PURPOSE & SCOPE
As a community bank with a long history of timeless values, Schuyler Savings Bank has developed a Code of Ethics that sets forth the guiding principles of ethical business behavior and personal conduct by which we operate. The Code is intended to safeguard the Bank’s tradition of strong moral, ethical and social standards of conduct and applies to all of the directors, officers and employees of the Bank.

INTRODUCTION
A bank, as a business built upon public trust and confidence, depends upon favorable perception of the conduct of its business by customers, Federal and State regulators, and others, both in the business and general communities. Therefore, any individual connected with Schuyler Savings Bank must assure that no one observing his or her actions would have reason to believe that even the slightest irregularity in conduct exists or could be implied.

To this end, this policy will address six general areas:

A. Conflicts of Interest
B. Confidentiality
C. Receipt of Gifts
D. Outside Activities and Personal Finances
E. Protection and Proper Use of Bank Property
F. Fair Dealing

GUIDELINES

A. Conflicts of Interest

1. A “Conflict of Interest” occurs when a director’s, officer’s or employee’s private interest interferes in any way with the interests of the Bank. You are expected to avoid all situations that might lead to a real or apparent conflict between your self-interest and your duties and responsibilities as an employee, officer or director of the Bank. Any position or interest, financial or otherwise, which could conflict with your performance as an employee, officer or director of the Bank, or which affects or could reasonably be expected to affect your independence or judgment concerning transactions between the Bank, its customers, suppliers or competitors, or otherwise reflects negatively on the Bank would be considered a conflict of interest.
   
   No director, officer or employee shall represent the Bank in any transaction with respect to which he or she has any material connection or substantial financial interest. Without limiting the scope of the term, a material connection includes the involvement of any family member or close personal friend. “Family member” includes spouse, son, daughter, parent, sister, brother, grandparent, grandchild, aunt, uncle, niece, nephew, cousin, father-in-law, mother-in-law, sister-in-law, brother-in-law or any other members of a household who are not otherwise included in this list of relatives. The transactions covered by this rule include, but are not limited to, approval of Bank overdrafts, authorizing or accepting checks on uncollected funds, waiving Bank charges or other nominal fees, making loans, waiving financial statements or similar activities.
   
   As an officer or employee of the Bank, you should not personally act as an executor, trustee, or guardian of an estate or trust of a customer unless the customer is a relative.
   
   
2. It is the policy of Schuyler Savings Bank that individuals shall not be appointed to any full-time, part-time or temporary position which would create a supervisor/employee relationship between two individuals who are related by blood, marriage or law. Nor may any member of the board of directors be of a relationship to any officer or employee of the Bank which violates this policy. In the event of marriage between employees creating a relationship which violates this policy, one of the persons affected must leave the employment of the Bank by the end of the fiscal year or within six months from the date the relationship was established, whichever is a greater period.

The degrees of relationship included in the above restrictions are as follows:

By Blood: Parent, child, grandparent, grandchild, brother, sister, uncle, aunt, nephew, niece, first cousin.

By Marriage: Husband, wife, stepparent, stepchild, father-in-law, mother-in-law, sister-in-law, brother-in-law, daughter-in-law, son-in-law, half-sister, half-brother, uncle, aunt, nephew, niece.

By Law: Guardianship relationships, adoptive parent/child relationships.

In the appointment and selection of new employees, the Bank adheres to this Anti-Nepotism Policy. All current supervisors/employee relationships established prior to June 30, 2005 will not be affected by the Policy so long as they remain in present assignments.

B. Confidentiality

1. As a director, officer or employee of the Bank you are trusted with confidential information and must maintain the confidentiality of such information.
2. Confidential information acquired through the course of employment, about the Bank and its customers and suppliers, is to be used solely for banking purposes and not as a basis for furthering a private interest, a means of making a profit, or any other reason.
3. No staff member may disclose confidential information of one customer to another customer or to any other outside party including family and friend, except when required by laws, regulations or legal proceedings. Disclosure to other Bank employees should be kept to a minimum on a need-to-know basis and in accordance with respective Bank policy and procedures.
4. It is improper for a Bank director, officer or employee to invest in a customer’s business or enable others to do so as a result of material inside information.

