Travel & Expense Policy

I. Purpose:

To provide Gilbane Inc. (Gilbane) policies and guidelines for travel and other business expenses and to communicate the procedures for expense report reimbursement. Adherence to the policies and procedures contained here will help to insure that appropriate/reasonable business expenses are incurred, are properly documented consistent with Company and Internal Revenue Service requirements, and have been reviewed/approved by supervisory management prior to reimbursement. It is the policy of the Company that all business travel is to be arranged in the most economical yet efficient manner possible and, to the extent possible, should be arranged so that travel occurs outside of normal business hours in order to maximize the business day. The employee’s immediate supervisor should authorize all business travel in advance.

II. Scope:

This policy is applicable to all employees of Gilbane, its subsidiaries, as well as contractors/consultants doing business on behalf of Gilbane who request reimbursement of expenses in their contract.

III. Key Requirements:

1. The Company will reimburse employees for travel and other business expenses that are reasonable and necessary to accomplish a Gilbane business purpose. Specific guidelines around travel and other expenses such as entertainment, lodging, etc. are contained in the applicable sections below.

2. ALL airline arrangements must be made through the Company-designated travel management partner, FCm Travel Solutions. Wherever practical, alternatives to travel, such as web-based shared presentations, telephone or video conferencing should also be considered.

3. Travel and other business expenses shall be reported on the Company travel and expense report; see attached Supplement 1, also available on the intranet.

4. Original receipts for any expenses over $25.00 must be attached to the expense report for all business expenses not covered by the per diem. Receipts shall preferably consist of the detailed receipt from the establishment rather than a credit card charge receipt. For any missing receipts, a credit card statement will be accepted if accompanied by adequate written explanation.

5. Unless otherwise evident, travel and other business expenses, particularly entertainment expenses, shall be sufficiently documented as to purpose, business affiliation with the person(s) entertained, employee and non-employee individuals in attendance, and nature of the business discussed.

6. Managers and Supervisors are responsible for reviewing and approving their direct report’s expense reports to insure the expenses incurred are proper, adhere to policy, and have appropriate supporting documentation in accordance with Company requirements. Additionally all employee expense reports will be subject to audit by the respective office accounting department. Any non-compliance will be reported to the applicable employees and their manager for resolution prior to processing for payment. Expenses not in compliance with Company policy, including travel booked outside of the designated travel management firm will be rejected.

7. FCm Travel Solutions now offers Gilbane travelers two booking methods for booking travel;

A) Agent assisted (traditional calling into an agent) and

B) Concur Travel & Expense - an online travel and expense tool. This is located on the gnet portal under Quick-Links-Employee Travel & Expense.

8. Concur Travel and Expense is the preferred method for booking travel as it offers a significantly discounted fee versus the fee for an agent assisted reservation.

9. FCm offers Emergency Travel Center (ETC) service for all urgent after hours situations from 8 pm ET. You may contact FCm’s ETC by calling 866-637-1354 and citing your access code IO80. Please note, each call to ETC results in an additional fee and should only be used for emergencies.

10. Gilbane travelers are responsible for payment for all their respective travel expenses using either the company sponsored US Bank Visa or their own personal credit card. An employee may apply for a US Bank Visa by contacting their respective regional controller and completing an application.

11. When multiple Gilbane employees are traveling together then the most senior ranking employee shall be responsible to pay for group meals, entertainment or other business expenses.

12. Expense reimbursement requests should be submitted in a timely manner, preferably within 7 days of the expense transaction.

13. Employees are required to enroll in the direct deposit program for expense report reimbursements (see Supplement 2 for enrollment form). Properly completed and approved expense reports shall generally be reimbursed to the employee within the next Expense Reimbursement Cycle after receipt by Accounting. (See Supplement 3 for the Expense Reimbursement Cycle.)

14. Certain expenses are typically not considered appropriate business expenses and, accordingly, may not be submitted for reimbursement. Refer to Section V for a list of these expenses.

15. Misrepresentation of expenses or other significant violations of this policy by an employee will result in corrective action, up to and including termination of employment.

