Non-Employee Travel and Related Expenses

(Candidates, Service Providers, Suppliers, Consultants and Independent Contractors)

Introduction

Expense policy and administrative procedures are established for CIGNA ("the Company") to ensure that all non-employees are subject to a common set of expense guidelines. This policy applies to new hires, candidates, service providers, suppliers, consultants and independent contractors and candidates. The guidelines contained in the policy statement are the minimum acceptable standards to be adhered to by all non-employees.

General Policy Statement

Non-employees will be reimbursed in accordance with CIGNA's Non-Employee Travel and Related Expenses Policy for actual, necessary and reasonable expenses incurred in the conduct of CIGNA business.

• Non-employees must account for all expenses by submitting a complete and accurate invoice detailing all travel and related expenses on a monthly basis to their respective employer or hiring manager. Less frequent travelers should submit their completed travel expense report upon completion of each trip.
• Non-employees may not personally arrange to have charges on their behalf direct-billed to CIGNA.
• Non-employees are required to provide detailed information and documentation regarding their expenses to their employer.

CIGNA Corporate Travel Services

CIGNA Corporate Travel Services has negotiated discounted CIGNA rates with preferred airlines, rental cars, rail service and hotels. Travelers are required to use these preferred vendors unless business requirements dictate otherwise. Specific travel-related questions and/or concerns should be referred to CIGNA Travel & Meeting Services. All non-employees who plan to travel on CIGNA business should adhere to the following procedures:

• Air and rail tickets, hotel and rental car reservations must be made through the Non-Employee online booking tool, or the Corporate travel agency if the tool is not accessible. The current CIGNA Corporate Travel Agency is Carlson Wagonlit Travel (CWT) at 1.866.98CIGNA (1.866.982.4462). To get access to the tool, call the Agency and request that a Traveler Profile be built. A pin and password along with the URL will be provided to access the online booking tool. Non -employees must use their own form of payment when booking travel. Charges to the central airline billing account are not allowed.
• Travelers are required to submit travel itineraries (provided by the CIGNA Corporate Travel Agency) with each expense report to document that arrangements have been made through the CIGNA Corporate Travel Agency.
• In those limited circumstances where reservations cannot be made through the online booking tool or Corporate Travel Agency in a timely manner, non-employees should purchase tickets using their personal credit card and document the reason for the exception.

Approval responsibilities

Travel expenses submitted for reimbursement must have the original signature of the CIGNA manager or a designated CIGNA employee with appropriate approval authority. The approving CIGNA manager is responsible for ensuring that the expenses are legitimate, reasonable, properly documented and in conformance with CIGNA's policy. Exceptions to the stated policies must be specifically approved on an individual basis by the applicable Business Unit Finance Officer.

Receipt and Documentation Requirements

Adherence to the following guidelines regarding receipts, documentation, and explanation is required for reimbursement. Original receipts must be obtained and submitted with the travel expense report for all expenditures of $25 or more.

• The following expenses require receipts regardless of amount or method of payment: air, hotel, car rental, and rail tickets.
• The traveler should request a receipt when it is not routinely provided in the due course of business.
• Original credit card receipts or itemized register receipts are acceptable forms of documentation.
• When no receipt is available or the receipt has been lost, a written explanation should be given on the expense report.

Air Travel

Coach is the approved class of travel for domestic and international flights. Business class is optional for international flights greater than eight (8) hours flying time with approval of the applicable CIGNA Business Unit Lead.

Every effort should be made to qualify for the lowest logical airfare by planning trips and ordering tickets in advance and by allowing flexibility in arrival and departure times. The Corporate Travel Agent will book non-refundable tickets whenever substantial savings are available. Any unused tickets must be returned to the CIGNA Corporate Travel Agency and may be used for future travel subject to the same restrictions as the original ticket with a minimal penalty. Any change fees and or fare increases incurred by changing flights en-route will not be reimbursed unless justified by a significant business need.

Reimbursable Fees

The following fee schedule is only reimbursable given the appropriate circumstances as outlined:

Non-reimbursable fees

• Overweight baggage
• Preferred seating
• Airline Club memberships
• Airline upgrade certificates or purchases of upgrades
• Internet access on board an aircraft
• Registered Traveler Program registration fees for security/TSA pre-clearance
• Headphones or personal entertainment

Use of Private or Personal Air/Water Craft

Use of private or personal air/ watercraft is not approved. No reimbursement will be made for the use of private or personal air/water craft. Non-employees are prohibited from flying their personal aircraft for CIGNA business.

Rail Travel

Coach or business class must be used for rail. A roomette or duplex accommodation is permitted when an overnight stay is required on board a train.

CIGNA travelers are now able to easily book reservations for rail via CIGNA Travel Online.

Amtrak is a cost-effective alternative to air travel when traveling between most major cities positioned along the Eastern seaboard. If travel between Hartford and Philadelphia is required, employees should consider traveling by Amtrak to contain expenses. When traveling from Philadelphia to Hartford, employees may also consider checking fares and schedules in and out of New Haven, CT, and renting a car as a viable alternative.

