Travel & Expense Reimbursement Policy

2010

Travel & Expense Reimbursement

Policy

AMS Travel & Expense Policy 2010 - 2

To: All AMS U.S. Based Travelers

From: Tony Bihl

Subject: Travel Expense Policy

The attached policy results from a through analysis of our current travel practices. It defines appropriate spending levels for various expenses types, and outlines the basic controls required to properly account for expenses in a timely way. Please review the policy thoroughly and ensure that you are in compliance with all aspects of the policy.

Managers who approve travel expense requests must have a thorough understanding of the policy and are accountable for ensuring compliance to it, and for getting approval from their Vice President for any exceptions to policy.

Please direct any questions to your supervisor or to Julie Morey in Minnetonka, at 952-930-6146.


Travel & Expense Policy Table of Contents

Page Number

Introduction 2 Table of Contents 3 Purpose 7 Reference Documents 7 Responsibility 8 AMS Employee AMS Manager Finance & Accounting Department Employee Expense Reports 10

The General Procedures Receipts Electronic Expense Reporting Manual Expense Reporting

Corporate Credit Cards 12

Corporate Credit Card The Travel Department 13 On-Site Travel Agency Phone Numbers and Hours of Operation Traveler Profile Travel Reservations 14 Reservation Procedures Methods of Payment Weekend Travel Airline Travel 15

General Guidelines Using Restricted Airfares


Airline Upgrades Changing Airlines en Route Obtaining Credit for Unused Airline Tickets Frequent Flyer Programs and Airline Clubs Delays/Layovers/Denied Boarding Compensation Lost Airline Tickets Travel Insurance Joint Employee Travel

Hotel and Lodging 20 Reservations Cancellations Traveling Companions Lodging provided by Others Hotel Services Ground Transportation 22

General Guidelines Automobile Rental Rental Car Insurance Reporting a Rental Vehicle Accident or a Stolen Vehicle Other Ground Transportation Airport Parking

Entertainment 24

Entertainment Guidelines Employee Rewards Entertaining Health Care Professionals Gifts to Health Care Professionals

Gratuities 26 Meals 26

Meals Family Member Accompaniment Reporting

Business Use of Personal Vehicles 28

Reimbursement Guidelines Company-Provided Vehicles 28

General Provisions


Garaging Gasoline Car Wash Maintenance Auto Repairs Emergency Road Service Accidents, Parking Lot Locations & Vandalism Automobile Reimbursement Program Personal Use of Company Vehicle Request for Non-Policy Drivers Mileage Reporting New Car Ordering Procedure Safe Driving Policy Safe Driving Review Traffic Violations Trailer Towing Personal Property Protection of Personal and Company Property US-Based employees driving outside the U.S.

Telephone Expenses 36

General Guidelines Telephone Calls While Traveling Cellular Phones Corporate Sponsored Cell Phone Programs Cell Phone Accessories

Internet 36

Network Cards Hotel Internet

Other Reimbursable Expenses 37 Meeting and Group Travel 37 General Guidelines Sales Meeting Trade Shows Other Events AMS Meetings


Other Travel Services 38 VISA and Passport Services Other Services

Consultant Travel 38 Consultant Definition Consultant Travel Guidelines

Non-Reimbursable Expenses 39

Appendix A – AMS HCP Expense Reimbursement

Request Form 41

Appendix B – International Travel Airfare Reimbursement

Request Form 45

Document Maintenance/Approval Requirements 46


PURPOSE American Medical Systems (AMS) recognizes the importance of

travel and entertainment in conducting business, especially for the purpose of maintaining a positive working relationship with its customers and business partners. The purpose of this booklet is to outline AMS’ policies and definitions regarding travel and entertainment and the procedures for reporting and obtaining reimbursement for business related expenses.

This policy applies to all employees of AMS worldwide. However, certain references included in this policy may not be applicable to employees located outside the United States, due to program restrictions or local regulations. For example, corporate credit card, calling cards and corporate car programs are only available for U.S. based employees. Similarly, International employees should comply with local country regulations, which are not covered in this document. Questions regarding applicability of specific requirements to employees based outside the US should be directed to the Travel Manager or Corporate Controller.

REFERENCE DOCUMENTS

AMS Code of Business Conduct

Authorized Signature List

AdvaMed Code of Ethics

AMS Cardholder Agreement


RESPONSIBILTY AMS Employee

As an AMS employee, you are responsible for adhering to policies and procedures established to ensure we conduct our business appropriately and efficiently. You are responsible for the completeness and accuracy of your expense report. Your manager is also accountable for its accuracy. Any disputed amounts should be questioned and dealt with prior to submitting the expense report. It is the employee’s responsibility to provide complete and accurate reports. By submitting an expense report, you certify that the information you report is true, complete, and accurate. Good business practice, various regulatory agencies, the AMS Code of Business Conduct, and the AdvaMed Code of Ethics require that you adhere to the practices and procedures outlined in this policy.

Using Individual Judgment These guidelines are designed to help you understand what is in the best interest of the Company, your fellow employees, and those with whom we do business. Ultimately, however, you are responsible for exercising sound individual judgment and seeking input from your manager in deciding if an action or expenditure is appropriate. As you consider a particular situation, the following questions may help you arrive at an appropriate decision:

• Is my action consistent with approved Company practices? • Does my action give the appearance of impropriety? • Will my action bring discredit to a fellow employee if it is

disclosed? • Can I defend my action to my manager, other employees,

and to the general public? • Does my action meet my personal code of behavior? • Does my action conform to the spirit of AMS’ Code of

Business Conduct? • Does my action subscribe to the AdvaMed Code of Ethics?

The corporate expense reimbursement reporting system is offered to AMS employees as a privilege. Abuse of the system may result in the revocation of that privilege. Note: In short, always remember to use good judgment and common sense, and to seek advice from your manager when confronted with new, unclear or sensitive situations. You may also contact the Travel & Expense Manager or Travel & Expense Coordinator in Finance.

AMS Manager

By approving the expense report of an employee who reports to you, you indicate that:

• The expenses reported were incurred for an approved business purpose that is adequately documented and


described. • The expenses appear to be reasonable and in compliance

with the AMS Travel and Expense Policy, and that proper documentation is provided.

• The employee has signed the expense report. • Any disputed amounts should be questioned and resolved

with the employee prior to submitting the expense report to the Finance & Accounting Department.

It is your responsibility as a manager to approve all expense reports submitted for your approval on a timely basis. An approval time beyond three working days is considered excessive. Approvals not processed within seven days are forwarded to the next level manager by the Electronic Expense System (for those locations implemented on Concur).

AMS Finance & Accounting Department AMS Finance & Accounting Department (Finance) is responsible for processing all approved expense reports and for ensuring compliance with this policy. Finance will perform a complete audit on all expense reports submitted. Any findings of a questionable nature or abuse of corporate policies will be further investigated and communicated to the employee and his/her approval manager. If necessary, the abuse will be communicated to the functional Vice President and the Controller and could result in disciplinary action including termination of employment with AMS.

Finance will ensure an expense report has been received for all expenses processed on a Company-provided credit card. Finance is also responsible for providing timely reimbursement for all expense reports, whether submitted manually or via the Corporate Expense Reporting System.


EMPLOYEE EXPENSE REPORTS The General Procedure

Those employees who regularly incur out-of-pocket expenses for business purposes will be issued a corporate credit card.

To enroll in the corporate credit card program, an individual must complete an “AMS Cardholder Agreement” form.

The employee must submit an expense report within 14 days of the expense occurring with all receipts attached for manager approval. The AMS expense reporting system is offered to the AMS employee as a privilege. Abuse of the system may result in the revocation of that privilege. The expense report must be approved by your manager or, in their absence, by the next highest manager in the same reporting line who is authorized in the Authorized Signature List.

Submit your expense report and original receipts to your supervisor/manager within 14 days following the occurrence of the expense (in the case of credit card charges, 14 days from the time it appears on the statement). Managers are responsible for timely approval.

Receipts

Original receipts or approved documentation for all items $25 or more must be attached to the expense report. Every effort should be made to include receipts for all expenses, regardless of amount.