IV. Specific Expense Guidelines:

A. Air and Rail Travel

1. Employees are required to book all air and rail tickets through FCm Travel Solutions in order to track costs, to adhere to policy compliance, utilize company and agency contracts and for safety tracking. Reimbursement may be delayed or rejected for travel not booked thru FCm.

2. Employees are expected to travel in coach class on all airline domestic trips.

3. All employees shall use the lowest fare routings offered. Preference for specific airlines for the purpose of accumulating mileage must not influence air travel arrangements or add incremental cost. You are not authorized to purchase up fares (full Y fares) in an attempt to upgrade based on mileage and/or status. This will be considered an exception and reported to Senior Management. Employees will only be reimbursed for the equivalent coach fare in the event they chose a more expensive class of travel.

4. Refundable fares are permitted and should be considered when the difference in non-refundable vs. refundable fares is within $150 and there is potential for changing your business plans. Refundable fares may be purchased via an agent or Cliqbook.

5. Amtrak Acela may be booked in business class and should always be considered when traveling to New York City, Philadelphia and any other locations where it may make business sense to do so. Rail can be booked via an agent or Cliqbook.

6. Airline club/lounge memberships and travel upgrades are not reimbursable.

7. Southwest Airline early check in (“Early Bird”) is permitted per policy. Please note, canceling a flight will result in a loss of the prepaid early check in and may not be reimbursable.

8. Receipts for airline and train travel must show the ticketed price paid (e.g., not just reserved), and boarding passes or other evidence of travel shall be included with the expense report wherever practical. Credits received for travel that was reported but not taken must be reported on the employee’s expense report upon receipt of credit, for offsetting the initial expense and reimbursement.

9. Unused tickets will be stored in your travel profile housed by FCm and should be applied whenever possible to mitigate costs. Please note on any Cliqbook reservations when you wish to use a used ticket. Any tickets that need to be canceled must be done via the agent to store for future use.

B. Lodging

1. Hotel properties for all hotel reservations and stays shall not exceed full service, business class hotels. Employees are not authorized to stay in luxury hotels unless the property is listed within the Gilbane preferred program.

Examples:

Business Class: Marriott, Starwood, Hilton, Intercontential hotels offer business class properties

Luxury: Four Seasons, Ritz Carlton, Mandarin Oriental, etc are all examples of luxury

As we alongside FCm continue to negotiate preferred rates nationally or within local areas, such preferred hotels will be communicated to all employees and posted on the intranet. Travelers should stay with these preferred hotels during business travel, wherever practical. Negotiated hotels will appear on Cliqbook as “Preferred” status and will also be offered when calling into an agent.

2. Hotel charges shall be limited to room, tax, and telecommunication expenses; charges for personal mini-bar or movie rentals are included in the per diem and are not directly reimbursable, Employees are strongly encouraged to use their cell phones for telephone calls and avoid costly hotel phone charges. Laundry and dry cleaning charges are reimbursable during extended stays of 4 nights or more.

3. The detailed lodging bill must be included with the expense report. Employees must itemize and report charges in the applicable category rather than combine all charges under “lodging”:

· Room and room tax

· Meals (unless per diem is applied)

· Telecommunications (e.g., internet service where necessary)

· Tips and gratuities are included as part of the Incidental portion of the Per Diem Rate

C. Ground Transportation and Auto Rentals

1. Transportation costs for travel to/from the office and other locations while visiting customers or otherwise conducting business are reimbursable. Costs for commuting to/from your assignment and home are not reimbursable business expenses.

2. Wherever practical, taxi service must be used in place of more costly sedan car services.

3. Gilbane travelers are required to book our preferred and contracted car vendor Hertz when a car rental is needed. In the event that no cars are available thru Hertz then National / Enterprise is the secondary provider for car rentals.

4. Employee shall rent cars on out of town business trips requiring regular transportation (e.g., where cost justified in comparison with taxi services). Generally, intermediate/mid-size or smaller cars should be rented, unless the trip includes multiple travelers warranting a full-size vehicle. A full size vehicle will be considered an exception and noted for reporting.

5. To avoid excessive refueling charges, wherever possible rental cars should be returned with a full tank of gasoline.

6. GPS rentals are permitted, you should use your discretion.

7. Tolls and reasonable parking fees incurred while traveling on business will be reimbursed.

8. Original receipts for car rentals, taxis, car services and related parking fees/tolls must be provided.

9. ALL INSURANCE for rental vehicles should be DECLINED as employees traveling on Company business are covered under the Gilbane corporate insurances for physical damage to hired vehicles.

