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HomeMy WebLinkAbout2023-02-07; City Council; ; Revise City Council Policy No 2 - Travel PolicyCA Review GH Meeting Date: Feb. 7, 2023 To: Mayor and City Council From: Scott Chadwick, City Manager Staff Contact: Zach Korach, Finance Director zach.korach@carlsbadca.gov or 442-339-2127 Subject: Revise City Council Policy No 2 - Travel Policy Districts: All Recommended Action Adopt a resolution approving revisions to City Council Policy No. 2 - Travel Policy. Executive Summary The city’s Travel Policy was last updated in June 2017. The City Council is being asked to approve a revised Travel Policy to meet current needs and conditions that have changed over the last five years. Explanation & Analysis It is often necessary for city personnel to attend meetings, travel outside the city to conduct city business, and attend conferences, seminars or training sessions. The City Council adopted Council Policy No. 2 - Travel Policy to control the costs involved related to travel and to compensate elected officials, commissioners, City Council appointed employees, city employees and volunteers for the actual and necessary expenses related to city business travel. Periodic review of the Travel Policy is prudent to ensure the policy is still meeting the needs of the city, those that travel on its behalf and the current regulatory and social environment. The new Travel Policy: • Allows for more efficient recording of employee travel expenses • Establishes standard limits for lodging, meals and incidental costs as set by the United States General Services Administration. The reduced requirements for tracking individual meal and incidental costs will earn time savings in both the employee’s department and in Finance. The defined per diem for daily travel may, in some cases, exceed actual meal and incidental expenses, although it is offset by other expenses potentially incurred when an employee is asked to travel on city business. Feb. 7, 2023 Item #3 Page 1 of 16 Fiscal Analysis While there will be a fiscal impact associated with some of the proposed Travel Policy revisions, the fiscal impact cannot be accurately quantified at this time. Staff believe that the changes are immaterial and are offset by increases in efficiencies. As a result, departments should be able to manage any possible increases within existing budgets. Next Steps If approved by the City Council, the proposed revisions to the Travel Policy and the associated Travel Guidelines and Procedures, both of which would take effect March 1, 2023. Environmental Evaluation This action does not require environmental review because it does not constitute a project within the meaning of the California Environmental Quality Act under California Public Resources Code Section 21065 in that it has no potential to cause either a direct physical change or a reasonably foreseeable indirect physical change in the environment. Exhibits 1. City Council resolution 2. Council Policy No. 2 with revisions shown 3. City Manager Designee Memorandum 4. City Manager Designee Memorandum with revisions shown Feb. 7, 2023 Item #3 Page 2 of 16 RESOLUTION NO. 2023-042 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF CARLSBAD, CALIFORNIA, APPROVING REVISIONS TO CITY COUNCIL POLICY NO. 2 - TRAVEL POLICY WHEREAS, on August 18, 1970, as amended from time to time, the City Council adopted Council Policy No. 2 that established the city's Travel Policy; and WHEREAS, it is the policy of the City Council to ensure that all costs incurred by the city are in the best interest of the public and an appropriate use of taxpayer funds, and to compensate elected officials, commissioners, City Council appointed employees, city employees and volunteers for their actual and necessary expenses for city-related travel; and WHEREAS, staff proposes revisions to the Travel Policy in order to, among other things, increase operational efficiencies, appropriately compensate for city-related travel expenses, and promote the ethical and transparent use of taxpayer funds. NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Carlsbad, California, as follows: 1.That the above recitations are true and correct. 2.That City Council Policy No. 2 -Travel Policy is amended to read as set forth in Attachment A. 3.That the maintenance of the Travel Guidelines and Procedures that help implement C_ity Council Policy No. 2, will be the responsibility of the City Manager or designee. Exhibit 1 Feb. 7, 2023 Item #3 Page 3 of 16 PASSED, APPROVED AND ADOPTED at a Regular Meeting of the City Council of the City of Carlsbad on the 7th day of February, 2023, by the following vote, to wit: AYES: NAYS: ABSTAIN: ABSENT: Blackburn, Bhat-Patel, Acosta, Burkholder. None. None. None. KEITH BLACKBURN, Mayor �SHERRY FREISINGER, City Clerk (SEAL) Feb. 7, 2023 Item #3 Page 4 of 16 City Council POLICY STATEMENT Subject: Travel Policy Purpose Policy No. Date Issued 2 2/7/2023 Resolution No. 2023-042 To establish a policy to be followed by all elected officials, commissioners, City Council appointed employees, city employees and volunteers when traveling on city business. This policy supersedes all other travel policies. Background It is periodically necessary for city personnel to attend meetings, travel outside the city to conduct city business, and attend conferences, seminars and training sessions. Costs can vary considerably as there are various modes of transportation, various options for lodging, and relative price fluctuations among different geographic regions. The City Council has adopted a policy to control the costs involved, to ensure the expenditures are in the best interest of the public and an appropriate use of taxpayer funds, and to compensate individuals for actual necessary expenses related to meetings and business travel. Statement of policy 1.In all cases, requests for travel shall be limited to situations from which the city will derive a benefit though the attendance of a representative. 