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 institution’s 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).
