Business Travel and Expense Reimbursement Policy

1. OVERVIEW AND SCOPE

DEA TopCo LP and its direct and indirect subsidiaries (collectively hereinafter the “Company“) is committed to providing clear guidance on what expenses are authorized and uniform rules for their timely reimbursement. This Business Travel and Expense Reimbursement Policy (the “Policy“) provides standards and procedures for incurring and seeking reimbursement of authorized expenses. Where applicable, an incremental country overlay to the Policy is included in Annexure III. The Company will implement controls to ensure compliance with the requirements of this Policy. You may incur and will be reimbursed for expenses that are authorized in this Policy. If an expense is not authorized by this Policy, you are prohibited from incurring it and, if incurred and reimbursed by the Company, you may be required to repay it and any reimbursement may be classified as taxable compensation to you in accordance with applicable tax laws, rules, and regulations. In addition, failure to comply with this Policy may result in disciplinary action. Expense reports are meant for reimbursement or payment of business travel, entertainment and other expenses as outlined in this Policy. The purchasing of business goods and services is covered under a separate set of policies and procedures. Do not process the purchasing of operating-type goods or capital equipment (i.e., Fixed Assets) or services for the Company through an expense report unless specifically authorized by the Finance Department. You must use a Purchase Requisition or Payment Request Form for these expenditures. More information can be found in the Digital Edge Purchase Order and Accounts Payable process (Digital Edge Intranet – Documents – All Documents (sharepoint.com), under the Company Policies and Procedures folder. Save and except for the Company’s Code of Business Conduct, Anti-Bribery and Anti-Corruption Policy and Gifts & Entertainment Policy, this Policy supersedes all previous directives relating to travel, entertainment, and other business expenses. 2. RESPONSIBILITIES It is the responsibility of managers and employees to ensure these guidelines are followed. Specifically, managers are responsible for: o Ensuring that the policies and procedures outlined in this Policy are understood and followed by employees under their direct supervision. o Determining that each business trip is essential and that the benefits of the trip cannot be achieved through other more cost-efficient means (e.g., telephone calls, Teams Meetings, incoming supplier visits, etc.). o Limiting the number of personnel traveling on a given trip to those necessary to achieve the expected business results. o Reviewing expenses to ensure compliance with the Policy. Employees are responsible for: o Complying with the policies and procedures outlined in this Policy.

o Controlling the cost of travel as is reasonable under the circumstances. o Ensuring submission of accurate expense reports.

o Identifying and paying for personal expenses.

3. CONSEQUENCES OF NON-COMPLIANCE

You are personally liable for expenses that are not in compliance with all requirements of this Policy. If the Company pays for or reimburses you for any expense that is not ordinary, necessary, and reasonable or is not a business expense, you may be required to repay the Company for the expense, or it may be classified as compensation taxable to you. In addition, you may face disciplinary action up to and including dismissal.

4. REPORTING

The Company’s personnel have an obligation to adhere to this Policy. If you witness behavior on the part of the Company’s personnel that you believe may represent a violation of this Policy, you must promptly report it. Internal reporting is important to the Company, and it is both expected and valued. The Company takes all reports seriously, and every report received will be assessed and, where necessary, appropriate investigation will be undertaken. The confidentiality of reported violations will be maintained where possible, consistent with the need to conduct an adequate review and subject to applicable law.

Reports should in the first instance be made to the Country Finance Head and who will ensure that the information is properly handled and escalated, as necessary. No retribution or retaliation will be taken against any person who has made a report based on the reasonably good faith belief that a violation of this Policy has occurred. Alternatively, reports may be made pursuant to the Company’s Ethics Hotline

(whistleblower@digitaledgedc.com).

5. PERIODIC AUDITS

In furtherance of this Policy, the Company will conduct periodic confidential audits. Our management team will determine the frequency and scope of any periodic audit. These periodic audits are designed to prevent and detect violations of applicable tax laws, this Policy and other Company policies.

6. INVESTIGATIONS

In addition to the periodic audits described above, there may also be individual instances in which the Company may wish to investigate a certain matter. In these situations, the Finance Department, in consultation with legal counsel, may perform an investigation of the Company’s records, books and accounts, and any other evidence required under the circumstances to prevent and detect violations of applicable tax laws and to ensure compliance with tax laws, this Policy and other Company policies.

7. ENFORCEMENT AND DISCIPLINARY ACTION

The Company will impose discipline on individuals found to have breached this Policy, in a manner that is fair, consistent and that reflects the nature and facts of the violation. Anyone subject to this Policy who violates it may face disciplinary actions up to and including termination of his or her employment for cause and without notice. The violation of this Policy may also violate certain tax laws. If the Company discovers a violation of any tax laws, it may refer the matter to the appropriate authorities, which could lead to penalties, fines or imprisonment or other liability.

