Corporate Codes Of Conduct Guidance on Implementing an Effective Ethics Program
FIL-105-2005 October 21, 2005
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)