Bank of Commerce Holdings and its affiliates (Redding Bank of Commerce and Sacramento Bank of Commerce, a division of Redding Bank of Commerce) (collectively, "the Company") are judged by the collective and individual performance of their directors, officers, and employees. We recognize that our first duty to our customers, shareholders, and to the public is to act in all matters in a manner that merits public trust and confidence. This policy is the tone at the top.

Due to the increased number of financial institution failures resulting from self-dealing, fraud and misconduct of directors, management, and employees, the Board of Directors of the Company intends to hold its employees and directors to this strict code of conduct and to require reporting of conflicts of interest. Individuals associated with the Company have a primary responsibility to uphold its standards.

Any individual violating this code of conduct is subject to appropriate corrective action, which may include dismissal and, if appropriate, prosecution by the Company.

Principles

The Company's ethical principles include: honesty and integrity, fairness, quality, people, and responsibility. All personnel shall act in accordance with these principles and shall encourage others within the Company to adhere to them.

Company Code of Conduct

The Company and its employees must, at all times, comply with all applicable laws and regulations. The Company will not condone the activities of employees who achieve results through violation of the law or unethical business dealings. This includes any payments for illegal acts, indirect contributions, rebates and bribery. The Company does not permit any activity that fails to stand the closest possible public scrutiny.

All business conduct should be well above the minimum standards required by law. Accordingly, employees must ensure that their actions cannot be interpreted as being, in any way, in contravention of the laws and regulations governing the Company’s operations. Employees uncertain about the application or interpretation of any legal requirements should refer the matter to their supervisor.