Emergency Capital Investment Program Excessive or Luxury Expenditures Policy

“Excessive or luxury expenditures” means excessive expenditures on any of the following to the extent not reasonable or appropriate expenditures for businessdevelopment, staff development, proper performance incentives, or other similar reasonable measures conducted in the ordinary course of the Credit Union’sbusiness operations:

1. Entertainment or events. This category includes fees, dues, ticket costs related to social, athletic, artistic, dining clubs, activities, celebrations, other events,and similar expenditures. Expenditures for charitable contributions and events are not prohibited under this policy. Entertainment or events expenditures inan amount less than $10,000 per instance, and $100,000, on an annual aggregate basis per individual, are exempt from this policy.
2. Office and facility renovations. This category includes costs and allowances for office renovation, including furniture, art, office personalization, interiorfinishings, design and decoration, and similar expenditures. Office and facility renovation expenditures of less than $10,000 per instance, and $50,000 onan annual aggregate per individual basis, are exempt from this policy.
3. Aviation or other transportation services. This category includes charter fees, tickets, slip or docking fees, vehicle installment payments, reservations,travel agent expenses, and similar expenditures associated with transportation services (e.g., airlines, trains, rental cars, or vans). Mileage reimbursableaccording to current Internal Revenue Service mileage rates is exempt from this policy. Transportation services in an amount less than $5,000 per instance,and $25,000 on an annual aggregate basis per individual, are exempt from this policy. The principal executive officer may establish or delegate to anappropriate executive officer the authority to develop processes for reimbursing reasonable travel expenditures, which methods must be reviewed by Executive Management no less frequently than annually.
4. Tax gross-ups. This category includes any reimbursement of taxes owed concerning any compensation. This category does not apply to tax equalizationagreements for employees subject to taxation from non-U.S. Jurisdiction. This will not include current or future executive benefits related to retirementusing split-dollar and life insurance plans.
5. Other similar items, activities, or events for which Neighbors FCU may reasonably anticipate incurring expenses or reimbursing an employee for incurringexpenses. Expenditures related to other items not listed in the proceeding categories are exempt from this policy in an amount less than $5,000 perinstance. All expenditures permitted under this policy may not exceed $25,000 on an annual aggregate per individual.

To avoid doubt, reasonable capital investments in technology, equipment, and similar items that expand the long-term capability of an ECIP recipient to provideproducts and services to its customers and community are not excessive or luxury expenditures.

The principal executive officer may establish or delegate to an appropriate executive officer the authority to develop processes for evaluating and approvingexpenditures in the preceding categories that are not luxury or excessive expenditures and are not otherwise exempt from this policy. Executive Managementmust review these processes no less than annually, and any additional threshold expenditure amounts per item, activity, or event, or a threshold expenditureamount per employee receiving the item or participating in the activity or event under this policy. Such approvals must be reported to the Board of Directorsinappropriate summary form no less frequently than annually.