Highlights: 

• A corporate code of conduct or ethics policy should be implemented to provide employees, officers, directors and agents with specific guidelines on acceptable and unacceptable business practices. 
   
• The policies should cover the entire organization, including subsidiaries and specific business activities unique to an institution. 
   
• The corporate code of conduct or ethics policy should adopt provisions that explain the general prohibitions of the Federal Bank Bribery law. 
   
• Management should require bank employees, officers, directors and agents to sign a written acknowledgement of the institution’s corporate code of conduct or ethics policy, including written acknowledgement of any subsequent material changes to the code or policy. 
   
• Management should provide periodic training about its corporate code of conduct or ethics policy. 
   
• Compliance with the policies should be monitored. Violators should be subject to specific and appropriate actions to deter wrongdoing, compel accountability and promote adherence to the policy. 

Distribution: 
FDIC-Supervised Banks (Commercial and Savings) 

Suggested Routing: 
Chief Executive Officer 
Compliance Officer 
Internal Auditor 
Fraud Prevention 
Personnel/Human Resources 
Legal Counsel 

Note:

FDIC Financial Institution Letters (FILs) may be accessed from the FDIC's Web site at www.fdic.gov/news/financial-institution-letters/2005/index.html .

To receive FILs electronically, please visit http://www.fdic.gov/about/subscriptions/fil.html .

Paper copies of FDIC FILs may be obtained through the FDIC's Public Information Center, 801 17 ^th Street, NW, Room 100, Washington, DC 20434 (1-877-275-3342 or (703) 562-2200).