CODE OF ETHICS
General
The purpose of this Code of Ethics is to establish certain
standards of conduct for the trustees, officers and individuals performing similar functions
for Ambler Savings Bank. The Bank expects the highest possible
ethical conduct from these individuals in order to merit and
maintain the complete confidence and trust of its customers
and the public in general, and compliance with this Code is
mandatory. The intent of this Code is to support a culture of
transparency, integrity and honesty.
This Code is intended to supplement the requirements of the
code of conduct that is applicable to all of the Bank’s
trustees, officers and employees.
Standards
Honest and Ethical Conduct
This Code requires the Bank’s trustees and officers
to exercise honest and ethical conduct, including the ethical
handling of actual or apparent conflicts of interests between
personal and professional relationships.
Conflicts of interest are prohibited as a matter of Bank
policy. A “conflict of interest” exists when an officer’s
private interest interferes or conflicts in any way (or even
appears to interfere or conflict) with the interests of the
Bank. A conflict situation can arise when an officer takes actions
or has interests that may make it difficult to perform his work
for the Bank objectively and effectively. Conflicts of interest
may also arise when a trustee or an officer, or a member of his
family, receives improper personal benefits as a result of his
position with or in the Bank, whether from a third party or from
the Bank. If a question arises as to the existence of a conflict
of interest, the trustee or officer should bring it to the prompt
attention of the Audit Committee of the Bank’s Board of Trustees.
In addition, trustees and officers are prohibited from taking
for themselves opportunities that properly belong to
the Bank or are discovered through the use of corporate property,
information or position without the consent of the Audit Committee
of the Board of Trustees. No trustee or officer may use corporate
property, information or position for improper personal gain. No
trustee or officer may compete with the Bank directly or indirectly.
Trustees and officers owe a duty to the Bank to advance the Bank’s
legitimate interests when the opportunity to do so arises.
Each trustee and officer is further expected to deal fairly with the
Bank’s customers, vendors, competitors, officers and employees. No
trustee or officer should take unfair advantage of anyone through
manipulation, concealment, abuse of privileged information, misrepresentation
of material facts or any other unfair dealing practices.
Full and Fair Disclosure
This Code requires the Bank’s trustees and officers to
promote full, fair, accurate, timely and understandable disclosure in
the reports that the Bank files in public communications. The Bank expects
its trustees and officers to take very seriously their responsibility to
provide necessary information to assure that the Bank’s public reports are
complete, fair and understandable and to provide prompt accurate answers to
any inquiry related to the Bank’s public disclosure requirements.
All of the Bank’s books, records, accounts and financial statements must
be maintained in reasonable detail, must appropriately reflect the Bank’s
transactions and must conform both to applicable legal requirements and to
the Bank’s system of internal controls. Unrecorded or “off the books” funds
or assets should not be maintained unless permitted by applicable law or
regulation. Trustees and officers must not make a deliberate misrepresentation
concerning the Bank or its business operations. No trustee or officer shall
create, or assist another in creating, a false or misleading entry on the
Bank’s books or records.
In addition, trustees and officers must make open and full disclosures to,
and have honest discussions with, the auditor of the Bank’s financial
statements. Trustees, officers, and any other persons acting under their
direction, are prohibited from taking any action to fraudulently influence,
coerce, manipulate or mislead any independent public accountant engaged to
perform audit or non-audit services for the Bank.
Compliance with Law
This Code requires the Bank’s trustees and
officers to comply with applicable governmental laws, rules and regulations.
Trustees and officers are expected to understand, respect and comply with all
of the laws, regulations, policies and procedures that apply to them in their
position within the Bank.
Reporting of Violations
This Code requires the Bank’s trustees and
officers to adhere to prompt internal reporting of violations of this Code
to appropriate persons.
Trustees or officers who suspect or discover any other trustee or officer
engaging in any illegal or unethical act have the responsibility to promptly
notify the Audit Committee of the Board of Trustees. Such communication will
be kept confidential to the extent possible. The Bank will not permit
retaliation against any employee for reports of breaches of this Code.
Accountability
This Code requires the Bank’s trustees and
officers to maintain accountability for adherence to this Code. It is the
responsibility of each trustee and officer to be familiar with this Code.
The Audit Committee of the Board of Trustees is expected to make every
reasonable effort to ensure that each trustee and officer complies with
the provisions of this Code.
Officers who violate this Code may be subject to discipline, up to and
including, but not limited to, dismissal from employment. Trustees may be
asked to resign from the Board. Any such action shall be reasonably designed
to deter wrongdoing and to promote accountability for adherence to this Code
Thank You for your Loyalty, Trust and Business!
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