NCM TRAVEL AND ENTERTAINMENT POLICY

To: / NCM Employees
Date Published: / August 16, 2016
Subject: / Travel and Entertainment Policy
Policy Owner: / NCM Accounting

General Note - All expense reimbursement inquires/correspondence with NCM accounting should be sent to . Please ensure all submitted receipts are legible.

Purpose:

To provide guidelines and procedures to NCM employees for travel and entertainment expense reimbursement. The Company reserves the right to amend this policy at any time. Failure to adhere to this policy may result in delayed reimbursement, non-reimbursement and/or disciplinary action.

Policy:

The below policies are designed to provide formal guidelines regarding all business travel and related expenses to National CineMedia (NCM) employees. Employees are reimbursed for necessary and reasonable out-of-pocket expenses that are directly related to their job responsibilities. Good judgment must be used when incurring any business expense. Responsibility for expense control and compliance rests with the employee and employee’s approving supervisor, but it is primarily the responsibility of the employee’s approving supervisor to determine and certify that expenses incurred (whether submitted for reimbursement or booked as company paid travel) are necessary, reasonable, and fall within the provisions of this policy.

Out-of-Town Business Travel is defined as travel away from an employee’s permanent job, during which the employee may require an overnight rest prior to returning. Examples of these types of expenses include airfare, car rental, lodging, out-of-town meals, as well as other costs to be discussed within this policy.

Reimbursable In-Town Travel is defined as incremental travel away from the employee’s permanent job. Examples of these types of expenses include mileage in excess of the employee’s commute mileage, parking costs in order to attend meetings, and certain in-town meals covered under this policy.

Preferred vendors are defined as those vendors with which NCM has entered into agreements for discounts or other incentives. Preferred vendors should be used whenever presented by the travel agency or online booking tool. Non-Preferred vendors are only authorized if the employee can justify a significant cost savings or other legitimate business reason.

Employees are responsible for adhering to the outlined policies and booking their own travel.

EXPENSE REPORTS

NCM finance/general ledger personnel are required to review and audit all expense reports and ensure there is proper documentation and compliance with the company policy. They are also responsible for resolving issues, working through rejected expense reports and resolving deficiencies with the employee and the employee’s direct supervisor. Below are some general guidelines related to expense reports:

•  Expense reports are processed and paid weekly by NCM finance.

•  Expense reports are submitted on-line via the Microsoft AX portal on the Insider, which are routed for supervisor review and approvals via system workflow.

•  Expenses are recorded to the employee’s default/home department, and splitting of expenses to multiple departments is not permitted.

•  Expense reports are to be submitted based on NCM’s period-end (not the calendar month-end) and must be submitted no later than within 30 days of the expense. If received after 30 days, the supervisor, Department VP and CFO approvals could be required.

•  All reimbursable expenses require detailed receipts and guests must be entered into AX under “guests and gift receipts” see “Meals” section below. AP will use its discretion for any items without a proper receipt, but the expectation is receipts are to be obtained for all items.

•  Tips are reimbursable when confined to reasonable limits, as determined by the services required and received. The general guideline is 15% tip with no greater than 20% and cash tips are to be avoided as they will not be reimbursed. (include tip amount on the receipt).

•  Expense report receipts must be scanned and attached when submitting in AX. Any expense report with partial receipts attached will be rejected until completed (all support must be included).

•  Supervisors reviewing expense reports are expected to ensure expense reports are complete and accurate, including compliance with all guidelines in this document. Ultimately, signing supervisors will be held accountable for signed expense reports.

TRAVEL ARRANAGEMENTS

NCM’s designated travel agency is Travel CTM (formerly Polk Majestic Travel Group). The travel website is http://us.travelctm.com/corporate/ncm. All travel arrangements should be made through this travel agency. These include arrangements for all air, car, and hotel bookings. NCM and Travel CTM will monitor all travel for policy compliance and potential preferred vendor discounts. Air arrangements which are not booked through Travel CTM may not be reimbursed and require CFO or Controller approval. Extenuating circumstances for not booking with Travel CTM must be noted in the expense report submission.

