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 U.S. Treasury.
Chambers Bancshares, Inc. (CBI) and its wholly-owned subsidiary, Chambers Bank (hereinafter collectively referred to as “the Company”) have traditionally and historically guarded its expenditures and have not undertaken excessive, or otherwise luxurious expenditures beyond the bounds of reasonableness. Our total overhead expenses have remained in line with or lower than those institutions of similar size and geographic setting, and it is our desire to ensure that current and future expenditures remain reasonable and would not definitively be considered “excessive”, extreme, unnecessary, unwarranted or disproportionate. Nor will expenditures be undertaken for the sake of unnecessary “luxury”, lavishness, opulence, or extravagance.
The Company believes its standards with regards to its expenditures have not been nor will they be considered excessive or used for unnecessary luxury purposes, and therefore sets forth the following prohibition and prudent standards.
The Company hereby expressly prohibits excessive, extreme, unnecessary, unwarranted or disproportionate expenditures which may also include expenditures for the sake of luxury, lavishness, opulence, or extravagance.
Renovations of facilities and office spaces should be relative to the approved project and current Strategic 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 or retain a facility operational for customer use. At no time should renovations be incurred that would have the appearance of being extraordinary, or excessive.
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 expense incurred by the Company would be for company purposes, and used to develop business toward further enhancing the Company’s reputation, public image and ultimately, cultivate profitable business relationships for the Company. Occasional events such as taking customers or prospective customers on trips, outings, luncheon or dinner meetings, social gatherings or parties, or other similar events that wherein the focus of the activity is for the purpose of cultivating business relationships and a favorable public image for the Company is a necessary part of the Company’s marketing efforts and is not deemed as “luxury” or a violation of this Policy. Similar expenses may be incurred toward furthering the betterment of the communities served within our designated assessment area (as defined within the Community Reinvestment Act) which may include sponsorship of community events, fundraising activities, and the Company’s participation in local, County and State sanctioned events.
Any related expenses will be documented and detailed as to the benefit derived by the Company and where applicable, the community, through the normal expense review and approval process
Conferences, Seminars and other Industry Related Events
The Company believes that ongoing education is the key to excellence in service, and the overall continued well-being of the Company, and therefore remains committed to providing educational opportunities to its employees. Additionally, the dynamics technological advances and regulatory changes dictate that the staff remain educated and able to cope within and respond in a proactive manner to those constantly evolving frameworks.
Reasonable expenditures for staff and executive attendance at conferences, seminars and other industry related events, educational and networking opportunities, as related to the financial services industry, and networking and/or career development has been, and will continue to be encouraged.
Employee Recognition/Holiday parties
The size and geography of the Company has allowed us to retain a “family atmosphere”, and it remains the desire of the Company to provide employee recognition and/or holiday parties show employee appreciation for the hard work and dedication that has helped to keep the Company reputable and profitable for over 78 years.
For the purposes of this policy, events should be local in nature, and may include reasonable costs for such things as facility use, food and beverage, service awards and nominal door prizes.
Retreats should only be used for education and business planning purposes, and should be kept in consideration and viewed with the same discretion as all other expenses. The Company believes that Board and Management education is a vital part of maintaining a dynamic director base. Such retreats focus on strategic planning and/or education and render valuable insights toward planning and oversight for the Company.
Travel and Transportation Expenses
Travel and transportation for Company staff to outlying locations, including Company branch locations, conferences, business development purposes, and other legitimate business purposes, should be conducted in a cost-effective mode for the Company. Modes of transportation to be used may consist of vehicle, commercial or private air, or rail service. The selection of transportation services will factor in cost, efficiency and timeliness of travel.
Violations of this Policy
Any person who has knowledge of apparent violations of this are required to immediately report such occurrences to the Chief Financial Officer of the Company. The identity of the person reporting such occurrences will, to the extent provided by law, be kept confidential if requested. Any person may make such a report which describes any alleged violation to this policy to:
Chief Financial Officer
Chambers Bancshares, Inc.
P.O. Box 1330
Danville, Arkansas 72833
Each and every employee of the company will be held accountable to ensure that the purpose and provisions of this policy are not deviated from. The Chief Financial Officer will be responsible for direct oversight and review of day-to-day expenditures to ensure ongoing compliance with this policy. Violations, deviations, and/or infractions of this policy will be reported to the Directorate of the Company.