HCP Reimbursement Policy - Treace Medical Concepts

Health Care Professional Expense Reimbursement Policy

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Effective July 19, 2021

Consistent with the AdvaMed Code and standards of Treace Medical Concepts, Inc. (the “Company”), this is a policy regarding reimbursement of modest and reasonable expenses incurred by HCP’s in receiving training on the safe and effective use of the Company’s products at Company-run training events. The Company may revise this Policy upon the approval of the members of its Management Compliance Committee (the “Committee”). The Committee shall also have the right to grant exceptions to this Policy for individual HCPs with bona fide qualifying circumstances, but only so long as such exceptions fall within what the Committee reasonably believes to be current industry standards and/or best practices, and generally comply with the AdvaMed Code, and applicable laws and regulations.

Required Documentation. Itemized receipts must be submitted to the Company before any expenses are reimbursed. The Company reserves the right to not reimburse any expenses submitted more than 90 days after they were incurred. The Company will pay approved reimbursable expenses promptly after it receives properly submitted receipts and verifies that the expenses comply with this Policy. A completed W-9 form, NPI number, and payment remittance address for the HCP will be needed prior to Company reimbursing HCP’s expenses.

PLEASE REVIEW BELOW FOR REIMBURSABLE AND NON-REIMBURSABLE ITEMS.

TRAVEL EXPENSES

PAID/REIMBURSED BY THE COMPANY	NON- REIMBURSABLE ITEMS
Coach class, lowest logical round-trip commercial airfare at rates reflecting booking promptly after the trip is scheduled. We prefer airfare to be booked 2 weeks or more before the scheduled meeting date where feasible to reduce higher, last-minute airfare charges Round trip from home city to destination of educational event If HCP books a business class or first class flight or other class besides coach, HCP must provide evidence of the equivalent coach class airfare booked in advance when submitting a reimbursement request. Baggage charges Fees incurred from unavoidable travel changes necessitated by the Company Taxi or comparably priced ground transportation; fares may be reimbursed for travel to and from the destination airport to the meeting location. Reimbursement of rental car charges between the destination airport and the meeting location require pre-approval. A reasonable, mid-size rental car from home to the meeting location if driving is less expensive than airline travel. Fuel receipts will be reimbursed. Parking fees at airport and hotel Mileage, for use of personal vehicle between home city and the meeting location at the then-current IRS standard mileage rate. To be reimbursed for mileage, HCP must provide a Google Map or similar documentation of mileage verifying the miles traveled from the home city to the meeting location.	Travel (including flight upgrades) and ground transportation upgrades. HCP will be responsible for the additional costs of flight upgrades and must provide evidence of the equivalent coach class commercial airfare. Other travel-change fees not related to a Company-directed schedule change Use of airline frequent flyer club facilities Travel for spouses or other guests Limousine ground transportation, unless pre- approved and provided directly by the Company for a scheduling necessity where other transportation is not available Private aircraft costs or charter service Mileage for rental cars Insurance costs; e.g., life insurance, flight insurance, personal or rental car insurance, baggage insurance Lost baggage charges

PAID/REIMBURSED BY THE COMPANY

NON- REIMBURSABLE ITEMS

Coach class, lowest logical round-trip commercial airfare at rates reflecting booking promptly after the trip is scheduled. We prefer airfare to be booked 2 weeks or more before the scheduled meeting date where feasible to reduce higher, last-minute airfare charges
Round trip from home city to destination of educational event
If HCP books a business class or first class flight or other class besides coach, HCP must provide evidence of the equivalent coach class airfare booked in advance when submitting a reimbursement request.
Baggage charges
Fees incurred from unavoidable travel changes necessitated by the Company
Taxi or comparably priced ground transportation; fares may be reimbursed for travel to and from the destination airport to the meeting location. Reimbursement of rental car charges between the destination airport and the meeting location require pre-approval.
A reasonable, mid-size rental car from home to the meeting location if driving is less expensive than airline travel. Fuel receipts will be reimbursed.
Parking fees at airport and hotel
Mileage, for use of personal vehicle between home city and the meeting location at the then-current IRS standard mileage rate. To be reimbursed for mileage, HCP must provide a Google Map or similar documentation of mileage verifying the miles traveled from the home city to the meeting location.

