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Lilly Pulitzer Travel & Entertainment Policy Table of Contents Updated August 2011 Statement of Purpose 1 Travel Arrangements 1 Oxford Travel Services Traveler Profile Weekend/Non-Business Travel Guest Travel/Personal Travel Cancellations/Refunds Transportation 3 Air Travel Internet Fares Alternate Airports Class of Service Ancillary Airline Fees Personal/Chartered Planes Reimbursement Requirements Ground Transportation Rental Cars Refueling Car Rental Insurance Personal Cars Reimbursement Requirements Lodging 7 Room Type Direct Bill Guaranteed Arrival/Cancellations Personal Services Conference Hotels Alternate Lodging Reimbursement Requirements Meals 8 Guidelines Reimbursement Requirements Tipping 9 Communication Expenses 9 Telephone Aircraft Phone Calls Mobile Phones and Pagers Miscellaneous Travel Expenses 10 Conference or Convention Accommodations Interviewees
Transcript
Page 1: Travel & Entertainment Policy · form. It is the responsibility of the traveler to make any changes or additions to his/her travel profile. In addition, a credit card should be listed

Lilly Pulitzer

Travel & Entertainment Policy

Table of Contents Updated August 2011

Statement of Purpose 1

Travel Arrangements 1

Oxford Travel Services

Traveler Profile

Weekend/Non-Business Travel

Guest Travel/Personal Travel

Cancellations/Refunds

Transportation 3

Air Travel

Internet Fares

Alternate Airports

Class of Service

Ancillary Airline Fees

Personal/Chartered Planes

Reimbursement Requirements

Ground Transportation

Rental Cars

Refueling

Car Rental Insurance

Personal Cars

Reimbursement Requirements

Lodging 7

Room Type

Direct Bill

Guaranteed Arrival/Cancellations

Personal Services

Conference Hotels

Alternate Lodging

Reimbursement Requirements

Meals 8

Guidelines

Reimbursement Requirements

Tipping 9

Communication Expenses 9

Telephone

Aircraft Phone Calls

Mobile Phones and Pagers

Miscellaneous Travel Expenses 10

Conference or Convention Accommodations

Interviewees

Page 2: Travel & Entertainment Policy · form. It is the responsibility of the traveler to make any changes or additions to his/her travel profile. In addition, a credit card should be listed

Travel & Entertainment Policy, updated March 2011

ii

Personal Travel

International Travel 11

Foreign Documentation

Travel Safety

Foreign Currency Exchange

Reimbursable Business and Entertainment Expenses 11

Business Meals and Customer Entertainment

Host/Hostess Gifts

Employees Traveling Together

Non-Travel Entertainment of Lilly Pulitzer Employees

Non-reimbursable Expenses 13

Payment Methods 13

Travel Cards

Travel Advances

Direct Bill

Personal Vouchers

Expense Reporting and Reimbursement Requirements 14

Page 3: Travel & Entertainment Policy · form. It is the responsibility of the traveler to make any changes or additions to his/her travel profile. In addition, a credit card should be listed

Travel & Entertainment Policy, November 2011

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Statement of Purpose

The purpose of this policy is to provide guidelines for ensuring efficient use of the employee's time and to

provide control of and effectively manage the cost of travel and entertainment expenses incurred on

necessary company business in accordance with sound, value-oriented practices while providing

visibility to the company and ensuring the safety of our employees while traveling. The policy is also

intended to provide instructions for processing Travel and Entertainment Expense Reports. This policy

does not cover reimbursements for the purchase of samples, relocation, or educational assistance.

The individual submitting the expense report is responsible for ensuring compliance with all provisions

of this policy and for justifying, with adequate and reasonable explanations, any exception(s) to this

policy. It is the responsibility of the person proposing to incur Travel and Entertainment expenditure to

obtain the authorization of their expense report approver before incurring such expenditure.

In addition, the expense report approver must rigorously enforce this policy, which means that the

person approving the report must be satisfied that all expenditures listed on the report are:

Allowable and substantiated in accordance with this policy.

Comply with IRS requirements to be “ordinary, necessary and reasonable to the conduct of the

business.”

Reasonable in amounts and frequency of occurrence.

Managers are responsible for compliance by employees under their supervision.

In the event of unauthorized expenditures, Lilly Pulitzer (further referred to as the Company) maintains

the right to deny reimbursement.

Due to differences in governmental regulations, customs and tax implications, some portions of the

policy may vary by country of origin. Offshore offices may obtain travel exception authorizations from

the Company CEO or President.

