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F I N A N C E & A C C O U N T I N G

Expense Reimbursement Policies

K P M G L L P

GUIDING PRINCIPLES.................................................................................................................................. 1

Page TABLE OF CONTENTS

ABOUT THIS DOCUMENT ........................................................................................................................... 4 POLICY CHANGES............................................................................................................................................ 4 TRAINING ........................................................................................................................................................ 4

DOCUMENTATION STANDARDS............................................................................................................... 5

CLASSIFICATION OF EXPENSES .............................................................................................................. 7

KPMG TRAVEL SERVICES AND DINERS CLUB CARD........................................................................ 9 TRAVEL SERVICES........................................................................................................................................... 9 DINERS CLUB CORPORATE CARD ................................................................................................................... 9

OTHER ADMINISTRATIVE ASPECTS..................................................................................................... 11 FOREIGN CURRENCY TRANSLATION ............................................................................................................. 11 TRAVEL ADVANCES ...................................................................................................................................... 11 SPECIAL PROVISIONS FOR EXTENDED OUT-OF-TOWN PROJECTS ................................................................. 11

REIMBURSEMENT TOPICS....................................................................................................................... 14 AIRLINE CLUB/LOUNGE FEES ....................................................................................................................... 14 AIRLINE TRAVEL ........................................................................................................................................... 14 AUTOMOBILE RENTALS................................................................................................................................. 17 CELLULAR PHONES, PAGERS, AND WIRELESS DATA DEVICES..................................................................... 17 CIVIC AND CHARITABLE ORGANIZATIONS.................................................................................................... 19 CLUBS – ATHLETIC, SOCIAL, AND LUNCHEON.............................................................................................. 19 HOME/REMOTE TECHNOLOGY AND EQUIPMENT .......................................................................................... 20 HOTELS.......................................................................................................................................................... 21 INCIDENTALS................................................................................................................................................. 22 LAUNDRY AND DRY CLEANING SERVICES.................................................................................................... 22 LONG-DISTANCE TELEPHONE ....................................................................................................................... 22 MEALS........................................................................................................................................................... 23 PARKING........................................................................................................................................................ 26 PARTIES, NEW HIRE/FAREWELL FUNCTIONS AND OTHER EVENTS .............................................................. 27 PARTNER PHYSICAL EXAMINATIONS ............................................................................................................ 27 PROFESSIONAL AND INDUSTRY CONFERENCE FEES/EXTERNAL TRAINING COSTS ...................................... 28 PROFESSIONAL EXAMINATIONS .................................................................................................................... 28 PROFESSIONAL LICENSES.............................................................................................................................. 28 PROFESSIONAL SOCIETIES............................................................................................................................. 28 RAIL TRANSPORTATION ................................................................................................................................ 29 RECREATIONAL FEES .................................................................................................................................... 29 SPOUSE/DOMESTIC PARTNER TRAVEL.......................................................................................................... 29 TAXI AND CAR SERVICE................................................................................................................................ 30 TICKETS TO SPORTING EVENTS AND OTHER ENTERTAINMENT.................................................................... 30 TIPS................................................................................................................................................................ 31 TRANSPORTATION AND MILEAGE REIMBURSEMENT.................................................................................... 31 TRAVEL INCENTIVES ..................................................................................................................................... 32 VISA AND PASSPORT FEES............................................................................................................................. 33 WEEKEND TRAVEL........................................................................................................................................ 33

NON-REIMBURSABLE EXPENSES........................................................................................................... 34

EXPENSES COVERED BY PURCHASE AGREEMENTS....................................................................... 36

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APPENDIX A – MEALS AND INCIDENTAL PER DIEM RATES ............................................................ I

APPENDIX B – REIMBURSEMENT REQUEST FORM FOR CLUB INITIATION FEES/DUES/ASSESSMENTS ........................................................................................................................ II

APPENDIX C – GUIDELINES AND EXPECTATIONS FOR PROPRIETY REVIEWS AND FUNCTIONAL LEADER APPROVALS .....................................................................................................III

APPENDIX D – GIFT POLICIES ................................................................................................................ VI

APPENDIX E – AUTHORIZED APPROVERS.......................................................................................... XI

APPENDIX F – EXPENSE EXCEPTIONS – ESCALATION PROCESS.............................................. XII

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GUIDING PRINCIPLES 1.01 This policy provides guidelines for the reimbursement of business expenses. All individuals are expected to use good judgment when claiming or approving the reimbursement of business expenses. All claims for reimbursement should be based on compliance with laws and firm policy. Individuals should also consider the implications to both the firm and our clients when incurring and requesting reimbursement for expenses. 1.02 The purposes of the guidelines are: • To be fair and equitable. An individual working for the firm should

neither gain nor lose personally because he or she has incurred reasonable business expenses. Individuals incurring similar expenses for similar business needs are to be reimbursed or not reimbursed consistently throughout the firm.

• To be responsible and prudent in spending our clients’ and the firm’s money.

• To ensure proper documentation is maintained by the firm to support both internal and client reimbursable expenditures, and to ensure the documentation standards required by the Internal Revenue Service and other regulatory agencies are met.

1.03 When reporting time and expense charges, personnel are expected to adhere to the firm’s Code of Conduct, from which the following excerpt is taken: “KPMG partners and employees are required to truthfully charge all time and expenses incurred to the appropriate engagement or internal charge code – no more and no less. KPMG employees should also be prudent and exercise good judgment when incurring work-related expenses. KPMG has policies and procedures related to travel and other expenses and you should follow them carefully.” Individuals are ultimately responsible for the correct and accurate completion of their time and expense reports – delegation of this task (e.g., to an administrative assistant) does not relieve this responsibility.

Revised December 2007

http://www.eandc.kworld.kpmg.com/CofC/default.asp

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When submitting expenses for reimbursement, individuals should SPEND SMART:

S Spend the firm’s money as if it is your own

PPartners, managers, and performance managers have a responsibility to guide others to “ do the right thing in the right ” when making spending and reimbursement decisions

EExpenses that are valid, reasonable and appropriately documented as you fulfill your KPMG responsibilities are the only ones that should be submitted for reimbursement

NNeed help dealing with expense reimbursement, reporting and compliance matters? Do not hesitate to work with your performance manager, area controller, or the Dallas Accounting Service Center (DASC)

DDecisions about whether to incur an expense and/or claim reimbursement should be consistent with our high ethical and professional standards

S

P

E

NDecisions about whether to incur an expense and/or claim reimbursement should be consistent with our high ethical and professional standards

D

Need help dealing with expense reimbursement, reporting and compliance matters? Do not hesitate to work with your performance manager, area controller, or the Dallas Accounting Service Center (DASC)

Expenses that are valid, reasonable and appropriately documented as you fulfill your KPMG responsibilities are the only ones that should be submitted for reimbursement

Partners, managers, and performance managers have a responsibility to guide others to “ do the right thing in the right ” when making spending and reimbursement decisions

Spend the firm’s money as if it is your own

S Sound business judgments, in accordance with our Code of Conduct, are to be made at all times

MMake sure expenses that you incur are within the guidelines and expectations established by your engagement management team and/or your leadership team

A All partners and employees need to take personal responsibility for the appropriateness of reimbursement claims

R Reimbursement claims need to be accurate, complete and compliant

T The Expense Reimbursement Policies, just like our business, are subject to change

S

M

A

R

The Expense Reimbursement Policies, just like our business, are subject to changeT

Reimbursement claims need to be accurate, complete and compliant with policy

All partners and employees need to take personal responsibility for the appropriateness of reimbursement claims

Make sure expenses that you incur are within the guidelines and expectations established by your engagement management team and/or your leadership team

Sound business judgments, in accordance with our Code of Conduct, are to be made at all times


Review Procedures

3 Revised December 2007

2.01 Expense reports are subject to review to ensure: • Prudence and business propriety of expenses incurred on behalf of clients

and the firm; and • Compliance with firm policy, IRS regulations and other regulatory

requirements. Refer to Appendix C for guidelines and expectations for propriety reviews and functional leader approvals. 2.02 Expense items that appear to represent noncompliance with this policy document will be referred to the partner or employee so that corrective action may be taken. Such action may require additional documentation or approval. Exceptions noted during the review process must be resolved timely or a chargeback will be processed, i.e., the individual will not be reimbursed for the submitted expenses. In limited circumstances, a functional leader may approve one-time exceptions to the policies set forth in this document. Requests for policy exceptions should be submitted by using the Expense Approval Request form. The functional leader may delegate the approval process to a direct report as considered appropriate (e.g., while the functional leader may be responsible for certain approvals, he or she may designate a person, such as a Business Unit Partner in Charge or area specialty practice leader, to actually perform the review and approval). Refer to Appendix E for a listing of individuals so designated. The term “functional leader” is defined as Deputy Chairman, Executive Vice Chair, Vice Chair, Area Managing Partner, National Product Leader or National Process Owner. Blanket exceptions to these policies must be approved by a functional leader and the firm’s Chief Financial Officer. Requests for blanket exceptions should be submitted by using the Expense Approval Request form. 2.03 If significant noncompliance is noted, such matters will be referred to functional leaders, resulting in action that may include termination of the employee or separation from the partnership. Refer to Appendix F for the Expense Exceptions – Escalation Process. 2.04 When an individual separates from the firm, KPMG reserves the right to the extent permitted by law to recover for any non-reimbursable expenses already advanced to or charged by the individual. Amounts may be recovered either through a deduction from any final amounts due to the individual upon separation (including without limitation the individual’s final compensation, accrued leave balance, or other substantiated expense reimbursements due), by requiring separate payment from the separating individual, or through a separate collection action.

http://dasc.us.kworld.kpmg.com/TE/ExpensePreApproval.aspx


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ABOUT THIS DOCUMENT 3.01 Individuals are required to submit timely, complete, and accurate semi-monthly expense reports through TIMEnX. KPMG reimburses individuals for appropriately authorized, reasonable and documented business expenses that comply with these policies. Expenses should generally be submitted no later than the cycle following the date incurred to ensure that charges are billed and reported timely. Expenses submitted more than three months after the incurred date will not be reimbursed unless approved by a functional leader, as defined in section 2.02. 3.02 This document describes expenditures that are reimbursable through the semi-monthly TIMEnX reporting process. To qualify for reimbursement, expenditures must meet the criteria and the documentation standards set forth herein. 3.03 Certain expenditures require approval or pre-approval by a functional leader or engagement partner. Hyperlinks are provided in the applicable sections of this document to the Expense Approval Request form which must be completed. The form may also be accessed via the DASC website (T&E/ Expense Approval Request). The system generated e-mail evidencing approval must be submitted with other supporting documentation. Policy Changes 3.04 Changes to our internal operations and regulated environment will result in occasional updates to this document. Policy changes will be updated via messaging on KPMG Today and/or scrolling notifications on the TIMEnX homepage. Personnel are expected to be familiar with policy updates and to review, understand and apply policy changes when submitting their claims for reimbursement. Questions regarding these policies or suggested updates and changes to this document are welcomed, and can be e-mailed to US-Finance & Accounting. A current copy of this document is accessible via the TIMEnX, KWorld, and Finance & Accounting homepages. Training 3.05 All individuals are required to complete expense reimbursement and compliance training. This web-based training requires successful completion of a brief exam to ensure that all individuals understand their roles and responsibilities with respect to the firm’s expense reimbursement policies. Additional training is available for the following groups: newly hired partners and employees; administrative assistants who prepare expense reports on behalf of others; newly appointed functional leaders; and ExpRT reviewers (refer to Appendix C).




mailto:[email protected]

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DOCUMENTATION STANDARDS 4.01 The firm requires all personnel to submit their semi-monthly expense reports through TIMEnX by the specified due dates. Compliance is the responsibility of each individual. The firm acknowledges that there may be unusual circumstances which result in the late submission of an individual’s time and expense report. However, repeated non-compliance with firm policy will be referred to functional leaders, resulting in actions that may include termination of the employee or separation from the partnership. 4.02 Reimbursable expenses must be supported by documentation included with your semi-monthly bar-coded TIMEnX expense report. Failure to submit adequate documentation may result in a chargeback of the submitted expenses. Receipts may be taped to 8-1/2” x 11” paper, or alternatively, “loose” receipts may be submitted, in a pre-addressed expense processing envelope, available from your local office supply room. Do not staple receipts. Stapled receipts increase the firm’s costs for document preparation and imaging. The “hours” portion of the TIMEnX report should not be included in the mailing. In all cases, the documentation must include cross-references to the corresponding line items on the TIMEnX expense report, and there must be a clear trail from the receipted amounts to the amounts claimed on the expense report. 4.03 The Internal Revenue Code requires reimbursable expenses to be supported by adequate records which clearly establish that they were (i) ordinary and necessary, (ii) reasonable in amount and (iii) incurred for a valid business purpose. The firm interprets this to mean that all of the following criteria must be met to qualify for reimbursement: • The identity of the individual(s), vendor(s) or supplier(s) must be

indicated. • The business purpose for the expenditure must be stated. • The identity and business relationship of others participating in the event

(e.g., entertainment, business meal, etc.) covered by the expenditure must be stated.

