Seagate Technology will reimburse employees for their reasonable expenses incurred in connection with necessary and authorized Company business. The purpose of this policy is to establish consistent, reasonable, and accountable standards to record and control the cost of business travel and entertainment.
Controlling travel and entertainment as well as business meal costs is the responsibility of each employee. It is expected that good judgment will be exercised when authorizing the use of and/or when utilizing Company funds.
As travel is an inherent part of doing business, employees are hired with the expectation that they are willing to travel in accordance with these guidelines and provide supporting documentation.
This policy covers all Seagate Technology employees as well as any individuals under contract with Seagate who incur, authorize, or reimburse Company funds. This policy shall be implemented on a worldwide basis; however, for non-U.S. operations, this policy may be adapted to meet local requirements within individual countries. The Chief Financial Officer (CFO) must first approve any policy changes.
Non compliance with this policy may result in delayed/non-reimbursement and / or disciplinary action up to and including termination of employment.
I. TRAVEL REQUEST
SEAGATE-APPROVED TRAVEL AGENCY
All employees are required to make all business travel arrangements through the Seagate-approved travel agency or through Seagate's approved online booking tool. Airline tickets purchased through a channel or agency other than the Seagate-approved travel agency or online booking tool will not be reimbursed unless approved by the cognizant VP. If your country of work is not serviced by Seagate's approved travel agency, travel arrangements can be made through a local agency.
Changes to travel made mid-trip must be made by the approved travel agency
in your home country.
II. AIR TRAVEL
To control Company travel expenses, Seagate employees are expected to accept
the lowest logical airfare when traveling.
"Lowest logical fare" is defined as the fare quoted by the Seagate-approved
travel agency which:
- Requires no more than one interim stop each way for domestic travel and no more than two interim stops each way for international travel.
- Does not increase the one-way total elapsed trip time (end point to end point) by more than two hours for domestic and four hours for international travel.
- Requires departure no more than two hours before or after requested time for domestic travel and no more than six hours before or after requested time for international travel.
- Results in arrival no more than two hours before or after requested time for domestic travel and no more than six hours before or after requested time for international travel.
- Provides savings of 20% or more (minimum $100 USD for domestic travel and $500 USD for international travel) off the cost of the round trip air ticket.
Seagate has signed volume agreements with many travel vendors, including air carriers. The Seagate-approved agency will offer preferred airlines unless a lower logical fare is available on a reputable carrier.
With the exception of Executive Vice Presidents (EVPs) and above, registered-Traveler Identification Programs are not reimbursable.
AIRLINE ANCILLARY FEES
The following ancillary fees are not reimbursable:
- Early Boarding
- Seat Upgrades/Preferred Seating
A. CLASS OF SERVICE
All Seagate travelers with the exception of EVPs and above are expected to fly in coach class utilizing the lowest logical airfare when traveling on Company business.
Exempt employees in professional jobs (Grade 150 or above) may travel in economy plus on non domestic flights of a minimum of 6 hours flying time to destination. VPs and above may travel in business class on non domestic flights of a minimum of 6 hours flying time to destination. Flights less than 6 hours following an overnight stay must be in coach.
Executive Vice Presidents (EVPs) and above may fly in first class on all flights.
A traveler may fly with a VP in the same class of service for the purpose of conducting Seagate business. This exception is available only at the request of the VP.
A traveler may accompany a customer or potential customer who is traveling in business class or first class. This exception must be approved in advance by the cognizant VP.
All requests for policy exceptions must be noted on your TR and must be approved in advance by the cognizant VP.
Unauthorized upgrading of air tickets from coach to coach plus or coach plus to business class is considered a personal expense and will not be reimbursed by Seagate Technology.
Fees for seat assignments /early boarding / etc. are not reimbursable
A traveler may not downgrade air tickets to subsidize personal travel or to subsidize travel for non Seagate accompanying individuals. In addition, changes may not be made to travel to subsidize another portion of travel – cost savings in one area may not be used to subsidize upgrades and/or other spend. No exceptions to this policy are allowed.
