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BUSINESS TRAVEL AND ENTERTAINMENT

POLICIES AND PROCEDURES FOR NORTH AMERICA

INDEX
1.0 Purpose . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . HR-10-2
2.0 Applicability. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . HR-10-2
3.0 General information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . HR-10-2
4.0 Credit cards. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . HR-10-2
5.0 Travel services . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . HR-10-3
6.0 Required documentation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . HR-10-3
7.0 Lodging . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . HR-10-4
8.0 Meals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . HR-10-4
9.0 Entertainment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . HR-10-4
10.0 Air travel . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . HR-10-5
11.0 Ground transportation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . HR-10-7
12.0 Telephone . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . HR-10-8
13.0 Business gifts. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . HR-10-9
14.0 Travel expenses of spouses at meetings or conventions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . HR-10-9
15.0 Miscellaneous . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . HR-10-10
Appendix I Declaration of Missing Receipts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . HR-10-12
Appendix II Manager Pre-Approval . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . HR-10-13

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BUSINESS TRAVEL AND ENTERTAINMENT


POLICIES AND PROCEDURES FOR NORTH AMERICA

1.0

PURPOSE
1.1

The purpose of this policy is to provide guidance regarding travel and entertainment expenses incurred by
employees in the conduct of Company business. Its aim is to provide equitable standards and effective
procedures for properly controlling and documenting travel costs. This policy is also intended to facilitate
compliance with Internal Revenue Services (IRS) requirements and other regulatory authorities..

2.0

APPLICABILITY
1.1

This policy is applicable to all Saint-Gobain North America locations. Specific procedures with respect to travel
performed in conjunction with government contracts should be obtained at the business-unit level.

3.0

GENERAL INFORMATION
3.1

3.2

It is Company policy that only travel expenses that meet the following criteria will be reimbursed:
3.1.1

The expenses are ordinary and necessary to the conduct of Company business.

3.1.2

The expenses are neither lavish nor extravagant under the circumstances.

3.1.3

The expenses are supported by proper documentation and receipts as defined in the policy.

3.1.4

The expenses are submitted for reimbursement within 60 days of being incurred.

In order to ensure timely payment of American Express charges, an expense report should be submitted as soon
as possible after a trip is completed.

4.0

CREDIT CARDS
4.1

Personnel who travel on Company business or entertain for business reasons are to use an American Express
Corporate Card for charging businessrelated expenses. The American Express Corporate Card should not be
used for personal or non-business-related expenses.
Personal credit cards should not be used for charging business-related expenses except where the traveler
demonstrates that the American Express Corporate Card is not accepted by the establishment.

4.2

Newly hired employees or infrequent travelers who have not yet been issued an American Express Corporate
Card must have airline and train tickets purchased by their manager using his or her American Express
Corporate Card. The manager must then submit an expense report for reimbursement.

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4.3

The Membership Rewards fees are at the Cardholders discretion and are not reimbursable.

4.4

Finance charges associated with late fees, penalties, or service charges, or lost/stolen card fees are generally not
reimbursable. It is each cardholders responsibility to submit timely expense reports or to pay his/her American
Express Corporate Card bill when due, and to promptly report lost/stolen cards. If the traveler can demonstrate
to the satisfaction of his/her manager that a timely expense report had been submitted and that a late fee was
the result of delayed reimbursement by the Company, such a fee may be reimbursed.

5.0

TRAVEL SERVICES
5.1

Saint-Gobain has implemented an online travel booking system (http://wcp.getthere.com/3e5hen7g). It is


expected that travelers will use this tool for all uncomplicated itinerary trips, as there is a significant discount on
the agency fee for online booking. For complicated itineraries, it is recommended that travelers book their
travel through American Express.

5.2

American Express is the Company-approved travel agency for all North America-based locations. American
Express is known worldwide and has a network of locations Company-owned and affiliated to service the
travel needs of employees located throughout North America.
All business travel must be arranged through either the Saint-Gobain on-line system or American Express
(except for employees of SG Containers, who can continue to use World Travel Partners). Airline tickets
purchased by any other means will not be reimbursed.