• Original itemized receipts must be attached (e.g., itemized hotel bills,

airline passenger receipts, Diners card meal receipts, automobile rental invoices, parking receipts, telephone bills, club charges, etc.) for all expenses $25 or greater with the following exceptions:

– Overtime Meals. Regardless of the amount, such expenses require a

receipt. – Mileage and per diem allowances. Mileage should include to/from

information. – Situations where a receipt is not readily available, (e.g., golf caddie

fees). Receipts submitted should be in the name of the person claiming reimbursement. Photocopies and computer printouts of receipts will not be accepted, except for airline ticket receipts obtained from the Travel Services AirWeb site and other receipts not otherwise available (e.g., web-based car


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rental receipts, cellular phone invoices, Southwest Airlines receipts, etc). The firm-issued Diners Club card is the required method of payment, unless it is not accepted by the vendor. Cash payment should be made only when other forms of payment are not accepted. A receipt should be obtained when a cash payment is necessary, except as noted above. Substitute or incompletely documented receipts will not be accepted and reimbursement will be disallowed (e.g., guest check stubs, receipts without dates). If the original itemized receipt is not available, adequate proof of payment must be submitted (e.g., original credit card statement or copy of canceled check), along with an explanation of why original documentation is not being submitted. Past due amounts included in a larger total appearing on an invoice are not reimbursable; rather, the earlier invoice on which the past due amounts appeared as current should be submitted to receive reimbursement for such charges. In addition to meeting the above criteria, any specifically required explanations per provisions contained in this document must be entered in each TIMEnX comment box as appropriate. 4.04 In the rare event that neither a receipt nor proof of payment is available, an explanation must be provided (i.e., accidentally destroyed, lost, etc.) and the functional leader may be required to approve the specific reimbursement. 4.05 Individuals claiming expenses must send their signed, bar-coded TIMEnX report (expense portion only) with the corresponding receipts to be received at the address below by the third workday after each cycle end. Expense exceptions that are not satisfactorily resolved will be charged back. Expense reports and accompanying documentation should be sent to: U.S. Mail KPMG T&E Processing P.O. Box 981130 El Paso, TX 79998-1130 Courier Service GENPACT – Mexico Operations c/o Brokers Logistics, LTD Attn: KPMG – T&E Processing 1000 Hawkins Blvd., Suite A El Paso, TX 79915 Note: It is not necessary to copy receipts and other documentation submitted in support of expenses claimed. Doing so increases costs to the firm and is contrary to the firm’s Green Initiative. If it is necessary to obtain information from previously submitted receipts or other documentation, images may be accessed via the DASC website (T&E/Expense Reimbursements/Status, then click on the cycle date).


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CLASSIFICATION OF EXPENSES 5.01 Reimbursable expenses must be charged to an appropriate project number. Individuals may need to use the project search feature in TIMEnX or other means to determine the specific project number that applies to their business unit and product. Individuals should observe the following guidelines when determining the appropriate project number: • Expenses directly related to clients, client matters, or those involving client

personnel should be charged to the appropriate client project number. • AICPA dues, state society dues, and dues and fees of other approved

professional, civic and industrial societies are to be processed through TIMEnX, using the “Prof. Dues” expense category. These expenses should be charged to the Professional Activities authorized project for your business unit and product. Optional expenditures, which often appear as part of these billings, (e.g., PACs, scholarship funds and subscriptions) are not reimbursable. See section 8.63 through section 8.65 for more information about approved professional licenses and professional societies.

• Firmwide, area, or line of business meeting expenses should be charged to

the Firm Meetings authorized project for your business unit and product, unless a specific authorized project has been established for the meeting.

• Expenses related to attendance at professional society meetings and

community activities should be charged to the Professional Activities authorized project for your business unit and product.

• Jury duty expenses are not reimbursable. Time spent serving on jury duty

should be charged to the Excused Leave project number 10000013, provided the time is supported by a "certificate of jury service" issued by the court. This certificate should be provided to the individual’s performance manager.

• Practice development expenses, such as meals and entertainment, should

be charged to the New Business Development authorized project for your business unit and product, unless a specific authorized project has been established for the particular development effort. The appropriate functional leader must approve all authorized projects. The charges to these accounts should be prudent expenses commensurate with the benefits derived.

• Professional development expenses should be charged to the Education

authorized project for your business unit and product, unless a specific authorized project has been established for the course.

• Recruiting expenses should be charged to the Recruiting authorized project

for your business unit and product. • Special project expenses, such as those incurred for National Support

Services or functional projects, should be charged to the authorized projects provided by the entity receiving the services.

• While nearly all expenses should fall into one of the above categories, any

other expenses should be charged to the Administration authorized project for your business unit and product.


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5.02 The proper location code must be selected for both time and expenses. A separate line in TIMEnX must be used to record time or expenses for each state or locality in which time or expenses were incurred, using the correct location code. Refer to the domestic and foreign location code documents on the TIMEnX Information Center homepage for a list of valid location codes and examples of proper reporting.


http://usisweb.us.kworld.kpmg.com/finadmin/te/html/te_location.asp

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KPMG TRAVEL SERVICES AND DINERS CLUB CARD


Travel Services 6.01 The firm obtains significant savings through the use of Corporate Travel Online (CTO), which must be used except if required itineraries are not available in CTO (e.g. complex multi-location travel, certain international travel, etc.). In such instances, reservations must be booked with a representative of KPMG US Travel Services to obtain negotiated rates. Business-related airline, automobile rental, and hotel reservations must be charged to the traveler’s KPMG sponsored Diners Club credit card for subsequent reimbursement through TIMEnX. If an individual is required to use a client’s travel agency, the engagement partner must submit to the DASC controller a statement to that effect, indicating the applicable project number. 6.02 Personnel should complete and file with Travel Services a Traveler Information Profile. This will expedite reservations, ensure consistency, maintain compliance with travel policies, and facilitate accounting and reporting. Profile forms are available online on the Firmwide Procurement website. Diners Club Corporate Card 6.03 KPMG-sponsored corporate Diners Club cards are issued to KPMG client service personnel and must be used when traveling on firm business. Client service support personnel will only be issued a corporate Diners Club card when their position requires travel and with the approval of their functional leader. Charges incurred on firm-sponsored cards are the responsibility of the individual. KPMG’s arrangement with Diners Club enables the firm to measure travel spending to obtain and maintain favorable airline, hotel, and automobile rental rates. The Diners Club card must be used for all airfare, hotels, and car rentals, and wherever it is accepted for all reimbursable business expenses. Diners Club has entered into an alliance with MasterCard and, as a result, the firm’s corporate card is accepted wherever MasterCard is accepted. In the rare situation where MasterCard is not accepted, another credit card may be used. In such instances, please note on your receipts the non-acceptance of the firm’s corporate card when submitting your expense documentation, to minimize potential questions from the expense reviewer. 6.04 Firm-sponsored Diners Club cards should only be used for the cardholder’s business related expenses (i.e., personal spending on the Diners Club card is prohibited). The Diners Direct program must be used for all Diners Club charges submitted through TIMEnX. Information about Diners Club and the application for Diners Club membership may be accessed through the Diners Club Application website. Expenses claimed will offset any amounts due the firm prior to such expense claims being used to pay Diners Direct.

http://www.kworld.kpmg.com/microwebs/us/meettrav/travel_services/cto/index.htm

http://www.kworld.kpmg.com/microwebs/us/meettrav/travel_services/cto/index.htm

http://www.kworld.kpmg.com/microwebs/us/meettrav/travel_services/agency_services/travel_onsites.htm

http://www.kworld.kpmg.com/usmeettrav/travel_services/agency_services/traveler_profile.htm

http://www.kworld.kpmg.com/microwebs/us/meettrav/diners_club/application.htm

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6.05 The delinquency policy with respect to outstanding balances on firm-sponsored Diners Club cards is as follows: • Courtesy notifications will be sent to all card members who have balances

at 45 days. The balance must be paid before it reaches 60 days. • Diners Club will suspend use of accounts that have 60-day balances.

Interest fees and delinquency fees will be charged by Diners and are not reimbursed by the firm.

• The card member’s performance manager will be notified of any balances

reaching 90 days. • If the overdue balance is paid before reaching 90 days the account will be

reinstated. Abuse of the Diners Card program, (e.g., significant misuse of the Diners Card or failure to pay amounts due), will be referred to functional leaders, resulting in action that may include termination of the employee or separation from the partnership.


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OTHER ADMINISTRATIVE ASPECTS


Foreign Currency Translation 7.01 Expenditures in foreign currencies should be converted to U.S. dollars when entering data into TIMEnX as follows: • For Diners Club credit card transactions, use the actual dollar amount

billed on the credit card statement. This amount also appears in TIMEnX from the automated Diners Club interface. Documentation of the conversion rate must include either the Diners Club statement or a copy of the Diners Club online statement.

• For cash transactions, use the conversion rate from

http://www.oanda.com/cgi-bin/ncc. For documentation, the printed conversion rate from the website must be submitted.

• For credit card transactions when Diners Club cannot be used, use the

credit card statement or a copy of the online credit card statement. Copies of the credit card statement or online statement must be submitted as documentation.

All other documentation required in the Expense Reimbursement Policies must also be included with the expense report. Travel Advances 7.02 Travel advances are not available. Individuals requiring cash advances for out-of-pocket business expenses are entitled to reimbursement for one ATM transaction fee per trip. To the extent possible, all travel and entertainment expenses should be charged to your Diners Club card. Special Provisions for Extended Out-of-Town Projects 7.03 Under the current provisions of U.S. tax law, reimbursements of ordinary and necessary trade or business expenses incurred in connection with a temporary work assignment away from home do not constitute taxable income to the employee receiving the reimbursements. If, however, the facts and circumstances suggest that the work assignment fails either the temporary or away from home requirements, any reimbursements of the related travel expenses are fully taxable to the employee. Temporary Work Assignment Requirement 7.04 To meet the temporary work assignment requirement, both the firm and the employee must, at the beginning of the assignment, reasonably expect that the assignment will require the employee to be away from home for less than 12 months in a single location, and the actual length of the assignment must be less than 12 months. If the employee is away from home on an assignment that meets the temporary (less than 12 month) requirement, the firm’s reimbursement of the employee’s ordinary and necessary away from home travel expenses will not be included in the employee’s taxable income.

http://www.oanda.com/cgi-bin/ncc

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Indefinite or Long Term Assignments 7.05 If at the beginning of the assignment, or at any time during the assignment, the firm and the employee reasonably expect the assignment will require the employee to be away from home in a single location for more than 12 months, the assignment will be treated as indefinite for tax purposes. The result is that all expense reimbursements for away from home travel expenses incurred after the date on which it was determined that the assignment would exceed 12 months will be fully taxable to the employee. To avoid this result, to the extent appropriate, employee assignments on out-of-town projects should be made for periods not exceeding 12 months in a single location. An assignment memorandum that clearly sets forth the expected length of the assignment should document employee assignments to out-of-town projects expected to last 6 months or more. An assignment memorandum should also document subsequent changes in the expected duration of the assignment. Copies of assignment memos should be forwarded to the Dallas Accounting Service Center controller to allow for proper review. In cases where an employee is assigned to a project that will require the employee to be away from home for more than 12 months in a single location, the engagement partner, with functional leader approval, will determine the extent to which an employee will be reimbursed for away from home travel expenses, and whether a tax gross-up will be paid to the employee. These arrangements are to be agreed upon before the assignment begins, and must be documented in the assignment memorandum. Unless the assignment memorandum provides to the contrary, employees on indefinite or long term assignments will be reimbursed for all away from home travel expenses as provided in this document and will be eligible for a full tax gross-up reimbursement, including federal and state income taxes and FICA/Medicare taxes attributable to the taxable expense reimbursements paid during the calendar year. A partner that is asked by the firm to relocate to another city may, in lieu of relocating, elect to commute to the new city to fulfill his/her responsibilities. In such instances, the firm will pay the lowest applicable coach fare when traveling between the partner’s principal residence and the new city. Upgrades are a personal expense. All other costs to live in the new city, such as apartment rental, apartment furnishings, hotel charges, meals, utilities, etc., will be a personal expense and not subject to reimbursement, unless superseded by an agreement between the partner and the firm. A copy of the agreement should be forwarded to the Dallas Accounting Service Center controller to allow for proper review. The reimbursed airline travel will be taxable to the partner. The airline expense should be reported as “Taxable Reimbursement” on the TIMEnX report. Away From Home Requirement 7.06 The other requirement that must be satisfied to allow the firm’s reimbursements of away from home travel expenses to be treated as nontaxable reimbursements is that the employee must be “away from home” in the pursuit of a trade or business. Generally, a taxpayer’s “home” for purposes of the away from home requirement is considered to be located at (1) the taxpayer’s regular or principal place of business, or (2) if the taxpayer has no regular or principal place of business because of the nature of his or her trade or business, then at


http://dasc.us.kworld.kpmg.com/downloads/Less%20Than%2012%20Months%20Sample.doc

http://dasc.us.kworld.kpmg.com/downloads/Duration%20Changes%20Sample.doc

http://dasc.us.kworld.kpmg.com/downloads/Greater%20Than%2012%20Months%20Sample.doc