If the air carrier downgrades a traveler, for any reason, the refund must be returned to Seagate Technology via the Expense Report process.
C. FREQUENT TRAVELER PROGRAMS
Mileage credits and other benefits from individual frequent traveler programs may be accumulated by Seagate Technology travelers for personal use. Suppliers (airlines, hotels, car rentals, etc.) must be selected without regard to these promotional programs.
Any fees for using frequent flyer miles for upgrade are not reimbursable and upgrade requests must be made directly with the airlines.
D. FLIGHT INSURANCE
When purchasing airline tickets via Seagate's approved travel agency with Seagate's central bill account, the traveler is covered by Business Travel Accident Insurance. Additional flight insurance is not a reimbursable expense.
E. PERSONAL TRAVEL
The Seagate approved travel agency will accommodate travelers who wish to add a personal air segment to a business trip. The agency will not accommodate hotel or car requests for the personal portion of a trip. It is the employee’s responsibility to have the agency quote and document the fare difference at the time of booking.
The traveler is responsible for payment of any additional costs that may be incurred with the addition of the personal travel. Those costs must be paid by the traveler's personal credit card or personal check to the Seagate-approved travel agency. If the fare can’t be issued on a separate ticket, the employee must reimburse Seagate by personal check (made payable to Seagate) submitted to AP. In addition, a scanned copy of the check must be attached to the expense report.
F. CHARTER/PERSONAL AIRCRAFT
All aircraft charter requests, as well as requests for the use of personal aircraft, must be submitted in writing and approved by the CFO, CEO or President. Due to insurance policy provisions in non-owned aircraft and Travel Accident Insurance Policies, special chartered aircraft must meet the following minimum
- Aircraft must have current and valid airworthiness certificate.
- Pilot must possess a valid and current certificate of competency of a rating authorizing them to pilot the aircraft.
- Aircraft Liability insurance of not less than $100,000,000.
G. PERSONNEL ABOARD SAME AIRCRAFT
In order to ensure the continuity of Seagate Technology's operation in the event of an airline accident, no more than one-half of the employees from the same department (or a maximum of ten employees) should travel together on the same flight. No VP shall fly with more than three direct reports. Exceptions to this policy must be approved in advance by the cognizant VP.
Groups/Meetings should consider this policy when selecting meeting/event locations.
Organizations are responsible for assessing the risk of the employees traveling on the same flight and adjusting travel plans as needed.
H. CANCELLED RESERVATIONS AND CHANGES
If a trip has been ticketed and then cancelled, it is the responsibility of the individual traveler (or travel planner) to advise the agency of the cancellation prior to the departure date. This will ensure that electronic tickets can be refunded if there is any value, or documented and used toward future travel if the ticket is non-refundable.
Should it become necessary to change reservations after the ticket has been issued, the original ticket may, in most cases, be exchanged for a new airline ticket - airline change fees may apply. If a paper ticket was issued, it must be returned immediately to the Seagate-approved travel agency.
Contact Corporate Travel for details concerning refunded airline tickets.
I. LOST AIRLINE TICKETS
In the unusual event that a paper ticket was issued and has been lost, please contact Seagate approved travel agency or issuing airline immediately for assistance.
III. GROUND TRANSPORTATION
The most cost-effective means of transportation must be used while on Company business. The employee should investigate the use of alternative transportation (i.e., airport shuttle, taxi, etc.) before deciding to rent a car.
A. CAR RENTALS
Seagate Technology has a negotiated corporate rates inclusive of insurance with its preferred car rental company.
- If Company business requires the rental of an automobile, all employees must utilize our preferred vendor. If our preferred vendor is not available, the most economical alternative must be booked. Insurance must be accepted when renting with a company other than our preferred vendor. All employees are asked to decline all insurance coverage when renting an automobile from our preferred vendor.
- All car reservations must be made through the Seagate-approved travel agency or online booking tool. Car reservations made through a different booking channel or agency will not be reimbursed.
