Drake Bank Luxury Expenditure Policy

August 11, 2009

Purpose

The purpose of this policy is to ensure that there is the proper oversight, review and approvals of all expenditures and expenses of its officers and employees.

Authority and Responsibility

It is the responsibility of all officers and employees to receive the proper approvals before they receive reimbursement for their expenses and expenditures. All employees will be held accountable for the compliance of this policy.

Requirements

Plato Holdings* and Drake Bank prohibit excessive expenditures by officers and employees on the following:

  1. Entertainment or events.
  2. Office and facility renovations.
  3. Aviation and transportation services.
  4. Other activities or events that are not reasonable expenses for staff development, reasonable performance incentives, or other similar measures taken in the normal course of business.

Internal Control Objectives

All expenses are reviewed for reasonableness by the Senior Vice President of operations. Approval of all expenses is done monthly by Drake Bank's board of directors. All expense accounts are reviewed by both internal and external auditors.  Any Employee who suspects a violation of this policy should either report it to Rick Gobell, President, Vickie Finnegan, Senior Vice President, or Michael Ohlhauser, Senior Vice President.

* Drake Bank is a subsidiary of Plato Holdings