If the board doesn't approve them and some management level does, be sure you're covered under Reg. O as to who is and is not an insider.
Personally, if it warrants a policy and is guidance on how you'll operate, I think the board should be involved.
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell