​Guidance Notes

This Code of Conduct cannot anticipate or address appropriate behavior for every situati​on. Nor should it seek to do so. In the final analysis, the Bank relies on its employees to make an ethical judgment on what is right and proper in each particular situation.

If you are having difficulty determining whether a certain action is appropriate, you should be able to answer “yes” to all of the following questions before taking action:

  • Is my action legal, and does it comply with the Bank policy ?
  • Is this action the “right thing to do ?” Does my action “feel right ?”
  • Would this action withstand public scrutiny ?
  • Will this action uphold the Bank reputation as an ethical Bank ?

​If any answer is not “yes”, don’t do it.