BUSINESS TRAVEL & ENTERTAINMENT POLICY FOR SUPPLIERS

It is the policy of Barcel USA, LLC to pay necessary and reasonable travel-related expenses associated with the conduct of Company business. Policy guidelines are intended to permit a reasonable balance between cost control and a level of convenience that maximizes productivity of business travelers. For the purposes of this policy, the "Company" or "Barcel USA" means Barcel USA, LLC.

Responsibility

Each Supplier is responsible for understanding and adhering to this policy. It is the Supplier’s responsibility to ensure:

• Travel and entertainment serve a necessary Barcel USA business purpose.
• Expenditures comply with Barcel USA policy.
• All required supporting documents are submitted to Barcel USA in a timely manner.

Every effort should be made to avoid unnecessary travel and entertainment.

Policy

General

The Company does not designate a travel agency for Suppliers. Suppliers should use the least cost suppliers of air and other transportation and hotel accommodations. It is not appropriate to use alternative providers in an effort to maximize benefit to the Supplier that may be available due to "frequent flyer" or "frequent stay" programs. Suppliers are prohibited from receiving any incentives for making such travel arrangements.

Company reimbursement for spouse travel will not be approved.

Air Travel

It is Company policy that Suppliers fly coach/tourist class when traveling on Barcel USA business. Suppliers are free to use their frequent flyer miles to upgrade flight class or to personally pay for upgrades beyond the regularly authorized class.

Suppliers must use the lowest cost flights available that are consistent with other objectives and elements of this policy. Suppliers should seek out flight opportunities that depart within a reasonable time span surrounding an optimal departure time and select the less expensive alternative.

When traveling by air, Suppliers must use regularly scheduled airlines. Barcel USA will not reimburse Suppliers for chartered flights.

Suppliers may not trade down in flight class or fare to achieve cost reductions to subsidize the non-business travel of others, i.e., family, friends, associates.

Suppliers are permitted to keep and use premiums, coupons, etc. from frequent flyer or frequent hotel stay programs. However, Suppliers should not fly unusual or unnecessary routings or use travel or accommodation alternatives in order to accumulate mileage for these programs. It is intended that Supplier participation in such programs in no way increase the cost to the Company. Suppliers are not permitted to keep and use other incentives, such as those for voluntary "bumping."

Barcel USA will not reimburse Suppliers for costs to join airline clubs.

Automobile Rental

Automobile rentals should be limited to out of town travel or travel beyond 75 miles of the Supplier’s location which is doing business with Barcel USA. Exceptions must be explained and approved by Barcel USA in writing in advance. Except in pre-approved extraordinary situations, the standard size to be rented is intermediate.

Supplier should refuel the rental vehicle before it is returned. Refueling charges for not doing so will not be reimbursed by Barcel USA.

Insurance charges and costs for repairs to rental vehicles and/or liability will not be reimbursed by Barcel USA.

Personal Automobile Use

Suppliers will not be reimbursed for mileage, tolls and parking expenses incurred in the use of personal vehicles. Suppliers using their personal vehicles on Barcel USA business shall carry adequate insurance to cover loss resulting from personal injury or property damage as well as liability coverage for injury to others. Insurance as well as repairs and/or liability will be at the Supplier’s expense and will not be reimbursed by Barcel USA.

Hotel Accommodations / Lodging

Standard rooms in economy class hotels should be rented. Suppliers will not be reimbursed by Barcel USA for luxury accommodations.

Meals and Entertainment

Suppliers are expected to use prudent business judgment when incurring and seeking reimbursement by Barcel USA of expenses for meals and entertainment. It is the Company’s objective to avoid unreasonably expensive meals and entertainment.

An expense is considered "Entertainment" when more than one person is involved in the activity and it is for a business purpose. The business purpose, names and affiliation of persons entertained, type, where and when entertainment took place must be furnished.

Receipts are required for all entertainment expenses and meals. The use of chits (tear-off stubs) will not be acceptable for reimbursement purposes.

Total cost of meals is limited to $50.00 per day per person.

Creative / Alternative Travel Arrangements

Pre-approved, alternative arrangements may be used, but they should not result in any increase in cost to Barcel USA above a regular, necessary business trip. Alternative arrangements may include "stay-overs" or Saturday departures, which could result in a net saving to Barcel USA.

Telephone

Telephone, cell and otherwise, expenses will not be reimbursed by Barcel USA.

Laundry Expenses

Laundry and dry-cleaning expenses will not be reimbursed by Barcel USA.

Additional Guidelines for Reimbursable Expenses / Miscellaneous

Except as otherwise expressed, reimbursement is limited to food, lodging, transportation and other normal expenses directly associated with necessary business travel.

No-show charges for hotel, car rental and limousine service are not reimbursable unless directly caused by Barcel USA. Babysitting expenses are not reimbursable.

Money or personal property lost, damaged or stolen while on business travel is not a reimbursable expense.

Travel advances will not be provided by Barcel USA.

Personal Expenses

Expenses of a personal nature, incurred while traveling on business, are not reimbursable. These expenses may include, but are not limited to, clothing, golf, tennis, theater, in-room movies, mini-bar, sightseeing, reading material, toiletries.

Expense Reporting

All expenses incurred while traveling on business are to be submitted to Barcel USA for reimbursement in a detailed invoice with accompanying receipts. There will be no direct billings.

Documentation to be attached to the itemized invoice includes:

• Travel Itinerary
• Airline Ticket Receipt
• Car Rental Receipt
• Itemized Hotel Bill
• Receipts for all entertainment, meal and any "other" expenses, regardless of the amount
• In those rare instances where a receipt is lost or cannot be obtained, an explanation must be included with the expense report documentation

All receipts must be original or copies. Chits (tear tabs or check stubs) are not acceptable receipts.

Expense invoices must be submitted in a timely manner. Expenses reported more than 45 days after they were incurred will not be reimbursed.