8. CORPORATE CREDIT CARDS

The Company’s policy is not to issue a corporate credit card. Rather employees should incur expenditure on their own account and can seek reimbursementimmediately upon occurrence of this

spend. To the extent that this presents a cashflow issue for the employee, they should raise this with their manager or the Finance Department who can find a suitable arrangement.

9. TRAVEL APPROVAL

(a) International Travel – All international travel requires the prior written approval from the Employee’s direct supervisor and EX-Level executive to which he or she reports. The same supervisor and EX-Level executive should review the employee’s Expense Reports and submit for reimbursement in accordance with the Company’s Expense Approval Process.

(b) Domestic Travel – Domestic air travel requires pre-approval from the employee’s direct supervisor or manager.

Request for all travel approval should be submitted using the Pre-Travel Authorization Form attached to this policy as Annexure I

10. AIR TRANSPORTATION

(a) Reservation Procedures – Employees should always attempt to book tickets in the least costly manner. Although Employees may make business travel reservations directly with the airline by phone, transaction fees from online booking tools are generally less expensive than the traditional methods of telephone reservation requests. Therefore, employees should, where possible, use online sites to book routine non

complex travel. Employees are encouraged to schedule airline reservations fourteen (14) days in advance but not less than five (5) days prior to travel. The Company generally incurs lower costs when air travel arrangements are made as far in advance as possible and will track costs for travel arrangements that are made less than fourteen (14) days in advance.

The original passenger receipt must be attached to the Expense Report for reimbursement of the expense.

(b) Airline Class of Service

Unless otherwise specified below, the authorized airline class of service is set out below:

LENGTH OF NON-STOP FLIGHT	AUTHORIZED CLASS OF TRAVEL
Grade	EX, X2, X1	E, A and Other
For all domestic flights	Economy	Economy
For all international non-stop flight of six (6) hours or less	Premium Economy	Economy
For all international non-stop flights longer than six (6) hours	Business Class	Premium Economy
For all international non-stop flights longer than six (6) hours – overnight	Business Class	Business Class

Employees should seek to book non-refundable airfare tickets where possible as the cost will be significantly less expensive than fully refundable airfare. With that said, employees should book an appropriate airfare based on the certainty of travel, especially if multi-cities are booked as part of the same itinerary (in order to allow for changes in the event of itinerary changes).

Where the costs of travel are being reimbursed by external parties / agencies – travel bookings may be done in the class of travel as per the arrangement agreed to with such

parties / agencies.

For the avoidance of doubt, First Class travel is never permitted under this Policy.

In the case of specific events (e.g., sales conferences) requiring larger number of employees to travel to participate in such events – entitlement for travel for such trips will be governed by the specific travel guidelines that are issued separately for each such event.

(c) Connecting Flights – Only actual airtime (as estimated by the airline) should be used when calculating the flight time. This means that layovers and time spent in airports waiting for connecting flights cannot be used in calculation of flight time. In all cases, employees must use the most direct route between the origination and destination points when calculating the flight-time. Employees are not permitted to use indirect routing to increase the flight-time so as to be entitled to fly in the next level of class service.

(d) Airport Parking – Airport parking expenditures are reimbursable, but Employees must select the most cost-effective parking options. Employees should utilize local Long-Term parking options when available, as they are normally the most economical parking option. Employees should use their judgement where it is more cost effective to take an alternative mode of transport to the airport (e.g., taxi, airport express, etch).

(e) Lost or Excess Baggage – Individual airlines are responsible for retrieving and compensating travelers for lost baggage. The Company does not reimburse travelers for baggage lost while traveling on business except as per the provisions of any Baggage Insurance cover as may be applicable.

The Company will reimburse employees for excess baggage charges when traveling with heavy or bulky materials or equipment necessary for business or when the excess baggage consists of Company records or property.

(f) Overnight Delays – If an airline delay requires an overnight stay, the employee should first attempt to secure complimentary accommodation from the airline. If the employee is unsuccessful, then he/she should contact his/her manager as soon as reasonably practicable to explain the situation. Such expenses would then be reimbursed on specific approvals which must be supported by the managers signature on the expense report or via e-mail.

(g) Unused & Void Airline Tickets – Unused or partially used airline tickets should be returned to the booking agent / airline as soon as possible for reimbursement. Employees should obtain refunds for these tickets or hold for future bookings. Unused tickets should not be included with Expense Reports unless approved by the employee’s EX Level executive – which for the avoidance of doubt, will be granted only in special circumstances.

(h) Cancellations – When a trip is cancelled after the ticket is issued, the employee should contact the booking agent or airline about using the same ticket for future travel. Air ticket credits will not be reimbursed until such time as the credit has been utilized by the employee as evidence by a new itinerary and travel records.

