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28 MOBILITY/DECEMBER 2011 A n “extended business traveler” (EBT) generally is defined as an employee who travels interna- tionally on business on a temporary basis for a minimum of 10 consecutive days at any one time during a one-year period to a given country. Typically, business line management determines the need for employee travel and expenditure for business trips. In many organizations, no distinction exists between the travel process and oversight of an employee traveling to a location for a week or a month. Given that travel expenditures are being processed and initially tracked by the company’s corporate travel department or preferred provider, they are key stakeholders in the iden- tification of EBTs. The travel function may use a web- based platform, company intranet, or alternate technolo- gy for bookings that may or may not be integrated into the company’s data warehouse. Why should this be a concern? Each country has its own governing immigration and tax laws. The number of days an EBT is physically present in a given country, the nature of the work he or she may be performing, and other criteria (such as the employee’s employing entity, payroll location, stock option exercise, etc.) may result in unintended tax and immigration com- pliance risks for the employer. This lack of compliance reporting may translate into immigration delays or denial, employee deportation or legal prosecution, increased costs, audits, and overall, a negative company reputation. Consistent infractions can even jeopardize a company’s ability to operate and conduct business in a country. EBTs— Clear and Present Danger BY SARAH DEHAYES AND SOFIA PIRES Compliance remains a topic of perpetual importance for mobility professionals, especially when extended business travelers are considered. DeHayes and Pires write that various measures can be employed to proactively manage and mitigate the risks associated with these types of mobile employees, with technology playing an integral role in the solution architecture.

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  • 28 MOBILITY/DECEMBER 2011

    An extended business traveler (EBT) generallyis defined as an employee who travels interna-tionally on business on a temporary basis for aminimum of 10 consecutive days at any one time duringa one-year period to a given country.

    Typically, business line management determines theneed for employee travel and expenditure for businesstrips. In many organizations, no distinction existsbetween the travel process and oversight of an employeetraveling to a location for a week or a month. Given thattravel expenditures are being processed and initiallytracked by the companys corporate travel department orpreferred provider, they are key stakeholders in the iden-tification of EBTs. The travel function may use a web-based platform, company intranet, or alternate technolo-

    gy for bookings that may or may not be integrated intothe companys data warehouse. Why should this be aconcern?

    Each country has its own governing immigration andtax laws. The number of days an EBT is physically presentin a given country, the nature of the work he or she maybe performing, and other criteria (such as the employeesemploying entity, payroll location, stock option exercise,etc.) may result in unintended tax and immigration com-pliance risks for the employer. This lack of compliancereporting may translate into immigration delays or denial,employee deportation or legal prosecution, increasedcosts, audits, and overall, a negative company reputation.Consistent infractions can even jeopardize a companysability to operate and conduct business in a country.

    EBTsClear and Present Danger

    B Y S A R A H D E H A Y E S A N D S O F I A P I R E S

    Compliance remains a topic of perpetual importance for mobility professionals, especially whenextended business travelers are considered. DeHayes and Pires write that various measures can beemployed to proactively manage and mitigate the risks associated with these types of mobileemployees, with technology playing an integral role in the solution architecture.

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  • 30 MOBILITY/DECEMBER 2011

    From immigration caps to financialreform legislation, it can be challeng-ing for companies to both navigateand remain up-to-date on criticaloperating procedures and furtherassess the effects on global mobility.With government coffers runninglow, typical responses can be feltglobally from protectionism of oneslabor pool, seizing the opportunity tolevy taxes on capital flow, and bene-fits scheme changes to a more vigor-ous adherence of laws already inplace.

    Organizationally, we can all sensethe intense scrutiny on costs at all lev-els in this economic climate. Budgetlimitations notwithstanding, surpriseexpenditures such as lingering tax lia-bilities are unwelcome. The distrac-tion of playing catch-up with internalownership and allocation of theseunanticipated consequences of EBTsis frustrating at best.

    The following is an account ofhow one organization confrontedthis risky landscape and found a newadministrative design to addresscompliance and awareness.

    Theory in PracticeA multinational organization we

    have assisted serviced their globalmobility program via a regional ser-vice delivery model. They have a largepopulation of EBTs globally and thismobility type was managed by theglobal mobility function. The report-ing and management of their EBTswas inconsistent across regions.

    Because of these concerns, thecompany embarked on a journey tocreate awareness across various levelsand functions of the organizationthrough education; to proactivelyidentify EBTs prior to the com-mencement of travel and developstandardized tracking tools to ensure

    consistency throughout its supportstructure.

    To achieve these goals, the compa-ny first explored the current state ofprocedures relative to candidateidentification and decision-makingcriteria. This was a cross-functionalexercise with the commitment ofglobal mobility, tax, and corporatetravel. A dedicated EBT mobilitypolicy and assignment letter werecreated, distinguishing this popula-tion from a typical business traveleror a short-term assignee (this policydistinction created instant awarenessacross the HR community). Policybenefits included mandatory taxbriefings and immigration coordina-tion. The company also centralizedthe operations team dedicated toEBTs, resulting in greater consisten-cy with reporting and tracking.Tools such as process flows, scripts,and reporting were developed tofacilitate the workflow.

    From a technology perspective, thecompanys intranet was leveraged topush out information and shareresources. The human resource infor-mation system (HRIS) was not origi-nally designed to accommodateEBTs, causing resistance by users andthe use of manual processes to sup-

    plement data collection. The base ofthe tracking and reporting data ware-house became the travel depart-ments software, which then wasincorporated into a plan for a morefully integrated technology platformfeeding in data from the accountspayable and HRIS systems.

