Travel Requirements for Non-Seagate Travelers

GENERAL REQUIREMENTS

1. Scope. This exhibit applies to any traveler who is not a Seagate employee (such as an independent contractor, consultant, supplier, or their personnel) and whose travel expenses will be reimbursed by Seagate. This exhibit applies to air, hotel, car, meals, and other travel expenses.

2. Policy. When expense reimbursements are authorized by Seagate, Seagate will reimburse only the actual, reasonable, and necessary expenses that comply with this Exhibit. Seagate will not reimburse expenses that do not comply with this exhibit.

3. Exceptions. Any exceptions to this Exhibit must be obtained before booking travel and must be approved in writing by a Seagate Executive Vice President or above.

CLASS OF SERVICE

1. Economy Class. All travelers must fly in economy class for flights with less than 6 hours flying time following an overnight stay or connection

2. Business or Premium Economy Class. Travelers may fly in business or premium economy class for international flights with 6 hours or more flying time following an overnight stay or connection if the airfare does not exceed $6,500.

3. Unauthorized Downgrading. A traveler may not downgrade any air travel and use the difference in price to subsidize other expenses or obtain refunds or credits. All credits or cost savings obtained by downgrading air travel must be returned to Seagate.

AIRFARE

1. Lowest Comparable Airfare. Seagate will only reimburse the lowest comparable airfare within the permitted class of service between the origin and destination. To determine the lowest comparable airfare, the following requirements apply:

   1. The comparable airfares must include non-refundable flights within the same class of service with up to 1 stop each way for domestic travel and up to 2 stops each way for international travel.

   2. The comparable airfares must include non-refundable flights within the same class of service with longer travel time each way of up to 2 hours for domestic flights and up to 4 hours for international flights.

2. Excess Amounts. If there is a lower comparable airfare that meets the above requirements, then Seagate will reimburse only the lowest amount. Any amounts greater than the lowest comparable airfare will be the responsibility of the traveler or his or her employer.

BOOKING AND REIMBURSEMENT PROCEDURES

1. Purchase Order Required. An approved Seagate purchase order must be obtained in advance for all expenses.

2. Payment and Reimbursement. Travelers are expected to pay their expenses when incurred or when due, and then obtain reimbursement by invoicing the expenses to Seagate against the approved purchase order. If the traveler is an employee of a Seagate independent contractor, consultant, supplier, or other business partner, then the traveler should obtain reimbursement from his or her employer and the employer should invoice the expenses to Seagate against the approved purchase order.

3. Seagate Approved Travel Agency. Seagate badge account holders who hold Seagate Global ID numbers must book their travel through Seagate’s approved travel agency. Badge account holders may contact Seagate’s corporate travel department to request a “guest” profile to access Seagate’s travel agency and book travel arrangements. If the lowest comparable airfare is only offered on options that cannot be booked through Seagate’s approved travel agency, then the traveler may book the lower cost option directly with the carrier.

PROHIBITIONS AND NON-REIMBURSABLE EXPENSES

1. No Government Officials. Seagate prohibits reimbursing travel expenses for government employees or government officials unless approved in writing in advance by Seagate’s Legal and Compliance Department.

2. No Spousal or Guest Travel. Seagate prohibits reimbursing travel expenses for spouses or guests whose attendance is not necessary or highly desirable for an approved Seagate business purpose. Any exceptions to this prohibition must be obtained before booking travel and must be approved in writing by a Seagate Executive Vice President and the Chief Financial Officer.

3. Non-Reimbursable Expenses. Seagate prohibits reimbursing expenses for any of the following:

   1. Alcoholic beverages

   2. Credit card late fees

   3. Laptops, PCs, desktops, tablets, cell phones, laptop bags, or computer peripherals

   4. Registered-traveler identification programs or security clearnace programs

   5. Airline frequent traveler program fees or club memberships

   6. Preferred seat assignments, early boarding, or unauthorized upgrades

   7. Flight insurance

   8. Transportation between home and office on regular workdays

   9. Traffic or parking tickets

   10. GPS systems, satellite radio, prepaid fuel or fuel options in rental cars

   11. Additional travel or car rental insurance costs

   12. In-room movies

   13. Any personal items lost, stolen, or damaged while traveling

   14. Medications and recurring prescriptions

   15. Transportation, duties, taxes, and other fees for shipping personal items

   16. Travel expenses for pets

   17. Baby-sitting or day-care