Expense and Travel Policy

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1. Purpose

DGS Data Governance Systems LLC is committed to ensuring responsible, transparent, and compliant business travel and expense management. This policy establishes clear guidelines for managing corporate travel, business-related expenses, per diems (viáticos), and reimbursements while preventing misuse, excessive spending, or conflicts of interest.

This policy aligns with our Anti-Corruption Policy and Gifts and Hospitality Policy to ensure that travel-related expenditures comply with ethical business practices.

2. Scope

This policy applies to:

• All  employees, contractors, consultants, and business partners who incur expenses on behalf of DGS.
• All travel, entertainment, and hospitality expenses associated with business operations.
• Any expense requiring reimbursement from DGS or its subsidiaries.

3. General Guidelines

3.1. Expense Authorization & Pre-Approval

• All business-related expenses must be pre-approved by a direct manager or department head.
• Travel expenses for international or high-cost destinations require senior management approval.
• Any expense exceeding $500 must have prior written authorization.

3.2. Eligible Expenses

• Transportation: Airfare (economy class unless pre-approved for business class), taxis, rental cars (mid-sized unless required otherwise).
• Lodging: Hotel accommodations within standard corporate rates.
• Meals & Per Diems: Daily meal allowances must comply with the established corporate rate per region.
• Business Entertainment: Meals or activities with clients must be directly related to business development and must not create conflicts of interest (see Gifts & Hospitality Policy).
• Miscellaneous Expenses: Parking, Wi-Fi, business-related phone calls, and reasonable tips.

3.3. Non-Reimbursable Expenses

• Personal expenses (e.g., mini-bar, personal entertainment).
• First-class or luxury accommodations without pre-approval.
• Unjustified or excessive entertainment expenses.
• Alcohol, except when part of an approved business meal.

4. Travel & Per Diem (Viáticos) Guidelines

4.1. Travel Class & Accommodation Standards

• Air travel should be booked at least 14 days in advance to secure reasonable fares.
• Employees should choose cost-effective accommodations aligned with business needs.

4.2. Per Diems (Viáticos) & Meal Allowances

• Employees on business travel exceeding 24 hours are entitled to per diem allowances.
• The daily per diem covers meals, transportation, and minor incidentals.
• Per diems must not exceed corporate limits and should align with local regulations.

4.3. Business-Related Entertainment & Client Meetings

• Entertainment expenses must be directly related to business objectives and must not influence business decisions.
• Any entertainment or hospitality expenses exceeding $100 must be pre-approved.
• The company strictly prohibits lavish or excessive entertainment that may be perceived as bribery (see Anti-Corruption Policy).

5. Reporting, Compliance & Monitoring

5.1. Expense Reporting & Documentation

• Employees must submit detailed receipts and expense reports within 30 days of incurring the expense.
• Reports must include the purpose of the expense, attendees (if applicable), and supporting documentation.
• Falsifying expense reports will result in disciplinary action.

5.2. Compliance Monitoring & Audits

• The Finance Department conducts quarterly reviews to ensure policy compliance.
• Expenses      are subject to internal and external audits to prevent fraud and misuse.

5.3. Violations & Disciplinary Actions

• Non-compliance may result in denied reimbursements, disciplinary action, or contract termination.
• Severe violations may lead to legal consequences.

6. Approval & Contact Information

This policy is approved by the Senior Management / Board of Directors.

For any questions, approvals, or clarifications, contact:
📧compliance@dgs-online.com