Code of Business Conduct and Ethics

Introduction

EastWest Bank recognizes the fiduciary relationship of the Bank with its depositors, investors, borrowers, clients and the public in general. For EastWest Bank to discharge its fiduciary role, the Code of Discipline and Ethics serves as a guide to set standards of discipline and work ethics for its Employees in order to achieve: a) an ethics-based work environment; b) disciplined, accountable, customer-oriented and productive workforce; and c) harmonious employer-employee relation.

EastWest Bank’s Code of Discipline and Ethics outlines the Norms of Conduct expected of each Employees and sets forth acts or omissions inimical to its interests.

Responsibility of Employees

Every Employee shall [a] observe the highest degree of integrity in his professional conduct, [b] exercise extraordinary diligence in the performance of his work, and [c] know, understand and comply with the Code of Discipline and Ethics, including applicable business, operational and regulatory policies and procedures, and cooperate with the Bank in the enforcement thereof.

Responsibility to Customers

EastWest Bank recognizes its obligation to be truthful and objective in its dealings with its customers. While the Bank is entitled to employ all fair and honest means to promote its products and services, it shall not, however, knowingly make false representations to customers.

Trust and Confidence

EastWest Bank recognizes that its business is built on public trust from the public. As such, its employees are rigorously screened to ensure that they are worthy of the trust and confidence reposed upon them by the Bank. Its Employees are then directed to preserve and maintain the trust and confidence bestowed on him/her by the Bank when it entrusts to him/her records, documents, cash and other restricted and confidential matters pertinent to Bank operations and business. Any incident of breach committed by its Employees is never countenanced.

Bank Transactions and Records

EastWest Bank vouches the integrity and accuracy of bank records and its Employees are mandated to maintain the confidential relationship between the Bank and each of its customers. All confidential information that employees may have access to is held in strictest confidence and must neither be divulged to other parties unless with the consent of the owner of such confidential information or with order by a court of law, nor discussed outside the normal and necessary course of employment with the Bank. Confidential information may include, but is not limited to employee (preset and past) records, customer information, EastWest Bank propriety information, internal management information systems, supplier/vendor information or any information not available publicly. Likewise, those Employees, who by virtue of their responsibilities are privy to Employees’ personal data should keep in strictest confidence such information, unless required by the Management or by a court of law.

The completeness, accuracy and integrity of the bank records are maintained at all times. Any willful action, which would affect the integrity of the said records, including falsification, misrepresentation or concealment of material and or relevant facts, shall not be tolerated.

Work Performance

In furtherance of EastWest Bank’s quest to provide service excellence, it is every employee’s responsibility to discharge his/her duties and responsibilities efficiently, satisfactorily and to the best of his/her ability. EastWest Bank ensures that its employees are equipped with the knowledge, skills and proper decorum needed to discharge their respective job functions.

Attendance and Office Attire

Employees of all levels whether staff or officer must strictly observe their normal working hours and must report to work on time. It is also necessary that employees maintain professional appearance and proper business attire at all times.

Business and Personal Conduct

EastWest Bank acknowledges that the conduct of its employees reflect on its image and reputation. Its employees are strictly enjoined to conduct themselves in a manner consistent with common decency or morality. Employees should deal with their colleagues, whether superiors, peers, or subordinates, as well as with the Bank’s customers and suppliers, with courtesy and respect. Disrespect, discourtesy, insult or use of foul language towards any client, co-employee or any Bank officer will not be tolerated.

Employees are prohibited from engaging in activities that would constitute unsafe and unsound bank practice under the Manual of Regulations for Banks and such other regulations.

Employees should conduct their personal finances in such a manner as to avoid criticism, or prevent any unfavorable reflection on the Bank as a result of such behavior. This applies particularly to the payment of debts and/or settlement of obligations.

Employees are prohibited to borrow funds from individual clients or customers. While employees may borrow money from other banks or lending institutions, no favorable treatment from such institutions may be allowed.

Employees are prohibited from soliciting financial contributions from clients, suppliers and other third-party individuals and corporation for any purpose. No employee shall solicit or accept personal benefits, such as fees or commissions from any customer of the Bank, or individual or organization doing or seeking to do business with the Bank.

No employee shall accept lavish gifts or entertainment from customers, suppliers and other third party individuals and corporations for any purpose. Gifts and entertainment received on appropriate occasions that are small enough or with a nominal may be accepted subject to certain guidelines.

Outside Activities

Employees are not allowed to become directors or officials of a business organized for profit, accept part-time employment or engage in business endeavor, either formally organized or otherwise, without written approval from the Management.

Conflict of Interest

No employee may engage in any business or activity that, directly or indirectly, is in competition with the Bank or to the performance of his/her respective job or work assignment. Every employee must avoid circumstances in which his/ her personal interests, financial or otherwise, or relationships with Bank customers, conflict, or may appear to conflict with the interests of the Bank.

Health and Safety

EastWest Bank is concerned with the welfare, health and safety of its employees. Appropriate programs and guidelines are implemented to promote its employees’ health and ensure their safety.

On the other hand, every employee is responsible for the cleanliness and orderliness of his assigned equipment and immediate working area; unsafe conditions should be minimized if not totally eliminated. Employees are enjoined to report unsafe conditions and practices within the Bank premises.

Firearms, explosives and other deadly weapons that may cause undue fear and alarm in the work area are not allowed. Illegal activities like gambling and acts related to illegal or prohibited drugs are proscribed by the Bank. Employees are also strictly prohibited from bringing any form of liquor or alcoholic beverages within the Bank premises or from being under the influence of liquor, intoxicants or drugs while on the job, or while within the Bank premises. Random drug testing of its employees is implemented by the Bank.

Treatment of Bank Property

Employees are properly oriented of the proper and wise use of bank property and resources. They are responsible in taking good care of them and these should be used in the business and operations of EastWest Bank, not for personal benefit.

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