    Continuous informational trainingsessions with HR and business man-agers proved most effective and led to sustainable results. Cross-functional participation requiredinvolvement from senior manage-ment and an understanding of therepercussions of non-compliance. Ashift in perspective took place, nowviewing these recurring businesstrips as a function of employeemobility. Disciplinary action wastaken to address repeat offenderswith senior management.

    Effective ApplicationThis company took several steps

    that highlight some representativebest practices in the successful man-agement of EBTs. The following rec-ommendations identify the anchorsof a well-integrated program:

    Policy development. Defining eli-gibility criteria for extended businesstrips within ones organizational con-text and suite of mobility plans andtiers will aid in clear delineation ofthis population. A dedicated policyand EBT memo (outlining the termsand conditions) help facilitate consis-tent and equitable treatment andsupport of employees while alsoframing the employees responsibili-ties in the process. The oversight andownership of EBTs are most success-fully placed within the global mobili-ty space given the existing architec-ture of compliance, tools, servicedelivery resources and technicalexpertise. Typical policy provisions

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  • MOBILITY/DECEMBER 2011 31

    and guidelines include temporaryaccommodation, per diem or T&Ereimbursement in alignment with theglobal travel policy, tax consultationand return preparation (as required),immigration procurement, excessbaggage and airfare.

    The power of technology.Technology drives business forwardby leveraging efficiencies. The inte-gration of systems allows for regionaldata to be synthesized globally andultimately safeguard compliance.Technology affords mobility teamsthe ability to manage workflow, trackactivity and share data with theirexternal suppliers. Limiting the inter-face to pertinent key EBT identifiers,along with the additional supportinginformation required to deliver theprogram, reduces the extensive timeand cost of standard technology con-structs. Typical relevant data include:employee name, employee ID,employee contact details, home loca-tion, host location, business division,cost center, business manager, startdate, end date and the number ofdays in the host location for each trip.

    Suppliers, who may have existingaccess to the clients HRIS system viaa web portal, can extract the neces-sary information in real time andproactively service the EBT popula-tion. For those clients who do nothave the internal technology, similarresults can be obtained via assess-ment tools offered from various sup-pliers that provide both country-specific compliance regulations andcost projections to be used for bud-getary purposes. Maintenance ofthose assessments for current applica-tion requires due diligence but canprove highly effective in addressingthe exposure associated with EBTactivity.

    Cross-functional involvement.The engagement of multiple depart-ments within the organization high-lights the grasp that mobility and thisparticular mobility typeEBTstruly have. From tax and treasury totravel and legal, the effects of EBTsare far-reaching, thus a solutionshould best be crafted synergistically.Securing buy-in within an organiza-tion can assist in forging a new path

    to proactive management of theseemployees on extended businesstravel. This strong partnership aids inthe implementation of new proce-dures and workflow that could bemet with resistance or at a minimum,irritation, if the rationale is not suc-cessfully conveyed.

    Communication and education.Launching an internal awarenesscampaign to highlight the compli-ance risks and exposure EBTs canpose to the organization can be aneffective call to action. EducatingHR business partners and line man-agement alike, an organization canbe well on the way to greater invest-ment in the EBT process and admin-istration. Supplemental manager andadministrator guides can supportcontinued learning and new teammember onboarding. Communi -cations can be reviewed on a quarter-ly basis to maintain focus and rele-vance.

    Ongoing vigilance. The mainte-nance of data integrity is vital.Country regulations or modificationsto corporate governance rulings are

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  • 32 MOBILITY/DECEMBER 2011

    ever-changing. Communicatingthese regulatory updates to stake-holders ensures that complianceterms are being met. Similar to othermobility programs, the EBT policyand accompanying administrativetools should be audited frequently,as the maintenance of this education-al material is fundamental in the suc-

    cessful management of EBTs. Ex -tracting and disseminating valuablereporting from an organizationsmobility system of record can bebeneficial to keep a close eye on themovement of its mobile population.In tandem with tracking tools, theestablishment of prescribed escala-tion protocols can be implemented

    to send off alarms to key stake-holders and decision-makers prior toan EBT approaching a critical taxthreshold. The organization then isempowered to make an informeddecision rather than pick up thepieces after an unwitting commit-ment.

    Bringing It All TogetherThe subject of extended business

    travelers and their related compliancerisks for organizations will continueto be a hot topic of discussion in themobility community. It is true thatthe hazards are plentiful, however,the various measures discussed abovecan be implemented to tighten pro-cedures, enhance visibility anddeploy mobility administration withgreater confidence and ease. Now goforth and wear your compliancebadges proudly!

    Sarah DeHayes is director, consulting services at Crown Relocations, Brookfield,CT. She can be reached at +1 203 482 6271or e-mail [email protected].

    Sofia Pires is a project manager, consultingservices at Crown Relocations, Brookfield,CT. She can be reached at +1 203-788-9943or e-mail [email protected].

    Testing Your Knowledge

    Lets take a birds eye view of your own organization and the management of EBTs. Though some of the choices are a bit irreverent, we hope the themes of technology, oversight and compliance resonate.

    1. How do you define EBTs in your organization? a) Eagerness Before Thinkingb) Extended Business Travelers2. How do you identify EBTs? a) Pick them out of a line-upb) In our HRIS system3. How do you track EBTs? a) Via the signal from an ankle monitorb) Our integrated HRIS system with enhanced tracking tools4. Who does the employee on an EBT call if detained at the border? a) The immigration providerb) Global mobilityc) The client

    Answers: 1. b 2.c b 3. b 4. a and b.

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    mailto:[email protected]://Answers:1.b2.cb3.b4.aandbhttp://www.gmsmobility.comhttp://www.gmsmobility.com

    TOC-1EBTsClear and Present Danger