OVERVIEW

Citystate Savings Bank is committed to conducting business honestly, legally, and with the highest sense of integrity. Every employee of CSBI is expected at all times and in all circumstances to uphold the standard of compliant and ethical behavior. The Code of Discipline imposes a duty to all employees of CSBI to know and comply with the letter and spirit of all company policies, regulations, and requirements related to their work. While the Code neither presents a rule that answers every question nor addresses every specific situation, the same nonetheless provides guidance on everyone’s responsibilities to the company and colleagues. It is therefore each and everyone’s duty to understand the general policies and those which specifically apply to his or her area of responsibility and to conduct business accordingly. Those who supervise personnel are expected and in fact obliged to take efforts to ensure that they understood and follow company policies. All CSBI employees are expected to know that anyone who violates the Company Policies or fails to comply with the standards set forth in the Code of Discipline shall be subjected to disciplinary actions in which proper penalties, including dismissal, may be imposed.

GENERAL POLICIES

1. It is the duty and responsibility of all employees of CSBI to know, understand, and comply faithfully and strictly with, all the general and specifics policies, regulations, and directives of the company;

2. The management of the CSBI is responsible for the maintenance of discipline, the promotion of stability, job security and the fair and equal treatment of all employees. All levels of Management are therefore responsible for the maintenance of discipline.

3. It is the duty of all CSBI employees to report within forty eight (48) hours from knowledge of any known or suspected violations of Company Policy and/or commission of a crime by any CSBI employee within or outside the company premises;

GUIDELINES FOR IMPLEMENTATION

1. The Code of Discipline shall be implemented by the immediate superiors, Department Heads, Human Resources Department, and Personnel Committee, all of which are expected at all times to perform their respective roles diligently, competently, professionally, objectively, without discrimination or bias or likeliness of bias, and in the highest standards of ethical behavior;

2.In all disciplinary proceedings, the Personnel Committee shall act competently and efficiently in order to take all necessary measures to ensure a speedy and just resolution to a case, thus avoiding undue delay and waste of time and resources;

DUTY TO REPORT VIOLATIONS

The Code of Discipline imposes upon all CSBI employees the duty and responsibility to report to the Department Head, Head of HR, or any member of the Personnel Committee, all known or suspected violation of company policy, or any circumstances that the employee believes in good faith to constitute an offense punishable under the Employee Handbook, violation of company policy, rule, or regulation, commission of a crime, or violation of existing laws and government regulations. Any employee who shall deliberately, and without justifiable reason, fail to comply with the duty to report known or suspected violation(s) may himself be subjected to disciplinary action for the commission of an offense classified under Neglect of Duty (Class III) of the table of offenses.

CSBI denounces any form of retaliation against individuals who, in good faith, report suspected violations, or who cooperate in an investigation of a suspected violation reported by someone else. Any employee who may be found liable for acts constituting retaliation against a whistleblower may be held liable under Conduct and Behavior (No.10) of the table of offenses.

CONFLICT OF INTEREST

No employee is allowed to engage in any business or undertaking that directly or indirectly, is in competition with the Bank and / or its subsidiaries and affiliates, or to the performance of his respective job or work assignments.