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the taxpayer’s regular place of abode in a real and substantial sense. If a taxpayer has neither a regular or principal place of business, nor a regular place of abode, the taxpayer is considered to be an itinerant whose “home” is wherever he or she happens to work. Thus, it is impossible for an itinerant to be “away from home” for purposes of travel expense reimbursements, and any such reimbursements would constitute taxable income to the employee regardless of the duration of the assignment. Since it is not possible for the firm to know whether an employee would be viewed as an itinerant under the foregoing rules, the firm will assume that employees claiming away from home travel expense reimbursements meet the away from home requirement. Employees who may be viewed as itinerants under the foregoing rules must discuss their eligibility for travel expense reimbursements and the related tax consequences with the engagement partner. A memorandum summarizing the agreement between the itinerant employee and the firm with respect to travel expense reimbursements must be prepared and forwarded to the Dallas Accounting Service Center controller to allow for proper review. Reporting Taxable Expense Reimbursements 7.07 Taxable expense reimbursements related to indefinite or long-term assignments are to be reported on the semi-monthly TIMEnX report in the same manner as nontaxable expense reimbursements, with a few exceptions. First, expense reimbursements that are taxable solely because an assignment is indefinite or long-term (see section 7.05) should be charged to a separate project number established to capture taxable expense reimbursement data for tax reporting and tax gross-up calculation purposes. Second, taxable reimbursements of meal expenses related to indefinite or long-term assignments are not subject to the 50% disallowance rule that applies to nontaxable reimbursement of meals and entertainment expenses. Such expenses should be reported as a “Miscellaneous” expense type, with an appropriate explanation on the TIMEnX report. Only those away from home travel expenses relating to the identified long-term engagement are to be reported as taxable reimbursements. Other travel expenses that may occur during the assignment period, such as travel expenses incurred to attend a training seminar, should not be reported as taxable reimbursements. When a separate project number is established as described above, the engagement partner must contact the area controller to coordinate the implementation of the above policy.


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REIMBURSEMENT TOPICS


Airline Club/Lounge Fees 8.01 Partners are entitled to reimbursement for one annual membership in an airline club/lounge. Partner requests for additional memberships and all employee requests are reimbursable with the approval of the appropriate functional leader. Such fees should be reported as “Other Club” expense type on the TIMEnX report and charged to the Club Dues authorized project for the business unit and product. Airline Travel 8.02 Domestic travel includes trips within the 50 states and to Canada, the Caribbean, and Mexico. International travel includes all overseas trips including South and Central America. When authorized for business or first class, individuals should attempt to use upgrade coupons or reserve full fare coach seating with an automatic upgrade as a more economical way of attaining the authorized service. All personnel requiring airfare to attend internal or external training, internal firm meetings or to participate in internal firm activities must purchase non-refundable tickets. In such instances, Group CTO must be used when available. In other situations where it is unlikely that an itinerary will change, non-refundable tickets provide considerable savings opportunities and should be used. If your plans change, note that non-refundable tickets retain value and can be exchanged within a designated timeframe – ask your travel counselor. If additional costs are incurred due to changes in travel plans, these additional costs are reimbursable and should be charged to the appropriate project or absorbed personally if the change was for personal reasons. Should you no longer need to travel, you must cancel your non-refundable ticket prior to the originally scheduled outbound flight date or the entire value of the ticket will be lost. Reimbursement for the cost of non-refundable tickets may be submitted after the originally scheduled outbound flight, even if your plans change and the tickets are applied to a future flight. Employees Partners

Domestic Reserve lowest refundable coach fare, except as noted above. Upgrades are a personal cost. International Upgrade to business class. If upgrade is unavailable, reserve business class.

Flights less than 2 hours Reserve lowest refundable coach fare, except as noted above. Upgrades are a personal cost. Flights between 2-4 hours Reserve lowest refundable coach fare, except as noted above. Upgrades will be reimbursed.



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Flights greater than 4 hours Business class is authorized. If business class is unavailable, first class is authorized. Full fare coach (Y-Up Fare) with an automatic upgrade should be utilized when available to obtain business class seating.

Travel with a Client Travel with a client is at the class prescribed by the client as long as it is at the client’s request and is an expense chargeable to the project. Non-billable client travel expense must have express written approval of the appropriate functional leader.

Travel with a Client Travel with a client is at the class of service prescribed by the client. Number of Partners on Same Flight Please refer to the Partner Travel Continuity Policy.

8.03 The cost of upgrade coupons, when authorized as described above, is reimbursable at the time of purchase (e.g., a booklet of 10 upgrades). Appropriate documentation must be attached to the TIMEnX report. Upgrades for personal use should be purchased separately. The use of upgrades should be documented when claiming reimbursement for the corresponding airline tickets, (e.g., “used three upgrades with this ticket”). 8.04 Reservations should be made as early as business plans permit. Many of the best airfares are found when looking from 21 to 14 days before travel. An explanation of airfares booked less than seven days before travel should be provided on your TIMEnX report. 8.05 Airline tickets that have been billed to a master account are not charged to the traveler’s credit card and may not be claimed for reimbursement by the traveler. Travelers should verify that each airline ticket claimed for reimbursement has been charged to their credit card, as shown on the passenger receipt. 8.06 A higher-grade ticket may not be converted into two lower-class tickets to permit another person to accompany the traveler on a business trip. 8.07 Travelers are not entitled to personal payments or rebates if they travel at a fare class lower than their otherwise entitled fare class. 8.08 Travelers should request airline reservations according to approximate necessary departure or arrival time rather than by specific airline or flight number. The firm has negotiated agreements, which offer substantial discounts with major domestic and international airlines. Travelers are required to use these designated airlines when they provide the lowest logical or negotiated fare for flights departing within one hour before or after the preferred departure or arrival time. 8.09 Travelers should consider the use of alternate airports when the fare differential represents significant savings. 8.10 If a change in itinerary results in an exchange of tickets, only the net amount actually paid for the tickets should be claimed for reimbursement. This amount may be less than the total fares appearing on the passenger receipts. For example, assume a $200 return leg of a round-trip ticket (original round trip cost $400) is exchanged for a one-way return ticket costing $300 ($200


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original cost, plus $75 change fee, plus $25 incremental one way fare). The total fares appearing on the passenger receipts might be $700 ($400 for the original and $300 for the exchanged ticket). However, the amount claimed for reimbursement should be $500, representing the amount actually paid ⎯ $400 for the original ticket and $100 for the exchanged ticket. In such instances, an explanation of the amount claimed should be provided. 8.11 Reimbursement for the cost of airline tickets generally may only be requested as the tickets are used. This means that the date of the latest leg of the ticket cannot be later than the close of the pay period covered by the TIMEnX report. However, if the Diners Club due date for the tickets purchased precedes the reimbursement date that would occur by adhering to the above guideline, early reimbursement may be requested to satisfy the payment due date. In such cases, an explanation of the early reimbursement request should be provided in TIMEnX. Reimbursement for the cost of non-refundable tickets may be submitted after the originally scheduled outbound flight, even if your plans change and the tickets are applied to a future flight. 8.12 Although it is unusual for a traveler to receive a cash refund or rebate against a credit card payment, it is possible upon check-in to receive a refund when a fare is reduced or when a rebate is offered due to a promotion by the airline. In such instances, the refund/rebate should be reflected as a credit on the traveler's semi-monthly TIMEnX report by netting the amount against other air expenses claimed for the same project. If this is not possible, contact the Dallas Accounting Service Center for instructions. 8.13 Changes in airline pricing structures have eliminated many of the savings formerly associated with Saturday night stayovers. However, to provide overall savings to the firm, travelers may select a discounted airfare that requires a Saturday night stayover and travel outside of normal business hours. If so, the firm will reimburse the individual for the single hotel room costs, applicable meal expenses (per diem for staff) and local transportation costs for up to three days. Reimbursement of these expenses is limited to the difference between the lowest applicable non-stayover fare and the actual discounted stayover fare. Documentation of the lowest non-stayover fare, provided by CTO or Travel Services, should be submitted with the expense report. A calculation of the extra expenses compared with the reimbursement limitation should also accompany the TIMEnX report. Expenditures for entertainment during the extended stay are absorbed personally. 8.14 Certain foreign airports may have arrival and/or departure taxes that must be paid separately by the individual traveler. Such expenditures are reimbursable when traveling on KPMG-related business in accordance with these policies.


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Automobile Rentals 8.15 Automobiles may be rented only when public transportation and taxis are impractical, more expensive, or not available, and when traveling outside of the area serviced by your resident office, except as noted below. Occasionally, an individual who does not own an automobile may be assigned to a client within the local office service area where alternative modes of transportation, (e.g., taxis, trains, buses, etc.) are not available. In such instances, if that individual elects to rent an automobile for commuting to the client site, the rental fee and other ancillary costs, such as monthly parking, gasoline, etc. are not reimbursable. However, the individual will be reimbursed for mileage in accordance with section 8.77. 8.16 All reservations should be made using the traveler’s corporate Diners Club card and booked through CTO or Travel Services, which use KPMG's preferred vendor contract rates. 8.17 Vehicles up to an intermediate (midsize) class are customary for individual travelers. When more than one person travels to the same location, they should share a rental vehicle if it is cost-effective and practical. The next size class may be rented when three or more people are traveling together. 8.18 Reimbursable items include tolls, gasoline purchases and the actual cost of the rental excluding the fee or surcharge associated with a frequent flier mileage award program, as defined in the rental agreement. The rental of a navigational device (e.g., GPS) is reimbursable if the traveler is unfamiliar with the area and the rental will alleviate safety concerns or potential delays. One-way rentals, although reimbursable, should generally be avoided because they often include mileage or drop-off charges, and must be specifically explained in the documentation attached to the TIMEnX report. Cellular Phones, Pagers, and Wireless Data Devices 8.19 Single-Rate Cellular Plans – Individuals with significant business usage who would reduce the firm’s costs by participating in a “single-rate plan” must have their cellular service provided through such a plan, utilizing firm-negotiated contracts. Individuals should select a plan that best suits their business needs, taking into account long-distance charges, number of monthly minutes, roaming and international usage. If your current plan is not with a firm authorized provider, you must switch to an authorized firm plan to be reimbursed as described below. If the firm’s authorized providers do not provide adequate coverage to fit your needs, you may request authorization from your functional leader to use a different provider. The first $20 per month (intended to represent the cost typically associated with lower usage personal plans) is not reimbursable. In addition, where the actual cost associated with personal usage is greater than $20, (e.g., in the case of excess charges resulting from personal calls), the amount claimed for reimbursement should be the total bill reduced by that greater amount. Similarly, any “family plan” costs that are included in your monthly bill are not reimbursable and must be deducted from your reimbursement request. The maximum reimbursement amount is the total bill minus $20. It is not necessary to attach the detailed listing of all phone calls made.




