Great American Bank

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Headquartered in De Soto, Kansas, Great American Bank is a local institution with local decision makers, committed to serving the financial needs of consumers and business owners in and around Kansas City.

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Excessive or Luxury Expenditures Policy

First Financial Bancshares
Great American Bank


OVERVIEW: We are committed to fiscal responsibility and doing the right thing for our customers, employees and shareholders. Based on our normal business practices, we have created policies that manage expenditures and ensure appropriate management oversight.

In addition to fulfilling the requirement under the United States Treasury Regulations for the Capital Purchase Program participants under Section 111(d) of the Emergency Economic Stability Act of 2008, as amended by the American Recovery and Reinvestment Act of 2009, to develop and maintain a policy on excessive and luxury expenditures, this excessive and luxury expenditures policy is designed to provide principles for prudent spending across multiple expense types, allow reasonable flexibility to accomplish business goals, and yet eliminate excessive or luxury expenditures.

POLICY: This Policy:


COVERED EXPENDITURES
This Policy applies to all employees and directors, and covers expenditures for:

In general, all expenses outside of the normal course of business (including, without limitation, any personal expenses) are prohibited unless and until approved by the Board of Directors.

ENTERTAINMENT OR EVENTS
We recognize that entertaining potential and current customers is a vital part of business development. Any expenses incurred shall be primarily for our benefit to attract new customers, to maintain current client relationships or to help advance our community and philanthropic objectives. Reasonable dinners, sporting event attendance, trips or other events are not luxury expenditures and do not violate this Policy. Expenditures over $25,000 in total shall require the prior approval of the Board of Directors.

OFFICE AND FACILITY RENOVATIONS
We recognize that any office or facility renovations should be reasonable relative to our size and scope to meet the functional needs of the business, customers and employees and to optimize our overall use of real estate. Excessive expenditures are prohibited, which include specialty or antique furniture, customized finishes, non-standard office sizes and private bathrooms. This Policy will not apply to an emergency situation, such as destruction from a fire or tornado, requiring immediate attention to allow us to continue to operate. Expenditures for renovations over $25,000 shall require the prior approval by the Board of Directors.

AVIATION AND TRANSPORTATION
Transportation is necessary for business purposes and conference attendance, among other reasons. The standard rate for mileage reimbursement for employees using their personal vehicles for business purposes is the IRS guidelines in effect at the time of travel. Directors and employees will be reimbursed for parking and tolls when these expenses are required in the course of business related travel. All air transportation shall conform to the guidelines in the Expense Reimbursement Policy in the Employee Handbook.

EVENTS, PERFORMANCE INCENTIVES AND EDUCATION
We recognize that employee events and reasonable performance incentives play an important role in the morale and loyalty of our employees. We also recognize that director and employee education is important to our success. Expenditures for employee or director events or education over $25,000 in total shall require the prior approval the Board of Directors.

CERTIFICATION OF APPROVAL FOR EXPENDITURES REQUIRING PRIOR APPROVAL
Our Principal Executive Officer and our Principal Financial Officer shall provide written certification that any expenditure requiring prior approval was properly obtained pursuant to this Policy, and such certifications shall be maintained in our files in accordance with our document retention policy.

MANDATORY ADHERENCE AND ACCOUNTABILITY & REPORTING OF VIOLATIONS
Adherence to this Policy is mandatory for all directors and employees. Any violations of the Policy shall be reported promptly to the Board of Directors, the Principal Executive Officer and the Principal Financial Officer. Any employee found violating this Policy may be subject to disciplinary action up to and including termination.


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