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HomeMy WebLinkAbout20221223_Veolia to Staff Attachment - Response to No. 104.pdfVEO-W-22-02 IPUC DR 104 Page 1 of 1 VEOLIA WATER IDAHO, INC. CASE VEO-W-22-02 THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF Preparer/Sponsoring Witness: Cary REQUEST NO. 104: Please provide a copy of the Company credit card and purchase card policy. RESPONSE NO. 104: Please see the Attachment for the Company’s purchasing card policy. Purchasing Card Policies and Procedures January 5, 2021 VEO-W-22-02 IPUC DR 104 Attachment Page 1 of 11 January 5, 2021 Page 2 Purchasing Card Policies and Procedures SUEZ PURCHASING CARD POLICIES & PROCEDURES TABLE OF CONTENTS Purpose 3 Scope of the Policy 3 Obtaining a Purchase Card (Eligibility) 3 Card Issuance Criteria 4 Card Activation 4 Card Renewal 4 Purchase Card Use 5 Resolving Returns, Credits, Disputes & Billing Problems 5 Declined Transactions 5 American Express Card Acceptance 6 Limit Changes and Exceptions 6 Inactive Purchasing Cards 6 Transfer and Terminations 6 Safeguarding your Card Account 6 Fraud 7 Misuse and Policy Violations 7 Audit of the Card 7 Reconciliation Process 8 Purchase Card Payments 9 Business Ethics and Employee Obligations 9 Failure to Comply with Procedures and Guidelines 9 General Roles and Responsibilities 9 Amendments to Purchase Card Policy 10 VEO-W-22-02 IPUC DR 104 Attachment Page 2 of 11 January 5, 2021 Page 3 Purchasing Card Policies and Procedures PURPOSE This policy sets forth the terms and conditions that employees of SUEZ North America (“SUEZ,” “SUEZ NA” or the “Company”) must comply with when using SUEZ bank-issued purchasing cards (P- Card) to purchase high volume and low cost materials and services. “Low cost” transactions are defined throughout this policy as those individual purchases under $2,500 per individual transaction. Use of the P-card to purchase services is permitted for services deemed to be of low risk based on the business unit assessment and relative spend level (under $2,500 per individual transaction). While the P-Card program is primarily suited to OPEX purchases, there are limited situations whereby the card can be used to purchase low-risk, CAPEX equipment and services. Please consult your supervisor or Supply Chain Management (“SCM”) if you require further clarification to assess whether a contract/MSA is a more suitable approach. Scope of the Policy The P-card is a charge card issued by American Express which is used to make purchases for approved business related goods and services. This is a payment method that enables SUEZ to reduce and eliminate the administration for sanctioned goods and services, reduce overall purchase- to-pay process costs, increase productivity, improve relationships with suppliers and streamline the audit process. These benefits can be achieved while maintaining management controls and promoting spend visibility which increases our purchasing power and ensures appropriate use of company funds. This policy applies to all authorized SUEZ NA employees. Purchasing Cards are individually requested and must be approved by the employee’s immediate supervisor (except in rare situations where the requested credit limit exceeds the approver’s Delegation of Authority in which case EXCOM approval will be required). All purchases will be paid centrally by SUEZ. The SCM Department is responsible for administering and enforcing the policies and procedures of the P-card program as approved by the EXCOM. The P-card shall not be used as a substitute for: • Personal business expenses • Fleet fuel cards • Circumvention of SUEZ Procurement Policies/Procedures/Programs/Preferred Vendors • Other corporate cards Personal use of the P-card is strictly prohibited and may result in disciplinary action up to and including termination of employment. Obtaining a Purchase Card (Eligibility)  SUEZ employees who have a relevant business need to procure certain types of low cost goods and services  Cards will not be issued to contingent workforce or contractors/consultants  Eligibility is subject to approvals by immediate supervisor or EXCOM (per the Delegation of Authority) VEO-W-22-02 IPUC DR 104 Attachment Page 3 of 11 January 5, 2021 Page 4 Purchasing Card Policies and Procedures Card Issuance Criteria All cardholders must meet the following conditions, prior to card issuance:  Cardholder and approver review and accept P-Card Policy and Cardholder Agreement during the BTS Portal application process. The Cardholder Agreement signifies that the applicant and approver acknowledges that they have had adequate training, understand the P-card Policies and Procedures, and accept responsibility for compliance with the P-card Policies and Procedures. Cardholders and Approvers will need to positively attest to reading/acknowledging the Purchasing Card Policies & Procedures prior to card issuance.  