The UBSI Code of Business Conduct and Ethics is approved annually by the Board of Directors and is available here. The Board of Directors determines or appoints a designee to take appropriate action in the event of a code violation. The Code outlines that United employees, management, and Directors must comply with the Federal Bank Bribery Statute, which makes it a crime to seek or accept gifts, or anything of value, from any person with the intention to influence or reward the employee in connection with the business transaction. It also includes “Special Ethics Rules for Principal Executive Officers” in compliance with Sarbanes–Oxley Section 406. This SOX control is tested annually by United’s Internal Audit. In addition, Internal Audit reviews all operations at least once every three years, based on the assessed risk. Some of these audits, such as Corporate Governance, would include elements of business ethics and anti-corruption.
United also maintains a whistleblower policy and an anonymous “hotline” in the form of a website submission form. All items reported through the Company’s whistleblower website or reported directly to the Corporate Auditor are researched and followed through to resolution by Internal Audit, or in the case of employee fraud or losses, by Risk Management. All items are reported to the Audit and Risk Committees of the Board.
United is committed to the highest possible standards of openness, integrity, and accountability. In line with that commitment, we encourage employees and others with serious concerns about any aspect of the Company’s work to come forward and voice those concerns without fear of reprisals. The policy outlines that United will do its best to protect the identity of whistleblowers when they do not want their name to be disclosed.1 United will not tolerate harassment or victimization of those who report a concern and will do what it lawfully can to protect those employees who act in good faith.
All full-time, part-time, and temporary employees are assigned the Code of Business Conduct and Ethics policy and employee handbook – which includes an outline of ethics, anti-bribery, and whistleblower procedures -- for review upon hire and with major updates. Employees must certify that they have read these documents.