EXPENSE REIMBURSEMENT POLICY / EXCESSIVE OR LUXURY EXPENSE POLICY EFFECTIVE DECEMBER 17, 2010
Serving our customers and developing new business objectives are some of the key activities in the attainment of our corporate objectives. This Employee Expense Reimbursement Policy is designed to properly reimburse employees for all appropriate expenses incurred in working toward these objectives. In addition, the Policy addresses approval, reporting, and record keeping required to conform to regulations and to effectively control costs.
SpiritBank employees should use judgment and consider spending SpiritBank dollars as if they are spending their own. Lavish expenditures waste the company’s resources and often reflect unfavorably on SpiritBank in the eyes of customers and others. To the extent possible, employees are expected to minimize reimbursable expenses.
This Policy provides employees with a statement of SpiritBank’s policies and procedures related to the expenditure and accounting for company funds used for conducting business. All employees, including managers approving expense reports, are expected to become acquainted with, and live within, the spirit of this policy. SpiritBank will reimburse employees for actual, reasonable, and proper expenditures incurred while conducting company business.
The purpose of this Policy is to provide uniform guidelines for all employees’ reimbursable expenses. Additionally, the Policy provides general guidelines and is not intended to cover every circumstance. In many instances, it is left to the good judgment of the employees incurring the expense to determine the appropriateness of the expenditure.
This Employee Expense Reimbursement Policy applies to all employees of SpiritBank.
4. ORGANIZATIONAL RESPONSIBILITIES and POLICY EXCEPTIONS
Officers, department heads, supervisors, or others designated by management as expense account approvers, are responsible for the approval of expense reports and other required records submitted by employees, including the determination that activities for which the expenses were incurred are permissible expenditures as defined in this Policy.
Any exceptions to this Policy must have the approval of an Executive Council member. Unapproved exceptions to this Policy will not be reimbursed.
5. MONITORING POLICY
SpiritBank relies on employees to follow this policy. The employee’s supervisor is responsible for monitoring compliance. By signing an employee’s expense form, the supervisor certifies that the employee is in full compliance with this policy. Adherence to this policy will be monitored periodically by Management.
6. COST EFFECTIVENESS
Reimbursable business expense represents a significant cost of doing business for SpiritBank and it is the responsibility of each employee to incur these expenses in the most cost effective manner consistent with the accomplishment of the business mission. However, no employee is expected to compromise their, or others’, safety for the sake of cost reduction.
7. EMPLOYEE EXPENSE REIMBURSEMENT FORM REQUIREMENTS
Proper documentation for employee expense reimbursement is accomplished by completing the attached electronic expense reimbursement form, submitting all receipts and obtaining proper approval.
When possible, all small receipts should be affixed to an 8 ½ x 11 sheet of paper to facilitate review and prevent loss of receipt.
Expense Reimbursement Forms must be signed by the employee and their supervisor.
Employee reimbursable expenses exceeding $1,000 and all reimbursable business related expenses must be approved by the CEO or CFO.
Employees must adhere to the following requirements for property completion of the electronic expense reimbursement form and the mileage reimbursement form:
The expense reimbursement form and the mileage reimbursement form must be completed electronically allowing the formulas to calculate automatically.
All business development expenses must be listed individually, with itemized receipts and be accompanied by the customer name, the business purpose for the expense and any other information that management deems necessary. This information must be entered into the Business Development Detail form included in the attached electronic employee reimbursement form.
Reimbursable mileage expenses must be accompanied by a completed mileage reimbursement form. The mileage reimbursement form is included in the employee reimbursement form file. The form must be completed electronically and be itemized.
Mileage to non-bank locations must be accompanied by supporting documentation such as a Mapquest printout in order to substantiate the miles claimed.
If the employee uses a bank purchased automobile, fuel receipts will be required for reimbursement.
8. CREDIT CARDS
Generic cards carried in SpiritBank’s name are prohibited.
Individual credit cards carried in SpiritBank’s name will be limited to those held by Senior Management as of December 31, 2009.
Employees using credit cards carried in SpiritBank’s name or using personal credit cards for business related expenses must submit an employee reimbursement form and include itemized receipts. Credit card statements are not acceptable as receipts.
9. APPLICABLE TO ALL EMPLOYEES
This policy shall be applicable to all employees of SpiritBank, any subsidiary of SpiritBank as well as the parent company of Spirit BankCorp, Inc. (the “Employee Base”). The Employee Base shall be held accountable for compliance with this policy.
10. REPORTING VIOLATIONS
Any employee shall be responsible for reporting violations of this policy by reporting directly to the Director of Human Resources.
11. A. EXCESSIVE OR LUXURY EXPENSES
Unless otherwise approved by the CEO or CFO the Bank and all officers and employees shall refrain from making “excessive or luxury” expenditures on:
· Entertainment or events;
· Office and facility renovations;
· Aviation or other transportation services;
· Other activities or events that are not reasonable expenditures for staff development, reasonable performance incentives, or other similar measures conducted in the normal course of the business operations of the Bank (or its parent company).
B. STANDARDS FOR EXCESSIVE OR LUXURY EXPENSES
The standards for determining excessive or luxury expenditures are as follows:
(i) Prohibited Expenditures –
· Entertainment or events. Entertainment or events expenditures in excess of $1,000 and made solely for the benefit of an officer or employee and unconnected to a business purpose of the Bank shall be prohibited; provided however, employee events at the branches or bank-wide functions at a separate location shall not be prohibited if the expenditures are reasonable.
Additionally, with respect to entertainment venues where the Bank maintains a suite, box seats, etc., the use of these shall be predominantly for entertaining customers or prospective customers. The CEO, CFO or their designees shall monitor and control the officers’ and employees’ usage consistent with this paragraph.
· Office and facility renovations. Office and facility renovations solely for the benefit of an officer or employee and unrelated to an overall plan for office and facilities renovation on a comprehensive basis (for a branch or other location) shall be prohibited.
· Aviation or other transportation. It shall be the policy of the Bank that no corporate planes shall be owned and operated by the Bank for use by the officers or employees. Reasonable expenditures for commercial travel by plane, car or otherwise shall not be prohibited.
· Other similar items. Other similar items solely for the benefit of an officer or employee and unconnected to a business purpose of the Bank shall be prohibited.
(ii) Prior Approval. All excessive or luxury expenses in excess of $1,000 shall require the prior approval of the CEO or CFO of the Bank.
(iii) Procedure. Any officer or employee that proposes to expend monies for an excessive or luxury expense in excess of $1,000 shall submit such request to the CEO or CFO in writing (memo, email, etc.) for approval.
(iv) CEO and CFO Certification. At least annually the CEO and the CFO shall certify that all prior approvals for excessive or luxury expenses were obtained.
(v) Prompt Internal Reporting. Any officer or employee knowing of a violation of this policy provision on excessive or luxury expenses shall promptly report the alleged violation to the CEO, CFO or the Board of Directors of the Bank.
(vi) Adherence. All officers and employees shall be accountable for and adhere to the provisions of this policy provision.