D. Personal Automobiles

1. Employees traveling on business with personal vehicles will be reimbursed for mileage incurred according to the IRS guidelines or the company auto allowance program. The Company expense report template located on the intranet will be updated as these rates are changed (up or down), so it’s important to periodically reference the current report template on the intranet. The current IRS rates can also be found at http://www.irs.gov/ under mileage.

2. Mileage submitted for reimbursement should be adjusted to exclude the employee’s normal cost for commuting to/from assigned location to a maximum of 30 miles each way. In the event a trip is taken over 30 miles in each direction, the difference in miles may be submitted for mileage reimbursement.

Example:

An employee takes a 1 day business trip to a client located 70 miles each direction from his/her assigned location. The employee shall submit reimbursement for 80 miles (140 miles- 60 miles).

3. Fuel, repairs or other car related expenses incurred on business trips shall not be included on an expense report as the IRS mileage allowance is all inclusive. As noted above under Ground Transportation and Auto Rentals, tolls and parking fees for business travel are reimbursable with submission of receipts if in excess of $25.

E. Per Diems - Business Meals / Incidentals

1. Our policy is to provide a lump sum amount paid for meals and incidental expenses while traveling on Authorized Company Business. The allowance amount(s) will be based on the General Service Administration’s ‘CONUS” (Continental US) rates for meals and incidental expenses at 100% of the published rates. (See TSA guidelines, http://www.gsa.gov/graphics/ogp/FY10_Per_Diem_File.xls)

Incidental Expenses as defined by the GSA are fees paid to/or for: porters, baggage carriers, bellhops, hotel maids, valet services, transportation between places of lodging or business to where meals are taken and postage to mail in travel vouchers.

NOTE: In certain circumstances, the Company’s contract with a client may require documentation and reimbursement of meal expenses instead of the daily per diem. In those situations, the Regional Controller will provide the policy requirements as appropriate.

Day Travel is defined as:

· A full day of travel (employee leaves before 6:00 a.m. and returns after 8:00 p.m.), if considered necessary and appropriate by the employee’s manager, the employee will be reimbursed at 100% of the standard GSA CONUS Rate, which is $46.00 to all destinations or counties not specifically listed on the FY2010 Domestic Per Diem Rates List. [See FY2010 Domestic Per Diem Rates List for Further Information.]

· A partial day of travel (employees leaves after 6:00 a.m. and/or returns before 8:00 p.m.), if considered necessary and appropriate by the employee manager a percentage of the standard GSA CONUS rates will be reimbursed. Employees will need to identify which meals were required for travel in the Concur Expense allowance entry screen and Concur Expense will automatically adjust your daily rate to reflect the meal requirements.

If an employee is attending an event either sponsored by Gilbane or another organization and all meals are provided during the course of the event, then only the Daily Incidental portion of the Daily Per Diem will be reimbursed, which is currently $5.00 per day.

The actual expenses associated with necessary parking fees and tolls will be reimbursed to the employee.

Travel Expenses, if travel is by means other than personal vehicle, will be reimbursed as described above in the Business Travel section.

Overnight Travel:

Employees on authorized overnight travel will be reimbursed, based upon submission and approval of expense statement, for the following expenses in addition to what is listed above:

· The actual cost of overnight accommodations. Employee is expected to acquire reasonably priced accommodations. The use of competitively priced business class hotels should be used when possible, i.e., Marriott, Starwood, Hilton

· If employee overnights with friends or relatives, no accommodation expenses will be reimbursed.

Reimbursable Travel Expenses do not include Temporary Living Expenses, Subsistence or costs related to Relocation. There are specific policies for these types of expenses and should be discussed with your Regional Controller in order to make sure that they are being handled correctly and that the proper policy is being followed

2. Individual meal expenses shall be reported on an expense report under the “Meals” category; meals involving multiple employees and/or customers or other third parties, shall not be reported under Meals but rather as “Entertainment” expenses. Refer to the next section for further discussion.