Travel & Entertainment Policy

Travel - General Guidelines

  1. Employee travel must be consistent with the business objectives of Noble Capital Markets
  2. All business travel must be pre-approved by submitting a Travel / Event Request on NobleLinx.
  3. All arrangements must be made fourteen (14) days prior to travel - if this is not possible, explanation must be provided on the request.
  4. When short-notice travel is avoidable, reimbursement is limited to the costs associated with advance-planned travel
  5. All requests for attendance at conferences must be submitted sixty (60) days in advance together with the rationale for attendance
  6. Travel must be via the lowest cost alternative, consistent with good business practices – neither luxury, nor sub-standard modes of transportation and accommodations will be used – and reimbursement will be limited to such lowest cost alternative
  7. Airline tickets, car rentals, hotel accommodations (and all other travel-related expenses that can be arranged in advance) will be booked and paid for directly by the travel coordinator.
  8. Change fees and/or upgrades are not reimbursable unless it is determined that such change was outside of the control of the employee.
  9. Trips of less than 50 miles one-way do not qualify for overnight stay
  10. For use of personal vehicle, travel will be reimbursed on a direct route basis for the cost of using a car for trips when driving is more appropriate than flying or other public forms of transportation
  11. For employee transportation, the actual cost of a compact car rental will be reimbursed for the portion of the trip that is official business – when a rental invoice includes days of personal use, the total will be prorated based on the number of days for personal use and the number of days for business use
  12. When transportation is required for three or more employees / guests, a mid-size / full size rental may be selected
  13. Airport parking fees are limited to the cost of long-term parking rates; the total amount of personal auto use and parking fees may not exceed the lowest cost of third-party return airport travel
  14. Shared expenses or those to be charged to another party must be detailed on the TRF
  15. Dated original receipts must be provided for reimbursement – credit card payment slips and/or statements are not acceptable – the detail of the individual expenses (all items which constitute the total amount of the receipt) must be submitted
  16. Expenses should be submitted within 30 business days upon return from travel to receive reimbursement. Expenses more than 90 days old will not be accepted.

Travel Expenses

Noble uses Average Daily Rates (ADR) guidelines on lodging, meals and incidental expenses – the ADR is a widely accepted lodging industry measure based upon a property's room rental revenue divided by the number of rooms as reported by the hotel property to a leading provider of lodging industry economic data.

Note: ADR per diem rates are available through the GSA (U.S. General Services Administration) website; only the third-party-provided ADR rates apply to the Noble travel policy - please ignore any and all other references to GSA policy and procedure

MEALS & INCIDENTAL EXPENSES

  1. Rates are the maximum reimbursable amounts allowed (before tax) - no credit in any other expense category is offered to the employee spending less than the maximum allowable per diem daily amount
  2. The first and last day of business travel are reimbursed at 75% of the full day per diem rate
  3. Meals provided by others, such as those included in registration fees or in hotel rates must be deducted from the per diem – meals provided as part of conference registration must be deducted from the per diem
  4. In all cases, no reimbursement will be made without a detailed receipt, regardless of the amount

PERSONAL AUTO USE

  1. Use of personal car is currently reimbursed at a rate of $0.58 per mile – necessary tolls and parking costs will be reimbursed with the submission of a receipt
  2. To receive reimbursement for mileage, start and finish odometer reading, point of origin and destination must be recorded on the expense submission
  3. Employee assumes the responsibility for any parking and traffic fines and infractions

NON-REIMBURSABLE TRAVEL EXPENSE

Non-reimbursable expenses include, but are not limited to airline club dues, rental car club membership fees, airline headset rentals, in-room movies, insurance on life or personal property while traveling, purchase of clothing or other personal items, expenses for family, child, pet, home and property while on a trip, excessive / premium alcoholic beverages. Commission-based employees may be responsible for up to 50% of travel expense based upon non-achievement of goals.

Entertainment

Noble Financial recognizes the need for the appropriate entertainment of clients and final-stage prospects. Federal tax code limits the corporate deduction of reasonable entertainment expense to 50% of the total expenditure. Expenditures deemed as excessive will result in a tax deduction below 50% - or rejected as a legitimate business expense. As these expenditures are among the most scrutinized by both the IRS and the Company's auditors, proper judgment must be exercised when considering client entertainment.

  1. All entertainment expenditures must be pre-approved using the TRAVEL / ENTERTAINMENT REQUEST FORM(TRF)
  2. The reason / rationale for the expenditure and an estimate of the cost, together with the name(s) and position(s) of those to be entertained must be recorded on the TRF
  3. All of the guidelines applicable to business travel must be followed in order to obtain reimbursement for entertainment expense – receipts must be detailed and include the individual costs on the receipt

Entertainment Limitations

  1. When traveling, the employee portion of any entertainment expense for dining is limited to the subsistence daily per diem
  2. With the exception of corporate planned / sanctioned events, the employee cost for entertaining clients is non-reimbursable (eg: green fees, sporting tickets, dinners, etc.)
  3. The cost of a single client-entertainment event / function may not exceed $100 per individual (including travel, taxes and gratuities related to guests)
  4. Reimbursement may include a gratuity of up to 18% of the bill before sales tax – a single gratuity may not exceed $100
  5. Material variance(s) from the cost(s) estimate(s) on the TRF will be the responsibility of the employee
  6. Individual items of entertainment expense or collective expense(s) deemed excessive will not be reimbursed.
  7. Travel and entertainment expenses may not exceed 2% of commission-based employees revenues' and not more than 5% of any individual client-account in any calendar year
  8. Commission-based employees may be responsible for a portion of, or all entertainment expense(s) when the limits expressed above are exceeded.

Acknowledgment of Noble Financial Capital Markets' Travel & Entertainment Policy

This is to acknowledge that I have received the guidelines and related materials governing travel and entertainment expense reimbursement at Noble Financial Group via the Noble Financial website and understand that it sets forth the terms, conditions and limitations for reimbursement of expenditures I make as an employee of the Company. I understand it is my responsibility to read and understand the policy, procedures and limitations set forth and I further understand that I must follow such policy and procedures in order to be reimbursed for expenditures I have made relating to Company travel and entertainment of guests.

* I have read and understand the Noble Capital Markets Travel & Entertainment Policy