Homeland Community Bank (the "Bank") believes that the business practices of its directors, officers, and employees must meet the highest ethical standards. This Code of Ethics (the "Code" or the "Policy") has been adopted so that everyone involved in the business of the Bank will know how to meet these standards. This Code has been adopted by the Board of Directors, and any person who is employed by the Bank or who serves on its Board of Directors who disregards or violates its provisions will be subject to immediate dismissal.

Understanding the needs of our customers is the single most important requirement of our employees. It is the primary duty of every employee to promote customer satisfaction and loyalty by "doing it right the first time." Every employee is "the Bank" in the minds of those customers we contact, either in person, by correspondence, or by telephone. The Bank's reputation and prestige are enhanced or diminished by the quality of each encounter. Our mission requires us to "be the best at serving our customers, one opportunity at a time."

Quality at the Bank is defined as "conformity to our customers' financial needs and expectations of products and services." We will continually try to find out what our customers expect through market surveys.

The Bank's most valuable resource is its employees. We attract and retain highly motivated people by rewarding excellent performance and by providing an environment that promotes customer orientation, enthusiasm, teamwork, and respect. Our employees are encouraged to use their own initiatives to satisfy customers, increase market share, and improve profitability. Employees' opinions and ideas are requested and expected by management.

Each employee's business and private life should reflect credit on the Bank and on fellow employees. A reputation for good moral character, ethics, and integrity is expected, and each Bank employee's reputation must remain above reproach. The Bank will not ask any employee to perform an act contrary to his or her moral standards or to any laws or regulations. It is the responsibility of each employee to conform to these high standards.

The Bank recognizes its responsibility to increase shareholder return on investment by using prudent business practices and the resources provided by its experienced-capable staff and management.