Group Compliance

Date of Approval: Dec 2011

Approved by: Board

Policy Owner: Paul Boulton

Next review date: September 2016

Version No. 2016 V1

Business Travel and Expenses Policy

Purpose
• To define the Group’s acceptable business travel and expenses practices.
• To minimise the security and personal risks to employees while travelling on business.
• To be compliant with laws and regulations in the countries in which we operate, the UK
Senior Accounting Officer requirements and the UK Bribery Act.
• To protect the reputation of the Company and its employees.

Responsibility
• Morgan’s Board has ultimate responsibility for setting the Policy requirements.
• The Chief Executive Officer is responsible for implementing this Policy within the
Business.
• Group and MBU Executives are responsible for implementing and enforcing this Policy
within their MBU’s or teams.
• General/Site Managers are responsible for implementing and overseeing compliance with
this Policy at each site.
• Every employee is responsible for complying with this Policy and specific requirements in
the countries in which they operate. Any breaches or potential infringements must be
reported in accordance with the Ethics Hotline Policy.

Policy Statements

Security
• The number of employees and/or Board members travelling together should be limited to
3 Exec/Board members and/or 4 senior employees where logistics permit.
• Employees should follow guidelines for personal security when travelling to other
countries. Guidelines are generally available from the Group’s travel agents and security
websites.

Cost Control
• The company will reimburse reasonable travel and entertainment expenses when
evidenced by receipts and confirmation that it relates to business expenditure. The
standard of hotels and subsistence should be the same for all staff – standard business
class hotels and good quality but reasonably priced restaurants.

www.morganadvancedmaterials.com
Morgan Advanced Materials plc Registered in England & Wales at Quadrant, 55-57 High Street, Windsor, Berkshire SL4 1LP UK Company No. 286773
• The company will not reimburse employees for expenses that are not wholly or
necessarily incurred for the running of the business (Non reimbursable expenses include
family members travelling with employees or being entertained.)
• Travel and entertainment expenses must be approved by employees’ managers.

Occasional exceptions to the above three points where there are acceptable reasons,
require approval from 2 levels of management above the employee.

• All plc Director’s expenses must be signed off in accordance with the Director’s Expense
Claim Procedures established by the Board’s Remuneration Committee.
• The MBUs must implement accounting for expenses that complies with tax requirements
in the countries in which they operate and minimises the tax risk on the Group.

Business Ethics
• The Group’s Ethics Policy prohibits the direct or indirect offer, payment, demand or
acceptance of a bribe in cash or equivalent.
• If the giving or receiving of gifts or corporate hospitality or entertainment becomes
excessive or over frequent, they can be interpreted as being a form of bribery. Gifts or
hospitality must not be offered or accepted when they may unduly influence a business
decision.
• Permissions required/reporting of gifts/hospitality are set out in the Anti-Bribery &
Corruption Manual.
• All gifts, hospitality or expenses must be accounted for in a clear, transparent manner.

Policy Implementation, Applicability & Enforcement

• This Policy must be implemented by all Morgan operations worldwide.
• This Policy applies to:
o all Morgan directors, officers and employees; and
o all Morgan operations, including legal entities and business area units, and to Morgan joint
ventures over which Morgan is able to exercise control over policies and procedures.
• The Company will take such disciplinary action as it deems appropriate in enforcing this
Policy, up to, and including, dismissal.

External/Internal Monitoring & Compliance

• The Group is subject to legal and regulatory requirements in the countries in which it
operates. As a UK based company it is subject to the UK Bribery Act. This covers
behaviour of the Group’s worldwide workforce and their actions.
• External Audit
• Internal Audit
• Annual Group Policy self-certification requirements

Exception/Non-Compliance Reporting
Exceptions and non-compliance must be reported to and approved by the Chief Financial
Officer.

www.morganadvancedmaterials.com
Morgan Advanced Materials plc Registered in England & Wales at Quadrant, 55-57 High Street, Windsor, Berkshire SL4 1LP UK Company No. 286773