We're not sure what you mean by "enforceable", but I doubt that a criminal court would entertain prosecution for a code of conduct violation, unless there was a violation of some local, state, or federal law. On the other hand, Business Codes of Conduct have definitely been used in terms of official policy for financial services companies, and they have formed the basis of civil actions in large scale violations. Frankly, we'd be surprised if a bank didn't have some form of a Code of Conduct policy. The key is to publish an official Code of Conduct policy, and have every employee (and in most cases vendors and contractors) acknowledge in writing the receipt and understanding of that policy. Once a signature is obtained, it would most likely be viewed in the context of contract law, which is "enforceable" through a progressive discipline program up to and including termination. For sample programs, we suggest that you conduct an internet search for "Business Code of Ethics for Banks".
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