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Financial Institution Letters

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


Summary: 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.

Highlights:
  • 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 institutionís 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.

Distribution:
FDIC-Supervised Banks (Commercial and Savings)

Suggested Routing:
Chief Executive Officer
Compliance Officer
Internal Auditor
Fraud Prevention
Personnel/Human Resources
Legal Counsel

Related Topics:
FDIC Statement of Policy – "Guidelines for Compliance with The Federal Bank Bribery Law 18 U.S.C. 215"

FDIC Statement of Policy – "Statement Concerning the Responsibilities of Bank Directors and Officers"

FIL-46-2005, dated June 1, 2005: "Guidance on Developing an Effective Pre-employment Background Screening Process"

FIL-80-2005, dated August 16, 2005: "Guidance on Implementing a Fraud Hotline"

Attachment:
"Corporate Codes of Conduct: Guidance on Implementing an Effective Ethics Program"

Contact:
Examination Specialist Kathryn Weatherby at kweatherby@fdic.gov or (202) 898-3673

Printable Format:
FIL-105-2005 - PDF 64k (PDF Help)

Note:
FDIC Financial Institution Letters (FILs) may be accessed from the FDIC's Web site at www.fdic.gov/news/news/financial/2005/index.html.

To receive FILs electronically, please visit http://www.fdic.gov/about/subscriptions/fil.html.

Paper copies of FDIC FILs may be obtained through the FDIC's Public Information Center, 801 17th Street, NW, Room 100, Washington, DC 20434 (1-877-275-3342 or (703) 562-2200).


Last Updated 10/21/2005 communications@fdic.gov