1. | Protection of Confidential Information |
2. | Acceptable Use of Bank Technology |
3. | Investments |
4. | Insider Trading |
5. | Conflicts of Interest |
6. | Receipt of Gifts |
7. | Outside Activities and Employment |
8. | Board Directorships and Partnerships |
9. | Improper Payments |
10. | Trade Associations and Relationships with Competitors |
11. | Separation of Trust and Commercial Banking Services |
12. | Advertising Policy |
13. | Political Action Committees/Corporate Payments |
14. | Public Statements |
15. | Recommendations to Customers |
16. | Financial Responsibility |
17. | Use of Bank Letterhead |
18. | Personal Conduct |
(1) | Caution should be exercised by each Director, Officer and Employee to assure that the nature and amount of such permitted investments do not exceed amounts that are prudent for a person maintaining a financial condition within conservative limits. |
(2) | Acceptance of preferential treatment in the form of an allocation of "hot" issues that are, or may become, in such demand that the broker, investment banker, issuer, or other seller of securities could reasonably expect |
(3) | To receive or has already received favorable treatment by reason of making the allocation available is prohibited. |
4. | Insider Trading |
(1) | financial results for the quarter or year-end; |
(2) | financial forecasts regarding future revenues; |
(3) | potential mergers, acquisitions, tender offers, joint ventures or changes in assets; |
(4) | changes in control or in management; |
(5) | actual or threatened litigation or major developments in such litigation; |
(6) | new products or discoveries, or developments regarding customers or suppliers (e.g., the acquisition or loss of a contract); |
(7) | Change in auditors or auditor notification that this Bank may no longer rely on an auditor’s audit report; |
(8) | Events regarding this Bank’s securities (e.g., defaults on senior securities, calls of securities for redemption, repurchase plans, stock splits or changes in dividends, changes to the rights of security holders, public or private sales of additional securities); and bankruptcies or receiverships. |
(1) | trading in this Bank’s securities (including trading in options, puts, calls or other derivative securities of this Bank); |
(2) | having others trade for you in this Bank’s securities; and |
(3) | disclosing the information to anyone else (“tipping”) who might then trade. |
(4) | having an “open order trade” where a broker is given directions to buy or sell Bank stock at a set price without first obtaining your consent before executing the trade. |
(1) | A customer of the Bank. |
(2) | Any individual or organization that is or seeks to be a borrower, supplier, or competitor of the Bank. |
(1) | gifts (other than those of "nominal" value defined as less than $100.00) i.e. promotional items |
(2) | "lavish" entertainment - services or price concessions beyond that available to the general public |
(3) | cash or gift certificates |
(1) | Gifts, gratuities, amenities or favors based on obvious family or personal relationships (such as those between the parents, children or spouse of a Bank official) where the circumstances make it clear that it is those relationships rather than the business of the Bank concerned which was the motivating factors; |
(2) | Meals, refreshments, entertainment, accommodations or travel arrangements, all of reasonable value, in the course of a meeting or other occasion, the purpose of which is to hold bona fide business discussions or to foster better business relations, provided that the expense would be paid for by the Bank as a reasonable business expense if not paid for by another party (the Bank may establish a specific dollar limit for such an occasion); |
(3) | Loans from other banks or financial institutions on customary terms to finance proper and usual activities of Bank officials, such as home mortgage loans, except where prohibited by law; |
(4) | Advertising or promotional material of reasonable value, such as pens, pencils, note pads, key chains, calendars and similar items; |
(5) | Discounts or rebates on merchandise or services that do not exceed those available to other customers; |
(6) | Gifts of reasonable value that are related to commonly recognized events or occasions, such as a promotion, new job, wedding, retirement, holiday or birthday (the Bank may establish a specific dollar limit for such an occasion); or |
(7) | Civic, charitable, educational, or religious organization awards for recognition of service and accomplishment (the Bank may establish a specific dollar limit for such an occasion). |