Policy Name:

Travel & Entertainment Expense Policy

Issued to:

Oversight Employees & Contractors

Effective date:

December 21, 2022

Owner:

Finance Department

Sponsor Approval:

CFO

POLICY

This document outlines guidance and limits for all Travel & Entertainment (T&E) expenses incurred by Oversight employees and contractors who have out-of-pocket business expenses.

The T&E program is an employee reimbursement program whereby Oversight will honor the reimbursement of legitimate, in-policy and/or pre-approved expenses. Oversight expects that employees will use the same judgment and control in incurring Company expenses that a prudent person would exercise if incurring expenses on a personal basis. Employees with business expenses that are not reasonable, appropriately documented, properly authorized, submitted/approved in a timely manner and within the guidelines of this policy will be subject to repayment and/or disciplinary action.

Unless prior authorization is given, all business expenses are to be paid using the employee’s credit card. Oversight understands that this can be an inconvenience for employees, and that timely reimbursement for approved expenses is very important for personal financial health. On this point, Oversight will commit to reimbursing employees in no more than 15 days from Manager Approval in Concur.

PURPOSE

The purpose of the policy is to establish travel and expense guidelines for all departments and employees to follow. These guidelines are intended to ensure clear and consistent understanding of the policies and procedures, ensure compliance, and enable departments and Oversight to better manage their travel and expense budgets.

SCOPE

These guidelines apply to all Oversight employees and contractors who incur T&E expenses.

360 Interstate North Parkway SE • Suite 300 • Atlanta, GA 30339 • 770.984.4650 • www.oversight.com

RESPONSIBILITY

Employees should use discretion when making purchases for which they intend to be reimbursed and ensure that expenditures are necessary and appropriate for meeting business needs. In addition, Employees are expected to:

• Be familiar with and follow the policies and procedures specified in this manual

• Submit expense reports via Concur (with manager approval) to request reimbursement. This includes mileage reimbursement.

It is the Manager’s responsibility to review all expenses and related receipts, to ensure spending is consistent with the policy prior to approving such expenses.

Any questions related to the policy may be referred to the Employee’s direct manager and/or Finance@Oversight.com.

BOOKING TRAVEL

The following travel procedures are standard within Oversight. All Oversight Business Travelers or Travel Arrangers are expected to first look for flights, hotels, etc. using Expedia (or other discount sites) before booking directly from the airline/hotel as this is typically less expensive. Employees should begin to schedule their itinerary as soon as their travel dates and destination are known.

Frequent Flyer & Hotel Memberships

Many airlines, hotels and rental car agencies have frequent guest programs that reward travelers with free flights or accommodations. Rewards from such programs may be retained by travelers for personal use as long as there is no extra charge to the Company. However, participation in these programs must not influence airline or hotel selection to the detriment of Oversight costs.

AIR TRAVEL

• Whenever possible, employees are expected to book their travel arrangements at least 2 weeks in advance to secure availability and optimal access to the lowest fares.

• Employees are expected to choose the lowest logical fare available

• ALL AIR TRAVEL (domestic or international) MUST BE IN COACH/ECONOMY CLASS.

o However, in certain instances, business class may be approved for international flights longer than 6 hours, not including layovers. Airfare for these types of tickets must be approved by the executive leader (i.e. budget owner) in advance of the ticket purchase and evidence of approval must be submitted as part of the

360 Interstate North Parkway SE • Suite 300 • Atlanta, GA 30339 • 770.984.4650 • www.oversight.com

expense report (attaching an email will suffice). Any tickets purchased outside of the policy guidelines must be approved by the executive leader and such approval must be submitted with the expense report along with the receipt.

Flight Insurance

When purchasing airline tickets, flight insurance is not a reimbursable expense.

Ancillary Fees

The following ancillary fees are not reimbursable:

• Priority Boarding

• Seat Upgrades (i.e. Economy Comfort, Business Class, First Class)

Personnel Aboard the Same Aircraft

Departments are responsible for assessing the risk of the employees traveling on the same flight and adjusting travel plans as needed.

Airport Parking

• Travelers must use Economy/Long term parking when traveling on Company business, unless such lower cost parking is not offered by the airport.

• Short-term parking may be used for trips under 24 hours.

