The Bank of Southern Connecticut

The safekeeping of client information is a priority for The Bank of Southern Connecticut. We recognize and respect the importance of your personal privacy and the security of your information and are committed to treating client information responsibly.

At The Bank of Southern Connecticut our clients have access to a broad range of products and services. To deliver these products and services as effectively and conveniently as possible, it is essential that we use advanced technology to manage and maintain certain client information. Any information obtained by The Bank of Southern Connecticut from our clients will be for our purposes only, in order to evaluate requests to open accounts or issue credit. Your information helps us to provide service and manage your accounts, anticipate and meet your financial needs, protect your account against fraudulent activity and operate our business to serve you more efficiently. Personal information you provide is protected at the highest level current technology allows and will be kept confidential. The Bank of Southern Connecticut takes steps to safeguard client information via the use of advanced technology and information management to implement security, audit and control programs designed to protect the confidentiality and security of the information we collect.. The Bank of Southern Connecticut maintains physical, electronic and procedural safeguards to comply with federal standards to guard your non-public personal information. Non-public personal information is information that we obtain in connection with providing a financial product or service to you. For example, non-public personal information includes information regarding your account balance, payment history and overdraft history. Access to nonpublic, personal information is limited to Bank employees with a valid business reason for such access. Employees are educated on the importance of maintaining the confidentiality of client information. Employees who violate these standards will be subject to disciplinary measures. 

The Bank of Southern Connecticut may collect “non-public personal information” about you from the following sources:

Information we receive from you on applications or other loan and account forms,

Information about your transactions with us or others; and

Information we receive from third parties such as credit bureaus.

Additionally, The Bank of Southern Connecticut builds checks and balances into procedures; such as asking information only you would know when you call us so that we can properly identify clients. Clients can also help safeguard their personal information by taking a few simple precautions. Protect your account, PIN and client access numbers. Never share your password or disclose confidential information to unknown callers.

Financial institutions are permitted to share client information with companies and third parties under certain conditions. The Bank of Southern Connecticut may share information with outside firms or agencies that are hired to help us with any part of our business or to perform data processing. When we do share information, it is always under confidential conditions. We require these outside firms to maintain the confidentiality of your information in accordance with The Bank of Southern Connecticut’s privacy principles and to comply with applicable law. In addition, like other banks and financial institutions in the course of doing business, we sometimes exchange information with consumer reporting agencies and clearing houses. The Bank of Southern Connecticut may also share information for security reasons, however, we do not provide any client information to mailing lists, nor do we sell information for cross-selling purposes.

It is a priority for The Bank of Southern Connecticut to maintain accurate and up-to-date client information based on what our clients, credit-reporting agencies and other outside sources provide to us. If you notify us of inaccurate information or updated information, we will promptly investigate and make any necessary corrections. If you decide to close your accounts or become an inactive client, we will continue to adhere to the privacy policies and practices described in this notice.

The Bank of Southern Connecticut will not obtain personally identifying information when you visit our website unless you choose to provide such information. Additionally, The Bank of Southern Connecticut will not require you to send confidential information such as your social security number or account numbers via e-mail. If this information is needed we will ask you to provide it via telephone, mail or in person. We may enter the information you provide into our electronic database, and you may also be contacted by us for additional information.

