BUSINESS EXPENSE CLAIMS (inc TRAVEL AND SUBSISTENCE) 1 EXECUTIVE SUMMARY 1.1 The aim of this document is to provide further guidance to supplement section D9 and 10 of the Financial Procedures. The guidance outlines the University’s approach to the reimbursement of costs necessarily incurred by employees (including governors) to ensure that the principles of transparency and disclosure are upheld. It sets out what can, and cannot, be reclaimed and describes the expenses claim process in more detail. The Bribery Act 2011 may also be relevant in relation to this guidance, particularly with regard to hospitality and entertaining. Employees should be aware that the making or offering of a bribe or requesting, receiving or accepting a bribe are offences under the Act. Separate guidance on the implications of the Bribery Act will be available. 2 INTRODUCTION 2.1 As an organisation partially funded by public money, the University has an obligation to ensure economic and effective use of those funds. Furthermore, it aims to ensure appropriate levels of authorisation are obtained in respect of reimbursed expenditure which will satisfy the University (and any external entity) that it has achieved value for money and that budgetary guidelines have not been breached. At the same time, it is expected that employees will be aware of the need to minimise the costs of travel and subsistence to the University, but in a way consistent with its mission. 2.2 Expenses should only be claimed for business travel expenses which are incurred by the employee over and above their normal home to office travelling expenses. This means that if the University requires an employee to travel to somewhere other than their normal place of work, or base, the University would expect to reimburse them at the most economical available rate for the additional travel. This includes travelling to a different site for meetings or other business purposes. 2.3 The University wishes to ensure that all employees travel in, and are accommodated in, a safe manner. Reimbursement of expenses should be claimed only for incidental business expenditure; expense claims should not be used for general purchasing other than in exceptional circumstances. A general rule of thumb is that any purchase transaction that generates an invoice (as opposed to a simple receipt) will probably be more appropriately handled through Oracle as a requisition item. Goods and services should be requisitioned through Oracle using the current University purchasing procedures. 2.4 No individual may authorise reimbursement of his or her own expenses 2.5 All expense claims must be signed by an authorised signatory within the School/Directorate Approval Hierarchy. 2.6 The source of funding (i.e. funds generated from research activities or other income generating initiatives) is immaterial - any expenditure coded to the Cardiff University chart of accounts is subject to the terms of this policy. 2.7 Purchase of any item which may be deemed to be a taxable benefit must be notified to Payroll, and a tax receipt obtained. Reimbursement will not be made for claims not supported by a valid tax receipt. The University reserves the right to decline to reimburse expenses claims in cases where the procedure has clearly been abused. 3 WHAT CAN, AND CANNOT, BE CLAIMED VIA THE EXPENSES PROCEDURE 3.1 WHAT CAN BE CLAIMED 3.2 Bona fide travel and subsistence costs incurred in the course of official University business and in accordance with the currently published rates Business expenses that cannot be paid through Oracle. Travel bookings, i.e. flights, hotels bookings, that genuinely cannot be made via the University's designated travel management company, Co-operative Travel Management, or can be obtained more economically by an alternative method (please note that Co-op Travel Management should be used in the first instance although alternative providers may be used if it can be evidenced that a cheaper fare can be obtained). WHAT CANNOT BE CLAIMED Items that would be more appropriately processed through Oracle using existing Suppliers Electrical equipment - computers, computer accessories Stationery and Computer consumables Subscriptions (please note that personal subscriptions to professional bodies cannot be reclaimed – see Financial Procedures 10.47) Payments to individuals for services rendered (this includes payment by voucher or any other reward or incentive - there may be tax implications in making such payments) Items with a direct cash exchange value, ie foreign currency, traveller’s cheques etc Any punitive interest, fines or compensation charges incurred by an individual 3.3 The above is intended to set out the general principles, is not intended to be exhaustive, and may be revised, expanded or amended from time to time, at the University's discretion. 4 CASH ADVANCES 4.1 Cash advances (minimum £100) for travel and subsistence can be requested by completing an EXP4 expense claim form. Advances must be reconciled within 60 days of the return date, and additional advances will not be issued if you have an outstanding un-reconciled advance. 