Conflicts of Interest

          ​Employees shall not place themselves in positions where their own interests can conflict with those of the Bank or any of the Bank customers. The Bank policy regarding possible conflicts of interest is based on the principle that an employee’s decisions in the business must be made solely in the best interest of our customers and the Bank. In reaching these decisions, an employee shall not be influenced by personal or family considerations that may affect their judgment towards the best interest of the Bank and our customers.

  • Circumstances shall be avoided in which personal interests conflict with the interests of the Bank or our customers. Where conflicts arise, the individual and the Bank must ensure fair treatment to the affected party by disclosure, declining to act, etc. The Bank shall not unfairly place their interests above those of customers in a situation where a properly-informed customer would reasonably expect the Bank to place their interests above our own; the Bank shall live up to that expectation.
  • Circumstances may arise where an employee or family member directly or indirectly has a business interest that is in conflict with, or may conflict with, the Bank interests. In order to ensure objective decision-making within the Bank, employees must declare any potential conflicts of interest in advance to their Compliance Officer, or to supervisors or other authorized persons; they may be required to disassociate themselves from any involvement in the Bank decisions that relate to such personal conflicts.
  • Any involvement in an external activity or position, e.g., taking up a directorship, consulting position, agency, or employment outside the Bank, must not give rise to any real or apparent conflict with any customers’ interests, and must not adversely reflect the Bank or interfere with that individual’s job performance.
  • Employees are prohibited from undertaking full or part-time employment with any institutions which undertakes the same business as the Bank, may compete with the Bank, or that conflicts with the Bank interests.​