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RESTATED CODE OF CONDUCT AND ETHICS of Southern Connecticut Bancorp, Inc. This restated Code of Conduct and Ethics (the “Code”) is adopted as a means of promoting ethical conduct among all of the directors, officers and employees of Southern Connecticut Bancorp, Inc. (the “Company”), and is intended to promote honesty in communication within the Company and from the Company to its customers, markets and shareholders. Compliance with this Code is the obligation of each director, officer and employee, and failure to do so will be considered a serious violation of Company policy subject to sanctions, including the possible dismissal of the offending individual from all Company positions depending on the nature and circumstances of the violation. 1. Compliance with Applicable Law All employees, officers and directors of the Company should respect and comply with all laws, rules and regulations of the United States, Connecticut and the towns and other jurisdictions in which the Company conducts its business. This Code of Ethics does not summarize all laws, rules and regulations applicable to the Company and its employees, officers and directors. Please consult the various policies and guidelines that the Company has issued for additional clarification, or consult your supervisor or senior management if you have additional questions. 2. Conflicts of Interests All employees, officers and directors of the Company should be scrupulous in avoiding a conflict of interest with regard to the Company’s interests. A "conflict of interest" exists whenever an individual’s private interests interfere or conflict in any way (or even appear to interfere or conflict) with the interests of the Company. A conflict situation can arise when an employee, officer or director takes actions or has interests that may make it difficult to perform his or her Company-related work objectively and effectively. A conflict of interest may also arise when an employee, officer or director (or a member of his or her family) receives a personal benefit as a result of his or her position in the Company, whether received from the Company or a third party. Loans to or doing business with employees, officers and directors and their respective family members and/or business interests may create a conflict of interest. In addition to these general guidelines, the Company maintains a Company Bribery Policy and a Regulation O Policy which, respectively, specifically restricts the acceptance of certain personal benefits by Company directors, officers and employees and restricts loans to the Company’s directors, executive officers and the related interests of these individuals. Conflicts of interest are prohibited as a matter of Company policy, except under guidelines approved by the Board of Directors (the “Board”), the Audit Committee or other appropriate committees of the Board. Conflicts of interest may not always be clear-cut; employees and officers who have a question, should consult with higher levels of management; directors should disclose any conflicts to the Board of Directors and recuse themselves from any related discussions. Any employee or officer who becomes aware of a conflict or potential conflict should bring it to the attention of a supervisor, manager or other appropriate personnel or otherwise follow the procedures described in this Code. When in doubt, disclose a potential conflict to higher levels of management and abide by any instructions you are given. It is almost always a conflict of interest for a Company employee or officer to work contemporaneously for a competitor, customer or supplier. You are not allowed to work for a competitor as a consultant or board member, without written approval from the Board of Directors. The best policy for employees and officers is to avoid any direct or indirect business connection with our customers, suppliers or competitors, except on our behalf. Directors have outside interests which may facilitate the Company’s business; however, any potentially conflicting interest must be disclosed to the Board so that the Board can make an informed decision as to whether the potential conflict is acceptable in the Company’s best interests. 3. Corporate Opportunity Employees, officers and directors owe a duty to the Company to advance its legitimate interests when the opportunity to do so arises. Employees, officers and directors are prohibited from (a) taking for themselves personally opportunities that properly belong to the Company or are discovered through the use of corporate property, information or position; (b) using corporate property, information or position for personal gain; and (c) competing with the Company. 4. Confidentiality Employees, officers and directors of the Company must maintain the confidentiality of confidential information entrusted to them by the Company or its suppliers or customers, except when disclosure is authorized by senior management, permitted as a matter of Company policy or procedure, or required by laws, regulations or legal proceedings. Employees, officers and directors should consult senior management if they believe they may have a legal obligation to disclose, and prior to the disclosure of that confidential information. Information about the Company’s customers and their accounts is per se confidential and protected by various state and federal laws. 5. Fair Dealing Each employee, officer and director should endeavor to deal fairly with the Company’s customers, suppliers, competitors, officers and employees. No one should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts or any other unfair dealing practice. 6. Protection and Proper Use of Company Assets All employees, officers and directors should protect the Company’s assets and ensure their efficient use. Theft, carelessness, and waste have a direct impact on the Company’s profitability. All Company assets should be used only for legitimate business purposes. 7. Accounting Complaints The Company’s policy is to comply with all financial reporting and accounting regulations applicable to the Company. If any employee, officer or director of the Company has concerns or complaints regarding questionable accounting or auditing matters of the Company, then he or she is encouraged to submit those concerns or complaints (anonymously, confidentially or otherwise) to the Audit Committee of the Board (which will, subject to its duties arising under applicable law, regulations and legal proceedings, treat such submissions confidentially). Such submission may be directed to the attention of the Audit Committee. 8. Reporting Any Illegal or Unethical Behavior Employees, officers and directors are encouraged to talk to supervisors, senior managers or other appropriate personnel about observed illegal or unethical behavior and, when in doubt, about the best course of action in a particular situation. Employees, officers and directors who are concerned that violations of this Code, or that other illegal or unethical conduct by employees, officers or directors of the Company, have occurred or may occur should either contact their supervisor or superiors (in the case of directors, such matter should be raised with the Board) of Directors). If they do not believe it appropriate or are not comfortable approaching their supervisors or superiors about their concerns or complaints, then they may contact either the Company’s internal auditor (liaison) or the Audit Committee of the Board of Directors of the Company. If their concerns or complaints require confidentiality, including keeping their identity anonymous, then this confidentiality will be protected, subject to applicable law, regulation or legal proceedings. 9. Company Bribery The purposes of business entertainment and gifts in a commercial setting is to create good will and sound working relationships, not to gain unfair advantage with customers. The Federal Bank Bribery Act applies to the Company’s directors, officers and employees, and the Company has adopted a Company Bribery Policy which you should understand and comply with. No gift or entertainment should be offered, given, provided or accepted by any Company employee, officer, or director, family member of the foregoing or agent unless it complies with the Company’s Company Bribery Policy. Please discuss with your supervisor or senior management any things of value offered to you that you are not certain are appropriate under the Company’s Bribery Policy. 10. Sanctity of Books and Records All of the Company’s books, records, accounts and financial statements must be maintained in reasonable detail, must appropriately reflect the Company’s transactions and must conform both to applicable legal requirements and to the Company’s system of internal controls. Unrecorded or "off the books" funds or assets should not be maintained unless permitted by applicable law or regulation. Records should always be retained or destroyed according to the Company’s records retention policies. In accordance with those policies, in the event of litigation or governmental investigation please consult your supervisor. 11. No Retaliation The Company will not permit retaliation of any kind by or on behalf of the Company and its employees, officers and directors against good faith reports or complaints of violations of this Code or other illegal or unethical conduct. 12. Public Company Reporting As a public company, it is of critical importance that the Company’s filings with the securities authorities be accurate and timely. Depending on their position with the Company, an employee, officer or director may be called upon to provide necessary information to assure that the Company’s public reports are complete, fair and understandable. The Company expects employees, officers and directors to take this responsibility very seriously and to provide prompt, accurate answers or certifications to internal inquiries related to the Company’s public disclosure requirements. 13. Amendment, Modification and Waiver This Code may be amended, modified or waived by the Board of Directors; waivers may also be granted by the Audit Committee, (subject to the disclosure and other provisions of the of the Securities and Exchange Act of 1934, and the rules there under and the applicable rules of the American Stock Exchange, Inc.). The undersigned has received, understands, and will endeavor to comply with all provisions of the Code of Conduct and Ethics. Date: __________________ ____________________________________ Signature ____________________________________ Please print name