COMPANY POLICY

Effective Date: September 30, 2026
Last Updated: September 30, 2026
Organization: First Heritage Trust Bank
Website: firstheritagetrust.com


1. PURPOSE

This Company Policy establishes the general principles, standards, responsibilities, and operating expectations applicable to First Heritage Trust Bank ("First Heritage Trust Bank," "First Heritage," "the Bank," "we," "us," or "our").

The purpose of this policy is to establish a framework for:

  • responsible business conduct;

  • customer protection;

  • information security;

  • privacy;

  • regulatory compliance;

  • ethical conduct;

  • employee responsibilities;

  • financial integrity;

  • risk management;

  • fraud prevention;

  • conflicts of interest;

  • complaint handling;

  • operational security; and

  • responsible corporate governance.

This policy should be read together with applicable laws, regulations, employment policies, product agreements, procedures, and other Bank policies.


2. COMPANY PRINCIPLES

First Heritage Trust Bank is committed to conducting business according to principles of:

Integrity

We seek to conduct business honestly and responsibly.

Customer Protection

We seek to protect customer information, accounts, funds, and legitimate interests.

Security

We maintain processes designed to protect financial and information systems.

Privacy

We respect applicable privacy and data-protection requirements.

Compliance

We operate in accordance with laws, regulations, contractual obligations, and applicable regulatory requirements.

Accountability

Employees and representatives are expected to take responsibility for their actions and decisions.

Professionalism

Employees are expected to communicate and conduct themselves professionally.


3. GOVERNANCE

The Bank's management and governing bodies are responsible for establishing appropriate oversight and accountability structures.

Responsibilities may include:

  • strategic oversight;

  • risk oversight;

  • compliance oversight;

  • financial oversight;

  • cybersecurity oversight;

  • operational oversight;

  • internal controls;

  • audit functions;

  • regulatory reporting; and

  • customer-protection oversight.

Specific governance responsibilities may vary according to the Bank's legal and regulatory structure.


4. COMPLIANCE POLICY

First Heritage Trust Bank expects employees, officers, contractors, and authorized representatives to comply with applicable laws and internal requirements.

No employee is authorized to knowingly:

  • violate applicable law;

  • falsify records;

  • conceal material information;

  • circumvent required controls;

  • facilitate fraudulent activity;

  • misuse customer information; or

  • knowingly assist unlawful activity.

Employees should raise potential compliance concerns through appropriate internal channels.


5. CODE OF ETHICAL CONDUCT

Employees and representatives are expected to:

  • act honestly;

  • protect confidential information;

  • avoid conflicts of interest;

  • maintain accurate records;

  • treat customers respectfully;

  • comply with applicable laws;

  • protect Bank property;

  • avoid unauthorized use of systems;

  • report suspected misconduct; and

  • perform their responsibilities professionally.


6. ANTI-FRAUD POLICY

First Heritage Trust Bank maintains controls designed to prevent, identify, investigate, and respond to fraudulent activity.

Fraud may include:

  • identity theft;

  • unauthorized transactions;

  • account takeover;

  • document fraud;

  • payment fraud;

  • internal theft;

  • false applications;

  • manipulation of records;

  • phishing;

  • social engineering;

  • cybercrime; and

  • other deceptive activity.

Suspected fraud may be investigated and reported to appropriate parties where required or permitted by law.


7. ANTI-MONEY-LAUNDERING POLICY

The Bank maintains procedures designed to comply with applicable anti-money-laundering and counter-terrorist-financing requirements.

Depending on applicable law, procedures may include:

  • customer identification;

  • customer due diligence;

  • beneficial ownership verification;

  • transaction monitoring;

  • sanctions screening;

  • suspicious activity monitoring;

  • recordkeeping;

  • employee training; and

  • regulatory reporting.

Employees must not intentionally assist in circumventing these controls.


8. SANCTIONS COMPLIANCE

The Bank may maintain controls designed to identify and prevent transactions involving prohibited persons, organizations, jurisdictions, or activities where required by applicable law.

