This Ethics Policy applies to WSFS Financial Corporation and its subsidiaries and affiliates (collectively "WSFS").
Values describe how an organization behaves under all circumstances. WSFS believes there are four fundamental values that describe our behavior. They are, "At WSFS we":
Do the right thing
Are welcoming, open and candid
Grow and improve
It is important that all Directors recognize that the first value, do the right thing, is the most fundamental in terms of defining the expectations we have of ourselves.
WSFS believes that the highest ethical principles must be used to guide us as we pursue a fair profit in the marketplace. The purpose of this Ethics Policy is to provide some specific guidance to all Directors of WSFS with respect to appropriate ethical conduct. However, this policy cannot cover every possible situation. This policy provides an overview of the corporate policies that govern the actions and working relationships of the WSFS's Directors with current and potential customers, clients, associates, competitors, vendors, government and self-regulatory agencies, the media or press, and anyone else with whom WSFS has contact. These relationships are essential to the continued success of the Company as a trusted financial services provider.
This policy can best be summarized by the simple statement that at all times Directors are expected to continually strive to "do the right thing" even when no one is watching and regardless of adversity or prosperity to WSFS.
Since there are potentially many standards for determining what "do the right thing" means, it is important that we provide a standard so that Directors will have a frame of reference. We believe having an overarching guide for behavior is important, because it fills the gaps where our legal system and even the policies enumerated below may not provide enough clear guidance. When faced with a question or challenge that doesn't have an obvious answer or solution, we encourage our Directors to reference our strategic plan and read, again, our mission and core values. Specifically, we ask that our Directors look through the lens of integrity as that is the foundation of our values. Our values serve as our Company's moral compass and guide our behavior and decisions. Over time, as we practice and demonstrate our values, our WSFS culture evolves. Through that evolution, we strengthen our organization and deepen our ethical roots. We respect and value all people, regardless
WSFS Bank Center
500 Delaware Avenue
Wilmington, Delaware 19801
of race, gender, age, national origin, religion or sexual orientation. We are one community and "one family"; we serve humbly and care deeply. Together, we stand for what is right.
WSFS will continue to grow and operate and pursue a fair profit guided by these simple principles and values. WSFS is a growing, moving, involved member of the community whose true worth is the sum total of our Associates and Directors actions and deeds. With these principles and values as our guide, they are responsible to abide by a code of conduct that clearly demonstrates that our values are not simply hollow words on a piece of paper but values by which we continue to live.
WSFS is committed to a working environment free from demeaning or harassing behavior. We will thoroughly investigate all reported incidents of harassment and will not tolerate any form of retaliation against anyone who, in good faith, reports an incident or participates as a witness in an investigation. All issues will be taken seriously and investigated, and we will take appropriate actions. Retaliation against anyone who raises a good-faith concern or reports misconduct will not be tolerated.
Conflict of Interest - Directors are expected to avoid all situations that might lead to a real, potential or apparent conflict between your self-interest and your duty as a WSFS Director. This means you are not to use your position or knowledge for personal gain or benefit or in any manner that could reflect unfavorably on WSFS. Directors will not divert WSFS opportunities to their own benefit or to the benefit of others. A conflict does not exist when the Directors' activities are based upon the ordinary course of their commercial business/banking relationships with WSFS.
Confidential Information - Confidentiality is one of the essential elements of our business. WSFS Directors will hold all WSFS corporate information including financial data and strategic information (unless this information is available to the public), customer information and Associate information including Associate health information in strict confidence and will not share it with anyone outside of WSFS, except its agents on a need-to-know basis, or to respond to any subpoena, summons, court or administrative order, or other legal process that requires compliance. Agents are companies or individuals that have been engaged by WSFS to provide various services to WSFS such as accounting services, data processing services, payroll services, legal services, consulting services, etc.
Customer and Supplier Relationships- Directors will not solicit or accept, from customers or suppliers, gifts or services of other than a nominal value. For purposes of this policy, nominal value is defined as no more than $150 per item for an outright gift of merchandise from the customer or supplier or $300 for tickets to events where the provider does not attend. At times, gifts in excess of these amounts may be provided by our customers/suppliers (refer to the Gift and Gratuities Policy for more information regarding acceptance and approval of such gifts).
WSFS Bank Center
500 Delaware Avenue
Wilmington, Delaware 19801
Inside Information - WSFS has established a Policy and Procedures for Permissible Trading by Insiders. Directors are expected to adhere to this policy. Please refer to the Policy and Procedures for Permissible trading by Insiders for complete details.
Signature - Directors are expected to take responsibility for their signatures and are permitted to sign only their own names.
