Name and location of the restaurant
• Explanation which demonstrates:
o The employee was traveling on behalf of WFS
o The employee was actively conducting WFS business as the main purpose
of the business meal
o That the meal directly preceded or followed a bona fide business
discussion.

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Original credit card receipts and original cash register receipts are the only acceptable
receipts.
• Itemized receipts should include the printed name of the establishment, address,
service date and proof of payment
• Guest check tear-offs are not acceptable as support of documentation.
• Receipts are required for all business meals

11.0 NON-TRAVEL RELATED MEALS AND ENTERTAINMENT

EXPENSES

11.1 Business Meals

For business meals with two or more WFS employees, the highest ranking employee
must pay for the meal.

Business meals include meals taken with non-WFS employees, e.g. suppliers, business
consultants, prospects or clients, during which (or immediately before or after the meal)
a specific business discussion takes place. The meal costs must be reasonable and not
lavish or extravagant.

Business meals/meetings are not allowed to be at any adult entertainment

establishments.

The details of business meals must be documented in the expense report. In general,
local (i.e. non-overnight travel) meals with other employees will not be reimbursed as
the meal was not necessary to the business discussion. However, infrequent meals with
another employee to discuss business matters would be reimbursable if accompanied
by an explanation (in the business purpose section of the expense report) as to why it
was necessary to leave the building and have the discussion during mealtime. Similarly,
infrequent meals with a WFS employee from out of town would be reimbursable if the
necessity of having a business discussion at mealtime was documented.

Meals for spouses/domestic partners are not reimbursable without advanced approval
by your Supervisor.

WFS employees traveling on company business will be reimbursed for actual meal
expenses. Alcohol is unallowable on all government contracts; however, for the
purposes of WFS, non-federal circumstances, nominal alcohol charges may be
reimbursable by the company provided the expenses are not lavish or extravagant and
are approved by the manager. Alcohol charges plus associated tax and tip must be
coded to an unallowable account.

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The following information is required for all business meal expenses:

• Date of the business meal

• Cost, including tip
• Name and location of the restaurant
• Explanation which demonstrates:
o The employee was traveling on behalf of WFS
o The employee was actively conducting WFS business as the main purpose
of the business meal
o That the meal directly preceded or followed a bona fide business
discussion.

Original credit card receipts and original cash register receipts are the only acceptable
receipts.

The receipts must include the printed name of the establishment, address, service date
and proof of payment
• Guest check tear-offs are not acceptable as support of documentation.
• Receipts are required for all business meals

11.2 Employee Activities Expense

Employee activities expenses are expenditures for employee picnics, dances, holiday
parties, service anniversaries, etc. which provide a business benefit in the form of
improved morale and future job performance. The business purpose and a list of
recipients with name and title must be clearly stated on the expense report. Employee
activities expenses are 100% deductible for income tax purposes. These expenditures
should be recorded as Employee Morale.

11.3 Entertainment
Reimbursements to the employee under this Policy will only be made for entertainment
expenses for business purposes (as opposed to entertainment that is of a general social
nature), and for which there is a documented business purpose. The entertainment
should include only those parties whose presence is necessary to facilitate the business
discussion. The business purpose must be recorded on the expense report.

Business meals/meetings/entertainment (with or without a client) are not allowed to be

at any adult entertainment establishment.
An employee must be present during the entertainment, the type of entertainment
must be customary for our trade or business, and the entertainment may not be lavish
or extravagant.

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The Following Information is Required for All Entertainment Expenses:
• Date of entertainment
• Cost, including tip
• Full names, titles and business relationship of all persons attending
• Name and location of place and nature of entertainment
• Explanation which demonstrates that the employee actively conducted company
business as the main purpose of the entertainment or that the entertainment
directly proceeded or followed a bona fide business discussion.

If two or more WFS employees are in attendance, the highest-ranking employee must
pay for the entertainment item.

11.4 Departmental Functions

Certain departmental functions, such as holiday parties, retirement parties, and other
significant departmental gatherings, serve an important business purpose in supporting
morale and encouraging networking amongst colleagues. Expenditures should be
reasonable to the business purpose. Prior approval from the department/division head
or the WFS CEO is required before committing funds for a departmental function.

11.5 COMPENSATORY EXPENSES

Under IRS regulations, there are certain items paid by WFS or reimbursed to an
employee that must be included in an employee's taxable wages (W-2 earnings):

• Spouse, domestic, other partner travel expenses

• Rental of formal attire
• Company Vehicle – personal miles only

Reimbursement of these expenses will be added to the employee's Form W-2.

