Code of Conduct

Corporate Code of Conduct

It is the policy of First Citizens National Bank to prohibit its officers and employees from engaging in any activity or practice in conflict with the interest of a customer or of the Bank. Even the appearance of such a conflict should be avoided. Each officer, employee or director of First Citizens National Bank is required to certify that he/she has personally reviewed the code of conduct and that he/she is fully in compliance. Each employee shall review the Code of Conduct paying special attention to the following:

Confidential Information

It is the policy of First Citizens National Bank that Directors, Principal Shareholders, Officers and Employees shall keep in strict confidence all information received by them regarding the affairs of customers and Bank business.

Information relating to account balances, the financial condition of a customer, and anticipated changes in the management or conduct of the affairs of a business must be held in strict confidence.

Acceptance of Gifts, Fees, Legacies, and Loans

It is the Policy of First Citizens National Bank to prohibit Directors, Officers, Employees, or Bank legal counsel from soliciting for themselves or for a third party anything of value from anyone in return for any business, service or confidential information of the bank and from accepting anything of value other than bona fide salary, wages, and fees from anyone in connection with the business of the bank either before or after a transaction is discussed or consummated. The policy states the limited circumstances in which the acceptance of gifts, by Directors, Officers, and Employees from customers or suppliers of the bank is permitted.

Political Activities

Any officer or employee desiring to run for an elective political office or to accept an appointment to a federal, state, or local government office, must secure the approval of the CEO to his or her becoming a candidate or accepting an appointment. Each employee and officer must abide by the Code of Conduct Policy concerning political offices.

Purchase or Sale of Securities

Officers and Employees are prohibited from acting upon material inside information prior to public disclosure through the purchase of such securities for their own accounts or for fiduciary or agency accounts, and for divulging such information or others except as required by Bank business.

Code of Ethics for Financial Professionals

This First Citizens Code of Ethics for Financial Professionals applies to the principal executive officer of First Citizens and its reporting subsidiaries and all professionals serving in a finance, accounting, treasury, tax or investor relations role. First Citizens expects all of its employees to act in accordance with the highest standards of personal and professional integrity in all aspects of their activities, to comply with all applicable laws, rules and regulations, and to deter wrongdoing and abide by the First Citizens Code of Conduct and other policies and procedures adopted by First Citizens that govern the conduct of its employees. This Code of Ethics is intended to supplement the First Citizens Code of Conduct.

Employees agree to:

• Engage in and promote honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships:
• Avoid conflicts of interest and to disclose to the Auditor or an Executive Officer of First Citizens any material transaction or relationship that reasonably could be expected to give rise to such a conflict.
• Take all reasonable measures to protect confidentiality of non-public information about First Citizens or its subsidiaries and their customers obtained or created in connection with your activities and to prevent the unauthorized disclosure of such information unless required by applicable law or regulation or legal or regulatory process.
• Produce full, fair accurate, timely and understandable disclosure in reports and documents that First Citizens or its subsidiaries files with, or submits to, the Securities and Exchange Commission and other regulators and in other public communications made by First Citizens or its subsidiaries.
• Comply with applicable governmental laws, rules and regulations, as well as the rules and regulations of self-regulatory organizations of which First Citizens or its subsidiaries is a member; and
• Promptly report any possible violation of this Code of Ethics to the Auditor or an Executive Officer of First Citizens or any of the parties or channels listed in the First Citizens Code of Conduct.

You are prohibited from directly or indirectly taking any action to fraudulently influence, coerce, manipulate or mislead First Citizens or its subsidiaries' independent public auditors for the purpose of rendering the financial statement of First Citizens or its subsidiaries misleading.

You understand that you will be held accountable for your adherence to this Code of Ethics. Your failure to observe the terms of this Code of Ethics may result in disciplinary action, up to and including termination of employment. Violations of this Code of Ethics may also constitute violations of law and may result in civil and criminal penalties for you, your supervisor and/or First Citizens.

If you have any questions regarding the best course of action in a particular situation, you should promptly contact the Auditor or an Executive Officer. You may choose to remain anonymous in reporting any possible violation of this Code of Ethics.