Financial Responsibility - Directors are expected to maintain their financial affairs in an ethical manner and to manage their personal finances properly. Insurance and Real Estate Activities - Directors should not acquire real estate, an insurance interest or other interests from WSFS customers over whose accounts the Directors exercise direct control or purchase property, on which WSFS is foreclosing or is known to be contemplating foreclosure without prior WSFS approval. If a Board member wishes to bid on a current Bank customer's or active prospective customer's property; (whether we finance that property or not), the following steps should be taken:
The Board member must inform the Executive Committee of the Board of the relevant information and gain approval to bid on the property;
Seller and seller's representatives must be made aware that a Board member is a bidder on the property and the Board member must remove themselves from any involvement (voting, advice, counsel, etc) regarding all of this customer's banking activity for, at least, a period of one year; and
Internal Audit must complete a price/appraisal review of the purchase transaction prior to the closing of the transaction.
Purchasing of Corporate and Fiduciary Assets- No Director shall purchase any assets owned by WSFS (or being administered by WSFS) or in which WSFS has a security interest or other lien unless approval by WSFS is first obtained, fair value is paid for the assets, and the transaction is completely and properly documented on the books of WSFS .
Dealings with Auditors, Examiners and Legal Counsel- Directors will not attempt to improperly influence auditors, examiners, legal counsel or others in the course of their work.
Foreign Corrupt Practices Act - Bribes of any type are against the law and the values of WSFS. Accordingly, Directors cannot make any payment with WSFS or personal funds to customers, vendors, suppliers, governmental agencies, politicians or other parties (both foreign and domestic) to get or keep WSFS business or to influence decisions.
WSFS Bank Center
500 Delaware Avenue
Wilmington, Delaware 19801
Fraud - WSFS continues to emphasize fraud awareness to better protect our customers and WSFS. We have a zero-tolerance policy and may seek prosecution against individuals and vendors who commit fraud.
Laws, Rules and Regulations - Every Director is required to comply with all applicable federal and state laws, rules and regulations, including the requirements of the Bank Secrecy Act.
Litigation - In the event that a claim of any kind, including but not limited to litigation, is initiated or threatened against WSFS, Directors should immediately notify our Chairman, President & CEO and our Chief Legal Officer /Legal Department, even if the action or threat appears to be without merit or significance.
Media or Press - Directors are advised to consult with General Counsel or the President & CEO before making comments about WSFS's business if contacted by the media or press about any situation/release that relates to WSFS business.
Community Activities - WSFS should not be identified nor its name used in community activities without the knowledge of management.
Political Contributions - Directors are prohibited from consenting to or making political contributions or expenditures of any kind or nature directly or indirectly to any political organizations on behalf of, or in the name of WSFS, unless approved in writing by WSFS, except for WSFS PAC activities.
Use of WSFS (Company) Assets - WSFS assets are to be used exclusively in the pursuit of WSFS business. WSFS assets include equipment, facilities, supplies, services such as telephones and computer networks. Directors should not use WSFS assets for personal gain or convenience.
Stationery - Directors may not use WSFS' logo or stationery for personal purposes.
Any request for a waiver of or exception to the Directors Ethics Policy, or for any modification or amendment thereto, made by or on behalf of a Director, shall be directed to and shall only be approved by the Board. Any such waiver, exception, modification, or amendment will be promptly disclosed as required by applicable law, regulation and/or the NASDAQ listing standards.
Accounting, Auditing, Internal Control and Ethics Hotline
The Audit Committee has established an "Accounting, Auditing, Internal Control and Ethics Hotline" for the confidential receipt, retention and treatment of complaints regarding accounting, auditing, internal control or ethics matters. This "Hotline" is provided by an independent third party and is available 24 hours a day, 7 days a week. The "Hotline"
WSFS is also required to disclose any amendments to the Ethics Policy applicable to its Directors. Amendments to the Ethics Policy will be disclosed in the Corporation's Form 8-
The Ethics Policy is also available on the WSFS Bank website atwww.WSFSBank.comunder About /Investor Relations/Corporate Governance.
Administration of the Ethics Policy
Fin al rulings regarding violations of the Ethics Policy by Directors will be made by the Corporate Governance Committee other than as may be provided herein. Violations of the Ethics Policy may result in disciplinary action commensurate with the seriousness of the conduct up to, and including, asking for the Director's resignation.
Director and Management Responsibility
It is the responsibility of every Director to report any violations of this policy, as well as any violation or suspected violation of federal criminal law or any sort of suspected misconduct. Management has the additional responsibility of deterring and detecting violations of this policy. Any known or suspected reported violations of this policy by a Director or suspected act(s) of misconduct by a Director will be investigated by the Corporate Governance Committee.
All Directors are annually required to review and certify to the Corporate Governance Committee their compliance with the Ethics Policy.
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WSFS Financial Corporation published this content on 21 May 2021 and is solely responsible for the information contained therein. Distributed by Public, unedited and unaltered, on 21 May 2021 19:50:01 UTC.