Excessive and Luxury Expenditure Policy
This policy is adopted by the First State Bank Central Texas (the "Company") and is intended to be in compliance with a policy on expenditures under an Interim Final Rule issued by the Department of the Treasury (Federal Register, Vol. 74, Number 113, June 15, 2009), 31, CFR Part 30. This filing is based on the Company's parent, Central Community Corporation ("CCC") closing a sale on February 22, 2009, of $22 million in TARP funds under the government's capital purchase program.
First State Bank Central Texas (Company) and its subsidiaries, First Central Texas Insurance, and First Community Title Company, prohibit excessive or luxury expenditures on entertainment and events, office or facility renovations, aviation or other transportation services or other activities or events that are not reasonable expenditures for conferences, staff development, reasonable performance incentives or other similar measure conducted in the normal course of business operations of First State Bank Central Texas.
Renovations of facilities and office spaces should be relative to 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 luanagement 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. At no time should facility improvements or renovations be done that would have the appearance of being extraordinary, or excessive from a shareholder perspective.
Entertainment is defined as an activity that an Employee or Executive would use corporate funds for business development purposes relating to a current customer or prospective customer, or to further enhance the Company's marketing efforts.
Our expectation is that all expenses incurred to the Company would be for company purposes, and used to direct 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 is not deemed as "luxury" or a violation of this Policy. These expenses should be documented and detailed as to the benefit derived by the Company in accordance with the established expense reporting and accounts payable procedures. If a guest or customer is being entertained, the individual's name, title, affiliation, place of meeting or entertainment, date, and business reason for the entertainment must be included on the expense reimbursement documentation.
We encourage our staff to attend conferences that are appropriate educational opportunities. Conferences are defined as financial related conferences, conventions, seminars, round table events, etc. These conferences should be related to the financial services industry and have a direct correlation to the employee's job. At times it may be appropriate that a spouse would travel to these conferences with Company attendees. Typically these conferences are sponsored by vendors, banking associations, or other industry related entities. Reimbursement of any spousal related expenses must be requested and approved by the Chief Executive Officer prior to the conference or event.
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 air or rail service. The selection of transportation services will factor in cost, efficiency and timeliness of travel. Private air services are not allowed without the approval of the Chief Executive Officer.
The Chief Financial Officer is responsible for the day-to-day administration of this Policy, and the Chief Executive Officer is accountable for overall adherence to this Policy and must approve any exceptions. Strict adherence to this Policy is mandated for all Company employees. Violations of this Policy shall be promptly reported to the Board of Directors.
The Chief Executive Officer and the Chief Financial Officer of the Company shall certify to the Board at least annually that the provisions of this Policy are being enforced and are sufficient to provide reasonable assurance that the Bank's expenditures for such purposes are properly approved and are not excessive.
This Policy and any amendments hereto, shall be posted on the Company's Internet website and provided to the U.S. Department of the Treasury and applicable regulatory agencies. This Policy shall be subject to modification only with the approval of the Board or Compensation Committee stating the specific business rationale for the change in policy.
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