Any policy violations can result in one of the following actions:

Notification of violation to employee and approving manager.

Refusal by Oxford Industries to reimburse all or part of the expense.

Disciplinary action up to and including termination.

Travel Arrangements

Oxford Travel Services

All business-related travel, accommodations and rental car reservations should be coordinated through

Oxford Travel Services (OTS). OTS provides professional travel services to associates while reducing

related expenses to the Company through negotiated contracts with travel agencies, airlines, hotels and

car vendors and retains information for emergency purposes.

OTS provides the following services:

Domestic and international air travel reservations

Hotel reservations and corporate apartment reservations

Car rentals and other ground transportation

Meeting or group planning assistance

International travel guidelines and requirements including passport and visa assistance

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Travel safety reports

Travel utilization reporting to business heads

Any new requests may be sent via email to Travel Requests or by calling OTS at 404.653.1555.

When requesting travel arrangements, the traveler should give OTS necessary arrival and departure

parameters. All reservations should be made as far in advance as possible to take advantage of advance

purchase fares and other cost savings options. For domestic travel, a 10-day minimum is expected. For

international travel, a 2-week minimum is expected. Employees are not guaranteed to receive specific

flights, vendors, airports or upgradeable fares unless they offer the best value as determined by OTS.

For domestic airfare, web-direct booking is recommended through Concur. Information on how to access

Concur is available through OTS.

Occasionally OTS will advise the traveler to obtain services from an offshore location in order to secure

the lowest possible fares or rates. A copy of the itinerary should be provided by the traveler to OTS in

case of the need to contact the traveler for emergency purposes.

Traveler Profile

Oxford Industries Traveler Profile can be completed online on the Lilly Pulitzer Intranet by following the

link at http://intranet/Travel/OnlineTravelProfile. A hard copy will be made available on request. Those

employees who travel on company business two or more times each year are required to complete this

form. It is the responsibility of the traveler to make any changes or additions to his/her travel profile. In

addition, a credit card should be listed on the traveler profile for use when guaranteeing hotels and cars.

If a personal or corporate credit card is unavailable, then the traveler should contact OTS to determine

alternatives.

Employees may participate in, but will not be reimbursed for, airline or other frequent traveler programs

in connection with business travel as long as the following guidelines are observed:

It does not create an undue administrative hardship for the travel agents.

It does not negatively affect the employee's ability to adhere to this policy.

Efforts to move trips around to accumulate miles on a particular carrier will not be supported unless

financially beneficial to the Company.

Delayed booking of travel in order to purchase higher upgradable fares is not authorized.

Those employees who frequently (typically 2 or more weeks per month for 6 or more months in a 12-

month period) travel internationally on company business may be reimbursed for airline club room

memberships and/or “fast pass” lane access only if approved by the Company CEO or President.

Weekend/Non-Business Travel

If an employee wishes to extend a business trip for a non-business related reason, it is the responsibility

of the employee to pay for all car, hotel and other expenses incurred as a result of the extended stay. If

the resulting changes in airline reservations increase the cost of the ticket, the employee must provide the

difference in cost to the Company prior to the ticket being issued.

A Saturday night stay may be requested if it is determined to be financially beneficial to the Company,

i.e. the net costs including hotel, meals, etc. is less than the airfare without the Saturday night stay, in

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which case the manager may approve the reimbursement of applicable hotel, meals, and transportation

for that weekend stay.

Guest Travel/Personal Travel

If a traveler combines business travel with personal travel, they are expected to receive approval in

advance by their manager to ensure there are no business ethics or conflict of interest concerns with the

arrangements.

Cancellations/Refunds

If it becomes necessary to cancel a trip, notify OTS immediately to avoid costly no-show charges. If the

cancellation occurs after normal business hours, call the travel management agency's emergency

telephone service located on your itinerary to cancel the trip immediately.

Unused hardcopy tickets are considered the same as cash and must be returned to OTS for credit as soon

as possible. All unused paper or electronic ticket credits must be reported for refund or credit. All

unused tickets that are nonrefundable can be used towards a future purchase and will be added to your

personal profile. Airline vouchers received from the airlines as compensation for flight-related

inconveniences may be used for personal travel. The traveler will not be compensated for using such

vouchers for business travel.

Transportation

Air Travel

All air travel should be booked through OTS or Concur to ensure the appropriate use of discounts,

corporate agreements and the lowest fares and should be made as far in advance as possible. The airline

fare must be the least expensive available coach class that fits the travel itinerary, airport connections, etc.

