Doing business honestly and ethically is at the core of our culture.
Our Code of Ethics and Business Conduct provides guidance in how we expect our employees to conduct business on a daily basis and live up to our core principles. The policies in our Code of Ethics apply to all of our directors, officers, and employees. Anyone who violates the Code may face disciplinary action, up to and including termination.
Our Code addresses:
Confidential Information
Earning and maintaining the trust of our clients are essential to the success of our business.
Anti-Harassment
We are committed to the fair treatment of all employees and applicants for employment. We expect that all work relationships will be free of bias, discrimination, harassment, and retaliation.
Diversity and Inclusion
We are committed to a diverse and inclusive workplace where all backgrounds, experiences, interests, and skills are respected, appreciated, and encouraged. We strive to be the company where our employees, clients, and communities see, feel, and believe our commitment to diversity and inclusion.
Gifts and Entertainment
We restrict gifts from third parties so that they do not impair our ability to make objective business decisions or create the appearance that our objectivity has been compromised.
Conflicts of Interest
Each of us must carry out our professional responsibilities with integrity and with a sense of loyalty to the company. We are expected to make sound business decisions in the best interests of the company, without regard to our personal interests.
Compliance with Laws and Regulations
We operate in a highly regulated environment and are subject to examination by federal and state banking regulators. We seek to comply with — and never intentionally violate — the laws and regulations applicable to our businesses.
All employees receive training on our Code of Ethics upon joining the company, after which all employees receive bi-annual training and must certify their understanding of and compliance with our Code.
In addition to our Code of Ethics, we also maintain an Insider Trading Policy to prevent illegal insider trading and tipping by our directors, officers, and employees. We provide training to all employees on their obligations not to trade in our securities while in possession of material, non-public information about the company.
We encourage employees to inform management or our Audit Committee of any accounting irregularities or any potential violations of our Code of Ethics or other policies or laws. Our whistleblower policy governs the receipt, retention and treatment of concerns raised and protects the confidential, anonymous reporting of employee concerns regarding questionable accounting or auditing matters or other ethical violations.
Employees can also submit concerns or complaints regarding suspected violations on a confidential and anonymous basis through a toll-free response line or web portal, both monitored by an independent third-party provider. All submissions through the response line or web portal are reported to our Audit Committee and investigated by our General Counsel, Human Resources department, or Internal Audit department, as appropriate.
We maintain a strict non-retaliation policy. Employees who engage in retaliation against a colleague who has raised a concern or questions in good faith and in accordance with the Code are subject to disciplinary action, up to and including termination.
Corporate Political Contributions
Our Code of Ethics and Business Conduct reflects our policy of non-partisanship. We do not support any employee-funded political action committees, nor do we contribute any corporate funds to candidates for public office or political parties or use corporate funds to make independent political expenditures.
All employees are encouraged to participate in the political process, and we respect the rights of employees to support issues and candidates of their choosing.