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Financial Institution Letter

Corporate Codes Of Conduct Guidance on Implementing an Effective Ethics Program

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 


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 17 th Street, NW, Room 100, Washington, DC 20434 (1-877-275-3342 or (703) 562-2200). 

Additional 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"
Last Updated: October 21, 2005