Code of Conduct ("Code")
Alloya Corporate Federal Credit Union (“Alloya”) has an Employee Handbook describing business ethics and Policy manual outlining corporate policies applicable to all Alloya employees and employees of its wholly owned affiliated subsidiaries. Both these documents are located on Alloya’s intranet, and it is the responsibility of each employee to read and abide by the policies and standards set forth. Alloya reserves the right to revise these documents with or without notice. All employees are bound by the provisions set forth therein relating to ethical conduct, conflicts of interest and compliance with law. Each employee will receive a copy of this Code of Conduct (“Code”) annually and will receive a copy of the associated procedures (Attachment B). In addition to the requirements in the Employee Handbook, Alloya Policies and other applicable procedures, employees are subject to the following:
- Employees are responsible for full, fair, accurate, timely, and understandable disclosure in the financial reports required of Alloya. Accordingly, it is the responsibility of employees to promptly bring to the attention of the Chief Audit Executive (CAE) any material information of which they may become aware that affects the disclosures made by Alloya in its financial reports or otherwise assist in fulfilling its responsibilities as specified in Alloya’s Policy.
- Employees shall promptly bring to the attention of the CAE any information they may have concerning: (a) significant deficiencies in the design or operation of internal controls which could adversely affect Alloya’s ability to record, process, summarize and report financial data or (b) any fraud, whether or not material, that involves management or other employees who have a significant role in Alloya’s financial reporting, disclosures, or internal controls.
- Employees shall promptly bring to the attention of the CAE and/or any member of the Senior Management Team any information they may have concerning any violation of Alloya’s Employee Handbook, Policies, or related documents including any actual or apparent conflicts of interest between personal and professional relationships, involving any management or other employees who have a significant role in Alloya’s financial reporting, disclosures, or internal controls. This includes potential conflicts of interest related to internal controls, employment, Capital Markets/Investments or otherwise specified in Alloya Policies and procedures.
- Employees shall promptly bring to the attention of the CAE and/or any member of the Senior Management Team any information they may have concerning evidence of a material violation of the securities or laws, rules, or regulations applicable to Alloya and the operation of its business, by Alloya or any agent thereof, or of violation of Alloya’s Employee Handbook, Policies, related documents or of these additional procedures.
Senior Management shall determine, or designate appropriate persons to determine, appropriate actions to be taken in the event of violations of Alloya’s Employee Handbook, Policies, related documents or of these additional procedures by Employees. Such actions shall be reasonably designed to deter wrongdoing and to promote accountability for adherence with these documents. In determining what action is appropriate in a particular case, the Senior Management team or such designee shall take into account all relevant information, including the nature and severity of the violation.