Code of Ethics

For Senior Financial Officers

General Philosophy

The honesty, integrity and sound judgment of City National Bank (the "Bank") Senior Financial Officers is fundamental to our reputation and success. While all directors, officers and employees are at all times required to adhere to the Bank’s Code of Conduct, the professional and ethical conduct of the Senior Financial Officers is essential to the proper functioning and success of the Bank.

Applicability

This Code of Ethics shall apply to the Bank’s Senior Financial Officers. "Senior Financial Officers" shall include the principal executive officer, the principal financial officer, the assistant chief financial officer, the principal accounting officer, and controller, or persons performing similar functions, including the Bank’s Chief Executive Officer, Chief Financial Officer, Chief Accounting Officer, Controller, and Assistant Chief Financial Officer. In the event of the change of an officer’s title or designation as a principal officer, or the addition of an officer to the foregoing definition, any officer performing a similar function shall be included within the scope of this Code.

Standards of Conduct

To the best of their knowledge and ability, the Senior Financial Officers shall:

  • act with honesty and integrity, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships;
  • comply with applicable governmental laws, rules and regulations;
  • promote the prompt internal reporting of violations of this Code of Ethics to the chair of the Audit & Risk Committee of the board of directors and to the appropriate person or persons identified in the Bank’s Code of Conduct;
  • respect the confidentiality of information acquired in the course of employment;
  • maintain the skills necessary and relevant to the Bank’s needs;
  • refrain from any inappropriate or undue influence of any kind in all dealings with independent auditors;
  • promote, as appropriate, contact by colleagues of the Bank with the appropriate persons under the Bank’s Special Procedures for Complaints regarding any colleague concerns regarding  questionable activity relating to accounting, accounting controls, internal controls, disclosure controls or auditing matters, and other related business conduct,  including contact with the Chair of the Audit & Risk Committee of the Board of Directors, without fear of retaliation; and 
  • proactively promote ethical and honest behavior within the Bank and its subsidiaries.

All Senior Financial Officers are expected to adhere to both the Bank’s Code of Conduct and this Code of Ethics. Any violation of this Code of Ethics will be subject to appropriate discipline, up to and including dismissal from the Bank and prosecution under the law.

The Board of Directors shall have sole and absolute discretionary authority to approve any deviation or waiver from this Code of Ethics for Senior Financial Officers.