BRIDGEVIEW BANCORP, INC.
Excessive and Luxury Expenditure Policy
This policy fulfills the requirements under the American Recovery and Reinvestment Act of 2009 (ARRA) enacted February 17, 2009. ARRA requires each recipient of funds under the Capital Purchase Program (CPP) of the Troubled Assets Relief Program (TARP) to have in place a company-wide policy regarding excessive or luxury expenditures, as identified by the Secretary of the Department of the U.S. Treasury.
Bridgeview Bancorp, Inc., including Bridgeview Bank Group (collectively, the “Company”), prohibits excessive or luxury expenditures on entertainment and events, office or facility renovations, aviation or other transportation services and certain other activities or events. Excessive or luxury expenditures are determined when judged in light of costs and benefits to the Company. In order to prevent excessive or luxury expenditures, the Company adopts this Policy.
Renovations of facilities and office spaces should be in line with the approved project and current profit plan, and tracked within the capital expenditure policy of the Company. An exception to this can be allowed if management must deal with an emergency situation, such as an act of nature, and the expenditure is necessary to make the facility operational for customer use (an “Emergency Renovation”). Unless previously approved through the budget approval process, any Company expenditure or reimbursement for renovations of facilities and office spaces (other than an Emergency Renovation) with a cost of over $50,000 must be approved in advance by either the Chairman or the CEO. In the case of a request by either the Chairman or the CEO, the request must be approved by the Board of Directors.
Entertainment is defined as an activity whereby an employee, officer or director uses corporate funds for business development purposes relating to a current customer or prospective customer, or to further enhance the Company’s marketing efforts.
All expenses charged to the Company as entertainment expenses must be for company purposes, and for the purpose of driving business to the Company. Occasional events such as taking customers or prospects on trips, playing golf, eating dinner, or taking them to other events the customer/prospect would find pleasurable is a necessary part of the Company’s marketing efforts and are not deemed as “luxury” or subject to this Policy. These expenses are subject to the policies and procedures set forth in the Employee Handbook.
Notwithstanding the foregoing, any reimbursement for expenditures for entertainment in excess of $10,000 for a single event that was not previously approved through the budget approval process is deemed subject to this Policy and must be approved in advance by either the Chairman or the CEO. In the case of a request by either the Chairman or the CEO, the request must be approved by the Board of Directors.
We encourage our staff to attend conferences that are appropriate educational opportunities. These conferences should be related to the financial services industry and have a direct correlation to the job of the employee. At times it may be appropriate that a spouse would travel to these conferences with Company attendees. In the event that a spouse of a Company attendee travels such conferences, the Company will only cover such spouse’s travel expenses if the request is approved in advance by the Chairman or the CEO. In the case of a request by either the Chairman or the CEO, the request must be approved by the Board of Directors.
Employee Recognition/Holiday Parties:
We feel that employee recognition/holiday parties are part of an employee appreciation process. These events should be local in geographic nature, and would include costs for such things as service awards and nominal door prizes. An event should not cost the sponsoring business unit more than an average day’s payroll per employee.
Retreats should only be used for educational or business planning purposes, and should be kept in consideration and looked at, in the same view and discretion as all other expenses. Board education is a vital part of maintaining, and keeping a dynamic director base, and this policy should not limit a retreat that is focused on strategic planning or education.
Transportation for Company staff to outlying locations, including bank locations, conferences, business development purposes and merger and acquisition research, should be conducted in the most cost appropriate way for the Company. Modes of transportation to be used may consist of vehicle, commercial or private air service, or rail service. The selection of transportation services will factor in cost, efficiency and timeliness of travel. Any reimbursement for the use of private air service must be approved in advance by the Chairman or CEO. In the case of the Chairman or the CEO, the request must be approved by the Board of Directors.
All employees of the Company are subject to this policy and will be held accountable for any violations. Similar to the procedures set forth in the Employee Handbook, should a manager or an employee suspect that a violation of this policy has occurred, he/she must promptly report such observations to his or her supervisor or superior. If the individuals to whom such information is conveyed are not responsive, or if there is reason to believe that reporting to such individuals is inappropriate in particular cases, then the employee, officer or director may contact the Human Resources Department. Such suspicions will be investigated in a manner consistent with the procedures and policies set forth in the Employee Handbook under Whistle Blowing Policy / Reporting Illegal or Unethical Behavior.
The internal audit program of the Company shall adopt appropriate procedures and programs to review the Company’s compliance with this Policy. In so doing, the internal audit shall report to the audit committee of the board of directors.
Employees found to have violated this policy will be subject to disciplinary procedures as outlined in the Employee Handbook, including ultimately dismissal.
All requests for any approval required under this Policy shall be made in writing to the appropriate party, and be supported by appropriate explanation and/or documentation. For example, a request for renovation expenditures subject to this policy should contain specific information on the reasons for the renovations and detailed information on the costs, including where possible cost estimates. A request for entertainment expenditures subject to this policy shall include the names of the attendees, the organization with which the individuals are associated, the nature of the entertainment and a description of the benefits to the Company that are anticipated. Any request for spouse travel shall offer an explanation as to how the accompaniment of the spouse will benefit the Company. Any request for the use of private aircraft shall detail the benefit to the Company. A copy of any approval shall be maintained with other documentation evidencing the Company’s compliance with TARP restrictions and policies.