At PSCU Financial Services, Inc., our business is founded on vision, trust, and member confidence. We thus bear special responsibilities for high standards in our personal and professional behavior.

To meet these high standards, PSCU Financial Services has established an Ethics and Compliance Program. Under the Program, PSCU Financial Services and its staff strive to follow an ethical culture and to comply with the spirit as well as the letter of pertinent laws and regulations. When any law, regulation, or policy seems unclear or ambiguous, staff members are encouraged to seek assistance in determining procedures that are both lawful and ethical. The goal of this Code of Ethics is to make staff members aware of the responsibility they share for promoting and protecting the company's ethical culture.

Personal honesty and integrity are the highest priorities at PSCU Financial Services and require consistent and continuous attention to the following:

• Staff members do not: offer, solicit, or accept personal fees, commissions, or other forms of remuneration because of any transactions or business involving PSCU Financial Services ; solicit or accept any gifts of significant value; lavish entertainment, or other benefits to or from members of vendors/suppliers. Special care must be taken to avoid even the impression of conflict of interest by accepting benefits for themselves, members of their families, or any person, firm, or corporation doing business or seeking to do business with PSCU Financial Services or its affiliates.
• Staff members seek to identify transactions involving their families or friends and take appropriate steps to avoid any conflict of interest as well as any appearance of impropriety.
• Staff members do not make any explicit or implicit commitments regarding PSCU Financial Services, formally or informally, without proper prior authorization in accordance with existing procedures.
• Staff members at all times comply with PSCU Financial Services' operation policies, procedures, and controls, and in particular with established data security requirements. All records should reflect our transactions in a timely manner, and any errors should be corrected immediately.
• In addition, complete candor of staff with our Corporate Officers, and our internal and external auditors, is essential. Any concealment, regardless of reason, will be considered a violation of this code. Full disclosure of facts and the earliest possible identification of real or potential problems is expected of all.

Integrity At Work — Submit A Report

You may anonymously and confidentially communicate any issue or concern associated with activities that you suspect may violate PSCU Financial Services' Ethics and Compliance Program:

• Access www.ethicspoint.com
  or
• Call 1-866-384-4277

Or, if you prefer, you may contact PSCU Financial Services' Ethics and Compliance Officer at (727) 561-2227.