First Bank Whistleblower Program
Stockholders, clients and other interested parties are welcome to contact First Banks, Inc. (the Company) by sending an email.
The Company’s Director of Internal Audit and Director of Human Resources (the Coordinators) receive all communications sent to this email address (Communications). Primary responsibility for the coordination of all Communications and related activities lies with the Coordinators. The Coordinators will individually distribute each Communication to the appropriate individuals within the Company for resolution, as appropriate. The Coordinators will document and maintain secure records of all Communications and any related activities.
In order to expedite the resolution of ordinary business matters, the Coordinators will assign each such Communication to management for resolution on behalf of the Company regarding a personal or business account or transaction, including customer service issues, or other matters (except accounting, internal accounting controls or auditing matters) as deemed appropriate (an “ordinary business matter”).
If a Communication does not involve an ordinary business matter, the Report will be forwarded, depending on the subject matter, to the appropriate director(s) or other Company official(s). In particular, if a Communication involves a complaint regarding accounting, internal accounting controls or auditing matters, the Communication may be addressed to, and will be forwarded to, the Audit Committee. The Audit Committee is comprised of independent directors. A copy of all Communications and any related activities forwarded to one or more directors, depending on the subject matter, may be sent to management to enable the Company to research and resolve the matter, if appropriate.