REGULATORY OVERVIEW

We Florida Financial has authority to provide compensation and benefits that are reasonable. This Policy establishes a prohibition on expenditures that are Excessive, or Luxury Expenditures as required by the Department of the Treasury’s Emergency Capital Investment Program regulations (31 CFR Part 35), and as may be required by other statutes and regulations.

POLICY STATEMENT

This Policy establishes limitations and internal controls governing expenditures by We Florida Financial (together with its subsidiaries and controlled affiliates, referred to hereafter as the “Organization”) that might be deemed to be Excessive or Luxury Expenditures (as defined below). As a general principle, all expenditures by the Organization should be customary, prudent, consistent with applicable laws and regulations, and reasonably related to the Organization’s business objectives and needs. This Policy identifies expenditures that may be Excessive or Luxury Expenditures, creates processes that are reasonably designed to identify and prevent such expenditures, and establishes accountability for compliance. Routine operating expenses, capital expenditures, and other reasonable expenses are not prohibited by this Policy. For the avoidance of doubt, reasonable capital investments in technology, equipment, and similar items that expand the long-term capability of the Organization to provide products and services to its members and community are not Excessive or Luxury Expenditures.

MANAGEMENT AUTHORITY

This Policy is the responsibility of the Board of Directors of We Florida Financial. This Policy has been adopted by the Board of Directors. The Board of Directors will review compliance with this Policy no less frequently than annually. The Chief Executive Officer/President and/or the Chief Financial Officer/Senior Vice President of the Organization will provide the Board of Directors with a periodic report (at least annually) that summarize all expenditures that might be considered Excessive or Luxury Expenditures, including those expenditures that were approved by the Board of Directors or the Chief Executive Officer/President and/or the Chief Financial Officer/Senior Vice President because they were determined to be customary, prudent, consistent with applicable laws and regulations, and reasonably related to the Organization’s business objectives and needs. This Policy applies to all employees, officers, and board directors of the Organization about any expenditure of the Organization that might be an Excessive or Luxury Expenditure. Prior to making any expenditure on behalf of the Organization, employees, officers, and board directors should consider whether the expenditure could be viewed as an Excessive or Luxury Expenditure that is prohibited under this Policy.

GUIDELINES

Excessive or Luxury Expenditures

The term “Excessive or Luxury Expenditure” means any excessive expenditure on any of the following categories of expenditures to the extent not reasonable or appropriate for business development, staff development, reasonable performance incentives, or other similar reasonable measures conducted in the normal course of the Organization’s business operations:

(1) Entertainment or events.

This category includes amounts expended on member entertainment, social, athletic, artistic, and dining clubs, activities, celebrations, or other events, and similar expenditures, including costs of meals, dues and membership fees, cost of tickets, costs of such activities and other costs of such items. Expenditures for charitable contributions and charitable events are not prohibited under this Policy. Any expenditures more than the following limits require approval of either the Chief Executive Officer/President and/or the Chief Financial Officer/Senior Vice President or the Board of Directors under the Review and Approval of Exceptions subsection of this Policy:

(i) expenditures for individual activities, celebrations, or other events in an amount of $1,000 or more, or (ii) aggregate annual expenditures for any individual employee, officer, or board director more than $3,000. Any expenditures in this category below these amounts are not subject to this Policy.

(2) Office and facility renovations.

This category includes costs and allowances for office and facility renovations, including expenditures related to furniture, art, office personalization, interior finishing, design and decoration, and similar expenditures. Any expenditures more than the following limits require approval of either the Chief Executive Officer/President and/or the Chief Financial Officer/Senior Vice President or the Board of Directors under the Review and Approval of Exceptions subsection of this Policy:

(i) expenditures for an individual office renovation of more than $5,000, (ii) aggregate annual expenditures for all office renovations of more than $60,000 or (iii) facility renovations of more than $100,000. Any expenditures in this category below these amounts are not subject to this Policy.

