Non-Employee Travel and Related Expenses

Introduction

Expense Policy and administrative procedures are established by Cigna (“the Company”) to ensure that all non-employees are subject to a common set of expense guidelines. This Policy applies to new hires, service providers, suppliers, consultants and independent contractors and candidates. The requirements of this Policy are the minimum acceptable standards to be followed by all non-employees.

General Policy Statement

Cigna will reimburse non-employees for actual, necessary and reasonable expenses incurred while conducting Cigna business in accordance with the requirements of this Policy. Compliance to all Cigna and Cigna vendor policies is required. Any actions outside of this Policy are the sole responsibility of the non-employee or their company of employment. Cigna assumes no further responsibility or liability.

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. Additional requirements for expense report documentation may be required by individual managers.

Non-employees who submit time for billing and payment through PRO Unlimited should invoice Cigna for their business travel expenses, including documentation of the expenses, through Wand. The Cigna manager is responsible for reviewing and approving the invoice in Wand. Once approved, expenses will be processed for payment to the vendor employer. The vendor employer is responsible for making expense reimbursement payments to their employees.

Non-employees who do not bill their time through PRO Unlimited or Wand should invoice Cigna for their business travel expenses directly, including documentation of the expenses. The Cigna manager is responsible for reviewing the invoice and submitting the approved invoice to Cigna Centralized Accounts Payable for payment.

Non-employees must note that business entertainment is strictly prohibited at establishments that provide adult entertainment. Business entertainment is not permitted, when in the opinion of Cigna management, either the nature of its activity or its venue could negatively impact Cigna's image, reputation or cause embarrassment for the Company, or that explicitly discriminates on the basis of race, gender, religion or other exclusionary factors. These restrictions apply regardless of whether Cigna is paying for the entertainment or if an employee is paying for business entertainment with his or her own funds. Cigna will not reimburse any expense that violates this requirement and will refer the matter to the vendor employer for appropriate review and action.

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 this Policy. Exceptions to the stated Policies must be specifically approved on an individual basis by the applicable Business Unit Finance Officer prior to travel.

Receipt and Documentation Requirements

Receipts are required for air, hotel, car rental and rail tickets, regardless of the amount or method of payment.

Original receipts must be obtained and submitted with the travel expense report for all expenditures of $50 or more. 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.

Please note that Cigna managers may require itemized receipts for expenditures under $50.

Cigna Global Travel Services

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

• Carlson Wagonlit Travel (CWT) is Cigna's corporate travel agency in the U.S.
• Non-employee air and rail tickets, and hotel and rental car reservations must be made through the CWT online booking tool or CWT directly at 1.866.98CIGNA (866.982.4462), Prompt 4, if the tool is not accessible.
• To get access to the tool, call CWT 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 or their vendor employer must use their own form of payment when booking travel. Charges to the central airline billing account are not allowed.
• Non-employee travelers are required to submit travel itineraries provided by CWT with each expense report.
• In those limited circumstances where reservations cannot be made through the online booking tool or CWT, non-employees or their vendor employer should purchase tickets using their personal credit card and document the reason for the exception.

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 pre-approval of the applicable Cigna Business Unit Lead.

Only Cigna Global Risk Management approved airlines must be used when traveling on Cigna business. If the airline is neither available on the booking tool, or through a CWT Travel Counselor, the airline is not approved and may not be used.

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. A change of itinerary must exceed a time change of four (4) hours. Travelers that find a flight pricing at less than what is displaying on Cigna Travel Online should call CWT (866.982.4462), select prompt 1, and speak to a travel counselor for assistance in obtaining a price match.

Reimbursable Airline Fees

• First checked bag fee: Reimbursable in all cases. Please note that the fee is included in the ticket price for most airlines, except for low cost carriers.
• Second or additional checked bag fees: A second bag is reimbursable if the duration of the business trip exceeds four (4) days. Fees for three (3) or more bags are not reimbursable.
• Buy-on-board meals or beverages: These are reimbursable; however, the daily meal allowance applies.

Non-reimbursable Airline Fees

Cigna will not reimburse the fees for the following items:

• Overweight baggage
• Preferred seating
• Airline Club memberships
• Airline upgrade certificates or purchase of upgrades
• Airline priority check-in, boarding or security line services
• Internet access on board an aircraft
• Registered Traveler Program registration fees for security/TSA pre-clearance
• Headphones or personal entertainment
• Accrued airline miles cannot be redeemed for an airline ticket and used for business travel and the value is not a reimbursable expense.

Use of Private or Personal Aircraft or Water Craft

Cigna will not reimburse for the cost of use of private or personal aircraft or water craft. Non-employees are prohibited from flying their personal aircraft for Cigna business.

Rail Travel

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

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, travelers must consider traveling by Amtrak to contain expenses. When traveling from Philadelphia to Hartford, travelers 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 to meet the business purpose, including taxis, airport and hotel shuttle vans, rental cars, personal cars and public transportation. Cigna will not reimburse the cost of a private town car (black car) service or limousine for ground transportation.

Uber, Lyft and Careem are the only ridesharing services approved for use and travel reimbursement. Non-employees must note that there are no price controls with ridesharing services; during certain seasons or events, drivers can increase their rates without notice. Travelers must use appropriate judgment when securing the service and must check options such as cabs or public transportation for cost effective options to facilitate travel.