(i) Exceptions – Only the CEO or CFO are entitled to make exceptions to the Authorized Class of Travel, and such exceptions must be documented in writing and attached to the employee’s expense report.

(j) Employees Traveling Together – The number of employees traveling together on the same flight cannot exceed four (4) executives from the Senior Management Team (EX, X1 or X2) or eight (8) travelers for other cases.

11. ACCOMMODATION

(a) Reimbursable Accommodation Expense – Accommodation expenses are reimbursable for employees traveling for Company business outside a 150-kilometer radius of their work location or residence. Employees may also be reimbursed for accommodation within a lesser distance if special circumstances would justify an overnight stay. Accommodation charges should be for a business standard, reasonably priced hotel. Only standard single rooms are approved for use by employees under this Policy (e.g., no suites, executive floor rooms, double rooms, etc.). Refer to country overlays (if any) in Appendix III for further details.

(b) Accommodation Rates – Employees should endeavor to book their accommodation at hotels with which the Company has corporate rates, or alternatively, if none, by using web booking sites which cater to hotel bookings.

(c) Hotel upgrades – Employees may accept room upgrades to suites or executive floor rooms if the upgrade is at no additional cost to the Company.

(d) Long-Term Hotel Stays – Employees staying a week or longer should contact the hotel directly to seek long-term stay discounts. Those employees involved in ongoing projects which require their presence in a particular location for a longer period (e.g., one (1) month) should inquire about long-term stay discounts or service apartments before booking.

(e) Hotel Cancellation Procedures – It is the responsibility of the employee to cancel hotel reservations within the hotel’s cancellation policy time frame. Employees will be given a cancellation number by the hotel or travel agency and must keep the cancellation number until the credit card statement verifies no charges have been

applied.

(f) Laundry & Valet Service – Employees may use laundry and valet services if they have been away from home for three (3) consecutive nights or longer. Emergency laundry will be reviewed on a case-by-case basis.

(g) Lodging Alternatives—While traveling on company business, an employee may be provided lodging without charge by a fellow employee, business acquaintance, friend or relative. In such situations, it may be appropriate to offer the host a token of appreciation. A maximum of US$50.00 per night for flowers, a meal or a small gift is reimbursable up to a total of US$250.00 for the entire stay. The original receipt must identify the recipient, the purpose of the gift, and be attached to the expense report using the regular lodging category and noting “friends and family stay.” Gift cards are not allowed for reimbursement due to tax implications.

12. REWARD PROGRAMS

Many hotels and airlines have reward programs (e.g., frequent flyer and frequent guest programs) that reward travelers with free airline miles or flights, or free accommodation in exchange for a given number of paid room nights at the hotel. Such reward points are the property of the employee, and the employee may retain the awards from such programs for personal use. However, booking flights or hotels that cost the Company additional money or delays the traveler while on Company time to accumulate affinity points will not be tolerated. Every effort must be made to arrange travel and accommodation in the most expeditious and cost-efficient manner. Any membership fees associated with joining these programs are non-reimbursable and the employee’s responsibility.

13. AUTOMOBILE RENTAL

Employees may often travel to locations where use of public transportations is not feasible and use of automobile rentals therefore becomes necessary. All associated costs of the rental, gas and insurance are reimbursable under this Policy.

The Company permits the use of rented automobiles for employees when required. Midsize cars are the standard for all employees traveling on Company business. Full size cars can be used if three (3) or more employees are riding together.

The employee should use the major rental companies when available. Upon selection of the vehicle, the employee should inspect it for any damage prior to leaving the car rental lot. Rental cars are to be returned with a full tank of fuel to minimize the refueling surcharges imposed by the rental agencies. Refueling costs for rental vehicles are reimbursable. The receipt should be attached to the employee’s expense report.

If an employee requires the use of a rental vehicle for a one-way trip should be aware that drop-off charges can be very high depending on the distance from the rental location.

The Company does not currently have insurance discount programs for rented automobiles. Each traveler should take the Liability and Collision insurance offered by the rental company. Such coverage protects the traveler in case of an accident. In some countries, theft protection insurance is mandatory. As the Company’s medical insurance program covers each employee, it is recommended NOT to take the extended medical insurance offered by the rental agency.

14. PERSONAL AUTOMOBILE

Personal vehicles may be used for business trips if the reimbursement mileage expense will not exceed the airline ticket and/or automobile rental expense. Employees must have sufficient automobile liability and property damage insurance coverage. Employees will be reimbursed on a “per mile/kilometer” rate established locally or as published each year by the local government as “deductible mileage allowance.” Check with the Finance Department to ascertain the current reimbursement amount in your location.

