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#307747 - 01/24/05 09:59 PM Bank Bribery and conflicts of interest
Anonymous
Unregistered

Is there an annual requirement that all employees read and sign a statement that they understand the Bank Bribery and Conflict of Interest Policy and will abide by it?

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Audit
#307748 - 01/25/05 04:57 PM Re: Bank Bribery and conflicts of interest
Anonymous
Unregistered

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.

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#307749 - 01/25/05 05:25 PM Re: Bank Bribery and conflicts of interest
Tennismom Offline
Platinum Poster
Tennismom
Joined: Jan 2004
Posts: 778
Check your board approved policies. These policies may dictate the annual certification of code of conduct.

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