C. Receipt of Gifts

1. Federal Bank Bribery Law (18 U.S.C. 215) prohibits Bank directors, officers or employees from (1) soliciting for themselves or for a third party (other than the Bank itself) anything of value from anyone in return for any business, service or confidential information of the Bank, and (2) accepting anything of value (other than a bona fide salary, wage or fee) from anyone in connection with the business or the Bank, either before or after a transaction is completed.

There are certain exceptions to this rule:

1. You may accept gratuities, amenities or favors based on obvious family or personal relationships (such as those between the parents, children or spouse of a Bank directors, officer or employee) where the circumstances make it clear that it is those relationships rather than the business of the Bank concerned which are the motivating factors;
2. You may accept meals, refreshments, entertainment, accommodations or travel arrangements, all of a reasonable value, in the course of a meeting or other occasion, the purpose of which is to hold bona fide business discussions or to foster better business relations, provided that the expense would be paid for by the Bank as a reasonable business expense if not paid for by another party (such reimbursement shall not exceed $100.00). Reimbursement of expenses above the $100.00 limit must be approved by the President/CEO prior to acceptance. Receipt by the President/CEO of reimbursement above the $100.00 limit must be approved by the Board;
3. You may accept loans from other banks or financial institutions on customary terms to finance property and usual activities such as home mortgage loans, except where prohibited by law;
4. You may accept advertising or promotional material of nominal value, such as pens, pencils, notepads, key chains, calendars and similar items;
5. You may accept discounts or rebates on merchandise or services that do not exceed those available to other customers;
6. You may accept gifts of reasonable value that are related to commonly recognized events or occasions, such as a promotion, new job, wedding, retirement, holiday or birthday; and
7. You may accept civic, charitable, educational, or religious organization awards for recognition of service and accomplishment.

There may be other circumstances not identified in Paragraphs (a) through (g) under which a Bank director, officer or employee may accept something of value in connection with Bank business. However, approval from the President/CEO must be obtained in advance, based upon a full written disclosure of all relevant facts, and in accordance with the Bank Bribery Statute.

2. If a Bank director, officer or employee is offered or has received something of value from a customer beyond what is authorized above; or has a potential conflict of interest, including those in which he or she has been inadvertently placed due to either business or personal relationships with customers, suppliers, business associates or competitors of the Bank, he or she must disclose that fact to the President/CEO. The Bank will keep contemporaneous written reports of such disclosures.

3. As director, officer and employee of the Bank, you may not do indirectly what you are prohibited from doing directly. For example, you may not arrange to have a member of your family accept a gift from a customer that would not otherwise be allowable for you to accept.

D. Outside Activities

1. Directors and Officers
   Acceptance of outside employment and participation in the affairs of an outside organization must be reported to the President and disclosed annually as required by State law. Specific types of outside activities that may raise conflict of interest issues include:
   1. Serving as a director or officer for another financial service business (Management Interlocks.)
   2. Employment by a company that is competitive with the Bank.
   3. Preparation of an audit of statements to be presented to the Bank to secure a loan.
      
   4. Rendering investment counsel based on information, reports, or analyses prepared for or by the Bank.
      
   5. Performing a service that the Bank itself could perform.
      
   6. Employment by a company that provides goods or services to the Bank.
      
      
2. Staff/Employees
   Employees who are not officers or directors may be employed outside of the Bank, provided the employment is disclosed to that employee’s supervisor, and does not interfere with his or her work for the Bank. Employees may not work for another financial institution.
   
   
3. Political Activities and Contributions
   Officers, directors and employees are encouraged to support the political party and candidate of their choice. Directors, officers and employees must not, however, make gifts or contributions in the name of the Bank to any political committee, candidate or party. The Bank does not offer or allow the use of its facilities, equipment or personnel in connection with any federal, state or local election campaign.
   
   
4. Personal Finances and Borrowing
   An officer, director or employee should maintain a sound personal financial condition. Failure to do so may only create a distraction and may lead to a compromise of the Code of Ethics. Personal finances, if handled improperly, can undermine impartiality, credibility and judgment.

