According to the FDIC's GUIDELINES FOR COMPLIANCE WITH THE FEDERAL BANK BRIBERY LAW it states the following
To make effective use of these guidelines, the FDIC recommends the following additional procedures:
(a) The insured state nonmember bank should maintain a copy of any code of conduct or written policy it establishes for its bank officials, including any modifications thereof;
(b) The insured state nonmember bank should require from its bank officials an initial written acknowledgement of its code or policy plus written acknowledgement of any
{{4-30-98 p.5291}}subsequent material changes to the code or policy and the bank officials' agreement to comply therewith; and
(c) The insured state nonmember bank should maintain contemporaneous written reports of any disclosures made by its bank officials in connection with a code of conduct or written policy.
By order of the Board of Directors, November 10, 1987.
We require annual certification --- typically changes are made from year to year. Our Code of Conduct is incorporated into our employee handbook.