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.


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.


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


Mail:                                                                Phone: 1-513-852-4714                 Email: [email protected]

201 E. 4th St. Suite 800                                  Fax: 1-513-564-6912

Cincinnati, OH 45202

ATTN: Chief Human Resources Officer


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.