5.3

A fee will be charged directly to the American Express card of the traveler for each airline or train ticket arranged
through either the on-line system or American Express. As of May 2005, the fees are $17.50 and $40.00,
respectively. The travel agency reservation fee will appear at the bottom of each e-mailed invoice and on the monthly
American Express Corporate Card statement. Either will be acceptable as receipt for the agency reservation fee.

6.0

REQUIRED DOCUMENTATION
6.1

Reimbursement claims for travel and entertainment must be made using GELCO ExpenseLink and must be
supported by proper documentation, including original itemized receipts containing the date of expense as well
as the name and location of the establishment or service provider, and complete explanations of expenses
incurred. Regardless of the dollar amount, original receipts must be submitted for every expense.
An itemized receipt shows each individual item comprising a bill and, generally, the corresponding charge for
each item. For example, the itemized receipt for a meal shows each item of food or drink ordered, as well as
taxes and service charges, if applicable.

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6.2

In addition to the documentation requirements noted in Section 6.1, all entertainment expenses must be
supported by a complete description of the nature of the expenses; names and affiliations of the people
involved; purpose of the entertainment; and name and location (city and state/province) of the establishment to
which the payment was made.

6.3

In the rare case where a receipt is lost or unavailable, the traveler must complete and sign a Declaration of
Missing Receipt form and attach it to the expense report. The form is available in Appendix I and through
GELCO ExpenseLink. One form may be submitted for all missing receipts on an expense report. Failure to
provide this Declaration may delay and/or preclude reimbursement.

6.4

Certain expenses require manager pre-approval. This approval must be documented on the Manager PreApproval form available in Appendix II and through GELCO ExpenseLink. Failure to file this form together
with the related expense report may delay and/or preclude reimbursement.

7.0

LODGING
7.1

Lodging costs should be reasonable for the area visited. Wherever possible, accommodations where corporate
discount rates have been negotiated should be used. As noted in Section 5.0, all reservations must be made
through the Saint-Gobain on-line system or American Express.

7.2

Travelers must cancel guaranteed reservations by the deadline specified by the hotel to avoid any penalties for
no cancellation.

7.3

The original hotel folio showing itemization of the charges as well as the total paid must be provided in support
of lodging.

8.0

MEALS
8.1

The Company will reimburse traveling employees for the reasonable cost of meals. Approving managers are
responsible for verifying the reasonableness of reported meal costs.

8.2

Entertainment of one employee by another at Company expense must be essential for the business purpose.
The most senior employee present must assume responsibility for paying the bill related to such entertainment.

9.0

ENTERTAINMENT
9.1

To comply with IRS rules, it is essential that travelers precisely describe the business purpose of entertainment.
As noted in Section 6.2, all entertainment must be supported by itemized receipts, details regarding names and
affiliations of those attending, and the location at which the entertainment took place.

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9.2

The IRS limits the tax deduction of expenditures for entertainment to those expenses that are either directly
related to or associated with the active conduct of the Companys business.
9.2.1

Directly related entertainment involves a business discussion or negotiation that looks forward to
income or other business benefit at some specific time; business must be actually conducted during
the entertainment period.

9.2.2

Associated entertainment may be deductible if directly preceded or followed by a substantial and


bonafide business discussion with a clear business purpose in making the expenditure.

9.3

There are some forms of entertainment that the Company considers to be inappropriate and not in keeping
with several of its other policies. Therefore, expenses incurred at establishments where such entertainment takes
place will not be reimbursable regardless of IRS rules or whether they have been reimbursed in the past. Such
establishments include, but are not limited to, those popularly known as gentlemens or womens clubs,
adult entertainment or a place where movies, videos, shows or dancing that could constitute adult
entertainment takes place.

9.4

There are some occasions where it may be appropriate for employees to entertain business associates at their
homes as part of a business meeting. To be reimbursed, the employee must obtain prior supervisory approval
for the specific entertainment in question. The following procedures must be strictly observed for approved home
entertainment to qualify for reimbursement:
9.4.1

The entertainment must be for a Company-related business purpose specifically stated on the travel
expenses report.

9.4.2

The cost must be reasonable and supported by itemized receipts.