On its own, a credit card signature receipt is not a valid receipt. Take care to ensure that a receipt includes all necessary information. Whenever possible, provide restaurant receipts listing individual charges rather than credit card vouchers.

Restaurant tear slips are NOT acceptable.

Receipts must indicate proof of payment. For example, items such as ticket stubs for entertainment events must include a charge card receipt or cash receipt.

All receipts including but not limited to restaurant receipts must be

itemized. In the event of a lost receipt you will be able to submit a written

receipt with the approval of your manager. Please contact the T&E Coordinator to obtain the “Missing Receipt Form.” Finance maintains the right to limit the number of times the form can be used by any one individual or one trip. Managers should not be approving habitual missing receipts.


Electronic Expense Reporting

US-based employees with an AMS network email address are required to submit expense reports electronically via the Concur Expense Reporting system. Employees in locations that have not yet implemented the Concur Expense Reporting system must submit expense reports on the form approved by Finance for that location. Reports must be submitted within 14 days of the occurrence of the charges.

Manual Expense Reporting

Manual expense reports will be accepted only from employees who do not have access to an AMS Network email address, (for those locations which have implemented the Concur expense reporting system).

Reports must be submitted on the proper manual expense report form.

Reports must be submitted within 14 days of the occurrence of the charges.

Finance will process all properly documented and approved expense reports within 7 business days of receipt.

Any deviation from this policy that requires additional information and approvals will slow down the reimbursement process.


CORPORATE CREDIT CARDS AMS Corporate Credit Card

If you incur company related expenses on a regular basis, you will be issued a Corporate Card for all business-related expenses. To receive a card, you must complete an “AMS Cardholder Agreement” form and return it to the Travel & Expense Coordinator in Finance. Using the Corporate Card allows AMS to collect valuable information on airlines, hotel and restaurant chains, which we can utilize to negotiate corporate discounts and reduce overall travel and entertainment expenses.

The Corporate Card is offered to the AMS employee as a privilege.

Abuse of the credit card can result in the revocation of that privilege.

Key points relating to the Corporate Credit Card include:

• All “personal” charges and unauthorized expenses are the responsibility of the cardholder and will be deducted via a payroll deduction, as described in the AMS Cardholder Agreement.

• Charges: The Corporate Card should be used for all reimbursable business-related expenses, except where cash is the appropriate form of payment or in cases where the Corporate Card is not accepted.

• Credits: All business-related credits issued to you on your credit card must be accounted for on your next expense report.

• Alternate Cards: Use of personal credit cards for corporate charges is strictly prohibited unless your Corporate Card is not accepted by the merchant, or if your Corporate Card has been suspended or revoked due to late submission of expense reports or other issues. Employees with Corporate Cards suspended or revoked beyond 60 days are reported to the CFO.

• If your Corporate Card is not accepted by a merchant please notify the Travel & Expense Coordinator. This is important so that we can continuously improve the service of the AMS credit card program.

• If an expense report is not timely completed and prohibits AMS from being able to make payment within thirty (30) days of incurring the expense, AMS reserves the right to suspend Card privileges and hold you personally responsible for all applicable penalties and interest at the current respective rates of $29 late payment penalty and 19% interest (subject to change).

• If an expense report is not completed and payment not able to be made within sixty (60) days of incurring the expense, AMS has pre-authorized Fifth Third Bank to terminate the Card.

Department Travel Card

Those employees who travel on an infrequent basis and therefore are not issued a Company Credit Card, will have their airfare direct-billed to their assigned departments “ghost” card, with their managers pre-approval.


THE TRAVEL DEPARTMENT On-Site Travel Agency

To establish consistent, high-quality service to our travelers, AMS provides on-site representation through a contracted travel agency for all employee travel. The on-site Travel Department is located in the Minnetonka facility. In order to achieve maximum savings to the Company, all business travel arrangements for employees located in the US must be made through the on-site agency – this includes hotel arrangements, car rental, ground transportation, and all meetings involving hotel stays or hotel room rentals. All travel and lodging for our customers (including physicians, consultants and other guests to AMS) must be arranged through our on-site Travel Department.

Phone Numbers and Hours of Operation: On-site Travel Department: 8:00 a.m. to 5:00 p.m. Central Time Monday through Friday (952) 930-6510 After-Hours Emergency Service: (952) 831-2202 for all metro area calls (800) 827-1885 toll free Traveler Profile

All travelers are required to complete a confidential Traveler Profile. The Traveler Profile is important to assure that your personal preferences can be honored whenever possible. Updating your profile is your responsibility and should be done annually or whenever changes occur such as credit card number, department (cost center) number, or contact information.


TRAVEL RESERVATIONS Reservation Procedures

Company Policy requires at least a 14 to 21 day advance booking for travel. AMS employees are expected to travel at the lowest reasonable cost to the company. Therefore, all reservations are to be made at the lowest logical airfare (defined below), unless a valid business reason dictates otherwise. When making reservations, be prepared to provide the following information: • Departure date • Destination city • Preferred departure time adhering to “lowest logical airfare” two-

hour window definition • Preferred return flight date and time • Hotel needs • Car needs • Seat preferences (if not in profile)

Method of Payment All travel-related expenses, including airfare, will be charged to your

company-issued Corporate Card and will be billed in your name to AMS. Those infrequent travelers who do not have a Corporate Card may have their airfare direct-billed to your department’s ghost card with management pre-approval.

Personal/Business Travel and Weekend Travel

You are responsible for the cost of extending/interrupting a trip for your personal convenience. The Travel Department will book your tickets for personal/weekend travel, but any incremental cost must be paid by you within the current 14-day reporting period. This extra expense is not eligible for reimbursement. You must comply with the usual receipt and reporting requirements for all personal and/or weekend travel booked through the Company or as part of a company-related trip. All interrupted or extended trips need pre-approval by your manager.


AIRLINE TRAVEL Advance Purchase

A minimum of 14 to 21 day advance purchase is required on all airline tickets unless a valid business reason dictates otherwise.

Airfare Pre-Approval Domestic

All domestic airfare, over the designated threshold, requires an approving manager’s pre-approval before ticketing. To see the current threshold please refer to the Expense Reporting Systems home page or contact either the travel desk or travel manager.

International/Intercontinental All International and Intercontinental flights require pre-approval by

the employee’s manager. Airfare Guidelines– Within the US

Lowest logical airfare is defined as the most economical airfare available at the time of booking that enables business objectives to be met.

• Determined as the least expensive, restricted coach-class fare on the preferred carrier designated by AMS for a specific route.

• Lowest logical airfare is designated when the selected airline flight departs no more than two (2) hours before or after the traveler’s preferred time, and arrives within two (2) hours of preferred arrival time. Please use good judgment with regard to the difference in costs vs. flights that may be more than two hours from the preferred time.

• Requests for specific flights are accommodated if seats are available at the lowest logical airfare.

• A particular airline may be designated as the preferred carrier on a particular route. The Travel Department will advise you or your travel arranger if a particular airline is the preferred carrier on a particular route.

• When the route has not been assigned to a preferred carrier: the least expensive, restricted coach-class fare generally available.

Airfare – Outside the US All international travel must be pre-approved before ticketing.

Business-class fare is allowed when the one-way, non-stop flight time is nine hours or more or when the total flight time to a destination requires more than eleven hours of total flight time.


With the approval of a Vice President (or higher), business-class fare may be approved for travel in excess of seven hours, and only in situations where either the extremely the short duration or urgency of the travel does not allow adequate time for rest before arriving and going to work.

Travelers must book the least expensive coach-class fare when the one-way, non-stop flight time is less than seven hours. Upgradeable coach-class fare is allowed when the one-way, non-stop flight time is greater than seven hours. Travelers may upgrade to business class using their own frequent flyer miles; the travel desk may assist you. Some airlines will not allow anyone other than the traveler to upgrade using miles, in which case the traveler will need to contact the airline themselves. Note: No company paid first-class travel is permitted without the prior approval of the President/CEO or the functional Senior Vice President.

International Travel Reimbursement:

For travel from the United States to international destinations with a flight time of nine hours or more, the following additional rules apply:

• The business-class fare selected must be the lowest price fare available at booking, with minimum 7-day advance booking and a maximum of one connection.