2.For all elected officials, all travel involving more than 5 days should be approved in advance by the City Council. Travel of 5 days or less need not have prior approval if funds are available in the current budget. The Mayor is authorized to approve extended overnight travel for emergency cases. 3.Except for elected officials, commissioners and City Council appointed employees, the number of city employees or volunteers attending any single conference should be limited to those whose attendance will provide a benefit to the city. Any number of elected officials, commissioners, or City Council appointed employees may attend conferences, provided that funds are available for such purposes. 4.Travel should be approved by the operating budget. The City Manager, or designee, may approve any travel to destinations within the continental United States if a business need exists and funds are available. City Council approval is required for travel to destinations outside the continental United States and/or when additional budget appropriations are required. 5.Elected officials, commissioners, City Council appointed employees, city employees and volunteers of the city are expected to be as reasonable as possible when traveling at the city's expense. To ensure stewardship of taxpayer funds and that elected officials, commissioners, City Council appointed employees, city employees and volunteers are Attachment A Feb. 7, 2023 Item #3 Page 5 of 16 City Council Policy Statement 2/7/2023 Page 2 able to travel when necessary to accomplish essential city business, travel funds must be expended in the most economical and efficient way possible. 6.In order to comply with Internal Revenue Service (IRS) and state regulations, the city will reimburse lodging and meals based on GSA.gov rates, relevant to the location of travel where applicable. Designated conference lodging for attendees may exceed GSA rates and these exceptions may be reimbursable to the traveler. 7.Per diem rates will apply based on GSA.gov rates for all meals and incidental expenses (M&IE). M&IE includes taxes and tips for meals and the Federal Travel Regulation Chapter 300, Part 300-3, under Per Diem Allowance, describes incidental expenses as: Fees and tips given to porters, baggage carriers, hotel staff, and staff on ships. Receipts and documentation are required in the following instances where per diem reimbursement is not permitted: a.M&IE incurred by any elected official b.M&IE reimbursement requests from commissioners, City Council appointed employees, employees or volunteers below the per diem allowance c.All or partial M&IE incurred on a city credit card that fall into the per diem calculation d.M&IE incurred and reimbursement is being requested beyond the per diem rates Receipts will be required to include the following details: i.The amount of the expenditure. ii.The date and place of the expenditure. iii.The business purpose of the expenditure. iv.The business relationship to the person entertained, as well as the individuals' names. 8.Travel Advances will not be provided without City Manager or designee approval. 9.Administration and interpretation of this policy will be as directed from time to time by the City Manager or designee. The policy should be reviewed every five years for effectiveness. Procedure Transportation 1.Use of air, train, private automobile, or other mode of public transportation shall be selected on the basis of the most reasonable total cost to the city after all expense items are tabulated, including travel time salary costs. 2.When the use of a private vehicle-is approved, mileage reimbursement shall be at the rate then currently prescribed by IRS regulations. Individuals with an auto allowance will not receive mileage reimbursements. However, use of city-owned vehicles is allowed. Feb. 7, 2023 Item #3 Page 6 of 16 City Council Policy Statement 2/7/2023 Page 3 •If use of a private vehicle is approved, reimbursement shall not exceed the cost of a round trip coach or equivalent class air fare plus ground transportation between the airport and place of lodging. Exceptions, including use of a city-owned vehicle, are subject to approval by the City Manager or designee (such as in cases where items required to be transported are not allowed on any other mode of public transportation). Such reimbursement, if applicable, shall be computed based on the mileage from the normal work location to the final destination. •For the purpose of determining personal vehicle mileage reimbursement, the designated normal work location for elected officials, commissioners, City Council appointed employees, city employees and volunteers is the place where that individual spends the largest portion of their regular workday or working time, or the place to which they return upon completion of regular or special assignments. The cost of the daily commute to the office is the elected official's, commissioner's, City Council appointed employee's, city employee's and volunteer's responsibility. 