Complete cardholder introductory training prior to card issuance. Annual, refresher training must also be completed to maintain P-Card program eligibility. Card Application and Approval Purchasing Card applications must be submitted by the requestor using the SUEZ BTS Portal on The Resource. All applications will be automatically routed for approval by immediate supervisor or respective EXCOM member. When the steps above are successfully completed, American Express will issue the card within 7-10 business days. The card will be delivered directly to the Cardholder at the business address specified on the application. Card Credit Limits and Restrictions To ensure adequate control, all Purchasing Cards are assigned with a standard credit limit of $2,500 per individual transaction and $10,000 per month. Credit limit variations will be reviewed/approved on an exception basis only and must be accompanied by an EXCOM approval and business justification. In addition, certain spend categories have been restricted to ensure compliance with this policy. See Appendix A for a list of restricted Merchant Category Codes (MCC). Card Activation Upon receipt, employees must sign the back of the card and immediately activate the card using one of the following processes: Call: 1-800-362-6033 Link: www.americanexpress.com/confirmcard Please note you will be asked to verify your identity using the telephone number provided on your application. This ensures you are the only one authorized to activate the P-card. Card Renewal The Purchasing Card expires every four years, as indicated on your card. Prior to card expiration, SCM will review each Cardholder’s status and if eligible, the Cardholder will be issued a new card to ensure uninterrupted service. Cardholders are responsible for secure destruction of any expired cards. Expired cards will no longer remain active after 30 days of receiving the new card. VEO-W-22-02 IPUC DR 104 Attachment Page 4 of 11 January 5, 2021 Page 5 Purchasing Card Policies and Procedures Purchase Card Use The Purchasing Card is the preferred method of payment for high volume, low cost products and services. For the purposes of this policy, “high volume” is defined as those low-risk transactions under $2,500 that generate a significant amount of administrative burden associated with the purchase to payment process (PO’s, invoices, etc.). Acceptable Purchasing Card use guidelines are provided below:  Use for relevant, business purchase of unrestricted categories (as previously defined in this policy).  Certain categories of spend have been blocked to ensure proper utilization of the card program per this policy  Purchase of products and low-risk services under $2,500 per individual transaction. Splitting charges to adhere to the individual transaction limit is strictly prohibited.  Monthly transactions limits under $10,000 (limited exceptions only with EXCOM approval)  Repetitive transactions such as E-ZPass®, uniforms, office supplies, etc. Supply Chain Management acknowledges that exceptions will have to be made for certain Cardholders when it makes business sense and these exceptions must be approved at the discretion of the respective EXCOM member. Resolving Returns, Credits, Disputes & Billing Problems The Cardholder is responsible for resolving any issues related to returns, credits, disputes and/or incorrect charges.  The Cardholder will work directly with the vendor to reach a resolution.  Disputes may result from failure to receive materials or services ordered, fraud or misuse, altered charges, duplicate charges, defective merchandise, incorrect amounts, credits not processed, etc.  Cardholders may request a credit from the vendor for any disputed items as well as a credit slip to attach with your monthly statement. Disputed items should be documented in the reconciliation process.  If an acceptable resolution cannot be reached with the vendor, contact American Express Customer Service at 1-800-492-4920 or dispute the transaction using American Express MYCA. Declined Transactions A transaction may be declined for various reasons, including:  The Merchant Category Code (MCC) is not approved by SUEZ for P-card use (See Appendix A);  The amount exceeds the authorized dollar amount for a single transaction;  The maximum spending limit per month/cycle has been exceeded; and  Charging privileges may be suspended due to administrative violations per policy. VEO-W-22-02 IPUC DR 104 Attachment Page 5 of 11 January 5, 2021 Page 6 Purchasing Card Policies and Procedures If a transaction is denied, the Cardholder should login to the American Express MYCA tool to identify the reason for the decline and resolve the