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Insurance Corporation

Each depositor insured to at least $250,000 per insured bank

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Financial Institution Letters

Corporate Codes Of Conduct
Guidance on Implementing an Effective Ethics Program
October 21, 2005

Summary: The FDIC is providing the attached guidance to financial institutions to remind them of the importance of an effective internal corporate code of conduct or written ethics policy.

  • 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.

FDIC-Supervised Banks (Commercial and Savings)

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

Related Topics:
FDIC Statement of Policy – "Guidelines for Compliance with The Federal Bank Bribery Law 18 U.S.C. 215"

FDIC Statement of Policy – "Statement Concerning the Responsibilities of Bank Directors and Officers"

FIL-46-2005, dated June 1, 2005: "Guidance on Developing an Effective Pre-employment Background Screening Process"

FIL-80-2005, dated August 16, 2005: "Guidance on Implementing a Fraud Hotline"

"Corporate Codes of Conduct: Guidance on Implementing an Effective Ethics Program"

Examination Specialist Kathryn Weatherby at or (202) 898-3673

Printable Format:
FIL-105-2005 - PDF 64k (PDF Help)

FDIC Financial Institution Letters (FILs) may be accessed from the FDIC's Web site at

To receive FILs electronically, please visit

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

Last Updated 10/21/2005

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