LODGING

It is expected that employees comply with the following:

• Employees, whenever possible are to use properties in the moderate category and costing less than $250 USD per night. Daily hotel rates for high-cost cities (Los Angeles, Boston, New York, Washington DC, Seattle, Vancouver, etc.) should receive manager approval if more than $350 per night. Note: Taxes are excluded from the hotel rate guidance. Individuals may upgrade accommodations at their own expense.

• International hotels should be reasonable and pre-approved.

• This policy does not apply if the employee is attending a convention or meeting and there is a negotiated meeting rate at the host hotel.

• Employees are required to obtain a detailed invoice/receipt from the hotel.

• Frequent traveler programs must not receive priority over cost savings for Oversight

• NON-Reimbursed Personal Expenses include luxury hotels, health spa, hair styling and haircuts, nail salons, massages, kennel expense for pets, babysitting fees, personal medications, extravagant tips, mini-bars (alcohol), entertainment expenses including movies in the hotel room, magazines or newspapers, laundry or dry-cleaning expenses for trips less than four nights.

360 Interstate North Parkway SE • Suite 300 • Atlanta, GA 30339 • 770.984.4650 • www.oversight.com

GROUND TRANSPORTATION

The most cost-effective means of transportation should be used while on Company business. Travelers should investigate the use of alternative transportation (i.e., airport shuttle, Uber, Lyft, etc.) before deciding to rent a car. Reasonable tips (in the 10-20% range) for ride-share drivers are eligible for reimbursement.

Automobile Rentals

Rental cars may be used in the destination city when the cost of taxi fares or ride share fees is estimated to be greater than that of a car rental.

• All car reservations must be made through Expedia (or other discount sites).

• Mid-size cars or smaller are to be rented unless business circumstances such as multiple employees traveling together warrant a larger vehicle.

• Rental cars should be returned on time and are to be refueled before return. Conduct a visual inspection of the vehicle with the rental agent before surrendering the vehicle.

• Every effort must be made to return the car to the original pick-up location.

• The rental car cost, tolls, and fuel are reimbursable expenses with rental cars.

Notes:

• Additional accident insurance will not be reimbursed.

• All drivers must have a valid driver’s license.

Rental Car Accidents

Should a rental car accident occur, travelers should immediately contact:

• Local authorities as necessary or required, especially in case of injuries.

• The rental Company and follow their prescribed reporting procedure.

• Keep all paperwork and email to Finance@Oversight.com

360 Interstate North Parkway SE • Suite 300 • Atlanta, GA 30339 • 770.984.4650 • www.oversight.com

Personal Automobiles

Employees may be asked to use their personal automobiles for Company business. Mileage for business travel plus actual tolls and parking is reimbursable. Mileage is to be calculated as the distance from home to destination, or office to destination, depending on the circumstance.

• In lieu of fuel purchases, reimbursement for the use of personal automobiles on Oversight business will be made at the current authorized IRS or local country guideline rate per mile.

• Fuel purchases will not be reimbursed for personal car usage.

• Mileage reimbursement must be requested through Concur. Attach appropriate documentation supporting mileage or use the mileage calculator function available in Concur. Comments must include description of trip, to/from location, beginning and end date of trip.

• Home to primary work location will not be reimbursed.

• It is the personal responsibility of the owner of a vehicle being used for business, to carry adequate insurance coverage for his/her protection and for the protection of any passenger’s costs for which will not be reimbursed by Oversight.

• Receipts for tolls and parking must be obtained and submitted. If no receipt is provided by the vendor, provide address of location, date, and pre-paid toll statement.

NON-Reimbursed Expenses

• Traffic violations of any kind

• Fuel, if mileage is claimed/submitted

MEALS & ENTERTAINMENT

See below for expense allocation instructions

Meals

• When more than one employee is present at a business meal, the most senior level employee should pay and expense the bill.

• Oversight will not be responsible for meal costs for special occasions, such as an employee birthday or retirement, unless pre-approved by manager.

Daily meal and incidental expenses should be kept at levels that are reasonable (not to exceed $75.00 in total for the day inclusive of tips) for the locations visited. As a guideline, daily meal expenses should be as follows:

A. $15 breakfast

B. $20 lunch

C. $35 dinner

D. $5 snacks

360 Interstate North Parkway SE • Suite 300 • Atlanta, GA 30339 • 770.984.4650 • www.oversight.com

Note:

a. Itemized detailed receipts* must be provided

b. Altered or generic receipts are not permissible

c. Any amount over a reasonable threshold may be subject to review.

