Creating a Travel Policy for Government Contractors Certified Government Travel Professional

For Government Contractors the creation of a Travel Policy is not only a resource for cost effective travel it also incorporates laws that must be followed in order to perform travel for the Federal Government. Two of the most important documents that must be included in the Travel Policy are the Federal Acquisition Regulation (FAR) and Federal Travel Regulation (FTR). These documents contain the basic framework contractors need to follow.

This document includes broad United States Federal Travel policy guidelines necessary to comply with Federal regulations. This provides the employee with helpful data and resources in order to ensure travel costs are allocated in a responsible manner. This document may be more restrictive than the company’s Travel and Entertainment Policy; and while it covers the most important and most frequented applications of the governing Federal Travel Regulations, please defer to your travel counselor when arranging travel for any nuances or changes to policies and procedures.

Federal Travel Regulation (FTR) Compliance

This Act requires that foreign air travel funded with Federal dollars be performed on US flag air carriers or on foreign air carriers that code share with a US flag carrier. If there is no U.S. carrier to your destination, you must travel on aU.S. carrier as far as possible. Additional cost for U.S. carrier flights is NOT sufficient justification to fly on foreign carriers.

This serves to communicate the company’s policy on utilization of and reimbursement of cost for business related meals and entertainment. Business related meals and entertainment assist in meeting organizational goals, but must be used productively and with efficiency of cost expenditure, while maintaining a commitment to standards of conduct business ethics as defined by the federal government.

Business meal expense reimbursements outside of normal travel expenses are only authorized for those employees of the company who fall within executive leadership, own responsibility for a billable contract or P&L account, or sit at the head of a professional services department. The above management personnel may delegate this authority to only those individuals given the responsibility, by the nature of their job function, to strategically drive the business through new customer generation and/or in the preservation of existing customer relationships. (E.g. Business Development, Operations, and Project Management)

As a member of an organization which emphasizes the value of integrity, each employee must pledge to uphold the Company’s reputation in keeping compliant with all applicable federal laws regulating procurement with the USgovernment. As a component of our company’s standardization in compliance, employees are prohibited from offering or providing, or being perceived to offer or provide, entertainment to government officials or employees and employees of government contractors or subcontractors. Employees finding themselves in a position to question the appropriateness of their actions, in providing entertainment to any individual, must seek the advice of the Company’s Compliance department and/or the Company’s legal counsel, prior to taking any action. Employees should refer to the Company’s Code of Business Ethics and Conduct for additional detail about contacting the Compliance department.

On those occasions where, in the interest of business, facilitation of a meal and/or some form of entertainment is required, The company will cover costs by allowing for the reimbursement of business meals or entertainment as they relate to fair and lawful expenses that are solely in pursuit of profitability for the Company. The Company expressly forbids any business meal or entertainment event sponsored by, or with the knowledge of, an employee that is, or is perceived to be, with the intent of gaining influence in procurement of a government contract.

Business Meals: Those meals taken for obvious business purpose and where business is the primary reason for the meal as it falls before, during, or after a business meeting with partners, clients, potential clients, or co-workers where discussion supports a progressive advantage to the company. Excluding all government officials, or individuals representing a government agency, and with no suggestion, or appearance of attempting to influence those individuals involved in the contract decision making process.

Entertainment: Expenses incurred in conjunction with a Company social event where participants include a non-governmental company partner, client, prospective client, or employee, where the main purpose of the event is business, and where such discussion takes place prior to, during or after the event. The entertainment of such partners, clients, or employees is dependent upon the promotion of a business relationship that is advantageous for the company. Entertainment is to include such items as light refreshments, space rental cost, flowers, decoration or the like.

Documentation to support actual costs expended may be made in accordance with Company’s established practice. The United States Federal Government provides a structured definition around allowable cost on billable expenditures, and any expenses not meeting the government’s standards for allowed cost will become the responsibility of the company. Please see FAR 3.1205-46 for additional information. http://www.arnet.gov/far/current/html/Subpart%2031_2.html#wp1095619 Submitting Reimbursements

Compliance and administration of this policy is the responsibility of every employee. The interpretation of this policy shall be the responsibility of the Vice President of Human Resources. The Vice President of Human Resources, or their designee, shall be available for the consultation with supervisors and managers when and where appropriate.The policy should be read in conjunction with all applicable policies of the company, including and not limited to, the company’s Code of Business Ethics and Conduct Policy.