- All employees are expected to rent intermediate size cars or smaller. If two or more Seagate travelers choose to share a car, the renter may upgrade to a full size car. A list of travelers must be submitted with expense report. VPs and above may rent full size vehicles.
- Cars may not be rented for use in Asia, India, Central or South America, Africa or the Middle East unless approved in advance by the cognizant VP.
- It is the employee's responsibility to ensure that the proper rate is being charged at the time of rental. Please refer to your travel itinerary.
- Insurance is not included for any personal/leisure rentals. It is important that employees check with their own insurance carrier regarding car rental coverage.
- In the event an employee has an accident, the following
procedures should be followed:
- Contact local police authorities immediately and file an accident report.
- If another party is involved, obtain the appropriate information such as driver's license number, vehicle registration number, and insurance information.
- Notify the local car rental office from which the car was rented and fill out a car rental accident form.
- Upon your return, forward a copy of the police report, car rental accident report, and rental agreement to the Corporate Travel Administration in Corporate Headquarters.
- If there are injuries involved, contact the Corporate Risk Sr. Manager as soon as possible at (408) 658-1122.
- Fines incurred due to parking, speeding or other violations of the law are NOT reimbursable and must be paid on or before the due date.
- Employees are to decline all fuel option purchases and return the car with a full tank of gas (Exception VPs). If circumstances prevent the refueling of the car, a detailed explanation must be included on the expense report.
- With the exception of applicants, direct billing of car rental charges to Seagate Technology is not allowed. All car rental expenses should be charged to the employee's corporate credit card or to their personal credit card if they are not on the corporate card program. Exception to this policy
must be pre-approved by Corporate Travel.
- To receive proper reimbursement, an original copy of the Rental Agreement must be attached to the Expense Report.
B. PERSONAL AUTOMOBILES
Employees may be asked to use their personal automobiles for Company business. Mileage for business travel plus actual tolls and parking is reimbursed. In the US, mileage is reimbursed at the IRS standard mileage rate. Mileage should be calculated as the distance from home to destination minus commuting distance from home to regular office.
If mileage is claimed fuel will not be reimbursed.
In all countries outside the U.S. the general country rates will be reimbursed.
The employee has the sole responsibility for properly insuring his/her vehicle against damage incurred while on legitimate Company business.
C. TRANSPORTATION FROM HOME TO THE AIRPORT
Shuttle service (e.g. Airporter, Supershuttle, etc.) may be used for round trip transportation from the employee's
home to the airport, if the cost of airport parking plus mileage allowance equals a greater amount than the round trip shuttle service.
The most cost-effective private car service (e.g. taxis, sedan service) may be used when transferring to or from an international flight exceeding 6 hours of continuous flying. The Seagate travel agency will research and recommend the most cost-effective service.
D. AIRPORT PARKING
Employees must use long-term parking while traveling on Company business.
E. USE OF TAXI SERVICE
The daily expense for utilizing a taxi must not exceed the cost of a car rental. If the employee is uncomfortable driving in a foreign country, a VP exception may be requested.
Seagate has negotiated corporate rates and amenities at hotels in our top travel destinations. It is expected that employees will utilize Seagate's preferred hotels at the Seagate preferred rate listed in the Seagate preferred hotel directory.
Hotels will be considered in policy if they meet the following guidelines:
- Seagate preferred hotel booked and charged at the preferred rate.
- Seagate preferred hotel booked at a rate higher than preferred rate if:
- There are no other Seagate preferred hotels available in the city of travel at the Seagate preferred rate.
- There are no lower rates available at non-preferred hotels.
- A non preferred hotel if there is no preferred hotel in the city of travel or if the location of the Seagate preferred hotel is impractical - Seagate's preferred rate/hotel class must be used as a guideline when reserving alternative accommodations.
- A non preferred hotel if the rate is lower than the lowest available Seagate preferred rate in that city.
When preferred hotels are sold out of Seagate's negotiated room type, the Seagate-approved travel agency will work to accommodate the traveler at the best available rate.