To be eligible for reimbursement, employees must submit a clear description of the business purpose of the trip, the start and end points and the number of miles/kilometers. Mileage is not paid for commuting to work from home. Only business trips that exceed the normal commuting distance are reimbursable and only for the mileage more than the normal commuting distance.

Depending on the terms of their contract, employees who receive a monthly car or transportation allowance may not be eligible to claim reimbursement for mileage and other car expenses.

15. OTHER TRANSPORTATION

Employees are encouraged to utilize the most economical and safest mode of transportation available. The most economical route or mode of transport do not apply under special circumstances such as a natural disaster to ensure employee safety. Employees should consider the use of local transportation such as hotel shuttles, taxis or public transportation between airports, home, employment location and the departure point or between the arrival point and place of meeting or lodging. Individual expenditures of this nature must be properly identified on the employee’s expense report.

16. OUT OF OFFICE HOURS

Employees required to be at the office or work-related location outside of business hours, being before 7am and after 9pm, may take a taxi to or from home. Employees working at the office after 9pm may also claim a meal of up to the equivalent of US$15.

17. PERSONAL MEALS

For the purposes of this Policy, there are two covered meal types: Personal Meals (covered by this Section 18) and Business Meals and Entertainment (regardless of whether conducted whilst on overnight business travel) which is covered by Section 18.

Personal meals are meal expenses incurred by an employee when dining alone while traveling on overnight business (i.e., breakfast, lunch and dinner). Employees should dine at reasonably priced establishments whilst on business travel. Only reasonable meal expenses directly related to overnight travel will be reimbursed under this Policy.

Meals purchased for other employees who are traveling for Company business may be included in an employee’s expense report provided the employee specifies the employee for which the meal was purchased, and such expenditure would not otherwise be un-reimbursable had the other employee submitted the expense him or herself. Meals purchased by an employee traveling on business for employees who are not otherwise traveling but nevertheless are engaged in a bona-fide business discussion with the traveling employee are considered reimbursable subject to the above requirements.

In-room refreshment (mini-bar) for any item other than water will not be reimbursed by the Company.

Itemized original receipts are required for all expenses. Where receipts are not available, the employee must provide an explanation for the expense attached to the employee’s expense report. Failure to provide receipts towards a total amount beyond US$25 per day may result in denial of reimbursement.

18. MISCELLANEOUS TRAVEL EXPENSES

(a) Tips and Gratuities – Tipping practices differ from country to country. In some countries, the bills may have a service charge already included as part of the meal, while in others, no service charge is payable. Gratuities and tips should be limited to the accepted norm within the country, and it is the employee’s responsibility to understand the local practices to avoid excessive or improper tipping. Reasonable gratuities and tips may be included on the employee’s expense form. It is reasonable to show “tips” for hotel porters and bellhops.

(b) Telephone calls & Internet expenses– Telephone calls & Internet access charges for business purposes while traveling are authorized and will be reimbursed upon completion of the business trip. Additionally, reasonable personal phone expenses will be reimbursed. Employees traveling on business are encouraged to use internet calling (e.g., WhatsApp, Line, etc.) when available rather than making calls from their mobile service or hotel room.

(c) Immunizations & Visas – Employees will be reimbursed for the cost of all health check-ups, immunizations and inoculations required for travel on Company business. The Company will also pay visa fees required for business travel. It is the responsibility of the traveling employee to know and understand all immunization, inoculation, passport and visa requirements prior to undertaking international travel. It is the responsibility of the employee to maintain a current passport and has suitable remaining valid term where they expect to travel as part of their role.

(d) Personal Travel – Personal travel is the responsibility of the employee. Occasionally, an employee on a business trip may decide to include some personal travel during the trip. This is acceptable provided ALL the following criteria are met:

✔ The primary purpose of the trip is business.

✔ No extra expense to the Company is involved.

✔ The personal travel does not interfere with the trip’s business objective.

(e) Spouse / Companion Travel – When traveling in business class for the Company, employees are not allowed to downgrade the class of service to purchase ticket(s) for their family members. Furthermore, if a spouse or family member travels with an employee on business trip, any and all expenses incurred by such additional traveler (e.g., food, lodging or transportation) should be to the personal account of the employee.

(f) Other Reimbursable Expenses – Airport transfer or airport pick-up & drop, Inter-city travel costs within a foreign country in the course of the trip and any other business related expense will be reimbursed at actuals. All such expenses must be incorporated in the expense report and supported with appropriate vouchers and/or receipts.

(g) Non-Reimbursable Expenses – The aim of this Policy is to ensure that employees are reimbursed for all permissible expenditures made for the benefit of the Company. Employees should be aware that not all expenses incurred during a business trip are reimbursable. Some items considered being a personal nature and otherwise non

reimbursable are set forth on Annexure II.