Non-refundable tickets should be accepted on all trips when the chance of a flight change is minimal or

the savings exceed the cost of changing tickets. If the needs of the Company require such, not the

convenience of the individual, the employee may choose air travel that must not exceed $100 over the

lowest original fare quoted. Airfares may not be reserved at a higher rate in order to qualify for

upgrading. It is the personal responsibility of the traveler to pay for any upgrades selected. Exceptions

require written approval by the most senior executive of the business, division, or corporate function.

Although the Company allows travelers to make this determination, all declined flight options are

reported to Company management.

In order for air travel to be accurately accounted for, all air travel must be ticketed on an individual basis

and charged to each individual traveler. One employee may not purchase an airline ticket for another

employee. For “infrequent” travelers who may not have a credit card, please refer to the section in this

policy on Payment Methods/Travel Cards.

Internet fares

All travel should be booked through OTS or Concur, the online booking tool that will provide access to

airline, hotel, and car rental fares. Should the employee find a lower fare on the internet or by other

means, he/she should call OTS immediately so they may book the fare. If OTS and Concur are

unavailable and an internet fare meets the employee’s business needs at the lowest possible fare, the

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Travel & Entertainment Policy, November 2011

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employee may book the flight and will be reimbursed. However, the employee must notify OTS of

his/her itinerary when booking through sources other than OTS or Concur.

Alternate airports

Airports that are within 50 miles of other major airports will be considered interchangeable and must be

accepted if fares are a minimum of $100 less expensive, e.g., New York LaGuardia Airport vs. Newark

Liberty International Airport.

Class of Service

International airfare should be booked using OTS at least 14 days in advance for the best rates and

availability. All international travel must be booked for economy class travel with the following

exception:

The second (and subsequent) 12 hour trips within a calendar year may be booked for business class

travel. A 12 hour trip is defined as a trip with 12 or more hours of scheduled flying time for consecutive

legs. Lay-over time is not included in the calculation. The first 12 hour trip of the calendar year will be

economy class travel.

For any trip which the traveler is eligible to fly business class at Company expense, the traveler has the

option to fly economy class and receive a bonus of 50% of the cost difference between business and

economy class, up to a maximum bonus of $2,500. This bonus requires the written approval of a Lilly

Pulitzer Vice President.

Occasionally, business class is not available on certain legs on the appropriate time for a trip. Trips

should be scheduled primarily based on the business need, rather than the availability of business class

on flights. If an employee travels economy one way on a leg that was eligible for business class, the

employee is eligible for a bonus of one half the difference of the one leg, up to a maximum bonus of

$1,250, for any single leg that exceeds 12 hours. This bonus requires the written approval of the Company

CEO or President. All travel for which the employee is requesting the bonus must be booked through

OTS.

Examples of International travel that qualify as 12 hour trips:

Philadelphia to Hong Kong via Chicago

Philadelphia to Seoul, Korea via San Francisco

Example of International travel that does NOT qualify as a 12 hour trip:

Philadelphia to Lima, Peru via Miami

Ancillary Airline fees

Many airlines charge ancillary fees for services such as checked baggage, seat assignments, Wi/Fi access,

etc. Travelers should consider these fees when booking an airline ticket and seek to minimize such fees

whenever possible. Seat assignment fees are a non-reimbursable expense. The cost of meals-on-board

will be reimbursed if they meet the guidelines as outlined in the “Meals” section of this policy.

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Personal or Chartered Planes

Business use of personal, leased, rented or charted aircraft requires the approval of the CEO and

notification to OTS and the General Counsel.

Reimbursement requirements

Passenger receipts for all airline expenses are required. The following is acceptable documentation as

long as it includes the ticket number:

Copy of the itinerary

Copy of the credit card statement that includes the charge of the fare

Copy of the ticket from the employee’s online profile transactions at www.travelinc.com

Ground Transportation

Employees traveling to the same location should share ground transportation whenever possible.

The most cost-effective means available should be used for transportation to and from airports, bus and

rail terminals, and hotels. The following modes of transportation should be considered:

Buses, subways, taxis

Hotel and airport shuttles

Personal car

When Company business is transacted at hotels that have their own shuttle transportation, this form of

transport should be utilized in lieu of rental or taxis. Car rental is appropriate when it is less costly than a

taxi or shuttle service.

Garage parking is reimbursable, but valet parking is not except when no reasonable alternative is

available or the safety of the employee may be an issue (e.g. late night arrivals). The use of short-term

parking at airports should be minimized and used only in emergencies or for safety reasons. Airport

parking for trips exceeding two days should be in long-term or park-and-fly lots.

