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Luxury Expenditure Policy

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.

Green Circle Investments, Inc. (Company) and its subsidiary, Peoples Trust & Savings Bank, an Iowa State Chartered Bank, prohibit 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 measures conducted in the normal course of business operations of Green Circle Investments, Inc. or Peoples Trust & Savings Bank.

RENOVATIONS:

Office and facility renovations should be designed to:  1)  Enhance operational efficiency;  2) Comply with applicable fire codes and ADA requirements;  3)  Maintain a safe, sanitary and clean working environment;  4)  Enhance the public image of the Company;  5) Improve employee morale;  6) Other worthwhile purposes as may be identified by the Company.  An exception to this can be allowed if management must deal with an emergency situation, such as an act of nature, and the expenditure is necessary to make the facility operational for customer use.  At no time should renovations be done that would have the appearance of being extraordinary, or excessive from a shareholder perspective.  

ENTERTAINMENT:

Entertainment is defined as an activity that an Employee or Executive would use corporate funds for business development purposes relating to a current customer(s) or perspective customer(s) or to further enhance the Company’s marketing efforts.

CONFERENCES:

We encourage our staff to attend conferences that are appropriate educational opportunities.  These conferences should be related to the financial services industry and have a direct correlation to their job.  At times it may be appropriate that a spouse would travel to these conferences with Company attendees.  Typically these conferences are sponsored by vendors, banking associations or other industry related entities.

This Policy would EXCLUDE reward conferences whether paid for by the Company or other vendors as a violation of this policy if the purpose is meant to be a reward, or would have no value of education to the employee or executive.

HOLIDAY PARTIES:

We feel that holiday parties are part of an employee appreciation process.  Holiday parties should be local in geographic nature, and the costs should not be excessive. 

Board Retreats should only be used for educational purposes, and should be kept in consideration and looked at in the same view and discretion as all other expenses.  Board education is a vital part of maintaining and keeping a dynamic director base.  This policy should not limit a retreat that is focused on strategic planning or education.

Events and parties focused on customers for the purpose of attracting their business would not fall under this policy.

AVIATION SERVICES:

Transportation for Company staff to outlying locations, including bank locations, conferences, business development purposes and merger and acquisition research, should be conducted in the most cost appropriate way for the Company.  The accounting department will maintain, when appropriate, an analysis of trips to determine which mode of transportation is the most appropriate for the Company and its Shareholders.  Modes of transportation to be used for the analysis, for example, may consist of vehicle, commercial air service and private air service.  A determination of transportation analysis will factor in cost, efficiency and timeliness of travel.

APPROVAL OF EXPENDITURES:

All expenditures for Green Circle Investments, Inc. or subsidiary Peoples Trust & Savings Bank must be approved by the Branch Market President.  Any expenditure exceeding $1000.00 must have prior approval of the Bank’s CEO or CFO and must be signed by the CEO or CFO prior to payment.  All expenditures made by the Bank will be reviewed and approved by the Board of Directors at each monthly Board meeting to ensure the expenditure was necessary and meets the guidelines of this policy. 

ACCOUNTABILITY:

All employees of Green Circle Investments, Inc. and subsidiary Peoples Trust & Savings Bank are subject to this policy and will be held accountable for compliance with the policy.  All employees are encouraged to report immediately, to senior management, any violations of this policy.  Any employee found violating this policy will be subject to disciplinary action, up to and including termination.

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