problem. If further assistance is required please contact the Purchasing Card Administrator. American Express Card Acceptance If a supplier does not accept the American Express P-card, employees should contact the P-card Administrator. The P-card Administrator will review the supplier with Procurement to ensure that a competitive and preferred supplier does not already exist. If the supplier is deemed to be essential to the business, Procurement will advise American Express to contact the supplier and encourage them to enroll as a participating merchant. Limit Changes and Exceptions All permanent P-card limit or restriction changes to existing cards must be requested via the BTS Portal on The Resource. Any permanent P-card limit increases above the default $2,500 individual transaction and $10,000 monthly limits must be approved by an EXCOM member and CFO. Temporary individual credit limit increases and MCC/category restrictions will be considered on an exception basis with appropriate business justification at the discretion of the P-card administrator. Any approved, temporary credit limit increase will be at a standard $5,000/individual transaction and $20,000/monthly level and will revert back to the standard limits after 90 days. Inactive Purchasing Cards Purchasing Cards are periodically audited for inactivity. Any P-card that has had no charge activity for a period longer than 12 months will be automatically cancelled. Transfer and Terminations The card may not be transferred to, assigned, or used by anyone other than the designated Cardholder. Any cardholder turnover resulting from termination or project reassignment should be communicated to SCM immediately. The Manager should also resolve any disputes and reconcile outstanding expenses on behalf of the terminated employee. The Manager will immediately submit a notification to cancel the account. If any employee is taking a leave of absence, then the P-card can be placed on an “inactive” status during the leave period and can be reactivated upon the employee’s return in writing from their department’s manager. Safeguarding your Card Account It is the cardholder’s responsibility to safeguard the P-card and account number at all times. P-cards must be kept in a secure location and should only be used to process transactions by the respective cardholder. In order to prevent exposure to fraud, the full P-card account number should not be recorded electronically or on paper. Employees must report a stolen, lost or misplaced P-card immediately by telephone to American Express (1-800-492-4920). VEO-W-22-02 IPUC DR 104 Attachment Page 6 of 11 January 5, 2021 Page 7 Purchasing Card Policies and Procedures Fraud Fraud is the intentional, unauthorized use of a card or account, which results in damage to the company, usually through purchases which do not benefit the company. This can occur from stolen cards, account numbers, or counterfeit cards, used by a third-party which did not have actual, implied, or apparent authority to use the card or account. Use of a card or account by the cardholder or other authorized user, in collusion with a supplier for personal gain also constitutes fraud. Employees should set-up account alerts with American Express and monitor their monthly billing statement for unauthorized charges. Report suspected fraud immediately to the P-card Administrator and American Express. Misuse and Policy Violations Policy violations may be subject to sanctions including suspension of card privileges, card cancellation, and other disciplinary action as deemed appropriate by SUEZ. Examples of misuse and policy violation include, but are not limited to: Misuse: Purchase of items for personal use; purchase of restricted commodities; splitting one charge over multiple transactions to circumvent the transaction limit; use of the card by anyone other than the authorized Cardholder; Purchases from a Merchant set up as PO type and PO (purchase order) is rejected. Administrative Violations: Failure to obtain and maintain supporting documentation for card transactions; failure of Cardholder and Approver to sign off on transactions by deadline; Lack of timely and proper reconciliation of posted transactions; Approval of transactions that violate other policies. Personal use of the P-card is strictly prohibited and may result in disciplinary action up to and including termination of employment. Audit of the Card As with all other forms of purchases, the use of the P-card is subject to the same levels and types of supervisory approvals and accounting controls as would otherwise apply. Purchases and records are also subject to the Company’s internal and external audit review and review by the P-card Administrator. Following is an overview of the audit types and procedures. Full detail on the audit process is available only to the P-card Administrator. Audits include but are not limited to:  Termination Audits: Based on termination notice from Human Resources or approving manager.  