Transactions may be delayed, rejected, blocked, or reviewed when required or permitted.


9. CUSTOMER PROTECTION POLICY

First Heritage Trust Bank seeks to treat customers fairly and respectfully.

Employees should:

  • provide accurate information;

  • avoid misleading statements;

  • explain applicable requirements;

  • protect confidential information;

  • process requests appropriately;

  • escalate complaints;

  • avoid discriminatory conduct prohibited by law; and

  • comply with applicable consumer-protection requirements.


10. PRIVACY AND CONFIDENTIALITY POLICY

Employees may only access customer information when authorized and when access is necessary for legitimate business purposes.

Employees must not:

  • browse customer accounts without authorization;

  • disclose customer information improperly;

  • share credentials;

  • copy information unnecessarily;

  • use customer information for personal purposes; or

  • disclose confidential information to unauthorized persons.

Violations may result in disciplinary action and, where applicable, legal consequences.


11. INFORMATION SECURITY POLICY

The Bank maintains information-security controls designed to protect:

  • customer information;

  • account systems;

  • payment systems;

  • internal systems;

  • employee information;

  • business information; and

  • other sensitive data.

Security controls may include:

  • authentication;

  • access controls;

  • encryption;

  • monitoring;

  • network protection;

  • vulnerability management;

  • backups;

  • incident response;

  • security testing; and

  • employee security training.


12. ACCESS CONTROL

Employees receive access to systems based on their job responsibilities.

Access should be limited to the information and systems reasonably necessary to perform assigned duties.

Employees must not attempt to access systems or information without authorization.


13. PASSWORD AND CREDENTIAL POLICY

Employees must protect passwords and authentication credentials.

Passwords must not be:

  • shared;

  • written in publicly accessible locations;

  • transmitted through unauthorized channels; or

  • reused in ways that create unnecessary security risks.

Where supported, multi-factor authentication should be used for sensitive systems.


14. DEVICE SECURITY

Bank-issued devices and systems must be used responsibly.

Employees should:

  • keep devices secured;

  • use approved software;

  • install security updates;

  • report lost or stolen devices;

  • avoid unauthorized applications;

  • protect screens from unauthorized viewing; and

  • follow Bank security procedures.


15. REMOTE WORK POLICY

Where remote work is permitted, employees must maintain appropriate security.

Remote workers should:

  • use authorized devices;

  • use approved networks or security controls;

  • protect confidential documents;

  • avoid public disclosure of customer information;

  • follow authentication requirements; and

  • report security incidents promptly.


16. RECORDKEEPING POLICY

The Bank maintains records in accordance with applicable laws, regulatory requirements, operational requirements, and internal procedures.

Records should be:

  • accurate;

  • complete;

  • appropriately secured;

  • accessible to authorized personnel; and

  • retained for the applicable period.

Employees must not intentionally falsify, destroy, conceal, or alter records improperly.


17. FINANCIAL INTEGRITY

Employees responsible for financial records, reporting, accounting, or transactions must maintain accurate records.

The Bank prohibits intentional:

  • falsification;

  • concealment;

  • manipulation;

  • unauthorized alteration;

  • misappropriation; or

  • improper accounting treatment.


18. CONFLICTS OF INTEREST

Employees must avoid situations in which personal interests improperly interfere with their professional responsibilities.

Potential conflicts may include:

  • personal financial interests;

  • outside employment;

  • relationships with vendors;

  • gifts;

  • investments;

  • business relationships;

  • personal relationships involving decision-making; and

  • other circumstances that could create an actual or apparent conflict.

Potential conflicts should be disclosed through appropriate internal channels.


19. GIFTS AND ENTERTAINMENT

Employees must not accept or provide gifts or entertainment that could improperly influence a business decision or create an inappropriate obligation.

Reasonable business courtesies may be permitted where consistent with applicable law and internal procedures.


