Exhibit 14.1
WVS FINANCIAL CORP.,
And
WEST VIEW SAVINGS BANK
ETHICS POLICY
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STATEMENT OF INTENT:
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WVS Financial Corp. has adopted this Ethics Policy to assure uniform standards
of ethical conduct and to protect the reputation and integrity of our Company,
our employees and our directors. WVS Financial Corp. (the "Company"), and its
affiliate, West View Savings Bank, accept the challenge of fostering the highest
possible ethical standards in dealings with clients, employees, suppliers,
regulators, and the community at large. Committed to honesty, integrity and
impartiality, we strive continually to assure the highest standards of ethical
conduct and to maintain the trust and confidence of all those with whom we
interact.
It is imperative that our employees and directors fully understand and subscribe
to this Policy. It is equally imperative that whenever uncertainty exists with
regard to the interpretation of this Policy, employees seek counsel from the
Vice President - Operations. Should the Vice President - Operations, employees
or directors involved need further counsel or discussion, the issue may be
presented to the Chief Executive Officer or the Chairman of the Board of
Directors. At the CEO or Chairman's discretion, the issue may be presented to
the Board of Directors.
RESPONSIBILITY FOR COMPLIANCE:
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All business activities of the company are designed to comply with applicable
laws. An equal responsibility for compliance with federal, state and local laws
rests with each employee and director of the Company. The Company relies on your
good judgment to avoid all activities which you believe involve improper subject
matter or improper conduct, or even the appearance of improper conduct.
This Ethics Policy is not a summary of the laws applicable to each Company
activity. It is intended only to highlight and emphasize the underlying
standards of conduct to which the employees and directors of the Company are
expected to subscribe. You should seek the guidance of your supervisor or the
Company's Vice President - Operations if any concerns arise.
ETHICAL STANDARDS:
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1. Fraud by Employees
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The Company intends to prevent any instances of fraud or misappropriation,
or any fiscal irregularities by its employees. These include, but are not
limited to, the following:
A. Any dishonest or fraudulent act;
B. Forgery or alteration of any document or account belonging to the
Company;
C. Forgery or alteration of a check, bank draft, account statement or
any other financial document;
D. Misappropriation of funds, securities, supplies, or other assets;
E. Profiteering as a result of insider knowledge of corporate
activities;
F. Disclosing confidential and proprietary information to unauthorized
parties; and
G. Disclosing to other persons securities, acquisition, or strategic
activities engaged in or contemplated by the Company.
2. Gifts and Entertainment
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Gifts, favors, entertainment and payments without a legitimate business
purpose may have the effect of improperly influencing decision making and
may create the appearance of impropriety. Company employees and directors
should not seek or accept for themselves or others any gift, favor,
entertainment, or payment of services from any individual or entity which
conducts or seeks to conduct business with the Company or is competitive
with the Company, unless: (i) to do so would be consistent with good
business practices; (ii) all such benefits, taken as a whole, are of
nominal value; and (iii) public disclosure of the transaction would not
embarrass the Company. Gifts of money should never be accepted. Gifts
offered or received with a fair market value greater than $100 or
Entertainment received with a fair market value in excess of $500 must be
pre-approved by the President. Bribes or attempted bribes must be reported
immediately to the Company's Vice President - Operations. If you have any
questions as to whether a gift or entertainment is permissible under this
policy, you should consult with the Company's Vice President - Operations.
3. Conflict of Interest
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Company employees and directors should avoid situations where their
personal interests could conflict, or reasonably appear to conflict, with
the interests of the Company. An example of conflict of interest includes,
but is not limited to, any opportunity for personal gain apart from the
normal compensation provided by the Company through its normal
remuneration policies. In that regard, the following are some guidelines:
A. Personal Financial Gain and Outside Activities
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Employees and directors should avoid any outside financial interest
that may influence their corporate decisions or actions. Such
interests might include, among other things, a personal or family
interest in an enterprise that has business relations with the
Company. This would include any instance where an employee or
director has an investment in or participates in the management of a
business that provides services or products to or receives services
or referrals from the Company. However, this restriction does not
apply to minimal (less than 1%) holdings of stock of a business
entity whose shares are publicly traded, and which may,
incidentally, do business with the Company.
In addition, employees and directors should avoid an investment or
participation in another business that competes directly with the
Company or has interests which are adverse to those of the Company.
However, this restriction does not apply to (less than 1%) holdings
of stock of a business entity whose shares are publicly traded, and
may compete directly with the Company.
Finally, employees should avoid outside employment or activities
that would have a negative impact on the performance of their job,
conflict with their obligation to the Company, or in any way
negatively impact the Company's reputation in the community.
If you feel you may have a conflict of interest due to your
investments or outside activities, you should consult with the
Company's Vice President - Operations.
