TABLE OF CONTENTS

PAGE

1. STATEMENT OF PURPOSE 2

2. RESPONSIBILITIES AND ENFORCEMENT 2

3. TRAVEL ARRANGEMENTS 3

4. AIR TRAVEL 3

5. LODGING 4

6. CAR RENTALS 4

7. OTHER TRANSPORTATION 5

8. MEALS AND ENTERTAINMENT 6

9. SPOUSE TRAVEL 6

10. OTHER REIMBURSABLE EXPENSES 7

11. NON-REIMBURSABLE EXPENSES 7

12. PAYMENT METHODS - CORPORATE CARDS 8

13. EXPENSE REPORT PROCESSING 8

1. STATEMENT OF PURPOSE

This document establishes policies governing the reimbursement of travel and entertainment expenses incurred during the conduct of Richemont business. It is Company policy to reimburse employees for ordinary, necessary and reasonable travel expenses when directly connected with or pertaining to the transaction of Company business. Employees are expected to exercise prudent business judgment regarding expenses covered by this policy.

Reimbursement for expenses that are not in compliance with this policy requires the written approval of a Brand President or the Controller of Richemont North America.

Specific brands or business units may, at their discretion, impose greater control than required by this policy, but never less.

2. RESPONSIBILITIES AND ENFORCEMENT

Company employees who incur travel and entertainment expenses are responsible for complying with this policy. Employees submitting expenses that are not in compliance with this policy risk delayed, partial or forfeited reimbursement. Cases of significant abuse may result in disciplinary action, including employee termination.

Prior to approving expense reports, managers and supervisors must ensure that their staff is adhering to this Travel Policy. Any deviations must be explained with the approval of the reviewer noted, and risk delayed, partial or forfeited reimbursement.

The Finance Department and Human Resources are responsible for the development of this policy, and for ensuring its distribution to all travelers, travel arrangers, expense approvers, accounts payable staff and newly hired employees expected to travel. Any questions regarding interpretation of this policy should be directed to 1) the direct supervisor, 2) Judy Quigley – Corporate Travel Manager, at 203 925-6574 or 3) Human Resources Department.

3. TRAVEL ARRANGEMENTS

It is the responsibility of the traveler’s manager to consider if the trip is essential, or whether alternative forms of communication would be as effective, e.g. video conferencing or telephone conference calls.

The Company provides employees access to Concur, an online travel booking and expense reporting tool. Concur is supported by TSI (Travel Solutions International). All travel arrangements must be booked either online via Concur, or by calling TSI at 214-915-9112 or toll-free at 866-396-1032.

4. AIR TRAVEL

CLASS OF SERVICE: All employees are expected to travel coach class. However, for flights greater than 3,000 miles each way, employees may travel in business class if approved by their manager.

LOWEST AVAILABLE AIRFARE: All airline tickets must be booked and expensed at the lowest airfare available at the time of booking. Employees are encouraged to book in advance to take advantage of cost savings.

FREQUENT FLIER PROGRAMS: Traveling employees may retain frequent flier program benefits. However, participation in these programs may not result in any incremental cost to the Company beyond the “lowest available airfare,” as defined above.

INSURANCE: The Company provides Travel Accident insurance coverage for accidental injury or death while traveling on business. Any purchase of business travel insurance is a personal expense. Personal items that are lost or stolen are not covered by the Company’s insurance. Please check with your homeowner’s policy for coverage.

PAYMENT AND DOCUMENTATION: Airline tickets must be charged to the employee’s corporate American Express card, and submitted on an expense report in Concur. The confirmation email or itinerary generated by TSI may be used as the required receipt.

5. LODGING

HOTEL SELECTION: Employees are expected to choose a moderately-priced business class hotel. Hotels should be booked through Concur, which reflects the Company’s preferred hotel properties and negotiated rates.

CANCELLATION: Please be sure to note the hotel cancellation policy, regardless of whether your reservations have been made through Concur, TSI or directly with the hotel. When cancellations are necessary, you must cancel with adequate notice to avoid a no-show charge. Please retain the cancellation number you are given.