20. ANTI-BRIBERY AND CORRUPTION

First Heritage Trust Bank prohibits bribery and improper payments.

Employees must not offer, promise, authorize, request, or accept improper benefits intended to influence a business or governmental decision.

This applies to dealings with:

  • customers;

  • vendors;

  • business partners;

  • government officials;

  • regulators;

  • agents;

  • contractors; and

  • other parties.


21. VENDOR MANAGEMENT

Third-party providers may be subject to appropriate due diligence before receiving access to Bank systems or information.

Depending on the service, vendor oversight may include:

  • security assessments;

  • contractual requirements;

  • privacy requirements;

  • service-level requirements;

  • compliance reviews;

  • access controls; and

  • ongoing monitoring.


22. CUSTOMER COMPLAINTS

The Bank seeks to provide customers with appropriate channels for raising complaints.

Complaints should be:

  1. received through an authorized channel;

  2. documented where appropriate;

  3. reviewed;

  4. investigated as necessary;

  5. escalated where appropriate; and

  6. resolved or responded to in accordance with applicable procedures and legal requirements.

Customers should not experience retaliation for raising a legitimate complaint.


23. WHISTLEBLOWER AND REPORTING POLICY

Employees should have appropriate channels to report suspected:

  • fraud;

  • corruption;

  • misconduct;

  • regulatory violations;

  • financial manipulation;

  • security violations;

  • privacy violations; or

  • other serious concerns.

Reports should be handled appropriately and, where possible and legally permitted, confidentially.

Retaliation against individuals who make protected reports in good faith is prohibited to the extent required by applicable law.


24. EMPLOYEE CONDUCT

Employees are expected to:

  • treat colleagues and customers respectfully;

  • follow applicable procedures;

  • protect Bank property;

  • maintain professional standards;

  • comply with security requirements;

  • avoid harassment and unlawful discrimination;

  • maintain confidentiality; and

  • perform assigned responsibilities responsibly.


25. WORKPLACE HARASSMENT

The Bank does not tolerate unlawful harassment.

This includes prohibited conduct based on legally protected characteristics or other conduct prohibited by applicable law.

Complaints should be reported through appropriate internal channels.


26. EQUAL OPPORTUNITY

First Heritage Trust Bank seeks to maintain employment practices consistent with applicable equal-employment and anti-discrimination laws.

Employment decisions should be based on legitimate job-related considerations and applicable requirements.


27. HEALTH AND SAFETY

The Bank seeks to maintain a safe workplace.

Employees should report workplace hazards, accidents, security concerns, or emergencies through appropriate channels.


28. BUSINESS CONTINUITY

The Bank may maintain business-continuity and disaster-recovery procedures designed to support critical operations during:

  • natural disasters;

  • cyber incidents;

  • infrastructure failures;

  • telecommunications outages;

  • power failures;

  • emergencies;

  • operational disruptions; and

  • other significant events.


29. INCIDENT RESPONSE

Potential security, privacy, operational, or financial incidents should be reported promptly.

Incident-response procedures may include:

  • identification;

  • containment;

  • investigation;

  • recovery;

  • documentation;

  • notification where required; and

  • corrective action.


30. COMMUNICATIONS POLICY

Employees representing First Heritage Trust Bank must communicate accurately and professionally.

Employees must not make unauthorized public statements concerning:

  • confidential matters;

  • customers;

  • regulatory investigations;

  • internal disputes;

  • security incidents;

  • financial information; or

  • other restricted information.


31. SOCIAL MEDIA POLICY

Employees should exercise caution when discussing First Heritage Trust Bank on social media.

Employees must not:

  • disclose confidential information;

  • publish customer information;

  • impersonate the Bank;

  • make unauthorized official statements;

  • disclose security information; or

  • represent personal statements as official Bank positions without authorization.


32. INTELLECTUAL PROPERTY

Bank intellectual property must be used only for authorized purposes.

