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Excessive Or Luxury Expenditures Policy

Policy

It is the policy of Discover Financial Services, including its subsidiaries (collectively referred to herein as the "Company") to use corporate assets in a prudent manner; accordingly, the Company prohibits excessive or luxury expenditures.

Purpose

The American Recovery and Reinvestment Act of 2009 and the implementing regulations promulgated by the United States Department of the Treasury require each recipient of funds under the Capital Purchase Program of the Troubled Assets Relief Program adopt a company-wide policy regarding excessive or luxury expenditures. The Company currently maintains policies and procedures designed to eliminate luxury or excessive expenditures, including but not limited to, the Company's Travel and Related Business Expense Policy and Gifts and Entertainment Policy. In addition to the requirements of this Policy, all Company expenditures must be made in accordance with such other Company policies and procedures governing expenditures.

Scope

This Policy applies to the Company and its employees.

Requirements

The Company and its employees shall not engage in excessive or luxury expenditures. "Excessive or luxury expenditures" means excessive expenditures on any of the following to the extent that such expenditures are not reasonable expenditures for staff development, reasonable performance incentives, or other similar reasonable measures conducted in the normal course of Company's business operations:

  1. entertainment or events,
  2. office and facility renovations,
  3. aviation or other transportation services and
  4. other similar items, activities or events for which Company may reasonably anticipate incurring expenses, or reimbursing an employee for incurring expenses

Any proposed Company expenditure on one or more of the expense categories listed in (1)-(4) above which is (a) outside the scope or approval limits of the Company's Travel and Related Business Expense Policy and Gifts and Entertainment Policy; (b) for private or chartered aircraft services; or (c) for office or facility renovations and which (i) is reasonably expected to cost more than $25,000; (ii) may be considered an unreasonable use of corporate assets; or (iii) may harm the reputation of the Company, must first be approved by the Expenditure Review Committee ("Committee"). Any approval of such expenditures by the Committee shall be in addition to all other required approvals. No member of the Committee may vote on the approval of an expenditure for their own business unit. The Committee shall be available to consult with authorized managers regarding any expenditures.

The Company's Chief Executive Officer, Chief Financial Officer or the President and Chief Operating Officer (each an "Authorized Officer") may act in lieu of the Committee. Any Authorized Officer who takes action under this Policy shall promptly report such action to the Committee. The Company's Chief Executive Officer and Chief Financial Officer shall annually certify that all expenditures were approved in accordance with applicable Company policies and procedures.

This Policy shall be posted on the Discover Financial Services corporate website.

Violations of this Policy

Employees must promptly report violations of this Policy to their supervisor, the Law and Compliance Department or the Company's Integrity Hotline. Any employee who engages in excessive or luxury expenditures will not be reimbursed by the Company for such expenditures. Failure to comply with this Policy may result in disciplinary action by the Company, including termination of employment.

Compliance

Compliance with this Policy shall be monitored by the Compliance Department. .

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