PAYMENT AND DOCUMENTATION: Lodging charges are to be billed to the employee’s corporate American Express card (or a personal credit card for those employees without a corporate card). These charges need to be itemized (by day and expense type, e.g. lodging, phone, hotel parking) and submitted on an expense report in Concur (see #13 below). The original hotel folio bill must be provided as a receipt when submitting your expense report. Please contact the Corporate Travel Manager or the Accounts Payable Manager with any questions regarding this expense process.

6. CAR RENTALS

Cars should be rented by employees only when other means of transportation are unavailable, more costly, or impractical. The use of a rented car must be justified as a business need and not as a matter of personal convenience. All rentals should be for intermediate size cars or smaller whenever possible.

The company uses Hertz as a preferred car rental vendor. Reservations made through Concur or TSI will automatically be made using our corporate discount program. If you make reservations directly with Hertz via the telephone or online, please be sure to provide our CDP (Corporate Discount Program) number of 260940.

Please contact Judy Quigley, Corporate Travel Manager if you would like information on joining the Hertz Gold Plus Rewards Program.

CAR RENTAL INSURANCE: For rentals within the United States, please decline all insurance coverage. If you elect Personal Effects or Personal Accident Coverage, this must be at your own expense and is not reimbursable. When renting a vehicle outside the U.S., optional property casualty insurance may need to be purchased from the rental car company, and is reimbursable to employees. If you have any questions about car rental insurance, please contact the Corporate Travel Manager.

Personal items that are lost or stolen (e.g. if your rental car is broken into) are not covered by the Company’s insurance. Please check with your homeowner’s policy for coverage.

PAYMENT AND DOCUMENTATION: Car rentals are to be charged to employee held corporate charge cards and must be documented on expense reports with the original car rental contract. If you will be traveling for business and do not have a corporate credit card, please contact the Corporate Travel Manager for assistance.

7. OTHER TRANSPORTATION

Expenses incurred when traveling between your home and normal place of work are not reimbursable. However, if you are required to work after 10:00 p.m., your manager may approve that you claim the cost of a taxi to a train station or home.

Travel between Richemont offices in Shelton and New York should be made by train or your personal vehicle only. Hired or rented car is only justifiable if traveling in a group of three or more employees.

PERSONAL CAR: Employees may utilize personal cars for business travel when other transportation is unavailable or uneconomical. The use of personal cars for business will be reimbursed at the standard rate prescribed by the IRS. This mileage allowance covers all auto costs (e.g. gasoline, repairs, insurance, etc.) other than parking and tolls. Accidents or other losses must be claimed through your personal insurance company.

RAIL: Rail transportation can be in business class in the U.S. and may be first class internationally only if economy represents a hardship. Sleeping accommodations, when necessary, are limited to a roomette or equivalent.

TAXIS, LIMOUSINES AND OTHER LOCAL TRANSPORTATION: Employees are entitled to reimbursement for taxi fare in the normal course of business. Use of limousines is authorized only when traveling with clients or when more economical services (hotel vans, shuttles, taxis, etc.) are not available. Airport transportation services, such as Connecticut Limousine, should be selected rather than booking private limousines. Receipts are required for all transportation expenses of $10.00 or greater.

8. MEALS AND ENTERTAINMENT

FOOD DELIVERED TO OFFICE expenses are those incurred when ordering food to be consumed by staff in the regular place of business (such as ordering in pizza, sandwiches, etc.) when such meals are justified to facilitate Company business. This type of expense must be charged and submitted by the department manager. Please note that this is expected to occur only occasionally, and by no means should be used as providing meals to staff on a regular basis.

BREAKFAST, LUNCH OR DINNER expenses are those incurred by employees when dining alone on an out-of-town business trip. Actual meal expenses will be reimbursed up to a daily limit of $100.

BUSINESS MEALS are those meals taken with Richemont associates during which a business discussion takes place. This expense should be charged and submitted by the most senior employee present.

ENTERTAINMENT EXPENSES are expenses which are incurred entertaining clients or prospects. It is expected that a business discussion take place immediately before, during or after the event.