Employees are strongly encouraged to use Travel CTM’s online booking tool, Concur, as opposed to a travel agent over the phone. Self-Booking, through Concur, results in significant travel agency transaction savings.

Travel CTM contact information is as follows:

·  Address: 4500 Cherry Creek South Drive, Ste. 900, Glendale, Colorado 80246

·  Website: http://us.travelctm.com/corporate/ncm

·  Concur Booking Site: http://us.travelctm.com/corporate/ncm

·  Concur Support Desk: 866-905-7774

·  Business Hours: 7:30am-5:30pm (Denver Time)

·  Phone Contact: 303-333-6161 (Ask the receptionist for dedicated NCM agent)

·  Emergency After Hours: 800-875-7655

Each employee is responsible for submitting and updating their own travel profile online at http://us.travelctm.com/corporate/ncm.

Air Travel

All air travel must be booked through Travel CTM.

NCM employees are expected to schedule the minimum amount of travel necessary to meet their business objectives.

United Airlines is NCM’s preferred airfare provider and NCM is enrolled in the United Pass Plus program. The Pass Plus program provides significant savings (2% - 10% discounts) on United fares. NCM has pre- paid funds and has committed to spend a significant amount of our air travel exclusively with United to receive such discounted fares. As a company, the bulk of our air travel needs to be booked with United. All travellers will need to book with United exclusively and only book through other airlines when United does not offer flights to your destination, or if your travel is time sensitive and United does not have a flight that coincides with your needs.

The travel department understands that staying within department travel budgets is very important and often times travellers prefer to book a low-cost airline rather than a higher cost United flight. Please keep in mind that NCM pre-paid for the above mentioned discounts on United flights so even though a United flight may be more expensive, NCM has already covered these costs up front.

The United fare discounts are already loaded into Concur (online travel booking tool). When booking a non-United flight you will receive a pop-up box asking for a reason as to why you are not booking with United. Air travel booked on airlines other than United will be closely monitored.

Class Service and Purchased Upgrades

·  All travel must be booked in Coach Class unless authorization to purchase Economy Plus, Business or First Class tickets is given to specific individuals per the CEO’s office for the CFO or the CFO for all other employees.

·  Class upgrades can be purchased by EVP’s and C level management for trips in excess of 3.5 hours, and SVP’s for trips in excess of 4.0 hours.

·  Employees are expected to use the lowest logical airfare available.

Airline Frequent Flyer Programs

Traveling employees may retain frequent flyer program benefits; however the participation in these programs must not influence flight selection which would result in incremental cost to the company beyond the lowest available airfare, as defined in this policy.

Trip Cancellations

When a trip is cancelled after the ticket has been issued, the traveller is responsible for returning the unused ticket to the travel agency for the purpose of using the same ticket for future travel or a refund.

Change Fees

Airfare change fees should be made through the booking travel agent (Travel CTM) whenever possible. If change fees are paid directly to the airline and charged to the employee’s credit card or to a on-line provider, please note the reason for the change in the expense report submission.

Airline Internet

Airline internet charges are reimbursable when required for business, but should not be purchased for entertainment purposes.

Spouse

Expenses for spouses are reimbursable under acceptable circumstances and with approval from the Department Supervisor and/or EVP. Acceptable circumstances may include customer dinners, corporate holiday dinners, functions, company sponsored employee recognition programs and outings sponsored by clients, bankers, etc. Expenses should be submitted under the employee.

Other Airfare Items

The following items are not reimbursable by NCM:

·  The costs of in-flight services such as movies, gifts, telephones, and earphones

·  Excess baggage fees, except for international travel or trips greater than five business days.

·  Dues and Fees for airline terminal clubs are not approved as reimbursable expenses, unless pre- approved by the CEO, CFO or President of Sales and Marketing.

Billing/Paperwork

All airfare, booked through Concur/Travel CTM, is paid using the NCM corporate travel credit card or UATP card for United airfare. These card numbers are stored within the Concur reservation system and personal cards will not be charged for airfare.

Other Transportation

Rail Travel

Any rail travel is to be booked and charged to the employee’s credit card.

