Executive Officers:Įxecutive officers include division heads, COO & President/CEO. Definitions: Insider:Įach executive officer or director and each of his or her related interest (as defined in Regulation O) is deemed to be an insider for the purpose of this policy. Recuse themselves from voting on the matter or transaction (if the insider is a director). Refrain from participating in the Board’s discussion of the matter or transaction, and,ģ. The facts known to the insider as to the matter or transaction under consideration.Ģ. The existence, nature and extent of the insiders’ interest Ģ. Disclose to the Board all material non-privileged information relevant to the Board’s decision on the matter or transaction, includingġ. Insiders must, if they have an interest in a matter or transaction before the Board of Directors:ġ. Insiders must not advance their own personal or business interest, or those of others with whom they have a personal or business relationship, at the expense of the Bank. Policy Elements Conflict of Interest Policy Statement:
Establish authority as to approval of exceptions to policy.Įstablish the authority for the President to require all insiders to submit a statement attesting to their compliance with this policy each calendar year.Įstablish the basic “Code of Ethics” to be employed by all insiders during the period for which he or she works for or represents the Bank. Set policy as to what constitutes a conflict of interest. Additionally, the policy will establish a “Code of Ethics” for all insiders. To provide the insiders of this Bank with the standards as to what is and what is not acceptable behavior with regards to conflict of interest. In order to protect that reputation, the Board has adopted this policy to ensure ESSA remains a trusted and viable entity in this community. The Board of Directors understands that ESSA Bank & Trust’s (ESSA’s) reputation for integrity and trust is determined by the conduct of its insiders.
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