Governance

Maintaining the Highest Business Standards

Doing business honestly and ethically is at the very 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.


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.


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.


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.


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.


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 2020, 100 percent of employees completed the required training and certified their understanding of and compliance with the 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.

In 2020, we received two confidential submissions, neither of which resulted in substantiated ethical violations or accounting irregularities.

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.

During 2020 we did not incur any monetary losses as a result of legal proceedings associated with fraud, insider trading, anti-trust, anti-competitive behavior, market manipulation, malpractice or other related financial industry laws or regulations.