E. Protection and Proper Use of Bank Property

1. Embezzlement, Theft, Misapplication of Funds, Fraudulent Transactions
   Misappropriation or improper use of corporate or banking funds or property or false entry to records by employees or others will be, in accordance with banking regulations, reported to federal authorities for investigation, possible prosecution and potential imprisonment if convicted.
2. Use of Bank Property for Non-Bank Purposes
   All directors, officers and employees should protect the Bank’s property and assets and ensure their efficient and proper use. All Bank assets should be used for legitimate business purposes. For example: Bank stationery may not be used for personal non-job-related purposes.

F. Fair Dealing
The Bank seeks to outperform its competition fairly and honestly through superior performance and never through unethical or illegal practices. Stealing proprietary information, possessing or utilizing trade secret information that was obtained without the owner’s consent or inducing such disclosure by past or present employees of other companies is prohibited.

Each officer, director or employee should undertake to deal fairly with the Bank’s customers, suppliers, competitors and fellow employees. Additionally, no one should take advantage of another through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, discrimination or any other unfair-dealing practices.

The Bank will ensure that the content and impact of any advertising in any type of media made for or on behalf of the Bank shall be in accordance with social values and accepted good taste.

IMPLEMENTATION AND ADMINISTRATION

1. Reporting Illegal or Unethical Behavior
   Directors, officers and employees who suspect or know of violations of this Code of Ethics or illegal or unethical business or workplace conduct by directors, officers or employees have an obligation to contact either their supervisor or the President/CEO. If the individuals to whom such information is conveyed are not responsive, or if there is reason to believe that reporting to such individuals is inappropriate in particular cases, then the employee may contact the Board of Directors. If concerns or complaints require confidentiality, then this confidentially will be protected to the extent feasible, subject to the applicable law.
   
   
2. Non-Retaliation
   The Bank prohibits retaliation of any kind against individuals who have made good-faith reports or complaints of violations of this Code of Ethics or other known or suspected illegal or unethical conduct.
   This Code of Ethics is meant to guide each director, officer and employee in making business decisions so as not to bring discredit to the Bank or themselves. It obviously cannot cover all situations, uncertainties are bound to occur. The best approach to take when in doubt is to request a determination from a supervisor, compliance officer or the President/CEO.
   
   Subject to applicable law, a director, officer or employee who compromises or violates the law or the ethical standards contained in this Code may be subject to dismissal and/or such other action as may be permissible under the law.
   
   
3. This Code of Ethics shall be administered and monitored by the President/CEO.
   All management personnel and direct supervisors are responsible for reviewing this Code of Ethics with their subordinates each time a new edition of the Code of Ethics is published. This Code of Ethics is also available on the Bank website at www.schuylersavings.com.
   
   It is also the responsibility of the President/CEO to annually reaffirm compliance with this Code of Ethics by all directors, officers and employees, and to obtain a signed certificate that each director, officer and employee has read and understood the Code of Ethics and will comply with its provisions.

I HAVE RECEIVED AND READ A COPY OF THE “CODE OF ETHICS.” AFTER HAVING READ THE “CODE” I AFFIRM THAT:

1. I do not presently hold a position as director, officer, partner or other position in any financial business or professional enterprise except as follows:
   Name and Address of Corporation or Firm: _______________________________________________
   ___________________________________________________________________________________
   Official Capacity: ____________________________________________________________________
   Percent of Ownership or Interest: ________________________________________________________
   Income or Fees – Past 12 Months: _______________________________________________________
   Name and Address of Corporation or Firm: _______________________________________________
   ___________________________________________________________________________________
   Percent of Ownership or Interest: ________________________________________________________
   (Attach a separate memorandum if more space is needed)
   
   
2. I am not presently engaged in any other outside business activity, nor do I have any other outside employment except as follows:
   Business Activity or Employer: _________________________________________________________
   Capacity: __________________________________________________________________________
   Hours of Work: _____________________________________________________________________
   (Attach a separate memorandum if more space is needed)
   
   
3. I am not presently engaged in any not-for-profit enterprise or activity except as follows:
   Business Activity or Employer: _________________________________________________________
   Capacity: __________________________________________________________________________
   Hours of Work: _____________________________________________________________________
   (Attach a separate memorandum if more space is needed)
   
   
4. I am not now, nor have I been during the past year, in violation of any section of the “Code.”
   
   
5. I AFFIRM THAT THE ABOVE INFORMATION IS CORRECT.
   Signature: _____________________________________
   Dated: ________________________________________
   Name (Print): __________________________________
   Title: _________________________________________