• Employees electing to book an upgradeable coach non-stop direct or single connection fare, will be paid a pre-determined amount of gross compensation upon submitting proof of fare and completion of trip to the Travel Manager. These amounts are updated semi-annually and are available on the Corporate Travel Site. Appropriate payroll taxes will be withheld from this reimbursement. Managers are responsible for verifying the Cash Reimbursement Request Form, prior to submission to Payroll. See Appendix B for details on payroll reimbursement request.

Using Restricted Airfares

Generally, the lowest airfares are available only if the traveler meets certain conditions, the majority of which include: •Cancellation penalties •Advance purchase of at least 14 to 21 days, with a Saturday night stay •Refund restrictions


It is the policy of AMS to use restricted airfare. However, unrestricted airfare may be authorized under special conditions and must be approved by your manager prior to booking the flight if your trip is booked in advance and you are likely to change reservations after the initial booking. Most airlines’ policies allow trade-in of a non-refundable ticket toward the cost of a new ticket at an equal or higher fare as long as it is done prior to the travel time on the original ticket. Currently, most airlines charge a minimum fee of $100 to make changes to restricted airline tickets. AMS will reimburse you for fees imposed by the airline to change the itinerary (see restrictions below). The Travel Department will advise you when reservations can be confirmed at a restricted fare, and will inform you of the specific restrictions of the fare.

Change Restrictions It is understood that changes in flights must be made on occasion.

Because there is a minimum $100 fee for any changes in flights, good judgment and sound business discretion must be used. Indecision or poor time management are not acceptable reasons for changing a flight. All changes in flights should be carefully considered. Excessive changes in flights will be communicated to the functional VP and may be charged back to the individual.

Airline Upgrades

Once the lowest applicable airfare ticket has been purchased, you may upgrade the ticket at your own expense. You may arrange upgrades through the Travel Department, however many airlines will not allow the travel agency to upgrade your ticket and may require the traveler to make this request. You may obtain an upgrade to a higher class of service, provided that:

There is no increased cost to AMS. You must indicate on the expense report that there was no increased cost to AMS. No change is made to the lowest logical airfare obtained by the Travel Department

Preferred Seating

AMS will not reimburse the additional fee charged by an airline for a guaranteed preferred seat; you may purchase the guarantee at your own expense.

Checked Bag Fees

For all travel 5 days or less; AMS will reimburse you for one standard weight checked bag.


If traveling more than 5 days you will be reimbursed for two bags. If there are certain circumstances that require you to carry more than two bags, you will need prior pre-approval from your manager.

Changing Airlines en Route

Changing airlines while en route can dramatically increase the cost of the airline ticket. Whenever possible: Travel with the original airline and use the original ticket.

Make every effort to make en-route changes by calling the Travel Department (24 hour service).

If you make en-route changes directly with an airline ticket agent, be sure to obtain receipts from the ticketing agent whenever changes to the original ticket prices are made. Submit all receipts with your expense report along with a brief explanation of the flight changes, so that Finance can verify the correct charges.

Obtaining Credit for Unused Airline Tickets

For refundable tickets, notify the Travel Department for refund or credit as appropriate. Be sure to keep a copy of all credit documents for your records. Most non-refundable reservations must be cancelled before the travel time on the ticket. If this is not done, the ticket will have no value. Note: It is very important that you notify the Travel Department of any unused electronic tickets, as your notification is the only method to obtain a refund.

Frequent Flyer Programs and Airline Clubs

Because AMS recognizes the difficulty associated with business travel, you retain your own frequent flyer award miles. The Travel Department can enroll you in programs and will provide the information to the airline when it is part of your profile. However, the Travel Department will determine the most appropriate flights regardless of frequent flyer preferences. AMS does not reimburse an employee for the cost of any award or frequent flyer programs.

Delays/Layovers/Denied Boarding Compensation If you are unable to make a connecting flight because the first flight

has been delayed or canceled for any number of reasons, inquire about vouchers supplied by the carrier for overnight stays and meals. Note: airlines are not required to pay for hotel expenses if flights are canceled due to circumstances beyond their control such as weather.

If you receive compensation (monetary or voucher) due to voluntary


or involuntary removal (“bumping”) from a flight while on Company business, the compensation belongs to you if no additional cost to AMS is incurred (meals, lodging).

If removal from a flight results in additional cost to AMS, the compensation belongs to AMS. In this case, return the compensation together with your expense report and note the circumstances.

Travel Insurance AMS provides business travel accident insurance, which is detailed

in your benefit materials. Therefore additional travel insurance will not be reimbursed.

Joint Employee Travel The Company has a responsibility to its employees and

shareholders to ensure the continuity of overall operations provided by knowledgeable and experienced employees. To assure that this continuity of operation is not lost in a transportation disaster, the following guidelines should be adhered to, with exceptions only in extreme circumstances:

• No more than three (3) officers traveling on the same mode of transportation.

• No more than two (2) of the following officers on the same mode of transportation: CEO, COO, and CFO.

• A combined total of no more than five (5) officers and their direct reports traveling on the same mode of transportation.

• No employee may use private aircraft (owned or leased, including that owned or leased by health care professionals) for company business under any circumstances. Employees are not covered by any corporate insurance if such aircraft is used.


HOTEL AND LODGING Hotel and Room Selection

AMS preferred lodging is mid-size business class chains such as Hilton Garden Inn, Courtyard, or Holiday Inn. Hotels you select should be business-class, well-established, reasonable in price, in a safe location and conveniently located in relation to the work assignment. Give strong consideration to locations that would eliminate the expense of ground transportation such as auto rental and taxi.

Reservations

All hotel reservations must be made through the Travel Department or the AMS provided online booking tool for US based employees. The itinerary showing the hotel with the confirmed rate must be attached to your expense report. Your room reservations will be guaranteed using your Corporate Credit Card (or department “ghost” card, if you have not been issued a Corporate Credit Card)..

Cancellations

If you need to cancel a lodging reservation, inform the Travel Department as soon as you know that you no longer need the room. Generally, cancellations will be respected until 4 P.M. on the day of arrival, but should be attempted even later. Please note that some hotels have a cancellation policy of 24-hours or more. If you are unable to contact the Travel Department, it is your responsibility to call the hotel and cancel your reservation. Request the name of the person with whom you speak and cancellation number so that you will have recourse in case the charge appears on your credit card invoice.

Note: If you fail to notify the Travel Department or the hotel and do

not show, you will be charged the full hotel rate and will be personally responsible for these charges.

Room Rates

The rate quoted will appear on your invoice/itinerary. Hotel rates change frequently as a result of promotions or occupancy trends.

• Verify at check-in that the hotel charges do not exceed the room

rate confirmed by the Travel Department and noted on the itinerary.

• Report to the Travel Department any instance when a hotel

does not honor the room rate noted on the itinerary, since the Travel Department may be able to secure a refund from the hotel for the price difference.

• Occasionally, on the day of check-in, hotels are able to provide

a lower room rate than was available when reservations were made. Therefore, you are encouraged to ask at check-in if a


lower-priced room is available. • If you are unable to resolve a dispute on site, please contact the

Travel Department for problem resolution. Traveling Companions

Additional expenses incurred by non-approved companions are your responsibility and will not be reimbursed. Deduct additional expenses on the hotel receipt and reflect the net amount on your expense report.

Lodging Provided by Others

When family, friends, or acquaintances (exclusive of health care professional customers) are providing lodging it is permitted to offer an appreciation gift other than money or gift cards. Gifts for this activity should not exceed $25 and must be supported by a receipt. Any gift over $25 is not tax deductible by AMS. When lodging is provided by others, note this on the expense report, so that other activities, such as meals, (reported as entertainment) will be understood by the approver.

Services Reasonable room service charges are reimbursable. The use of in-

room beverage service is discouraged but is reimbursable within reason.

Calls from the hotel telephone should be avoided (and are

generally not reimbursed if you have been issued a Corporate cell phone) to avoid hotel-imposed premium charges.

Reasonable fees for use of exercise facilities incurred while

traveling are reimbursable as long as the exercise facility is in your hotel or if your hotel does not have an exercise facility you may use one close to the hotel. This does not include use of spa services, massages, etc.