11.6 Gifts

Business Gifts
Gifts given in conjunction with business should not to exceed $100 per gift per recipient
per year. However, government procurement regulations prohibit any government
official. Accepting a gift with a value over $20, which includes meals and incidentals.
Any attempt to provide a government official with a "gift" exceeding the $20 value will
be considered offering a bribe and should be avoided at all times.

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Employee Gifts
Any individual gift greater than $25 requires prior approval from a company official
authorized to approve expense reports.

12.0 OTHER BUSINESS EXPENSES

12.1 Professional Fees

Professional fees, trade association fees and dues, and/or gifts and publication costs will
be reimbursed with approval of the appropriate supervisor.

12.2 Conferences and Seminars

Registration fees are reimbursable and should be coded as training expenses. Travel
expenses, meals, lodging, etc. are not part of training expenses and are coded under
the appropriate travel expenses.

13.0 NON-REIMBURSABLE EXPENSES

WFS's policy is to reimburse employees for all reasonable and necessary expenses
incurred in transacting company business. Following is a list of expenses (not all­
inclusive) which will not be reimbursed by WFS:

• Babysitting costs
• Chauffeurs
• Commuting costs to and from principal place of employment
• Costs of boarding pets
• Credit card fees, including late payment fees
• Interest on credit card balances
• Items of a personal nature such as shoe shines, haircuts, magazines, other reading
material, tobacco, toiletries, medications, massages, saunas, clothing, travel
insurance premiums, car rental insurance (except as required for ONCONUS travel),
or souvenirs
• Political or charitable contributions
• Repairs, maintenance or insurance on personal cars (except as advised in the
Company Vehicle Policy)
• Sports team sponsorship
• Additional expenses for spouse, domestic partner, family or other guest's travel
costs unless approved by the Supervisor prior to the expense being incurred
• Traffic fines and court costs
• Business meals/meetings/entertainment at adult entertainment establishments
• Fees for upgrades of air, hotel or auto
• Personal entertainment expenses (movies, shows, golf fees, sporting events, social

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 and amusement activities, etc.)
• Alcoholic beverages (if not purchased for allowable business entertainment)
• Loss or theft of cash, personal funds or property, including lost baggage
• Optional conference events (e.g. tours, golf outings, etc.) unless there is a specific
business networking purpose as approved by the Supervisor

14.0 RESPONSIBILITIES

14.1 Responsibility of Requester

It is the responsibility of each employee who incurs expenses while engaged in WFS
business and requests reimbursement from WFS to:

• Certify that all expenses being paid or reimbursed by WFS were incurred, are valid,
reasonable, and adequately documented, serve a legitimate WFS business purpose,
and are in full compliance with the provisions of this policy, and understands that
requests that do not comply with this policy, or lack required documentation, will not
be reimbursed.
• Certify that expenses have not been previously paid via a previously submitted
expense report, or by another organization or person.

By signing the expense report, the employee is attesting to the above.

14.2 Responsibility of Authorized Approver

A company official authorized to approve expense reports is responsible for verifying
the following:

• Business purpose of the transaction is valid and directly related to WFS business.
• Expenses are ordinary, necessary and reasonable, are consistent with this policy and
are charged to the proper accounts.

15.0 AUTHORIZATION

All expense reports must be approved by the employee's direct supervisor or

department head.

All approved expense reports will additionally be reviewed by the Accounting

department for entry into the accounting system.

The CFO is authorized to approve expense reports during the absence of the
employee’s supervisor or department head.

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16.0 PAYMENT

Complete the WFS Expense Report

The WFS Expense Report is available in electronic form and should be used whenever
possible. Reimbursement will be faster if the employee’s expense report is complete
and organized in a manner that facilitates an efficient review. Receipts should be
arranged in a sequence that follows the individual line items on the expense report
form. Taping numerous small receipts to a single page of paper is preferred to simply
attach them to expense report.

Submit the original report and original receipts to the employee’s supervisor for
approval.

The approving company official will forward the expense report and receipts to
accounting for review and payment.

Accounting will review the expense report for compliance with this policy.
Reimbursement for any expenses not in compliance with this policy will be withheld
from the reimbursement. The approving company official will be informed so the issue
can be resolved.

The reimbursement will be processed, and payment will be made via direct deposit.
Expense reports submitted on Tuesday of any week will be processed for payment on
Tuesday of the following week. The remittance statement will be mailed to the address
provided by the employee or emailed.

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