Private car services should be used only when valid business reasons preclude the use of more

economical modes of transportation and if authorized by the CEO or President. Please contact OTS for

questions regarding what car services are on the approved list. Car service from airports should be used

in limited circumstances such as arrival by the traveler at night and the safety of the employee may be an

issue or no reasonable alternative is available. Because flight arrival times often vary from that listed by

the airline and the car service charges for waiting time, if a car service will be utilized, advanced

reservations of the car service from a New York City airport is not recommended. Rather, the employee

should call the car service directly once he/she has landed. The car service can usually dispatch a car

within 10 minutes of the call.

Upon advanced approval of the traveler’s manager, and when circumstances warrant such, an employee

may use a car service to an area airport. Advanced reservations for trips to the airport are recommended.

Any employee utilizing a car service must pay for the service when it is used and include a copy of

payment when submitting T&E expenses if he/she wishes to be reimbursed.

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Rental Cars

Rental cars should only be used when:

Public transportation is not available

Schedules do not permit the use of public transportation

The cost of public transportation equals or exceeds the cost of a car rental

There is a need for the traveler to have the space to carry samples of product or other business

materials

All car rentals should be booked through OTS or Concur in order to take advantage of corporate discount

agreements. The following rental categories, as defined by the rental companies are acceptable:

Mid size for one or two people

Standard sedan for more than two people (An intermediate sedan may be requested if the amount of

luggage for the number of passengers cannot be easily accommodated in a standard sedan.)

When picking up a rental car, lower counter rates (which are unavailable to travel agents) may be offered.

These specials may be taken advantage of only if the Company does not assume any additional liability.

Except when authorized in advance, navigation systems (GPS) or other advanced technological systems

are not reimbursable. Requests will be considered on a case-by-case basis and must be approved by the

employee’s manager.

Refueling

The traveler should consider the most cost-effective means based on circumstances of refueling of rental

vehicles. Either the vehicle should be refueled prior to drop off to avoid costly rental location fuel costs.

In situations where the employee knows that last-minute refueling will not be possible or most of the gas

will be used, he/she may obtain the prepaid gas option when picking up the car.

Car Rental Insurance

Domestic Rentals

Insurance coverage is included in the domestic corporate rental rate when the employee uses his/her

Oxford corporate Visa credit card, so there is no need to obtain additional insurance when using this card

to pay for the rental. Employees using a credit card other than the Oxford corporate Visa credit card will

be subject to whatever coverage is provided for rental cars through that credit card. If an employee

chooses to purchase coverage, it will be at their own expense or they may cover the vehicle under their

own personal auto policy.

International Rentals

For international rentals, optional insurance covering injury to persons, other vehicles, and property must

be purchased through the rental company.

Personal Cars

Reimbursement for the use of personal automobiles will be based on the corporate mileage rate in effect

at the time of travel. Mileage will be paid for the distance in excess of the employee’s normal commute.

For example, if the normal commute for the employee to his/her place of business is 25 miles each way

and the employee must travel 40 miles each way for company business, he/she would be eligible for

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mileage reimbursement of 15 miles each way for a total of 30 miles. For the current mileage rate, go to

http:/intranet/BusResources/TravelInfo/MileageRate.html. The employee will also be reimbursed for

parking and tolls for authorized business use of personal cars.

The Company does not provide collision insurance for personal cars used for company business.

Damage to personal cars is the owner’s responsibility.

Reimbursement Requirements

The original car rental receipt and any fuel receipts should always be included when submitting the

reimbursement request. Additionally, the employee should submit receipts for parking and tolls.

Lodging

It is important that lodging accommodations are booked that are convenient, offer good value and meet

business and safety needs of our travelers. Hotel bookings should be made through OTS or Concur

except in the case where offshore Company offices have access to better availability and rates. In

locations where the Company leases corporate housing or apartments, OTS will schedule the traveler in a

company apartment, if available, with a back-up reservation made in a hotel in the same vicinity.

In locations where negotiated discounts have been obtained from preferred hotels, these properties

should be used. Other hotels in these areas will not be booked unless they are less expensive or if the

preferred hotel is not available. In locations where the Company has not established preferred hotels,

travelers may suggest their preferences, but another hotel in close proximity may be selected if a better

value is offered that meets the Company’s business and safety needs. If the hotel is being reserved and

paid for by someone other than the Company, e.g. a vendor, the hotel information including address,

rate, and phone numbers should be provided to OTS. This information will be included on the travel

itinerary for reporting purposes as well as emergency use.

