Delaware Place Bank respects your right to privacy and takes every precaution to provide you with the same level of privacy within our virtual branch that you receive through more traditional bank delivery channels.
The collection of personal information online is designed to protect access to your personal accounts and to assist the bank in providing you with the products and services you want and need. All personal information collected and stored by the bank is used for specific business purposes-to protect and administer your personal accounts and transactions, to comply with state and federal banking regulations, and to help the bank better understand your financial needs in order to design or improve our products and services.
Employing stringent security measures in the collection of your personal information, all Delaware Place Bank online account applications are submitted to the bank's secure administration site through an encrypted direct line to the bank. Once received by the bank, only approved personnel may open and process the application. Furthermore, auditing mechanisms have been put into place to further protect your information by identifying which employee(s) has accessed and in any way modified-for example, updated or added to-your personal information.
It is in the best interest of both you and the bank to maintain accurate records concerning your personal information. For this reason, Delaware Place Bank allows you to update your personal information online, at anytime, through the submission of encrypted email requests sent to the bank's secure administration site. Notifications are immediately sent to approved bank personnel alerting them to the receipt of your request. This procedure allows Delaware Place Bank to update your personal information within a timely manner.
Delaware Place Bank limits employee access to your personal information to only those bank administrators with a business reason for knowing such information. Delaware Place Bank also educates all employees about the importance of confidentiality and customer privacy. In addition, individual user names and passwords are used by approved bank personnel to access your personal information online, providing audit trails to further safeguard the privacy of your personal information.
Delaware Place Bank follows strict privacy procedures in regard to protecting your personal information. In addition, the bank requires all third parties with a business need to access this information to adhere to similar and equally stringent privacy policies. Personal information may be supplied to a third party in order to process a customer transaction; if the customer requests it; the disclosure is required or allowed by law (i.e. exchange of information with reputable reporting agencies, subpoena, or the investigation of fraudulent activity, etc.); or for marketing purposes of which the customer has been previously informed and has been given the opportunity to decline.
This Excessive and Luxury Expenditure Policy has been adopted by Chicago Shore Corporation (the Company) pursuant to the requirements of Section 111(d) of the Emergency Economic Stabilization Act of 2008, as amended by the American Recovery and Reinvestment Act of 2009 (the Act), and the interim final rule (the Rule) issued thereunder (see 31 C.F.R. Part 30). The Company is required to implement a company-wide policy regarding certain categories of expenditures identified as "excessive or luxury expenditures" by the U.S. Department of the Treasury (Treasury) in connection with the Company's participation in the Treasury's TARP Capital Purchase Program. According to the Act and Rule, those categories address expenditures relating to: (1) entertainment or events, (2) office and facility renovation, (3) aviation and other transportation services and (4) other similar items, activities or events for which the Company may reasonably anticipate incurring expenses, or reimbursing an employee for incurring expenses. These categories are more fully addressed below in this Policy. The Company's Board of Directors and executive management are committed to complying fully with this requirement and the objective of this Policy is to implement various guidelines regarding such expenditures to ensure that the Company meets the requirements of Section 111(d) of the Act.
Responsibilities of the Board of Directors and Compensation Committee
Pursuant to the Act and the Rule, this Policy is adopted by the Board of Directors (Board). The Board and the Compensation Committee of the Board are responsible for oversight of the Company's compliance with the Policy as well as other compensation and corporate governance requirements. In support of their oversight responsibilities, the Board and the Compensation Committee shall have the following responsibilities, among others:
The Compensation Committee of the Board shall timely review and recommend to the full Board, and upon such recommendation the Board shall approve, any amendments of this Policy as they may deem appropriate or as otherwise required pursuant to any amendments of the Rule.
The Board shall review any exceptions to this Policy, that may be proposed or approved by executive management from time to time, at the next regularly scheduled meeting subsequent to the granting of any exception(s). It is anticipated that any such exceptions shall only be approved by executive management if such expense must be incurred, in management's reasonable determination, prior to the next Board meeting. In all other cases, such exceptions shall be proposed by executive management to the Board in advance for approval.
Responsibilities of Executive Management
Executive management is responsible for the effective implementation, administration and certification of compliance of the Company with this Policy. To that end, executive management shall:
Communicate this Policy to all employees to whom it applies. Monitor expenditures addressed by this Policy to ensure compliance. Document and justify any exceptions to this Policy and submit for approval, or report approved exceptions, as provided above, to the Board. Promptly recommend modifications of this Policy to the Compensation Committee to ensure it remains compliant with the Rule as it may be amended. Ensure that this Policy is posted on the Company's public internet web site (www.delawareplacebank.com).