3.When the use of public air carrier is approved, the city shall pay the lowest available fare at the time the reservation is booked. Upgrades to a higher class of air service will be at the employee's expense. The City Manager, or designee, may authorize exceptions when a higher fare results in a lower overall cost to the city such as a fare that includes cancelation insurance. Business related air carrier Wi-Fi charges will be reimbursed up to $10 per flight. 4.Authorized travel time shall be based on that required by the most appropriate and expedient mode of public transportation. The additional travel time from anything less than the most appropriate and expedient mode will not be considered city work hours. 5.While traveling, elected officials, commissioners, City Council appointed employees, city employees and volunteers are encouraged to use public transportation whenever possible. For example, courtesy shuttle service, buses, taxis, or limousine service should be utilized between airports and meeting locations when such services are reasonably available. Rental vehicles should only be used when other transportation is unavailable, untimely, or a rental vehicle is the most economical mode of transportation. In no case shall valet services for parking be reimbursed. 6.Reimbursement for travel time will be made in accordance with Fair Labor Standards Act (FLSA) guidelines. Lodging Feb. 7, 2023 Item #3 Page 7 of 16 City Council Policy Statement 2/7/2023 Page 4 1.Lodging shall be obtained at the ITIOSt reasonable rate available for good quality lodging. Lodging expense limits will be based on current GSA rates for the location in which the travel occurs. Although, when there is an officially designated conference hotel, the traveler is encouraged to take advantage of these accommodations even if this _rate exceeds GSA rates for the area. Lodging expenses for spouses or other non­ agency individuals are not reimbursable, and any additional expenses beyond those required for the business traveler must be personally paid by the elected officials, commissioners, City Council appointed employees, city employees and volunteers. Lodging expense limits will be based on current GSA rates for the location in which the travel occurs other than conference hotel. 2.Business related Wi-Fi charges which are added to the lodging bill will be reimbursed up to $10 per day. Reimbursement of Wi-Fi charges in excess of this limit may be authorized by the City Manager or designee, under special circumstances. Meals and Incidental Expenses 1.Notwithstanding other limits stated elsewhere, the elected officials will be reimbursed the actual costs of meals, plus tips and incidental expenses that are substantiated with a physical receipt while on official city business. 2.Each commissioner, City Council appointed employee, city employee or volunteer authorized to travel may be reimbursed for meals based on the per diem rates established by the GSA for the location in which the travel occurs. If it is anticipated that this limit will be exceeded, then prior approval by the City Manager or designee is required. The City Manager or designee may approve such additional expenditures, within the limits of expenditure authority, as necessary. 3.The city will not reimburse the cost of alcoholic beverages and may not be included in the per diem reimbursement. 4.Reasonable amounts for tipping up to 20% will be reimbursed; however, excessive tipping may not be included in the per diem reimbursement. Feb. 7, 2023 Item #3 Page 8 of 16 Page 1 of 5 Exhibit 2 Council Policy Statement Category: Specific Subject: TRAVEL POLICY PURPOSE: To establish a policy to be followed by Council Members, other all elected officials, commissioners/board members,volunteers, and all City Council appointed employees, city employees and volunteers when traveling on city business. This policy supersedes all other travel policies. BACKGROUND: It is periodically necessary for city personnel to attend meetings, travel outside the city to conduct city business, and attend conferences, seminars and training sessions. Costs can vary considerably as there are various modes of transportation, various options for lodging, and relative price fluctuations among different geographic regions. The City Council has adopted a policy to control the costs involved, to ensure the expenditures are in the best interest of the public and an appropriate use of taxpayer funds, and to compensate individuals for actual necessary expenses related to meetings and business travel. DEFINITIONS: City Business Travel shall be defined as travel which requires elected officials, members of a commissioners or board, volunteers, or city