Laundry and valet services Reasonable expenses for laundry services are reimbursable if the

trip is more than 5 days in duration, including weekends. Hotel expense reporting

Original itemized hotel invoices and credit card receipts must be submitted. Dates of hotel receipts must correspond with the expense report dates. Detailed charges from the hotel bill must be itemized separately on your expense report (meals, room, telephone, etc.)


GROUND TRANSPORTATION General Guidelines The method of transportation (rental car, airport limousine, and/or

public transportation) is dependent upon the location, duration and nature of the business trip. Do not automatically rent a car. Economical, suitable transportation services should be utilized. Many hotels/motels offer complimentary shuttle service. Rental of automobiles should occur when a large amount of local travel is expected. When traveling in groups, sharing of cars will be practiced to minimize costs.

Automobile Rental Automobile rental should be booked through the Travel Department

or the AMS online booking tool. AMS has a corporate agreement with specified car rental agencies and these will be the agencies used by the Travel Department. Car rental considerations: • Check with the car rental agency as to whether or not travel

across the United States border is permitted. • Unless there are special business requirements, request

intermediate cars. Any special requests require manager approval.

• Inspect the car for damage before departing the parking lot. • When personal activity interrupts or extends an automobile

rental, any additional expense is your responsibility. • The rental car should be returned fully fueled to avoid premium

charges for gasoline from the rental company. • Return the car to the rental location to avoid excessive drop-off

charges. Rental Car Insurance

When renting vehicles in the U.S., decline all insurance coverage (Collision Damage Waiver (CDW), Loss Damage Waiver (LDW), and Supplemental Liability Insurance (SLI)) AMS provides this insurance coverage. In all other countries (including Canada, Europe, and Australia) Bodily Injury Liability and Property Damage Liability coverage must be purchased. AMS provides Corporate Hired Auto Physical Damage Coverage. In the event of an accident, the rental agency will charge the credit card with an estimate of the damages. All accidents or damages to rented or company provided vehicles should be reported within 48 hours to the Travel & Expense coordinator.


Other Ground Transportation

When taxis, airport transportation services, and other means of ground transportation are used, reimbursement will be for the actual expense, including tip. Receipts must be attached for all transportation exceeding $25.00, including the tip. Car service to and from the airport is not a reimbursable expense unless you are accompanying a guest of the Company or where safety concerns are prevalent. You are encouraged to use no-charge hotel shuttle services whenever available.

Airport Parking

When traveling to the airport, balance the cost effectiveness of alternate ground transportation against airport parking fees. It is AMS policy to use off airport parking instead of airport short or long-term parking.

Parking/Tolls All daily parking and toll charges for business purposes are reimbursable. Reasonable overnight parking charges are reimbursable. Long-term airport parking is not reimbursable.


ENTERTAINMENT General Guidelines

• Entertainment costs include: amusement, social, cultural and

sports activities, meals, drinks, lodging, transportation, gratuities, etc.

• The purpose of entertaining business associates should be to

contribute, maintain, or improve relationships with existing or prospective customers or vendors, contributing generally to the development of AMS’ business.

• Business associates may include meetings among employees,

particularly employees from other AMS sites for the purpose of planning, relationship building and recognition.

• Such entertainment must be of reasonable value and not lavish

or extravagant. Entertainment must be appropriate as to time, place, kind, and guest, and should be infrequent.

• Entertainment should never be or appear to be provided as a

reward for doing business with the Company. • Gifts to employees (i.e., birthdays, birth of baby, Administrative

Day, etc) are not allowed a reimbursable business expense. See below regarding gifts to employees for service, retirement and performance.

Flowers to employees on the occasion of the death of a family member (as defined in the funeral leave policy), hospitalization of the employee and the arrival of an employee’s new child are paid for by AMS. These flower arrangements are to be made by the local HR department to avoid redundancy. In certain situations, floral gifts to physician business partners may be warranted; this must be arranged through the Corporate HR department. Any other floral giving is not paid by the Company and should be arranged outside of HR.

Special Notation: • Meals and entertainment expenses are generally only 50

percent deductible according to current IRS regulations. • You are responsible for using sound judgment in choosing a

restaurant. (Dine out as if you were using your own money.)

Employee Rewards

All employee gifts, rewards or contests are to be coordinated through HR in advance of the event or program. There are company-driven means to recognize service and retirement. Employees or tams may also be recognized through lunches, dinners, or events, covered within the Entertainment guidelines above. Please consult with HR as needed for guidance about group recognition.


Health Care Professionals

Refer to Appendix A of this Travel and Expense Reimbursement Policy for specific guidelines on reimbursed travel and expense policies for our health care professional business partners. Because AMS’ business focus frequently warrants the sponsorship of Health Care Professionals, you should be aware that the AdvaMed Code of Ethics has issued formal guidelines to their community on responsible standards for entertainment, gifts, and other subsidies. Additionally some states and countries have imposed even greater restrictions on how AMS may interact with Health Care Professionals licensed in their state or country. Be guided by these standards when planning to host or recognize physicians.

• Payments to doctors and/or hospitals or contributions of any

kind should not be made and are not reimbursable. • AMS interactions with Health Care Professionals should be

professional in nature and should facilitate the exchange of medical or scientific information that will benefit patient care. AMS does not provide or pay for any entertainment or recreational event or activity for any Health Care Professionals, their staff, spouse or guest. This includes theater, sporting events, golf, skiing, hunting, sporting equipment, and leisure or vacation trips. Such entertainment or recreational events, activities, or items should not be provided, regardless of: (1) their value; (2) whether AMS engages the Health Care Professional as a speaker or consultant; or (3) whether the entertainment or recreation is secondary to an educational purpose.

• AMS will not pay for meals, hospitality, travel, or lodging of

guests of Health Care Professionals or any other person, including spouses of health care professionals, who do not have a bona fide professional interest in the information being shared at the meeting.

• The value of the hospitality should be modest and infrequent

(maximum $125 per event). • The event should facilitate discussion among attendees, must

be appropriate as to time, place, and type of entertainment and should be infrequent.

• Any form of lavish or expensive entertainment, e.g. sporting

events, concerts and the theatre, are not allowed. Gifts to Health Care Professionals

Generally, gifts to Health Care Professionals are not allowed. Only modest gifts which benefit patients or serve a genuine patient education function are permitted. Any gift should have a fair market value of less than $100. Gifts of textbooks or anatomical models may exceed the $100 limit and should be reviewed with the


Corporate Compliance Officer in advance, if the $100 threshold will be exceeded. Cash or cash equivalent (e.g. gift certificates or gift cards) may not be given. • No branded promotional items may be given to Health Care

Professionals (i.e. pens and notepads). • Frequent gifts to the same individual are not allowed. • Documentation is required detailing the gift, its cost, the

recipient, and purpose. • Wedding gifts, baby gifts, birthday gifts, flowers, gift cards

and gift baskets of any kind to a physician or physician’s office or staff are not allowed.

GRATUITIES

Gratuities are to be no more than 20% of the total charge and are to be shown as a separate line item on your receipt.

MEALS

“Meals” are defined as breakfast, lunch, dinner and/or snacks of the individual employee. Meals with others (including other employees) are defined as “Entertainment” in this Travel and Expense Policy and when reporting expenses on the Expense Report. In the event you pay another AMS employee’s meal expense, report these expenses separately in the Entertainment section of the expense report. While traveling with fellow employees, report each person’s meal costs individually, whenever practical. If not traveling and there is a necessary reason to purchase meals for fellow AMS employees, note the expense in the Entertainment section of the expense report and include the reason for these expenses and a list of AMS employees who participated. When dining with fellow AMS employees, the most senior level person in attendance should pay for the meal. Actual, reasonable expenses incurred for your meals during travel are reimbursed by AMS, and must be recorded on your expense report as “Breakfast, Lunch or Dinner” on a daily basis.

Meals may be expensed up to the daily limit as determined by

AMS. For US based employees, this amount can be found on the Expense link on the network home page and is recalculated as necessary. As described more fully on this network home page, exceptions are made for reasonable variances in cities with higher average meal costs. Other employees should obtain these limits from their local Finance personnel. This rate applies to individual employee meals as well as group employee meals.

