The success of our business is dependent upon the trustworthiness of our team members and clients. We gain credibility by adhering to our commitments, displaying honesty and integrity, and reaching Bank goals solely through honorable conduct. Level One Bank team members are expected to adhere to the highest standards of ethical conduct in all aspects of professional business and organizational performance. Interaction with clients, other team members, outside vendors, and the community at large shall be conducted courteously, fairly, honestly and respectfully. It is further the responsibility of all Bank team members to comply with the code of conduct listed below:
- Promote activities that support and are consistent with the Bank’s goals and core values.
- Strict observance of both the letter and spirit of all applicable laws and regulatory requirements.
- Avoid conflicts between personal interests and the interests of the Bank, self-dealing, or even the appearance of such conflicts in addition to adherence to the Federal Bank Bribery law.
- Follow the policies and procedures applicable to the team member’s job functions.
- Follow best-practices for professional disciplines.
- Never engage in any harassing behavior (reference policies regarding harassment).
- The use of inappropriate language such as that prohibited by the Bank’s non-discrimination, harassment, and other policies is not acceptable in the workplace.
- Keep confidential business that is related to you and/or Bank business in accordance with the confidentiality provisions of this Handbook.
- Conduct personal affairs such that your duties and responsibilities to the Bank are not jeopardized.
- Team members may never use their position with the Bank or any of its clients for private gain, personal interests, or to benefit themselves, family members or any other individual, corporation, or business entity.
You should confer with a Manager when unsure of what to do in any given situation.
If a team member has knowledge of an obvious illegal or unethical action on the part of another team member, the team member must communicate the information to a Manager, Executive, or Human Resources Executive. These reports will be kept as confidential as possible and as appropriate under the circumstances. Failure to report knowledge of such information may reflect adversely on the team member and may result in disciplinary action, up to and including termination.
In the event a team member is uncomfortable reporting the situation to their Management Team or the Human Resources Team, Level One has entered into a partnership with EthicsPoint to provide a Whistleblower and Employee Relations Hotline (1-844-880-2601) to call. This Hotline is managed through EthicsPoint and includes an operator who will record the team member’s concern, either anonymously or not, depending on the desire of the team member. EthicsPoint also provides a web intake method www.levelonebank.ethicspoint.com for team members who would like to input their concern themselves, anonymously or not. The team member would be provided a digital code to be used to communicate with the company anonymously. This code allows for more information to be provided to the company as well as updates to the team member from the company without the team member’s identity being disclosed. All issues provided through either EthicsPoint method will be logged and tracked to resolution by Human Resources. Any claim that meets the legal definition of a Whistleblower claim will be reported to the Audit Committee of the Board for proper handling.
Individuals who believe they have been the victims of conduct prohibited by this harassment policy by a manager, team member, visitor, vendor, or other person, or who believe they have witnessed such conduct should promptly discuss their concerns with their immediate Manager, Human Resources or any other member of management, preferably in writing.
When possible, Level One Bank encourages individuals who believe they are being subjected to such conduct to promptly advise the offender that his or her behavior is unwelcome and request that it be discontinued. Often this action alone will resolve the problem. The Bank recognizes, however, that an individual may prefer to pursue the matter through complaint procedures.
Level One Bank encourages the prompt reporting of complaints or concerns so that rapid and constructive action can be taken before relationships become irreparably strained. Therefore, although no fixed reporting period has been established, early reporting and intervention have proven to be the most effective method of resolving actual or perceived incidents of harassment and are encouraged by the Bank.
Any reported allegations of harassment, discrimination or retaliation will be promptly investigated promptly and appropriate remedial action will be taken. The investigation may include individual interviews with the parties involved and, where necessary, with individuals who may have observed the alleged conduct or may have other relevant knowledge. Confidentiality will be maintained throughout the investigatory process to the extent consistent with the Bank’s need to conduct an adequate investigation and take appropriate corrective action.
Retaliation against an individual for reporting harassment or discrimination or for participating in an investigation of a claim of harassment or discrimination is a serious violation of this policy and, like harassment or discrimination itself, will subject team members to disciplinary action. Acts of retaliation should be reported immediately and will be promptly investigated and addressed.
Misconduct constituting harassment, discrimination, or retaliation will be dealt with appropriately.
If a party to a complaint does not agree with its resolution, that party may appeal to the Human Resources Executive.
Any team member who is determined to have engaged in harassment in violation of this policy will be subject to appropriate disciplinary action, up to and including termination of employment. Retaliation in any form against an individual who makes a report or who cooperates in an investigation of alleged harassment under this policy is also prohibited. Any team member who is determined to have retaliated against another will be subject to appropriate disciplinary action, up to and including termination of employment.