Sunday, January 17, 2010

UBL POLICIES



. Bank Property and Information

It is the responsibility of each of the Executive Officers and employees to protect and conserve UBSI property and use it for proper purposes.
Information that is not generally available to the public or that is considered confidential such as supplies, letterhead, as well as system and Bank related information may not be used other than for Bank business.




. Post-Employment Activities


.1 Information may not be discussed with former employees, who may contact you concerning any Bank or nonpublic customer information, which he/she participated with while employed with United.
.2 At the time employment is terminated, employees must leave all Bank documents, files, computer diskettes, reports and records containing any Bank or nonpublic information (including all copies of such information).



Disciplinary Action

.1 It is the goal of UBSI to ensure the general public has a confidence in the honesty and integrity of all staff members. Directors, Executive Officers and employees are encouraged to report violations of the Code of Conduct to Human Resources or your supervisor. A violation that involves corruption, fraud, or theft should also be reported to the Corporate Auditor. If you violate any provision of the Code of Conduct, you will be subject to disciplinary action that can include dismissal.




. Compliance With the Law

.1 Employees should be aware of the laws and regulations applicable to the Bank, including internal policies and procedures, commensurate with their position. These include, but are not limited to, the Bank Secrecy Act, the Bank Bribery Act, The Foreign Corrupt Practices Act, Federal Reserve Regulation W, Federal Reserve Regulation O, the Securities Exchange Act of 1934, the Sarbanes-Oxley Act of 2002, the Gramm-Leach-Bliley Act, the USA PATRIOT Act, the Community Reinvestment Act, the Fair Credit Reporting Act, regulations set forth by the Office of Foreign Asset Control (OFAC), Federal Fair Lending Laws, Antitrust Laws, Title VII of the Civil Rights Act, the Employee Retirement Income Security Act of 1972 (ERISA), the Age Discrimination in Employment Act, the Americans with Disabilities Act, the Family and Medical Leave Act, and the Uniform Services Employment and Reemployment Rights Act. Ongoing training is conducted to ensure our key managers are familiar with these laws and regulations and that they understand their responsibility for promoting compliance among their staff members. Additional information concerning compliance with laws, regulations, and internal policies and procedures is available upon request to our Corporate Compliance Officer.
.2 All employees and directors are strongly encouraged to assist management in its efforts to ensure his/her colleagues, staff members, superiors and directors are following the Code of Conduct. If an employee or a director observes or suspects a breach of the Code of Conduct or any law, regulation, or internal policy or procedure by another employee or director in connection with that other employee's or director's execution of his/her duties for the Bank, then the employee or director observing or suspecting that breach must report such observations and/or suspicions to management by memo, phone call, or by anonymous email through the Bank's website. Such reports are considered confidential to the extent consistent with appropriate investigation.
If an employee of United is uncertain about any aspect of compliance with the Code of Conduct, he/she is encouraged to discuss his/her concerns with his/her Manager, the Director of Human Resources, the Corporate Risk Manager, or the Corporate Auditor. An employee or director who violates or compromises the law and any employee who violates Bank policies and procedures is subject to corrective action, up to and including dismissal from employment or Directorship of the Bank, and, in some cases, may also be subject to criminal or civil proceedings under

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