Failure to follow hotel policy may result in the traveler paying the difference in the price. Please refer to Seagate's Hotel Directory located on the Corporate Travel web-site. It is the traveler's responsibility to ensure the correct Seagate rate is booked and charged correctly. Amenities are often negotiated into Seagate's rates. It is the traveler's responsibility to know what amenities are included. If breakfast is included in room rate, travelers are encouraged to utilize it.
All hotel reservations must be made through the Seagate-approved travel agency or online booking tool.
This policy does not apply if the employee is attending a convention or meeting and there is a negotiated meeting rate at the host hotel.
Hotel cancellations must be made per the hotel's cancellation policy (available in the Seagate hotel directory) to avoid "No Show" charges. "No Show" charges incurred due to employee's negligence will not be reimbursed.
Frequent traveler programs must not receive priority over cost savings for Seagate.
A. HOTEL DIRECT BILLING
The employee's corporate credit card, or personal credit card, if not in the corporate card program, must be used for hotel accommodations. No hotel charges of any kind are to be billed directly to Seagate Technology unless pre-approved by Corporate Travel Administration.
V. TRAVEL MEALS
It is Seagate policy to reimburse employees for reasonable meal expenses (breakfast, lunch and dinner) incurred while traveling on approved Company business. What is deemed reasonable will depend on the location traveled.
- Itemized receipts are required for any single meal costing $15.00 or more. Each site may impose more restrictive receipt requirements based on local tax regulations. All receipts must be itemized and imprinted with the name of the establishment. The date and amount of the expense must appear, but do not necessarily need to be imprinted. Alcoholic beverages are not reimbursable outside of customer entertainment or business meals with external guests.
Reimbursable Travel Meal Expenses
Meal expenses are reimbursable when:
- Overnight travel is required to conduct Company business.
- A one-day trip takes the employee outside their normal work location. This would include:
- Breakfast if the employee is required to leave home more than two hours earlier than normal.
- Dinner when an employee cannot reasonably return home until two hours or more after normal working hours.
VI. BUSINESS MEALS AND ENTERTAINMENT EXPENSES
This category is not to be confused with individual meals for traveling employees (See Item V Travel Meals above). Seagate Technology will reimburse employees for necessary and verifiable business meal, entertainment expenses, and internal catering. For a business meal, entertainment expense or internal catering to be considered reimbursable, a business discussion must take place during, directly proceeding, or directly following the event.
Reference Seagate's Ethical Conduct and Conflict of Interest Addendum for additional Entertainment guidelines.
“Business Meal Internal” is defined as a meal where business discussions take place and all participants are Seagate employees.
“Business Meal External” is defined as a meal that includes at least one non-Seagate participant (such as a current or potential customer, supplier, consultant, or industry associate).
“Entertainment” is defined as a business appropriate activity. If there is an activity and a meal is also provided, the entire cost is considered entertainment.
“Internal Catering” is defined as an organized on-site meal function for the purpose of conducting Seagate business.
Business meal or entertainment expenses must be incurred and reported by the most senior person within the host cost center present. An employee may not report business meal or entertainment expenses if his/her manager was present. If a VP or above is present and is not hosting the event they are not responsible for paying the bill.
Internal catering does not follow the payment guidelines above, but when expensing internal catering, the host cost center must be entered on the expense report and the following must be included: host name and GID, event name, attendee list or name of organization hosting the event.
For business meals, entertainment and internal catering expenses an attendee list must be submitted with request for reimbursement.
An employee hosting a business meal or entertainment should limit the business associates and other participants to only those who can be expected to contribute to the accomplishment of the business purpose.
Entertainment expenses in excess of $500.00 and all Seagate sponsored offsites and teambuilding events must have Vice President (VP) approval. The $500.00 limit is intended for an event, not for an expense report with multiple activities.
If a contract is issued for an activity, contract policy 2030 must be followed.
Reference Seagate's Ethical Conduct and Conflict of Interest Addendum for additional Approval guidelines.