"Entertainment" refers to those activities for which an officer or other employee would expend or incur corporate funds for business development purposes relating to current or prospective customers or to enhance the perception of the Company and Delaware Place Bank (Bank) in the market. Our expectation is that all expenses incurred for these activities would be for corporate purposes with the objective of attracting business to the Bank. Examples of entertainment activities include taking customers or prospects to restaurants, theater, sports events, concerts, golf and other activities that the customer/prospect would find enjoyable and provide an opportunity to reinforce and enhance business relationships. However, excessive and luxury entertainment expenditures are prohibited.
"Events" are meetings, conferences and employee recognition events that are intended to provide the Board and its Committees and management and other employees with opportunities for individual and team education, development and recognition, business planning, market and industry networking and related business purpose objectives. Events may include both those that are internally organized as well as those organized by other banks, trade associations, vendors and similar organizations. Occasionally, Company-organized events are held at non-Company facilities, such as restaurants and hotels, in order to accommodate the size of the group, to facilitate efficient administration of the meeting or to provide participants with a venue that is most conducive for the meeting's purpose. Directors, management and other employees may also participate in meetings hosted by other business partners that have a clear business purpose. The costs associated with meetings must be approved by a member of executive management.
Conferences typically offer educational, skill development and industry networking opportunities that enhance participant performance. These conferences should be related to the financial services industry and have a direct correlation to the participant's job duties. At times it may be appropriate that a spouse travel to these conferences with Company participants. Reimbursement of costs associated with spousal travel to conferences or sponsored events will be determined by executive management prior to the event or conference. Conference participation is subject to approval by a member of executive management. Employee recognition meetings, dinners and events are held occasionally to recognize the contribution of an individual, team or all employees. The cost of such meetings must be approved in advance by a member of executive management.
Expenditures for entertainment and events in the normal course of business are a necessary part of the Company's marketing efforts and are not deemed as "luxury" or a violation of this Policy. These expenses should continue to be documented and detailed as to the benefit derived by the Bank through the normal accounts payable process. The Chief Executive Officer shall use his reasonable discretion to establish guidelines for acceptable such expenditures and otherwise to evaluate whether any such expenditures submitted for approval are excessive and, if determined to be excessive, shall deny such expenditures.
Office and Facility Renovations Office and facility renovations should be designed to: enhance operational efficiency; comply with applicable fire codes and ADA requirements; maintain a safe, sanitary and clean working environment; enhance the public image of the organization; improve employee morale; or such other worthwhile purpose as may be identified by the organization. By way of example, relocating or adding to movable worker stations, improving the air flow or temperature, altering the wall, ceiling or lighting configuration of a work or storage space, establishing a new branch office or sales office are not considered excessive by their very nature. All other office and facility renovations are permitted only for projects approved by the Board. At no time should renovations be considered that would have the appearance of being extraordinary or excessive from a shareholder perspective.
Aviation And Other Travel Matters Aviation and other transportation services for Company staff to outlying locations, including for conferences, business development purposes and other purposes should be conducted in a cost-efficient manner. The selection of transportation services should include assessment of cost, efficiency and timeliness of travel. Private air services are not allowed.
Automobile Expenses The Company may provide an automobile(s) of an appropriate make, model and age or may provide an appropriate automobile allowance to employees for Bank business. Expenses for employee or director use of personal vehicles for Company business will be reimbursed at a rate that does not exceed the published IRS mileage rate. Documentation in support of such use must be provided in accordance with applicable Company policies and procedures.
Club Dues The Company may reimburse the Chief Executive Officer and other officers designated by the Board of Directors, or the Chief Executive Officer with respect to other officers, for annual/monthly dues associated with membership privileges in a country club, city club, or similar club in connection with promoting the Bank and attracting business to the Bank.
Documentation All expenditures covered by this Policy shall be documented, reported, supported by written invoices and receipts, and subject to audit in accordance with standard, uniformly-applied Company policies and procedures.
Reporting Violations; Disciplinary Action A violation of this Policy shall promptly be reported to the Chief Executive Officer and the Chairpersons of the Audit Committee and the Compensation Committee. Any employee who violates this Policy is subject to discipline as may be appropriate, up to and including termination of employment and reimbursement of all amounts paid or reimbursed by the Company or the Bank respecting such expenditure.