Reporting Illegal or Unethical Behavior

Reporting of Violations

All Employees, Officers and Directors should report violations of laws, regulations, rules, or this Code.

  • It is the Bank's policy not to allow discipline, reprisal, intimidation or retaliation for reports of misconduct by others made in good faith by Employees, Officers and Directors.
  • All Employees, Officers and Directors are expected to cooperate in internal investigations of misconduct.

Required Reporting of Violations

Employees have a right, and at times a legal obligation, to call the Bank's attention to situations in which legal or Bank Policy violations have occurred. Failure to make such a report is a violation of this Code and may subject Employees to disciplinary action up to and including termination.

Bank Assistance

Employees, Officers and Directors are encouraged to talk to supervisors, managers or other appropriate personnel, including the Bank's Compliance Officer, General Counsel or the Chief People Officer, for circumstances including, but not limited to:

  • Observed illegal behavior;
  • Observed unethical behavior; or
  • When an Employee is in doubt about the best course of action in a particular situation

Supervisory Violators

  • If a supervisor is a violator, Employees may contact the next supervisor in the chain of command and the Bank's General Counsel.
  • If the General Counsel is the violator, Employees may contact the Bank's CEO.
  • If the CEO is the violator, Employees may contact the Bank’s General Counsel.

Anonymous Reports

As an alternative to reporting to the Officers and Employees enumerated above, Employees, Officers and Directors may anonymously report potential violations via an anonymous Compliance Hotline (Toll Free Hotline 1-800-727-3217). (See Peoples Bank website).

Potential Effects of Reporting

The following include some potential effects of reporting violations of any applicable law, rule or regulation, this Code or other Bank Policies, applied equally across the Bank, its service corporation and its subsidiaries:

  • Employees may make reports anonymously, but those who choose to identify themselves are assured that they will not suffer disciplinary or retaliatory action.
  • Upon receipt of a concern, the Bank's CEO may authorize the Compliance Officer or General Counsel to initiate an investigation and report the results of said investigation to the Bank's CEO for appropriate disciplinary action.
  • Anyone violating the Code may be subject to disciplinary action up to and including termination of employment.
  • In instances of a concern regarding an Officer or Director of the Company, the CEO shall report to the Nominating and Corporate Governance Committee.
  • The Nominating and Corporate Governance Committee shall authorize and direct an investigation of the concern and take any disciplinary action in response as they deem appropriate.
  • In special cases, the Bank may be obligated to refer violations to appropriate law enforcement officials.
  • The CEO of the Bank or the Compliance Officer must notify the Bank's Board of Directors concerning any Suspicious Activity Reports (SARs) and Other Reports and Statements filed not later than its next regularly scheduled meeting following the filing of the report (see 12 CFR 563.180).
  • Confidentiality will be maintained to the extent possible in light of the duty to fully investigate any report of improper conduct in the Bank.
Code of Business Conduct and Ethics