If you have a business opportunity which may conflict with these
provisions, you should disclose in writing all material facts of the
opportunity, including your personal interest, to the Company's Vice
President - Operations.
B. Use of Company Funds and Assets
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Company assets are to be used solely for the benefit of the Company.
Employees and directors are responsible for assuring that Company
assets are used only for valid Company purposes. Company assets are
much more than our equipment, inventory, corporate funds, or office
supplies. They include concepts, business strategies and plans,
business opportunities, financial data, intellectual property rights
and other information about our business. These assets may not be
improperly used to provide personal gain for employees or directors.
Employees and directors may not transfer any Company assets to other
persons or entities, except in the ordinary course of business.
C. Trade Secrets and Confidential Information
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It is important for all employees and directors to appropriately
safeguard the Company's trade secrets, proprietary and confidential
information including non-public customer and account information
("Confidential Information"). Confidential Information includes any
information which is not in the public domain and which is useful or
helpful to the Company, and/or information which would be useful or
helpful to competitors. Common examples of Confidential Information
include: financial data, projected earnings and business unit
performance, business expansion information, strategic data,
business processes, regulatory examination information, client
information, lists of clients, wage and salary data, changes in
management or policies of the Company, or plans we may have for
improving any of our products.
The Company's guidelines regarding Confidential Information are as
follows:
1) Confidential Information to which employees and directors may
have access should be discussed with others only on a
need-to-know basis.
2) Disclosure of proprietary information to any outside persons
should be done only in conjunction with appropriate trade
secret or confidential information disclosure agreements in
conjunction with instructions from a senior officer of the
Company.
3) Employees and directors must be alert to inadvertent
disclosures which may arise in either social conversations or
in normal business relations with our customers and vendors.
4) Client account information and data must be handled in a
manner consistent with the Company's Privacy Policy.
5) Confidential Information obtained in the course of employment
with the Company shall not be used, or given to a third party,
for the purposes of trading in the securities of the Company
or its clients.
6) Employees shall not access information about clients or
employees except in the normal course of the employee's job
responsibilities.
4. Books and Records
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The Company maintains a system of internal controls which it believes
provides reasonable assurance that transactions are executed in accordance
with management's authorization and properly recorded. The system is
characterized by a control-oriented environment which includes written
policies and procedures. All employees are expected to adhere strictly to
these policies.
No secret or unrecorded funds or assets may be created or maintained for
any purpose. In addition, the making of false or fictitious entries in the
books with respect to Company transactions or the disposition of Company
assets is prohibited, and no employees may engage in any transaction that
requires or contemplates the making of false or fictitious entries.
5. Political Contributions
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Employees shall not use Company funds for contributions of any kind to any
political party or committee in the United States or to any candidate for
or holder of any office of any government - national, state or local.
Employees are free to make voluntary person contributions to political
action committees and to candidates and parties of their choice, but may
not make such contributions on behalf of the Company.
6. Personal Conduct
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The Company's reputation depends, in large measure, on the reputation of
its employees for honesty, integrity and financial responsibility.
Employees shall not engage in any behavior during employment which may
reasonably be deemed inappropriate and reflect negatively on the Company.
Employees shall pay in a proper and timely manner all financial
obligations. Employees who have been convicted, pleaded guilty or pleaded
no contest to a felony or other criminal offense involving dishonesty or
breach of trust which has not been annulled or expunged during the
employee's term of employment shall notify the Company's Vice President -
Operations.
COMPLIANCE:
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Any violation of this Policy may subject the Employee to disciplinary action up
to and including termination of employment. Any Employee having knowledge of any
violation of this Policy shall promptly report such violation to their
supervisor. The Company's Vice President - Operations shall be responsible for
all interpretive guidance and shall be authorized to issue written opinions
and/or waivers as to the application of this Policy to any specific
circumstance.
ACKNOWLEDGEMENT:
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On an annual basis, each Employee and Director of the Company will be required
to acknowledge in writing their awareness and understanding of this Policy and
their agreement to comply with its terms.
REPORTING ILLEGAL OR UNETHICAL BEHAVIOR
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Individuals who suspect or know of violations of this Code have an obligation to
contact the Company's Vice President - Operations in writing at 9001 Perry
Highway, Pittsburgh PA 15237.
REPORTING QUESTIONABLE ACCOUNTING OR AUDITING CONCERNS
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Individuals who suspect or know of questionable accounting or auditing practices
have an obligation to contact the Company's Chairman of the Board in writing at
9001 Perry Highway, Pittsburgh PA 15237.
RELATED POLICIES:
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o Employee Personnel Manual
o Information Systems Policy
o Privacy Policy
o Regulation O Policy