VII. NON-SEAGATE TRAVELERS
A. APPLICANT TRAVEL
Applicants must book travel via the Seagate approved travel agency.
The travel expenses of candidates for open Seagate Technology positions will be reimbursed when properly pre-approved by the cognizant VP or his/her designee.
Airline tickets should be charged to the hiring department via the company billed credit card. Candidate's auto rental will be direct billed. Hotels can be direct billed where available. If the hotel is not set up for direct bill, the applicant will need to pay via his/her personal credit card and submit charges to HR for reimbursement.
For detailed information regarding reservations and billing procedures for applicant travel, contact HR or the Corporate Travel Administration Department.
BADGE ACCOUNT HOLDERS (Contractors with GIDs)
Badge account holders must book travel via the Seagate approved travel agency. Air will be charged to Seagate's company billed credit card. Hotel, car, and other travel expenses must be paid by the traveler and reimbursed via hiring agency.
INDEPENDENT CONTRACTORS (Contractors without GIDs)
Independent contractors must book travel in accordance with the Independent Contractor Policy. A Purchase Order must be established for independent contractor expenses. Travel must be booked via Seagate's approved travel agency and all charges must be paid by the contractor and submitted to the appropriate department for reimbursement through invoice against the Purchase Order.
B. OTHER NON-SEAGATE TRAVELERS
The travel expenses of non-Seagate Technology employees accompanying an employee on a business trip will be reimbursed only in those instances where the presence of such person is necessary or highly desirable for business purposes, and only with the advance written approval of the cognizant VP. For questions regarding booking and expensing travel for non-Seagate employees, contact Corporate Travel.
Reference Seagate's Ethical Conduct and Conflict of Interest Addendum for additional guidelines.
This provision is not intended to permit customers or government officials to travel with Seagate personnel. Seagate sponsored travel involving customers and/or government officials is covered by Seagate's Global Anti-Corruption Policy.
C. SPOUSAL/GUEST TRAVEL EXPENSES- INCOME TAX TREATMENT FOR REIMBURSEMENT
Spousal/guest (“guest”) travel expenses will not be reimbursed by Seagate. Any exceptions to this policy will need the approval of the cognizant EVP as well as the Chief Financial Officer.
There will be no exceptions on guest travel for SVPs and above.
This does not apply to independent contractors accompanying Seagate employees on authorized Seagate business. It also does not apply to relocations covered under Human Resources (HR) Policy #6008 or a long or short term assignment covered under HR Policies #6007 and #6009.
In the event an exception is approved for events like Tech Awards, President's Club and Three Year Plan, the reimbursement of guest travel expenses will be included in the Seagate employee’s compensation. For this purpose, guest travel is defined as any non-employee accompanying the Seagate traveler. The employee is responsible for taxes incurred on the income inclusion and should prepare accordingly. Written approval and all expenses for guest travel must be forwarded to Corporate Travel for
Guest travel expenses reimbursed by the Company may be excluded from the employee's income only if the accompanying person's travel had a bona fide business purpose and the expenses are properly substantiated. Even when encouraged or required by Seagate, the guest's presence must also be necessary in relation to the conduct of the Seagate employee's job responsibilities to avoid reimbursement being treated as compensation under tax law. The senior tax officer of the Company must approve in writing any bona fide business purpose used to avoid income inclusion.
Guest travel expenses include all incremental costs associated with that individual's portion of the trip, including meals, airfare, lodging, ground transportation, and incidental expenses (e.g., green fees, shopping allowances). Withholding will be made on tax gross-ups paid to employees in the United States at the statutory federal rate of 25% and the applicable state rate (e.g. 6% California), in addition to FICA and other payroll taxes as appropriate. Withholding in foreign jurisdictions will follow local law.
All actual taxes due are the sole responsibility of the employee.
