I. PURPOSE

This Privacy Policy reaffirms the Bank's policies of respecting the confidentiality of information obtained in the course of the Bank's business and the maintenance of the Bank's reputation and avoidance of conduct which might reflect adversely on the Bank.

II. OBJECTIVE

The Bank has established this Privacy Policy to assist its employees in understanding and carrying out the Bank's mandate for the confidential treatment of customer information. The Bank's reputation for maintaining the confidentiality of information obtained during the course of the Bank's business is one of its most important assets and is determined by the conduct of its employees. At least annually, the Bank shall take appropriate measures to remind employees of the importance and contents of this Privacy Policy.

III. APPLICATION

This Privacy Policy applies to all Bank employees. The term "employee" as used in this Privacy Policy includes all directors, officers, employees, attorneys, and agents of the Bank.

IV. PRIVACY PRINCIPLES AND CONFIDENTIALITY

A. Privacy Principles

1. The Bank recognizes and respects the privacy expectations of its customers and has developed this Privacy Policy to mandate that the Bank's employees maintain the confidentiality of customer information. To provide customers who are concerned about financial privacy with an understanding of the Bank's treatment of customer information, employees shall explain to the customer that the Bank has adopted a Privacy Policy and provide the customer with a copy of the Bank's privacy principles.

2. The Bank shall collect, retain, and use information regarding its customers only where the Bank reasonably believes it would be useful (and allowed by law) to administer the Bank's business and to provide products, services, and other opportunities to its customers.

3. The Bank has established procedures to ensure that customer's information is accurate, current, and complete in accordance with reasonable commercial standards and the Bank shall correct inaccurate information in a timely manner.

4. The Bank shall limit employee access to personally identifiable information for those with a business reason for knowing such information. The Bank shall also educate and discipline its employees so that they will understand the importance of confidentiality and customer privacy.

5. The Bank has established security standards and procedures to prevent unauthorized access to customer information.

6. The Bank shall not reveal specific information about a customer's account or other personally identifiable data to unaffiliated third parties, except for the exchange of information with reputable information reporting agencies to maximize the accuracy and security of such information or in the performance of bona fide corporate due diligence, unless:

a. the information is provided to help complete a customer initiated transaction.

b. the customer requests it.

c. the disclosure is required or allowed by law (i.e., subpoena, investigation of fraudulent activity, etc.); or

d. the customer has been informed about the possibility of such disclosure for marketing or similar purposes through a prior communication and is given the opportunity to decline such disclosure.

B. Confidentiality of Customer Records and Credit Files

1. Confidentiality is a fundamental principle of the financial services business. One aspect of your work at the Bank that will be emphasized and again is the confidentiality nature of our business and the trust that we must never breach. As such, all Bank work is confidential.

2. In your work you will learn many things about many people that must remain confidential. You must never reveal any information about the Bank's customers to friends, relatives, or other employees, unless your work requires it. The principle of privacy of customer information applies with equal force to both informal and formal communications. Discussing a customer's business or finances is not only bad business but it may also subject the employee and the Bank to fines and civil liability.

3. Financial and personal information about customers is entitled to the same respect and care as funds or physical property. To protect the privacy rights of its customer, the Bank will in accordance with the Bank's privacy principles stated in Section IV A above:

a.Collect and maintain only that information which is specifically necessary to serve customer accounts properly and render fair credit judgment.

b. Maintain in a secure manner all files and record keeping systems which contain information on customers.

c. Divulge no personal or credit information to third parties except with proper customer authorization, or pursuant to proper legal process or regulation, or for purposes of extension of credit by other lenders.

4. In the event of subpoena or other legal process requiring the Bank to disclose customer information, employees shall comply with the Right to Financial Privacy Act, 12 U.S.C. 401, et seq, and the procedures below will be implemented:

a.Employee Procedure

1.-Do not tell any other employee when you receive a request or demand for information about a customer or a customer's account with the Bank. If an employee other than the designated officer in Section IV B 4 b of this Privacy Policy is served with a subpoena or request for information, such employee shall immediately deliver the subpoena or request to the designated officer without divulging its contents to any person.

2. -If the request or demand is from a state or federal government agency (including the IRS), refer the matter to the designated officer in Section IV B4 b of this Privacy Policy.

3. -If the request or demand is from another bank, do not respond to the request, but rather transfer the request to the officer in charge of the account.

4.-If the request or demand is from other than a state or federal government agency or another bank, advise the requestor that all information about the Bank's customers is confidential and that the Bank will not acknowledge whether or not the person about whom the request is made is a customer of the Bank. The employee should then notify the designated officer in Section IV B 4 b of this Privacy Policy of such request or demand.

b.Designated Officer Procedure

All requests or demands for customer information other than that required for bank examinations and required reports should be referred to Richard Avant. When a subpoena is served on the Bank, the designated officer shall immediately contact the Bank's legal counsel for advise. The designated officer shall follow the Bank's procedures for responding to requests for information from a governmental or judicial body as described in Exhibit A hereto.

5. Internally, customer information should be utilized only for the business purpose for which it was given and restricted within the Bank to those who need to know. Confidential information concerning customers and clients must never be exchanged between employees performing fiduciary or investment management services and those engaged in rendering commercial banking services such as credit. The primary purpose is to prevent trust and investment officers from making investment decisions based upon confidential information received from the commercial side of the Bank.