Excessive or Luxury Expenditure Policy

It is the policy of OneUnited Bank (“Bank”) that all employees and directors of the Bank are prohibited from making any excessive or luxury expenditures. The term “excessive or luxury expenditures” is defined as excessive expenditures on any of the following to the extent such expenditures are not reasonable expenditures for staff development, reasonable performance incentives, or other similar reasonable measures conducted in the normal course of the Bank’s business:

  1. Entertainment or events;
  2. Office or facility renovations;
  3. Aviation or other transportation services; and
  4. Other similar items, activities, or events for which the Bank may reasonably anticipate incurring expenses, or reimbursing an employee or director for incurring expenses.

Reasonable expenditures may be incurred for business-related activities, events and purposes, including, without limitation, legitimate travel and meeting-related costs for attendance at conferences and meetings in appropriate environments for purposes of professional development, education, training, familiarization with the Bank’s products and services, and/or networking and best practice sharing across banking-related industries; however, such expenditures must conform with all applicable Bank policies and procedures.

AIR TRAVEL
Air travel on Bank business shall be by commercial airline. Air travel by first or business class for trips less than four hours requires the prior approval of the Chief Executive Officer. The Bank does not own or lease, and does not intend to purchase or lease, any private aircraft for use by Bank employees or directors.

OTHER TRANSPORTATION SERVICES
The Bank does not provide Bank owned automobiles for use by employees. Rental cars must be consistent with the Bank’s policies and procedures.

ENTERTAINMENT EXPENSES
All expenditures by employees or directors for entertainment must comply with applicable Bank’s policies and procedures and must have a business purpose. Requests for reimbursement for such expenditures must be justified and supported by documentation in accordance with applicable Bank policies and procedures.

OFFICE OR FACILITY RENOVATIONS
Employees’ offices, including executive offices, shall be appropriate for the employee’s position but not ostentatious in size, furnishings or decoration. Materials used to construct or renovate offices and facilities shall be selected on the basis of their quality, appearance, cost and durability, considering their intended use and avoiding opulence. All expenditures for constructing, renovating, or furnishing offices must be approved by the Purchasing Committee and/or Board of Directors.

EXPENDITURES FOR ACTIVITIES AND EVENTS
All expenditures by employees or directors for activities and events must comply with applicable Bank’s policies and procedures and must have a business purpose. The Board of Directors prior approval is required for expenditures for an activity or event whose total cost exceeds $10,000.

REQUIRED REPORTING AND ACCOUNTABILITY
All Bank expenditures, including those expenditures covered by this policy, shall be documented, reported, supported by written invoices and receipts, and subject to audit in accordance with Bank policies and procedures.

Employees or directors should report any violation of this policy to Vice President – Internal Audit. Failure to adhere to this policy could result in non-reimbursement of expenses and could further result in disciplinary action up to and including termination.

The Chief Executive Officer and the Chief Financial Officer shall certify at least annually that this policy is being followed and that the approval of any expenditure requiring prior approval of an executive officer or the Bank’s Board of Directors was properly obtained with respect to each such expenditure.

Approved by:
OneUnited Bank
Board of Directors
October 26, 2018