Prior approval for an overnight stay must be obtained from the employee’s manager when working

within 50 miles of the employee’s normal place of business.

Room Type

Employees are expected to use standard single room accommodations. Club or concierge floors are not

allowed unless the upgrade is complimentary.

Direct Bill

Each employee should make arrangements to pay for dining and lodging accommodations and should

not have the hotel or restaurant bill Lilly Pulitzer directly. The Company will not accept direct billing for

meals or lodging except for company-sponsored meetings or conventions that have been approved in

advance by the Company CEO or President.

Guaranteed Arrival/Cancellations

All hotels booked through OTS are guaranteed for late arrival. Cancellations for guaranteed hotels are

the responsibility of the traveler. If the employee changes travel plans and neglects to cancel their room

reservation, any “no show” charges are the responsibility of the traveler unless an exception is made by

the traveler’s manager in which case the charge may be included on the expense report.

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Personal Services

Hotel services such as laundry and valet services are only reimbursable when traveling for five or more

consecutive nights.

Miscellaneous hotel services such as in-room movies, massages, health club charges, and newspapers are

not reimbursable. In exceptional circumstances, e.g., in situations or locations where health or safety are

of concern, room service and mini-bar use as a regular meal may be reimbursable if reasonable

alternatives are not available and the expense has been approved by the employee’s manager. Wi-

fi/internet services in the hotel may be reimbursed if approved in advance by the traveler’s manager

For a more complete list, please see the section in this policy on reimbursable and non-reimbursable

items.

Conference Hotels

Please see Miscellaneous Travel Expenses.

Alternate Lodging

There may be situations where the use of alternate lodging instead of conventional commercial hotels is

advantageous. Requests for alternate lodging such as at a private rental property must be made and

approved in advance of travel by the CEO, the President, or Lilly Pulitzer Vice-President. The use of the

lodging must not be in violation of the Conflict of Interest/Business Ethics policy and risk management

policy/procedures and the price must be commensurate (equal to or less than) with other lodging

available. Proof of the commensurate pricing, the name of the owner and his/her relationship (friend,

family, etc.) to the traveler must be provided at the time the request for approval is made.

Reimbursement Requirements

A receipt or folio that shows a balance due of zero should be submitted with the expense report.

Meals

The Company will reimburse employees for meal expenses (breakfast, lunch, dinner) actually incurred

while away from their normal place of work, providing such expenses are reasonable, appropriate and

supported by a receipt. It is not the intent of the Company to provide meals that are lavish or otherwise

extravagant. Meals for the traveler’s family or personal guests are not reimbursable. Special events

where the spouse or other family member has been invited by the Company may serve as an exception, if

approved in advance by the employee’s manager.

Guidelines

Breakfast will be reimbursed whenever the employee is out of town the night before. Also, breakfast

reimbursement is permitted if travel begins earlier than a normal breakfast hour and no meal is served on

the transportation used. Where full breakfast is included as part of the hotel stay, employees are

expected to utilize this option in which case reimbursement for a breakfast expense will not be allowed.

Lunch will be reimbursed on all out of town assignments with support of a receipt.

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Dinner reimbursement will be made when the traveler is away from his/her main place of work for the

evening meal or does not return home until after the normal dinner hour.

Travelers are asked to use discretion when expensing meals associated with traveling. Expensive alcohol,

wine, and food are inappropriate for business travel and all travelers are expected to use discretion when

making meal choices.

Reimbursement Requirements

All meals of $25.00 or more require a cash register or credit card receipt that indicates date, place and

type of expenditure (breakfast, lunch, dinner). Meals with customers should be clearly indicated under

the entertainment section of the expense report. If dining with other Lilly Pulitzer employees or company

guests, the bill should be paid by and submitted for reimbursement by the highest ranking employee

participating in the meal event. In some circumstances it may be more appropriate for an employee other

than the most senior one to pay a charge, but under all circumstances these expenses should be submitted

to the most senior employee’s manager for approval. As back up to the receipt, a list of all attendees

including Company employees, their positions, company and nature of the business discussed must be

described on the expense reimbursement request form.

Tipping

General guidelines for tipping are as follows:

Meals: 15 – 20%

Taxi: 10 – 20%

Bellhop/skycap: $1.00 per bag

Arranged car service: 0% (included with fees) unless driver provides service beyond customary and

usual such as unloading heavy luggage or equipment/materials

Housekeeping or maid services - $2.00 - $4.00 per night if service warrants such

Concierge services (business purposes only) - $5.00 - $10.00 depending on concierge’s efforts

Meal gratuity charges should not exceed 20 percent of the restaurant charge except in cases where an

establishment includes a set service fee. The amount of the tip must be notated on the receipt. Please be

aware in certain countries, gratuities are already included and anything additional is not expected.