Travel (including flight upgrades) and ground transportation upgrades. HCP will be responsible for the additional costs of flight upgrades and must provide evidence of the equivalent coach class commercial airfare.
Other travel-change fees not related to a Company-directed schedule change
Use of airline frequent flyer club facilities
Travel for spouses or other guests
Limousine ground transportation, unless pre- approved and provided directly by the Company for a scheduling necessity where other transportation is not available
Private aircraft costs or charter service
Mileage for rental cars
Insurance costs; e.g., life insurance, flight insurance, personal or rental car insurance, baggage insurance
Lost baggage charges

LODGING EXPENSES

PAID/REIMBURSED BY THE COMPANY	NON- REIMBURSABLE ITEMS
One standard room for the duration of the educational event, including the night before and the night of, if necessary due to travel schedules The Company may book rooms at the Company- approved facility and will pay or reimburse the cost of the rooms at the Company-approved facility. Lodging at a location other than at the Company-approved hotel or other exceptions will not be paid or reimbursed unless the alternate facility and its lodging costs are pre-approved by the Company in advance of the educational event. Reasonable internet access service Submission of bill detailing charges is required Reasonable gratuities in connection with reimbursable expenses	Incidental lodging expenses; e.g., in- room movies, room service, laundry, dry cleaning, spa services Lodging upgrades or the additional cost of an more expensive hotel or of a hotel other than the Company- approved facility without the Company’s prior approval of the alternate facility and its lodging costs. Costs related to a spouse or other guest staying with the HCP Charges for additional nights before or after the educational event not necessary due to travel schedules Valet parking fees Optional fitness and resort facility charges

PAID/REIMBURSED BY THE COMPANY

NON- REIMBURSABLE ITEMS

One standard room for the duration of the educational event, including the night before and the night of, if necessary due to travel schedules
The Company may book rooms at the Company- approved facility and will pay or reimburse the cost of the rooms at the Company-approved facility. Lodging at a location other than at the Company-approved hotel or other exceptions will not be paid or reimbursed unless the alternate facility and its lodging costs are pre-approved by the Company in advance of the educational event.
Reasonable internet access service
Submission of bill detailing charges is required
Reasonable gratuities in connection with reimbursable expenses

Incidental lodging expenses; e.g., in- room movies, room service, laundry, dry cleaning, spa services
Lodging upgrades or the additional cost of an more expensive hotel or of a hotel other than the Company- approved facility without the Company’s prior approval of the alternate facility and its lodging costs.
Costs related to a spouse or other guest staying with the HCP
Charges for additional nights before or after the educational event not necessary due to travel schedules
Valet parking fees
Optional fitness and resort facility charges

MEALS AND OTHER EXPENSES

PAID/REIMBURSED BY THE COMPANY	NON- REIMBURSABLE ITEMS
The Company may decide to offer meals during a business meeting with educational content, in which case the Company will arrange and pay for the meal.	The Company will not reimburse HCPs for any meal expenses, including costs of food and drinks. Company business meetings may include meals paid for by the Company. Only these meals arranged by the Company as part of the business meeting will be paid for by Company. Hospitality or entertainment expenses of any kind, including without limitation lift tickets, golf fees, excursion fees, sports tickets Any alcohol not arranged and paid for directly by the Company Meals for spouses or other guests Meals between the HCP and other Business Colleagues Personal grooming expenses; e.g., barber, hairdresser, shoe shine Loss or theft of cash advance money, airline tickets, personal funds, or property Parking tickets or traffic violation fees Personal automobile repairs

PAID/REIMBURSED BY THE COMPANY

NON- REIMBURSABLE ITEMS

The Company may decide to offer meals during a business meeting with educational content, in which case the Company will arrange and pay for the meal.

The Company will not reimburse HCPs for any meal expenses, including costs of food and drinks. Company business meetings may include meals paid for by the Company. Only these meals arranged by the Company as part of the business meeting will be paid for by Company.
Hospitality or entertainment expenses of any kind, including without limitation lift tickets, golf fees, excursion fees, sports tickets
Any alcohol not arranged and paid for directly by the Company
Meals for spouses or other guests
Meals between the HCP and other Business Colleagues
Personal grooming expenses; e.g., barber, hairdresser, shoe shine
Loss or theft of cash advance money, airline tickets, personal funds, or property
Parking tickets or traffic violation fees
Personal automobile repairs

M4702A