PAYMENT AND DOCUMENTATION: Business Meals and Entertainment expenses require you to identify attendees as well as the business purpose. Receipts are always required for this type of expense.

IRS REQUIREMENTS: It is Company policy to be in compliance with IRS regulations at all times; therefore, the following information must be included on employee expense reports as support for all business meal and entertainment expenses:

·  Name, title and company of all attendees

·  Name and location of the establishment where the event took place

·  Amount and date of the expense

·  Specific business topic discussed

Failure to comply with IRS requirements may result in a loss of expense deductibility to the Company, and to unforeseen tax liability to individuals.

9. SPOUSE TRAVEL

Travel expenses for a spouse are not reimbursable as a business expense unless the spouse’s presence was both essential and directly related to the effective accomplishment of Company business. In these limited instances, the employee must obtain written approval IN ADVANCE from their immediate supervisor. Spouse travel expenses are to be included on the employee’s expense report.

10. OTHER REIMBURSABLE EXPENSES

The following incidental expenses, when directly related to business travel, are reimbursable:

·  Tips for taxi drivers, doormen, bellmen

·  Laundry/Valet: For trips in excess of 4 days

·  Parking

·  Currency Conversion

·  Travelers Cheque fees

11. NON-REIMBURSABLE EXPENSES

The following are examples of non-reimbursable expenses:

·  Baby-sitter/daycare

·  Pet care

·  Airline club dues

·  Upgrades for air, hotel or auto

·  Health club fees

·  Massage

·  Barber/Hairstylist, manicures, and other grooming

·  Toiletries

·  Traffic fines

·  In-flight movies/refreshment

·  Hotel room movies

·  Hotel phone charges (if employee has a Company-issued cell phone)

·  Theatre tickets

·  Sporting events (other than Richemont-sponsored events)

·  Mini-bar charges (unless a snack is substituting a meal)

·  Luggage, briefcases

·  Car repair

·  Car wash

·  Political or charitable contributions

·  Credit card interest charges/late fees

·  Membership fees for credit card rewards programs

·  Club membership fees not related to your employment

·  Newspapers and magazines not related to your employment

12. PAYMENT METHODS - CORPORATE CARDS

USAGE: The Company utilizes the American Express Corporate Card system as its principal payment method for travel and entertainment expenses. Corporate cards are to be utilized for all air, lodging, car rental, meal, entertainment and miscellaneous T&E expenses. Corporate cards are intended for business use only, and may not be utilized for personal expenses.

Office expenses should not be charged on the American Express Corporate Card. Employees should develop service contracts with service providers and should establish direct billing.

ISSUANCE CRITERIA: Cash advances are not available. All employees expected to travel at least once per year, or who will incur at least $1,000 per year in local entertainment expenses, should acquire a corporate credit card. If you meet these criteria and do not have a corporate card, please contact the Corporate Travel Manager for application information. Any application will require appropriate approvals.

BILLING AND PAYMENT: Employees must submit their cash and corporate credit card charges on their expense reports using the Concur tool. Concur will pay American Express directly for all charges imported into approved expense reports. Employees who allow their corporate cards to fall into delinquent status will incur late fees and risk suspension or cancellation of the credit card. Cases of significant abuse may result in disciplinary action, including employee termination.

Please note, as mentioned above under “Usage,” employees who lose their corporate card charge privileges will not have access to cash advances or to any central billing mechanism.

13. EXPENSE REPORT PROCESSING

EXPENSE REPORT PROCESS: The Company utilizes a third party, Concur, to manage the expense reporting and reimbursement process. For enrollment instructions or if you have any questions about the expense reimbursement process, please contact the Corporate Travel Manager.

AUTHORIZATION: A supervisor with designated approval authority must approve all expense reports. These approvers are expected to check expense reports for accuracy and compliance with this policy.

ADDITIONAL INFORMATION: For additional information about this policy and the Company’s travel management program, please contact the Corporate Travel Manager.

Update: October -12 Page: 8 of 8