19. BUSINESS MEALS AND ENTERTAINMENT

(a) Business meals and entertainment with customers, vendors or third parties doing business with the Company should be infrequent, must not be lavish and must be necessary to conduct business. The specific rules, thresholds and procedures stated in the Gift & Entertainment Policy must be adhered to.

(b) Providing any gifts, meals, travel or entertainment to a government, quasi-government or government-affiliated entity is not allowed by the Company and is governed by the strict guidelines set forth in the Company’s Anti-Bribery & Anti-Corruption Policy and its Gift & Entertainment Policy.

(c) Without limiting the foregoing, business meals and entertainment expenses will be reimbursed by the Company ONLY if the entertainment meets ALL of the following criteria:

✔ The entertainment must comply with the Gift & Entertainment Policy

✔ The entertainment is directly related to the active conduct of business;

✔ The entertainment is directly preceded or followed by a substantial and bona fide business discussion; and

✔ The entertainment consists of a business meal (food and beverage) in a place conducive to a business discussion and guests are engaged in a trade, business, or activity having a relationship to the Company’s business.

If an Employee has meals or entertains without a clear business connection with the Company, then this will be considered non-business expense and will not be reimbursable.

(d) A full list of attendees, their titles and company name must be provided along with the reason for the expenditure when submitting the claim. The following information is REQUIRED for expensing meals/entertainment:

1. Date.

2. Name of Guest(s), their title and company name.

3. Detailed description of type of expense (i.e., dinner, lunch, cocktail, sporting event, etc.).

4. Establishment name and location (address).

5. Business Purpose.

6. Amount Spent – receipts for ALL entertainment must be attached and included in the expense report.

The most senior person attending the function must make the payment for the entire event. Where this is not possible, the expense claim must be authorized by an approved signatory not in attendance at the function. Documentation to support all entertainment expenses is required. Unless otherwise justified, expenses will be allocated in strict proportion to the number of people at the meal or function.

20. CORPORATE CELLULAR PHONE PLAN

The Company will meet the following costs associated with maintaining a cellular phone

• EX, X1 and X2 Plan and handset* (where required) as approved by manager

• E and A grade Plan and calls (work related). No subsidizing handset. Employees should endeavor to have a plan that comes with standard free calls and data.

* Handset reimbursement reflects basic most current model iPhone, Samsung, or other model of choice. Any upgrades will be at the employees’ expense.

To the extent employee enters bundled or family plans. Please discuss and agree a pro-rata approach with Finance Department prior to acquiring the same.

21. HOME INTERNET AND EXPENSES

Employees may apply to their Country Manager for a contribution by the Company to their home internet plan and home office expenses. Such contribution shall be considered based on factors including country work from home requirements (covid related etc) and the presence of a Digital Edge office.

22. GIFTS AND CHARITY

Expenses in the form of gifts that do not meet requirements under the Company’s Business Code of Conduct, Gift & Expense Policy, local laws, or regulations (e.g., anti-corruption and anti-bribery laws) are simply not allowed.

Under limited circumstances, it may be appropriate to give a small gift to a customer or business partner. In such circumstances, it is strongly preferred that the gift be a Digital Edge-logoed item. If not a Digital Edge-logoed item, the gift must be of nominal value only (e.g., non-excessive gift basket/wine) and must meet the requirements of the Company’s Business Code of Conduct, Gift & Entertainment Policy, FCPA/ABC legislation, and local laws and regulations. For any gift-related expense, the gift recipient’s name, company, and position must be listed with the submission of the expense report. For details on customer gift-giving, refer to the Company’s Gift and Entertainment Policy.

Under no circumstances are the following allowed to be claimed as gifts or entertainment expenses:

o Gift cards.

o Merchandise such as i-Pads or i-Phones.

o Raffle tickets.

o Cash or cash equivalent (e.g., gold, jewelry, watches).

o Charitable donations (including charity-related activities such as charity golf tournaments, raffles, etc.).

23. DUES, MEMBERSHIPS AND PROFESSIONAL ORGANIZATIONS

Membership dues to one technical or professional organisations and societies are reimbursable when determined by the manager to be applicable to an employee’s job function.

24. MISCELLANEOUS COMPANY EXPENDITURES

Payment of company expenditure must follow the Company’s Purchase Order and Accounts Payable processes. In the event where an employee incurs the company’s expenditure on their account, e.g. vendor only accepts credit card payment, the employee can seek reimbursement upon occurrence of this spend. Where this spend is in excess of US$1,500, written pre-approval must be obtained from Finance. Also refer to Section 1 of the Policy.