Rental Cars

Non-employees must use Cigna's preferred rental car carriers. Rental cars must be used only when they are clearly the most economical mode of transportation. When reserving a rental car, 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 will not reimburse the cost of 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.
• Purchase Loss/Collision Damage (LDW), Personal Accident Insurance (PAI), and Personal Property Insurance (PEP) at his/her own expense if the rental car is being used for combined personal and business travel.
• Return the rental car with a full tank of gasoline to avoid refueling charges. Refueling surcharges are a non-reimbursable travel expense.
• 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.)

As a reminder, travelers should not park personal cars at the rental car facility. If absolutely necessary, travelers are advised to make arrangements with the car rental agency office in advance. Satellite radio is a non-reimbursable expense.

GPS Devices

GPS rentals through Cigna's preferred providers and booked through Cigna's travel program, only, are a reimbursable expense.

Accident Reporting

In case of an accident, travelers must complete an accident report when returning the car to the vendor. Travelers should immediately report the accident to the local police, the rental car company and their manager. Refer to Cigna's Automobile Policy for additional guidelines and suggestions.

Refueling Charges

Rental cars must be returned with a full tank of fuel to avoid vendor refueling charges. Any agency-assessed fuel surcharge, such as refueling and fuel pre-purchase surcharges, is a non-reimbursable travel expense.

Personal Cars

Before using a personal car for Cigna business, all non-employees must check with their employer/vendor to validate whether use of a personal vehicle is allowed under the terms of their contract with Cigna. In addition, the non-employee needs to ensure they are covered under the employer’s commercial general liability, umbrella and or automobile liability insurance.

In those instances where the use of a non-employees personal vehicle is allowed, reimbursement for miles traveled will not exceed the Internal Revenue Service (IRS) allowable limits and may deviate based on market conditions. The mileage rate established by the IRS covers all gasoline, operating and maintenance costs.

If the distance traveled for business exceeds an average of 150 miles per day, travelers must rent a car versus using a personal vehicle as it is more economical. Adherence to this policy reduces Cigna travel expenses. Utilizing preferred rental car agencies also affords the traveler with the protection of insurance should an accident occur while in transit.

Example: An individual is taking a 3-day trip where that person drives 300 miles on the first day to arrive at their destination, 0 miles on the second day and 300 miles for the return trip. The individual should rent a car as their daily average mileage is 200 (600 total miles / 3 trip days).

When public transportation is unavailable or impractical, non-employees may use a personal auto for business purposes.

When submitting mileage for reimbursement, the traveler’s expense report must include documentation of miles traveled, a list the destinations traveled and the purpose of travel.

Non-employees using a personal auto must personally carry minimum auto liability insurance limits of $100,000 per person/$300,000 per accident.

Cigna will reimburse the cost of parking and tolls.

Cigna will not reimburse the cost of fines for parking or traffic violations

Hotel

Non-employees must make all hotel reservations through the corporate travel agency. Preferred hotels must be used to take advantage of discounted hotel rates.

Lodging bills must be paid by the traveler or their employer 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

Cigna will reimburse the actual cost of meals purchased while traveling on Cigna business. The maximum reimbursement per person per day (including tax and gratuity) for personal meals is as follows. Costs incurred above these limits are the responsibility of the non-employee:

• $75: North America, South America (including Canada and Mexico), Europe, Middle East, Africa
• $100: New York City and the City of Los Angeles(not Los Angeles County), Australia, Asia, India, New Zealand

Personal meals are reimbursable for non-employees traveling on Cigna business only. Spouse/guest meal expenses are not reimbursable by Cigna.

Travelers must note that these amounts are maximum limits and not entitlements; non-employees must submit only actual expenses for meals incurred. Managers are required to review expense reports for frequency of meal limits for appropriate usage. Consistent reimbursement requests at the maximum allowable amount may be considered abuse of the Policy.

The purchase of alcoholic beverages is not reimbursable for non-employees.

Managers or Finance Controllers may reduce the limitations for travel and meal expenses.

International Travel

Expenses related to international business travel are reimbursable, following the requirements of this Policy.

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 or their employer’s credit card) must be used in converting expenses to U.S. dollars, and noted on the expense report and the accompanying receipts.

Cigna will not reimburse any portion of international travel expenses unrelated to the 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 where no other expense is incurred, such as baggage handling.
• Internet access
• 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

Cigna will not reimburse the following expenses that may be incurred in conjunction with business travel:

• Expenses for any personal charge/credit cards, including all discount programs.
• Membership fees for airline, rental car or other frequent traveler reward programs.
• Air travel, rental car and other personal travel insurance.
• Charges for barber, manicurist, beautician, shoeshine, masseur, etc.
• Cost of toiletries, newspaper and magazines.
• Personal articles or clothing (except damage or theft thereto).
• Personal entertainment, such as in-room movies and mini-bars, except for bottled water which will be reimbursable.
• The purchase of luggage or briefcases.
• Fees for dependent care, elder care, pet care, home sitting, etc. Social, country club or golf/tennis fees for personal activities.
• Medical expenses.
• Satellite radio service in rental cars.
• Refuel charges through a car rental agency.
• Business entertainment activities that are not approved by Risk Management. Refer to the Business Entertainment section of the Employee Policy.
• Excessive luggage.
• The value of accrued airline miles redeemed for an airline ticket for business travel
• Alcoholic beverages