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.
4087136_2
|
