Affiliate Transactions Policy

The primary objectives of this policy are:

• To identify transactions that are with affiliates and other related parties and that are subject to restrictions by law or regulation
• To establish appropriate guidelines and procedures to ensure that all affiliate transactions are beneficial and fair to the Bank
• To ensure that affiliate transactionsare closely monitored by management, among other things, by requiring the periodic reporting of such transactions to the Board of Directors.
• To ensure that the decision-making process with respect to affiliatetransactions remains autonomous and that the integrity of the Bank is not compromised.
• To ensure that all affiliatetransactions are consistent with safe and sound banking practices.