EXCESSIV E AND LUXURY EXPENDITURE POLICY

As adopted by the Board of Directors August 26, 2009

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EXCESSIVE AND LUXURY EXPENDITURE POLICY

As adopted by the Board of Directors August 26, 2009

I. General Policy

It is the policy of the Bank that directors and employees of the Bank utilize corporate

assets in a prudent manner and as such are hereby precluded from engaging in excessive

or luxury expenditures. The following are the Bank’s minimum standards. Directors and

employees are encouraged to impose more strict standards upon themselves when they

deem the relevant circumstances require such standards.

II. Types of Excessive or Luxury Expenditures

Excessive or luxury expenditures can occur in the following areas:

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travel;

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events;

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office and facility improvements and/or renovations;

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entertainment; and

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other activities or events that involve expenditures which are not for staff

development, performance incentives or other similar matters conducted in the

normal course of business and which are not reasonable in amount.

III. Travel Expenses

A. Procedure for Reimbursement. All travel related expenses incurred by a director in

the ordinary course of business shall be submitted to the Chief Financial Officer (CFO)

(“Policy Officer”) on an employee expense report. The Policy Officer will be responsible

for making sure all documentation is appropriately completed and will submit all

approved expenses to Accounts Payable for reimbursement.

All travel related expenses incurred by an employee in the ordinary course of business

shall be submitted by the employee on an employee expense report and approved by such

employee’s supervisor before being submitted to Accounts Payable for reimbursement.

Reimbursement requests by the Chief Executive Officer (“CEO”) must be made by the

Chief Financial Officer (CFO).

Any travel expenditures that are not covered by the foregoing provisions must be

approved in writing by the Chief Financial Officer (if requested by a director or the CEO)

or the employee’s supervisor (if requested by an employee) prior to being incurred.