5 TRANSPARENCY AND DISCLOSURE 5.1 You should be aware that, as a publicly funded organisation, the University is subject to scrutiny of its expenditure streams and must promote financial transparency. Under the Freedom of Information Act we are required to disclose details of staff expenses payments. You are asked to bear this in mind when making purchases that you intend to subsequently reclaim. 6 TRAVEL - UK 6.1 Employees will normally be fully reimbursed for the cost of travel undertaken by train, tube and bus, if this has been undertaken for business purposes. The purpose of travel should be clearly stated on the claim. The cost of the standard class rail fare (evidenced by a ticket or receipt) will be reimbursed by the University – see Financial Procedures 10.12. It should be noted that savings can usually be achieved by booking rail journeys in advance (via the University's designated travel agent). Staff who already possess a travelcard covering journeys to and from work will be expected to use that for business and inter-site travel whenever possible. "Home to office" travel. 6.2 It is the employee's responsibility to get themselves from home to their normal place of work and the University does not pay home to office expenses; this would be a taxable benefit. Travel Between Cardiff University Sites 6.3 In cases where an employee is required to travel between sites to carry out their duties, the University will reimburse the cost of the most economical and appropriate means of travel, including the cost of a travelcard if this can be shown to be cheaper than buying individual fares. The cost of travelling by taxi between sites should be a last resort and used only in exceptional circumstances. Use of Private Transport 6.4 The reimbursement of car expenses will be limited to the mileage undertaken for business purposes at the mileage allowance rate prevailing at the time the journey was made (see the Financial Procedures 10.16). The reclaimable amount for car and fare expenses will be based on the additional mileage from the employee's place of work to their business destination or their home address to their business destination. 6.5 The use of a private car must be approved in advance of the business journey by either the primary or secondary budget holder (or their line manager) and should only be allowed in exceptional cases, e.g. transporting bulky goods, the avoidance of costs associated with an overnight stay or if the cost of hiring a car would be more expensive. It is the responsibility of the employee to ensure that they have adequate insurance in place to cover the use of a motor vehicle for business purposes and the vehicle has a MOT certificate where applicable. Most motor policies provide cover for private and home to office use, and can usually be extended at little or no additional cost to provide cover for a limited amount of business use. Employees may also use domestic air travel to fly to business destinations if it can be proven that this would be cheaper than incurring the total cost of an overnight stay and standard class train fare, or would result in substantial savings of the individual's time. Budget holder approval must be given in advance of such a mode of UK travel. Taxis 6.6 The University's sites are considered to be well served by bus and the use of taxis should be used only in exceptional circumstances. The University has contracts with local taxi firms (information available from the Purchasing Section). If your School/Directorate has an account, taxis should be booked through your Finance or equivalent function and a log is kept of all journeys undertaken and the reason why. If taxis are being claimed via expenses, the reason should be entered on the claim form when requesting reimbursement. Taxi fares are acceptable when employees require transport between the railway station and their business destination, though public transport should be used wherever this is feasible. Receipts should be obtained in all cases. As stated in the general principles, the safety of employees is considered of paramount importance and occasions may arise when employees have to travel late at night from Cardiff to their home. The University will reimburse the cost of the taxi fare from the employee's nearest serviceable station to their home address on such occasions. 