Whenever possible, receipts should indicate amount of tip paid. No receipt is necessary for bell

hop/skycap tips, tips to housekeeping, etc.

Communication Expenses

Telephone

The Company will reimburse employees for reasonable telephone expenses of a business nature. Cell

phones should be used when possible for business-related long distance calls. Otherwise, the Company

will pay for business calls made outside a company office provided the calls are substantiated by a

telephone bill, listing, or hotel bill.

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When traveling domestically on company business, the Company will pay charges for personal long-

distance calls of normal duration. For international travel, personal calls should be reasonable in nature

and duration. All personal calls must also be substantiated as mentioned above.

Employees should avoid in-room telephone calls from hotels unless no other option is available and the

call is absolutely necessary.

Aircraft Phone Calls

On-board aircraft phones should be used only when absolutely necessary.

Wi-Fi/Internet charges

On-board aircraft Wi-Fi/Internet charges will not be reimbursed unless approved in advance by the

manager.

Mobile Phones and Pagers

Associates may also prefer to use cellular/mobile phones. Cell phones can provide a good alternative to

hotel and other phones and when used with good judgment, calls will be reimbursed.

For frequent business users, as determined by your manager, a corporate plan may be arranged through

the Company’s Information Services department or the respective divisional Information Services for

pagers, mobile phones and other communication devices. If an employee is being provided by the

company with a mobile phone or other communication device, he/she should use the device for all

telephone calls outside of a Lilly Pulitzer office unless the economics of using an alternate telephone

outweigh the use of the employee’s communication device.

Miscellaneous Travel Expenses

Conference or Convention Accommodations

All transportation and hotel accommodations should be booked through OTS for proper follow-up and

for securing the maximum discounts. Attending a conference does not automatically guarantee that the

employee may stay at the hotel hosting the conference. Several options may be given to minimize costs

when considering conference hotels.

Interviewees

Interviewee travel should be booked through OTS for use of preferred vendors and maximum discounts.

Seven days advance notice should be given whenever possible.

Should their travel plans change, interviewees should be instructed to call the Travel Department

(404.653.1555) or call the toll free number after hours (1.800.241.0944) so that reservations are canceled in

time to prevent unnecessary “no show” or penalty charges to the Company. Weekend travel is not

considered normal practice for interviewees. Exceptions may be made if the proper authorization is

given prior to the reservation.

When necessary, car rentals and hotel charges for room and tax only may be direct billed to the Company

for interviewees. These arrangements should be made through OTS. Other business-related expenses

must be submitted to Human Resources for approval and reimbursement.

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Personal Travel

OTS is not responsible for making personal travel arrangements for employees but can assist you with

your personal needs as long as business travel requests will allow it.

International Travel

Due to the complications involved with international travel, employees should book all international

travel through OTS. Because the safety of our employees, especially during international travel, is very

important, Oxford does not allow any employee to travel to an area of the world that is listed under the

“Travel Warnings” section of the U.S. State Department’s International Travel web site

(http://travel.state.gov/travel/cis). Upon receipt of a request for international travel, OTS will first

confirm that the desired destinations are designated as “safe” for travel. Following that OTS will advise

the traveler of all documentation required by each country to be visited. This will include passport, visa,

and, immunization requirements. Note: Oxford will pay for all necessary entry documents for

international business travel, including passports, visas and inoculation certificates. If needed, OTS will

provide information for the traveler to access needed applications along with instructions and time lines

for application processing. Additionally, the traveler will be provided with a valid worldwide assistance

identification card that will include instructions for what to do in case of any emergencies.

Foreign Currency Exchange

The rate used should be the actual rate in effect when currency is exchanged. (Attach copies of exchange

transaction slips). Where no original exchange transaction slip is attached, use the book exchange rate in

effect at the time the expenditure was incurred, or use an average for the week.

You may also choose to wait until after you receive your credit card statement to submit your expense

report. It will show the actual conversion and U.S. dollars calculated. For more immediate needs, you can

call customer service for your selected card and they will advise you of the rate used. Foreign transaction

fees for all business related costs will be reimbursed upon submittal of the credit card statement showing

such expenses.