This includes:

  • trademarks;

  • logos;

  • software;

  • documents;

  • designs;

  • databases;

  • internal procedures;

  • marketing materials; and

  • proprietary information.


33. USE OF COMPANY SYSTEMS

Bank systems are provided for authorized business purposes.

The Bank may monitor systems and network activity to the extent permitted by applicable law and internal policy.

Unauthorized use may result in disciplinary action.


34. ARTIFICIAL INTELLIGENCE AND AUTOMATED SYSTEMS

Where artificial intelligence or automated systems are used, their use should be subject to appropriate:

  • security controls;

  • privacy safeguards;

  • human oversight where necessary;

  • accuracy controls;

  • access restrictions; and

  • applicable legal requirements.

Confidential customer information must not be entered into unauthorized AI systems.


35. DATA MANAGEMENT

The Bank seeks to maintain appropriate controls over information throughout its lifecycle.

This may include:

  • collection;

  • classification;

  • storage;

  • access;

  • transmission;

  • retention;

  • archival; and

  • secure disposal.


36. THIRD-PARTY RISK

The Bank may assess third-party risks relating to:

  • cybersecurity;

  • privacy;

  • financial stability;

  • operational resilience;

  • compliance;

  • business continuity; and

  • service reliability.


37. BUSINESS ETHICS

The Bank expects business relationships to be conducted honestly.

Employees and representatives must not knowingly engage in:

  • deception;

  • fraudulent reporting;

  • unauthorized payments;

  • bribery;

  • misuse of confidential information;

  • market manipulation; or

  • other unlawful conduct.


38. REGULATORY COOPERATION

The Bank will respond appropriately to lawful requests from regulators and government authorities.

Employees must not obstruct authorized regulatory examinations or investigations.


39. TRAINING

Employees may be required to complete training relating to:

  • privacy;

  • information security;

  • fraud prevention;

  • anti-money laundering;

  • sanctions;

  • customer protection;

  • workplace conduct;

  • compliance; and

  • other relevant subjects.


40. POLICY VIOLATIONS

Violations of Bank policies may result in corrective or disciplinary action consistent with applicable law and employment arrangements.

Potential actions may include:

  • counseling;

  • additional training;

  • access restrictions;

  • formal disciplinary action;

  • suspension;

  • termination of employment or engagement; or

  • referral to appropriate authorities where required.


41. POLICY ADMINISTRATION

Management may establish procedures, standards, manuals, and guidelines necessary to implement this Company Policy.

Individual departments may maintain additional policies appropriate to their functions.


42. POLICY REVIEW

This Company Policy may be reviewed periodically to reflect:

  • changes in law;

  • regulatory requirements;

  • operational developments;

  • technology changes;

  • security risks;

  • business needs; and

  • lessons learned from incidents.


43. NO CONTRACTUAL GUARANTEE

Unless expressly stated otherwise in a written agreement, this Company Policy establishes organizational principles and standards and does not itself create a contractual guarantee of any particular product, service, employment benefit, or regulatory status.


44. GOVERNING REQUIREMENTS

Where this Company Policy conflicts with mandatory applicable law or regulation, the mandatory legal or regulatory requirement will control.

Where another Bank policy contains more specific requirements, the more specific policy may apply to the relevant activity.


45. CONTACT INFORMATION

Questions concerning this Company Policy should be directed through the appropriate First Heritage Trust Bank administrative or compliance channel.

First Heritage Trust Bank
Website: firstheritagetrust.com
Administrative Location: New York, New York, United States

A specific street address should only be published after the Bank has legitimately obtained and is authorized to use that address.


46. FINAL STATEMENT

First Heritage Trust Bank is committed to maintaining a professional, secure, responsible, and compliant organization.

Every employee, officer, contractor, and authorized representative has a role in protecting customers, protecting information, maintaining operational integrity, and supporting the lawful operation of the Bank.

© 2026 First Heritage Trust Bank. All rights reserved.

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