25. EXPENSE REPORT/ TRAVEL CLAIM SETTLEMENT

(a) Converting Foreign Currency – Expenses should be listed in the currency in which the employee will be reimbursed. Expenses in foreign currencies paid directly by the employee are to be converted to the local currency in which the employee will be reimbursed. The actual exchange rate supported by receipts must be used. When the receipts are not available, the exchange rate for the month as provided by the Finance Department will be used. Where multiple currencies are listed on an employee’s expense report, a conversion rate into the local currency being utilized must be clearly noted on the expense report and on all supporting receipts.

(b) Business Travel & Expense Reimbursement – All employees must use the Company’s web-based automated expense reporting application to submit expenses for reimbursement. For instructions on how to access use this application, refer to the Finance Department. The expense report format may vary for different regions in order to comply with local accounting requirements and hence the correct form to be used may be obtained from your local HR or Finance Department.

The expense report submitted must include:

✔ Employee name and Employee Code.

✔ Dates of travel or expense incurred.

✔ Cost Centre.

✔ Purpose of travel or expense.

✔ Cities or locations of travel.

✔ Itemized list of costs by date.

✔ Separate disclosure of VAT, GST, consumption taxes (or similar) incurred

✔ Separate listing of lodging, meals, transportation, etc.

✔ Receipts (neatly attached to the expense report or scanned into reporting tool).

✔ Pre-Trip Authorization Form (Annexure I) attached to the expense report.

✔ Employee’s signature / approval.

✔ Manager’s signature / approval.

✔ Signature/ Approval of EX level executive, where required.

(c) Expense Report Submission – It is the Employee’s responsibility to ensure the prompt and accurate submission of Expense Reports. Expense Reports should normally be submitted within thirty (30) business days after the completion of the trip. Where possible, employees should include all expenses related to a single trip on one expense report.

(d) Expense Report Approvals and Payment – Expense Reports must be reviewed by the employee for accuracy and submitted to the employee’s manager for approval. It is the responsibility of the approving manager to review the expense report and approve, change, or deny the expenses and forward the approved report to the appropriate approving authority for approval and Finance Department for payment. Revised or denied expense reports should be returned to the employee with the manager’s or Finance Department’s comments.

These procedures serve to protect not only the Company, but also the individual Employee regarding his/her taxes. In some locations, taxes could apply where expenses are not properly documented and approved by the Company.

Expense reimbursements will be directly debited and paid to the same account that is on file as the employee’s primary bank with payroll upon submission of their first report. An employee can update or change his/her bank account with Payroll. To update your bank account, please contact your country finance team for assistance.

Payments will be made in the next salary run when a policy-compliant expense report is submitted and approved (with complete receipts attached) by the applicable cut-off date. Expense reports should be submitted within thirty (30) days after the expense was incurred. Deviations from policy will result in delayed expense reimbursement.

PLEASE REFER TO ANNEXURES FOR THE FOLLOWING:

Annexure I: Business Travel Request Form

Annexure II: Non-business Expense Examples

Annexures III-A to III-C: Country Overlay to the Business Travel & Expense Reimbursement Policy

END OF MAIN DOCUMENT

ANNEXURE II

NON-BUSINESS EXPENSE EXAMPLES

The examples listed in this Annexure are not an all-inclusive listing; any questionable or unusual business expenditures not specifically addressed here or elsewhere should be discussed with your direct manager prior to incurring the expense. Business expenses are those necessitated by business travel and incurred by the employee while away from home.

Personal expenses are those not directly connected with conducting business while traveling and are non-reimbursable. Examples of non-reimbursable expenses are as follows:

o Adult entertainment.

o Alcoholic beverages in excessive quantities or price (expensive wines, liquors or excessive quantities of any alcohol).

o Babysitting, childcare, pet care and home maintenance.

o Barber, haircut, manicure, massage etc.

o Cash advances (rare exceptions are allowed with direct manager and CFO or CEO approval).

o Cash rewards to employees.

o Cash withdrawals.

o Clothing, toiletries or other items of a personal nature (unless exception situation, e.g., change of travel plans).

o Entertainment expenses in the form of gifts that do not meet requirements under the Company’s Code of Conduct, Gift & Entertainment Policy, legal requirements under the FCPA/ABC, local laws or local regulations.

o Gift cards are never allowed as entertainment expenses. Merchandise such as i-Pads, or raffle tickets are not allowed.

o Employees are not allowed to pay and seek reimbursement for the travel-related expenses of a customer or business partner.

o Event expenses related to birthdays, graduations, weddings, retirements, going away are not reimbursable. The only exceptions are flowers for a funeral for a member of the employee’s immediate family, employee illness and recovery or a birth or adoption of child to the employee or spouse.

o Fines and penalties, such as parking tickets and traffic violations.

o Internet subscription (unless approved by manager).

o Late fees.

o Movies, including in-room movies and cinemas.

o Corporate housing or office space (unless by prior approval).