employees or volunteers to conduct specific items of city business away from their normal place of business. City Employee means any person regularly employed by the city, excluding elected officials, members of commissioners,committees, authorities or boards and volunteers. Commissioner shall mean any person appointed by the city council to an established board, committee, authority or commission. Elected Official shall mean any person elected into office at the city Appointed Employee shall mean any person appointed by the City Council, this includes the City Manager and City Attorney. Volunteer shall mean any person donating their time through the city’s volunteer program in support of city business and as outlined in a volunteer position description. Out-of-State Travel includes all costs related to business travel outside the State of California. Policy No. 2 Date Issued: 6/27/172/7/23 Effective Date: 6/27/173/1/23 Resolution No. Cancellation Date: Supersedes No. 4 5 (dated 4/4/066/27/17) Exhibit 2 Feb. 7, 2023 Item #3 Page 9 of 16 {city of Carlsbad Policy No. 2 Page 2 of 5 In-State Travel includes all costs related to business travel within the State of California. Miscellaneous Meals/Mileage includes all miscellaneous costs not directly attributable to conferences or training, such as travel to other city facilities. GSA Rates refers to the published U.S. General Services Administration (GSA) annual rates. The GSA establishes the per diem reimbursement rates that federal agencies use to reimburse their employees for subsistence expenses incurred while on official travel within the continental United States. This includes rates for both lodging and meals. Per Diem is an established daily rate of reimbursement for meals, where no detailed receipts are required. Elected officials are not eligible for the per diem calculation and receipts will remain a requirement for all travel expenses reimbursed. POLICY: 1. In all cases, requests for travel shall be limited to situations from which the city will derive a benefit through the attendance of a representative. 2. For City Council Membersall elected officials, all travel involving more than five (5) days should be approved in advance by the City Council. Travel of five (5) days or less need not have prior approval if funds are available in the current budget. The Mayor is authorized to approve extended overnight travel for emergency cases. 3. Except for elected officials, , commissionersand board members and City Council appointed employees, the number of City Employees attending any single conference should be limited to those whose attendance will provide a benefit to the city. Any number of elected officials, commissioners, or City Council appointed employees may attend conferences provided that funds are available for such purposes. 4. Anticipated in-state and out-of-state tTravel should be approved in the operating budget. The City Manager, or his/hertheir designee, may approve any unanticipated in-state travel or unanticipated out-of-state travel to destinations within the continental United States if a business need exists and funds are available, . City Council approval is required for unanticipated travel to destinations outside the continental United States and/or when additional fundsbudget appropriations are required. 5. Each elected official, officer, employee, advisory commissioner, City Council appointed employee, and board memberemployee, and volunteer of the city is expected to be as thrifty and prudent reasonable as possible when traveling at the city’s expense. To ensure stewardship of taxpayer funds and that city officerselected officials, commissioners, City Council appointed employees, employees, commissioners and board membersand volunteers are able to travel when necessary to accomplish essential city business, travel funds must be expended in the most economical and efficient way possible. 6. In order to comply with Internal Revenue Service (IRS) and State regulations, the city will reimburse lodging and meals based on GSA.gov rates, relevant to the location of travel. receipts are Formatted: Underline Formatted: Underline Formatted: Font: (Default) +Body (Calibri), 11 pt Formatted: Normal, No bullets or numbering Feb. 7, 2023 Item #3 Page 10 of 16 Policy No. 2 Page 3 of 5 required for all business travel expenses, including all meal and entertainment expenses, for City Council Members and Commissioners. Receipts are also required for all City Employee business travel expenses. In the event a meal or incidental receipt totaling thirty dollars ($30) or less is lost, a City Employee may certify the expense with the information below to receive reimbursement. This certification may occur no more than one time over a two day period, two times over a four day period, or three times over a five day period. For all business travel expenses (including meals and entertainment), the following information must appear on the expense report and/or the receipts submitted: Designated conference lodging for attendees may exceed GSA rates and may be reimbursable. For all elected officials and employee requests a for any other reimbursement request is submitted below the per diem allowance, receipts will be required to includewith the following requirements: a. The amount of the expenditure. b. The date and place of the expenditure. c. The business purpose of the expenditure. d. The business relationship to the person entertained, as well as the individuals’ names. The IRS considers the reimbursements “wages” subject to payroll tax withholding if the expenditures are not substantiated with the aforementioned information. The use of a city credit card for payment of business meals and entertainment does not preclude the requirement to complete and submit an expense report with the appropriate support. 