Run: Company Credit Card Policy

This policy establishes the rules for issuing, using, documenting, and reconciling company credit cards. It is intended to protect company assets, ensure accurate accounting, support timely reimbursement and expense reporting, and reduce the risk of fraud or misuse.

This policy applies to all policy holders, managers who approve card issuance or expenses, and Finance/Accounting personnel who review, reconcile, or audit card activity. It applies to all company credit cards, including physical cards, virtual cards, and any card-linked payment methods used for business purposes. **Jurisdiction-specific carve-outs:** - **California employees:** Expense reimbursement and business expense handling must be administered consistently with **California Labor Code § 2802**. - **All U.S. employees:** Expense administration must be applied in a non-discriminatory manner consistent with **Title VII of the Civil Rights Act of 1964** and **EEOC** guidance. - **FLSA considerations:** This policy must not be used to make improper deductions from exempt employees' salaries or to shift ordinary business costs in a way that violates the **Fair Labor Standards Act**.

Key terms used in this policy include policy holder, receipt, reconciliation, good-faith business expense, and misuse. Additional terms may be defined in the expense system or cardholder agreement.

Company credit cards are issued only for legitimate business expenses approved by the company. Cards remain company property and may be revoked at any time. The policy holder is personally responsible for safeguarding the card, using it only for authorized business purposes, and submitting complete documentation on time. The company may review card activity, request supporting documentation, and require repayment of unauthorized charges. Use of a company card does not create an entitlement to reimbursement for personal expenses or to continued card access.

1. **Issuance and eligibility** - Cards may be issued only with manager approval and Finance/Accounting authorization. - The company may require a signed cardholder agreement before activation. - Card limits, merchant category restrictions, and transaction limits may be set based on role and business need. 2. **Permitted use** - Use the card only for pre-approved, company-related expenses. - Keep purchases reasonable, necessary, and within budget. - Do not split transactions to avoid approval limits. - Do not use the card for cash advances, personal purchases, gifts, entertainment not approved by policy, or expenses that violate law or company standards. 3. **Receipt submission** - Submit itemized receipts and required business purpose details for each transaction. - If a receipt is missing, provide a written explanation and any available substitute documentation. - Expense reports must be submitted within **60 days** of the transaction or by the company’s payroll/accounting deadline, whichever is earlier. 4. **Reconciliation** - Match each charge to a receipt, business purpose, and correct cost center or project code. - Resolve discrepancies promptly when requested by Finance/Accounting. - Unreconciled charges may be treated as noncompliant and may be charged back to the policy holder where permitted by law. 5. **Lost, stolen, or compromised cards** - Report a lost, stolen, or compromised card immediately to the issuing bank and Finance/Accounting. - The policy holder must cooperate with any fraud investigation and replacement process. 6. **Card termination or role change** - Cards must be returned immediately upon termination of employment, transfer to an ineligible role, or request by the company. - Final expense reconciliation must be completed before separation when practicable.

**Policy holder:** Safeguard the card, use it only for authorized business expenses, retain receipts, submit reports on time, and cooperate with audits. **Manager:** Approve issuance and spending authority, review unusual charges, and ensure expenses are consistent with business need. **Finance/Accounting:** Set controls, review transactions, reconcile statements, maintain records, and investigate exceptions or suspected misuse. **HR:** Support policy communication, coordinate discipline when needed, and ensure enforcement is applied consistently and without discrimination. **Executives / Department heads:** Ensure their teams follow the policy and that spending aligns with budget and business purpose.

Violations of this policy may result in card suspension, repayment obligations, written warning, documented warning, removal of card privileges, placement on a PIP where performance issues are involved, and/or other disciplinary action up to and including termination of employment. The company will apply this policy consistently and in a manner that does not interfere with protected concerted activity under **NLRA Section 7**, request for reasonable accommodation under the **ADA**, or rights under the **FMLA**. Any investigation or corrective action must be based on documented facts and administered in good faith. Where permitted by law, the company may seek reimbursement for unauthorized charges, including through payroll deduction only if authorized in writing and lawful under applicable wage-and-hour rules.

This policy will be reviewed at least annually and updated as needed to reflect changes in business practices, accounting controls, and applicable law, including state-specific wage and reimbursement requirements. Revisions must be approved by HR, Finance, and Legal or their designated representatives.