Meal reimbursement, when making customer calls within your

“home” territory, is not allowed.


Business meals or entertainment expenses among AMS

employees of the same location are strongly discouraged. A company purpose might be served if a member of management takes certain subordinates to lunch or dinner when visiting a remote location, or when subordinates are visiting from remote locations.

Likewise, meals for local subordinates as part of a planned program

or activity, or in limited cases, to discuss business projects, as a reward or celebration for a successfully completed activity and may serve a company purpose.

Use good judgment in choosing dining options. Meals among employees for the sole purpose to commemorate certain events (Holiday, Administrative Assistant’s Day, Boss’s Day, Birthdays, etc.) are not reimbursable.

Family Member Accompaniment

Generally, travel and entertainment costs are confined to those expenses of the employee and business guests. However, under limited circumstances, it may be appropriate for bona fide business purposes which is directly attributable to Company business and is necessary to the conduct thereof for a spouse, or other family member to be entertained at Company expense, or to accompany the employee on a business trip. However advance approval by the President and CEO or the functional Vice President is required and must be submitted in writing with the expense report. Company reimbursed expenses incurred for a spouse or other family member, without a direct business purpose, are taxable to the employee and will be included on annual government wage reporting statements (e.g. W2 for US employees).


BUSINESS USE OF PERSONAL VEHICLES Reimbursement Guidelines

If you use your personal vehicle for incidental business purposes, AMS will reimburse you as follows:

• Standard mileage reimbursement rate, as determined by AMS

and in compliance with IRS guidance in the U.S., plus parking and tolls for actual driving distance by direct route, less normal commuting mileage.

• Commuting expense is the cost of travel between your home and your regular place of work and is not reimbursed by the Company.

• If you choose to drive your car rather than fly to a business destination, your mileage reimbursement may not exceed the lowest logical airfare.

• AMS does not reimburse for gas, oil, service and parts, car washes, towing charges, or repairs to a personal car.

• An employee who uses a personal vehicle for business purposes is expected to provide minimum levels of coverage, currently defined as Bodily Injury ($100,000), Property Damage ($300,000) and Medical Coverage ($50,000) on that vehicle.

COMPANY-PROVIDED VEHICLES

AMS considers it essential to protect the safety and health of all its employees and the public through promoting the safe operation of every vehicle driven while on Company business. This applies to all employees who will be required to operate a vehicle in order to fulfill their job responsibilities.

General Provisions (US Field Personnel)

AMS has a lease car program designed to enable its field selling force to cover designated territories safely and efficiently. This policy establishes standardized methods of furnishing automobiles for the business use of eligible employees. All vehicles used in the line of company business will conform to the policy. Key provisions include: • The use of a fleet vehicle is provided to the AMS sales force as

a privilege that can aid in the efficient conduct of AMS business. This privilege can be revoked for any serious abuse.

• The fleet will be managed centrally to control costs, satisfy statutory tax requirements and assure adequate insurance coverage

• Business use shall be greater than 80%. If for some reason personal use exceeds 20%, the current IRS rate will be applied to the excess and added to your W-2.

• The policy will reflect a system identifying vehicle selections and standard options, which will be reviewed and established annually.


• Policies related to personal use of leased cars will comply with current tax regulations.

• The Company reserves the right to discontinue or change the lease plan for any or all users at the Company’s discretion at any time.

• AMS will consider substance abuse by an employee to determine fitness to continue operating a Company vehicle.

• The Company may terminate the employment of a contingently hired employee whose driver’s license restriction impedes the ability to operate a Company vehicle in the performance of the assigned job, unless the license restriction is vacated within ten business days.

Note: Disclosures—Employees are required to disclose immediately to their immediate supervisor, the following: the suspension, revocation, invalidation, or surrender of a driver’s license; citation or conviction for driving with designated drugs in the employee’s system or while impaired/intoxicated in violation of state laws; and all accidents involving Company vehicles. The occurrence of and/or failure to disclose these events may result in remedial and/or disciplinary action up to and including termination of employment.

• No vehicle shall be operated in a manner which subjects it to abnormal depreciation, for any illegal purpose or by a person under the influence of alcohol or drugs, or in any manner which could cause any required insurance under the lease to be suspended, canceled or inapplicable.

Garaging It is up to the assigned driver to provide for all storage and parking

when the car is not being used on Company business. Fuel

Individuals on the fleet program will receive a fuel credit card with their vehicle. This credit card should be used for all gasoline purchases. When it is not possible to use the gasoline credit card, expenses for gasoline should be submitted on expense reports for reimbursement. The receipts should note gallons purchased and the date.

Whenever you buy gasoline, use a regular grade of unleaded

gasoline: premium high test is not allowed. The Company will not reimburse for “incidentals” purchased along with gasoline (i.e. snacks, magazines, etc.)

Car Wash

Receipts for car wash expenses will be reimbursed (limit one per week).

Maintenance

It is the driver’s responsibility to maintain the interior and exterior of his/her assigned vehicle to a continuous high standard, which will


reflect favorably upon the Company, and will help preserve its resale value.

Always refer to the owner’s manual to determine if any repair work is under warranty. Major maintenance and repair under warranty must be done at a franchised dealership representing the vehicle make.

No alterations may be made to a fleet vehicle (e.g. adding trailer

hitches, radios, etc). The driver should monitor all repairs to ensure that labor performed

and parts replaced are valid charges. Routine work such as oil changes, lubrication, tune-up and

inspection should be done at the recommended times, using your Preventative Maintenance Program Coupon Book at the national accounts listed on the cover.

When it is impossible to obtain authorization for emergency repairs, a written explanation of the circumstances should be submitted with the driver’s vehicle expense report.

Auto Repairs

AMS, with our fleet vendor, provides a scheduled maintenance program. Each Company vehicle comes with a booklet containing coupons to be used for scheduled service. Additional services not covered by the coupons, but necessary to keep the vehicle in good condition or any repairs exceeding $400, must first be approved by AMS Sales Management.

If you neglect to maintain your vehicle according to the

maintenance schedule in the Owner’s Manual, you may be liable for the cost of repairs.

Emergency Road Service

If you have a vehicle breakdown (a vehicle that is not drivable) due to situations such as a dead battery, required towing or out of fuel, call 1-800-323-0637 and an Emergency Road Service Coordinator will assist you with your problem. You must supply them with the following information: • Your name • Your company’s name • Your vehicle number (last eight digits of your VIN) • An explanation of your problem • Year, make and model of the vehicle • Location of breakdown • Phone number your call is originating from Note: If you have a problem with your vehicle and the vehicle

is operable, do not call Consolidated Service Corporation’s Emergency Service Department. Instead have the vehicle serviced in the same manner as you have previously.


Accidents, Parking Lot Incidents & Vandalism The guidelines below apply to all of the following situations: • Your car comes into contact with another vehicle (collision). • Your car comes into contact with and causes damage to

another party’s property. • Your car injures another party (a pedestrian, a driver in another

car, or passenger in another car). • A passenger in your car is injured. • You are injured while driving your car. • Your car is damaged, in any manner, by unknown parties

(vandalism, parking lot damage, etc.) When involved in an accident it is a requirement to contact Police if the accident produces property damage over $100 or if there has been any personal injury. A copy of the Police Report must be submitted to the insurance company and to the Travel & Expense Coordinator in Finance, when it becomes available. When such an incident occurs, driver should contact the Fleet Provider insurance claims department as soon as possible. In the event of an after hours incident, the driver should contact the 24-hour Claims Services. Please provide the insurance company with the following information: name, employer (AMS), policy number, location of accident, injuries and damage. Details of the accident that are provided to the insurance company must include information on whether or not a cell phone was in use at the time of the accident and whether the cell phone is “hands-free” or not.

After the Accident

• The driver is responsible for arranging towing of vehicle, and if necessary, rental of car.

• Driver must notify the Fleet Provider’s insurance company of

selection of repair shop and provide a copy of one repair estimate.

• The insurance company will forward a copy of estimate to your

assigned Claims Adjuster for approval of repairs or possible appraisal of the vehicle.

Note: NO REPAIRS ARE TO BE COMPLETED WITHOUT APPROVAL FROM THE FLEET PROVIDER’S CLAIMS ADJUSTER.

