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PROPOSAL FOR BANKING SERVICE <br />BLit\ KTHE h' ES 1 <br />value in a business transaction for the benefit of Bank of the West or themselves <br />(other than normal authorized compensation or permissible gifts as described <br />above). Similarly prohibited is the offering of anything of value with the intent to <br />influence or reward an officer, director, team member or agent of a financial <br />institution. These restrictions on gifts are aimed at avoiding situations in which you <br />find yourself indebted to a customer, supplier, or other party, facing a potential <br />conflict of interest, or exposed to a risk that may compromise the proper execution of <br />your employment responsibilities. These restrictions are also aimed at maintaining <br />impartiality and independence of decisions. <br />Wealth Management Personnel <br />Team members in the Wealth Management area of Bank of the West must exercise <br />particular care in handling personal investments in order to avoid any conflict with the <br />execution of orders for customers, as well as any possible misuse of material insider <br />information. <br />Personal Transactions <br />Bank of the West team members must not extend loans, accept loan payments, <br />open new accounts, issue ATM cards, accept deposits, cash checks, pay out <br />withdrawals, waive or reverse fees, or otherwise approve or process any transaction <br />for themselves, for relatives or friends, or on any account on which they are a signer <br />[Employee -Signer Accounts - See Guidelines for Ethical Conduct.] <br />In addition, you (including accounts and legal entities which you control or hold an <br />interest) and your immediate family must refrain from the following personal <br />transactions: <br />Any purchase or sale of goods or services with a customer with whom you have <br />direct professional relations, <br />Any purchase or sale of goods or services with Bank of the West <br />Any purchase or sale of goods or services that imitates, accompanies or takes place <br />alongside a transaction or service carried out by a customer or Bank of the West, <br />unless such purchases or sales relate to a public offering, relate to a team member <br />benefit program, or where the team member has obtained authorization from Bank of <br />the West. <br />Referrals to Other Financial Resources <br />Team members must not refer customers to lawyers, tax advisors, accountants, <br />financial planners or other financial resources or otherwise endorse the services <br />provided by such resources, except as authorized by Bank of the West. Team <br />members must not accept gifts, favors or payments of any kind arising from such a <br />referral. <br />Professional Conduct <br />You must conduct yourself in a professional manner at all times and not engage in or <br />facilitate any discriminatory, harassing or other inappropriate behavior directed <br />towards fellow team members, customers, suppliers or others in the context of <br />activities related to Bank of the West. Personal conflicts you may have with others <br />should not enter the workplace or affect the interests of Bank of the West. <br />10IPage <br />