Taxi and Private Car Service

Taxis should always be considered and weighted against the cost of car service, car rental, parking and gasoline. Generally chauffeurs, car services and limousines are not authorized, unless 1) SVP or above, 2) in a location where a car service is a practical option (typically only New York), and 3) approved by department EVP1. If car service charges are submitted through business reimbursement, they should be coded to the “car service” category in the expense report, and it is the approving supervisors responsibility to understand the business reason and why this was the more practical option.

Chicago and New York After Hours Transportation

Employees who use rail or busses to work may take alternative transportation home if the employee is required to work after 8:00 pm local time. The employee must get approval from his supervisor and submit a separate expense report with that expense only.

Hotels

Hotels should be booked through Travel CTM/Concur unless the traveller is attending a conference or meeting where there is a discount negotiated room block at the hotel. Travellers are expected to use negotiated or preferred rates whenever possible. When an on-line hotel company is used as the cheaper option, both the on-line agreement detail and the proof of payment from the employees credit card must

1 It is the approving supervisor’s responsibility to obtain EVP approval and understand and explain why used.

be provided for reimbursement. Travellers will be reimbursed for actual and reasonable hotel room costs charged to the traveller’s credit card.

Tips for hotel staff are reimbursable when charged and confined to reasonable limits, as determined by the services required and received. Refer to the “Expense Reporting” section for guidelines on tipping.

NCM has two preferred hotel properties in Centennial, CO listed below:

Element Hotel Denver Marriott South at Park Meadows

9985 Park Meadows Drive 10345 Park Meadows Drive

Lone Tree, CO 80124 Lone Tree, CO 80124 NCM preferred rate: 15% of best available NCM preferred rate: $184

A single room rate is the corporate standard and the following rate guidelines will be enforced by the NCM accounting department. These are only guidelines, not limits, and thus employees should always look for the most cost effective alternatives when booking hotels. If charges are over these rates please note in the expense report the reason for the overage since this will avoid delay in reimbursement:

Non-Officers (all others) Officers (VPs and Above) Standard Market Rates: $225/night $305/night Major Market

Major Market Rates: $330/night $415/night

Major Market Cities:

Atlanta Miami

Boston New York City

Chicago Philadelphia

Dallas San Francisco

Houston Washington DC Los Angeles

The major market list will be continually reviewed to ensure that limits are sufficient for reasonable lodging standards.

Reasonable telephone and internet usage expenses incurred while traveling are reimbursable. Travellers with corporate cell phones should use those before using a hotel phone. When traveling to other NCM offices, employees should use NCM phones and fax machines to avoid hotel surcharges.

Laundry expenses are reimbursable for trips lasting five nights or more or if the trip is extended longer than the original date of return.

Reasonable charges for the use of exercise equipment at a hotel will be reimbursed. The company will not reimburse for personal spa visits, massages and other charges not related to the use of exercise equipment.

The following hotel items are not reimbursable:

·  In-Room Movies

·  In-Room Mini-Bars

Employees must follow the same guidelines for Room Service charges as Meals. See the Meals section below for details.

Travel CTM will use the employee’s personal credit card number (provided in the employee’s travel profile) to guarantee hotel reservations. It is the employee’s responsibility to cancel any guaranteed reservations and be aware of each hotel’s cancellation policy. Any charges incurred due to a non-work related “no show” are the responsibility of the employee and are not reimbursable.

Billing/Paperwork

Employees must use their personal credit card to pay for hotel charges and submit these receipts for reimbursement on a Travel and Expense report. Receipts should be legible and include proof of payment and a detailed breakdown of all expenses.

Direct billing may be used in instances when large meetings are held. In these cases, an appropriate department travel coordinator within NCM will make these arrangements.

Car Rental

It is preferred that car rentals be booked through NCM’s designated travel agency (Travel CTM) and made in conjunction with corresponding air and hotel reservations. If booking independently the NCM preferred car rental supplier is Hertz, however if a lower rate is obtained, other vendors may be used. When an on-line car rental company is used as the cheaper option, both the on-line agreement detail and the proof of payment from the employees credit card must be provided for reimbursement. Rental cars should be used when it is more cost effective than airline, rail or other travel methods.