o Personal expenses associated with business travel (e.g., personal side trips, personal entertainment, personal travel and personal insurance).

o Personal memberships/entrance fees to country clubs, health clubs, spas and other leisure facilities.

o Personal items which are stolen during business travel.

o Private memberships to clubs, golf courses or executive services; personal credit card membership fees

ANNEXURE III-A

COUNTRY OVERLAY TO THE BUSINESS TRAVEL AND EXPENSE REIMBURSEMENT POLICY

(CHINA)

The objective of this Annexure III is to ensure that the specific country-based employees have a clear and consistent understanding of the additions and exceptions to the group’s Business Travel and Expense Reimbursement Policy as determined by local requirements and practices. This Annexure is to be read and applied in conjunction with the Business Travel and Expense Reimbursement Policy (“Group Policy”) and the Gift & Entertainment Policy.

The following applies to all employees of Digital Edge China legal entities and affiliates:

(1) Accommodation:

• In addition to Section 11 of the Policy, an employee should adhere to the hotel accommodation rate and meal expense guidance table below. This is based on reasonably priced hotel and business standards on meals. Should the accommodation rates exceed the amounts below, the employee should state the reason for the deviation when submitting the “Pre-Travel Authorization Form”.

• Long term stays through apartment rental must be pre-approved by Country General Manager. The rental contracts must be entered in the company’s name and properly executed in accordance with local requirements.

• Employee may claim the laundry and valet service expense in accordance with Section 11 (f) of the Policy based on a maximum of RMB 200 for every 3 nights of stay.

(2) Business Meals and Entertainment

• All Business Entertainment must be pre-approved by the Department Cost Centre Owner. Request for entertainment approval should be submitted using the “Business Entertainment Expense Application Form” attached, duly signed and dated and in accordance with the Company’s Gift & Entertainment Policy.

• Team meals and company employee activities will be reimbursed by the Company only if pre approved by Country General Manager or above. The title and names of all attendees must be stated in the expense claim.

(3) Communication Fees

Cellular phone and internet connection expenses incurred by the employee for business purposes will be eligible for reimbursement on a reasonable basis.

(4) Automobile Rental

Use of rented automobiles for employees is permitted in accordance with section 13 of the Policy. The employee must seek written pre-approval from the Country General Manager.

(5) Personal Automobile

Personal vehicles may be used for business trips. Only the related bridge toll and parking expenses incurred will be eligible for reimbursement. Employees must have sufficient automobile liability and property damage insurance coverage. Any loss or damage to the employee’s automobile will not be eligible for reimbursement.

(6) Expense Report / Travel Claim Settlement

(a) All employees must use the “China Expense Reporting Application Form” to submit expense for reimbursement.

(b) The receipt and supporting documentation must fulfil the following requirements in addition to the section 23(b) of the Policy:

• Original receipts and invoices of all expenses must be submitted with the expense report (neatly attached and pasted in transactional date and order).

• The employee should endeavour to obtain a specified VAT invoice from the vendor or supplier where possible.

• The specified VAT invoice should be issued in the registered company name of the vendor/supplier and contained the following information: tax registration number, company address and telephone number, company bank account and number information and company seal properly affixed.

• Invoices and specified VAT invoice without the proper vendor and supplier information as stated above may be rejected and non-reimbursable.

• For air travel, the employee must submit a copy of the travel itinerary or specified VAT invoice of the airfare with travel dates as proof of the business trip.

• Invoice for local transportation fees should state the place of departure and destination. • Bridge and toll fee claimed must be matched with the taxi receipt.

(c) Expense Report Submission: Per Section 23 (c) of the Policy, expense reports should normally be submitted within 30 business expense days after the completion of the trip or expense transaction date. Expense report submitted after 30 days should include a written explanation of the late submission and Country General Manager approval is required.

(7) Employee Cash Advances

(a) Scope – Employee cash advance is limited to short term travel advance, revolving cash advance and other temporary loan. They are permitted as a rare exception to cover only business travel and to allow small business expenditures to be made with the least inconvenience at the discretion and based on the pre-approval from the Country General Manager and Group Finance in accordance with Annexure II of the Policy. Employee cash advance must not be used for private purposes, or in violation of the Company’s Policies, including but not limited to, the Company’s Anti-Bribery & Anti-Corruption Policy.

(b) Initiating a Request, Authorizing and Issuing Funds – The employee initiates a request for an advance using the “Cash Advance Application Form”. This form includes the amount being requested, the purpose of the cash advance etc. Pre-approved advances are authorized by the Department Head and Head of Finance, China and issued to the employee. Revolving cash advance is issued to the authorized custodian. After approval, the funds will be transferred to the employee’s personal debit card (salary card).