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Information regarding the firm’s authorized cell phone service providers may be found on the Technology Center website. 8.20 The following costs related to cellular phone usage are not reimbursable: • Phone purchase (see section 8.21), lease, installation, and insurance costs; • Fixed monthly service charges, except in conjunction with participation in

a single-rate plan as described in section 8.19 above; • Special features, such as call waiting, answering service, voice mail,

conference calling and call forwarding, unless they are included in a single-rate plan;

• Additional hardware, such as spare battery, spare battery charger, car

adapter, and hands-free headset, except that the cost of a hands-free headset up to $50 is reimbursable if required by local law when driving an automobile.

Business related calls should be charged to a client or authorized project and reported in TIMEnX under the expense category “Cell Phone.” 8.21 Pagers, Aircards, Wireless Data Devices and Combination Phones (Treos, BlackBerries, etc.) – The cost of purchasing or leasing a pager and the related monthly service charges are not reimbursable unless approved by your functional leader. Approvals of pager expenses should be limited, since participants in single-rate cellular plans should generally not need pagers. The cost of a wireless broadband access card (Aircard) that enables wireless access to a provider’s network and the related monthly service fees are not reimbursable. If you are approved by your functional leadership to use wireless e-mail and have signed up for a firm-sponsored program, the initial cost of purchasing a firm-approved wireless data device will be reimbursed by the firm. Similarly, replacement of a lost, broken, or stolen device and ancillary items (stylus, battery charger, etc.) is reimbursable with functional leader approval. The firm has domestic and international discounted wireless service plans available for individuals with wireless data needs. Monthly charges for domestic wireless data services are reimbursable up to the amount negotiated by the firm with approved providers, currently $10, if such service is approved by your functional leader and is obtained through the firm-sponsored programs. If your needs also include international wireless data services, monthly charges are reimbursable up to $50 plus international data roaming fees. For international coverage to qualify for reimbursement it must be approved by your functional leader and the data plan must be obtained through a firm-sponsored program. Reimbursement is limited to one voice and one wireless data plan (typically packaged together with a Treo or BlackBerry). As noted above, the first $20 per month applicable to the cellular portion of the monthly charges is not


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reimbursable. Incremental costs associated with multiple cellular plans are not reimbursable. Accordingly, if you are approved to participate in a firm-sponsored plan, it may be necessary to switch your cellphone carrier and thereby be subject to a potential termination fee imposed by your former carrier. In such instances, the firm will reimburse you for the lesser of the amount of the termination fee, the cost of maintaining your existing service until your current contract expires, or $250. Termination costs or ongoing monthly charges not to exceed $250 must be supported by attaching to your expense report the contract or similar documentation evidencing the costs incurred, along with an explanation which references section 8.21 of this policy document. These costs should be reported as “Cell Phone” expense type on the TIMEnX report. Participants in the firm’s wireless e-mail program are required to sign an individual liability contract. Upon leaving the firm, participants are responsible for any termination fees imposed by the carrier if the election is made to discontinue cellular service prior to the contract expiration. The firm license for wireless e-mail will be discontinued upon termination, but the device may be kept and used for cellular service if the participant chooses to pay the ongoing monthly cellular fee.

Civic and Charitable Organizations 8.22 Certain civic and charitable organizations have annual membership fees. Such fees are reimbursable through the TIMEnX reporting system with approval of the appropriate functional leader. The approval should be included as part of the expense documentation submitted with the TIMEnX expense report. Civic and charitable membership fees should be reported as the “Civic Org” expense type on the TIMEnX report. Charitable contributions are not reimbursable through TIMEnX.

Clubs – Athletic, Social, and Luncheon 8.23 Initiation fees for partners (including capital assessments, capital improvement bonds, and related loans for club membership) to athletic, social, and luncheon clubs must be approved in advance by the functional leader as defined in section 2.02. Such expenditures are reimbursable through Partner Accounts (refer to Appendix B). For fees $25,000 or greater, functional vice chairman approval is also required. All fees for non-partners must be approved in advance by the functional vice chairman. A summary business case (refer to Appendix B) must be submitted in support of the reimbursement request. Memberships registered in the individual’s name rather than the firm’s name will result in taxable income to the individual in the year paid, except for the refundable portion, if any. The refundable portion of the membership will be accounted for as an interest-free loan from the firm, secured by the refundable deposit and repayable when the individual leaves the firm, is no longer a member of the club, or 15 years. The loan may be extended at the end of the initial 15-year period (refer to Appendix B). Only clubs that have a non-discrimination membership policy are eligible for reimbursement. An affirmative statement related to the non-discrimination policy must be included on any request for reimbursement of initiation fees or capital assessments. (Refer to Appendix B).



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8.24 Except as otherwise provided for in this document, club dues are not reimbursable. Minimum usage fees, locker fees, golf handicap and association fees, merchandise purchases and other non-capital assessments are also not reimbursable. Dues for luncheon clubs, i.e., city clubs offering business lunches only, are reimbursable with the approval of the appropriate functional leader. 8.25 For partners maintaining more than one golf club membership, club dues are not reimbursable for the first club. Additional club membership dues will be reimbursed if a partner uses the additional club(s) principally for business purposes, the club is a corporate membership, the membership is transferable by KPMG upon the partner’s retirement or departure from the firm, the club maintains a non-discriminatory membership policy and the membership is approved by the functional vice chair. An affirmative statement related to the non-discrimination policy (Refer to Appendix B) must be included on any request for reimbursement of “second club” dues. Only club charges related to particular business activities are reimbursable through the TIMEnX report and then only if the activity meets the criteria set forth in this document. Home/Remote Technology and Equipment 8.26 High-speed internet access charges of a reasonable amount incurred while in travel status, (e.g., hotel access charges or wireless hot spot charges) are reimbursable. The following expenses associated with remote access or maintaining a home office are not reimbursable: • Installation costs and monthly service charges for high-speed

telephone/connectivity, (e.g., DSL, fiber optics, cable modem, ISDN). • Installation costs and monthly service charges for second telephone line. • Printers, copiers, fax machines, paper shredders and related supplies. • Ancillary computer equipment, (e.g., data backup solutions, docking

stations, aircards, etc.). Note that data backup solutions for use in the KPMG office may be obtained through Firmwide Procurement – Technology Purchasing.




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Hotels 8.27 All hotel accommodations must be booked in a preferred hotel (where available) through CTO or Travel Services to ensure the most favorable negotiated or corporate rates. Except as noted below, the traveler must pay all hotel charges with the firm’s corporate Diners Club card upon checkout. Charges may not be billed directly to the firm unless the traveler is attending training or a firm meetng for which a master billing has been authorized. In these instances, lodging and group meals will be master billed. Incidentals such as room service, other meals charged to the room, etc., are paid by the traveler and claimed via TIMEnX. • Moderate-class hotels provide the best value and their usage is preferable

unless there is no moderate-class hotel in the city or unless the particular location of the hotel is not cost beneficial, (i.e., savings are realized on the hotel but more is spent on transportation). Under these circumstances business-class hotels are to be used. This policy will not apply when the traveler participates in a seminar or convention where the sponsoring organization has booked blocks of rooms at a specific hotel, and in those limited situations where clients insist on making the travel arrangements.

• In locations where there are no preferred hotels available, travelers should

not exceed the KPMG-established hotel rate. When necessary, travelers should contact Travel Services to obtain the applicable established rate and to obtain information about comparable hotels within the rate guidelines.

• To help travelers ensure they are paying the proper rate, Travel Services

will indicate on the itinerary the KPMG-negotiated rate to be charged by the hotel.

8.28 A single non-concierge level room should be reserved. Suites are acceptable only when the suite accommodation is the standard-type room of the hotel. 8.29 Except as noted in section 8.27, room reservation guarantees are automatically made to the traveler’s Diners Club card by Travel Services at the time of booking. If the traveler is unable to use the reservation, it is the traveler's responsibility to cancel through Travel Services. Most U.S. hotels require that cancellations be made by 4:00 p.m. on the scheduled date of arrival. “No-show” charges are not reimbursable, unless a business or personal emergency beyond the traveler’s control precludes the traveler from timely notifying the hotel. 8.30 Reasonable charges for the use of health clubs while traveling (hotel, airport, etc.) are reimbursable. Such reimbursements are taxable and should be reported as “Taxable Reimbursement” expense type on the TIMEnX report. The following types of expenses are considered to be of a personal nature and will not be reimbursed: • Personal or extra-cost services such as barber, beautician, manicurist,

shoeshine, and massage; • Special room services, such as in-room movies (mini-bar services are

reimbursable if used in lieu of allowable per diem); and

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• Additional charges for room upgrades, poolside rooms, or special floors 8.31 An itemized hotel bill must be included with your TIMEnX expense reimbursement request. Submission of a credit card statement is not acceptable. The cost of the hotel room should be reported as “Lodging” expense type on the TIMEnX report. Reimbursable meal, entertainment and telephone access charges included in the hotel bill must be segregated into the appropriate expense types on the TIMEnX report. Incidentals 8.32 Incidentals include tips for porters, bellmen, etc. The “Incidentals” portion of the per diem allowance is subject to the IRS 50% deductibility limitation, and accordingly, the full per diem amount including incidentals should be reported as “Per Diem Meals” on the TIMEnX report. (Also see section 8.76). Laundry and Dry Cleaning Services 8.33 Individuals traveling on firm business and away from their homes for more than three days are entitled to reimbursement for reasonable actual laundry/valet expenses, beginning with the fourth day. Long-Distance Telephone 8.34 Cell phones generally provide the most economical method of long distance voice communication. All personnel in travel status outside of a KPMG office are required to use either their cell phone covered under the firm’s single rate cellular plan or a firm-issued calling card. To obtain a calling card you must register at the Calling Card Program website. To facilitate long-distance calling when traveling internationally, individuals using calling cards should obtain the appropriate calling card country access codes at the Calling Card Program website (Dialing Instructions) prior to their departure. International roaming rates may be very costly, and in such instances, use of a calling card rather than a cell phone should be considered. Direct dial or operator-assisted calls from hotel phones are extremely expensive and should be avoided. Accordingly, such calls will not be reimbursed. Business-related calls are reimbursable, including calls home of reasonable length. Local area and 1-800 access charges, including those associated with remotely accessing KPMG’s network via our VPN, are reimbursable and should be submitted through TIMEnX. Cell phone charges should be reported as “Cell Phone” expense type on the TIMEnX report. Calling card charges should be reported as “Telephone/Non Cell Phone” expense type on the TIMEnX report. 8.35 Air phone charges are not reimbursable.


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Meals 8.36 Personnel may be reimbursed for meals when: • Working overtime, weekends, or KPMG holidays (except partners); • Traveling out-of-town; or • Conducting firm business, as described in sections 8.44 through 8.49 Refer to the policy and guidelines regarding the consumption of alcohol during meals and firm events. Overtime, Weekend and Holiday Meal Reimbursement 8.37 Employees who work outside their home ten or more hours on a weekday with a minimum of two hours in excess of their standard workday are entitled to be reimbursed for the lesser of their actual out-of-pocket cost of dinner or the current dinner allowance. Employees who work outside their home at least four hours on a weekend or holiday are entitled to be reimbursed for the lesser of their actual out-of-pocket cost of lunch or the current lunch allowance. Management personnel, excluding partners, working during these time frames are not subject to the reimbursement limitations defined below, but are expected to use good judgment in selecting moderately priced meals. Partners are not entitled to the overtime, weekend or holiday meal reimbursement. Maximum reimbursements for overtime, weekend and holiday meals are: • Lunch $6 • Dinner $16 8.38 Overtime, weekend and holiday meals, regardless of the amounts, require a receipt. 8.39 It is sometimes more convenient to have one individual pay for the meals of all team members who qualify for a meal reimbursement. This practice is acceptable providing the individual lists the names of all others covered by the payment and abides by the above limitations. The other team members are not entitled to any reimbursement under these circumstances. In such instances, to be fair and equitable, it is suggested that payment on behalf of other team members be rotated, since “Overtime Meals” are treated as taxable compensation. 8.40 Overtime, weekend, and holiday meal reimbursements must be reported as “Overtime Meals” expense type on the TIMEnX report (treated as taxable compensation) unless all of the following requirements are met: • The meal is consumed by three or more people, each of whom is working

overtime (evening, weekend or holiday – see above definitions); • The meal is consumed on premises (KPMG office or client worksite) in a

group setting; and • Work is performed before and after the meal by all individuals consuming

