Guidelines for Reimbursable Travel & Entertainment Expense

Created for Noble Financial Capital Markets

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  A. Travel - General

  1. Employee travel must be consistent with the business objectives of Noble Financial Capital Markets
  2. All business travel must be pre-approved by submitting a Travel / Event Request on NobleLinx.
  3. All arrangements must be made fourteen (14) days prior to travel - if this is not possible, explanation must be provided on the request.
  4. When short-notice travel is avoidable, reimbursement is limited to the costs associated with advance-planned travel
  5. All requests for attendance at conferences must be submitted sixty (60) days in advance together with the rationale for attendance
  6. Travel must be via the lowest cost alternative, consistent with good business practices – neither luxury, nor sub-standard modes of transportation and accommodations will be used – and reimbursement will be limited to such lowest cost alternative
  7. Airline tickets, car rentals, hotel accommodations (and all other travel-related expenses that can be arranged in advance) will be booked and paid for directly by the travel coordinator.
  8. Change fees and/or upgrades are not reimbursable unless it is determined that such change was outside of the control of the employee
  9. Trips of less than 50 miles one-way do not qualify for overnight stay
  10. For use of personal vehicle, travel will be reimbursed on a direct route basis for the cost of using a car for trips when driving is more appropriate than flying or other public forms of transportation
  11. For employee transportation, the actual cost of a compact car rental will be reimbursed for the portion of the trip that is official business – when a rental invoice includes days of personal use, the total will be prorated based on the number of days for personal use and the number of days for business use
  12. When transportation is required for three or more employees / guests, a mid-size / full size rental may be selected
  13. Airport parking fees are limited to the cost of long-term parking rates; the total amount of personal auto use and parking fees may not exceed the lowest cost of third-party return airport travel
  14. Shared expenses or those to be charged to another party must be detailed on the TRF
  15. Dated original receipts must be provided for reimbursement – credit card payment slips and/or statements are not acceptable – the detail of the individual expenses (all items which constitute the total amount of the receipt) must be submitted
  16. Expenses should be submitted within 30 business days upon return from travel to receive reimbursement.  Expenses more than 90 days old will not be accepted.

  B. Travel - Subsistence Expenses   

Noble Financial uses Average Daily Rates (ADR) guidelines on lodging, meals and incidental expenses – the ADR is a widely accepted lodging industry measure based upon a property's room rental revenue divided by the number of rooms as reported by the hotel property to a leading provider of lodging industry economic data  TRAVEL PER DIEMS

Note: ADR per diem rates are available through the GSA (U.S. General Services Administration) website; only the third-party-provided ADR rates apply to the Noble Financial Group travel policy - please ignore any and all other references to GSA policy and procedure

LODGING (when employee arranged)

  1. Hotel arrangements and/or accommodation planning must be made through an online comparative travel service (such as Expedia.com, Hotels.com, etc.)
  2. Print-out of comparative trip accommodation(s) must accompany expense report regardless if booking is through the online service or elsewhere - if such comparison is not attached to expense report, reimbursement will be limited to a 14-day-advance comparative search at the time of the submission of the expense report
  3. Frequent-stay points may be earned by the employee through corporate travel; however, accommodation decisions must be made on a cost-effective basis and not for the accumulation of such points
  4. Hampton Inn, Fairfield Inn and Holiday Inn Express type of accommodations have been set as an acceptable standard for Noble Financial Employees
  5. Rates (see Per Diems) are the maximum reimbursable amounts allowed (before tax) – when there is a lower cost alternative, such alternative must be selected by the employee – no credit in any other expense category is offered to the employee for obtaining a lodging rate lower than the maximum allowable rate TRAVEL PER DIEMS
  6. Reimbursement is provided for actual lodging costs – an itemized hotel receipt (folio) is required for lodging reimbursement
  7. If lodging is unavailable at or below the allowable maximum, then three quotes are required from reasonable, area lodging facilities and, if approved, the lowest quoted amount will be reimbursed up to a maximum of 150% of the allowable amount
  8. In all cases, only reasonable and necessary accommodations will be reimbursed

FLIGHT ARRANGEMENTS (when employee arranged)

  1. Flight arrangements and/or flight planning must be made through an online comparative travel service (such as Expedia.com, Travelocity.com, etc.)
  2. In larger centers, the choice of airports should be made based upon a cost-benefit basis including transportation costs to and from the chosen airport
  3. Print-out of comparative trip flight arrangements must accompany expense report regardless if booking is through the online service or elsewhere - if such comparison is not attached to expense report, reimbursement will be limited to a 14-day-advance comparative search at the time of the submission of the expense report
  4. Frequent-flyer points may be earned by the employee through corporate travel; however, flight decisions must be made on a cost-effective basis and not for the accumulation of such points
  5. In the event of cancellation of airline tickets due to no fault of the employee, monetary credits issued by the airline must be applied to future business travel. The amount credited to the employee must be itemized on the Expense Reimbursement submission (NOTE: the amount will not be deducted from the current reimbursement but will be recorded for future reference)