7.6. Travel advances to City Employees need to be substantiated or reimbursed as soon as possible upon completion of trip (normally within 30 days). No further city funds will be advanced for travel until the employee files his/her outstanding expense reportwill not be provided without City Manager or his/hertheir designee approval. 8.7. Administration and interpretation of this policy will be as directed from time to time by the City Manager or his/hertheir designee. The policy should be reviewed every five years for effectiveness. TRANSPORTATION: 1. Use of air, train, private automobile, or other mode of public transportation shall be selected on the basis of the least most reasonable total cost to the city after all expense items are tabulated, including travel time salary costs. 2. When the use of a private vehicle to destinations within 200 driving miles of the city limits is approved, mileage reimbursement shall be at the rate then currently prescribed by IRS regulations. Individuals with an auto allowance will not receive mileage reimbursements. However, use of city-owned vehicles is allowed.for travel within 200 driving miles of the city limits If use of a private vehicle to destinations beyond 200 driving miles is approved, by the City Manager or his/hertheir designee reimbursement shall not exceed the cost of a round trip coach or equivalent class air fare plus ground transportation between the airport and place of lodging. Exceptions, including use of a city-owned vehicle, are subject to approval by the City Feb. 7, 2023 Item #3 Page 11 of 16 Policy No. 2 Page 4 of 5 Manager or his/hertheir designee (such as in cases where items required to be transported are not allowed on any other mode of public transportation). Such reimbursement, if applicable, shall be computed based on the mileage from the normal work location to the final destination. For the purpose of determining personal vehicle mileage reimbursement, the designated normal work location for each cCity Council Memberelected official, Cocommissioner, Ccity Eemployee or Volunteer is the place where that individual spends the largest portion of his/hertheir regular workday or working time, or the place to which theirhe/she returns upon completion of regular or special assignments. The cost of the daily commute to the office is the City Council Memberelected official’s, cCommissioner’s, cCity eEmployee’s or vVolunteer’s responsibility. 3. When the use of public air carrier is approved, the city shall pay the lowest available fare at the time the reservation is booked. Upgrades to a higher class of air service will be at the employee’s expense. The City Manager, or his/hertheir designee, may authorize exceptions when a higher fare results in a lower overall cost to the city such as a fare that includes cancelation insurance. Business related air carrier Wi-Fi charges will be reimbursed up to $10 per flight. 4. Authorized travel time shall be based on that required by the most appropriate and expedient mode of public transportation. The additional travel time from anything less than the most appropriate and expedient mode will not be considered city work hours. 5. While traveling, City Council Memberselected officials, Ccommissioners, City Council appointed employees, and Ccity Eemployees and volunteers are encouraged to use public transportation whenever possible. For example, courtesy shuttle service, buses, taxis, or limousine service should be utilized between airports and meeting locations when such services are reasonably available. Rental vehicles should only be used when other transportation is unavailable, untimely, or a rental vehicle is the most economical mode of transportation. In no case shall valet services for parking be reimbursed. 6. Reimbursement for travel time will be made in accordance with Fair Labor Standards Act (FLSA) guidelines. LODGING: 1. Lodging shall be obtained at the most economical reasonable rate available for good quality lodging. When there is an officially designated conference hotel, the traveler is encouraged to take advantage of these accommodations. Lodging expenses for spouses or other non-agency individuals are not reimbursable, and any additional expenses beyond those required for the business traveler must be paid by the elected official, Commissioner, or City Employee, or Volunteer. Lodging expense limits will be based on current GSA rates for the location in which the travel occurs other than conference hotel. 