Reimbursable Business and Entertainment Expenses

Business Meals and Customer Entertainment

Expenses incurred while hosting customers, business acquaintances, and Company guests will be

reimbursed when they are essential to the transaction of Company business. The expenses incurred must

meet IRS requirements, be within reasonable limits and be commensurate with the business being

conducted.

IRS guidelines state:

A business meal or entertainment expense must be directly related to the conducting of business.

For local business guests, the meal or entertainment must take place either immediately before, during

or after the business is conducted.

For out of town guests, the meal or entertainment can take place the day before or after the business is

conducted.

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All entertainment expenses should be documented by original receipts. Meal and/or beverage receipts

should indicate the number of guests entertained including any employees. It is the responsibility of the

employee to ensure the accuracy of the receipt, including the date of the transaction. All entertainment

receipts must be marked as such with the following information notated on the expense report under the

Entertainment Expense section:

Date

Nature of entertainment (dinner, drinks, golf, theatre, etc.)

Location

Business purpose or topics discussed

Names and business relationships of all persons present including all Company employees

Amount of tip(s) if given

Any special entertainment expenditure must have prior approval by the traveler’s manager.

Host/Hostess Gifts

If an employee stays at a private home in lieu of a hotel, the employee may provide a one-time meal or

gift basket up to $75 and not to exceed the cost of the comparable expense in the locale.

Employees Traveling Together

When employees are traveling together, the highest ranking employee should account for the expense

when dining together or entertaining business guests. In some circumstances it may be more appropriate

for an employee other than the most senior one to pay a charge, but under all circumstances these

expenses should be submitted to the most senior employee’s manager for approval. As back up to the

receipt, a list of all attendees including Company employees, their positions, company and nature of the

business discussed must be described on the expense reimbursement request form. Each employee

should account for all other expenses he/she incurs such as hotel and airfare.

Meals are not normally reimbursable when dining with employees who are not out of town, (e.g. Atlanta

employee visiting N.Y. and “entertaining” NY employee) even though business matters may be

discussed, unless prior approval is received from the traveling employee’s manager.

Non-travel Entertainment of Lilly Pulitzer Employees

There are times when it is appropriate for a manager to take a subordinate out for a meal to celebrate an

achievement or review a business issue, but the cost should be reasonable and not lavish as noted in the

Meals section of this policy. Regular or planned incentive events, such as a department picnic or outing,

should be part of the regular budget and not be treated as ad-hoc expenses. Examples of inappropriate

expenses would be a lunch to celebrate a birthday, holiday or other personal event. Additionally, there

may be times when it is appropriate to provide refreshments or meals as part of a business meeting.

These expenses should be approved in advance by the employee’s manager and should be paid for

using an employee’s credit card and not directly billed to the business. Submission of these expenses

should be made following the procedure for other T&E reimbursements including documentation of

the business purpose, names of attendees, etc., as outlined above under “Employees Traveling

Together,” and approval by the manager of the highest ranking employee at the business meeting or

event. Exceptions to this must be approved in advance by the Company CEO or President.

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Meals in connection with special events such as farewell luncheons or team meetings are permitted only

when approved by the CEO, the President or Lilly Pulitzer Vice President.

Nonreimbursable Expenses

The following items are not considered reimbursable:

Child care or baby sitting expenses

In room movies

Valet parking unless specifically required by hotel or restaurant or there are safety concerns such as

the employee arrives late at night

Laundry and dry-cleaning expenses unless over five nights of travel

Flight or trip insurance

Use of athletic club, spa facilities, gyms, etc.

Traffic and parking fines and related court costs

Pet boarding or sitting

House sitting

Gifts for co-workers including flowers (other than service awards).

Medications or other personal needs

Personal reading matter such as newspapers, magazines, books

Purchase of merchandise, which may be used personally subsequent to a trip, such as clothing,

toiletries or novelty items.

Recreational activities while on a business trip which are not part of scheduled business activities.

Personal credit card annual fees (other than annual fee for company issued credit card.)

Credit card finance charges, late fees and any ATM fees.

Personal grooming costs, such as barber/hairdresser and shoeshine.

Snacks and refreshments such as bottled water, coffee, sodas, candy, etc., which are in addition to

meal charges for breakfast, lunch, and dinner, including items from in-room mini-bars.

Expenses for personal employee-related events such as showers, birthdays, etc. whether on premises

or not, e.g. birthday cakes

Monthly parking fees

Personal coupons, travel vouchers, gift certificates, etc.