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When all of the above requirements are met, the meal must be reported as “Fully Deductible Group Meals” expense type on the TIMEnX report. Such meals are subject to the limits defined in section 8.37. Out- of -Town Meal Reimbursement 8.41 The firm’s meal reimbursement for staff personnel when traveling out- of-town (outside of the local office service area) is based on the Federal government’s maximum per diem meals and incidental expense rates. These rates vary based on the city, county or country in which the expense is incurred. The breakdown of the per diem rates for selected KPMG locations appears in Appendix A. The per diem rates for other locations may be found at the website referenced below. If the per diem rate is used, the city and state or country traveled to and the applicable per diem locality, referenced by city and state or country, must be reported in the TIMEnX expense comment box. Official per diem rates for other locations within the continental U.S. (CONUS) and locations outside the continental U.S. (OCONUS) may be found on the Department of Defense Per Diem, Travel and Transportation Allowance Committee website. The documented dates for out-of-town travel (e.g., hotel bill, airfare receipt, etc.) must correspond with the dates of the per diems claimed. Where evidence of an overnight stay is not readily available, (e.g., extended stay apartment rentals), the functional leader must provide approval for reimbursement of per diems. However, such approval for reimbursement of per diems is not required when room charges are master billed and evidence of an overnight stay is not otherwise available. 8.42 Directors and managers may claim per diems or their actual meal costs. Partners should claim their actual meal costs, with the exception that per diems may be claimed for long-term assignments with functional leader pre-approval. It is expected that good judgment will be exercised in selecting moderately priced meals subject to reimbursement. Certain engagements, such as those assigned to the Federal Services practice, might contractually stipulate that the maximum amount billable to the client for meals is limited to the applicable per diem rates. In such instances, individuals otherwise authorized to claim actual meal costs should check with the engagement partner to determine the amount that should be submitted for reimbursement. 8.43 A per diem meal should not be claimed when a meal is paid for by others or provided onsite as part of a seminar or meeting. Business Meals 8.44 Meals provided to KPMG partners and employees or to external parties provide a means to encourage social interaction and develop business relationships. Individuals are expected to use good business judgment at all times.


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The cost of dining with clients, prospective clients, suppliers, other external parties or firm personnel may not exceed $150 per person or $2,000 in total. In situations where it is anticipated that the cost will exceed either of these amounts, functional leadership approval should be obtained in writing prior to the event. Meals should not be lavish or extravagant and must be directly related to a business purpose. Expenses incurred at venues which could be considered inappropriate, such as adult entertainment establishments, will not be reimbursed. Frequent meals with the same client, prospective client, supplier, or firm personnel may be viewed as questionable, unless there is a direct and discernable benefit derived. A broad guideline that may be applied to these situations is a maximum of four times per year. 8.45 The amount of any reimbursement is equal to the actual amount of the expense incurred plus a reasonable tip. Reimbursement for qualifying meals served in one’s home is equal to the actual cost of the food and drink purchased and consumed and/or the catering costs, and requires functional leader approval. Business Meals Involving Solely Local Office Personnel 8.46 Business meals involving solely local office personnel are reimbursable only when: • A formal functional or product group meeting, task force, or similar group

meeting is being conducted; or • Specific client matters are discussed and the engagement partner or

engagement manager is present; or • A partner or director (or designee with prior approval) takes an employee

to lunch for special circumstances, such as new hire, performance review, mentoring, farewell, etc.

8.47 Meals should be at a reasonably priced restaurant or club and the most senior person in attendance should pay for the meal. Business Meals Involving Others 8.48 Business meals involving others might include clients, prospective clients, suppliers, personnel from other KPMG offices, recruits, personnel from civic and community organizations, etc. Personnel are expected to use good business judgment for these types of expenditures. The most senior person in attendance should pay for the meal. 8.49 Individuals must take steps to avoid circumstances that might cause an outside party to violate their company’s policies or procedures with respect to meals and entertainment. Note that there are significant restrictions regarding the entertainment of public officials. Please consult with the Office of General Counsel or the Ethics and Compliance Group if circumstances warrant. Reporting of Meals 8.50 Meals (other than overtime meals and per diems) should be reported as “Meals” expense type on the TIMEnX report, except for meals which are not





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currently subject to the IRS 50% disallowance for meals. Such meals should be reported as “Fully Deductible Group Meals” expense type on the TIMEnX report. 8.51 Examples of “Fully Deductible Group Meals,” in addition to those referenced in section 8.40, include, but are not limited to: • Meals consumed at training sessions, conferences and seminars held inside

or outside the office where the meal is provided at the event site (including food and beverage charges allocated to participants on the lodging bill);

• Meals to recognize individual or group achievements (such as retirement

lunches and sign-off lunches at the conclusion of a major project) where a majority of the individuals invited to attend are below the manager level;

• Meals in connection with formal and informal mentoring programs where a

majority of the individuals included in the program are below the manager level;

• Meals consumed at any type of meeting of eight or more people which is

held occasionally, (e.g., four times or less per year), for social reasons, to discuss firm (non-client) business or to recognize individual achievements; and

• Coffee, pastries and nominal food items, (e.g., cookies and snacks),

provided buffet style Questions concerning the classification or reporting of meals should be directed to your area or process controller. Parking 8.52 Monthly and daily weekday parking fees incurred to work at your assigned KPMG office are considered personal commuting expenses and are not reimbursable and are not pro-ratable in the situations described below. 8.53 Parking fees are reimbursable when incurred for the following valid business reasons: • When working on weekends or holidays; • When traveling out-of-town on firm business, (e.g., at the airport); • At a client site or KPMG office other than your assigned office (the

reimbursable amount is the incremental cost over the cost of the assigned office parking);

• When attending a firm- or client-sponsored social event; • Short-term parking (less than two hours) at your assigned office to pick up

and/or drop off work materials; and • Subsequent parking fees paid in a business day. For example, if you pay a

daily parking fee to commute to your assigned office, travel to a client site and incur a second parking fee, or move your car to a safer location in the


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evening, the incremental cost in excess of the assigned office fee is reimbursable with supporting documentation for both fees paid.

Parking charges should be reported as “Ground Trans Exc Mileage” expense type on the TIMEnX report. Parties, New Hire/Farewell Functions and Other Events 8.54 The decision to have a sign-off or post-engagement party rests with the engagement partner. The appropriateness and propriety of this type of expenditure should be based on the recoverability of the expense and profitability of the engagement. The engagement partner is responsible for paying for the event and must be present. Reimbursement will be to the engagement partner only. Engagement teams should invite client personnel to these parties. Since reimbursable expenses for post-engagement parties are not currently subject to the IRS 50% disallowance for meals and entertainment expenses, they should be reported as ”Fully Deductible Group Meals” expense type on the TIMEnX report. 8.55 New hire or farewell group lunches are reimbursable with documented pre-approval by the business unit functional leader or budget owner. 8.56 New hire and farewell events held after normal business hours for client service delivery staff and client service support personnel are on a "no-host" basis. All expenses are considered personal in nature and are not reimbursable. 8.57 New hire and farewell events held after normal business hours for partners, directors and management personnel must be approved in advance by the business unit functional leader or budget owner. A sponsoring partner or director will be responsible for obtaining approval and paying for the event. Reimbursement will be to the sponsoring partner or director only. Since reimbursable expenses for farewell parties are not currently subject to the IRS 50% disallowance for meals and entertainment expenses, they should be reported as “Fully Deductible Group Meals” expense type on the TIMEnX report. 8.58 Parties or events not otherwise described in this document may be reimbursed via TIMEnX with documented pre-approval by the business unit functional leader or budget owner. However, such events with greater than 20 participants or estimated spend of greater than $5,000 require Events & Meetings Services (EMS) involvement, in accordance with firm policy. In these instances, reimbursement claims are generally not needed, since EMS handles billing and related matters. Refer to the policy and guidelines regarding the consumption of alcohol during meals and firm events. Gifts to departing personnel are not reimbursable through TIMEnX. Partner Physical Examinations

8.59 Annual partner physical exams are reimbursed by the firm up to certain limits. Reimbursements are credited to partners' accounts. Complete details on the program can be found in Benefits Connection under Benefit Plans/Health & Welfare/Annual Health Examinations.








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The 'Physical Reimbursement Form - Partners' can be found at http://hrscforms.us.kworld.kpmg.com/hrsc/. Professional and Industry Conference Fees/External Training Costs 8.60 Professional and industry conference fees and external training costs are reimbursable with the documented pre-approval of the appropriate functional leader. Such costs should be reported as “Miscellaneous” expense type on the TIMEnX report and charged to the Professional Activities or Education authorized project, as appropriate, for your business unit and product. Professional Examinations 8.61 The CPA exam fees and the cost of CPA review courses are reimbursable under certain circumstances. Refer to the Human Resources website for additional information. Other professional examination fees and related out-of-pocket expenses, which are approved by the appropriate functional leader, are reimbursable upon the successful passing of the exam. 8.62 Bonuses are paid to individuals who successfully pass certain professional examinations. Such bonuses are paid through payroll. Refer to the Human Resources website for additional information. Professional Licenses 8.63 Application and annual fees for licenses to practice in your resident state are reimbursable through TIMEnX. Such fees are reimbursable only after the licensing requirements have been completed. The annual fee for the state of original licensing is also reimbursable for those who have a reciprocal certificate in their resident state. When there is a requirement to practice in another state, such license fees are reimbursable. A copy of the fee notice will be accepted as documentation if the original notice must be returned to the applicable state. This is an approved exception to our policy of requiring original receipts. Professional license expenditures should be reported as “Prof. Dues” expense type on the TIMEnX report and charged to the Professional Activities authorized project for your business unit and product. Professional Societies 8.64 Annual membership dues for the AICPA and for your resident State Society of CPAs are reimbursable through the TIMEnX report. Optional expenditures, which often appear as part of these billings, (e.g., PACs, scholarship funds, etc.), and dues for non-resident state societies are not reimbursable. State CPA societies are required to disclose the portion of annual membership dues used for lobbying activities, as this portion of the annual dues is not deductible for tax purposes by the individual member. To ensure that the firm properly identifies the non-deductible portion of professional society dues designated for lobbying activities, annual professional society dues must be separated into the deductible and non-deductible components and entered as two line items on the TIMEnX report. The deductible portion of professional society dues should be reported as “Prof. Dues” expense type on the TIMEnX


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report. The portion of the dues used by the professional society for lobbying activities should be reported as “Lobbying” expense type on the TIMEnX report. Professional society dues should be charged to the Professional Activities authorized project for your business unit and product. 8.65 Membership dues in other professional societies required as part of the position, (i.e., actuarial societies, certified planners, etc.), or professional societies that promote diversity in the workplace, (i.e., National Association of Black Accountants; Association of Latino Professionals in Accounting and Finance; National Asian American Society of Accountants; American Society of Women Accountants; and American Women’s Society of Certified Public Accountants), are reimbursable through TIMEnX. Such reimbursement requires the documented pre-approval of the appropriate functional leader. A copy of the dues notice will be considered as acceptable documentation for all professional society memberships, since most societies require return of the original invoice with payment. This is an approved exception to our policy of requiring original receipts. It is not necessary to obtain a copy of the cancelled check payable to the respective society, although such documentation is acceptable. Rail Transportation 8.66 Rail transportation may be a more convenient means of travel than airline or automobile. All rail travel should be booked in advance through Travel Services. Personnel are reimbursed for coach class rail travel. Partners are reimbursed for first class (club car) if the duration of the trip exceeds two hours. Rail transportation expenditures should be reported as “Ground Trans Exc Mileage” on the TIMEnX report. Recreational Fees 8.67 Recreational fees incurred, such as greens fees, caddie fees, golf cart fees and tennis fees, are reimbursable as long as the expenditures are reasonable in amount and the particular activity has a valid business purpose. Where it is customary to pay such fees in cash, (e.g., caddie fees), a receipt is not required. Merchandise purchases and lessons are not reimbursable. 8.68 Personnel should use good judgment as to whether the reimbursement claimed has a valid business purpose. For example, frequent golf outings with the same individuals assume more of a personal purpose and are not reimbursable. 8.69 Recreational fees should be reported as “Entertainment” expense type on the TIMEnX report. Spouse/Domestic Partner Travel 8.70 When business-related activities of a KPMG partner require travel by a spouse/domestic partner, and the travel has been pre-approved by a functional leader, the costs are reimbursable by the firm. Such travel reimbursements are taxable to the partner and are grossed up for tax purposes. Spouse/domestic partner travel costs (airfare, car service, etc.) should be reported as “Partner Spouse” expense type on the TIMEnX report. The documented pre-approval for spouse/domestic partner travel must be submitted with the expense report.