2. Business related Wi-Fi charges which are added to the lodging bill will be reimbursed up to $10 per day. Reimbursement of Wi-Fi charges in excess of this limit may be authorized by the City Manager or his/hertheir designee, under special circumstances. MEALS AND INCIDENTAL EXPENSES: Feb. 7, 2023 Item #3 Page 12 of 16 ----__ - ---___ - Policy No. 2 Page 5 of 5 1. Notwithstanding other limits stated elsewhere, the City Councilelected officials will be reimbursed the actual costs of meals, plus tips and incidental expenses that are substantiated with a physical receipt while on official city business. 2. Each Commissioner, or City Employee or Volunteer authorized to travel may submit the actual cost of meals, tips and incidental expenses for reimbursement up to a limit of $70 per day.be reimbursed for meals based on the per diem rates established by the GSA for the location in which the travel occurs. If it is anticipated that this limit will be exceeded, then prior approval by the City Manager or his/hertheir designee is required. The City Manager or his/hertheir designee may approve such additional expenditures, within the limits of his/hertheir expenditure authority, as necessary. 3. The city will not reimburse the cost of alcoholic beverages. 4. Reasonable amounts for tipping will be reimbursed, however, reimbursement for tips will not be made in excess of 20%. Feb. 7, 2023 Item #3 Page 13 of 16 City Manager’s Office City Hall 1200 Carlsbad Drive ï Carlsbad, CA 92008 442-339-2821 t Memorandum March 1, 2023 To: Department Heads From: Scott Chadwick, City Manager Via: Laura Rocha, Deputy City Manager – Administrative Services Re: City Manager Designee for Travel Policy Exceptions Pursuant to Council Policy No. 2 (“Travel Policy) the City Manager or designee has been given authority over various items. As City Manager I am delegating my authority under the Travel Policy as follows, effective immediately: • Department heads will be responsible for authorizing necessary business travel within the continental United States when funds are available; • The Finance Director will be responsible for authorizing any requested Travel Advance; • The Finance Department will be responsible for administration and interpretation of the Travel Policy; • Department heads will be responsible for determining the use of city vehicles for travel; • Department heads will be responsible for determining exceptions to using the lowest available air fares; • Department heads will be responsible for determining exceptions to daily WiFi reimbursement; and • Department heads may approve additional expenditures for meals and incidentals within expenditure authority; When department heads make exceptions under the authority provided herein, the Finance Department must be provided written confirmation of the exception from the appropriate department head in order for the traveler(s) to receive reimbursement. If you have any questions, please contact Laura Rocha, Deputy City Manager – Administrative Services or Zach Korach, Finance Director. cc: Zach Korach, Finance Director Exhibit 3 Feb. 7, 2023 Item #3 Page 14 of 16 {city of Carlsbad Finance DepartmentCity Manager’s Office 1635 1200 Faraday Carlsbad Village AveDr. ï Carlsbad, CA 92008 ï 760-602434-24302820 ï 760-602720-8553 9461 fax Memorandum May 2, 2017JanuaryMarch 1, 2023 To: Department Heads From: Kevin CrawfordScott Chadwick, City Manager Via: Charles McBrideLaura Rocha, Deputy City Manager - Administrative Services Director Re: City Manager Designee for Travel Policy ApprovalsExceptions Pursuant to Council Policy No. 2 (“Travel Policy) the City Manager or his/her designee has been given authority over various items. As City Manager I am delegating my authority under the Travel Policy as follows, effective immediately: • Department heads will be responsible for authorizing unanticipated in-state and out-of- state travel; • Department heads will be responsible for authorizing the use of a private automobile to destinations beyond 200 driving miles from the city; • Department heads will be responsible for determining exceptions to using the lowest available air fares; • Department heads will be responsible for determining the use of city vehicles for travel; • Department heads will be responsible for determining exceptions to daily Wi-Fi reimbursement rates; and • The Finance Department will be responsible for determining exceptions to the daily meals, tips, and incidental expense reimbursement of $70; and • The Finance Director will be responsible for authorizing any requested Travel Advance; and • The Finance Department will be responsible for administration and interpretation of the Travel Policy. When department heads make exceptions under the authority provided herein, the Finance Department must be provided written confirmation of the exception from the appropriate department head in order for the traveler(s) to receive reimbursement. If you have any questions, please contact Charles McBride Laura Rocha, Deputy City Manager – Administrative Services. at 760-602-2415 or charles.mcbride@carlsbadca.gov. Sincerely, Formatted: Line spacing: Multiple 1.08 li Exhibit 4 Feb. 7, 2023 Item #3 Page 15 of 16 I~ - - --\l!fl ----- -- - {'city of Carlsbad Accounts Payable Batch Preparers June 2, 2016 Page 2 KEVIN CRAWFORDSCOTT CHADWICK CITY MANAGER Formatted: Line spacing: Multiple 1.08 li Feb. 7, 2023 Item #3 Page 16 of 16