*An itemized detailed receipt includes the merchant name, date of transaction, itemized listing of goods/services purchased, and a total of the transaction including tax.

Example of what needs to be submitted for a typical meal expense. BOTH the summary, showing the total AND the itemized receipt are needed in order to show all appropriate information.

Entertainment

Acceptable business practice includes entertaining commercial contacts under conditions conducive to business discussions. Such entertaining must serve a definite business purpose with a reasonable expectation of deriving business benefits. Meal expenses for entertaining

360 Interstate North Parkway SE • Suite 300 • Atlanta, GA 30339 • 770.984.4650 • www.oversight.com

commercial contacts should not be lavish or extravagant, but appropriate for the business purpose and must be approved by management.

NOTE: Internal Revenue Service (IRS) rules require appropriate and adequate documentation of the nature and reason for business entertainment. Proper documentation includes the names & affiliation of attendees and a general description of business discussed. Expenses or transactions which do not contain an adequate explanation in the comment section of Concur for entertainment can be subject to non-reimbursement.

Examples: Inadequate comments Appropriate and adequate comments

Dinner, Jack S, Mary K, John Dinner with clients from Lowes (Jack S & Mary K, Anil L), business reason 2022 specialty doors

L of Lowes Initiatives, include (Names of attendees from

Oversight)

Catering for team Catered, Support Team for closing 100% of tickets in March

(Brian J, Rochelle A, & Susan K)

Luncheon Luncheon for Sales team, exceeding

Sales goals for 1st quarter, (Shantelle A & Travis H)

COMBINATION OF BUSINESS AND PERSONAL TRAVEL

If an Employee combines personal with business travel, Oversight will not be responsible for out-of-pocket expenses, or those expenses incurred by a spouse or other individual accompanying an Employee on business unless approved by Management.

DOCUMENTATION AND APPROVAL OF EXPENSES

• All card transactions must be supported by itemized detailed receipts, allocated to the appropriate expense type, and submitted in the Concur system in order to be processed and paid.

• Receipts must be made readily available in Concur by the employee for review and approval by managers and for audit purposes.

• Receipts are required for transactions above $25. Any expenses for which there is no receipt, must be detailed in the notes section of the line item in the expense report with the individuals involved in the expense as well as the business purpose.

• Expenses that do not have proper documentation will not be reimbursed.

360 Interstate North Parkway SE • Suite 300 • Atlanta, GA 30339 • 770.984.4650 • www.oversight.com

SUBMITTING EXPENSE REPORTS

• All expenses related to the same trip/event must be reported on the same expense report. An exception will be considered for airplane tickets purchased in advance.

• One report can include multiple trips, however, each trip must be identified in the comment section by providing the client’s name.

• Expense reports are typically processed and paid every Wednesday. In order for a report to be processed on the next Wednesday, it should be submitted and approved by the manager Tuesday.

EXCEPTIONS

• Unless otherwise specified in this document, any exceptions to the Travel & Entertainment Policy must be approved in advance and in writing by the respective Oversight Leadership Team member.

*********Examples of Reimbursable and Non-Reimbursable Expenses**********

This is not intended to be an all-inclusive list. Employees are expected to use their best discretion.

Reimbursable Expenses:

• Airline Baggage Fees – Oversight will reimburse Employee for the cost associated with one checked bag.

• Airplane Wi-Fi for work purposes.

• Automobile rentals and related fuel cost.

• Mileage for travel when using personal vehicle

• Expenses associated with baggage handling, storage, and tips.

• Reasonable laundry and/or dry-cleaning expenses for trips longer than four nights.

• Lodging expenses.

• Personal meal expenses up to $75.00 per day including tips.

• Event catering or food purchases for meetings with clients.

• Transportation costs (railway, bus, Uber, Lyft, tolls, parking).

Non-reimbursable Expenses:

• Additional travel insurance, travel accident insurance or trip cancelation premiums.

• Any additional cost for booking a seat on board of a plane, upgrades to economy comfort, priority boarding.

360 Interstate North Parkway SE • Suite 300 • Atlanta, GA 30339 • 770.984.4650 • www.oversight.com