VIII. EXPENSE REPORTING AND RECORD KEEPING
All Expense Reports must be processed through Seagate's web based expense system. Employee Expense Reports should be submitted within 21 days of returning from a business trip. Reports submitted more than 21 days after a trip will be considered late. If the trip is in excess of 30 days, Expense Reports should be submitted on a weekly or bi-weekly basis. The expense Report System is used for reimbursement of travel related and entertainment expense, as well as office supplies (for items not offered through iProcurement), seminar or course fees and subscriptions for which other forms of payment are impractical. Expense reports may not be used for reimbursement of direct material or capital purchases.
An expense report must be filed for air only transaction with supporting documents e.g. receipts, itinerary, etc. for locations where local statutory required.
The following items must be included with the Expense Report:
- Copy of the travel request associated to the expense report, if applicable.
- The complete itinerary invoice provided by Seagate's approved travel agency and ticket.
- Original itemized receipts, however, if the vendor does not provide a receipt or if the receipt is lost, Seagate will reimburse for the expense up to a maximum of $15.00 for any single item. This includes, but is not limited to, meals, taxis, limousine service, or other forms of local transportation.Each site may impose more restrictive receipt requirements based on local tax regulations. Itemized receipts are required for lodging, car rental, cell phone bills and retail purchases regardless of amount. Itemized receipts for purchases charged to miscellaneous and other employee benefits are highly recommended. If the original receipt is lost, contact the supplier for a copy.
- All receipts must be itemized and imprinted with the name of the establishment. The date and amount of the expense must appear, but do not necessarily need to be imprinted.
- Check or money order payable to Seagate Technology for any amount owed.
All Expense Reports must be signed in accordance with the Delegation of Authority Policy, Definitions and Restrictions (#2025).
All expenses must be itemized.
Airline Ancillary Fees must be assigned to the appropriate expense type.
The Expense Report should include an explanation of any deviations of the policy, i.e., the use of unauthorized travel agencies, lodging, or transportation, etc.
Reimbursement of approved expenses processed through the Seagate Web based Expense Report system are as follows: Corporate credit card charges are paid weekly (US only); all other reimbursement is on the employee’s paycheck or, for certain non-US locations, through AP.
Exception approval process of expense reports:
- Noted Exceptions on the TR with the proper exception approval will be honored.
- Exceptions less than or equal to $1,000.00 will be evaluated by a GFS Director and may be approved for reimbursement. The nature of the exception and any past patterns will be considered by GFS.
If GFS declines the claim, the employee and his/her supervisor will be notified. Such exceptions declined by GFS may be escalated to the cognizant VP of Finance for final approval.
- Exceptions greater than $1,000.00 must be approved by the cognizant VP and if necessary, the cognizant VP of Finance.
- Should there be any conflicts between the exception approval process defined here in this policy and any other relevant policy, this policy prevails with regard to reimbursement of exception items.
- For Short Term Assignments and Long Term International Assignments please refer to HR Policy #6009 and #6007 for reimbursement instructions.
IX. PAYMENT METHODS
A. TELEPHONE EXPENSES
B. MEDICAL EXPENSES
C. MEDICAL EMERGENCIES AND EVACUATIONS
In the event of a medical emergency requiring evacuation while traveling on Company business, Seagate's insurance carriers provide certain referral and support services. Details are available through Corporate Travel. Travelers should report any medical emergency to their local Human Resources office as soon as
D. EXPATRIATE TRAVEL
Questions regarding expatriate travel i.e.: non-business related travel such as home leave, should be addressed to Global Mobility.
E. OTHER MISCELLANEOUS EXPENSES
Seagate will reimburse reasonable and necessary laundry and dry cleaning charges for employees traveling in excess of seven days or if clothing is soiled accidentally.
F. NON-REIMBURSABLE EXPENSES (not an inclusive list)
XI. CUSTOMS AND EXPORT CONTROL REQUIREMENTS
All Seagate employees, contractors and representatives of the Company are restricted from traveling for business purposes to any country identified on the U.S. embargo list. Please refer to the International Trade Administration (ITA) website for the current list of countries identified under the U.S. embargo.
