GERMANTOWN CAPITAL CORPORATION
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 Department of the U.S. Treasury.
Germantown Capital Corporation (the “Company”) prohibits 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. All employees of the Company and its subsidiaries are subject to this Policy and will be held accountable for compliance with this Policy.
Our expectation is that all expenses incurred by the Company would be for business purposes, and used to drive 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 through the normal accounts payable process.
Events and parties focused on customers for the purpose of attracting their business would not fall under this policy.
Employee Recognition/Holiday Parties:
Alleged violations of this Policy should be reported to the Chief Executive Officer and the Board of Directors. The CEO will review alleged violations and determine whether a violation has occurred. Any employee who engages in excessive or luxurious spending in violation of this Policy will be subject to disciplinary action up to and including separation of employment.
Amended May, 2010
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