9.4.3

The travel expense report must contain at a minimum the date and type of entertainment; the specific
purpose of the business meeting; and the names and affiliations of all attendees.

10.0

AIR TRAVEL
10.1

All domestic air travel shall be booked in the most economical class. American Express has been instructed to
offer the lowest fare available in all cases. In the rare case where travel in business class is necessary for domestic
travel, manager pre-approval is required. See Section 6.4.

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Our partner airlines are US Airways, American Airlines, Northwest, United Airlines, and Air France. We have
negotiated significant discounts with these airlines based on estimated volumes; accordingly, they should be
used whenever possible. In addition to routes not serviced by partner airlines, guidelines from Compagnie de
Saint-Gobain allow for the use of non-partner airlines only if the fare savings is greater than $100. All travel
must be booked through the authorized travel agencies.
10.2

Business class travel for intercontinental or cross-oceanic flights is permitted unless a more restrictive policy is
adopted at the business unit level.

10.3

Air travel arrangements shall be made as far in advance as possible to ensure availability of the most economical
fare. Manager pre-approval is required for advance purchase of an airline ticket.

10.4

With the exception of those required by itinerary changes, no changes in fare basis or upgrade while en route
shall be made at Company expense. It is no longer possible to change a nonrefundable ticket at the airport
counter without incurring a service fee in addition to any additional fare the change may create. Contact
American Express (or World Travel Partners) for any and all ticket changes.

10.5

Frequent flyer awards are considered to be for the benefit of traveling employees. Employees are, however,
required to cooperate with American Express to obtain the lowest cost fares that meet their reasonable requirements.

10.6

American Express will book airline tickets for infrequent employee travelers who do not have an American
Express Card only if such travel is charged to the managers American Express Corporate Card. The manager
must then submit an expense report for reimbursement.

10.7

Airfares for conferences or meetings involving several employees should be booked in advance through
American Express whenever possible as significant discounts may be negotiated with carriers. Generally, trips
involving 10 or more employees may qualify for additional discounts. Contact the Group Air Department at
American Express.

10.8

The cost of transportation (i.e., air travel and Amtrak) will not be billed directly to the Company. These
transportation expenses must be charged to the travelers American Express Corporate Card and submitted for
reimbursement on a travel expense report.

10.9

The traveler is to ensure that the travel agency is informed of any changes or cancellations so that proper
credits or saved tickets are tracked.
Unused non-refundable airline and train tickets will be stored electronically by the travel agency for future use.
Remember to contact the Agency to make any changes to travel plans. Call the on-line support number or the
traditional number, depending on how the reservation was booked (see travel internet site for details).

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10.10

Air travel must be documented by submission of the E-mail itinerary and invoice sent by American Express
and by boarding passes.

10.11

Airline club membership fees are considered personal expenses and will not be reimbursed.

10.12

Back-to-back ticketing and similar schemes are a violation of airline tariff rules and of the contracts Saint-Gobain
and its travel agencies have entered into with the airlines. Fees assessed by an airline as a result of back-to-back
ticketing and similar schemes are not reimbursable.

11.0

GROUND TRANSPORTATION
11.1

Private Automobile
11.1.1

Personal automobiles should be used for business trips under 100 miles one-way from the travelers
assigned office/plant location.

11.1.2

Business-related mileage traveled in the employees personal automobile shall be reimbursed at the
standard Company reimbursement rate, which includes gasoline and all other charges and costs with the
exceptions of parking fees and tolls. Other operating costs for private automobiles are not reimbursable.

11.1.3

Corporate Finance updates the mileage rate in accordance with the most recent IRS or Revenue of
Canada regulations. Travelers should contact their local accounting department for the current
reimbursement rate.

11.2

Rail / Bus
Trains or buses are acceptable forms of transportation for business-related travel where practical. When traveling by rail, coach accommodation shall be used.

11.3

Local Transportation
Airport/hotel limousines, taxis, and buses shall be used whenever practical. Employees are expected to use the form
of transportation most advantageous to the Company, considering cost, distance, time convenience, and safety.

