SAMPLE COE

AMALGAMATED BANK CODE OF ETHICS

Leadership letter
Code of ethics of Amalgamated bank is a document which exits in 2 forms, both online and
in hard copy form so that all employees can easily access for usage. Code of ethics has been
developed since establishment of Amalgamated bank and provide a set of values for working
ethically for bank. With the purpose of creating an ethical environment for employment and
for customers, code of ethics provide clear guidance on activities which are considered as
ethical or unethical.

Table of content
I. Introduction
II. Core values
III. Code provisions
IV. Information and resources

I. Introduction
Code of ethics is essential and mandatory for all employees working for Amalgamated bank.
It ensures good governance of Amalgamated Bank by defining in detail activities should be
done and which activities are forbidden during operational activities.
Scope of ethics is limited on Amalgamated bank only. The development of this document is
by human resource management and only regarding to human resource management area.

II. Core values

Our values are very simple and integrated:
+ Support common good
+ Be fair and equitable
+ Be passionately involved
+ Prioritize customers

III. Code provisions

1. Audit responsibilities
Audit department is responsible for internal controls practices to against conflict of interest.
Their task is to identify weaknesses in operation activities and make corrective action and
ensure their compliance with laws, regulations.

2. Management responsibilities
Managers take responsibilities to ensure compliance with guidelines that all employees are
allowed to have 5 days or more of vacation during calendar year. Besides, VPN capabilities
employees must notify information service at least 5 days before vacation period.

3. Confidentiality
Financial information is not allowed to disclosed. Amalgamated bank values financial
information as asset of our bank and require all employees to be responsible for safeguarding
disclosure of information.
Employees must avoid discuss confidential, competitors and or unreliable sources.
Employees must sustain the confidentiality of information.

4. Conflict of interest
Employees, officers, agents, attorneys, bank directors must inform themselves Federal Bank
Bribery Act regarding receipt and reporting of offers.
Acceptance or request of gifts, fees, rewards from customers or prospective customers in
return for services is forbidden except for case that it is stated exceptions or advance
approval.
Human resource department is responsible for information supplement for employees on the
first day of employment.

5. Privacy
Employees must respect and protect privacy of customers and the bank must also protect
privacy of employees.
Only Bank premiers are allowed to unlock, open or inspect any desk, locker, cabinet.
Audit Department is responsible for checking accounts.

6. Internal asset controls

All employees, officers or directors of Amalgamated bank must comply with internal control
policies which requires safeguarding of assets and proper reporting or financial information
report on disclosure of assets.

7. Misuse of bank account

Every transaction/maintenance of employees own accounts in Amalgamated bank is
forbidden. Activity includes increasing credit, card limits, waiving fees, maturity date
changing, float dates, … If employees commit one of these activities, disciplinary action will
be taken.

IV. Other information

For further information, please contact Amalgamated Human Resource Department Bank or
visit our websites.