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8.71 Extended (more than one week) out-of-town engagements may provide for reimbursement for periodic trips back to the individual’s place of residence. In lieu of such trips, the individual’s spouse/domestic partner may travel to the work location, with prior written approval from the engagement partner, as long as there is no incremental cost. Such travel expenditures should be reported as “Taxable Reimbursement” expense type on the TIMEnX report, and are considered taxable and subject to withholding (with no tax gross-up). Taxi and Car Service 8.72 Public transportation is generally the most economical transportation option, and should be used if it is considered safe and practical. Taxi or car service is reimbursable when it is a cost-effective means of transportation. The amount of the reimbursement is equal to the actual fare, tolls, “extra” charges (for luggage, passengers, etc.), and a reasonable tip. When more than one person travels to the same location, they should share a taxi or car service if it is cost-effective and practical. The Ground Transportation Matrix provides transportation options to/from each of the KPMG offices and the local airport. Please consult this matrix when planning a trip to a KPMG office to determine the most cost-effective option. Car service, in lieu of a taxi, is authorized only when taxis are impractical, more expensive, not available, or potentially unsafe for late night travel. Car service costs should be charged through the TIMEnX report and not billed directly to the office. A standard limousine (sedan) should be reserved when arranging for car service. Taxi and car services should be reported as “Ground Trans Exc. Mileage” expense type on the TIMEnX report, except for taxable amounts as noted below. Taxi, car service or other modes of transportation used to commute between the home and the workplace are not reimbursable. However, if an individual is required to work overtime or to attend an after-hours business function, and as a result incurs transportation costs in excess of normal commuting costs, the incremental costs are reimbursable. In such instances, the lowest cost mode of transportation that is reasonably available should be used. Reimbursements received under this provision are taxable if the number of occurrences exceeds a de minimis amount, which we have determined to be more than twice in any calendar month, and should be reported as “Taxable Reimbursement” expense type on the TIMEnX report. Tickets to Sporting Events and Other Entertainment 8.73 Entertaining clients, other external parties or KPMG personnel may be an effective way to encourage social interaction and develop positive business relationships. The cost of entertaining clients, prospective clients, suppliers, other external parties or firm personnel may not exceed $250 per person or $3,000 in total. In the rare situations where it is anticipated that the cost will exceed either of these amounts, functional leadership approval should be obtained in writing prior to the event. Entertainment should not be lavish or extravagant and must be directly related to a business purpose. Expenses incurred at venues which could be considered

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inappropriate, such as adult entertainment establishments, will not be reimbursed. Frequent entertainment of the same client, prospective client, supplier, or firm personnel should be avoided. A broad guideline that may be applied to these situations is a maximum of four times per year. Individuals must take steps to avoid circumstances that might cause an outside party to violate their company’s policies or procedures with respect to meals and entertainment. Note that there are significant restrictions regarding the entertainment of public officials. Please consult with the Office of General Counsel or the Ethics and Compliance Group if circumstances warrant. 8.74 Ticket costs are reimbursable if incurred in connection with a valid business purpose. Reimbursement for other costs that may be incurred during the event, (e.g., meals, parking), is governed by the appropriate policies set forth elsewhere in this document. The individuals in attendance and the business purpose must be listed. Ticket costs are reimbursable at the time of actual use and not at the time of purchase. A client project number should be charged when the entertainment expense is client-related. 8.75 The cost of tickets purchased by the firm and allocated to the user through the Ticket Manager process should be reported in accordance with the instructions provided on the e-mail message received from Ticket Manager. The face value of tickets directly purchased by the user should be reported as “Entertainment” expense type on the TIMEnX report. Premiums paid in excess of the face value of the tickets should be reported as “Ticket Broker” expense type on the TIMEnX report. Tips 8.76 Tips to porters, skycaps, bellhops, and others of a similar nature are permitted where reasonable and appropriate. If per diems are claimed, such tips are included as part of the “Incidentals” portion and should not be claimed separately. Receipts need not be provided since they are typically unavailable. Tips (other than those included in per diems) should be reported as “Miscellaneous” expense type on the TIMEnX report. Transportation and Mileage Reimbursement 8.77 Individuals will be reimbursed for use of personal automobiles when the firm requires such usage and the mileage in any single day exceeds their base mileage rate (normal commuting distances). The mileage reimbursement rate is the maximum rate allowed by the IRS and the reimbursement is calculated as follows: • Determine the total number of business-related miles traveled during the

day - beginning and ending at your residence. • Subtract from that total your base mileage amount (normal commuting

distance) when making a round trip between your residence and your assigned office.


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• The difference is your allowable reimbursed miles that are entered in the

“Mileage” box on the TIMEnX report. TIMEnX computes the reimbursable amount based on the current IRS business use rate. If the difference is zero or a negative number, you are not entitled to any reimbursement.

• If individuals who normally use public transit are required to use their

personal automobiles for business purposes they may be reimbursed for mileage, less normal public transit costs. The incremental costs incurred should be entered as “Ground Trans Exc Mileage” expense type on the TIMEnX report, with an appropriate calculation and explanation provided.

8.78 Mileage amounts claimed and the specific destination, (e.g., the client name), should be documented in the “Mileage” expense comment box on the TIMEnX report. 8.79 When more than one person is working at a client, carpooling is encouraged. The driver should claim the mileage expense reimbursement. The other members of the carpool are not entitled to any reimbursement under these circumstances. 8.80 Occasionally, individuals visit multiple offices and/or client locations during a single business day. Under these circumstances, you should use your best judgment when allocating the mileage reimbursement charges among multiple project numbers. 8.81 Bridge and highway tolls are reimbursable in addition to the allowable mileage rate, and should be reported as “Ground Trans Exc Mileage” expense type on the TIMEnX report. Exceptions to Above Policy 8.82 Total actual round trip mileage or public transit fare from one’s residence may be charged when traveling for valid business reasons: (1) on weekends or holidays or (2) to and from local airports when using one's personal automobile in lieu of a taxi or other form of ground transportation. 8.83 Mileage incurred while attending firm-sponsored social events is not reimbursable. Travel Incentives 8.84 The traveler may keep points accumulated through participation in airline, hotel, car rental, or Diners Club promotions. Travel arrangements should be the most cost-effective available, without regard to the personal travel incentives offered. Travelers who choose to participate in such programs are responsible for application and program administration fees. Any incremental costs associated with earning travel incentives are not reimbursable. Individuals may not use travel incentives to purchase firm-reimbursed travel services.


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Visa and Passport Fees 8.85 Foreign country visa fees and passport fees, including renewal and expediting fees, for business-related travel are reimbursable. These fees should be reported as “Miscellaneous” expense type on the TIMEnX report. Weekend Travel 8.86 Extended (more than one week) out-of-town engagements may provide for reimbursement for periodic trips back to the individual’s place of residence. In lieu of such trips, the individual may be reimbursed, with prior written approval from the engagement partner, for weekend trips to another locale in lieu of flying home for the weekend, as long as the cost of the trip does not exceed the cost of the trip home. In support of the request, the individual must provide the approver with documentation from Travel Services, indicating the cost of airfare or other mode of transportation to his/her place of residence. The documentation from Travel Services and the written approval must be submitted with the expense report. In such instances, only travel costs (excluding meals and lodging) to the alternate location are reimbursable. Travel costs in excess of the cost of the trip home are considered personal expenses. Weekend travel expenditures to an alternate location should be reported as “Taxable Reimbursement” expense type on the TIMEnX report, and are considered taxable and subject to withholding (with no tax gross-up).





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NON-REIMBURSABLE EXPENSES


9.01 The following items are not reimbursable: • Air Phone Charges • Athletic and social club dues (except in accordance with sections 8.23

through 8.25) • Charitable contributions • Child care charges, except for firm-sponsored programs specifically

allowing for reimbursement • Clothing – however, Diners Club may cover the cost to replace your

baggage and its contents should they be lost, damaged or stolen. Contact Diners Club customer service at 1-800 2 DINERS.

• College/University alumni dues • Credit card fees – including Diners Club Rewards annual fees, interest

charges, late charges, and all other charges (except for one ATM transaction fee per trip in accordance with section 7.02)

• Gifts to KPMG personnel – not reimbursable through TIMEnX except as

provided for in accordance with the firm’s gift policies (Appendix D). • Gifts to non-KPMG personnel – not reimbursable through TIMEnX

except as provided for in accordance with the firm’s gift policies (Appendix D). Such gifts should not exceed $100 per person. The frequency of gifts should not exceed twice per year for any recipient.

• Home/Remote Technology and Equipment – except for high-speed

internet access charges of a reasonable amount incurred while in travel status, the following are not reimbursable:

– Installation costs and monthly service charges for high-speed

telephone/connectivity, (e.g., DSL, fiber optics, cable modem, ISDN); – Installation costs and monthly service charges for second telephone

line; – Printers, copiers, fax machines, paper shredders and related supplies;

and – Ancillary computer equipment, (e.g., data backup solutions, docking

stations, aircards, etc.). Note that data backup solutions for use in the KPMG office may be obtained through Firmwide Procurement – Technology Purchasing .

• House-sitting – regardless of the circumstances, (e.g., accompanying

spouse) • In-room hotel movies • Jury duty expenses • Parking tickets and traffic fines



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• Pet boarding and sitting charges • Political contributions • Relocation (moving) expenses – except firm sponsored moves. Contact

Montvale Relocation Services for reimbursement of firm sponsored moves. • Subscriptions – including local newspapers, (i.e., NY Times, Washington

Post, Chicago Sun Times, etc.), general business periodicals, (i.e., Forbes, Fortune, Barron’s, etc.), and consumer periodicals, (i.e., Sports Illustrated, People, etc.). Note that the Wall Street Journal is reimbursable to partners only, if the free KPMG online subscription does not meet their business needs.

• Toiletries – however, Diners Club may cover the cost to replace your

baggage and its contents should they be lost, damaged or stolen. Contact Diners Club customer service at 1-800 2 DINERS

• Travel accident insurance – provided free with Diners Club, therefore

any additional coverage is not reimbursable • Tuition reimbursement – not reimbursable except in accordance with the

Tax Services Tuition Reimbursement Program 9.02 If you are in doubt about a particular expenditure, you should check with your area or process controller before incurring the expense.


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EXPENSES COVERED BY PURCHASE AGREEMENTS


10.01 The following types of expenditures are generally covered by firmwide purchase agreements and are normally not reimbursable through TIMEnX. However, reimbursement via TIMEnX, not to exceed $500, is allowable for short-term time-sensitive needs for individuals who are traveling or in other rare situations where adherence to the normal procurement process is not practical. For these exceptions, functional leader approval must be provided. • Computer hardware and software – both new and upgrades. • Equipment rentals – including slide and overhead projectors, screens,

computers, printers, sound systems and similar items. • Office supplies – including paper, calendars, diaries, CDs, diskettes, fax

paper, notebooks, pens, pencils, printer and copier cartridges, refills, postage stamps, and similar items.

• Outside services – including courier services, typing, reproduction, slide

preparation and similar services.


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APPENDIX A – MEALS AND INCIDENTAL PER DIEM RATES Effective 11/01/07

Breakfast $7 $8 $9 $10 $11 $12Lunch 11 12 13 15 16 18Dinner 18 21 24 26 29 31Incidentals 3 3 3 3 3 3Total $39 $44 $49 $54 $59 $64

Applicable Rates for Selected KPMG Locations $39 $49 $54 $64

Billings, MT Albany, NY Austin, TX Annapolis, MD Jackson, MS Albuquerque, NM Boulder, CO Boston, MA Lincoln, NE Atlanta, GA Buffalo, NY Century City, CA Midland, TX Boise, ID Cincinnati, OH Chicago, IL Paris Tax Burlington, VT Cleveland, OH Cypress, CA Salem, OR Charlotte, NC Ft. Lauderdale, FL Long Island, NY Shreveport, LA Columbus, OH Nashville, TN Los Angeles, CA

Denver, CO Pittsburgh, PA McLean, VA $44 Detroit, MI Providence, RI Minneapolis, MN

Allentown, PA Greenville, SC Raleigh, NC New York City, NY Baton Rouge, LA Hartford, CT Richmond, VA Orange County, CA Birmingham, AL Jacksonville, FL Salt Lake City, UT Philadelphia, PA Chadds Ford, PA Kansas City, MO San Antonio, TX Reston, VA Des Moines, IA Knoxville, TN Tampa, FL San Diego, CA El Paso, TX Louisville, KY San Francisco, CA Farmington Hills, MI Memphis, TN $59 Seattle, WA Fort Worth, TX Montvale, NJ Anchorage, AK Stamford, CT Greensboro, NC Oklahoma City, OK Baltimore, MD Washington, D.C. Harrisburg, PA Omaha, NE Dallas, TX Woodland Hills, CA Indianapolis, IN Orlando, FL Houston, TX Milwaukee, WI Portland, OR Miami, FL $82 Princeton, NJ Short Hills, NJ Mountain View, CA San Juan, PR Radnor, PA Wichita, KS New Orleans, LA Roanoke, VA Norfolk, VA $111 Rochester, NY Oakland, CA St. Thomas, VI Syracuse, NY Phoenix, AZ Tallahassee, FL Sacramento, CA $112 Tulsa, OK St. Louis, MO Honolulu, HI

Official per diem rates for other locations within the continental U.S. (CONUS) and locations outside the continental U.S. (OCONUS) may be found on the Department of Defense Per Diem, Travel and Transportation Allowance Committee website. Note: The above rates do not apply to individuals sponsored by Global Mobility. International assignees, please refer to the Global Mobility LTIAP USA Template dated April 1, 2005 for applicable policies.