Accident Resolution

• The insurance company will confirm with the Claims Adjuster if repair estimate is acceptable or whether appraisal is necessary.

• The insurance company will notify the driver of acceptance of

the repair estimate. If appraisal is warranted, the appraiser will contact the driver and/or repair shop to make arrangements.

• Driver will contact the repair shop to begin repairs.


• Driver is responsible for coordinating return of vehicle from repair shop.

Automobile Reimbursement Program

Members of the US Sales force, who wish to use their personal vehicle as their business vehicle, may do so through a corporate auto reimbursement program. This is an employee-provided business vehicle allowance program. The reimbursement factors within this plan consist of two items.

1. A Fixed Cost factor calculated for reimbursing plan participants monthly covering ownership related costs such as insurance, license, registration, taxes and depreciation. All ownership and operating cost factors are associated with a standard vehicle that we believe meets the needs of our plan participants. Reimbursements are customized to reflect geographic cost differences. Any AMS employee on the reimbursement program cannot submit expenses for any “car” related expense for any reason (car washes, gas, repair, etc.)

2. A Mileage Reimbursement factor calculated for

reimbursing plan participants for every business mile reported, covering mileage-related costs such as fuel, oil tires and maintenance.

AMS Human Resources and Risk Management personnel are authorized to conduct periodic reviews of the Department of Motor Vehicles driver’s record and accident history of any employee or prospective employee who is reimbursed through the reimbursement program. Such reviews could lead to revocation of the privilege of driving a vehicle while conducting business for AMS, should the driving and accident records be deemed sufficiently unsatisfactory.

Personal Use of Company Vehicle If you have a valid driver’s license, which is not revoked, or

suspended, in any state, you may use your fleet vehicle for personal driving. If your spouse has a valid driver’s license, which is not revoked or suspended in any state, he/she may use your fleet vehicle for personal driving. No one else may drive the vehicle at any time.

While an employee’s assigned company vehicle may be used by

the employee and his/her spouse for personal purposes during non-business hours, AMS strictly prohibits:

• Transport of a hitchhiker or stranger. • The use of the car to conduct any business other than

AMS authorized business.

Request for Non-Policy Drivers In emergency situations such as illness, injury or extreme fatigue, you may give permission to another licensed driver to temporarily relieve you. You must be present in the vehicle at all times.


Mileage Reporting

AMS must account for all business miles on company vehicles (in accordance with regulations set by the Internal Revenue Service for US based employees), and charge for personal use of company vehicles. Personal use charges are established yearly and collected as a monthly payroll deduction. It is critical that procedures established for reporting mileage be strictly adhered to.

The fiscal year for personal use imputation runs from November 1st through October 31st. The mileage data you report may generate an Imputed Income Statement towards the end of the calendar year which amount, if any, will be included on your W-2 form for that year. In addition to the miles you report as personal, all unaccounted for miles will be considered personal. The method by which the amount of imputed income is calculated is based on special valuation rules provided by the IRS. You will be informed of the particular method used to compute your imputed income each year, approximately at the time you receive your W-2.

The Company is required by law to withhold Social Security

(“FICA”) taxes on the imputed income resulting from your personal use of the company car. The Medicare portion of the Social Security taxes will be withheld on all imputed income. Social Security taxes will be withheld only if your salary does not exceed the FICA maximum for each year.

New Car Ordering Procedure

The Travel and Expense Coordinator will assist you in the selection and ordering of a new fleet vehicle.

Safe Driving Policy Practice safe driving every time you drive. Your safety and the safety of others depend on it. In addition to state laws requiring the use of safety belts, it is AMS’ corporate policy that all occupants of fleet vehicles use safety belts, regardless of the length or nature of the trip. All 50 states now have child passenger safety laws and it is AMS’ policy that child-restraint seats be used when appropriate in all states to protect young riders in your fleet vehicle.

You are responsible for driving your vehicle in a safe manner, maintaining your vehicle in a safe operating condition and in accordance with the maintenance schedule in your Owner’s manual, following all related company policies and procedures, and abiding by all driving laws. As stated, only you and your spouse are authorized to drive your company vehicle. You must maintain a valid driver’s license for the state in which you are living.

If, for any reason, your license to drive is suspended or revoked, you are required to contact your supervisor and Human Resources immediately.

A defensive driving course should be taken periodically to help keep

skills fresh. AMS may provide such courses and can require participation. Such courses are aimed at facilitating safe driving and


preventing accidents. As stated previously, AMS Human Resources and Risk

Management personnel are authorized to conduct periodic reviews of the Department of Motor Vehicles driver’s record and accident history of any employee or prospective employee who is or will be required to operate a company-owned or company-leased vehicle. Such reviews could lead to revocation of the privilege of driving a company-provided vehicle, should the driving and accident records be deemed sufficiently unsatisfactory that they lead to exclusion from AMS’ auto insurance policy or exceed standards recommended by AMS’ insurance carrier

Traffic Violations

Should you, for any reason, receive a summons for a traffic violation, you must pay it as soon as possible. You are responsible for paying all violations, including penalties (if any). Under no circumstances are you to charge this expense to AMS. If you are found to have any outstanding violations, your company car may be subject to removal.

Trailer Towing Trailer towing for personal reasons is not permitted.

Personal Property Personal items lost or stolen from a leased car are not insured by the Company and are the driver’s responsibility – generally through homeowners or renters insurance coverage. Company products stolen from vehicles are to be reported to the Travel & Expense Coordinator, who will work with Risk Management to submit an insurance claim, if appropriate.

Protection of Personal and Company Property

Use common sense with cell phones, laptop computers, and other items, by placing them in the trunk, or taking them with you when the vehicle is parked in a public place for any period of time.

Personal use of company-owned or leased vehicles, garaged at AMS, is prohibited.

US Based Employees Driving Outside the U.S.

Before taking a Company-provided vehicle into Canada or Mexico, whether for business or personal use, you must notify the Travel & Expense Coordinator in Finance. Advise us in writing at least two weeks before your scheduled trip. We will send you authorization and proof of insurance.


TELEPHONE EXPENSES General Guidelines

In general, AMS will reimburse the cost of making business calls while at home or on the road provided you have not been issued a Corporate Cell Phone. With the advent of telephone deregulation, telephone bills have become complex. Consequently it is encouraged that you submit the entire original phone bill for reimbursement and highlight the selected calls for which you are seeking reimbursement.

Telephone Calls While Traveling

Reasonable, periodic personal phone calls are reimbursed by AMS provided you have not been issued a Corporate Cell Phone. Reimbursement will be evaluated on an individual basis. If you have a company issued corporate cell phone, use it for all long-distance business calls.

Cellular Phones AMS will not pay for monthly personal cell phone plans that are not part of the Corporate Cell Phone program.

Corporate Sponsored Cell Phone Program

AMS has a corporate account with both AT&T and Verizon Wireless, to provide cell phone service when necessary for AMS employees, wherever service is available. Billing for either of these accounts is direct to Corporate and is charged back to the individual’s department. All phones must be ordered through the IT Service Desk. If you are supplied with a Corporate Cell Phone you will not be reimbursed for additional phone charges. Please refer to Wireless Services Policy for more information.

Cell Phone Accessories

The Service Desk will only order the wireless device itself. Any additional accessories needed must be pre-approved by your manager and purchased through company purchasing processes (e.g. credit card, purchase order, check request).

INTERNET Network Cards

Additional internet charges will not be reimbursed if you have a network card.

Hotel Internet

Reasonable hotel internet charges will be reimbursed when traveling on AMS business.


OTHER REIMBURSABLE EXPENSES Employees should discuss any other expenses incurred in the normal course of business, but not specifically addressed in this Travel & Expense Policy, with their manager and consult the Travel Manager to determine reimbursement policies.

MEETING AND GROUP TRAVEL General Guidelines

Group travel represents a significant opportunity for discounts to AMS; therefore the following guidelines should be used whenever possible. • When 10 or more are traveling to the same destination for a

common purpose an air contract will be negotiated by the travel manager

• Hotel site inspections must be pre-approved through the travel manager to ensure there are not duplicate inspections.

• Trips for the sole business purpose of conducting site inspections are not allowed if the total cost of the meeting will not exceed $50,000.