(3) Aviation or other transportation services. This category includes charter fees, airplane tickets, car rentals, boat slip or docking fees, vehicle installment payments, reservation and travel agent expenses, and similar expenditures associated with transportation services (e.g., airline, train, rental cars, or vans). Mileage reimbursable according to current Internal Revenue Service mileage rates is exempt from this Policy. Any expenditures more than the following limits require approval of either the Chief Executive Officer/President and/or the Chief Financial Officer/Senior Vice President or the Board of Directors under the Review and Approval of Exceptions subsection of this Policy: (i) individual expenditures of more than $3,000, or (ii) expenditures for any individual employee, officer, or board director more than $15,000. Any expenditures in this category below these amounts are not subject to this Policy.

(4) Tax gross ups. This category includes any reimbursement of taxes owed with respect to any compensation. This category does not apply to tax equalization agreements for employees subject to tax from a non-U.S. jurisdiction. All tax gross ups are subject to approval of either the Chief Executive Officer/President and/or the Chief Financial Officer/Senior Vice President or the Board of Directors under the Review and Approval of Exceptions subsection of this Policy.

(5) Other similar items, activities, or events for which the Organization may reasonably anticipate incurring expenses or reimbursing an employee for incurring expenses. Any expenditures in this category more than the following limits requires approval of either the Chief Executive Officer/President and/or the Chief Financial Officer/Senior Vice President or the Board of Directors under the Review and Approval of Exceptions subsection of this Policy: (i) individual expenditures of more than $1,000, or (ii) expenditures for any individual employee, officer, or board director more than $12,000. Any expenditures in this category below these amounts are not subject to this Policy.

Review and Approval of Exceptions

Any expenditure in the categories listed above that exceeds the limits in each category requires the prior approval of either the Chief Executive Officer/President and/or the Chief Financial Officer/Senior Vice President or the Board of Directors as follows: The expenditure may be approved by the Chief Executive Officer/President and/or the Chief Financial Officer/Senior Vice President if it does not exceed $100,000 and does not involve an expenditure by the Chief Executive Officer/President and/or the Chief Financial Officer/Senior Vice President. All other expenditures more than the limits require the prior approval of the Board of Directors. Any expenditure may be approved if it is determined that such expenditure is reasonable or appropriate for business development, staff development, reasonable performance incentives, or other similar reasonable measures conducted in the normal course of the Organization’s business operations. All exceptions approved by the Chief Executive Officer/President and/or the Chief Financial Officer/Senior Vice President must be reported to the Board of Directors (which may be in an appropriate summary form) no less frequently than annually.

Violations

Any violation of this Policy must be promptly reported to (i) the Chief Executive Officer/President, (ii) the Compliance Officer, or (iii) any other officer designated with primary responsibility for overseeing the administration, monitoring, and compliance with this Policy. These officers must report violations to the Board of Directors at least annually, or more frequently as the nature and severity of violation may warrant. All employees, officers, and board directors of the Organization must adhere to this Policy and will be held accountable for compliance. Any employee or officer who violates this Policy may be subject to disciplinary action up to and including termination of employment.

INTERNAL REVIEW & REPORTING REQUIREMENTS

Any employee or officer that is aware of any circumstance that may indicate a violation of this Policy is required to report such circumstance to their supervisor or the Organization’s Compliance Officer. The Organization prohibits retaliation against any employee or officer for making a good faith report of actual or suspected violations of this Policy, the Organization’s code of conduct, the Organization’s other policies or any applicable laws or regulations. A finding of retaliation against any such employee or officer may result in disciplinary action up to and including termination. Failure to promptly report known violations by others may also be deemed a violation of the Organization’s code of conduct.

Employees and officers may ask questions, raise concerns, or report instances of non-compliance with this Policy and/or any of the existing underlying relevant policies by contacting the following: Barbara Paine, Compliance Officer, 954-745-2371, bpaine@wefloridafinancial.com or call the “We Care Line”, at 800-461-9330, or text 954-869-4770, or email support@convercent.com.

Certification

On an annual basis, the Organization will deliver to the Department of the Treasury a certification, executed by its Chief Executive Officer/President and Chief Financial Officer/Senior Vice President certifying that (i) the Organization follows this Policy and (ii) all expenditures that required prior approval under this Policy were properly approved in advance by the Board of Directors or the executive officer designated by the Policy to approve such expenditure.

TRAINING REQUIREMENTS

Staff are trained as required.