11.4

Auto rentals
11.4.1

Rental cars should be obtained from Company-designated automobile rental firms with whom
discounted rates have been negotiated for Company personnel. Normally, this discount must be
requested at the rental-originating location by displaying special identification stickers.

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11.4.2

Employees renting cars for Company business should decline collision damage and personal accident
insurance options once they have verified that the rental firm is not a franchise location. If the rental
car location is owned by the rental car firm (Hertz or Avis) and is not an independent franchise,
collision damage and personal accident insurance are covered by the Companys insurance programs.
If the rental location is an independent franchise, employees should accept their insurance coverage.
American Express can identify franchise locations for the traveler. For travel in Canada and Mexico,
the insurance should always be purchased by US-based travelers. Canadian-based travelers can
decline all coverages because use of the SGC Canadian American Express Corporate Card carries
insurance coverage.

11.4.3

Mid-size cars will automatically be reserved unless traveling in groups of three or more.
Company-designated providers and related rates and requirements may change from time to time.
Please contact the Corporate Fleet and Travel Service Manager for the firms of choice and rates.

11.4.4

When evaluating use of the fuel purchase option for rental cars, the traveler should use his/her best
judgments, keeping in mind that the fuel purchase options are generally more expensive than
self-fueling. Therefore, travelers are encouraged to return a fully refueled rental car, the fuel having
been purchased at a local gas station. The gasoline purchase can be submitted for reimbursement.

11.5

Leased Automobiles
The use of Company-leased automobiles on Company travel is covered by specific procedures governing SaintGobain leased fleet vehicles. Employees using Company-leased autos will not be reimbursed for mileage.

11.6

Tolls
EZPass or other transponder systems for tolls may be used at the election of the employee. The specific charges
incurred during business travel should be reported as a cash toll when used.

12.0

TELEPHONE
12.1

Telephone charges incurred in connection with Company business are reimbursable expenses. When business calls
are charged to ones personal telephone bill or a calling card, the original statement and detail must be attached
to the expense report. With the exception of reasonable calls home while out of town, personal calls are not
reimbursable.

12.2

The installation and monthly services for a business phone or Internet Service Provider in the home is reimbursable with prior written supervisory approval. Business phones should only be used for Company business
and the complete original statement with all supporting detail must be submitted for reimbursement.

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13.0

BUSINESS GIFTS
13.1

Business gifts are subject at all times to the cost and value limitations and to the Company policy on business
ethics:
13.1.1

They cannot be construed as intended to corrupt the judgment of the recipient so as to secure unfair
or preferential treatment.

13.1.2

They must be of such limited value that they could not have a significant impact on either the total
financial operations of the Company, or on the total income of the recipient.

13.2

Receipts are required for all gifts and must be attached to the travel expense report for each individual
expenditure. Business gifts in excess of $ 25.00 (or equivalent) per donee per year are not deductible for U.S.
federal tax income purposes.

13.3

Authorization for promotional customer trips or outings, regardless of the number of customers, must be
approved in advance by the employees supervisor in accordance with limits set by the business units.

13.4

Promotional trips for customers should be discussed in advance with the corporate Tax Department to ensure
proper handling of tax issues with respect to customer and employee participation.

13.5

Award trips for customers should be discussed in advance with the corporate Tax Department to ensure proper
handling of tax issues with respect to customer and employee participation. Business unit controllers are
responsible for ensuring adherence with these regulations.

13.6

14.0

Holiday or other gifts for a Company employee are personal in nature and are not reimbursable.

TRAVEL EXPENSES OF SPOUSES AT MEETINGS OR CONVENTIONS


14.1

14.2

Travel expenses of spouses are not normally covered by the Company except as noted below:
14.1.1

The attendance by a spouse is necessary for business reasons and is clearly in the Companys interest.

14.1.2

The convention/meeting invitation clearly and expressly extends the invitation to spouses.

14.1.3

The prior approval of a business unit president or corporate officer is obtained.

Travel and entertainment expenses of spouses of other companies are not tax deductible by the Company.
Business unit controllers are responsible for initially determining the business purpose of the trip and ensuring
that both the employee and spouse complete necessary documentation to support the determination.