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APPENDIX B – REIMBURSEMENT REQUEST FORM FOR CLUB INITIATION FEES/DUES/ASSESSMENTS

Complete Part A or B as applicable and submit as indicated below (See Sections 8.23 through 8.25) Part A - Reimbursement Request for Club Initiation Fees/Capital Assessments I hereby request reimbursement of club initiation fees and/or capital assessments in the amount of $__________ applicable to (Name of Club) _________________________________________. I understand that a membership registered in my name rather than the firm’s name will result in taxable income to me in the year paid, except for the refundable portion, if any. The refundable portion of the membership will be treated as an interest-free loan, in accordance with the terms specified in the attached promissory note. I confirm that this club has a non-discriminatory membership policy. ____________________________ ____________________________ (1) ___________________________ Requestor Signature Functional Leader Approval Functional Vice Chair Approval

(as defined in Section 2.02) _________________________ _________________________ _________________________ Date Date Date The attached summary business case must be submitted with this request. To obtain reimbursement, submit this original document, the completed business case and any related attachments, including the original invoice for club initiation fees and/or capital assessments and a promissory note if applicable, to NSS-Montvale, attention: Partner Accounts. (1) Functional Vice-Chair approval is required for fees $25,000 or greater. _________________________________________________________________________________________ Part B - Reimbursement Request for “Second” Golf Club Annual Dues This will confirm the attached request for reimbursement of golf club annual membership dues at (Name of Club) ___________________________________________________ meets the following conditions:

1. This is not my primary golf club; I am a member of one or more other golf clubs that I personally pay annual dues to.

2. The membership in this club is transferable by KPMG upon my retirement or departure from the firm. 3. I use the club principally for business purposes. 4. This club has a non-discriminatory membership policy.

I understand that second club dues reimbursed to me will result in taxable income to me in the year paid. ____________________________________ _____________________________________ Requestor Signature Functional Vice Chair Approval _________________________ _______________________ Date Date Note: Submit this original document to NSS-Montvale, attention: Partner Accounts. Include a copy of this document with the original invoice for club dues and submit them with your TIMEnX expense report to obtain reimbursement.


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APPENDIX C – GUIDELINES AND EXPECTATIONS FOR PROPRIETY REVIEWS AND FUNCTIONAL LEADER APPROVALS

Propriety Reviewer Guidelines and Expectations The oversight of expense submissions helps to ensure that the firm’s financial resources are appropriately leveraged to provide the highest possible value, and that all KPMG team members have an appropriate awareness of cost control. The Expense Reporting Tool (ExpRT) enables the assignment of expense reviewers for all KPMG partners and employees. Area controllers, working with leadership, are responsible for managing the ExpRT reviewer assignments. Recommended assignments are: Client Service Delivery

• Staff reviewed by practice managers and senior managers • Managers and senior managers reviewed by practice partners • Partners and managing directors reviewed by practice leader • Practice leaders reviewed by practice Vice Chair • Vice Chairs and Board of Directors reviewed by Deputy Chairman • Deputy Chairman reviewed by Chief Financial Officer • Chairman reviewed by Chief Financial Officer Client Service Support • Staff levels below senior associate reviewed by performance managers • Senior associates reviewed by managers • Managers reviewed by associate directors • Associate directors reviewed by directors • Directors reviewed by executive directors • Executive directors reviewed by process owner/partner • Process owner reviewed by Vice Chair – Operations ExpRT reviewers are provided a summary profile of each individual’s reported hours and expenses for each semi-monthly pay cycle. This information is generated and e-mailed automatically by ExpRT. Expense explanations submitted via TIMEnX are easily accessible using ExpRT, with a mere “point and click.” In most instances, your review of expense explanations and comments will be sufficient to provide you with assurance that the expenditures have a valid business purpose, are reasonable in amount and comply with firm policies. The scanned version of the related receipts and documentation may be easily accessed if you require additional information. ExpRT provides a link to the Expense Portal website, where you can review details for the current cycle and the previous 12 months. Your review of the business propriety of the submitted expenses supplements the “compliance” review performed by the Dallas Accounting Service Center (DASC) and the review of engagement reports performed by the project team. Note that the DASC review is focused primarily on compliance with firm policies and documentation standards. ExpRT reviewers are expected to know the expense reimbursement policies and the business environment and/or special considerations impacting expense reimbursement claims. Reviewers should consider the following when performing their reviews: • Expenses for staff should generally be limited to travel costs. These costs should be appropriate and necessary based

on individual circumstances. • If the individual is attending industry or trade conferences, they should be appropriate for that individual based on his

or her industry or client focus.


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• Professional development charges should be appropriate for that individual, based on responsibilities and industry or

client focus. • Meals and/or entertainment expenses for clients, prospective clients or other external parties should be appropriate

under the circumstances, providing a benefit to the firm. We should be entertaining only key clients or key prospects with appropriate client profitability considerations.

• Meals and/or entertainment expenses for solely KPMG personnel should be appropriate under the circumstances,

providing an Employer of Choice benefit to the firm. • Travel costs should be appropriate and necessary based on individual circumstances. • Any other unusual or excessive expenses should be scrutinized. Additional considerations when performing your review: • Did the partner or employee “Do the right thing in the right way?” • Did the partner or employee exercise sound business judgment when considering whether to incur the expense? • Is the request in accordance with the letter and spirit of the firm’s Code of Conduct? During the review process you should be alert for unusual patterns, and review prior cycle data (available in the Expense Portal website) as considered necessary. Your review should provide confidence that the expenses claimed are reasonable under the specific circumstances. If, after reviewing the explanations of the expenses and/or supporting documentation, you find exception with the expenses claimed, you should contact the individual for additional information. If you do not approve an expense item after reviewing the additional information, use the chargeback utility in ExpRT to initiate a chargeback by the DASC. ExpRT reviewers do not have the authority to approve expense claims which are not in compliance with firm policies. One-time exceptions to policy must be approved by the functional leader or delegate as described in section 2.02. Blanket exceptions must be approved by the functional leader and the firm’s Chief Financial Officer. The chargeback feature in ExpRT provides an option that will route the exception to the DASC to initiate the approval process, if required. Once your review is complete for each cycle and all necessary action has been taken, you will be required to acknowledge that you have assessed the expenses claimed and find them to be reasonable and appropriate, by clicking on the CONFIRM button in ExpRT. You will have two cycles to perform your review. After such time, if your confirmation has not been processed you will receive a reminder e-mail. Functional Leader Approval Guidelines and Expectations Functional leaders have a responsibility to manage expense reimbursement costs within their business environment. You (or your delegate) may be requested to approve one-time exceptions to the policies herein or certain other expenses in advance of being incurred. You should consider the following before granting approval: • Would you be willing to consider and/or approve the same request for all partners and employees? • Did the partner or employee exercise sound business judgment when deciding whether to incur the expense? If not,

and you approve, are you making an error in judgment? • Would you be willing to reimburse this claim if you were spending your own money? • Did the partner or employee “Do the right thing in the right way?”


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• Where required, was the request presented to you in advance of spending the money? • Is the request fair and equitable? • Is the request in accordance with the letter and spirit of our Code of Conduct? If you are not able to answer YES to all of these questions, you should consider disallowing the request for approval, or charging back the expense claim if approval is being requested after the fact.


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APPENDIX D – GIFT POLICIES The purpose of this Appendix is to provide rules and guidelines that will apply to reimbursement requests for gifts to external parties and for expenditures related to performance recognition, major life events, retirement/separations, service milestones or other items given to partners and employees (e.g., expenditures incurred to express appreciation, impact morale or respond to career or life-related matters). General Rules and Guiding Principles Expenditures incurred by partners or employees for items in the above categories are not reimbursable through the TIMEnX submission process, except as noted below. Generally, reimbursement of expenditures incurred to purchase authorized gifts (see below) can only be processed through the Gift Information and Funding Tool (GIFT), which will facilitate the electronic approval, reimbursement via Diners Direct, direct deposit or payroll check, and the reporting of related expenditures. To access GIFT, click here. Also, see additional information about GIFT that is included below. Gifts will not be paid for through the KPMG Accounts Payable or Purchasing Card processes. Purchases of KPMG branded merchandise must be made through Firmwide Procurement. All gifts should be in good taste and of a nature such that public disclosure of the expenditure would not cause embarrassment to the firm. A gift is not permissible if it violates the KPMG Independence Policy, the recipient’s policy and/or applicable law. Violations of the policies described herein will be subject to an escalation process similar to that described in Appendix F. Questions about these policies should be directed to the Ethics and Compliance Group and/or the Independence Group in the Department of Professional Practice. Detailed Discussion Performance Recognition KPMG’s primary method for recognizing performance and/or extraordinary assignments/commitments is through the annual compensation process. In addition, the Firm provides a supplementary “on the spot” performance recognition policy and process in the form of Encore. To access Encore, click here. Recognition type expenditures incurred outside these programs: (1) require pre-approval of your Functional Vice Chair, Process Owner or authorized delegate; (2) can only be reimbursed through GIFT, except for recognition meals described below; and (3) may constitute taxable income to the recipient. Examples of recognition gifts that would fall outside the parameters of our compensation and Encore programs include, but are not limited to, meals provided in recognition of performance (such as taking one’s spouse out to dinner “on the firm”), incremental gifts of any type that are specific as to a person, or team/group gifts such as gift certificates to Starbuck’s, iTunes, Borders, department stores, AMEX gift cards, etc. Service Milestones and Licensing/Certification The firm has well-defined programs to acknowledge service milestones and licensing/certification achievements. To access the website for service milestones, click here. For information regarding the acknowledgement permitted for licensing /certification achievements, click here. Expenditures to acknowledge achievements outside the parameters of these programs: (1) require pre-approval of your Functional Vice Chair, Process Owner or authorized delegate; (2) can only be reimbursed through GIFT; and (3) may constitute taxable income to the recipient. Revised December 2007

http://dasc.us.kworld.kpmg.com/Applications/PARS/oprGiftEntry.aspx

http://usisweb.us.kworld.kpmg.com/finadmin/procurement/home/index.asp

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http://www.eawardcenter.com/u/0000103997/20/html/presidentsmsg.htm

http://hrweb.us.kworld.kpmg.com/hrweb/policy/profrecogprogram.asp

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Examples of expenditures that require pre-approval and processing through GIFT include incremental gifts outside of the programs described above and gifts given upon retirement/separation. Major Life Events The firm celebrates the new birth or adoption of a child by its partners and employees by automatically sending a gift such as a basket which includes a teddy bear and other items. The HRSC sends this gift when personal/family information is updated by the partner/employee. This policy also permits one other new birth celebratory expression by the local office or team (i.e. flowers sent by the local office, etc.), in situations involving extended hospitalization (i.e., more than 2 – 3 days) with a cost up to $100. In the case of a major illness, flowers or similar items costing less than $100 may be sent. An expression of sympathy (e.g., flowers or a charitable contribution in lieu of flowers) upon the passing of a family member of a partner or employee may be made without pre-approval, provided the amount does not exceed $100. If the local office or team decides to make a charitable contribution in lieu of flowers, the amount must be requested and paid through KPMG’s normal charitable contribution process. The charitable contribution will not be reimbursed (i.e., do not make the contribution and then request reimbursement – the contribution must come directly from KPMG). Expenditures incurred for a new birth or adoption, illness, or to express sympathy (except charitable contributions) can be reimbursed through TIMEnX, provided they do not exceed the amounts stated above. However, if the expenditures for such items will exceed the above amounts, then they: (1) require pre-approval of your Functional Vice Chair, Process Owner or authorized delegate; and (2) can only be reimbursed through GIFT. Other Items and Important Considerations Holiday Gifts and Other Similar Items The firm has typically provided, on a national level, annual holiday gifts (e.g., gift baskets, etc.) and other similar items from time to time throughout the year. Consequently, a decision to incur an incremental expense for such events or for the other items listed below is considered a personal decision and the expense will not be reimbursed by the firm: • Holidays • Birthdays * • Graduations • Weddings • Wedding and baby showers • Administrative Professionals Day or National Boss Day *Birthday gifts that are provided under an office-wide program (i.e., where all office members receive the same token or expression of good wishes) that is approved by the applicable Lead Area Managing Partner, and where the token or expression of good wishes does not exceed $10 per employee, are permissible and will be reimbursed. “Bulk” Purchases “Bulk” purchases, e.g., the purchase of several hundred gift cards for future distribution where the recipients are not specifically identified at the time of purchase, must be coordinated with your area controller to ensure that potential tax considerations, as noted below, are appropriately addressed. Such purchases should occur no more than one month prior to the intended distribution of the items, to facilitate appropriate reporting. Bulk purchases require pre-approval of your Functional Vice Chair, Process Owner or authorized delegate. Revised December 2007