Monthly Audits: Active cards will be randomly audited to review transactions for policy compliance.  Timely Submission: Itemized receipts, approval and validity, appropriate use and high risk. Failed audits may result in suspension/cancellation of account privileges (requiring EXCOM approval for reactivation) and/or disciplinary action up to and including termination of employment, depending on the severity of the offense. VEO-W-22-02 IPUC DR 104 Attachment Page 7 of 11 January 5, 2021 Page 8 Purchasing Card Policies and Procedures Reconciliation Process Concur is a web-based tool that allows Cardholders to review, reallocate accounting information, and reconcile their monthly transactions. The tool is also used to interface information to SUEZ’s financial systems, generate reports, and facilitate payment to American Express. Supplier transaction information is available via Concur within 48-72 hours after the supplier processes the transaction. The following process will be conducted for each transaction by the Cardholder:  Verify the transaction data from American Express agrees with your own personal record of the transaction  Review data provided by the supplier for each transaction captured at the point of sale  Add the business justification in the comments box for each transaction  Select the correct Expense Type for P-Card transactions (denoted by card image) and code correctly  Allocate transactions between various Business Units & Departments and GL Accounts.  Add comments and other details for each transaction (ex: note if a charge is disputed). In addition, notify your business unit accounting department of the omission for accrual.  Attach receipt copy at line item level for all transactions. Failure to review and/or reallocate transactions by the close of the billing cycle, may result in the suspension/cancellation of charge privileges until such time all reconciliation requirements have been completed. Monthly Billing Statement Each Cardholder will have access to their monthly billing statement via Manage Your Card Account at www.americanexpress.com/checkyourbill, 48 hours after the billing cycle ends.  Attach all appropriate receipts, credit slips and/or invoices to your monthly billing statement  Document any missing receipts with the Missing Receipt Affidavit Form on Concur To adhere with record retention guidelines, Concur must can be used as a repository for P-Card receipt images in place of maintaining hard copy receipts. Receipt attachment at the line item transaction level is a mandatory requirement of expense submission. Approver Reconciliation Responsibilities It is the responsibility of the designated Approver (usually the supervisor/manager of the Cardholder) to ensure that all purchases on the individual’s statement are for appropriate and business purposes only. Managers will be held accountable for any misuse that was not identified and reported to the P- card Administrator. Following are the steps for the monthly review and approval process:  Review all supporting transactions and receipts in Concur to ensure the charges and documentation are valid  Approve transactions electronically via Concur before monthly cycle cut  Ensure a brief description is included for each transaction in the “Comments” box or description if the Cardholder has not done so VEO-W-22-02 IPUC DR 104 Attachment Page 8 of 11 January 5, 2021 Page 9 Purchasing Card Policies and Procedures  Managers should have access to cardholder receipts (electronically in Concur) when signing off on transactions in Concur, comparing to monthly statement Discrepancies must be investigated immediately and resolved in a timely manner to ensure SUEZ is not assessed a late fee for non-payment of a charge. P-Card Payments SUEZ will submit payment directly to American Express for all P-card charges. Under no circumstances will the Cardholder be permitted to make a direct payment to American Express. Business Ethics and Employee Obligations The Cardholder, as an authorized purchaser for SUEZ, must adhere to the Company’s principles of ethics, integrity and transparency in the purchasing process. All Cardholders are required to comply with the obligations set forth in SUEZ Group’s Ethics Charter and Practical Guide 2015: ethics in commercial relations. During any involvement (direct or indirect) with vendors, the Cardholder’s only legitimate interest must be the best interest of SUEZ. You must not give or even appear to give a preference to anyone at the expense of the Company. The vendors are, in a sense, your business partners. In line