7 TRAVEL - Overseas 7.1 The following key points should be noted: Permission to travel overseas should be sought in advance of any bookings being made. An EXP4 for should be completed and approved by the Head of School/Directorate. This will automatically generate a travel insurance certificate which will be valid for any other work related travel for the current financial year. See 7.2 Travel Insurance. An EXP5 form should be completed for the reimbursement of travel and subsistence expenses incurred in accordance with the Financial Regulations and Procedures. Documentary evidence must be provided of the foreign exchange rate used. The EXP5 form has a link to the website of XE.com which is most commonly used for exchange rates. In order to enhance our reputation as a socially responsible organisation staff should only travel when necessary and use the means of transport which is most cost effective and, where possible, has least impact on our carbon footprint. By default, staff will be required to travel Economy class. Premium Economy may also be used but supplementary evidence must be provided to the relevant authorised signatory specifying the reason. It is expected that most travel-related expenditure (hotel accommodation, air fares etc) will be requisitioned through the University's nominated travel agent, Co-op via Oracle. In cases where this route has not been followed (ie purchase by purchasing card etc) travellers will be expected to explain the reasons, and to demonstrate that best value has been achieved. Under only very exceptional circumstances will business or first class travel be permitted; Exceptions to these general rules will only be made in the following circumstances: When specifically approved by the Vice Chancellor, Deputy VC or DPFR or nominated deputy, and the reason for this approval is clearly specified. Reasonable actual expenses incurred will be reimbursed and the London overnight rate is used as a guide. However, if a more expensive hotel was booked because of for example advised by conference organiser then a brief explanation added to the claim should be attached. Travel Insurance 7.2 Employees are expected to use the University's travel insurance cover, and claims for other individually arranged travel insurance cover will not be reimbursed by the University. The University's block travel insurance policy provides cover for staff while travelling on official business. Further details of the cover are available from Stephen Blake (ext. 79071) blakes@cardiff.ac.uk. The University’s insurers UMAL has a website that provides useful travel advice including security, health and assistance advice. Further details can be found on www.umal.co.uk/umal/travel Travel to certain areas may be deemed unsafe. Country-specific travel advice is published on the FCO website (www.fco.gov.uk) and this together with the information on the Zurich site should be checked before travelling. Failure to heed such advice may invalidate your travel insurance cover. If a doctor has advised you not to travel, then you should be aware that your travel insurance will probably be invalidated should you decide to travel against that advice. Employees should also seek advice, where applicable, in respect of any inoculation treatment that is required. The University also has kidnap cover for staff, students, volunteers and alumni travelling with an insured person on University authorised business. The cover is worldwide except for 4 countries (Afghanistan, Iraq, Yemen and Somalia) where insurance cover will have to be bought separately if available. This kidnap cover is for 24 hours per day, 7 days a week and 365 days a year. The insurer is Special Contingency Risks and staff should continue to complete form EXP4 and forward to Stephen Blake prior to travelling. In the unlikely event of an occurrence which may lead to a claim you should call Special Contingency Risks on the following numbers immediately. Office Hours (GMT): +44 20 7088 9111 Outside office hours: +44 769 939 1710 (24 hour emergency line) Spouses or Partners 7.3 The University will not reimburse costs incurred by spouses or partners who accompany a travelling employee. Alternatives to Travel 7.4 The University encourages employees to look at alternatives to travel which save both money and the employee's own time and energy, e.g. video conferencing. 8 SUBSISTENCE AND HOSPITALITY 8.1 'Subsistence' is defined as the cost of accommodation, meals and incidental expenses incurred when a member of staff is working away from their home or usual place of work. 'Hospitality' is defined as expenditure incurred in offering meals and refreshments to external visitors to the University. Refreshments (ie Tea, Coffee, Biscuits and Sandwiches) 8.2 These can be provided, at the discretion of the organiser, for meetings likely to be in excess of two hours. These should be provided by CSERV and should be ordered in advance through Kinetics. Further guidance can be found on the Catering website. Meals 8.3 These should only be provided in the form of "working lunches." Alcoholic beverages will not be allowable with ‘working lunches’ but a moderate (around £5) amount of alcohol is allowed with evening meals. 9 HOSPITALITY AND ENTERTAINMENT 9.1 ‘Entertainment’ is defined as follows: "the provision of certain goods and services, free of charge to the recipient, designed to foster goodwill and enhance the business relationship between the University and a customer, academic or business partner, or such other third party as may be deemed appropriate" _ provision of food and drink; _ provision of accommodation (such as in hotels); _ use of University-owned assets such as meeting rooms, sports facilities or vehicles for the purpose of entertaining. 