Travelers in the Northeast corridor may consider Acela train service, available in the booking tool, if pricing is competitive to standard Amtrak fares.

If you are not able to find the route or time you need, please call Carlson Wagonlit Travel at 866.982.4462, Prompt 1, for assistance.

Ground Transportation

Non-employees must use the most economical and reasonable means of ground transportation that satisfies the traveler's business purpose and requirements. These include and are limited to taxis, airport/hotel shuttle vans, rental car, personal car and public transportation. Costs for a private town car service or limousine will not be reimbursed.

Rental Cars

Rental cars should be used only when they are clearly the most economical mode of transportation. When reserving a car with CIGNA's preferred car rental company, through the online booking tool or Corporate agency, non-employees must:

• Request a compact or intermediate size car through the Corporate Travel Agency to obtain CIGNA's contracted rates.
• Refuse Loss/Collision Damage Waiver (LDW), Personal Accident Insurance (PAI), and Personal Property Insurance (PEP) for domestic business travel. CIGNA is self-insured and provides coverage for business rentals. Non-employees will not be reimbursed if they purchase this coverage. · Purchase available insurance coverage for business rentals outside the continental U.S., the cost of which will be reimbursed as a business expense.
• Return the rental car with a full tank of gasoline to avoid refueling charges.
• Pay for rental cars with a credit card and be reimbursed through the travel expense report process. (Direct billing of rental car expenses is not authorized.)

When rental cars are used for combined personal and business travel, the non-employee must purchase Loss/Collision Damage (LDW), Personal Accident Insurance (PAI), and Personal Property Insurance (PEP) at his/her own expense. CIGNA's self insurance will not apply to personal usage, e.g., weekends or extended non-business travel.

Personal Cars

• When public transportation is unavailable or impractical, non-employees may use a personal auto for business purposes.
• Reimbursement for miles traveled will be at the maximum rate allowed by the IRS. The mileage rate established by the IRS covers all gasoline, operating and maintenance costs.
• Parking charges and tolls will be reimbursed.
• Fines for parking or traffic violations will not be reimbursed under any circumstances.
• When submitting mileage for reimbursement, the traveler should show the miles traveled and the rate, as well as listing the destinations traveled to on the face of the expense report under purpose of travel. A detail log for mileage and client visits is acceptable documentation.
• Non-employees using a personal auto must carry minimum auto liability insurance limits of $100,000 per person/$300,000 per accident.
• In case of an accident while engaged in Company business, Company liability insurance will apply above the personal insurance. However, physical damage coverage by the Company will apply for the least of the actual loss, the personal insurance deductible or $1,000.

Lodging

All lodging reservations must be made through the Corporate Travel Agency. Preferred hotels must be utilized to take advantage of discounted hotel rates.

• Lodging bills must be paid by the traveler and included on expense reports with an original itemized invoice attached. Direct billing of lodging expenses to CIGNA is not authorized.
• Room cost, including taxes, should be listed separately from room service meals, parking, phone charges, etc. on the expense report, due to tax and other considerations.

Personal Meals

The actual cost of breakfast and dinner purchased while traveling is reimbursable within the guidelines set forth herein. If the individual leaves after the normal breakfast time or returns before the normal dinnertime, no expense should be incurred. Maximum reimbursable expense for such personal meals is $50/day ($75 in New York and Los Angeles).

Foreign Travel

Expenses related to normal foreign business travel are reimbursable.

• Expenses must be reported on the travel expense report form in U.S. currency. The exchange rate applicable at the time of the trip (as applied to charges on the individual's AMEX card or as posted in the Wall Street Journal) must be used in converting expenses to U.S. dollars, and noted on the expense report and the accompanying receipts.
• Non-employees will not be reimbursed for any portion of foreign travel expenses unrelated to the approved trade or business activity.

Other Reimbursable Expenses Related to Travel

Specific reimbursable miscellaneous/other expenses incurred while traveling include:

• Dry cleaning/laundry expenses for trips exceeding five (5) working days.
• Traveler's check fees and currency exchange fees, where applicable.
• Reasonable gratuities for service.
• Other minimal expenses deemed reasonable and necessary may be allowed. Non-employees must discuss these items with the approving CIGNA manager or designee prior to incurring the cost.

Non-Reimbursable Expenses Related to Travel

The following expenses that may be incurred in conjunction with business travel are not reimbursable and should not be included on a travel expense report:

• Airplane telephone charges.
• Fees associated with any personal charge/credit cards, including but not limited to late fees, overcharge fees and all discount programs.
• Air travel, rental car or other personal trip insurance, except as expressly provided herein.
• Charges for a barber, manicurist, beautician, shoeshine, masseur, etc.
• Athletic, social or country club fees for personal activities.
• Cost of newspapers, magazines, toiletries, cigarettes, etc.
• Fees for dependent care, elder care, pet care, home sitting, etc. arising from travel normally required by the engagement.
• Medical expenses
• Personal articles or clothing
• Personal entertainment, such as in-room movies and mini-bars.
• Luggage/briefcases.