with these principles, employees must also comply with SUEZ North America’s Ethics Policy, Conflict of Interest Policy and Gift Policy. If any employee suspects P-card fraud or abuse, the employee should report the fraud or P-card abuse to their supervisor, who in turn, should contact the P-card Administrator and the Ethics Committee (via the SUEZ NA Ethics Hotline at 877-384-4277 or ethics@suez-na.com). Failure to Comply with Procedures and Guidelines Any clear infraction of prevailing business ethics, misuse or non-compliance with the procedures contained in the SUEZ P-card Procedure Manual, Ethics Policy, Conflict of Interest Policy and Gift Policy, or failure to comply with any of the responsibilities set forth in this Policy, may result in permanent revocation of the P-card. In addition, the Cardholder may be subject to disciplinary action, up to and including termination. The Company also reserves the right to seek recovery from the Cardholder for any unauthorized or personal use of the P-card. General Roles and Responsibilities Employee  Read and understand the P-card Policy, Terms & Conditions.  Submit legal or employee conforming name changes to the P-card Administrator.  Adhere to policies & procedures when making purchases.  Utilize preferred suppliers whenever possible.  Be accountable for all purchases and appropriate use of Company funds.  Ensure orders are complete when receiving goods & services.  Attach/upload itemized receipts for ALL transactions to Concur.  Work with the supplier to resolve any issues and/or discrepancies concerning an order.  Be responsible for the safeguarding and safekeeping of the P-card number at all times.  Contact the P-card Administrator to cancel a P-card that is no longer required. VEO-W-22-02 IPUC DR 104 Attachment Page 9 of 11 January 5, 2021 Page 10 Purchasing Card Policies and Procedures  Complete introductory and annual recurring P-Card training Manager  Approve new Cardholder applications for employees that meet the requirements outlined in this policy.  Accept ownership and responsibility for card use by all his/her employees.  Ensure that all Cardholders in their department use the P-card according to the guidelines described in this Policy.  Notify the P-card Administrator of active Cardholder(s) changing roles or leaving the Company so that the employee’s card(s) in the program will be reviewed or cancelled immediately. For employees leaving the company, the Manager should then destroy the P- card immediately.  Timely review and approval of P-Card transaction accuracy including itemized receipt review  Complete annual training P-card Administrator  Ensure Cardholders have met the eligibility requirements and completed program pre- requisites.  Manage Cardholder communications and support training requirements.  Ensure all card transactions are reconciled by the due date.  Review and audit P-card transactions for reasonableness, misuse, and/or abuse.  Manage controls and restrictions including monitoring spending limits and updating category restrictions.  Coordinate Cardholder enrollment, termination, and changes.  Manage all P-card suspensions and terminations.  Collaborate with Internal Control and Finance to develop, implement, enforce, and measure effectiveness of program controls.  Collaborate with Sourcing to evaluate spend categories and suppliers approved for the P- card program.  Conduct an annual review and, if necessary, update the P-card policy and distribution to Cardholders, Managers and Finance. Accounts Payable  Issue payment to the P-card provider. Procurement  Review requests to modify category restrictions to the P-card program.  Responsible for working with P-card Administrator on the strategic development of the P-card program. Amendments to P-Card Policy This policy may be modified or updated from time to time. A new version of the policy will be published incorporating such modifications or updates, as approved by Procurement and Legal, or as recommended by SUEZ Group. VEO-W-22-02 IPUC DR 104 Attachment Page 10 of 11 January 5, 2021 Page 11 Purchasing Card Policies and Procedures Appendix A – Blocked/Restricted Merchant Category Codes (MCC) for P-Card Program Blocked Categories Furriers and Fur Shops Securities Brokers and Dealers Beauty and Barber Shops Funeral Services and Crematories Counseling Services, Marriage and Personal Pawn Shops Dating and Escort Services Massage Parlors Betting, Lottery, Casino, Gambling Bail and Bail Bond Payments Jewelry, Precious Stones, Metals and Watches Political Organizations Religious Organizations Restricted Categories Court Costs, Fines, Fees, Child Support Electronic Stores Gift Cards Charitable or Political Contributions Prescription Drugs Cash Advances VEO-W-22-02 IPUC DR 104 Attachment Page 11 of 11