9.2 Entertainment should, wherever possible, be carried out at the University's own facilities, and requisitioned via Oracle. Entertainment expenditure may only be an appropriate use of University funds and avoid tax liability if it is incurred wholly, necessarily and exclusively for University purposes. A schedule must be included with the claim giving details of the organisation being entertained (including the names of the individuals concerned) and the purpose of the entertainment. The authorisation and submission of a claim for entertaining is a declaration that the cost was incurred wholly, necessarily and exclusively for University purposes. Only on this basis can the claim be paid in full without deduction of tax. In authorising entertainment expenditure, budget holders are also undertaking that, if in any case tax is subsequently levied, any cost which is not recoverable from the individual beneficiaries will fall on the budget concerned. 9.3 Staff should be aware of the provisions of the Bribery Act 2010 in offering hospitality or entertainment and should refrain from any action which could be construed as offering a bribe, unless it can be clearly demonstrated as a legitimate business requirement.. External Hospitality 9.3 The University will support meals wholly and exclusively in pursuance of the business requirements of the institution. It is expected that budget holders will use such restaurants so as to minimise the outlay. The guideline amount per person which will be reimbursed is outlined in the Financial Procedures D9. 9.4 Expenditure significantly in excess of the guideline amount must be borne by the diners. The University will reimburse a reasonable amount of expenditure on alcohol consumed with the meal (a figure of around £5 per head is suggested). Details of the names of the external participants and reasons for the meal must be clearly set out when requesting a reimbursement of expenditure, or the claim may not be reimbursed. Accommodation 9.5 The University will fully reimburse its employees for expenditure incurred on accommodation in respect of journeys undertaken on University business. Wherever possible, employees must return on the day of their business activity, but when this is deemed impractical due to the length of the journey or the need to attend meetings, etc, they should book into an economical class of hotel. This is defined as a three star hotel in the UK and the equivalent class in overseas locations. Employees must ensure the University achieves value for money by either using the University's nominated travel agent or booking with hotels on the University's approved list. 9.6 The University will reimburse the cost of meals, which should be in accordance with current subsistence rates, on production of receipts. In instances where employees have an over-riding requirement to attend a certain hotel, ie conferences, events, etc., then the booking must be placed with the organiser of the event, unless a cheaper rate can be negotiated. Any variances from the guidelines shown above must be approved in advance of the booking by the primary budget holder (or their line manager when they are the claimant). 10 EXTENSIONS TO BUSINESS TRIPS 10.1 Employees may extend their business trips, to a limited extent, for nonbusiness reasons (e.g. holidays, personal research). 10.2 Employees must ensure that invoices clearly identify the non-business element of their trip which will not be met by the University. In instances where this split is not readily ascertainable, a proportional split must be made between the business and non-business element of the trip, with the University only meeting the business part. If there is a doubt on this advice should be requested from FINCE prior to trip. 11 CHECKLIST 11.1 Employees should check the following to ensure they are meeting the policy and procedures of the University. Is the journey really necessary and is it wholly and exclusively for business purposes? Has prior approval been obtained in respect of the use of a car, or where an employee requires to travel or be accommodated at a cost, or class of travel, in excess of the maximum allowed by the University? Is it cheaper to travel before a planned meeting economy class and stay at a hotel overnight than require business class travel to be fresh on arrival for a meeting? Have you ensured adequate insurance arrangements are in place? Have appropriate precautions been taken regarding any medical provisions as recommended for the countries that are being visited, ie inoculations? Have you booked travel/accommodation through the nominated agents of the University or purchasing schemes/organisations for which the University is a member, to ensure value for money is being achieved? If costs are incurred only partially on University business, then the reclaim of expenditure reflects only the business portion. Has the most economical train fare been sought, ie material savings can be achieved by booking 7 days in advance? Has the "non business" element of the trip been excluded when submitting invoices for settlement? Have alternatives to travel been considered, e.g. video conferencing? 