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14.3

In the U.S, the total cost of Company-paid spouse travel will be reported as income to the employee unless the
expenses are incurred in connection with attendance at a business function, and such attendance is considered
to be necessary for business reasons.
Business unit controllers should submit notice of such nondeductible trips to the office processing the
employees payroll.

14.4

Business functions arranged or sponsored by third parties where spouses have been specifically invited may have
appropriate business justification, but attendance requires the advance approval of the business units president
or corporate officer.

14.5

Business functions arranged and sponsored by a Saint-Gobain organization and including third parties (e.g.,
customers or potential customers) where spouses have been specifically invited may have appropriate business
justification. The senior attendee from the sponsoring organization is responsible for obtaining pre-approvals
and for submitting the expense for reimbursement. For out-of-town functions, each employee must receive the
advance approval of the business units president or corporate officer.

14.6

Business justified spousal travel costs should be clearly reflected on the expense report in order for the Company
to comply with tax requirements. If there is no business justification for the Company costs incurred, the costs
will not be tax deductible by the Company.

14.7

Babysitting expenses will not be reimbursed in connection with employee or spouse travel or attendance at
business events.

15.0

MISCELLANEOUS
15.1

Laundry charges are generally not reimbursable. The manager should use judgment in assessing individual
situations. For example, if the traveler is away from home for more than five consecutive days on Company
business, reasonable laundry costs may be submitted for reimbursement.

15.2

Hotel movie rental charges and other types of personal entertainment expenses are not reimbursable. Other
examples of non-reimbursable personal expenses include reading material, sporting events, museums, and
theater tickets.

15.3

Personal care services for example, barber, manicurist, shoeshine, massage or other spa services are considered personal expenses and are not reimbursable. Similarly, except in the case of an unplanned overnight stay
during which the traveler must purchase essential personal care products, such items may not be submitted for
reimbursement.

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15.4

Damage to, or purchasing costs of clothing for personal use, even if associated with a business trip or function,
is considered a personal expense and should not be submitted for reimbursement.

15.5

The choice to purchase airline or other trip insurance is a personal decision, and a personal expense that will
not be reimbursed. Both American Express and Saint-Gobain Corporation programs cover business travelers.
Details of the American Express program are available on the Saint-Gobain Corporation intranet page for
Travel & Fleet Services. Details of the Saint-Gobain Corporation program are available from your human
resources representative..

15.6

Theft, loss or damage to personal luggage or personal effects is a non-reimbursable expense. If the loss or
damage is associated with air travel, a claim should be filed with the airline. American Express may also provide
coverage for loss or damage in excess of the amount reimbursed by the airline. Details of the American Express
coverage are available on the Saint-Gobain Corporation intranet page for Travel & Fleet Services.

15.7

Tips, other than when included in or added to a restaurant charge, must be separately reported. This includes,
for example, tips to hotel employees, parking attendants, or drivers.

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APPENDIX I: DECLARATION OF MISSING RECEIPTS


BUSINESS TRAVEL AND ENTERTAINMENT POLICIES AND PROCEDURES

EMPLOYEE NAME:

DATE:

EXPENSE REPORT GELCO NUMBER:

DATE

DESCRIPTION

AMOUNT

CERTIFICATION
In addition to the certification made in the Travel and Entertainment Expense Report, I hereby certify
that receipts for the above expenses are either non-existent or lost.

EMPLOYEE SIGNATURE

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APPENDIX II: MANAGER PRE-APPROVAL


BUSINESS TRAVEL AND ENTERTAINMENT POLICIES AND PROCEDURES

TRAVELERS NAME:

PURPOSE:

TYPE OF ITEM

Domestic business class airline travel


Advance purchase airline ticket
Business phone or ISP
Travel expense of spouse (1)
Entertainment expense of spouse (1)
Training course or Seminar
Customer trips or outings
Award trip for customers
In-home entertainment

POLICY

10.1
10.3
12.1
14.0
14.0
13.4
13.5
9.4

BRIEF COMMENTS

REQUIRED SIGNATURES

EMPLOYEE:

DATE:

MANAGER:

DATE:

CORPORATE OFFICER:

DATE:

(1) Requires approval by business unit president or corporate officer

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