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Pre-Approval Process Pre-approval by your Functional Vice Chair or Process Owner is required for gifts to partners and employees purchased outside of the firm’s defined programs as articulated or referred to above. With the approval of the appropriate Executive Vice Chair, Functional Vice Chairs can delegate their approval authority to Area Managing Partners or National Service Leaders, and Process Owners can delegate their approval authority to partners or Executive Directors within their processes. Approval authority can not be delegated below these specified levels. Tax Considerations A gift is taxable to the recipient partner or employee unless it is specifically excludable from income per IRS regulations (e.g., certain length of service awards) or it is considered “de minimis,” i.e., the value of all gifts to that individual by KPMG is nominal and accounting for the gift as additional compensation would be administratively impracticable. Gifts that are subject to tax include (but are not limited to) the following: • Any cash regardless of amount • Any gift card, gift certificate or cash equivalent (i.e., AMEX gift cards, etc.) regardless of amount • Any item or service, including KPMG branded merchandise, presented to a partner or employee with a fair market

value of $100 or greater • Any item or service the recipient partner or employee receives from KPMG on a frequent basis • Any meal in recognition of performance (such as taking one’s spouse out to dinner “on the firm” to reward efforts on

an engagement), when the person authorizing the meal is not in attendance. Such meals can be reimbursed through TIMEnX, using the “Taxable Reimbursement” expense type (not “Meals”).

On a quarterly basis, Partnership Tax Matters will review gift transactions and advise the payroll department and Partner Accounts of those transactions that should be reported as taxable compensation. On an annual basis, the recipients of taxable gifts will receive a tax protection payment in order to avoid a reduction in the net benefit from such gifts due to tax consequences. Gifts to Third Parties In circumstances where it would not create an appearance of impropriety, partners and employees may offer reasonable gifts to third parties such as clients, potential clients, government officials (including regulators and employees), vendors or other non-KPMG personnel including related parties of the aforesaid individuals, only when consistent with the following policies and guidelines.Gifts to third parties may be claimed for reimbursement in TIMEnX. Questions may arise when applying these guidelines or when dealing with situations not specifically addressed below. In such instances, questions should be addressed to the Ethics and Compliance Group and/or the Independence Group in the Department of Professional Practice. • The (lack of) presence of a KPMG partner or employee determines the nature of the expenditure. For example, if a

KPMG partner or employee gives sporting event tickets to a client and does not attend the event (whether intending to attend or not), this is considered a gift. However, if a KPMG partner or employee attends the event with the client, this is considered entertainment. Refer to sections 8.73 through 8.75 of this document for policies regarding entertainment.

• A gift is not permissible if it violates the spirit of the KMPG Code of Conduct, the KPMG Independence Policy, the

recipient’s policy and/or applicable law. Revised December 2007

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• All gifts must be in good taste and of such a nature and given under such circumstances that public disclosure would not cause embarrassment to the firm.

• Monetary gifts, including gift certificates, gift cards or other cash equivalents, are prohibited. • Gifts to federal, state and local government officials are very strictly regulated, generally prohibited, and can carry

severe civil and criminal penalties. KPMG partners and employees must first confirm with the Office of Government Affairs and with the government officials that the offering of such gifts is permissible by law and regulation. For further detail, consult Chapter 14 of the Risk Management Manual.

• The cost of a gift to clients, potential clients, government officials, vendors or other non-KPMG personnel is

reimbursable through TIMEnX and is not to exceed $100 per person. For example, two sporting event tickets valued at $75 each would be considered a $150 gift to the recipient. Gifts must be directly related to a business purpose. Gifts in excess of $25 are not deductible by KPMG.

• Gifts must not be provided to the same client, potential client, government official, vendor or other non-KPMG person

more than two times per year. • Gifts are to be offered in the proper context and spirit. They are never to be offered for the personal benefit of the

individual giving the gift. • KPMG partners and employees are to never offer anything to clients, potential clients, government officials, vendors

or other non-KPMG personnel to obtain an improper or unlawful advantage in selling services. • Under no circumstances are KPMG partners and employees to make or facilitate any offer, payment, promise, gift or

offer anything of value to government officials for the purpose of influencing their actions or decisions in their official capacity, inducing them to do or fail to do anything in violation of their lawful duty, inducing them to influence any governmental act or decision, or to assist the firm in obtaining or retaining business.

• If the firm is asked by a client to make a donation to a charity, the amount must be requested and paid through the

firm’s normal charitable contribution process. Gifts Received from Third Parties KPMG bases its relationships in all dealings between firm partners and employees and third parties such as our clients, prospective clients, government officials, vendors or other non-KPMG personnel on lawful, efficient, and fair business practices. Positive relationships are to be founded upon professional and impartial conduct in all phases of the selling and purchasing cycle, as well as with the delivery of all services. In circumstances where it would not create an appearance of impropriety, partners and employees may receive reasonable gifts from third parties such as clients, prospective clients, government officials, vendors or other non-KPMG personnel, only when consistent with the following policies and guidelines: • The (lack of) presence of a client, prospective client, government official, vendor or other non-KPMG person

determines the nature of the goods or services received. For example, if a KPMG partner or employee receives sporting event tickets from a client who does not attend the event, this is considered a gift. However, if the client attends the event with a KPMG partner or employee, this is considered entertainment. Refer to sections 8.73 through 8.75 of this document for policies regarding entertainment.


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• Acceptance of a gift is not permissible if it violates the spirit of the KPMG Code of Conduct, the KPMG Independence Policy, the provider’s policy and/or applicable law.

• All gifts are to be in good taste and of such a nature and received under such circumstances that public disclosure

would not cause embarrassment to the firm. • Soliciting or accepting monetary gifts, including gift certificates, gift cards or other cash equivalents, loans, credits or

preferential discounts is prohibited. • The value of a gift received is not to exceed $100 per person. For example, two sporting event tickets valued at $75

each would be considered a $150 gift to the recipient. Gifts exceeding $100 should be courteously and firmly refused. Any gift exceeding a value of $100 per person that cannot reasonably be refused must be approved by your Functional Vice Chair, Process Owner or authorized delegate.

• Gifts must not be accepted from the same third party such as a client, potential client, government official, vendor or

other non-KPMG person more than two times per year. Gift Information and Funding Tool (GIFT) TIMEnX was designed to handle the reporting of time and the reimbursement of travel and entertainment expenses; however, it is not capable of handling the pre-approval, reimbursement and tax reporting obligations associated with giving and receiving gifts. Consequently, the Dallas Accounting Service Center (DASC) has designed and implemented an automated process referred to as GIFT. Except for the situations specifically noted above where the use of TIMEnX is authorized, all requests for reimbursement of gifts must be processed through GIFT. Click here to access GIFT, which is simple and intuitive to use. Please contact the DASC if you have any questions about GIFT. Revised December 2007

http://dasc.us.kworld.kpmg.com/Applications/PARS/oprGiftEntry.aspx

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APPENDIX E – AUTHORIZED APPROVERS Practice SE BU PICs MA BU PICs NE BU PICs MW BU PICs SW BU PICs WE BU PICs

Audit So. Florida Steve Appel Wash DC/Balt John Keenan NY FS Bob Garrett Chicago Metro Bruce Piller Dallas Randy Hill No. California Lincoln Clark

No. Florida Steve Appel Pennsylvania Jerry Maginnis NY Metro Joe Verga No. Heartland Steven Zenz Houston Dennis Whalen Pacific NW Ann Nelson

Carolina Paul Chapman Virginia Candy Duncan NE/Upst. NY Bud LaCava Gateway West Ralph Clermont Denver Mike Keys LA Sub-Geo Scott London

Midsouth Brad Benton New Jersey Tom Duffy Mid-America Rick Siebert Pacific SW David Down

Silicon Valley Ed Cannizzaro

Advisory

ITA Chris Mottram Tony Torchia David DiCristofaro Neil Brigham Bob Glickert Kevin Coleman

ORM Mike Carpenter Ralph Loretta John Simoneau Dan Doherty John Kunesek John Rittenhouse

IARC Ken Welch Phil Jacobsen Ron Safran Mike Hughes Dan Chestnut Mark Hutchins

FRM Carl Carande Mark Twerdok Mike Conover Julie Luecht John Kunasek Jamie Negus

CFO Mike Carpenter Cynthia Bertrando Joe Orlando Dan Doherty John Kunesek Arun Kumar

Forensic Phil Ostwalt Ron Forster Rich Girgenti Graham Murphy Bryan Jones Ron Durkin

Tran Svcs Robert Coble Bob Esposito Malcolm Wright Dan Tiemann Drew Koecher Stan Anders

Federal John Cherbini Laura Odell John Cherbini John Cherbini John Cherbini John Cherbini

GSC Stuart Campbell Stuart Campbell Stuart Campbell Stuart Campbell Stuart Campbell Stuart Campbell

Tax So. Florida Steve Elker Wash DC/Balt Steve Rainey NY FS Steven Evans Chicago Metro Daniel Rahill Dallas Joseph Norville CPSW Craig Ellis

No. Florida Steve Elker Pennsylvania Edward Liva NYC&CT Scott Weisbecker No. Heartland Laura Newinski Houston Greg Engel No. California Edward Silicani

Carolina Frank Huber II Virginia Steve Rainey NE/Upst. NY Rob Noonan Gateway West John Eichhorn Denver Rod Martinez Pacific NW Greg Alwood

Midsouth Charles Walker New Jersey John Kuchinski Mid-America Paul Phillips

EVS Patricia A. Fouts Howard Scribner Howard Scribner Steve Sherman Patricia A. Fouts Steve Kadenacy

ICS Robert Wilkerson Michael Henderson Penny Mavridis Rodney Lawrence Stuart Cruikshank Brett Weaver

IES Gary Lusk Tim Lung Trish Brown Ann Goddard Ray Pascuzzi John McLearie

M&A Thomas W. Avent Mark French Gregory A. Falk Scott E. Moresco Alan Barton Keith Kechik

SALT Dianne Gerrits Larry Cusack Gary S. Rosen Eric Pierce Michael Camp Rob Lang

Natl. Processes & NSS

Finance & Acctg Mike Biehl

Human Resources Nancy Midwinter

Industries & Marketing Karen Schimpf

Information Technology Rowan Snyder

International Aidan Walsh

Operations/Meeting Services Steve Clemente

Procurement Joe Reynolds

Prof. Prac./Legal & Compl. David Mesinger

Real Estate & Facilities Mike Biehl

Tax Technology John McGowan

LARO William Foley

Note: The individuals listed above are authorized to approve reimbursement for expenditures requiring functional leader approval and to approve one-time exceptions to the policies set forth in this document.


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APPENDIX F – EXPENSE EXCEPTIONS – ESCALATION PROCESS


expense reimbursement policyprounlimitedglobalsolutions.com/suppliers/wp...expenses. all individuals...

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