Luxury Expenditure Policy for

The Baraboo Bancorporation, Inc.

I.  General Policy

Company funds shall be used only to fulfill corporate purposes and only to the extent reasonably necessary or appropriate to achieve those purposes.  Expenditures should be scaled in proportion to the corporate benefit expected to be achieved.  The Company prohibits excessive or luxury expenditures, defined as expenditures that are not reasonable to achieve the Company’s business objectives, on customer or employee entertainment and events, office or facility renovations, aviation or other transportation services or other activities or events.  References to the Company in this Policy include The Baraboo Bancorporation, Inc. and all of its parents, subsidiaries and affiliates, as appropriate.

II.  Effective Date of Policy 

This Policy is effective on September 9, 2009 as to covered expenditures incurred after such date. In all events, there may be other Company expense policies that will apply to an expenditure.  To the extent that prior Company policies, whether or not formalized in written form, are not inconsistent with this Policy, such policies remain in place. 

III. Categories of Expenditures Addressed by Policy

This policy addresses expenditures for:

1.    Entertainment or events

2.    Office and facility renovations

3.    Aviation or other transportation services

4.    Other Similar Expenditures

IV.  Entertainment or Events

a.  Customer-Related Expenses.  Entertainment events or activities (including golf, professional or college sporting events, theater, etc.) are only considered for reimbursement when accompanied by a customer and must be associated with the active conduct of business.  A business discussion must occur, during or after the event.  The number of Company employees attending an event or activity relative to the number of customers or prospects should be the number appropriate to accomplish the business objective.  Procedures governing the submission of corporate expense reports, if any, must be followed in all instances to qualify for reimbursement of such expenses. 

b. Employee-Related Expenses.  Occasional events (including entertainment, meals, office parties etc.) for employees are reimbursable.  This may include holiday parties and other events (such as golf outings, attendance at sporting events, etc.) for the sole purpose of employee recognition.  Procedures governing the submission of corporate expense reports, if any, must be followed in all instances to qualify for reimbursement of such expenses. 


c.  Professional Training/Seminar Costs.  Costs to attend professional training classes/seminars must be incurred to further the development of the skills and knowledge of the attending employee and are reimbursable if pre-approved by the attendee’s manager.  The cost of the professional training/seminar must be reasonable in light of the anticipated business benefit in enhancing the attending employee’s skills and knowledge.  In all instances, procedures governing the submission of corporate expense reports must be followed to qualify for reimbursement of such expenses.

V.  Office or Facility Renovations

No office or facility construction, renovation, furnishing or other similar project (a “Renovation”) may include lavish or extraordinary furnishings, decorations, or construction materials.  Employees must seek prior approval for Renovations in excess of $500, either by having the expenditure included in the applicable approved budget, or by getting specific approval from the employee’s manager.  No employee may approve a Renovation which directly and substantially affects his or her own office or that of a higher level manager to whom he or she reports.


VI.  Transportation Services

a.  Commercial Air Travel.  In general, economy and excursion airfares are to be utilized whenever possible and practical.  Business class travel is allowed if the flight will be six (6) hours or more (not including layovers).  

b.  Ground Transportation Services.  Use of other ground transportation services should be based on cost and efficiency given the business purpose, distance involved, location and number of people traveling. 

c.  Aviation Transportation Services.  The Company does not own or consistently lease any aircraft.  The Company prohibits the use of chartered aircraft without prior approval from the employee’s manager.  In all cases, chartered aircraft should only be used if the cost and time savings justify the charter in relation to the anticipated business benefit. 

VII.  Other Expenditures

Any item, activity or event for which there is no business purpose is prohibited.


VIII.  Policy Accountability and Reporting Policy Violations

The Company expects all employees to adhere to this Policy and to promptly report any violations of the Policy.  Any violation of this Policy shall be reported to the Chief Executive Officer by the violating employee, the violating employee’s manager or any other person(s) with knowledge of such violation.  If the Chief Executive Officer originated the violation, the violation shall be reported directly to the Board of Directors.  A report of a violation may be made on a confidential basis.  The Chief Executive Officer shall make a report to the Board of Directors at least monthly listing any employees who have violated this Policy.  In appropriate cases, the Board of Directors may grant waivers of the Policy.  Any non-compliance or violation of the Policy which is not waived shall be considered in the performance evaluation of the affected employee(s).

IX.  Policy Certification

The Chief Executive Officer shall provide the certification of policy compliance required by the Interim Final Rule, as now in existence or hereafter amended, no less frequently than annually to the Board of Directors.   






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