1.   For the Purposes of this Policy, “excessive or luxury expenditures” means excessive expenditures on any of the following:

a.    Entertainment or events;

b.    Office and facility renovations;

c.    Aviation or other transportation services; or

d.   All other activities or events that are not reasonable expenditures for staff development, reasonable performance incentives, or other similar measures conducted in the normal course of business operations.

e.    Prior to incurring expenses in an amount exceeding $100,000 that would fall into any of the categories described above; a written request for prior approval of such expenditure including documentation of the business purpose for the proposed expenses shall be submitted to the Board of Directors. The Board shall determine if such expenditure constitutes an “excessive or luxury expenditure.”    If it is determined to be an “excessive or luxury expenditure”, then such request shall be denied. If it is determined not to be an “excessive or luxury expenditure” then the request shall be approved.

f.     The Compliance Committee Chairperson shall keep the records of all such expenditures.

 

2.   Any violation of this policy shall be promptly reported to the Treasury and to the Board of Directors. Corrective action will be taken as appropriate.