Code of ConductThe Bank prides itself on the high standards of excellence embodied by our operating principles. We expect our employees to personify these ideals in their dealing with persons both inside and outside the company. The following code of conduct is intended to provide guidelines for the professional, ethical, legal, and socially responsible behavior we expect of our employees.
It is impossible for this code to cover every situation that may arise. When you have a question, ask your supervisor or the Human Resources officer. In circumstances where you are unable to consult with an appropriate person in the company, use your common sense and good judgment.
Consistent with our operating principles, employees should strive to conduct all business dealings and relationships with integrity, honesty, and respect for others. Employees should loyally and faithfully serve our principles and always deal fairly and honestly with customers and others with whom we do business. No employee should knowingly permit any transaction to occur through his or her offices that is not fair to our principals and customers alike.
Relationships with customers, manufacturers, suppliers, competitors, and employees are to be based on fair dealing, on fair competition in quality, price, and service, and on compliance with applicable laws and regulations.
Accurate and Complete Accounting
No unrecorded fund, reserve, asset, or special account shall be set up or maintained for any purpose. No false or fictitious entries shall be made in books, records, accounts, or in company communications for any reason. No payment or transfer of funds or assets (such as tangible and intangible premiums) shall be made for any purpose other than that described by the supporting documents, and specifically as authorized by the principal or clearly within the discretion granted to the Bank by the principal.
Employees are responsible for accurate and timely record keeping for all Bank assets, liabilities, revenues, and expenses. Compliance with accepted accounting rules and controls is required. All books, records, and documents must accurately and completely describe the transactions they represent.
Bribes and Kickbacks
A. The Bank does not permit or condone bribes, kickbacks, or any other illegal, secret, or improper payments, transfers, or receipts. This prohibition applies both to the giving and the receiving of payments or gifts.
B. All payments and transfers of premium and other items of value to employees of other business entities or to such entities themselves shall be made openly and must be disclosed and authorized in advance by the principal, the customer, and the Bank .
C. No employee shall offer, give, or transfer any money or anything else of value for the personal benefit of any employee or agent of another business entity for the purpose of:
1. Obtaining or retaining any business that the business entity itself would not otherwise provideD. No employee shall assist in the misuse of Bank funds, including, without limitation, the misappropriation of such funds for the personal benefit of employees of the Bank or customers.
2. Receiving any kind of favored treatment that the business entity itself would not otherwise provide
3. Inducing or assisting such employee or agent to violate any duty to his employer or to violate any law.
E. No outside agent of any kind shall be used to circumvent the prohibition against bribes, kickbacks, and other illegal, secret, or improper payments. Fees, commissions, and expenses paid to outside agents must be based upon proper billings, accurate record keeping, and reasonable standards for services rendered.
Gifts and Entertainment
A. Except in connection with and specifically pursuant to programs officially authorized by our principals, employees may not accept, directly or indirectly, any money, objects of value, or premiums from any person or company that has or is doing or seeking business with the Bank. All employees must disclose authorized transactions of this nature to the Human Resources officer. Providing excessive gifts or entertainment to others who may represent potential business is prohibited.
B. Employees may accept only business-related meals, entertainment, gifts, or favors when authorized by management and when the value involved is not significant and clearly will not create an obligation to the donor.
C. Any payments or transactions must be accurately recorded in the Bank’s books and records and must be consistent with applicable law and accepted practice in the community.
Conflicts of Interest
A. No employee should use his or her position with the Bank or information acquired during employment in a manner that may create a conflict, or the appearance of a conflict, between the employee's personal interests and those of the Bank.
B. All activities conducted as an employee of the Bank should always place the lawful and legitimate interests of the Bank over personal gain.
C. Absent written authorization by the Bank, no employee shall be affiliated with any buyer, purchasing agent, or provider of goods or services to the Bank. Such affiliation generally is inconsistent with the employee's capacity to deal equitably with all buyers, to fairly and honestly service principals, and to discharge his or her responsibility to the Bank. Carrying on Bank business with a firm in which the employee, or a close relative or associate of the employee has a substantial ownership or interest in, or participating in the management of a firm to which the Bank makes sales to, or from which it makes purchases may be considered a conflict of interest.
D. Absent written authorization from the president, no employee may have simultaneous employment by another firm, if the other firm is a competitor or supplier.
E. If an employee has any reason to believe there may be a conflict of interest, he or she should immediately disclose the matter to an immediate supervisor, Human Resources officer, CEO, COO or follow procedures as set forth in the Improper Activities Complaint Policy. Failure to disclose a conflict of interest may lead to disciplinary action up to and including termination.
Business and Professional Ethics
No profession or industry has maintained higher standards of conduct nor provided greater public service than the financial institutions industry. Employees of financial institutions must recognize their duty to act in a manner of public trust and confidence. The Bank’s reputation for integrity is perhaps its most valuable asset and is determined by the conduct of its employees. Each of us must strive to avoid situations that might cause a perception of unethical or unprofessional behavior that would reflect on the Bank, its customers, or ourselves.
Exactly what constitutes a conflict of interest or an unethical business practice is both a moral and a legal question. The Bank recognizes and respects the individual employee's right to engage in activities outside of his or her employment that are private in nature and do not in any way conflict with or reflect poorly on the Bank. Management reserves the right, however, to determine when an employee's activities represent a conflict with the Bank’s interests and to take whatever action is necessary to resolve the situation — including terminating the employee.
It isn't possible in a general policy statement of this sort to define all the various circumstances and relationships that would be considered "unethical." Employment by the Bank carries with it a responsibility to be constantly aware of the importance of ethical and professional conduct.
A. Except as properly authorized by the Bank, it is the responsibility of all employees to maintain the confidentiality of:
1. Proprietary information of the Bank.B. Employees should refrain from discussing confidential Bank business with outsiders and with anyone else who does not have a legitimate need to know the information. Employees should refer outside inquiries regarding the Bank to executive management authorized to respond to the particular inquiry.
2. Information entrusted to the Bank by principals or customers that is otherwise not readily available to the public.
Political and Charitable Contributions
Although employees are encouraged to be socially responsible and politically active, employees may not contribute the Bank’s or any principal's funds or assets to any political candidates, party, charity, or similar organizations, unless such contribution is expressly permitted by law and has been pre-approved by the appropriate, authorized representative of both the Bank and the principal.
Administration of Code
A. All employees who suspect violations of the letter or spirit of this code have an obligation to report their concerns to the Human Resources officer, CEO or COO or follow procedures as set forth in the Improper Activities Complaint Policy. Matters of concern include pressure exerted by manufacturers, customers, company personnel, or others to utilize accounts in an unauthorized manner or to take or enable other actions inconsistent with authorized company procedures and policies or this code. Employees may also relate their suspicions or specific incidents to any member of the board of directors.
B. All allegations of improper or illegal behavior will be investigated promptly and thoroughly. The investigation shall remain as confidential as practicable and those conducting the investigation shall respect the privacy of all persons involved.
C. No adverse action shall be taken or permitted against anyone for communicating legitimate concerns to the appropriate persons. While an investigation will be facilitated if the employee identifies himself or herself, the Bank will accept and investigate matters submitted anonymously.
D. This code is subject to amendment and may be reviewed and updated periodically. All employees must certify annually their intent to comply with the guidelines herein.