• The Travel Manager must pre-approve the use of all third party planning agencies.

Sales Meetings Group travel to sales meetings will be coordinated through AMS’ Travel Department.

Trade Shows Group travel to trade shows will be coordinated with AMS’ Travel Department. If you are assigned to attend a trade show, contact the Travel Department as soon as possible so group travel arrangements can be made.

Other Events If you are planning to attend a non-AMS trade show, meetings, or seminar, provide the Travel Department with any available information regarding group rates through the event’s organizers.

AMS Meetings If you are planning a meeting, provide the Corporate Travel Manager with the city, preferred hotel and approximate number of attendees. The Corporate Travel Manager will negotiate hotel contracts and get airline discount contracts if there are enough attendees to warrant contract pricing.


OTHER TRAVEL SERVICES VISA and Passport Services

The Travel Department can assist with arrangements for visas and passports, as well as supply information regarding medical inoculations/requirements. • To obtain a passport, you must have a recent photo, of a

specific size. Contact the Travel Department for assistance. • AMS will reimburse the cost of passports, visas, photos, and

any inoculations required as a result of company business-related travel.

Other Services

The Travel Department offers additional services including lost luggage service, visa and passport arrangements, translation services and more. Contact the Travel Department for more information.

CONSULTANT TRAVEL Consultant Definition

A consultant is defined as a Health Care Professional or other individual or entity who posses unique knowledge, skills or services for which AMS has a Legitimate Business Need and has entered into a written agreement.

Consultant Travel Guidelines

AMS will reimburse for all reasonable travel-related expenses (including transportation, modest food and lodging) incurred in connection with performing the services required by the Agreement. AMS must authorize any travel and that travel (air, ground transportation and hotel) should be booked through the AMS travel desk. The same guidelines and restrictions used for AMS employees are to be used for Consultant travel. AMS will pay for reimbursable expenses within thirty (30) days after submission of a statement containing the dates of travel and receipts of all the related expenses.


NON-REIMBURSABLE EXPENSES

It is the Company’s policy to reimburse the employee for all reasonable and necessary expenses incurred in transacting the affairs of the business. However, there are specific types of expenses that are considered to be of a truly personal nature and are non-reimbursable.

Use Good Judgment.

The following list is not intended to be all-inclusive, but to show examples of such non-reimbursable expenses:

• Additional costs for transportation, meals, and lodging incurred

when personal travel is combined with a business trip. You should identify such costs and adjust the expense report accordingly.

• Airline upgrade certificates • Automobile Clubs, e.g. AAA • Corporate Credit Card late fees

• Car rental costs over standard vehicle model or level • Cash gifts of any type • Child care costs while entertaining or on a business trip • Clothing or toiletry items • Commuting to or from work during regular business hours • Computer equipment (should be ordered through the Corporate

IT department) • Contributions or donations of any type, including support of

community/youth athletic groups (Requests for such contributions must be made through the AMS Corporate Compliance Officer or Human Resources).

• Employee gifts (Holiday, Birthday, Boss’ Day, Administrative

Assistant’s Day, Retirement, etc.) • Flowers not ordered through the HR department • Entertainment or recreational activities for personal reasons • Entertainment of spouse not on approved business • Fines for traffic violations, parking tickets, or related

towing/storage charges • Hair care, shoeshine, massages or similar services • Insurance (as this is provided directly by the Company): Travel

accident insurance, collision damage, or other insurance provided by rental car companies (excluding international


travel); travel insurance purchased from an independent insurance company.

• Laundry expenses for business trips of four (4) days or less. • Loss of personal property, such as luggage, briefcases,

computers, computer carrying cases, etc., including items stolen from rental cars

• Luggage purchases • Memberships in social or athletic organizations • Office equipment, including phones, fax machines, copiers, etc.,

unless instructed to do so by the Corporate IT department (include documentation of pre-approval in request for reimbursement).

• Pay-per-view movies in hotels and motels • Pet care and boarding while you are entertaining or on a

business trip

• Physician gifts or payments of any type • Subscriptions to newspapers, magazines, or books for personal

reading (Business literature may be purchased through Library Services.)

• Telephone extra line charges in your home • Unauthorized trips, entertainment, gifts, or donations • Repairs, maintenance or insurance on personal vehicles


Appendix A

AMS HCP Expense Reimbursement Request Form

AMS adheres to the AdvaMed Code of Ethics on Interactions with Health Care Professionals, IRS and other pertinent guidelines and regulations regarding reimbursement specifications for travel expenses or other associated expenses. Please enter all allowable expenses as defined by the AMS HCP Expense Reimbursement policy and definitions on pages 3-4, in the spaces provided below. To be reimbursed, the following section on the AMS HCP Expense Reimbursement Request must be completed and submitted as soon as possible. AMS requires original itemized receipts for all expenses with the exception of mileage, tolls and tips. In addition, please note that IRS regulations state that credit card statements are not accepted as sufficient documentation of expenses. AMS assumes that the physician submitting the reimbursement attended an event with duration of one day.

Requester Name (please print):

Note: The Sub Form W-9 on Page 3 is required for payment.

Event Name:

Event Location: (City, State): Event Date:

Day

Date

Mon

/ /

Tue

/ /

Wed

/ /

Thur

/ /

Fri

/ /

Sat

/ /

Sun

/ /

GROUND TRANSPORTATION (i.e. taxis, commuter bus, shuttle) :

PARKING (i.e. hotel/event parking,

airport parking):

NON-AMS PROVIDED MEALS2:

AIRFARE3

LODGING3:

MILEAGE4 @ $0.50 per mile:

______ miles x .50 =

INCIDENTAL EXPENSES5:

Daily Totals:

Reimbursement Total:

2Except as pre-approved and documented by an AMS representative. Breakfast and lunch are provided by the hotel and paid for by AMS at AMS-sponsored events. See acceptable spending limits on page 3. Exceptions will be reviewed on a case-by-case basis e.g. diet requirements. AMS reserves the right to deny reimbursement for meals, based upon what AMS has determined to be reasonable and modest and in compliance with applicable state and federal laws, AdvaMed Code of Ethics and other pertinent guidelines and regulations.

3Lodging and airfare reimbursements will be reviewed on a case-by-case basis. AMS reserves the right to deny reimbursement for airfare and lodging in compliance with AMS’ Policies, applicable state and federal laws, AdvaMed Code of Ethics and other pertinent guidelines and regulations. Airfare is booked at the lowest logical coach airfare or at the conference rate, whichever is lower, and within a reasonable timeframe. See detailed requirements on page 3.

4 Mileage reimbursements are for personal car use only. Reimbursement rate is determined by the Internal Revenue Service. Gas is included in the mileage reimbursement and is not a separate reimbursement.

5See page 3 for detailed requirements.

I have read the attached AMS HCP Expense Reimbursement Policy and definition guidelines and agree to all terms listed. I understand and agree that all expenses submitted are subject to review and approval by AMS, and that AMS reserves the right to deny reimbursement, in full or in part, based upon what AMS has determined to be reasonable and modest and in compliance with IRS regulations, applicable state and federal laws, AdvaMed Code of


Ethics and other pertinent guidelines and regulations.

Requester Signature: Date:

Please Print Name:


AMS HCP EXPENSE REIMBURSEMENT POLICY

Lodging (original receipts are required for this type of expense)

Please call our Travel Desk at least 10 days in advance to make reservations through AMS. Reservations will be made for you by AMS at AMS’ contracted hotel. If permissible, AMS will prepay the room rate and applicable tax only. If prepayment is not provided, the hotel room rate and applicable tax will be charged to your credit card. Please note that AMS will not reimburse for any room upgrades and/or other hotel accommodations.

Air Fare (original receipts are required for this type of expense)

All travel arrangements are to be made through the AMS Travel Desk. Please call our Travel Desk at least 10 days in advance to make reservations through AMS. AMS will pay/reimburse*: - Airfare at the lowest logical coach price when flight time is less than 7 hours.