In addition, government regulations require the declaration of all merchandise, technical data, and/or currency (reportable value level is country specific) that is exported and imported. It is the responsibility of all employees traveling to foreign countries who hand carry such goods, data, and/or monetary amounts to comply with Seagate’s “Hand Carry Policies and Procedures”
http://financeweb.okla.seagate.com/wwita/Procedure_HandCarry.htm and to contact ITA at least one business day in advance of travel date for export licensing clearance and to coordinate hand carry activity including the issuance of proper export/import documentation. All Seagate travelers are required to properly declare all hand carried items including technical data, and pay all customs entry fees, duties and taxes at the time of entry unless prior arrangements have been made with ITA.
XII. MEETING/GROUP SERVICES
Group travel is defined as ten or more employees traveling to the same destination for the purpose of conducting Company business.
Requests for meeting or group travel must be submitted to Seagate Corporate Travel at Corporate Headquarters when contracts are required with airlines, hotels/conference centers and ground transportation suppliers.
Corporate Travel Administration's goal is to establish and communicate effective procedures for reducing meeting and group travel costs and to ensure consistent operation of all meetings. It is also the focus of Corporate Travel Administration to assist the meeting planner to more effectively negotiate travel related
contracts and to ensure compliance with Purchasing Contract Policies 2030 and 2035.
XIII. MOBILE APPLICATIONS
Seagate encourages employees to find and use any free smartphone applications that add convenience to business travel, within the following strict guidelines:
Except for the Concur Mobile Application, Apps may not be used to book air, car or hotel reservations. All business travel reservations should be made via Seagate's online booking tool, the Concur Mobile App or by calling Seagate's Travel Agency.
Smartphone apps are not reimbursable.
XIV. SOCIAL MEDIA
Seagate strictly forbids employees from broadly sharing corporate travel itineraries on social media sites including Facebook and LinkedIn.
Travelers may forward itinerary information to personal contacts as needed to ensure convenience and safety, but sharing for the purpose of social networking is not allowed.
Avoid posting negative "reviews" or comments about Seagate's preferred suppliers on social networking sites like Facebook, Twitter and Trip Advisor. Please contact Seagate Corporate Travel to report any negative experiences with Seagate's preferred vendors.
XV. ADDENDUM A: ETHICAL CONDUCT AND CONFLICT OF INTEREST
Travel and Expense Policy 2022 does not apply to travel sponsored by Seagate for customers, potential customers or others with whom Seagate does business. Please refer to Seagate's Global Anti-Corruption Policy for the Company's policies on such travel.
BUSINESS MEALS AND ENTERTAINMENT EXPENSES
Consistent with Seagate's Ethical Conduct and Conflict of Interest Policy (1070), no meals or entertainment may be provided when a decision is pending with the intended recipient's employer that could affect the Company.
Entertainment does not include gifts. For guidance on the appropriate use and receipt of gifts, see Seagate's Global Anti-Corruption Policy.
If any of the following circumstances exist, the prior approval of the Legal Department/Chief Ethics Officer and the hosting employee's VP is required:
The total expense for all Entertainment exceeds the following amounts per attendee:
China: 200 RMB per attendee
Japan: 10,000 Yen per attendee
United States: $75 USD per attendee
United Kingdom: £75 per attendee
Continental Europe: €75 per attendee
Other Countries: Get guidance from the regional legal
- Ten or more customer/government attendees are invited and/or participate in the Entertainment.
- The recipient of the Entertainment has received Entertainment for more than six times in the prior year.
In all cases, the list of participants, the business purpose, the expense receipts and the internal approval must all be properly documented and recorded before Seagate will reimburse for the expenses.
Exceptions will not be approved without the authority of Chief Ethics Officer/regional legal representative.
OTHER NON-SEAGATE TRAVELERS
This provision is not intended to permit customers or government officials to travel with Seagate personnel. Seagate sponsored travel involving customers and/or government officials is covered by Seagate's Global Anti-Corruption Policy.
Current Revision Date:18-AUG-2015
Policy Effective Date:19-AUG-2015