CAR RENTALS (when employee arranged)

  1. Car rental arrangements and/or planning must be made through an online comparative travel service (such as Expedia.com, Travelocity.com, etc.)
  2. The costs associated with car rental, fuel and parking must be compared with the combined costs of taxis, subways, trains and other forms of public transportation - the most cost effective method of transportation should be selected
  3. Optional insurance coverage and additional services (such as GPS) offered by the rental company are not reimbursed
  4. Cars must be re-fueled prior to return; additional charges for refueling by the rental company are not reimbursed
  5. Print-out of comparative car rental arrangements must accompany expense report regardless if booking is through the online service or elsewhere - if such comparison is not attached to expense report, reimbursement will be limited to a 14-day-advance comparative search at the time of the submission of the expense report

MEALS & INCIDENTAL EXPENSES  

  1. Rates are the maximum reimbursable amounts allowed (before tax) - no credit in any other expense category is offered to the employee spending less than the maximum allowable per diem daily amount
  2. The first and last day of business travel are reimbursed at 75% of the full day per diem rate
  3. Meals provided by others, such as those included in registration fees or in hotel rates must be deducted from the per diem – meals provided as part of conference registration must be deducted from the per diem  TRAVEL PER DIEMS
  4. In all cases, no reimbursement will be made without a detailed receipt, regardless of the amount

PERSONAL AUTO USE

  1. Use of personal car is currently reimbursed at a rate of $0.54 per mile – necessary tolls and parking costs will be reimbursed with the submission of a receipt
  2. To receive reimbursement for mileage, start and finish odometer reading, point of origin and destination must be recorded on the expense submission
  3. Employee assumes the responsibility for any parking and traffic fines and infractions

NON-REIMBURSABLE TRAVEL EXPENSE

Non-reimbursable expenses include, but are not limited to airline club dues, rental car club membership fees, airline headset rentals, in-room movies, insurance on life or personal property while traveling, purchase of clothing or other personal items, expenses for family, child, pet, home and property while on a trip, excessive / premium alcoholic beverages. Commission-based employees may be responsible for up to 50% of travel expense based upon non-achievement of goals.   

  C. Entertainment - General  

Noble Financial recognizes the need for the appropriate entertainment of clients and final-stage prospects. Federal tax code limits the corporate deduction of reasonable entertainment expense to 50% of the total expenditure. Expenditures deemed as excessive will result in a tax deduction below 50% - or rejected as a legitimate business expense. As these expenditures are among the most scrutinized by both the IRS and the Company's auditors, proper judgment must be exercised when considering client entertainment. 

  1. All entertainment expenditures must be pre-approved using the TRF
    TRAVEL /  ENTERTAINMENT REQUEST FORM
  2. The reason / rationale for the expenditure and an estimate of the cost, together with the
    name(s) and position(s) of those to be entertained must be recorded on the TRF
  3. All of the guidelines applicable to business travel must be followed in order to obtain reimbursement for entertainment expense – receipts must be detailed and include the individual costs on the receipt

  D. Entertainment - Limitations   

  1. When traveling, the employee portion of any entertainment expense for dining is limited to the subsistence daily per diem
  2. With the exception of corporate planned / sanctioned events, the employee cost for entertaining clients is non-reimbursable (eg: green fees, sporting tickets, dinners, etc.)
  3. The cost of a single client-entertainment event / function may not exceed $100 per individual (including travel, taxes and gratuities related to guests)
  4. Reimbursement may include a gratuity of up to 18% of the bill before sales tax – a single gratuity may not exceed $100
  5. Material variance(s) from the cost(s) estimate(s) on the TRF will be the responsibility of the employee
  6. Individual items of entertainment expense or collective expense(s) deemed excessive will not be reimbursed.
  7. Travel and entertainment expenses may not exceed 2% of commission-based employees revenues' and not more than 5% of any individual client-account in any calendar year
  8. Commission-based employees may be responsible for a portion of, or all entertainment expense(s) when the limits expressed above are exceeded.  

Form PXNF2751   5/20/13


Acknowledgment of Noble Financial Capital Markets' Travel & Entertainment Policy

This is to acknowledge that I have received the guidelines and related materials governing travel and entertainment expense reimbursement at Noble Financial Group via the Noble Financial website and understand that it sets forth the terms, conditions and limitations for reimbursement of expenditures I make as an employee of the Company. I understand it is my responsibility to read and understand the policy, procedures and limitations set forth and I further understand that I must follow such policy and procedures in order to be reimbursed for expenditures I have made relating to Company travel and entertainment of guests.

TRAVEL GENERAL │  SUBSISTENCE EXPENSE │  ENTERTAINMENT GENERAL │  ENTERTAINMENT LIMITATIONS
TRAVEL /  ENTERTAINMENT REQUEST FORM │  TRAVEL PER DIEMS │  HOME