- Upgradeable Coach-Class fare when one-way flight time is more than 7 hours in duration - Business Class only when one-way, non-stop flight time is more than 9 hours in duration or total flight time

requires more than 11 hours in duration

AMS does not reimburse for: - expenses associated with the use of privately owned aircraft - airfare for private charter planes

*Note: Travelers may upgrade to business or first class using their own frequent flyer miles only; the travel desk may assist you. Some airlines will not allow anyone other than the traveler to upgrade using miles, in which case the traveler will need to contact the airline directly.

Ground Transportation (original receipts are required for this type of expense)

Ground transportation between home, the airport and the meeting location, by shuttle, taxi or commuter bus will be reimbursed.

Parking (original receipts are required for this type of expense)

Includes hotel/event parking, and airport parking for personal car.

Mileage Reimbursement Ground transportation to/from the HCP’s home and the airport and/or to the meeting location or AMS arranged event location. Reimbursement is for use of HCP’s personal car in lieu of traveling by commercial airline and will be limited to the lower of $0.50 per mile or the applicable lowest logical coach airfare.

Modest Meals (original receipts are required for this type of expense)

AMS will reimburse for actual cost of meals in restaurants up to but not to exceed the maximum dollar amount of $100, inclusive of taxes and tips. The allowable amount is restricted to the cost of food and drink for the Health Care Professional only.

Incidental Expenses (original receipts are required for this type of expense with the possible exception of Tolls & Tips)

AMS will only reimburse reasonable incidental expenses not associated with meals for:

o Tips for sky caps, bellmen, etc. o Tolls o Snacks and beverages

• Examples of incidental expenses that will not be reimbursed include: o Hotel and airline movies o Greens fees, tennis court fees, ski lift tickets, health clubs, etc. o Reading material not directly related to AMS business

Guest (Immediate Family, Relative, friend)

In accordance with AdvaMed Code of Ethics and, AMS will not reimburse any expenses for an accompanying spouse, relative or friend, who do not have a bona fide professional interest and business purpose, directly or indirectly associated with the AMS sponsored event.

Additional Restrictions May Apply

Some States, countries and individual institutions do not allow or may restrict reimbursement for travel, lodging, meals or other expenses. AMS will comply with those additional restrictions on reimbursement when they apply.


DEFINITIONS

Allowable Expenses refers to those expenses that are approved by AMS, as defined in the AMS HCP Expense Reimbursement policy, and that are in accordance with IRS regulations, AdvaMed Code of Ethics and other pertinent guidelines and regulations.

AMS Representative are persons, acting within the scope of their engagement, expressly authorized to act on behalf of AMS under a contract or relationship of agency to sell or market AMS products and services, and who are subject to the control and consent of AMS to act on its behalf.

Business Purpose means for the purposes of: 1) explaining the features, use or other important aspects of AMS products; 2) understanding the product-related service or other concerns, needs or demands of a Customer; Case-by-Case in the context of exceptions refers to either a particular instance of an event or action, or a list of events or actions that are known and can be specifically identified at the time the exception is granted.

Customer(s) is any person, other than an individual patient, including, without limitation, any medical or health care professional or entity in a position to purchase, lease, recommend, use, influence or arrange for the purchase or lease of, or prescribe AMS products.

Lowest Logical Fare is defined as the most economical airfare available at the time of booking that enables business objectives to be met and ensures effective use of the traveler’s time.

Modest means (1) with respect to meals and receptions and any other expense for which there are established spending limits, an amount consistent with the Spending Limits.

Spending Limits are limits for expenditures permitted under the AMS HCP Expense Reimbursement Policy, based on industry standard and in accordance with AdvaMed Code of Ethics and other pertinent guidelines and regulations.

Training and Education means training and education to explain the safe and effective use of AMS products, including 1) training on how to use or implant a AMS product which includes via live surgery and cadaver and other lab environments 2) training on indications or therapies appropriate for use of a AMS product, including education regarding product-related disease states and the appropriate use of the product in the continuum of care; and 3) training on the quality, properties and/or design characteristics of a AMS product, to the extent that such training provides health care professionals information on how to use that product safely and effectively.

AMS sponsored event includes but is not limited to any marketing presentations, sales presentations, training and education events.


Purpose of Form

AMS requires that a record be kept of any individual or business that receives a payment from us, whether for services rendered, goods provided or any other circumstance for which monies would be paid. AMS uses the following Substitute W-9 form to create a vendor record for an individual or business. This form also meets the requirements of the IRS Form W-9, Request for Taxpayer Identification Number. An employer identification number, or EIN, is also known as a taxpayer identification number, or TIN.

Disclosure and Privacy Act Notice

AMS is requesting your Taxpayer Identification Number (TIN) to satisfy the requirements of Federal and State law. Section 6109 of the Internal Revenue Code requires that you provide your correct TIN to be used on information returns (Forms 1099) filed with the Internal Revenue Service. Your US Taxpayer Identification Number (TIN) must be provided regardless of your tax status in order for payment to be issued. AMS is required to withhold 28% of taxable interest, dividend, and certain other payments to a payee who does not provide a TIN. Willfully falsifying certifications or affirmations may subject you to criminal penalties including fines and/or imprisonment. Failure to provide your TIN could result in backup withholding and penalties. Any penalties assessed against AMS for failure to provide your correct TIN or SSN to federal and state authorities will be passed along to you. If individual payment requests reach and exceed $600.00, AMS is required to report the amount to the IRS on a 1099 Miscellaneous Income Form. AMS will not disclose your TIN or SSN to anyone outside the company except as mandated by law.

Please print or type: If check should be payable to an individual, leave business name blank and provide your home address:

Certification

Under Penalties of perjury, I certify that:

1. The number shown on this form is my correct taxpayer identification number, and 2. I am not subject to backup withholding because:

a. I am exempt from backup withholding, b. I have not been notified by the Internal Revenue Service (IRS) that I am subject to backup withholding as a result of a

failure to report all interest or dividends, or c. The IRS has notified me that I am no longer subject to backup withholding and

3. I am a U.S. person (including a U.S. resident alien).

Certification instructions. You must cross out item 2 above if you have been notified by the IRS that you are currently subject to backup withholding because you have failed to report all interest and dividends on your tax return. For real estate transactions, item 2 does not apply. For mortgage interest paid, acquisition or abandonment of secured property, cancellation of debt, contributions to an individual retirement arrangement (IRA), and generally, payments other than interest and dividends, you are not required to sign the Certification, but you must provide your correct TIN. (See the instructions on page 4.)

The Internal Revenue Service does not require your consent to any provision of this document other than the certifications required to avoid backup withholding.

Signature: Date:

Print your name:

Legal Name (as shown on income tax return): Business name (if different from Legal Name):

Social Security Number (Individual or Sole Proprietor) _______-____-________

Check appropriate box:

Individual (not an actual business) Corporation

Sole Proprietor (individually owned business) Partnership

Other __________________________

Employer Identification Number (Business) ____ - __________________________

Address (number, street, and apt. or suite no.)

City, state, and ZIP code

Substitute Form W-9


Appendix B

International Travel Airfare Reimbursement

For travel from the United States to international destinations with a flight time of nine hours or more, the following additional rules apply:

• The business-class fare selected must be the lowest price fare available at booking, with minimum 7-day advance booking and a maximum of one connection.

• Employees electing to book an upgradeable coach non-stop direct or single connection fare, will be paid a pre-determined amount of gross compensation upon submitting proof of fare and completion of trip to the Travel Manager. The reimbursement amount is updated semi-annually and is available on the Corporate Travel Site. Appropriate payroll taxes will be withheld from this reimbursement. Managers are responsible for verifying the Cash Reimbursement Request Form, prior to submission to Payroll.

Request for Reimbursement (Rev 08/2008)

Employee Name _______________________________ Cost Center ________________________

Dates of travel ________________________________ Destination _________________________

Type of fare:

_______ Upgradeable coach flight - $900 gross compensation to employee

Employee Signature Date

Manager Signature Date

Please attach copy of itinerary and boarding passes and submit to Travel Manager in Finance/Mtka.


DOCUMENT MAINTENANCE/APPROVAL REQUIREMENTS

This document will be maintained by Finance and Accounting Department (Controllers Organization). Approval Requirement's: CEO and CFO

Travel & Expense Reimbursement Policy

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Transcript of Travel & Expense Reimbursement Policy