EXHIBIT 99.1


                 CODE OF ETHICS FOR SENIOR FINANCIAL OFFICERS OF
                                OHIO LEGACY CORP

     The Senior Financial Officers of Ohio Legacy Corp identified in Exhibit A
hold an important and elevated role in corporate governance. As part of the
Corporate leadership team, Senior Financial Officers are vested with both the
responsibility and authority to protect, balance, and preserve the interests of
all of the Company stakeholders, including shareholders, clients, employees,
customers, depositors, borrowers and citizens of the communities in which our
business is conducted. Senior Financial Officers fulfill this responsibility by
prescribing and enforcing the policies and procedures employed in the operation
of the Company's financial organization, and by demonstrating the following:


I.   HONEST AND ETHICAL CONDUCT

     Senior Financial Officers will exhibit and promote the highest standards of
     honest and ethical conduct through the establishment and operation of
     policies and procedures that:

     o Encourage and reward professional integrity in all aspects of the
       financial organization by eliminating inhibitions and barriers to
       responsible behavior, such as coercion and fear of reprisal, with respect
       to reporting any matters contrary to Company policy.

     o Prohibit and eliminate the appearance or occurrence of conflicts between
       what is in the best interest of the Company and what could result in
       material personal gain for an employee of the Company, including Senior
       Financial Officers.

     o Provide a mechanism for employees of the Company to inform the Board of
       Directors or a committee appointed by the Board of deviations in practice
       from policies and procedures governing honest and ethical behavior.

     o Demonstrate their personal support for such policies and procedures
       through periodic communication reinforcing these ethical standards
       throughout the Company.


II.  FINANCIAL RECORDS AND PERIODIC REPORTS

     Senior Financial Officers will establish and manage the Company's
     transactional and reporting systems and procedures to ensure that:

     o Business transactions are properly authorized and completely, timely and
       accurately recorded on the Company's books and records in accordance with
       Generally Accepted Accounting Principles (GAAP), rules promulgated by the
       Securities and Exchange Commission, regulatory requirements and
       established Company policies.

     o The retention or proper disposal of Company records shall be in
       accordance with established Company financial policies and applicable
       legal and regulatory requirements.

     o Periodic financial communications and reports will be delivered in a
       manner that facilitates the highest degree of clarity of content and
       meaning so that readers and users will quickly and accurately determine
       their significance and consequence.


III. COMPLIANCE WITH APPLICABLE LAWS, RULES AND REGULATIONS

     Senior Financial Officers will establish and maintain mechanisms to:




     o Educate members of the Company about any federal, state or local statute,
       regulation or administrative procedure that affects the financial
       reporting operations of the Company.

     o Monitor the compliance of the finance affairs of the Company with any
       applicable federal, state or local statute, regulation or administrative
       rule.

     o Identify, report and correct in a swift and certain manner, any detected
       deviations from applicable federal, state or local statute or regulation.


                                    EXHIBIT A


     L. Dwight Douce
     Steven G. Pettit
     Eric Nadeau
     Paul Mederski