Airline or hotel Wi-Fi unless approved in advance by the manager

Excessive baggage fees unless necessitated by business

Membership fees for Clear program or similar programs requiring payment for expedited passage

through airport security and airline club rooms except where approved by the Company CEO or

President

Payment Methods

Travel Cards

Corporate Visa Travel Cards are available to travelers with the approval of the employee’s manager. The

nominal annual fee will be reimbursed by the company. The Treasury Department in Atlanta provides

applications and administers the program. An application form can be found on the intranet at

http://intranet/Forms/Travel/VisaTravelCardApplication.doc. Atlanta Accounts Payable can

electronically pay any portion of an expense reimbursement directly to the employee’s corporate Visa

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account. Personal charge cards are acceptable for travel expenses and airline reservations, however,

direct payment by Accounts Payable to personal charge cards is not possible.

For “infrequent” travelers, some groups retain a central Visa account. Air reservations for non-card

holders may be charged to this account with the prior approval of the employee’s manager and the

Company CEO or President and must be booked through OTS.

Travel Advances

Employees who do not have access to a credit card and who need funds to subsidize their travel and

entertainment costs can secure a temporary travel advance subject to the manager’s approval. Travel

advances may not exceed the amount that may reasonably be expected to be expended in cash on the trip

they are intended to cover. Advance requests require the same approvals as expense reports. Advances

are accounted for by submission of an Expense Report within seven days of returning from the trip. No

more than one temporary advance may be outstanding at one time.

Direct Bill

Each employee should make arrangements to pay for dining and lodging accommodations and may not

have the hotel, motel, or restaurant bill Lilly Pulitzer directly. The Company will not accept a direct

billing for meals or lodging except for company sponsored meetings or conventions or other business

events where billing has been pre-arranged and pre-approved by the CEO, the President, Business

division head, or Corporate function head,. Any direct billings should be sent to Corporate Expense

Payables for processing and not entered at the division business level.

Personal Vouchers

While employees are welcome to use personal travel vouchers, gift certificates, coupons, etc. to enhance

their business travel experience, such use will not be reimbursed by the company.

Expense Reporting and Reimbursement Procedures

Employees are responsible for completing their own expense reports in a timely and accurate manner

using the following guidelines:

Reports should be completed on a weekly basis or within 10 days of returning from a trip or incurring

the entertainment expense. Reimbursement requests submitted longer than 60 days of having paid or

incurred the expense will not comply with federal guidelines and may not be reimbursed.

The traveler should report all expenses in U.S. dollars with the conversion from foreign currency done

prior to the submission of the expense report. The cost of Foreign Transaction Fees (FTF) will be

reimbursed upon submission of the credit card statement showing such expense.

All expense reports require the signature of the employee requesting reimbursement.

Approval for out-of-policy travel costs that will result in an additional cost to the business of less than

$100 for employees affiliated with Lilly Pulitzer must be approved by the employee’s manager.

Approval for out-of-policy travel costs that will result in an additional cost to the business of less than

$500 for employees affiliated with Lilly Pulitzer must be approved by a Vice President. Out-of-policy

costs that will result in an additional cost to the business of $500 or more must be approved by the

Company CEO or President.

The minimum level of signed approval of expense reports is the traveler’s immediate supervisor

(manager) only, except in the case of the CEO who must have the approval of the President or Chief

Financial Officer. (Note: Some business units may require additional approval.) Supervisors are

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required to review all items to ensure that they are within corporate policy. In the absence of the

normal approval authority, the next higher level of approval authority within the department/division

may approve the expense report if it has no exceptions that require senior executive approval.

Original receipts for all expenses of $25.00 or more must be attached to the expense report. Receipts

submitted for reimbursement must be legible and intact. Acceptable receipts are original charge card

and/or register receipts. Credit card statements should not be used as documentation unless the

receipt is lost or unavailable. If a receipt is lost or unavailable, the employee must include with the

expense report a note detailing the expense and why no receipt is available.

Travel and entertainment expense reimbursements should not be made from any location funds (e.g.

petty cash, etc.). They must be processed through accounts payable.

All T&E claims must include the following:

Purpose of trip

Origin and destination

Names of persons entertained and category (Oxford employees, customers, vendors, etc.)

Correct totals

Incomplete or unapproved reports will be returned to the employee for proper submission. The employee

will receive a T&E Request Return Form which will contain an explanation of why the expense form is

being returned.

Reasonable effort will be made to reimburse travelers within a seven-day period after receipt of a

properly completed expense report. Expenses with insufficient supporting documentation will be

permitted only at the discretion of the Company CEO or President.


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