Banner County Bank

and

Banner County Ban Corporation

Harrisburg, NE

 

Limitation on Luxury Expenditures Policy

 

June 21, 2009

 

Section 111 of the Emergency Economic Stabilization Act of 2008 (12 U.S.C. 5221) requires that recipients of TARP investments develop a written policy placing certain limitations on what certain individuals or government agencies may deem to be luxury expenditures.  This policy is not intended in any way to limit or restrict the normal and customary expenditures for business development, employee moral or training or the ongoing operation of the bank or the company.

 

Sponsorship of excessive entertainment or events is prohibited.  This includes both foreign and domestic junkets that do not serve a demonstrated business purpose.  Excessive entertainment or an excessive event is quantitatively defined as any single occurrence or event where the per capita expenditure exceeds $2,000.   Business development and/or training trips are allowable and are not prohibited by this restriction.

 

Office and facility renovations should be designed to: enhance operational efficiency, comply with applicable fire codes and ADA requirements, maintain a safe, sanitary and clean working environment, enhance the public image of the organization, improve employee morale, or such other worthwhile purpose as may be identified by the organization. 

 

Excessive aviation or other transportation services expenditures are prohibited.  The organization(s) will not expend funds for travel other than in the normal course of business for training and or business development.   Travel expense reimbursement for travel expenses of employees, directors, and representatives and agents of the organization(s) for travel approved by the boards of the respective organization(s) shall not be deem excessive aviation or other transportation under this policy.

 

Expenses for activities or events should enhance staff development, provide reasonable performance incentives for employees, or otherwise be conducted in the normal course of the operation of the business.  Expenditures of this type may be made in the sole discretion or the chief executive officer and are not considered excessive. 

 

This policy shall govern all officers and staff of Banner County Bank and Banner County Ban Corporation.  Violation of the ploicy shall result in appropriate reprimand commensurate with the severity of the violation.  Repeat violations may result in actions including restitution, probation, or possible termination.