12 PROCEDURE FOR THE PAYMENT OF EXPENSE CLAIMS 12.1 The objective of the procedures set out in this document is to ensure employees are reimbursed for their approved expenditure on business travel and subsistence within a reasonable time (defined as a maximum of one month from the date of the submission of the claim). It is necessary to ensure that guidelines in respect of the authorisation of such expenditure have been strictly adhered to and the University complies with statutory regulations in the reporting of such expenditure, i.e. taxation rules. Employees must fill in an Expense Claim Form in respect of expenditure to be reimbursed with supporting documents attached to substantiate expenditure where appropriate. No other form of claim submission will be accepted. 12.2 Expense claim forms must be signed by either a secondary or designated budget holder (or their line manager). A budget holder cannot authorise his or her own expenses claim - their immediate line manager must do this. Authorisation of Expense Claims 12.3 It is the responsibility of Schools and Directorates to ensure compliance with the Financial Regulations and Procedures. All claim forms should be thoroughly checked to ensure they are completed fully and are clearly discernable as being for legitimate University business, and supporting receipts are submitted with each claim. Any claims submitted that do not comply should b e returned to the claimant. 12.4 UK expenses for staff and students are entered onto Oracle by nominated staff in Schools and Directorates. Completed forms should be sent to the Accounts Payable section for payment processing. UK claims for visitors to the University should be sent to Accounts Payable for processing. 12.5 Overseas travel claims and/reconciliation of advances should be sent to Accounts Payable for processing, and any forms not adhering to the Financial Regulations and Procedures will be returned to the School/Directorate and subsequently delaying payment. 13 INTERNAL AUDIT 13.1 A recent internal audit report on expenses identified a number of examples of non compliance with the regulations which are outlined in Annex A and summarised below:- supporting receipts not always attached to the claim; inadequate detail/purpose for the claim; non expense items e.g. books are claimed via expenses when they could be ordered via Oracle; claim form not fully completed; incorrect ex non-approved supplier used to purchase flights without explanation; inappropriate items claimed e.g. cigarettes; meals purchased for others without explanation; alcohol claimed without a meal. 13.2 It is important that staff processing expenses claim within Schools and Directorates check compliance with procedures and get further information/clarification if necessary. 14 FURTHER GUIDANCE The HMRC has published some useful guidance on Expenses, Benefits and Employee Travel, on its website: A-Z Guide on Expenses & Benefits http://www.hmrc.gov.uk/paye/reporting-az.htm Travel & Subsistence - when you can reclaim VAT http://www.hmrc.gov.uk/vat/managing/reclaiming/travel-subs.htm ANNEX A INTERNAL AUDIT REVIEW OF SCHOOLS AND DIRECTORATES – RECOMMENDATIONS Exchange rates should be checked to the XE.com website to ensure that rates used are accurate. When exchange rates are provided the rates used should be supported by documentary evidence. Claims should be submitted without delay and an explanation provided if over 3 months. If expenses are considered to be incidental an explanation should be provided to support the purchase and subsequent reimbursement via the expenses system. Heads of Schools / Directorates and/or Approving Officers should be reminded of the necessity for all expense claims to be thoroughly checked to ensure compliance with Financial Policies and Procedures, prior to being submitted for payment. Books purchased should be ordered via the procurement system. In exceptional circumstances, ie attendance of a spouse, upgrading of flights etc, written evidence of prior approval should be attached to the submitted claim. If evidence prior approval is not provided the claim should be either amended or returned to the claimant. Claimants should ensure that all expenses are clearly discernable as being for legitimate University business and adequately explained in order to provide total transparency in respect of expenses incurred. Claims identified as not being fully completed should be highlighted to the relevant School Administrator ensuring that remedial action can be taken to ensure that forms are fully completed in future “Request to Travel” forms should be submitted to the Head of School / Directorate for approval prior to travel and/or travel commitments being initiated. Claims submitted which include expenses not supported by an adequate receipt or explanation for the omission of a receipt should be returned to the claimant for amendment by the School Administrator. Approved supplier should be used to purchase flights or a justification provided.