Business Leaders and Business CFO’s: Business leaders and CFO’s are responsible for the proper day-to-day administration and enforcement of this Policy. Regular exception reports are to be reviewed by CFO’s.

Managers: MManagers are required to review and approve all expense reports of their employees. It is imperative that the manager is familiar with the Policy and all required documentation for expenses. A manager’s approval of an expense report certifies to the Company the following:

• All receipts have been reviewed and are complete, reasonable and attached to the expense report.
• All submitted expenses are compliant with this Policy.
• All submitted expenses are fully documented and the documentation is attached to the expense report.
• The Missing Receipt Affidavit must be accepted by the employee and will be electronically attached to the expense report in all instances. This affidavit should be used sparingly and excessive use of this form will be investigated by the CFO, International Corporate Controller and Business-level leaders.
• Managers should also be aware of VAT-able charges so that they know to expect itemized receipts in certain instances. VAT is discussed in Tax Compliance (Section 1.7) below.

It is the sole responsibility of the manager to promptly review and approve, or question and reject, any submitted expense reports which include items that are not in accordance with this Policy. Failure on behalf of the manager to accurately review expense reports may result in disciplinary action, including termination of employment.

Employees: All employees shall conduct Company business with integrity and good judgment and shall exclude considerations of personal advantage when traveling or entertaining on behalf of the Company. Expenses shall always be reasonable and kept to the minimum amount necessary to perform authorized Company business. Employees are expected to comply with this Policy at all times and report all expenses promptly and accurately with the required documentation.

The Company shall reimburse employees for reasonable and actual expenses incurred while engaged in authorized Company business that were incurred either as cash or not using the Corporate Card. All T&E reimbursement payments will be made via direct deposit to the traveling employee’s bank account. For entities using the Concur system this will be done directly via the Concur system, and in some territories through payroll. Employees will be reimbursed for actual expenses allowable according to the parameters set forth in this Policy and upon submission of a properly completed and approved expense report accompanied by required supporting documentation. The destination and business purpose of each trip and/or mode of travel must be included on the expense report. Incomplete forms or forms lacking appropriate receipts, approvals, or other required documentation may result in reimbursement delays, denials, or unprocessed expense reports.

Expense reports must be submitted within thirty (30) days following completion of a business trip or the occurrence of the expense event. Each employee must submit his/her own expense report. Failure to submit reports and have reports approved within sixty (60) days will result in suspension of the employee’s Corporate Card and placement of a hold on all reimbursements due the employee. The Corporate Card will not be reactivated until the employee has submitted a report explaining the business purpose of the charges, the employee’s manager has approved the report, and the employee has paid any money owed to the Company.

Paying for the transportation, lodging and/or ground transportation expenses of a fellow employee is not encouraged except in rare instances where the fellow employee has not been issued a Corporate Card and does not have the means to charge the business travel or entertainment expenses to another personal credit card.

Receipts (i.e. a valid VAT invoice) should be obtained for all expenditures and these must be attached to each expense claim. An electronic copy of the receipt should be attached to the expense claim and if applicable, the original receipt should be sent to your local country Travel Administrator. Where applicable, it is the employee’s responsibility to request a tax receipt when paying for goods and services. A credit card slip does not constitute a tax receipt.

Details of who attended should be entered as full names. Initials of individuals are not acceptable. In addition, be clear to indicate whether there are any overseas employees present for the meal and/or entertainment.

All other receipt requirements for expense documentation can vary depending on the country where the employee is based (many countries require all receipts, regardless of amount).

All hotel folios and itemized rental car receipts must be submitted, regardless of the amount of the charges, and must be original invoices addressed to the employee’s relevant business unit/employing entity as well as include the employee’s name – travelers must not use their home address. Some vendors provide eReceipts, which eliminate the need for paper copies of these documents.

Concur will automatically convert a foreign currency into local currency but in certain cases an employee may need to complete this exercise. If receipt is lost or unavailable, employee must complete the “Missing Receipt Affidavit” on the NBCUniversal Fax Cover Page. This form must be included with the expense report submission. This Affidavit should be used sparingly, and employees are expected to retain receipts for all expenses.

In certain instances, the employee may be required to indicate the VAT charge of a specific receipt. Please be sure to indicate as such when entering the expense type item into Concur or other system used to submit expenses.

No employee has the authority to have travel, lodging, meals, or entertainment expenses billed directly to the Company, except where the Company has established an existing account and granted consent to the employee to charge to that account.

It is the sole responsibility of the manager to question and reject any submitted expense that is not in accordance with this Policy. Failure on behalf of the manager to accurately review expense reports may result in disciplinary action up to and including termination of employment.

T&E reimbursement requests are routinely audited. If T&E reimbursement requests are returned for correction based upon policy violation, an employee is required to adjust the T&E reimbursement request to meet the policy. The revised T&E reimbursement request is then routed to the traveler’s first-level manager for approval.

In addition, all corporate credit card use and business travel will be audited formally on a quarterly basis and results reported to each business CFO and ultimately to Comcast.

It is the responsibility of the employee to obtain a valid Tax Invoice, and in certain countries that invoice must be in original form, where appropriate. A valid invoice should show:

• The VAT (or local equivalent, e.g. GST) number of the vendor
• Name of the vendor
• Description of the supplies
• VAT amount
• Pro forma/invoices for information purposes only (hotels)/credit card receipts are not valid VAT invoices
  • All hotel invoices, or where country legislation dictates, must be addressed to NBCUniversal and not the employee

VAT recovery will be determined by Concur, or the local finance team.