All business conducted must meet the highest moral and ethical standards and must comply with all laws and regulations pertaining to our business and operations.

BUSINESS ETHICS AND INTEGRITY

Acceptance of Loans or Gifts
No employee or member of his or her family may solicit or accept any loan or gift from any company, individual or other source, whether directly or indirectly, that could reasonably be construed as an inducement to the employee to act other than in the Company’s best interests.

Conflicts of Interest
No employee should act for the Company in a situation in which the employee has any financial, personal, or family interest that might prevent the employee from acting in the best interests of the Company.

Financial Relationships
No employee may have a direct or indirect financial or similar relationship with a person or company that transacts business with the Company, seeks to transact business with the Company, or competes with the Company. This restriction does not apply to a loan from a lending institution or customary business terms.

Illegal Payments
No bribes, kickbacks, payoffs, or other illegal payments may be given or promised, whether to a government official, an employee of the company with whom the Company does business or is seeking to do business, or under any other circumstance.

Use of Confidential Information
No employee may directly or indirectly use for personal gain or other benefit confidential information of the Company, or confidential information of others entrusted to the Company.

Human Trafficking
Employees, contractors, and vendors shall not traffic in persons or use any form of slave, forced, bonded, indentured, or prison labor. This includes the transportation, harboring, recruitment, transfer, or receipt of persons by means of threat, force, coercion, abduction, fraud, or payments to any person having control over another person for the purpose of exploitation. All work must be voluntary and workers shall be free to leave work or terminate their employment with reasonable notice. Workers must not be required to surrender any government-issued identification, passports, or work permits as a condition of employment.

An employee can report a suspected violation directly to the Compliance Officer as follows:

Pre-employment drug screening after a conditional offer of employment has been made.

You may call from branch location telephone or call collect. If you are calling from outside the United States or Canada, you will need to use the appropriate international access code for calls to the United States.

Reports of suspected violations, whether made by letter or telephone, may be made on an anonymous basis if necessary. Any such report should provide sufficient detailed information to enable the Compliance Officer to investigate and address the problem.