(c) Amount of Cash Advances – The amount advanced may not exceed the estimated or budgeted cash required for the business activity and not exceed RMB 30,000. Temporary loan shall not exceed RMB 5,000.

(d) Cash Advance Reporting and Reconciliation – The responsibility for the cash advance remains with the employee and authorized custodian until the reconciliation/accounting of expenditures through completion and approval of the China Expense Reporting Application Form. The required supporting documentation should be submitted in accordance with the requirement under this Policy.

• Advance for business travel shall be returned to the Company within 30 days after the completion of the business trip.

• The full amount of the revolving cash advance issued to the custodian shall be returned to the Company before their resignation or termination date.

• Temporary loan shall be returned to the Company within 30 days from the date of issue of the cash advance.

• For any outstanding cash advance as at the end of the financial year, the Finance Department will require a written balance confirmation from the employee.

(e) Returning Unused Funds – Unused funds and funds that are no longer needed for the purpose of the advance, must be returned to the Company. Where the advance is not returned to the Company within the specified time, they will be deducted from the employee’s salary or amounts owed by the Company to the employee. No new borrowing will be approved if the preceding advance has not been returned and cleared in full.

ANNEXURE III-B

COUNTRY OVERLAY TO THE BUSINESS TRAVEL AND EXPENSE REIMBURSEMENT POLICY

(SOUTH KOREA)

The following applies to all employees of Digital Edge Korea legal entity and affiliates:

(1) Transportation and Business Meals and Entertainment

• All Business Entertainment exceeding KRW250,000 (US$200) per event must be pre-approved by the Country General Manager. Request for entertainment approval should be submitted using the “Korea Expense Claim Application Form (Entertainment)” attached, duly signed and dated and in accordance with the Company’s Gift & Entertainment Policy.

(2) Expense Report / Claim Settlement

(a) All employees must use the “Korea Expense Claim Application Form (Non-entertainment)” to submit non-entertainment expenses for reimbursement.

(b) The receipt and supporting documentation must fulfil the following requirements in addition to the section 23(b) of the Policy:

• Original receipts and/or invoices of all expenses must be submitted with the expense report (neatly attached and pasted in transactional date and order).

• The employee should endeavour to obtain specified VAT invoice from the vendor or supplier where possible.

• The specified VAT invoice should be issued in the registered company name of the vendor/supplier and contained the following information: tax registration number, company address, telephone number, and the amount before and after VAT. VAT invoice without the proper vendor and supplier information may be rejected and non-reimbursable

• In case VAT invoice cannot be obtained, the employee should submit a credit card receipt (신용카드매출전표) or cash receipt (현금영수증), both of which are acceptable as eligible evidence by the Tax authorities, and the VAT should be clearly stated on the face of the evidence.

• Local transportation fees should be accompanied by the place of departure and destination. • Bridge and toll fee claimed must be matched with the taxi receipt.

• In addition to section 14 of the Policy, the standard rate of mileage reimbursement is KRW 400 per kilometre. This is subject to periodical update based on established local mileage rates. The employees who receive a monthly car or transportation allowance may not be eligible to claim reimbursement for mileage and other car expenses.

ANNEXURE III-C

COUNTRY OVERLAY TO THE BUSINESS TRAVEL AND EXPENSE REIMBURSEMENT POLICY

(JAPAN)

The following applies to all employees (and contractors where applicable) of Digital Edge Japan legal entity and affiliates:

(1) Domestic Business Travel

Domestic travel, accommodation and transportation expenses will be reimbursed in accordance with the following guidelines:

• Reimbursable Accommodation Expense – Accommodation expenses are reimbursable for employees traveling for Company business outside a 100-kilometer radius of their work location or residence.

• Other Domestic Business Travel Expense – An employee may seek reimbursement of other additional domestic business travel expense incurred as a result of natural disaster, or under exceptional circumstances e.g., travel and accommodation cancellation fee or re booking fee, by documenting the special reason and submitting the necessary receipt and supporting documents to their manager for approval.

• Domestic Travel Class and Accommodation – In addition to Sections 10 and 11 of the Policy, an employee should adhere to the travel class and hotel accommodation rate guidance table below. This is based on reasonably priced hotel and business travel standards. Should the accommodation rates exceed the amounts below, the employee should state the reason for the deviation when submitting the “Pre-Travel Authorization Form”.

Employee Grade	JR / Railway Class	Domestic Air Travel Class	Domestic Accommodation rate per night
EX1	Green Class	Economy	¥20,000
X1-A and above	Green Class	Economy	¥15,000
E	Normal Class	Economy	¥12,000
A	Normal Class	Economy	¥10,000

Note 1: Thresholds exclusive of meals, taxes, and surcharges

Note 2: Non-changeable discounted round-trip air tickets should be booked.